13 Environmental Monitoring and Audit Requirements

13.1 Project Organisation

13.1.1 A project organisation consisting of the Engineer’s Representative (ER), Independent Environmental Checker (IEC), Environmental Team (ET), Project Proponent (Civil Engineering and Development Department) and Contractor should be established to take on the responsibilities for environmental protection for the Project. The ET and IEC will be appointed by the Project Proponent to conduct independent auditing on the overall EM&A programme including environmental and operation monitoring, implementation of mitigation measures, Environmental Monitoring and Audit (EM&A) submissions, and any other submission required under the Environmental Permit (EP). The organisation, responsibilities of respective parties and lines of communication with respect to environmental protection works are given in the EM&A Manual.

13.2 EM&A Manual

13.2.1 EM&A is an important aspect in the EIA process which specifies the timeframe and responsibilities for the implementation of environmental mitigation measures. The requirements on environmental monitoring (including baseline and impact monitoring) are given in the EM&A Manual.

13.2.2 A project specific EM&A Manual to the Project has been prepared as part of the EIAO submission with reference to the latest design information available and Environmental Protection Department’s (EPD) generic EM&A Manual. The project specific EM&A Manual highlights the following issues:

· Responsibilities of the Contractor, the Engineer or ER, ET, and the IEC under the context of EM&A;

· Project organisation for the EM&A works;

· The basis for, and description of the broad approach underlying the EM&A programme;

· Details of the methodologies to be adopted, including all laboratories and analytical procedures, and details on quality assurance and quality control programme;

· The rationale on which the environmental monitoring data will be evaluated and interpreted;

· Definition of Action and Limit Levels;

· Establishment of Event and Action Plans;

· Requirements for reviewing pollution sources and working procedures required in the event of non-compliance with the environmental criteria and complaints; and

· Requirements for presentation of environmental monitoring and audit data and appropriate reporting procedures.

13.2.3 The Contractor shall be requested to review the mitigation measures and Project Implementation Schedule (PIS) with respect to the design developments and construction methodology. In the case where the Contractor needs to update the mitigation measures and the PIS, an updated EM&A Manual shall be submitted to the EPD for approval. The Contractor shall seek EPD’s prior approval on these amendments before construction commences.

13.3 Project Implementation Schedule

13.3.1 A PIS has been prepared and included in Appendix 13.1 and the stand-alone EM&A Manual to summarise all the required mitigation measures that need to be implemented during the design, the construction and operational phases of the Project. The implementation responsibilities will also be identified in the PIS. The EM&A Manual will also present the requirements for environmental monitoring and auditing (e.g. monitoring and audit frequency), throughout the construction and operation phases.

13.3.2 The Contractor should review the mitigation measures and PIS with respect to the design developments and construction methodology. In case the Contractor needs to update the mitigation measures and PIS, the EM&A Manual should be updated accordingly.

13.4 EM&A Programme

13.4.1 The Contractor will be requested to implement and operate a monitoring programme throughout the construction and operation period of the Project. This mechanism will include a system to report the monitoring results on the Project Proponent’s website within a period of time, to be agreed by EPD, after the relevant monitoring data are collected. In cases where exceedance is found, the Contractor and ET should take immediate actions to implement remediation measures following the procedures specified in the EM&A Manual.

13.4.2 Detailed requirements of the EM&A programme will be described in the EM&A Manual. Measurements and activities that shall be conducted in accordance with the requirements in the EM&A Manual are summarised as follows:

· Baseline monitoring (construction dust, airborne noise, water, etc.);

· Impact monitoring (construction dust, airborne noise, water, etc.);

· Remedial actions in accordance with the Event and Action Plan within the timeframe in case the specified criteria in the EM&A Manual were exceeded;

· Logging and keeping records of monitoring results; and

· Preparation and submission of Baseline, Monthly and Final EM&A Reports.

Air Quality Impact

13.4.3 Dust monitoring and regular site audit during construction phase of the Project are recommended to ensure that the mitigation measures would be properly implemented. Details of the recommended dust monitoring requirements are provided in the EM&A Manual.

