15.
ENVIRONMENTAL
MONITORING AND AUDIT
15.1.1
The
development of appropriate environmental monitoring and audit (EM&A)
programmes and methodologies are a vital part of the environmental management
and control of the Project. This
chapter provides an outline of the EM&A requirements for the Project,
highlighting the environmental parameters to be monitored, timing of the
monitoring work and the frequency of the monitoring and audit work. A detailed scope of work will be
provided in the EM&A Manual, prepared in accordance with Annex 21 of the
TMEIA and EPD=s EM&A Guidelines for
Development Projects in Hong Kong.
15.1.2 The broad objectives of the monitoring and audit process are:
(i) to clarify and identify sources of pollution, impact and nuisance arising from the works;
(ii) to establish a record of change associated with the implementation of a project;
(iii) to verify all or selected parameters measured are in compliance with legal and contract specifications, internal policies and standards;
(iv) to provide an early warning system for impact prevention;
(v) to provide a database of environmental parameters against which to determine any short term or long term environmental impacts;
(vi) to propose timely, cost-effective and viable solutions to actual or potential environmental issues;
(vii) to setup event and action plans and determine the degree and scope of any necessary remedial measures in case of exceedance of compliance, for which environmental monitoring forms the basis, or the recommendation of environmental controls in the event that the environmental objectives are not achieved;
(viii) to monitor
performance of the mitigation measures and to assess their effectiveness and, whenever necessary, identify any
further need for additional measures;
(ix) to
verify the EIA predicted impacts and compare the impact predictions with actual
impacts for the purpose of assessing accuracy of impact predictions in EIA;
(x) to
collate information and evidence for use in public and Government consultation;
and
(xi) to
audit the environmental performance.
15.2.1
In
accordance with the EIA, EM&A procedures are required during the design,
construction and operational phases of the project implementation only and a
summary of the requirements for each of the environmental parameters is
detailed in Table 15.1 below.
Table 15.1 Summary
of EM&A Requirements
|
Parameter |
EM&A Phase |
||
|
Design Phase EM&A
Phase |
Construction Phase |
Operational Phase |
|
|
Air Quality |
- |
U |
- |
|
Noise |
- |
U |
- |
|
Water Quality |
- |
U |
- |
|
Ecology |
U |
U |
U |
|
Landscape and Visual |
U |
U |
U |
|
Cultural Heritage |
- |
(1) |
- |
|
Hazard to Life |
U |
- |
- |
|
Fuel Spillage Risk |
U |
- |
- |
|
Fisheries |
- |
- |
- |
|
Land Contamination |
U |
- |
- |
|
Waste |
- |
U |
- |
(1) subject to the
recommendations of the Marine Archaeological Investigation
15.2.2
The
EM&A works during the design phase shall comprise an iterative audit
process of specific design elements by a suitably qualified auditor(s). This role could be filled by the
Independent Checker (Environment).
The specifications for certain risk and spill control mitigation
measures will be required to be designed during the detailed design phase of
the project. These items will
include:
¨
land
and marine spill response plan;
¨
pipeline
leak detection and automatic shut-off system;
¨
pipeline
rock armour protection;
¨
tank
high level shut-off;
¨
tank
bunding;
¨
tank
leak drainage isolation and containment system;
¨
on-site
fire fighting equipment;
¨
jetty
protection; and
¨
fuel
delivery shut off valves.
15.2.3
In
addition, other measures which will require specifications during the detailed
design will include and could require the input of specialists:
¨
dolphin
acoustic monitoring;
¨
dolphin
exclusion zone during percussive piling and dredging in the Marine Park;
¨
pre and post construction dolphin abundance monitoring;
¨
underwater noise monitoring during percussive piling;
¨
piling
acoustic decoupling methods;
¨
bubble
jacket design; and
¨
landscape
design drawings.
15.2.4
The
design audit shall be undertaken as and when the relevant design aspects are
produced and the Design Auditor will be required to prepare a Design Audit
Report at the end of the detailed design which will confirm that the
requirements of the EIA have been fully taken into account in the project
design. The Design Audit report
should be submitted to EPD, AFCD and the proponent at least. Other relevant parties should be
identified at the time of issue.
15.2.5 During the construction phase, the EM&A requirements are divided into environmental monitoring and/or project auditing in the form of site inspection and supervision. The environmental monitoring will be conducted in three distinct stages, as follows:
(i) baseline (pre-construction);
(ii) construction phase impact; and
(iii) operational phase impact.
