WATER RECREATION CENTRE

EP-097/2001/B

EP-097/2001/C

OPERATIONAL ENVIRONMENTAL MONITORING AND AUDIT PLAN FOR WATER RECREATION CENTRE

HONGKONG INTERNATIONAL THEME PARK

JULY 2005

List of Contents Page

1. Introduction 1

1.1 Project Background 1

1.2 Design, Construction and Operation of the WRC 1

1.3 Monitoring Requirements 2

1.4 Purpose and Contents of the Plan 4

1.5 Objectives of Environmental Monitoring & Audit Programme 4

1.6 Scope of the EM&A programme 4

1.7 Structure of the EM&A Plan 5

2. EM&A Strategy 6

2.1 Organisation Structure 6

2.2 Duty of Environmental Team and IEC 6

2.3 Action & Limit Levels / Event & Action Plans 7

3. WATER MoNITORING Procedures 9

3.1 Monitoring Requirements 9

3.2 Monitoring Equipment 9

3.3 Laboratory Analysis 11

3.4 Construction Phase Monitoring 11

3.5 Compliance Monitoring Locations 11

3.6 Compliance Monitoring Frequency and Duration 11

3.7 Compliance Assessment 11

3.8 Event and Action Plan 12

4. waste Management 17

5. AUditing 18

5.1 Site Inspections 18

5.2 Environmental Complaint 18

6. REPORTING 20

6.1 General 20

6.2 Baseline Monitoring Report 21

6.3 Monthly EM&A Reports 21

6.4 Datakeeping 23

Appendices

· Appendix A Lake Liner Details

· Appendix B Spill Control Plan

· Appendix C CEDD’s Water Quality Monitoring Plan Prior to Turnover to HKITP

1. Introduction

1.1 Project Background

The Hong Kong Disneyland Resort, including a Water Recreation Centre (WRC), was considered a Designated Project under the Environmental Impact Assessment Ordinance (EIAO) and was assessed under the Environmental Impact Assessment (EIA) for “Construction of an International Theme Park in Penny’s Bay of North Lantau and its Essential Associated Infrastructures” (AEIAR No. 032/2000, July 2000).

The WRC is a portion of the Contract for “Theme Park and Associated Infrastructures at Penny’s Bay”, which encompasses an area of approximately 12 ha and contains a multi-function artificial lake, water-based and land-based recreational facilities and ancillary facilities. Apart from recreation purpose, the lake water is a source of irrigation water for the entire Penny’s Bay. The location of the WRC is given in Figure 1.1.

Following approval of the EIA an Environmental Permit (EP) was issued to the Civil Engineering Department (CED) (now Civil and Engineering Development Department (CEDD)) and the subsequent variation of the permit no. EP-097/2001/B and EP-138/2002/C contain the requirements and obligations on the Environmental Monitoring and Audit (EM&A) during the operation of the WRC. As mentioned in the above-mentioned EPs, an Environmental Monitoring and Audit (EM&A) Plan is required to ensure that the mitigation measures recommended in the EIA Report and the EM&A Manual (Annex N to EIA Report) are implemented during the operation of WRC.

Under the Contract for “Theme Park and Associated Infrastructures at Penny’s Bay”, the WRC and ancillary facilities were designed and constructed under the supervision of CEDD. Upon completion, the WRC will be turned over from CEDD to Hong Kong International Theme Parks Ltd (HKITP) for operation under a licence arrangement. During the period that HKITP is the Licence Holder, HKITP will assume the roles and duties of the conditions applicable to WRC operation in the above-mentioned permits and implement the EM&A Plan.

