This Environmental Monitoring and Audit (EM&A) Manual (“the Manual”) has been prepared by ERM-Hong Kong, Limited (ERM) on behalf of the Civil Engineering and Development Department (CEDD) of the Hong Kong Special Administrative Region (SAR) Government. The Manual is a supplementary document of the Environmental Impact Assessment (EIA) Study of the Detailed Site Selection Study for a Proposed Contaminated Mud Disposal Facility within the Airport East/East of Sha Chau Area (Agreement CE 12/2002 (EP)) (hereafter referred to as the Project).
The Manual has been prepared in accordance with the EIA Study Brief (No. ESB-095/2001) 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.
From December 1992 to November 1997, a series of purpose-dredged seabed pits at East Sha Chau (Contaminated Mud Pits (CMPs) I to III) were used to dispose of dredged contaminated mud in Hong Kong. In 1996, as the capacity in these pits began to dwindle, the Hong Kong Government commissioned a study to examine the need for continued marine disposal of dredged material in Hong Kong in order to manage ongoing contaminated sediment arisings (). The study reviewed potential land-based options in Hong Kong including strategic landfills, treatment of materials, and the incorporation of contaminated dredged material into land reclamation projects, but found each to have inherent drawbacks. The study's review of environmental monitoring data collected at CMPs I-III from 1992-1995 concluded that there was no evidence of contaminant impacts on biota due to disposal, and that contaminants in dredged materials had been successfully contained. The study therefore recommended continued disposal in capped seabed pits in the East Sha Chau area as the preferred option. This finding led the Hong Kong Government to commission an EIA evaluating the use of disused borrow pits in the East Sha Chau area as the next contaminated mud disposal facility. This facility, known as CMP IV, consisted of three pits (CMP IV a, b and c) which had been dredged for sand during construction of the new airport at Chek Lap Kok and represented a total capacity of approximately 30 million cubic metres. The CMP IV EIA study () formulated an environmental design for disposal operations, which included specifications for disposal rates, cap thickness, and backfilling level. The Study concluded that impacts to water quality, marine ecology, air and noise were expected to be maintained within acceptable limits under the specifications of the agreed Operations Plan. The CMP IV EIA Report was endorsed by the Advisory Council on the Environment (ACE) in March 1997.
In December 1997, disposal operations commenced in CMP IVa in conjunction with an environmental monitoring programme that encompassed water and sediment chemistry, fisheries assessment, tissue and whole body analysis, and benthic recolonisation studies. A review of the collection and analysis of the environmental data from the first 38 months of operations demonstrated that there had not been any adverse environmental impacts resulting from disposal activities ().
Capacity to dispose of contaminated mud is currently predicted to be exhausted by early 2009 with the completion of backfilling of CMP IV at East of Sha Chau. When CMP IV is full, a new environmentally acceptable disposal capacity for essential arisings will be required. A capacity of 8 Mm3 is needed to provide disposal capacity up to 2015. The assignment Strategic Assessment and Site Selection Study for Contaminated Mud Disposal (Agreement CE 105/98) recommended a Contained Aquatic Disposal facility (CAD - capped seabed pit such as those already used at East of Sha Chau) at Airport East ().
Although members of ACE had no objection to proceeding with the recommended EIA, they considered that all sites, in particular remaining portions of East of Sha Chau, and other disposal options, in particular a confined disposal facility (CDF – material confined within an artificial island) should still be considered. To meet these requirements of ACE, the present study identified the most suitable sites and disposal option within both the Airport East and East of Sha Chau areas and, secondly it evaluated the environmental acceptability of impacts associated with construction and operation of these, through an EIA, and thirdly, based on a comparison of the outcomes of the two EIAs, a preferred disposal facility is recommended.
The conclusion of the Study was that both of the proposed facilities could be operated in an environmentally acceptable manner.
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 fisheries are defined.
The Project is classified as a Designated Project 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 under the Environmental Impact Assessment Ordinance (Cap. 499) (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 include the following:
i. Dredging of a series of seabed pits within the proposed facility boundaries (Figures 1.2a and 1.2b);
ii. Backfilling each dredged pit with contaminated mud that has been classified as requiring Type 2 disposal in accordance with ETWBTC 34/2002 (); and,
iii. Capping each backfilled pit with uncontaminated mud effectively isolating the contaminated mud from the surrounding marine environment.
Once the EIA Report has been formally approved by Government, CEDD will obtain an Environmental Permit (EP) for construction of the Project. Once the EP has been obtained the first pit is expected to be dredged during 2008 in order to be ready to receive contaminated mud in early 2009. According to the arisings estimates, the fourth pit at the East of Sha Chau Facility will be backfilled and capped during the first half of 2015 (Figure 1.2c). It should be noted that should the rate at which contaminated mud arises change (either increasing or decreasing) then the fourth pit may be capped earlier and the South Brothers pits activated before end 2015. The tentative construction programme is presented in Figure 1.2d. It should be noted that the timeline presents predicted timeframes for each works component.
Figure 1.2c Tentative Programme of Works for Option 1
Figure 1.2d Tentative Programme of Works for Option 2
There is a possibility that capacity will be reached at the East of Sha Chau Facility before predicted, this is dependant upon arisings of contaminated mud over the next 10 years. Concurrent projects in the South Brothers area are due to be finished by 2009, after which, the South Brothers facility may be utililsed if there is a need to provide further disposal capacity. Monitoring stations have been included in this EM&A manual to reflect monitoring at whichever pit is active. In addition to the South Brothers facility being required due to increased arisings of contaminated mud, uncertainties in developments in the area may also require the facility to come into operation as presented in Figure 1.2e.