13.4.4 Performance compliance tests are recommended for the deodourising units of planned sewage pumping stations (SPS), to ensure the effectiveness of deodorisation treatment implemented in the Project. Separate EIA studies would be conducted for the planned refuse transfer station (RTS) and the new Hung Shui Kiu Sewage Treatment Works (HSK STW) and the relevant EM&A requirements would be addressed in its individual EIA studies.

Noise Impact

13.4.5 Construction noise monitoring and regular site audit are recommended during construction phase to ensure that the proposed mitigation measures would be properly implemented.

13.4.6 Road traffic noise levels should be monitored at representative noise sensitive receivers (NSR), which are in the vicinity of the recommended direct mitigation measures, during the first year after road opening. The purpose of the monitoring is to ascertain that the recommended mitigation measures are effective in reducing the noise levels.

13.4.7 The assessment has indicated that the planned fixed plants at planned SPSs, STW, district cooling system (DCS), electrical substation (ESS), public transport interchange (PTI), vehicle depot, fire station and hospital within the Project would comply with the EIAO-TM standard if the design taking into account the proposed maximum allowable sound power levels. Monitoring of operation noise from these planned fixed plants during the testing and commissioning stage is recommended to verify the compliance with the EIAO-TM criteria. Separate EIA studies would be conducted for proposed HSK Station, RTS and the new HSK STW and the relevant EM&A requirements would be addressed in its individual EIA studies.

Water Quality Impact

13.4.8 Water quality monitoring at all major watercourses identified within the Project area is recommended to be carried out before, during and after the construction phase. It is recommended that regular site inspections during the construction phase should be undertaken to inspect the construction activities and works areas in order to ensure the recommended mitigation measures are properly implemented. Details of the recommended water quality monitoring requirements are provided in the stand-alone EM&A Manual for the Project.

Sewerage and Sewage Treatment Implications

13.4.9 An assessment of potential impacts due to the sewerage and sewage treatment implications has been assessed in Chapter 6 of the EIA Report.

Sewerage and Sewage Treatment Implications during Construction Phase

13.4.10 The sewage generated during the construction stage from the on-site workforce will be collected in chemical toilets and disposed of off-site. Therefore, no sewerage impacts are expected from the site during the construction phase. As such, environmental monitoring and audit of the sewerage system is considered not required.

Sewerage and Sewage Treatment Implications during Operational Phase

13.4.11 The different design / mitigation measures to minimise the emergency discharges will be thoroughly considered and assessed under the separate Schedule 2 EIA study for the new HSK STW.

Waste Management Implications

13.4.12 The Contractor shall be required to pay attention to relevant environmental standards and guidelines and carry out appropriate waste management and obtain the relevant licences / permits for waste disposal. The ET shall ensure that the Contractor has obtained from the appropriate authorities the necessary waste disposal permits or licences including:

· Waste Collection Licence and Waste Disposal Licence under the Waste Disposal Ordinance (Cap. 354);

· Application for Registration under Section 7(5) of the Waste Disposal (Chemical Waste) (General) Regulation (Cap. 354C);

· Public Dumping Licence under the Land (Miscellaneous Provisions) Ordinance (Cap. 28);

· Effluent Discharge Licence under the Water Pollution Control Ordinance (Cap. 358); and

· Approval of Construction & Demolition Material Management Plan.

13.4.13 The Contractor shall refer to the relevant information and guidelines issued by the Director of Environmental Protection when applying for the licence / permit and the ET shall refer to the information and guidelines for auditing purposes.

13.4.14 Regular audits and site inspections should be carried out during construction phase by the ET to ensure that the recommended good site practices and other recommended mitigation measures are properly implemented by the Contractor. The audits should concern all aspects of on-site waste management practices including waste generation, storage, recycling, transport and disposal. Apart from site inspection, documents including licences, permits, disposal and recycling records should be reviewed and audited for compliance with the legislation and contract requirements.