1.2 Design, Construction and Operation of the WRC

The design and construction of the WRC and ancillary facilities were undertaken by CEDD as mentioned above. The artificial lake was lined by High Density Polyethylene (HDPE) liner, the details of which including the lifespan is given in Appendix A. The design allows for the lake to be filled by either one of two following methods: (1) using water from the Tai Lam Reservoir, or (2) using water from the stream courses at the adjacent hills. Under the first method, the lake would be filled by opening the intake valve at Inlet A at the lake, thereby letting water from the reservoir to flow under pressure and to discharge directly into the lake. The location of inlet A and other important features of the lake are shown in Figure 1.2. For the second method, the valves at the east and west sedimentation tanks outside the WRC are opened, thus allowing the surface runoff from the stream courses to gravitate into two sedimentation tanks located upstream of the lake, namely, at Wan Tuk and Mong Tung Hang. Discharges from the Wan Tuk and Mong Tung Hang sedimentation ponds will then flow into two smaller settling ponds within the lake, located at the northwest corner and eastern corner of the lake, respectively.

Prior to the turnover of the lake by CEDD to HKTIP in July 2005, the WRC has been filled entirely with water from the Tai Lam Reservoir, through Inlet A. A facility was constructed near the northwest vicinity of the lake to provide additional pre-treatment capability to the incoming waters from the reservoir. This facility comprises primarily an alum drip system,

which includes a storage facility for up to 20m³ of alum solution, a feeding system to deliver the alum solution to Inlet A, and all ancillary pipe works. The alum drip system provides the operators the flexibility to exercise some level of pre-treatment to the inlet water, if it were considered required depending on monitoring results from future water quality sampling. It should be noted that the alum drip pre-treatment facility is provided only to the water source from Tai Lam Reservoir.

For the avoidance of doubt, the following table briefly describes the roles of CEDD, DSD and HKTIP in the various aspects of the WRC:

Table 1.1 Summary of Responsibilities for the Various Components of WRC

No.	Components/Areas	Responsible Party	Remarks
1	Design and construction of WRC and all ancillaries works.	CEDD	All works (within the area as defined and illustrated in item 2 below) to be turnover to HKTIP in July 2005.
2	Operations of WRC, including the lake, landscape areas, and buildings/structures	HKITP	The extent of area included within HKITP’s operation and maintenance responsibility is generally shown in Figure 1.2.
3	Sampling and monitoring of the water in the lake and maintenance of settling ponds	HKITP	Monitoring procedures are detailed in Chapter 3.
4	Maintenance of Wan Tuk and Mong Tung Hang sedimentation tanks, including the connecting pipeworks into the lake, the sedimentation ponds and associated structures, and the associated drainage channels.	DSD	The extent of area included within DSD’s operation and maintenance responsibility is generally shown in Figure 1.2.
5	Sampling and monitoring of quality of the runoff water from the stream courses.	Government Department to be identified

There will be water based and land based recreational facilities operated in the WRC, examples include paddle boats, jogging tracks etc. A few motorised boats will be provided for patrol and emergency purpose and a spill control plan (given in Appendix B) will be put in place to handle accidental spills of fuels or other pollutants within the WRC.

1.3 Monitoring Requirements

It was recommended in the EIA Report and the EM&A Manual that post construction monitoring of the quality of the water in the artificial lake be undertaken during the first year following the filling and landscaping of the lake.

WRC water quality monitoring has been conducted by CEDD since April 2005 and it is anticipated that the tentative schedule for the post-construction monitoring by HKITP will commence in August 2005 when the WRC starts operation.

Apart from the EIA, EM&A requirement for the Operation of the Water Recreation Centre are also provided in the environmental permits EP-097/2001/B (Conditions 3.1, 3.2, 3.3, 5.1, 5.2, 5.3, 5.4) and EP-138/2002/C (Conditions 4.1, 4.2, 4.3, 6.1, 6.2, 6.3, 6.4), summarised as follows:

3.1/4.1 No later than one month before the operation of the Water Recreation Centre at Penny’s Bay, the Permit Holder shall submit for the Director’s approval three hard copies and one soft copy of an Operational Environmental Monitoring and Audit (EM&A) Plan for the operation of the Water Recreation Centre. Before the submission to the Director, the EM&A Plan shall be certified by the IEC as conforming to the information and recommendations contained in the EIA Report.

