TABLE
OF CONTENTS
1 introduction. 1
1.1 Background. 1
1.2 Project Description. 1
1.3 Purpose of the
Manual 1
1.4 Project
Organisation. 2
2 air quality. 5
2.1 Introduction. 5
2.2 Mitigation Measures. 5
2.3 Audit Requirements. 5
3 noise. 6
3.1 Introduction. 6
3.2 Mitigation Measures. 6
3.3 Audit Requirements. 6
4 Hazard to Life. 7
4.1 Introduction. 7
4.2 Mitigation Measures. 7
5 water quality. 8
5.1 Introduction. 8
5.2 Mitigation Measures. 8
5.3 Audit Requirements. 8
6 Waste management implication. 9
6.1 Introduction. 9
6.2 Mitigation Measures. 9
6.3 Audit Requirements. 9
7 Ecology. 10
7.1 Introduction. 10
7.2 Mitigation Measures. 10
7.3 Monitoring and
Audit Requirements. 10
8 landscape & visual impact. 11
8.1 Introduction. 11
8.2 Mitigation Measures. 11
8.3 Baseline Monitoring. 12
8.4 Audit Requirements. 12
9 Site Inspection / Audit. 13
9.1 Site Inspection
Requirements. 13
9.2 Compliance with
Legal and Contractual Requirements. 13
9.3 Environmental
Complaints. 14
10 Reporting.. 15
10.1 Baseline Monitoring
Report 15
10.2 Monthly EM&A
Reports. 15
10.3 Final Summary
EM&A Report 19
10.4 Data Keeping. 21
10.5 Interim Notifications
of Environmental Quality Limit Exceedances. 21
List of Tables
Table 8.1 Landscape and Visual Impacts
Mitigation Measures for Construction Phase
Table 8.2 Landscape and Visual Impacts
Mitigation Measures for Operational Phase
List of Figures
Figure
1.1 Site Location Plan
List of Appendices
Appendix A Project
Organisation for Environmental Works
Appendix B Implementation
Schedule of Mitigation Measures
Appendix
C Sample Template for Interim
Notifications of Environmental Quality Limits Exceedances
1.1.1 With a growing and aging
population in Hong Kong, the numbers of deaths and cremations have been rising
gradually year by year, leading to a corresponding increase in the demand for
public niches. There is currently no public columbarium facility on Lantau
Island. Local villagers and residents in Lantau Island of Islands
District can only choose from public niches in Peng Chau or Lamma Island (in
addition to NT/Urban niches) if cremation is adopted, although there are two
public cemeteries on the Island, namely, Tai O Cemetery and Lai Chi Yuen
Cemetery where only coffin burial or urn burial are available. It is against
this background that Members of Islands District Council and Mui Wo Rural
Committee strongly requested public niches be provided on Lantau Island to cope
with the need of local villagers and residents.
1.1.2 In this regard, the Food
and Environmental Hygiene Department (FEHD) proposed an extension of the Mui Wo
Lai Chi Yuen Cemetery (hereafter referred to as “the Project”) to construct an
elevated platform of around 225m²
within the existing Lai Chi Yuen Cemetery boundary to accommodate the outdoor
niches and the ancillary facilities including one joss paper burner (with a
fresh water tank and a sewage holding tank for supporting its operation) and
planters. Also, a site access of 7.5m², which is indispensable for the
development, will be constructed just outside the cemetery boundary due to lack
of suitable space for accommodating it in the cemetery. Location and works
boundary of the Project are shown in Figure 1.1.
1.1.3 The Project is classified
as a Designated Project (DP) under Category Q.1 – the Project is wholly within
an existing country park, Part I in Schedule 2 of the Environmental Impact
Assessment Ordinance (EIAO).
1.1.4 An application for an
Environmental Impact Assessment (EIA) Study Brief under Section 5(1) of the
EIAO was made to Environmental Protection Department (EPD) and the EIA Study
Brief No. ESB-288/2015 for the Project was issued under the EIAO. AECOM Asia Company Limited (AECOM) was
commissioned by ArchSD as the Consultant to conduct this EIA study for the Project.
1.2.1 The Project site is located
at a slope next to the entrance staircase of the existing Lai Chi Yuen Cemetery
with a total area of 232.5m². An elevated platform of around 225m² supported by
structural columns will be constructed to accommodate some 790 niches. All the niches will be in outdoor
setting. The ancillary facilities like a
joss paper burner (with a fresh water tank and a sewage holding tank for
supporting its operation) and planters will be provided as well.
1.2.2 A site access of 7.5m² will
be constructed just outside the cemetery boundary. The site access area has
however been minimized to allow only pedestrian access without compromising the
wheelchair access requirement.
1.2.3 Construction of the Project
will commence tentatively in February 2018 with completion in September
2019.
1.3.1 The purpose of this
EM&A Manual (hereinafter refer to as the “Manual”) is to guide the setup of
an EM&A programme to ensure compliance with the recommendations in the EIA
study covering the provision of the new columbarium at Lai Chi Yuen Cemetery in
Mui Wo, Lantau, to assess the effectiveness of the recommended mitigation
measures and to identify any further need for additional mitigation measures or
remedial action. This Manual outlines
the monitoring and audit programme for both construction and operational phases
of the Project. It aims to provide
systematic procedures for monitoring, auditing and minimizing environmental
impacts associated with the construction and operational phases.
1.3.2 The Manual provides
specific information, guidance and instruction to personnel in charged with
environmental responsibilities and undertaking environmental monitoring and
auditing works for the Project. It also
provides systematic procedures for monitoring, auditing and minimizing
environmental impacts associated with the construction activities.