Figure 1.2e Tentative Programme of Works for Option 3
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 fisheries impacts during the construction and operation of the proposed facility. 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 the 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 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 sediment quality levels at specified locations;
· implement monitoring and inspection requirements for sediment quality monitoring programme;
· establish baseline sediment toxicity levels at specified locations;
· implement monitoring and inspection requirements for sediment toxicity monitoring programme;
· establish baseline body burden levels in marine biota at specified locations;
· implement monitoring and inspection requirements for the body burden (marine biota) monitoring programme;
· liaise with, and provide environmental advice (as requested or when otherwise necessary) to 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 liaise with other individuals or parties concerning other environmental issues deemed to be relevant to the construction and operation 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;
- submit regular 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; and
- Details of the methodology of implementing the capping works through using excavated soil can be found in Annex C.
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.
The objectives of the EM&A programme are as follows:
1. To monitor and report on the environmental impacts of the dredging operations associated with the construction of the disposal pits;
2. To monitor and report on the environmental impacts due to capping operations of the exhausted pits;
3. To monitor and report on the environmental impacts of the disposal of contaminated marine sediments in the active pits and specifically to determine:
· changes/trends caused by disposal activities in the concentrations of contaminants in sediments adjacent to the pits;
· changes/trends caused by disposal activities in the toxicity of sediment adjacent to the pits;
· changes/trends caused by disposal activities in the concentrations of contaminants in tissues of demersal marine life adjacent to and remote from the pits;
· impacts on water quality and benthic ecology caused by the disposal activities and capping works
· the risks to human health and dolphin of eating seafood taken in the marine area around the active pits.
4. To monitor and report on the environmental impacts of the disposal operation and specifically to determine whether the methods of disposal are effective in minimising the risks of adverse environmental impacts.
5. To monitor and report on the benthic recolonisation of the capped pits including previous ones and specifically to determine the difference in infauna between the capped pits and adjacent sites.
6. To assess the impact of a major storm (Typhoon Signal No. 8 or above) on the containment of any uncapped or partially capped pits.
7. To design and continually review the operation and monitoring programme and:
· to make recommendations for changes to the operation that will rectify any unacceptable environmental impacts; and
· to make recommendations for changes to the monitoring programme that will improve the ability to cost effectively detect environmental changes caused by the disposal activities.
8. To establish numerical decision criteria for defining impacts for each monitoring component.
9. To provide supervision on the field works and laboratory works to be carried out by contractors/laboratories.
The specific objectives of each component are discussed in the relevant sections of this EM&A Manual.
The Civil Engineering and Development Department (CEDD) 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, the ET shall also appoint independent auditor(s) to verify and validate the environmental performance of the Contractor and the ET.
The roles and responsibilities of the various parties involved in the EM&A process are further expanded in the following sections and in Figure 1.6a. 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 CEDD, the Contractor shall:
· work within the scope of the construction contract and other tender conditions;
· provide assistance to the ET in conducting the required environmental monitoring;
· participate in the site inspections undertaken by the ET, as required, and undertake any corrective actions instructed by CEDD;
· provide information/advice to the ET 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.
· 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; and
· instruct the Contractor to follow the agreed protocols or those in the Contract Specifications in the event of exceedances or complaints.
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 regular 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;
· employ an Independent Auditor(s) to audit the results of the EM&A works carried out by the ET;
· report on the environmental monitoring and audit results and the wider environmental issues and conditions to the Contractor, CEDD 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.
The remainder of the Manual is set out as follows:
· Section 2 sets out the EM&A general requirements;
· Section 3 details the methodologies, parameters to be tested and the requirements for the marine water quality monitoring for the dredging, backfilling and capping operations at the active pits;
· Section 4 details the methodologies, parameters to be tested and the requirements for sediment quality monitoring for the backfilling activities at the active pits;
· Section 5 details the methodologies, parameters to be tested and the requirements for sediment toxicity quality monitoring for the backfilling activities at the active pits;
· Section 6 details the methodologies, parameters to be tested and the requirements for marine biota monitoring for the backfilling activities at the active pits;
· Section 7 details the requirements for Human Health and Dolphin Risk Assessment;
· Section 8 details the requirements for benthic re-colonisation assessment;
· Section 9 details the methodologies, parameters to be tested and the requirements for the assessment of impacts due to major storms; and
· Section 10 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 the detailed design phase of the Project has been completed. The primary focus for reviews of the EM&A Manual 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.
() EVS Environment Consultants (1996a) Review of Contaminated Mud Disposal Strategy and Status Report on Contaminated Mud Disposal.. Final Report. For the Civil Engineering Department, Hong Kong Government..
() ERM – Hong Kong, Ltd (1997) EIA for Disposal of Contaminated Mud in the East Sha Chau Marine Borrow Pit. EIA Report. For the Civil Engineering Department, Hong Kong SAR Government..
() ERM – Hong Kong, Ltd (2002) Environmental Monitoring and Audit for Contaminated Mud Pit IV at East of Sha Chau. Final Report. For the Civil Engineering Department, Hong Kong SAR Government..
() ERM - Hong Kong, Ltd (1999) Strategic Assessment and Site Selection Study for Contaminated Mud Disposal. Final Report. For the Civil Engineering Department, Hong Kong SAR Government.
() ETWBTC (2002). Management of Dredged/Excavated Sediment. Environment, Transport and Works Bureau Technical Circular 34/2002.