3.2/4.2 The Operational EM&A Plan as required under Condition 3.1 of this Permit shall include without limitation:

(a) details of the impermeable liner used for the Artificial Lake of the Water Recreation Centre at Penny’s Bay, including the lifespan of the liner and a schedule for the replacement of the liner;

(b) clean-up plan for any accidental spills of fuel, petroleum or other pollutants into the Artificial Lake; and

(c) water quality monitoring programme for the Artificial Lake

3.3/4.3 The Operational Environmental Monitoring and Audit Plan approved under Condition 3.1 of this Permit shall hereinafter be referred to as “the EM&A Plan”. All measures recommended in the EM&A Plan shall be fully and properly implemented in accordance with the requirements and time schedule(s) set out in the EM&A Plan.

5.1/6.1 The EM&A programme during operation of the Water Recreation Centre shall be implemented as set out in the EM&A Plan approved under Condition 3.1 of this Permit. Any changes to the EM&A programme shall be justified by the IEC or ET Leader as conforming to the requirements set out in the EM&A Plan, and shall be approved by the Director.

5.2/6.2 The EM&A Plan as required under Condition 5.1 of this Permit shall contain monitoring locations, monitoring schedules, methodology, and qualification of monitoring team members.

5.3/6.3 Four hard copies and one soft copy of the monitoring reports shall be deposited with the Director within two weeks after the completion of each monitoring. The reports shall be certified by the IEC before deposit with the Director. If there are repeated non-compliances with the agreed water quality standards for the Water Recreation Centre recorded in the monitoring, the monitoring programme shall be continued after the first year operation as directed by the Director.

5.4/6.4 All environmental monitoring data and reports submitted under this Permit shall be true, valid and correct.

1.4 Purpose and Contents of the Plan

This Operational EM&A Plan has “reviewed and updated the EM&A Manual to make it specific to the Project’s operational phase” as required in Annex N of the EIA. This EM&A Plan sets out the arrangements for environmental monitoring and auditing, the organisational arrangement, the mechanisms for ensuring that the recommended mitigation measures are fully and effectively implemented, and the actions to be taken in the event of any exceedance of the event or action limits.

It was recommended in the EIA that the operational phase EM&A Plan be reviewed and updated at least on an annual basis. This suggestion is supported however it must be stressed that the review/updating of the EM&A Plan should also take place when any amendments to procedures are implemented which could affect the arrangements contained herein. Such additional reviews should be at the discretion of the ET Leader.

1.5 Objectives of Environmental Monitoring & Audit Programme

The general objectives of the Project EM&A Programme are: -

· to provide a database against which adverse environmental impacts arising out of the operation of the WRC can be determined;

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

· to monitor the implementation of mitigation measures,

· to determine environmental compliance with regulatory requirements, standards and government policies;

· to take remedial action if unexpected problems or unacceptable environmental impacts arise; and

· to provide data against which environmental audits may be undertaken.

1.6 Scope of the EM&A Programme

· Implement operational monitoring and inspection programmes for water quality at the lake;

· Implement inspection and audit requirements for waste management;

· Identify and resolve environmental issues as they may arise from the operation;

· Check and quantify the overall environmental performance, the implementation of EAP and remedial actions taken to mitigate adverse environmental effects as they may arise from the operation;

· Conduct monthly reviews of monitored data as the bases 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 report;

· Conduct regular site inspections of a formal or informal nature to assess:

· The implementation of the recommendations of the EIA report;

· The 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 operation team of any identified potential environmental issues

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

1.7 Structure of the EM&A Plan

Following this introductory chapter, the remainder of the EM&A plan is set out as follows:

· Chapter 2 outlines the EM&A strategy in terms of the organisation of parties involved in the EM&A process and the definition use of Action/ Limit levels

· Chapter 3 details the technical requirements and procedures for water quality monitoring

· Chapter 4 describes the audit procedures related to waste management issues

· Chapter 5 outlines the scope of site auditing and complaint handling procedures

· Chapter 6 details the EM&A reporting requirements

2. EM&A Strategy

2.1 Organisation Structure

The organisation and lines of communication with respect to environmental matters are shown in Figure 2.1. An Environmental Team (ET) will be established by HKITP during the period after the WRC has been transferred from CEDD under a Licence arrangement to HKITP. The ET will be supervised by the ET Leader (ETL) and an Independent Environmental Checker (IEC) will be employed. Both ETL and IEC will have at least 7 years' experience in EM&A or environmental management. They will be responsible for the implementation of the EM&A programme in accordance with this plan.