1.3.3 The EM&A programme
contain the following information:
• Project organisation for the Project;
• Responsibilities of the Contractor, the Engineer or Engineer’s
Representative (ER), Environmental Team
(ET) and Independent Environmental Checker (IEC) with respect to the
environmental monitoring and audit requirements during the course of the
Project;
• The basis for, and description of the broad approach underlying the
EM&A programme;
• Requirements with respect to the construction programme schedule and
the necessary environmental monitoring and audit programme to track the varying
environmental impact;
• Details of the methodologies to be adopted, including all field
laboratories and analytical procedures, and details on quality assurance and
quality control programme;
• 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;
• Requirements for presentation of environmental monitoring and audit
data and appropriate reporting procedures; and
• Requirements for review of EIA predictions and the effectiveness of
the mitigation measures / environmental management systems and the EM&A
programme.
1.4.1 Involvement of relevant
parties in a collaborative and interactive manner is essential for the
implementation of the recommended EM&A programme. The following sections outline the primary
responsibilities and duties of the key EM&A programme participants. The proposed project organisation and lines
of communication with respect to EM&A works are shown in Appendix A.
The Contractor
1.4.2 The Contractor shall report
to the ER. The duties and
responsibilities of the Contractor comprise the following:
• Work within the scope of the contraction contract and other tender
conditions with respect to environmental requirements;
• Operate and strictly adhere to the guidelines and requirements in
this EM&A programme and contract specifications;
• Provide assistance to ET in carrying out monitoring and auditing;
• Participate in the site inspections undertaken by ET as required,
and undertake correction actions;
• Provide information / advice to ET regarding works activities which
may contribute, or be continuing to the generation of adverse environmental
conditions;
• Submit proposals on mitigation measures in case of exceedance of
Action and Limit levels in accordance with the Event / Action Plans;
• Implement measures to reduce impact where Action and Limit levels
are exceeded; and
• Adhere to the procedures for carrying out complaint investigation.
1.4.3 The Contractor shall also
participate in the environmental performance review undertaken by the ER and
undertaken any corrective actions as instructed by the ER.
Environmental
Team (ET)
1.4.4 The ET Leader and the ET
shall be employed to conduct the EM&A programme and ensure the Contractor’s
compliance with the project’s environmental performance requirements during
construction. The ET Leader or the ET shall be an independent party from the
IEC and have relevant professional qualifications, or have sufficient relevant
EM&A experience subject to approval of the ER and the Environmental
Protection Department (EPD). The ET shall be led and managed by the ET leader.
The ET leader shall possess at least 7 years’ experience in EM&A and/or
environmental management.
1.4.5 The duties and
responsibilities of the ET are:
• Monitor various environmental parameters as required in this
EM&A Manual;
• Analyse the environmental monitoring and audit data and review the
success of EM&A programme to cost-effectively confirm the adequacy of
mitigation measures implemented and the validity of the EIA predictions and to
identify any adverse environmental impacts arising;
• Carry out regular site inspection to investigate and audit the
Contractors' site practice, equipment and work methodologies with respect to
pollution control and environmental mitigation, and effect proactive action to
pre-empt problems; carry out ad hoc site inspections if significant
environmental problems are identified;
• Audit and prepare monitoring and audit reports on the environmental
monitoring data and site environmental conditions;
• Report on the environmental monitoring and audit results to the IEC,
Contractor, the ER and EPD or its delegated representative;
• Recommend suitable mitigation measures to the Contractor in the case
of exceedance of Action and Limit levels in accordance with the Event and
Action Plans;
• Advice to the Contractor on environmental improvement, awareness,
enhancement matters, etc. on site; and
• Adhere to the procedures for carrying out complaint investigation in
accordance with Section 9 of this Manual.
Engineer’s
Representative (ER)
1.4.6 The ER shall appoint an
appropriate member of the resident site staff, who shall:
• Monitor the contractor’s compliance with the contract
specifications, including the EM&A programme, and the effective
implementation and operation of environmental mitigation measures in a timely
manner;
• Ensure that impact monitoring is conducted at the correct locations
at the correct frequency as identified in the EM&A programme;
• Instruct the Contractor to follow the agreed protocols or those in
the Contract Specifications in the event of exceedances or complaints;
• Review the programme of works with a view to identifying any
potential environmental impacts before they arise;
• Check that mitigation measures that have been recommended in the EIA
Report, this document and contract documents, or as required, are correctly
implemented in a timely manner, when necessary;
• Report the findings of site audits and other environmental
performance reviews to the ArchSD;
• Verify the environmental acceptability of permanent and temporary
works, relevant design plans and submissions; and
• Comply with the agreed Event Contingency Plan in the event of any
exceedance.
Independent
Environmental Checker (IEC)
1.4.7 The IEC shall advise the ER
on environmental issues related to the Project.
The IEC shall not be in any way an associated body of the ER, the
Contractor or the ET for the Project.
The IEC shall be empowered to audit from an independent viewpoint the
environmental performance during the construction of the Project. The IEC shall be a person who has relevant
professional qualifications in environmental control and at least 7 years’
experience in EM&A and environmental management.