15.2.6
Environmental
monitoring and audit for water quality during the construction phase is
recommended in order to ensure all proposed mitigation measures are implemented
and effective. Obtaining a suitable and representative
baseline data set will be critical to the whole monitoring and audit process
because it forms the standard against which environmental impacts are
assessed. Thus, baseline
monitoring for water quality will be required prior to the start of
construction. This parameter will
also be subject to audit through site supervision.
15.2.7
Site
supervision and procedures audit will be required during the construction phase to ensure the proper
handling, storage, transportation and disposal of the various waste arisings
from the project.
15.2.8
Monitoring
in the form of regular site inspections shall also be required to ensure dust
and noise levels are kept to a minimum and ecological measures in the form of
tree transplantation and establishment are being implemented and are effective. EM&A for landscape resources will
extend through the construction phase into the operational phase to ensure that
the planting/replanting has been effective.
15.2.9
The details of monitoring are discussed in the
following sections and summarised in Table 15.2 below.
Table 15.2: Framework
for Environmental Monitoring Plan
|
Monitoring |
Period |
Parameters |
Monitoring Frequency |
Responsibility |
|
Noise Dust Waste |
Baseline |
n/a |
n/a |
n/a |
|
Construction
Phase Impact |
Routine
supervision of construction works |
As per site
inspection schedule |
Environmental
Team |
|
|
Water |
Baseline |
Measurements of
suspended solids, turbidity, dissolved oxygen and pH. |
Baseline data
daily on both flood and ebb tides for at least one week before the start of
the construction. |
Environmental
Team |
|
Construction
Phase Impact |
Survey of
drainage channels in area of construction site. Measurements of suspended
solids, turbidity, dissolved oxygen and pH. |
Daily when marine
construction works are being undertaken within 1000m of the Lung Kwu Chau and
Sha Chau Marine Park. |
Environmental
Team |
|
|
Ecology |
Design |
Specifications
for: - dolphin acoustic
monitoring; - dolphin exclusion
zones during piling at jetty and dredging in Marine Park; - underwater noise
monitoring; - pre and post
construction dolphin abundance monitoring; - piling acoustic
decoupling methods; - bubble jacket
design. |
As and when
designs are produced. |
Auditor(s)
designated by the Franchisee |
|
|
|
|
|
|
|
Ecology |
Baseline |
Dolphin Abundance Monitoring |
28 days worth prior to construction |
Dolphin Specialist(s) / underwater acoustic specialist as members of
the Environmental Team) |
|
|
Construction
Phase Impact |
500m Dolphin Exclusion Zone 250m Dolphin
Exclusion Zone Dolphin Acoustic
Monitoring Post Marine Construction Dolphin Abundance Monitoring Underwater Noise
Monitoring Audit of noise
reduction measures |
During piling operations During dredging
in Marine Park First 7 days of
piling activities 28 days worth
after all marine works are completed During Percussive
Piling Once per week
during piling |
Dolphin
Specialist(s) / underwater acoustic specialist as members of the
Environmental Team) |
|
Landscape/ Visual Resources |
Design |
Detailed
landscape proposals and specifications |
As and when
designs are produced. |
Auditor(s)
designated by the Design Consultants |
|
Baseline |
Walkover tree
survey and vegetation identification. |
Once immediately
prior to construction works. |
Landscape
Architect (member of the Environmental Team) |
|
|
Construction
Phase Impact |
Survey of
protection measures for trees and landscaping. |
Twice a month
during construction works |
Landscape
Architect (members of the Environmental Team) |
|
|
Landscape/ Visual Resources |
Operational Phase
Impact |
Survey of
coverage and growth of plantings. |
Once every two
months for one year after the completion of the construction works |
Landscape
Architect (members of the Environmental Team) |
|
Hazard to Life Fuel Spill Risk Land Contamination |
Design |
Specifications
for: - land and marine
spill response plan; - pipeline leak
detection and automatic shut-off system; - pipeline rock
armour protection; - tank high level
shut-off; - tank bunding; - tank leak drainage
isolation and containment system; - on-site fire
fighting equipment; - jetty fenders;
and - fuel delivery
shut off valves. |
As and when
designs are produced. |
Auditor(s)
designated by the Design Consultants |
15.3
Baseline Monitoring
15.3.1.1
Baseline
water quality monitoring of the marine environment in the study area will be
carried out daily on both flood and ebb tides for a period of 1 week to measure
suspended solids, turbidity, dissolved oxygen and pH at all monitoring
stations.
