This Environmental Monitoring and Audit (EM&A) Manual ("the Manual") has been prepared by ERM-Hong Kong, Limited (ERM) on behalf of The Hong Kong and China Gas Company Limited (Towngas).  The Manual is a supplementary document of the EIA Study of the Proposed Submarine Gas Pipelines from Cheng Tou Jiao Liquefied Natural Gas Receiving Terminal, Shenzhen to Tai Po Gas Production Plant, Hong Kong (hereafter referred to as the Project).

The Manual has been prepared in accordance with the EIA Study Brief (No. ESB-087/2001) and the Technical Memorandum of the Environmental Impact Assessment Process (EIAO TM).  The purpose of the Manual is to provide information, guidance and instruction to personnel charged with environmental duties and those responsible for undertaking EM&A work during construction and operation.  It provides systematic procedures for monitoring and auditing of potential environmental impacts that may arise from the works.


1.2.1 Background to the Study

Towngas is examining the feasibility of developing a natural gas supply system from the Cheng Tou Jiao Liquefied Natural Gas Receiving Terminal (GRT), Shenzhen, People's Republic of China (PRC), to the Towngas Gas Production Plant (GPP) located in the Tai Po Industrial Estate, Hong Kong Special Administrative Region (HKSAR).  The system comprises two natural gas pipelines connecting the two sites and associated facilities consisting of a launching station at the GRT and a gas receiver station at the GPP.

Towngas operates the Towngas Network, which supplies gas to domestic, commercial and industrial consumers.  The gas (major components of which are hydrogen, methane and carbon dioxide) is produced at the Towngas GPP in the Tai Po Industrial Estate and is supplied through a network of transmission and distribution pipelines. 

Towngas proposes to install twin submarine pipelines to meet expected future demand and to supply natural gas as an alternative feedstock.  The pipelines will convey gas from the Cheng Tou Jiao GRT to the existing Towngas GPP in Tai Po.  At the outset of this study, three broad routing corridors were defined for locating the pipeline system, which involved a land route, a marine route and a combination of the two (ie land and marine route).

A desktop study was conducted to identify environmental and physical constraints, further define the route corridors and to undertake an initial environmental review and qualitative risk assessment of the three possible routes.  The purpose of the work was to identify the preferred routing corridor for analysis and further refinement as part of the EIA. 

The conclusion of the desktop study was that when considering both the potential environmental impacts and the potential risk associated with the Project, a marine route, was preferred and should be the subject of further refinement as part of the EIA.  The findings of the study were presented at a forum attended by various NGOs (1) and feedback was obtained on the preferred route for incorporation in the EIA.

On 31 October 2001, Towngas submitted an application (Project Profile No. PP-148/2001) for an EIA Study Brief under Section 5(1) of the Environmental Impact Assessment Ordinance (Cap 499)(EIAO).  The EIA Study Brief (No. ESB-087/2001) was issued on 10 December 2001 under Section 5(7) of the EIAO.

Subsequently, Towngas commissioned ERM as the Lead Environmental Consultant in association with Kvaerner E&C Singapore Pte Limited to undertake an EIA for this Project.  As part of the Study requirements, this Project specific EM&A Manual has been prepared to provide further details of the specific EM&A requirements that have been recommended during construction and operation of the Project.  In particular, the requirements for ensuring compliance with mitigation measures specified for water quality, marine ecology and landfill gas are defined.

1.2.2 The Project

 The Project constitutes a Designated Project by virtue of Item H.2 of Part I of Schedule 2 under the EIAO. 

The works that are the subject of the EIA Study include the construction and operation phases of the Project.  The key components of the Project includes the following:

i. A Gas Receiver Station (GRS) at the Tai Po Gas Production Plant within the Tai Po Industrial Estate;

ii. A gas launcher facility at the LNG Receiving Terminal (GRT) at Cheng Tou Jiao, Shenzhen; and,

iii. Twin submarine gas pipelines connecting the GRS and the launcher facility.