1.4.8 The IEC shall be
responsible for the duties defined in this Manual, and shall audit the overall
EM&A programme, including the implementation of all environmental
mitigation measures, submissions required in this Manual, as well as any other
relevant submissions required under the Environmental Permit (EP). The IEC shall be responsible for verifying the
environmental acceptability of permanent and temporary works, relevant design
plans and submissions under the EP. The
IEC shall verify the logbook prepared and kept by the ET Leader. The IEC shall notify EPD by fax, within 24
hours of receipt of notification from the ET Leader of any such instance or
circumstance or change of circumstances or non-compliance with the EIA Report
or the EP, which might affect the monitoring or control of adverse
environmental impact.
1.4.9 The main duties of the IEC
are to carry out independent environmental audit of the Project. This shall include, inter alias, the
followings:
• Review and audit in an independent, objective and professional
manner in all aspects of the EM&A programme;
• Validate and confirm the accuracy of monitoring results,
appropriateness of monitoring equipment, monitoring locations with reference to
the locations of the nearby sensitive receivers, and monitoring procedures;
• Carry out random sample check and audit on monitoring data and
sampling procedures, etc.;
• Conduct random site inspection (at least once a month);
• Audit the EIA recommendations and EP requirements against the status
of implementation of environmental protection measures on site;
• Review the effectiveness of environmental mitigation measures and
Project environmental performance;
• On an as needed basis, verify and certify the environmental
acceptability of the construction methodology (both temporary and permanent
works), relevant design plants and submissions under the EP. When necessary, the IEC agree in consultation
with the ET Leader and the Contractor the least impact alternative;
• Verify investigation results of complaint cases and the
effectiveness of corrective measures;
• Verify EM&A reports submitted and verified by the ET Leader; and
• Feedback audit results to ER / ET by signing accordingly to the
Event / Action Plans specified in the Manual.
2.1.1 Potential air quality
impacts arising from the construction and operational phases of the Project
were assessed in the EIA Report. Based on the assessment results, no adverse
air quality impact from the Project would be anticipated with the
implementation of dust suppression measures during construction phase and the
incorporation of flue gas treatment system, good operational practices and
administrative measures to the proposed joss paper burner during operational
phase. No air quality monitoring is therefore deemed necessary. Nevertheless,
regular site environmental audit is recommended to ensure the implementation of
the recommended mitigation measures during construction phase.
2.2.1 Mitigation measures for
construction phase and operational phase air quality impacts have been
recommended in the EIA Report. All the recommended mitigation measures are
detailed in the implementation schedule in Appendix B. The Contractor should be
responsible for the design and implementation of the mitigation measures.
2.3.1 Regular site inspection and
audit at least once per week should be conducted during the construction phase
of the Project to ensure the recommended mitigation measures are properly
implemented.
3.1.1 Potential noise impacts
arising from the construction and operational phases of the Project were
assessed in the EIA Report. The assessment results indicated that no adverse
noise impact from the construction and operation of the Project. No specific
noise monitoring is therefore considered necessary for both construction and
operational phases.
Construction Phase
3.2.1 Since exceedance of the
noise criteria from the construction of the Project was not predicted in the
EIA Report, no specific noise mitigation measure was proposed. Nonetheless,
good site practice and the noise control requirements stated in EPD’s
"Recommended Pollution Control Clauses for Construction Contracts” were
recommended to minimise the potential noise nuisance during construction phase.
Details of the recommended good site practices are presented in Appendix B.
Operational Phase
3.2.2 The fixed noise sources of
the Project include two water pumps and a joss paper burner. The maximum permissible sound power levels of
the identified fixed noise sources were predicted in the EIA Report. To ensure that the noise impact associated
with the fixed plant operations would comply with the noise standards
stipulated in the EIAO-TM and Noise Control Ordinance (NCO), the specified
sound power levels should be implemented and refined by the Contractor as
appropriate. The mitigation measures as
recommended in the EIA Report for the fixed plant noise arising from the
operation of the Project is presented in Appendix B.
3.3.1 Regular site environmental
audit at least once per week during the construction phase of the Project
should be conducted to ensure good site practices as listed in Appendix B
and the noise control requirements stated in EPD’s "Recommended Pollution
Control Clauses for Construction Contracts” are implemented to further minimise
the potential noise nuisance during construction phase.
4.1.1 Potential hazard to life impacts
arising from the construction and operational phases of the Project were
addressed in Section 5 of the EIA Report. No specific monitoring or auditing
requirement is deemed necessary for both construction and operational phases.
Construction Phase
Operational Phase
4.2.2 The Cost-Benefit Analysis
demonstrates that proposed Project is compliant with the As Low As Reasonably
Practicable (ALARP) principle.
Nonetheless, good practice for operator is recommended to minimize the
impact in case of chlorine accident as presented in Appendix B.
5.1.1 Potential water quality
impacts arising from the construction and operational phases of the Project
were identified and assessed in the EIA Report.
5.1.2 Construction site runoff,
wastewater generated from general construction activities, accidental spillage
of chemicals, and sewage effluent produced by on-site workforce would be the
potential sources of water quality impacts arising from the construction of the
Project. The identified potential source of impact on water quality during the
operational phase of the Project would be the sewage generated from the
visitors as well as other site runoff from the Project. The EIA concluded that
with the implementation of the recommended mitigation measures and Best
Management Practices, no significant water quality impact would be anticipated
during construction and operational phases.
No specific water quality monitoring is therefore considered necessary.
Construction Phase
5.2.1 Water quality arising from
construction activities would be well-controlled by implementing practices
outlined in ProPECC PN 1/94 Construction
Site Drainage and good management practices as detailed in Appendix B.
Operational Phase
5.2.2 Best Management Practices
(BMPs) as detailed in Appendix B to reduce storm water and non-point
source pollution have been proposed for the operation of the Project.