15.3.2
Landscape/Visual Resources
15.3.2.1
Baseline
monitoring for the landscape will comprise a walkover vegetation survey of the
vegetation and trees on the site.
Representative vegetation types will be identified along with typical
species composition.
15.3.3.1
Baseline
monitoring for ecology will comprise pre marine works dolphin abundance
monitoring. This should be
undertaken in accordance with the specification prepared during the detailed
design phase and should be undertaken for a minimum period of 28 days.
15.4
Construction Phase Impact Monitoring
15.4.1
Action and Limit Levels
15.4.1.1
Monitoring
stations will be set up at representative sensitive receivers and the results
will be used to ensure compliance with determined performance criteria, based
upon specific action and limit levels. The definition of these are as follows:
C
the Action Level represents a level at
which some appropriate action will be required to prevent conditions
deteriorating to the extent that statutory or guide criteria are breached; and
C
the Limit Level represents the upper limit
permitted and is generally equivalent to the statutory levels specified in
legislation.
15.4.1.2
The
construction phase monitoring and relevant audit criteria for water quality are
highlighted below. Action plans
will be developed for use in the event of exceedances, or non conformities in
the case of ecology, landscape and visual and waste, and these will be included
in the EM&A Manual.
15.4.1.3
Action
plans and audit criteria are not relevant to the noise, air, waste and
landscape and visual EM&A.
However, the supervision methodology is highlighted below.
15.4.2.1
Daily
surveys are to be undertaken for marine water quality on both flood and ebb
tides while dredging activities are being undertaken within 1000m of the Marine
Park. The surveys should include measurements of suspended solids and dissolved
oxygen. In addition to these water quality parameters, other relevant data
shall also be measured, including monitoring location/position, time, water
depth, water temperature, salinity, pH, DO saturation, weather conditions, sea
conditions, tidal stage, and any special phenomena and work underway at the
construction site etc.
15.4.2.2
Any
noticeable change to water quality should be recorded, investigated and
remedial actions shall be undertaken to reduce impacts. The key assessment
parameters are dissolved oxygen and suspended sediment and thus Action and
Limit Levels based on the assessment criteria are identified for these. However, turbidity can also provide valuable
instantaneous information on water quality and thus an Action Limit is also
recommended for this parameter to facilitate quick responsive action in the
event of any apparent unacceptable deterioration attributable to the
works. The proposed Action and
Limit Levels are shown in Table 15.3.
Table 15.3: Action and Limit Levels for Water Quality
|
Parameters |
Action (mg/L) |
Limit (mg/L) |
|
DO in mg/L (Depth Average & Bottom) |
Depth Average 4.5 mg/L; and upstream control stations’ mean D.O. (at the same tide of the same day) Bottom 2.5 mg/L; and upstream control stations’ mean D.O. (at the same tide of the same day) |
Depth Average 4.0 mg/L; and upstream control stations’ mean D.O. (at the same tide of the same day) Bottom 2.0 mg/L; and upstream control stations’ mean D.O. (at the same tide of the same day) |
|
Suspended Solids (depth averaged) |
35 mg/L; and 130% of upstream control stations’ mean SS (at the same tide of the
same day) |
40 mg/L; and 130% of upstream control stations’ mean SS (at the same tide of the
same day) |
|
Turbidity in NTU (depth averaged) |
130% of upstream control stations’ mean Turbidity (at the same tide of
the same day) |
N/A |
Notes:
- For
DO, non-compliance of the water quality limits occurs when monitoring result is
lower than the limits.
- For
SS, non-compliance of the water quality limits occurs when monitoring result is
higher than the limits.
- All
the figures given in the table are for reference only and these may be amended
with the agreement of DEP.
- “Depth
Averaged” is calculated by taking the arithmetic mean of the in-situ parameters
readings at all three depths. For
suspended solids “depth averaged” is calculated by combining all three samples
into one mixed sample which is analysed to produce a physical arithmetic mean.
15.4.3.1
Supervision
of the construction works should be undertaken on a weekly basis during site
inspections to ensure that waste material is being properly stockpiled and
handled and that measures as recommended in the EIA are being undertaken to
minimise noise and dust. Any
malpractice should be reported and remedial measures recommended. Review of the
waste documents shall be undertaken on a weekly basis to ensure waste management is being undertaken
in accordance with the Waste Management Plan.