Land Contamination Impact

13.4.15 The land contamination assessment examined the potential contaminative land use within the assessment area and their potential impacts to future land use. The majority of the potentially contaminated sites could not be accessed to assess the site conditions by site walkover, at the time of reporting. For those sites that were accessible for site walkover, permission could not be obtained from the site operators to carry out the site investigation (SI) works.

13.4.16 As the identified potentially contaminated sites are still in operation and the development will only commence in stages from 2019 to 2037/38, and there may be change in land use prior to development within both the potentially contaminated and non-contaminated sites, it is recommended to conduct further works. This would include site re-appraisal, SI works as well as submission of supplementary Contamination Assessment Plan(s), Contamination Assessment Report(s) and Remediation Action Plan(s) (RAP(s)) for the EPD approval after the sites are handed over to Project Proponent for development. If contaminated soil and/or groundwater were identified, remediation should be carried out according to EPD’s approved RAP(s) and Remediation Report(s) (RR(s)) which should be submitted to EPD for agreement after completion of the remediation works. No development works shall be commenced prior to EPD’s agreement of the RR(s).

Ecological Impact

13.4.17 To minimise the disturbance impact on the natural habitats and wildlife, the implementation of the mitigation measures recommended in the Section 9.7 should be subject to regular site audit. Site audit should be carried out monthly throughout the construction phase. In case of non-compliance, the Contractor should be informed to strengthen the proposed mitigation measures accordingly.

13.4.18 A monitoring programme covering construction phase for monitoring the condition and integrity of the San Sang San Tsuen egretry and use of the site by ardeids and any other species of conservation significance should be specified during the detailed design stage of the development. No construction works would be undertaken in Sites 3-32, 3-33, 3-37, 3-39 and 3-40 during the breeding season of ardeids (i.e. March to August). During the construction phase, the egretry would be monitored monthly by qualified ecologists with at least 10 years relevant local experience to confirm if it is active during the breeding season and if the egretry is significantly disturbed (e.g. physical damage of nesting vegetation or pollution of any kind) by other construction activities out of the aforementioned Sites.

Fisheries Impact

13.4.19 Based on the findings from the Fisheries Impact Assessment, no unacceptable fisheries impacts are expected from the Project. No specific monitoring programme for fisheries resources is required.

Landscape and Visual Impact

13.4.20 Monitoring for the landscape and visual resources identified within the Project area is recommended to be carried out during both the construction and operational phases. It is recommended that regular site inspections during the construction phase should be undertaken to inspect the construction activities and works areas in order to ensure the recommended mitigation measures are properly implemented. Details of the recommended landscape and visual resource monitoring requirements are summarised in Table 13.1 and provided in the stand-alone EM&A Manual for the Project.

Impact on Cultural Heritage

13.4.21 Based on desktop review and through archaeological field survey (AFS) conducted in 2015, a total of six Sites of Archaeological Interest (SAIs) and four Archaeological Potential Areas (APAs) were identified within the assessment area. The six SAIs contained high archaeological significance. Tseung Kong Wai SAI (F1) and Tung Tau Tsuen SAI (F2) might be partially impacted by construction works, but no insurmountable impact is anticipated. The archaeological impact arising from the construction works should be assessed when the detailed design of the works is available. Preservation in situ is the top priority to safeguard the archaeological remains in the impacted area by amending the layout plans of the construction works. However, if the works cannot avoid disturbance to the archaeological deposit, depending on degree of direct impact, the following mitigation measures should be considered, such as archaeological surveys, archaeological watching brief, preservation by records and relocation of archaeological remains. The scope and programme of the archaeological fieldwork would be agreed with Antiquities and Monuments Office (AMO).

13.4.22 The four APAs contained uncertain archaeological potential. Further archaeological survey is required to be conducted at APA1 and APA2 to ascertain the extent of any archaeological remains within the APAs if any construction works will be carried out. Based on the findings of the survey, mitigation measures could be proposed, such as preservation in situ, preservation by records, or relocation of archaeological remains, in prior agreement with the AMO. Direct impact arising from the proposed development within APA3 should be avoided as far as possible.