5.3.1 Weekly site audit should be
conducted to ensure that the recommended mitigation measures for water quality
impacts are fully implemented during construction phase of the Project.
6.1.1 Potential waste management
implication arising from the construction and operational phases of the Project
were addressed in the EIA Report. Waste management during the construction
phase will mainly be the responsibility of the Contractor, who should implement
the mitigation measures recommended in the EIA report in order to minimise
waste or resolve the issues associated with the management of wastes. The Contractor should also ensure that all
wastes produced during the construction phase are handled, stored and disposed
of in accordance with good waste management practices, relevant legislation and
waste management guidelines.
6.2.1 With the proper handling,
storage and disposal of wastes arising from the construction of the Project, it
is anticipated that the potential adverse environmental impacts would be
avoided or minimised. During site inspections, the ER and ET should
pay special attention to the issues relating to the waste management and check
whether the Contractor has implemented the recommended good site practices and
other mitigation measures as listed in Appendix B. The Contractor should submit a
Waste Management Plan (WMP) prior to the commencement of construction work, in
accordance with the ETWB TC(W) No. 19/2005 so as to provide an overall
framework of Waste Management and Reduction.
6.3.1 Regular audits and site
inspection at least once per week should be carried out by the ET to ensure
that the recommended good site practices and other mitigation measure are
implemented by the Contractor. The
audits should look at all aspects of on-site waste management practices
including the waste generation, storage, recycling, transportation and
disposal. Apart from site inspections, documents including licenses, permits,
disposal and recycling records should be reviewed and audited for the
compliance with the legislation and contract requirements. The requirements of the environmental audit
programme are set out in this EM&A Manual.
The audit programme should verify the implementation status and evaluate
the effectiveness of the mitigation measures.
6.3.2 During operational phase,
only limited amount of wastes would be generated and no adverse waste impact
would be anticipated with the implementation of the good waste management
practices. No monitoring or audit is
required during operational phase.
7.1.1 Potential ecological
impacts arising from the construction and operational phases of the Project
were assessed in the EIA Report. Mitigation measures have been recommended to
minimize potential direct and indirect impacts to ecological resources. With
the implementation of appropriate mitigation measures, no unacceptable
ecological impact would be anticipated.
7.2.1 Mitigation measures for
ecological impacts have been recommended in the EIA Report to minimize
potential direct and indirect impacts. The recommended mitigation measures for
construction phase include retaining plantations, restricting works area,
transplantation of a plant of conservation importance, and good site practices
to minimise disturbance to the flora and fauna near the works area. During
operational phase, adequate litter bins, a joss paper burner of proper function
and fire-fighting gears should be provided. Regular patrol should be conducted
at the open niche area during the Ching Ming Festival and Chung Yeung Festival
to ensure no uncontrolled burning occurs.
7.2.2 The Contractor should be responsible for the
design and implementation of these measures.
The implementation schedule of the mitigation measures is given in Appendix B.
7.3.1 During the construction
period, implementation of the recommended mitigation measures should be
regularly inspected and audited monthly by ET throughout the construction phase
to ensure proper implementation.
7.3.2 All flora species of
conservation importance (e.g. Aquilaria
sinensis) should be protected as far as practicable. As a mitigation measure, all the unavoidably
affected individual(s) should be transplanted to nearby suitable habitat(s)
prior to the commencement of site clearance.
A Detailed Vegetation Survey should be conducted by a suitably qualified
botanist / ecologist to identify and record the affected individuals prior to
the commencement of any site clearance works.
A Transplantation Proposal should be prepared by a qualified ecologist /
botanist, including detailed findings of the vegetation survey (i.e. number and
locations of the affected individuals, assessment of the suitability and / or
practicality of the transplantation) and locations of receptor site(s),
transplantation methodology, implementation programme of transplantation,
post-transplantation monitoring and maintenance programme. The proposal should
be submitted to and approved by AFCD prior to commencement of any works
(including ground investigation). The approved transplantation works should be
carried out before the commencement of any site clearance works and should be
supervised by the qualified botanist / horticulturist / Certified Arborist.
8.1.1 Potential landscape and
visual impacts arising from the construction and operational phases of the Project
were assessed and landscape and visual mitigation measures were recommended in
the EIA Report. This section defines the audit requirements to confirm the
recommended landscape and visual impact mitigation measures in the EIA Report
are effectively implemented.
8.2.1 The landscape and visual
mitigation measures proposed recommended in the EIA Report are listed in Table 8.1 and
8.2. The implementation schedule of the measures is
given in Appendix
B.
Table 8.1 Landscape and Visual
Impacts Mitigation Measures for Construction Phase
|
ID No.
|
Landscape and Visual Mitigation Measures
|
Funding Agency
|
Implementation Agency
|
|
CM1
|
Preservation of existing vegetation
All
the existing Trees to be retained and not to be affected by the Project
within the site shall be carefully protected during construction accordance
with DEVB TCW No. 7/2015 - Tree Preservation and the latest Guidelines on
Tree Preservation during Development issued by GLTM Section of DevB. Any existing vegetation on existing man-made
slope and natural terrain not to be affected by the Project shall be
carefully preserved.
|
ArchSD
|
ArchSD
|
|
CM2
|
Compensatory tree planting
Any trees to be felled under the Project shall be compensated in
accordance with DEVB TCW No. 7/2015 - Tree Preservation. Native species will be proposed.