15.4.4.1 The landscape construction works will be closely monitored to ensure all measures specified to promote the healthy establishment of plants are undertaken fully and that any defects or omissions are rectified at the earliest opportunity and before the end of the construction period.
15.4.4.2 The protection provided to all trees identified will be monitored throughout the construction period to ensure that it is kept in a good condition. Any damage by the Contractor or by other parties to the protection of the trees will be noted for remedial action.
15.4.4.3 Operations relating to the supply of specialist plant material (including the collecting, germination and growth of plants from seed) will be monitored to ensure that plants will be available in time to be used within the construction works.
15.4.4.4 The progress of the engineering works will be regularly reviewed on site to identify the earliest opportunities for the landscape works to be undertaken.
15.4.5.1 Audit of the ecological mitigation measures recommended by the EIA to reduce noise during the piling activities for the jetty shall be undertaken once per week during active piling activity. Reference should be made to the detailed specifications prepared during the detailed design stage which will define the measures to be employed and the method of application.
15.4.5.2 In addition, The ES will be required to undertake the acoustic dolphin monitoring, establish the dolphin exclusion zone during piling and dredging in the marine park and undertake underwater noise monitoring during piling activities.
15.5
Operational Impact Monitoring
15.5.1
Post
construction monitoring is limited to monitoring landscaping to ensure the
viability of the planting/replanting.
Site inspections shall be undertaken once every 2 months for the first
year of operation.
15.6.1
In
respect of the design phase EM&A, the Consultant commissioned to undertake
the Design and Construct contract will be required to designate an auditor(s)
to undertake an environmental audit of the design of these measures in order to
ensure that the recommendations of the EIA have been fully and properly
specified. The design audit shall
be undertaken as and when the relevant design aspects are produced. The Consultant shall use suitably
qualified staff to undertake the audit requirements to the approval of the DEP
and the PlanD/LPU as appropriate.
15.6.2
During
the construction and operational phase of the project, an Environmental
Specialist (ES) is to be employed by the Contractor. He shall ensure the Contractor=s compliance with the project=s environmental performance
requirements during construction and undertake the post construction EM&A
works and his responsibilities will include field measurements, sampling,
analysis of monitoring results, reporting and auditing. The ES shall be approved by the ER and
the Director of Environmental Protection (DEP) and shall be competent and shall
have at least 7 years relevant environmental monitoring and audit experience on
projects of a similar scale and nature.
15.6.3
The ES
will require suitably qualified support staff (the Environmental Team, (ET)) to
carrying out the EM&A programme.
Both the ES and members of the ET shall be independent and shall not be
in any way connected to the Contractor=s company. Due to the specialist nature of some of the EM&A works
required for this project, the ET should comprise professionals proficient to
undertake the tasks involved.
Thus, the ET should include personnel experienced in noise and dust
mitigation, water quality monitoring, supervision of waste management,
compensatory tree planting, underwater acoustic monitoring and dolphin spotting
and supervision.
15.6.4
Accordingly,
a Registered Landscape Architect, as defined by the Landscape Architect=s Registration Board, will be
required on the ET to monitor and audit the landscaping installation works. Any
archaeological EM&A as defined by the Marine Archaeological Investigation
shall be undertaken by a suitably qualified person to the acceptability of the
AMO.
15.6.5
In
addition to the ES, an Independent Checker (Environment) (IC(E)) shall advise
the ER on environmental issues related to the project. The role of the Checker shall be
independent from the management of construction works, but the Checker shall be
empowered to audit the environmental performance of the construction activities
and operational mitigation. The
IC(E) shall have project management experience in addition to the requirements
of the ES specified in Section 15.5.2 and the appointment of the IC(E) will be
subject to the approval of the ER and the DEP. The IC(E) may require specialist support staff in order to
properly carry out his duties.
15.7.1
Deliverables
during the design phase will comprise a Design Audit Report at the end of the
detailed design which will confirm that the requirements of the EIA have been
fully taken into account in the project design. Construction and operational reporting will be in the form
of the baseline survey report and regular and summary EM&A Reports which
should be prepared in accordance with the requirements of Annex 21 of the
TMEIA. It is recommended that
EM&A Reports are issued monthly and bi-monthly for the construction and
operational stages respectively.
Further details on the contents of these reports is provided in the
EM&A Manual.
15.8.1 The recommended mitigation measures specified in this EIA report have been summarised in the Environmental Mitigation Implementation Schedules provided in Appendix B for noise, water quality, waste, ecology, landscape and visual, cultural heritage, contaminated land and fuel spill risk.