2.2 Duty of Environmental Team and IEC

The duties of the ET are:

a. sampling, analysis and statistical evaluation of monitoring parameters with reference to the EIA/EP recommendations and requirements;

b. environmental site surveillance;

c. audit of compliance with environmental protection, and pollution prevention and control regulations;

d. monitor the implementation of environmental mitigation measures;

e. complaint investigation, evaluation and identification of corrective measures;

f. liaison with Independent Environmental Checker (IEC) on all environmental performance matters, and timely submissions of all relevant EM&A proforma for IEC’s approval;

g. advice to the HKITP on environmental improvement, awareness, enhancement matters, etc on WRC;

h. timely submission of the EM&A report to HKITP and the Director of Environmental Protection.

The duties of the IEC are:

a. Review and audit all aspects of he EM&A programme;

b. Validate and confirm the accuracy of monitoring results, monitoring equipment, monitoring locations, monitoring procedures and locations of sensitive receivers;

c. Carry out random sample check and audit on monitoring data and sampling procedures, etc;

d. Conduct random site inspection;

e. Audit the EIA/EP recommendations and requirements against the status of implementation of environmental protection measures on site;

f. Review the effectiveness of environmental mitigation measures and project environmental performance;

g. Check complaint cases and the effectiveness of corrective measures;

h. Review EM&A report submitted by the ET leader;

i. Feedback audit results to ET by signing off relevant EM&A proformas.

2.3 Action & Limit Levels / Event & Action Plans

“Action and Limit Levels” (“A/L Levels”) are defined levels of impact recorded by the environmental monitoring activities that represent levels at which a prescribed response is required. These levels are quantitatively defined later in the relevant Parts of this Plan, but can be described in principle below: -

· Action Limits: beyond which there is a clear indication of a deteriorating ambient environment for which appropriate remedial actions are likely to be necessary to prevent environmental quality from falling outside the Limit Levels, which would be unacceptable; and

· Limit Levels: statutory limits stipulated in the relevant pollution control ordinances, the HKPSG or the Environmental Quality Objectives established by the EPD such that, if exceeded, operation should not proceed without appropriate remedial action, including a critical review of operation procedures.

“Event and Action Plans” (EAP’s) provide, in association with the monitoring and audit activities, procedures for ensuring that if any significant adverse environmental incident (caused accidentally or through inadequate implementation of mitigation measures) does occur, the cause will be quickly identified and remediated, and risk of a similar event occurring reduced or removed (and shall also apply to exceedances of A/L levels).

Figure 2.1 HKITP Environmental Team Organisation Structure

3. WATER MoNITORING Procedures

3.1 Monitoring Requirements

It is recommended in the EIA that freshwater quality in the artificial lake should be monitored during the first year following the filling of the lake.

The monitoring requirements set forth in the original EM&A Manual are as follows:

In-situ monitoring for:

· Dissolved oxygen (DO as % saturation)

· Water Depth (m)

· pH value

· Temperature ( degrees Celcius)

· Turbidity (NTU)

Laboratory Analysis for:

· Dissolved oxygen (DO) (in mg/L);

· Conductivity;

· Salinity;

· Copper (Cu);

· Chromium (Cr);

· Lead (Pb);

· Zinc (Zn);

· Tributyltin (TBT);

· Suspended Solids (SS);

· total nitrogen;

· total phosphorous;

· total silica;

· 5-day BOD;

· COD;

· Ammonia;

· chlorophyll a; and

· E coli.

In addition to the water quality parameters defined above, other relevant data shall also be recorded, such as monitoring location, time, weather conditions and any special phenomena. It is important to note that this list will be revisited once enough data has been established to determine those parameters which define changes to the water quality.