|
ArchSD
|
ArchSD
|
|
CM3
|
Control of night-time lighting glare
Any
lighting provision of the construction works at night shall be carefully
control to prevent light overspill to the nearby VSRs and into the sky.
|
ArchSD
|
ArchSD
|
|
CM4
|
Erection of screen hoarding in visually unobtrusive
colour
Screen
hoarding in visually unobtrusive colour, which is compatible with the
surrounding settings, shall be erected during construction to minimize the potential
landscape and visual impacts due to the construction works and activities.
|
ArchSD
|
ArchSD
|
|
CM5
|
Management of construction activities and facilities
The
facilities and activities at works sites and areas, which include site
office, temporary storage areas, temporary works etc., shall be carefully
managed and controlled on the height, deposition and arrangement to minimize
any potential adverse landscape and visual impacts.
|
ArchSD
|
ArchSD
|
|
CM6
|
Reinstatement of temporarily disturbed landscape
areas
All
hard and soft landscape areas disturbed temporarily during construction due
to temporary excavations, temporary works sites and works areas shall be
reinstated to equal or better quality, to the satisfaction of the relevant
Government Departments.
|
ArchSD
|
ArchSD
|
Table 8.2 Landscape and Visual
Impacts Mitigation Measures for Operational Phase
|
ID No.
|
Landscape and Visual Mitigation Measures
|
Funding Agency
|
Implementation Agency
|
Maintenance/ Management Agency
|
|
OM1
|
Aesthetically pleasing design of aboveground
structures
The
Aboveground Structures of the Project including proposed elevated platform,
structural columns, niches and ancillary facilities in the regard of layouts,
forms, materials and finishes shall be sensitively designed so as to blend in
the structures to the adjacent landscape and visual context.
|
ArchSD
|
ArchSD
|
ArchSD
|
|
OM2
|
Amenity tree and shrub planting
Amenity
tree and shrub planting shall be provided at the edge of the platform to
provide green transition between the proposed extension and the existing
natural terrain.
|
ArchSD
|
ArchSD
|
ArchSD
|
|
OM3
|
Screen Planting to soften the Structural Columns of the elevated
platform
Shade
Tolerant species will be selected carefully. Screen planting on slope and
vertical screen planting in the form of climbers on wire mesh are proposed in
front of the structural columns of the elevated platform to minimize the
potential adverse visual impact.
|
ArchSD
|
ArchSD
|
ArchSD
|
8.3.1 Prior to the commencement
of construction works, a baseline report shall be prepared to check, record and
report the status of the landscape resources (LRs) and landscape character
areas (LCAs) within the works areas and the visually sensitive receivers (VSRs)
within the visual envelope. Any significant changes to the status of LRs,
LCAs and VSRs since the approval of the EIA Report should be identified. The
recommended landscape and visual mitigation measures should be reviewed if such
change warrants a change in the design of the landscape and visual mitigation
measures.
8.4.1 Site audits should be
undertaken during the construction phase of the Project to check that the
proposed landscape and visual mitigation measures are properly implemented and maintained
as per their intended objectives. Site
inspections should be undertaken by the ET at least once every two weeks during
the construction period. Inspection findings shall be logged in a site
monitoring report with any discrepancies or concerns regarding the
implementation and effectiveness of mitigation measures highlighted.
9.1.1 Site inspections/audits
provide a direct means to trigger and enforce the specified environmental
protection and pollution control measures. They shall be undertaken routinely,
at least once per week, to inspect/audit the construction activities in order
to ensure that appropriate environmental protection and pollution control
mitigation measures are properly implemented. With reference to the Project’s
contractual environmental requirements, pollution control and mitigation
specifications and a well-established site inspection/audit, deficiency and
action reporting system in accordance with the event contingency plan of the
EM&A programme, the site inspection/audit would be one of the most
effective tools used to enforce the environmental protection requirements on
the construction site. A site inspection/audit checklist, to be used for
undertaking site inspection/audit, will be prepared by the ET and submitted to
the ER for approval.
9.1.2 The ET is responsible for
formulation of the environmental site inspection/audit, deficiency and action
reporting system, and for carrying out the site inspection/audit works.
9.1.3 Regular site inspections/audits
shall be carried out at least once per week. All observations and results will
be recorded in the data record sheets, which will pass to the Contractor. If
non-compliance is found on site, the Event / Action Plan will be implemented.
9.1.4 The areas of
inspection/audit shall not be limited to the environmental situation, pollution
control and mitigation measures within the site; it will also review the
environmental situation outside the site area which is likely to be affected,
directly or indirectly, by the site activities. The ET shall make reference to
the following information in conducting the inspection/audit.
• The EIA recommendations on environmental protection and pollution
control
• mitigation measures;
• Works progress and programme;
• Individual works methodology proposals (which shall include proposal
on associated pollution control
measures);
• The contract specifications on environmental protection;
• The relevant environmental protection and pollution control laws;
and
• Previous site inspection/audit results.
9.1.5 The Contractor shall update
the ET Leader with all relevant information of the construction contract for
him to carry out the site inspections/audits.
The inspection/audit results and its associated recommendations on
improvements to the environmental protection and pollution control works shall
be submitted to the ER and the Contractor within 24 hours, for reference and
for taking immediate action. The
Contractor shall follow the procedures and time-frame as stipulated in the environmental
site inspection/audit, deficiency and action reporting system formulated by the
ET to report on any remedial measures subsequent to the site
inspections/audits. Weekly site audit
should be carried out to check the implementation status of the recommended air
quality impact mitigation measures throughout construction period.