13.4.23 Twelve nil grade built heritage in Yick Yuen Tsuen, Tin Sam San Tsuen and south of Tin Sam are to be directly impacted during the construction phase. Where their removal is unavoidable, preservation by record (including cartographic and photographic record) prior to any construction works would be required for the directly impacted nil grade built heritage. As these nil grade resources contained no cultural heritage significance, the impact to cultural heritage caused by the proposed development to them is unavoidable yet acceptable with mitigation measures.

13.5 Summary of EM&A Requirements for Schedule 2 Designated Projects Subject to Environmental Permit Application

13.5.1 A summary of key EM&A requirements for Schedule 2 designated projects (DP) subject to EP application is provided in Table 13.1 below. Details are provided in the stand-alone EM&A Manual.

Table 13.1 Summary of Key EM&A Requirements for Schedule 2 DPs Subject to EP Application under this Study

Designated Project	Summary of EM&A Requirements
DP1 – Construction of New Primary Distributor Road (Road P1)
Air Quality Impact	· Construction dust monitoring and regular site audit during construction period
Noise Impact	· Construction noise monitoring and regular site audit during construction period · Operational traffic noise monitoring during the first year after road opening
Water Quality Impact	· Water quality monitoring at watercourses and regular site audit during construction phase
Sewerage and Sewage Treatment Implications	· N/A
Waste Management Implications	· Regular audits and site inspections should be carried out during construction phase
Land Contamination Impact	· Any environmental monitoring in relation to land remediation is not required. However, regular site audit during construction phase is required to ensure the implementation of proposed mitigation measures effectively
Ecological Impact	· Regular site audit should be carried out throughout the construction phase and during the operational phase, as appropriate, to check and ensure implementation of the recommended mitigation measures
Fisheries Impact	· N/A
Landscape and Visual Impact	· Landscape and tree felling monitoring and regular site audit during construction period · Landscape and visual monitoring during construction and operation periods
Impact on Cultural Heritage	· N/A
DP2 – Construction of Eight New Distributor Roads (Roads D1 to D8)
Air Quality Impact	· Construction dust monitoring and regular site audit during construction period
Noise Impact	· Construction noise monitoring and regular site audit during construction period · Operational traffic noise monitoring during the first year after road opening
Water Quality Impact	· Water quality monitoring at watercourses and regular site audit during construction phase
Sewerage and Sewage Treatment Implications	· N/A
Waste Management Implications	· Regular audits and site inspections should be carried out during construction phase
Land Contamination Impact	· Any environmental monitoring in relation to land remediation is not required. However, regular site audit during construction phase is required to ensure the implementation of proposed mitigation measures effectively
Ecological Impact	· Regular site audit should be carried out throughout the construction phase and during the operational phase, as appropriate, to check and ensure implementation of the recommended mitigation measures
Fisheries Impact	· N/A
Landscape and Visual Impact	· Landscape and tree felling monitoring and regular site audit during construction period Landscape and visual monitoring during construction and operation periods
Impact on Cultural Heritage	· The construction of distributor road D5 might directly impact on Tseung Kong Wai Site of Archaeological Interest. The archaeological impact arising from the construction works should be assessed when the detailed design of the works is available. Preservation in situ is the top priority to safeguard the archaeological remains in the impacted area by amending the layout plans of the construction works. However, if the works cannot avoid disturbance to the archaeological deposit, depending on degree of direct impact, the following mitigation measures should be considered, such as archaeological surveys, archaeological watching brief, preservation by records and relocation of archaeological remains. The scope and programme of the archaeological fieldwork would be agreed with AMO
DP5 – Construction of Slip Roads Between: Road D8 Junction and Existing Castle Peak Road; Junction of D8/P1 and Junction of D7/P1; and KSWH Connection to Road D3
Air Quality Impact	· Construction dust monitoring and regular site audit during construction period
Noise Impact	· Construction noise monitoring and regular site audit during construction period · Operational traffic noise monitoring during the first year after road opening
Water Quality Impact	· Water quality monitoring at watercourses and regular site audit during construction phase