The gas launcher facility at the GRT at Cheng Tou Jiao, Shenzhen (item ii above) is not included in this EIA Study, as it is not covered by the EIAO due to the planned location outside of Hong Kong.  The project site for the GRS is within the Tai Po Industrial Estate and will be located within the boundary of the existing Gas Production Plant run by Towngas.  The submarine pipelines will be laid through Tolo Harbour, Tolo Channel and Mirs Bay (Figure 1.2a).  The Onshore Route is presented in Figure 1.2b.

1.2.3 Construction Programme

Once the EIA Report has been formally approved by Government, Towngas will obtain an Environmental Permit (EP) for construction of the Project.  Once the EP has been obtained the construction of the Project is scheduled to commence in the final quarter of 2004 for completion by the end of 2005.  The construction period is around 12 months for the entire construction, in which dredging, pipelaying and jetting will be conducted in sequential stages.  The tentative construction programme is presented in Figure 1.2c.  It should be noted that the timeline presents predicted timeframes for each works component. 


The construction and operational impacts resulting from the implementation of the Project are specified in the EIA Report.  The EIA Report also specifies mitigation measures that need to be implemented to ensure compliance with the required environmental criteria.  These mitigation measures and their implementation requirements are presented in the Implementation Schedule (Annex A).  The EIA recommends that environmental monitoring will be necessary to assess the effectiveness of measures implemented to mitigate potential water quality, marine ecology and landfill gas impacts during construction of the Project.  Regular environmental auditing is also recommended to ensure that potential impacts from other sources are adequately addressed through the implementation of the mitigation measures defined in this EIA Report. 

This Manual provides the EM&A requirements that have been recommended in the EIA Report in order to ensure compliance with the specified mitigation measures.  The main objectives of the EM&A programme are to:

* provide a database against which any short or long term environmental impacts of the project can be determined; 

* provide an early indication should any of the environmental control measures or practices fail to achieve the acceptable standards;

* monitor the performance of the project and the effectiveness of mitigation measures;

* verify the environmental impacts predicted in the EIA Study;

* determine project compliance with regulatory requirements, standards and government policies;

* take remedial action if unexpected problems or unacceptable impacts arise; and

* provide data against which environmental audits may be undertaken.


The scope of this EM&A programme is to:

* establish baseline water quality levels at specified locations;

* implement monitoring and inspection requirements for water quality monitoring programme;

* establish baseline levels of corals (hard and soft) at specified locations;

* implement inspection and audit requirements for marine ecology monitoring programme;

* implement monitoring and inspection requirements for landfill gas monitoring programme;

* liase with, and provide environmental advice (as requested or when otherwise necessary) to construction site staff on the comprehension and consequences of the environmental monitoring data;

* identify and resolve environmental issues and other functions as they may arise from the works;

* check and quantify the Contractor's overall environmental performance, implementation of Event and Action Plans (EAPs), and remedial actions taken to mitigate adverse environmental effects as they may arise from the works;

* conduct monthly reviews of monitored impact data as the basis for assessing compliance with the defined criteria and to ensure that necessary mitigation measures are identified and implemented, and to undertake additional ad hoc monitoring and auditing as required by special circumstances;

* evaluate and interpret all environmental monitoring data to provide an early indication should any of the environmental control measures or practices fail to achieve the acceptable standards, and to verify the environmental impacts predicted in the EIA;

* manage and liase with other individuals or parties concerning other environmental issues deemed to be relevant to the construction process;

* conduct regular site inspections of a formal or informal nature to assess:

- the level of the Contractor's general environmental awareness;

- the Contractor's implementation of the recommendations in the EIA;

- the Contractor's performance as measured by the EM&A;

- the need for specific mitigation measures to be implemented or the continued usage of those previously agreed;

- to advise the site staff of any identified potential environmental issues; and

- submit monthly EM&A reports which summarise project monitoring and auditing data, with full interpretation illustrating the acceptability or otherwise of any environmental impacts and identification or assessment of the implementation status of agreed mitigation measures.