9.1.6 Ad hoc site
inspections/audits shall also be carried out if significant environmental
problems are identified. Inspections/audits may also be required subsequent to
receipt of an environmental complaint, or as part of the investigation/audit
work, as specified in Action Plan for environmental monitoring and audit.
9.2.1 There are contractual
environmental protection and pollution control requirements as well as
environmental protection and pollution control laws in Hong Kong, which the
construction activities shall comply with.
9.2.2 In order that the works are
in compliance with the contractual requirements, all the works method statements
submitted by the Contractor to the ER for approval shall be sent to ET Leader
of vetting to see whether sufficient environmental protection and pollution
control measures have been included.
9.2.3 The ET Leader shall also
review the progress and programme of the works to check that relevant
environmental laws have not been violated and that the any foreseeable
potential for violating the laws can be prevented.
9.2.4 The Contractor shall
regularly copy relevant documents to the ET Leader so that the checking work can
be carried out. The document shall at
least include the updated Work Progress Reports, the updated Works Programme,
the application letters for different licence/permits under the environmental
protection laws, and all the valid licence/permit. The site diary shall also be available for
the ET Leader‘s inspection upon his request.
9.2.5 The ET Leader shall advise
the ER and the Contractor of any non-compliance with the contractual and
legislative requirements on environmental protection and pollution control for
them to take follow-up actions. If the
ET Leader’s review concludes that the current status on licence/permit
application and any environmental protection and pollution control preparation
works may not cope with the works programme or may result in potential
violation of environmental protection and pollution control requirements by the
works in due course, he shall also advise the Contractor and the ER
accordingly.
9.2.6 Upon receipt of the advice,
the Contractor shall undertake immediate action to remedy the situation. The ER shall follow up to ensure that
appropriate action has been taken by the Contractor in order that the
environmental protection and pollution control requirements are fulfilled.
9.3.1 Complaints shall be
referred to the ET Leader for carrying out complaint investigation
procedures. The ET Leader shall
undertake the following procedures upon receipt of the complaints:
• Log complaint and date of receipt and inform the ER immediately;
• Investigate the complaint to determine its validity, and to assess
whether the source of the problem is due to works activities;
• If a complaint is valid and due to works, identify mitigation
measures;
• If mitigation measures are required, advise the Contractor
accordingly;
• Review the Contractor’s response on the identified mitigation
measures, and the updated situation;
• If the complaint is a referral from EPD, submit interim report to
EPD after endorsement by ER on status of the complaint investigation and
follow-up action within the time frame assigned by EPD;
• Undertake additional monitoring and audit to verify the situation if
necessary, and review that any valid reason for complaint does not recur,.
• Report the investigation results and the subsequent actions to the
source of complaint for responding to complainant (If the source of complain is
a referral from EPD, the result should be reported within the time frame
assigned by the EPD); and
• Record the complaint, investigation, the subsequent actions and the
results in the monthly EM&A reports.
9.3.2 During the complaint
investigation works, the Contractor and ER shall cooperate with the ET Leader
in providing all necessary information and assistance for completion of the
investigation. If mitigation measures are
identified in the investigation, the Contractor shall promptly carry out the
mitigation. The ER shall ensure that the
measures have been carried out by the Contractor.
10.1.1 The baseline monitoring
results, their interpretation and proposals for the Action / Limit level
parameters should be presented in the form of a report which will be submitted
to the ER for agreement. The report
should be supported by the baseline monitoring data in electronic format
prepared in HTML or PDF format, along with information from the covering
monitoring locations, equipment and protocols.
The agreed baseline report will then be reissued as a standalone report.
10.1.2 The baseline monitoring
report shall include (but not limited to) the following elements:
(i)
Up to half a page of Executive
Summary;
(ii)
Project background information;
(iii)
Drawings showing the locations
of the baseline monitoring stations;
(iv)
Monitoring results (in both
hard and diskette copies) including graphical plots, together with the
following information:
•
Monitoring methodology
•
Name of the laboratory and
types equipment used and calibration details;
•
Parameters monitored;
•
Monitoring locations (and
depths);
•
Monitoring date, time,
frequency and duration; and
•
QA/QC results and detection
limits
(v)
Interpretation of the
significance of monitoring results and explanation of influencing factors,
including:
•
Major activities, if any, being
carried out in the Project site during the period;
•
Weather conditions during the
period; and
•
Other factors which might
affect the monitoring results
(vi)
Determination of the Action and
Limit levels for each monitoring parameter and statistical analysis of the
baseline data;
(vii)
Revisions for inclusion in the
EM&A programme; and
(viii)
Comments and conclusions.
10.2.1 The results and finding of
all EM&A work required in the EM&A programme shall be recorded in the
monthly EM&A reports prepared by the ET Leader. Monthly EM&A Reports shall be submitted
to the ER within 10 working days of the end of each reporting month, the first
report will be submitted in the month after construction works commence. Each monthly EM&A report shall be
submitted to the parties: the Contractor, the IEC, the ER and EPD. Before submission of the first EM&A
report, the ET Leader shall liaise with the parties on the required number of
copies and format of the monthly reports in both hard copy and electronic
medium.
10.2.2 The first monthly EM&A
Report shall be included at least the following:
(i)
1-2 pages executive summary:
•
Breaches of Action and Limit levels;
•
Compliant log;
•
Notifications of any summons
and successful prosecutions;
•
Reporting changes; and
•
Future key issues.
