10.0 ENVIRONMENT MONITORING AND AUDIT (EM&A) REQUIREMENT

10.1 Project Organisation

A project organisation consisting of the Engineer’s Representative (ER), Independent Environmental Checker (IEC), Environmental Team (ET), Project Proponent (Highways 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.

10.2 EM&A Manual

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 impact and operation monitoring) are given in the EM&A Manual.

A project specific EM&A Manual has been prepared as part of the EIA report 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.

The Contractor shall be requested to review the mitigation measures and Implementation Schedule (IS) with respect to the design developments and construction methodology. In the case where the Contractor needs to update the mitigation measures and the IS, an updated EM&A Manual shall be submitted to the EPD.

10.3 Implementation Schedule

An IS has been prepared and included in Section 12 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 operation phases of the Project. The implementation responsibilities will also be identified in the IS. 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.

10.4 EM&A Programme

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.

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 (dust and airborne noise);

· Impact monitoring (dust and airborne noise);

· 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

Environmental monitoring and audit for potential dust impacts should be conducted during the construction phase of the Project for checking compliance with the legislative requirements.

Regular environmental audits in accordance with EM&A Manual shall be undertaken during the construction works to ensure the proper implementation of the mitigation measures for potential construction dust emissions.

The site inspection shall be conducted in weekly basis. The ET is responsible for formulating an environmental site inspection, deficiency and remedial action reporting system, and for carrying out site inspections under the EM&A programme.

Noise Impact

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

Construction noise monitoring should be carried out at the designated monitoring station when there are Project-related construction activities being undertaken within a radius of 300m from the monitoring stations. The monitoring frequency should depend on the scale of the construction activities. An initial guide on the monitoring is to obtain one set of 30-minute measurement at each station between 0700 and 1900 hours on normal weekdays at a frequency of once a week when construction activities are underway.

During normal construction working hour (0700-1900 Monday to Saturday), monitoring of Leq, (30min) noise levels (as six consecutive Leq, (5min) readings) shall be carried out at the agreed monitoring locations once every week in accordance with the methodology in the EIAO-TM.

In order to evaluate the effectiveness of the proposed noise barriers and to verify the traffic noise predictions made in the EIA, operation noise monitoring upon commissioning of the noise barriers is recommended. Road traffic noise monitoring should be carried out during the first year of the operation phase at representative NSRs located in the vicinity of the recommended direct mitigation measures.

Water Quality Impact

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.

Monitoring of the effluent from the Project Boundary is required during the construction phase of the Project. The monitoring should be carried out in accordance with the valid discharge licenses issued by EPD throughout the entire construction period. The monitoring frequency and parameters specified in the Effluent Discharge License under the Water Pollution Control Ordinance (Cap. 358)should be fully complied with during the monitoring.

Waste Management Implication

The Contractor shall be required to pay attention to relevant environmental standards and guidelines and carry out appropriate waste management and obtain the relevant licenses / permits for waste disposal. Best management practice and mitigation measures as stated in Section 6.6 of the EIA Report shall be followed. The ET shall ensure that the Contractor has obtained from the appropriate authorities the necessary waste disposal permits or licenses including:

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

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

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

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

A Waste Management Plan (WMP), as part of the Environmental Management Plan (EMP) should be prepared in accordance with ETWB TC(W) No. 19/2005 and submitted to the Engineer, i.e. Resident Engineer appointed by the Employer to oversee the construction works in accordance with the specification and contractual requirement for approval. The recommended mitigation measures should form the basis of the WMP. The monitoring and auditing requirement stated in ETWB TC(W) No. 19/2005 should be followed with regard to the management of C&D materials.

Regular audits and site inspections should be carried out during construction phase by the ER, ET and Contractor to ensure that the recommended good site practices and the 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 licenses, permits, disposal and recycling records should be reviewed and audited for compliance with the legislation and contract requirements.

Ecological Impact

As the direct impact due to habitat loss is considered minor, and there is no significant and adverse impact from disturbance to wildlife and indirect / induced impacts resulted from the proposed works during construction and operation phases, hence, no ecological monitoring is required. However, regular site inspection by an experienced ecologist is recommended to ensure adequate mitigation measures / best practice guidelines are implemented throughout construction of the Project, in particular the Conservation Area, secondary woodland and near the watercourses.

Land Contamination

Site re-appraisal is required for the identified potentially contaminated sites as well as other areas within the Project Boundary to address any change in land use that may give rise to potential land contamination issues as soon as the sites become accessible and a supplementary Contamination Assessment Plan (CAP) should be submitted and endorsed by EPD before site investigation. A Contamination Assessment Report (CAR) which includes the site investigation sampling and testing results will be prepared for EPD's agreement upon completion of the site investigation. If contamination is identified, Remediation Action Plan (RAP) shall be also prepared and submitted to EPD for agreement prior to the commencement of the remediation works. Upon completion of the remediation, a Remediation Report (RR) shall be submitted to EPD for agreement. No construction works of site should be carried out prior to the agreement of the RR.

Landscape and Visual Impact

The measures proposed in the EIA to mitigate the landscape and visual impacts arising from the Project should be incorporated within the detailed landscape design drawings and contract documents including the protection of existing trees where possible, the transplanting of existing trees and the planting of new trees and shrubs. Regular site inspection is required to check the mitigation measures for landscape and visual impact. Retained trees as descripted in Chapter 9 are protected from the avoidance of works.

10.5 Summary of EM&A Requirements

A summary of key EM&A requirements is provided in Table 10.1 below. Details are provided in the stand-alone EM&A Manual.

Table 10.1 Summary of EM&A Requirements

Environmental Aspect	Summary of EM&A Requirements
Air Quality Impact	· Dust monitoring and regular site audits during construction period
Noise Impact	· Construction noise monitoring and regular site audits during construction period · Operational traffic noise monitoring during the first year after road opening
Water Quality Impact	· Regular site audits during construction phase · Effluent monitoring
Waste Management Implications	· Regular audits and site inspections should be carried out during construction phase
Land Contamination Impact	· Any necessary environmental monitoring in relation to land remediation subject to supplementary CAP findings
Ecological Impact	· Regular site audits by an experienced ecologist should be carried out throughout the construction phase to check and ensure implementation of the recommended mitigation measures
Landscape and Visual Impact	· Regular audits and site inspections should be carried out during construction phase