1.4.1 Environmental Management Plan

To ensure effective implementation and reporting on compliance with the stated mitigation measures, as well as the monitoring and auditing requirements and remedial actions defined in the EIA, an appropriate contractual and supervisory framework needs to be established.  The basis of the framework within which implementation should be managed overall is through the preparation of EMPs by the Contractor(s).

An EMP is similar in nature to a quality plan and provides details of the means by which the Contractor (and all subcontractors working to the Contractor) will implement the recommended mitigation measures and achieve the environmental performance standards defined in Hong Kong environmental legislation, the contract and in the EIA documentation.  The primary reason for adopting the EMP approach is to make the Contractor aware of his environmental responsibilities and to be pro-active about the commitment to achieve the standards specified, rather than relying on the EM&A programme.

The EMP also provides opportunities for the Contractor to draw upon the strength of other institutional processes such as ISO 9000/14000 to ensure that the achievement of the required standards and fulfilment of commitments are documented.

The contractual requirement for an EMP would generally comprise appropriate extracts from (and references to) the EIA Report and EM&A Manual, and include such typical elements as the relevant statutory environmental standards, general environmental control clauses and specific environmental management clauses, as well as an outline of the scope and content of the EMP.  In drafting the documentation, due consideration should be given to the predictive nature of the EIA process and the consequent need to manage and accommodate the actual impacts arising from the construction process.  In particular, the Contractor must be placed under a clear obligation to identify and control any implications arising from changes to the working methods assumed in the EIA, or to the progress rates and other estimates made during the preliminary design phase.


1.5.1 General

The Contractor shall appoint an Environmental Team (ET) to conduct the monitoring and auditing works and to provide specialist advice on the undertaking and implementation of environmental responsibilities. 

The ET shall have previous relevant experience with managing similarly sized EM&A programmes and the Environmental Team Leader (ET Leader) shall be a recognised environmental professional, preferably with a minimum of seven years relevant experience in impact assessments and impact monitoring programmes.  

To maintain strict control of the EM&A process, Towngas shall appoint independent environmental consultants to act as an " Independent Environmental Checker" (IC(E)) to verify and validate the environmental performance of the Contractor and his Environmental Team.

1.5.2 Project Organisation

The roles and responsibilities of the various parties involved in the EM&A process are further expanded in the following sections and in Figure 1.5a.  The ET Leader shall be responsible for, and in charge of, the Environmental Team; and shall be the person responsible for executing the EM&A requirements.


Reporting to Towngas, the Contractor shall:

* work within the scope of the construction contract and other tender conditions;

* employ an ET, as necessary, to undertake monitoring, laboratory analysis and reporting of the EM&A requirements outlined in this Manual;

* provide assistance to the ET in conducting the required environmental monitoring;

* participate in the site inspections undertaken by the ET and the IC(E), as required, and undertake any corrective actions instructed by Towngas;

* provide information/advice to the ET or IC(E) regarding works activities which may contribute, or be contributing to the generation of adverse environmental conditions;

* implement measures to reduce impact where Action and Limit levels are exceeded; and

* take responsibility and strictly adhere to the guidelines of the EM&A programme and complementary protocols developed by their project staff.

Towngas or Towngas's Representative

Towngas or Towngas's Representative shall:

* monitor the Contractor's compliance with contract specifications, including the effective implementation and operation of environmental mitigation measures and other aspects of the EM&A programme;

* comply with the agreed Event and Action Plan in the event of any exceedance;

* employ an Independent Environmental Checker [IC(E)] to audit the results of the EM&A works carried out by the ET; and

* instruct the Contractor to follow the agreed protocols or those in the Contract Specifications in the event of exceedances or complaints.