(ii)
Basic project information
including a synopsis of the project organization, programme, management
structure, and the works undertaken during the month;
(iii)
Environmental status:
•
Advice on the status of
statutory environmental compliance such as the status of compliance with the EP
conditions under the EIAO, submission status under the EP and implementation
status of mitigation measures;
•
Works undertaken during the
month with illustrations (such as location of works, daily excavation rate,
etc.); and
•
Drawings showing the Project
area, any environmental sensitive receivers and the locations of the monitoring
and control stations (with co-ordinates of the monitoring locations).
(iv)
Brief summary of EM&A
requirement:
•
All monitoring parameters;
•
Environmental quality
performance limits (Action and Limit Levels);
•
Event/Action Plan;
•
Environmental mitigation
measures as recommended in the EIA Report; and
•
Environmental requirements in
contract documents.
(v)
Implementation Status:
•
Advice on the implementation
status of environmental protection and pollution control/mitigation measures,
as recommended in the EIA Report;
(vi)
Monitoring results (in both
hard and diskette copies) together the following information:
•
Monitoring methodology;
•
Name of laboratory and
equipment used and calibration details;
•
Parameter monitored;
•
Monitoring location (and
depth); and
•
Monitoring date, time,
frequency and duration.
(vii)
Graphical plots of monitored
trends over the past four reporting periods and the following information:
•
Major activities being carried
out on site during the period;
•
Weather condition during the
period; and
•
Other factor which might affect
the monitoring results.
(viii)
Report on
non-compliance, complaints, and notifications of summons and successful
prosecutions:
•
Record of all non-compliance
(exceedances) of the environmental quality performance limits (Action and Limit
levels);
•
Record of all complaints
received (written or verbal) for each media, including locations and nature of
complaints investigation, liaison and consultation undertaken, actions and
follow-up procedures taken, results and summary;
•
Record of all notification of
summons and successful prosecutions for breaches of current environmental
protection / pollution control legislation, including locations and nature of
the breaches, investigation, follow-up actions taken, results and summary;
•
Review of the reasons for and
the implications of non-compliances, complaints, summons and prosecutions
including review of pollution sources and working procedures; and
•
Description of the actions
taken in the event of non-compliance and deficiency reporting and any follow-up
procedures related to earlier non-compliance.
(ix)
Others
•
An account of the future key
issues as reviewed from the works programme and work method statements;
•
Advice on the solid and liquid
waste management status;
•
Record of any project changes
from the originally proposed as described in the EIA Report (e.g. construction
methods, mitigation proposals, design changes, etc.); and
•
Comments (for example,
effectiveness and efficiency of the mitigation measures), recommendations (for
examples, any improvement in the EM&A programme) and conclusions.
10.2.3 The subsequent EM&A
Reports shall include at least the following:
(x)
1-2 pages executive summary;
•
Breaches of Action / Limit
Levels;
•
Complaint log;
•
Notifications of any summons
and successful prosecutions;
•
Reporting changes; and
•
Future key issues.
(xi)
Basic project information:
•
Project organisation including
key personnel contact names and telephone numbers;
•
Programme;
•
Management structure;
•
Works undertaken during the
month; and
•
Any updates as needed to
the scope of works and construction methodologies.
(xii)
Environmental Status
•
Advice on the status of
statutory environmental compliance such as the status of compliance with the EP
conditions under the EIAO, submission status under the EP and implementation
status of mitigation measures;
•
Works undertaken during the
month with illustrations (such as location of works, daily excavation rate,
etc.); and
•
Drawings showing the project
are, any environmental sensitive receivers and the locations of the monitoring
and control stations.
(xiii)
Implementation status
•
Advice on the
implementation status of environmental protection and pollution control /
mitigation measures, as recommended in the project EIA Report.
(xiv)
Monitoring results (in both
hard and diskette copies) together with the following information:
•
Monitoring methodology;
•
Name of laboratory and types of
equipment used and calibration details;
•
Monitoring parameters;
•
Monitoring locations;
•
Monitoring date, time,
frequency, and duration;
•
Weather conditions during the
period;
•
Any other factors which might
affect the monitoring results; and
•
QA / QC results and detection
limits.
(xv)
Report on non-compliance,
complaints, and notifications of summons and successful prosecutions:
•
Record of all non-compliance
(exceedances) of the environmental quality performance limits (Action and Limit
levels);
•
record of all complaints
received (written or verbal) for each media, including locations and nature of
complaints investigation, liaison and consultation undertaken, actions and
follow-up procedures taken, results and summary;
•
Record of all notification of
summons and successful prosecutions for breaches of current environmental
protection / pollution control legislation, including locations and nature of
the breaches, investigation, follow-up actions taken, results and summary;
•
Review of the reasons for and
the implications of non-compliances, complaints, summons and prosecutions
including review of pollution sources and working procedures; and
•
Description of the actions
taken in the event of non-compliance and deficiency reporting and any follow-up
procedures related to earlier non-compliance.
(xvi)
Others
•
An account of the future key
issues as reviewed from the works programme and work method statements;
•
Advice on the solid and liquid
waste management status;
•
Record of any project changes from
the originally proposed as described in the EIA (e.g. construction methods,
mitigation proposals, design changes, etc.); and
•
Comments (for examples,
effectiveness and efficiency of the mitigation measures), recommendations (for
examples, any improvement in the EM&A programme) and conclusions.
(xvii) Appendices
•
Action and Limit levels;
•
Graphical plots of trends of
the monitoring parameters at key stations over the past four reporting periods
for representative monitoring stations annotated against the following:
(a) Major activities being carried out on site during the period;
(b) Weather conditions during the period; and
(c) Any other factors that might affect the monitoring results.