Sewerage and Sewage Treatment Implications	· N/A
Waste Management Implications	· Regular audits and site inspections should be carried out during construction phase
Land Contamination Impact	· Any environmental monitoring in relation to land remediation is not required. However, regular site audit during construction phase is required to ensure the implementation of proposed mitigation measures effectively
Ecological Impact	· Regular site audit should be carried out throughout the construction phase and during the operational phase, as appropriate, to check and ensure implementation of the recommended mitigation measures
Fisheries Impact	· N/A
Landscape and Visual Impact	· Landscape and tree felling monitoring and regular site audit during construction period Landscape and visual monitoring during construction and operation periods
Impact on Cultural Heritage	· N/A
DP6 – Construction of Partly Depressed and Partly Decked-over Roads Located at Road D2, Road D4 and Road D6
Air Quality Impact	· Construction dust monitoring and regular site audit during construction period
Noise Impact	· Construction noise monitoring and regular site audit during construction period
Water Quality Impact	· Water quality monitoring at watercourses and regular site audit during construction phase
Sewerage and Sewage Treatment Implications	· N/A
Waste Management Implications	· Regular audits and site inspections should be carried out during construction phase
Land Contamination Impact	· Any environmental monitoring in relation to land remediation is not required. However, regular site audit during construction phase is required to ensure the implementation of proposed mitigation measures effectively
Ecological Impact	· Regular site audit should be carried out throughout the construction phase and during the operational phase, as appropriate, to check and ensure implementation of the recommended mitigation measures
Fisheries Impact	· N/A
Landscape and Visual Impact	· Landscape and tree felling monitoring and regular site audit during construction period · Landscape and visual monitoring during construction and operation periods
Impact on Cultural Heritage	· N/A
DP9 – Construction of Four New Sewage Pumping Stations (Sites 2-34, 3-41, 3-48 and 4-35)
Air Quality Impact	· Regular site audit during construction period · Performance compliance tests are recommended for the deodourising units of the four planned SPSs
Noise Impact	· Construction noise monitoring and regular site audit during construction period · Operation noise monitoring for fixed plants during the testing and commissioning stage
Water Quality Impact	· Water quality monitoring at watercourses and regular site audit during construction phase
Sewerage and Sewage Treatment Implications	· N/A
Waste Management Implications	· Regular audits and site inspections should be carried out during construction phase
Land Contamination Impact	· Any environmental monitoring in relation to land remediation is not required. However, regular site audit during construction phase is required to ensure the implementation of proposed mitigation measures effectively
Ecological Impact	· Regular site audit should be carried out throughout the construction phase and during the operational phase, as appropriate, to check and ensure implementation of the recommended mitigation measures
Fisheries Impact	· N/A
Landscape and Visual Impact	· Landscape and tree felling monitoring and regular site audit during construction period Landscape and visual monitoring during construction and operation periods
Impact on Cultural Heritage	· N/A
DP12 – Construction of Road P1 and Slip-road from KSWH to Road D3 Partly located with “Conservation Area” of Yuen Tau Shan
Air Quality Impact	· Regular site audit during construction period
Noise Impact	· Construction noise monitoring and regular site audit during construction period
Water Quality Impact	· Water quality monitoring at watercourses and regular site audit during construction phase
Sewerage and Sewage Treatment Implications	· N/A
Waste Management Implications	· Regular audits and site inspections should be carried out during construction phase
Land Contamination Impact	· Any environmental monitoring in relation to land remediation is not required. However, regular site audit during construction phase is required to ensure the implementation of proposed mitigation measures effectively
Ecological Impact	· Regular site audit should be carried out throughout the construction phase and during the operational phase, as appropriate, to check and ensure implementation of the recommended mitigation measures
Fisheries Impact	· N/A
Landscape and Visual Impact	· Landscape and tree felling monitoring and regular site audit during construction period Landscape and visual monitoring during construction and operation periods
Impact on Cultural Heritage	· N/A

Note:

* Location of DPs is presented in Figure 1.2 and Figure 1.3