Environmental Team

The duties of the Environmental Team (ET) and Environmental Team Leader (ET Leader) are to:

* monitor the various environmental parameters as required by this or subsequent revisions to the EM&A Manual;

* assess the EM&A data and review the success of the EM&A programme determining the adequacy of the mitigation measures implemented and the validity of the EIA predictions as well as identify any adverse environmental impacts before they arise;

* conduct weekly site inspections and to investigate and inspect the Contractor's equipment and work methodologies with respect to pollution control and environmental mitigation, monitor compliance with the environmental protection specifications in the Contract, and to anticipate environmental issues that may require mitigation before the problem arises;

* audit the environmental monitoring data and report the status of the general site environmental conditions and the implementation of mitigation measures resulting from site inspections;

* review Contractor's working programme and methodology, and comment as necessary;

* investigate and evaluate complaints, and identify corrective measures;

* advice to the Contractor on environmental improvement, awareness, enhancement matters, etc, on site;

* report on the environmental monitoring and audit results and the wider environmental issues and conditions to the IC(E), Contractor, Towngas and the EPD; and

* adhere to the agreed protocols or those in the Contract Specifications in the event of exceedances or complaints.

The ET shall be led and managed by the ET leader.  The ET leader shall have relevant education, training, knowledge, experience and professional qualifications subject to the approval of the Director of Environmental Protection.  Suitably qualified staff shall be included in the ET, and ET should not be in any way an associated body of the Contractor.

Independent Environmental Checker

An Independent Environmental Checker [IC(E)], independent from the management of construction works, shall be appointed to audit and verify the overall environmental performance of the works and to assess the effectiveness of the ET in their duties.  The main objectives will be to:

* Review and monitor the implementation of the EM&A programme and the overall level of environmental performance being achieved;

* arrange and conduct monthly 'independent' site inspections/audits of the works;

* validate and confirm the accuracy of monitoring results, monitoring equipment, monitoring locations, monitoring procedures and locations of sensitive receivers;

* carry out random sample check and audit on monitoring data and sampling procedures, etc;

* audit the EIA recommendations and requirements against the status of implementation of environmental protection measures on site;

* on a needs basis, audit the Contractor's construction methodology and agree the least impact alternative in consultation with the ET leader and the Contractor;

* provide specialist advice to the Client on environmental matters;

* check complaint cases and the effectiveness of corrective measures;

* check that the necessary mitigation measures recommended in the EIA and Contract documents, or as subsequently required, are effectively implemented,

* review EM&A report submitted by the ET leader and feedback audit results to ET by signing off relevant EM&A proformas; and

* report the findings of site inspections / audits and other environmental performance reviews to Towngas and the EPD.

The IEC should not be in any way an associated body of the Contractor or ET.


The remainder of the Manual is set out as follows:

* Section 2 sets out the EM&A general requirements;

* Section 3 details the requirements for water quality baseline and impact monitoring, and lists relevant monitoring equipment, compliance and Event and Action Plans (EAPs);

* Section 4 details the requirements for marine ecology baseline and impact monitoring, and lists relevant monitoring equipment, compliance and EAPs;

* Section 5 details the requirements for landfill gas monitoring, and lists relevant monitoring equipment, compliance and EAPs;

* Section 6 describes the scope and frequency of site auditing; and

* Section 7 details the EM&A reporting requirements.

The EM&A Manual is an evolving document that should be updated to maintain its relevance as the Project progresses.  It is suggested that the first revision to the EM&A Manual takes place when a) the monitoring locations have been agreed with Towngas, Independent Environmental Checker [IC(E)], EPD and AFCD; and b) when the proposed work processes and activities have been determined following any supplementary environmental reviews which may be required.  The primary focus for these reviews will be to ensure the impacts predicted and the recommended mitigation measures remain consistent and appropriate to the manner in which the works are to be carried out.



(1) Attendees included WWF Hong Kong, Friends of the Earth and Conservancy Association.