•
Monitoring schedule for the
present and next reporting period;
•
Cumulative statistics on complaints,
notifications of summons and successful prosecutions; and
•
Outstanding issues and
deficiencies.
General
10.3.1 The
EM&A programme for construction stage should be terminated upon
the completion of the construction activities, while the
EM&A programme for operation stage should be terminated upon the
completion of operation monitoring.
10.3.2 The proposed termination
should only be implemented after the proposal has been endorsed by the IEC and
the Project Proponent followed by approval from the Director of Environmental
Protection.
Final EM&A
Review Report for Construction Stage
10.3.3 The final EM&A review
report for construction stage (to be submitted after completion of construction
activities) should contain at least the following information:
(i)
Executive summary (1-2 pages);
(ii)
Drawings showing the project area, any environmental sensitive receivers and the
locations of the monitoring and control stations;
(iii)
Basic
project information including a synopsis of the project organisation, contacts of key
management, and a synopsis of work undertaken during the course of the project
or past twelve months;
(iv)
A brief
summary of EM&A requirements including:
•
Environmental mitigation
measures for construction stage, as recommended in the project EIA Report;
•
Environmental impact hypotheses
tested;
•
Environmental quality
performance limits (Action and Limit levels);
•
All monitoring parameters; and
•
Event and Action Plans.
(v)
A summary
of the implementation status of environmental protection and pollution control
/ mitigation measures for construction stage, as recommended in the project EIA
Report and summarised in the updated implementation
schedule;
(vi)
Graphical
plots and the statistical analysis of the trends of monitoring parameters over the
course of the project, including:
•
The major activities being
carried out on site during the period;
•
Weather conditions during the
period; and
•
Any other factors which might
affect the monitoring results;
(vii)
A summary
of non-compliance (exceedances) of the environmental quality performance limits
(Action and Limit levels);
(viii)
A review of
the reasons for and the implications of non-compliance including review of
pollution sources and working procedures as appropriate;
(ix)
A
description of the actions taken in the event of non-compliance;
(x)
A summary
record of all complaints received (written or verbal) for each media, liaison
and consultation undertaken, actions and follow-up actions taken and results;
(xi)
A review of
the validity of EIA predictions for construction stage and identification of
shortcomings in EIA recommendations;
(xii)
Comments
(for example, a review of the effectiveness and efficiency of the mitigation
measures, the performance
of the environmental management system, and the overall EM&A programme for construction stage); and
(xiii)
Recommendations
and conclusions (for example, a review of success of the overall EM&A programme for construction stage to
cost-effectively identify deterioration and to initiate prompt effective mitigatory action when necessary).
Final EM&A Review Report for Operation Stage
10.3.4 The final EM&A review
report for operation stage (to be submitted after completion of operation
monitoring) should contain at least the following information:
(i)
Executive
summary (1-2 pages);
(ii)
Drawings
showing the project area, any environmental sensitive receivers and the
locations of the monitoring and control stations;
(iii)
Basic
project information including a synopsis of the project organisation, contacts of key
management, and a synopsis of work undertaken during the course of the project
or past twelve months;
(iv)
A brief
summary of EM&A requirements including:
•
Environmental mitigation
measures for operation stage, as recommended in the project EIA Report;
•
Environmental impact hypotheses
tested;
•
Environmental quality
performance limits (Action and Limit levels);
•
All monitoring parameters;
•
Event and Action Plans;
(v)
A summary
of the implementation status of environmental protection and pollution control
/ mitigation measures for operation stage, as recommended in the project EIA
Report and summarised in the updated implementation
schedule;
(vi)
Graphical
plots and the statistical analysis of the trends of monitoring parameters over
the course of the project, including:
•
The major activities being
carried out on site during the period;
•
Weather conditions during the
period; and
•
Any other factors which might
affect the monitoring results;
(vii)
A summary
of non-compliance (exceedances) of the environmental quality performance limits
(Action and Limit levels);
(viii)
A review of
the reasons for and the implications of non-compliance including review of
pollution sources and working procedures as appropriate;
(ix)
A
description of the actions taken in the event of non-compliance;
(x)
A summary
record of all complaints received (written or verbal) for each media, liaison
and consultation undertaken, actions and follow-up actions taken and results;
(xi)
A review of
the validity of EIA predictions for operation stage and identification of
shortcomings in EIA recommendations;
(xii)
Comments
(for example, a review of the effectiveness and efficiency of the mitigation
measures, the performance of the environmental management system, and the
overall EM&A programme for operation stage); and
(xiii)
Recommendations
and conclusions (for example, a review of success of the overall EM&A programme for operational stage
to cost-effectively identify deterioration and to initiate prompt effective mitigatory action when necessary).
10.4
Data Keeping
10.4.1 The site document such as
the monitoring field records, site inspection forms etc. are not required to be
included in the monthly EM&A reports for submission. However, all documents
and records shall be well kept by the ET and be ready for inspection upon
request. All documents and data shall be kept for at least one year after
completion of the construction contract.
10.5.1 With reference to the Event
and Action Plans, when the environmental quality performance limits are
exceeded and if they are proven to be valid, the ET should immediately notify
the IEC and EPD, as appropriate. The notification should be followed up with
advice to the IEC and EPD on the results of the investigation, proposed actions
and success of the actions taken, with any necessary follow-up proposals. A
sample template for the interim notification is presented in Appendix C.