It is proposed to review the need for monitoring on those parameters without Water Quality criteria 3 months after operation

3.2 Monitoring Equipment

The water quality monitoring shall be undertaken using the following equipment:

Dissolved Oxygen and Temperature Measuring Equipment

The instrument shall be a portable, weatherproof dissolved oxygen measuring instrument complete with cable, sensor, comprehensive operation manuals, and shall be operable from a DC power source. It shall be capable of measuring:

· dissolved oxygen levels in the range of 0 – 20 mg L^-1 and 0 – 200% saturation; and

· a temperature of 0 – 45 degrees Celsius.

It shall have a membrane electrode with automatic temperature compensation complete with a cable of not less than 25 m in length. Sufficient stocks of spare electrodes and cables shall be available for replacement where necessary. (For example, YSI model 59 metre, YSI 5739 probe, YSI 5795A submersible stirrer with reel and cable or an approved similar instrument).

Turbidity Measurement Equipment

Turbidity within the water shall be measured in-situ by the nephelometric method. The instrument shall be a portable, weatherproof turbidity-measuring unit complete with cable, sensor and comprehensive operation manuals. The equipment shall be operated from a DC power source, it shall have a photoelectric sensor capable of measuring turbidity between 0 – 1000 NTU and shall be complete with a cable with at least 25 m in length (Hach 2100P or an approved similar instrument).

The turbidity meter shall be calibrated to establish the relationship between turbidity readings (in NTU) and levels of suspended solids (in mg L^-1). After calibration, turbidity measurements shall be taken as a true representation of levels of suspended solids only before laboratory test results for suspended solids are known.

Water Depth Gauge

A portable, battery-operated echo sounder (Seafarer 700 or a similar approved instrument) shall be used for the determination of water depth at each designated monitoring station. This unit shall either be hand-held or affixed to the bottom of the work boat if the same vessel is to be used throughout the monitoring programme.

Salinity Measurement Instrument

A portable salinometer capable of measuring salinity in the range of 0 – 40 mg L^-1 shall be provided for measuring salinity of the water at each monitoring location.

pH Measuring Instrument

A portable pH meter shall be provided for measuring pH of the water at each monitoring location.

Water Sampling Equipment

A water sampler, consisting of a transparent PVC or glass cylinder of not less than two litres which can be effectively sealed with cups at both ends, shall be used (Kahlsico Water Sampler 13SWB203 or an approved similar instrument). The water sampler shall have a positive latching system to keep it open and prevent premature closure until released by a messenger when the sampler is at the selected water depth.

Water samples for SS measurements shall be collected in high density polythene bottles, packed in ice (cooled to 4^oC without being frozen), and delivered t a suitably qualified HOKLAS laboratory as soon as possible after collection.

Positioning Device

A boat-fixed type digital Differential Global Positioning System (DGPS) shall be used during monitoring to ensure the monitoring vessel is at the correct location before taking measurements.

3.3 Laboratory Analysis

All laboratory work shall be carried out in a suitably qualified HOKLAS accredited laboratory. Water samples of about 1,000 ml shall be collected at the monitoring stations for carrying out the laboratory determination of Dissolved Oxygen (in mg 1-l) Copper, Chromium, Lead, Zinc, TBT, total nitrogen, total phosphorous, total silica, chlorophyll-a and E.coli. The determination work shall start within 24 hours after the collection of the water samples.

The analyses of SS shall follow the standards described in APHA Standard Methods for the Examination of Water and Wastewater, 19^th edition (SS: 2540D standard method).

3.4 Construction Phase Monitoring

Five monitoring locations have been established as part of the construction phase monitoring programme undertaken by CEDD which commenced during the filling of the Lake. Samples have been taken at 1m below the surface, at mid-depth and 1m above the bottom of the lake. The sampling locations have been selected such that they include the deepest part of the lake. Sampling locations are shown in Appendix C.

3.5 Compliance Monitoring Locations

Subject to the approval of the Director, it is proposed that the same monitoring locations (i.e., 5 nos.) that were used by CEDD for the construction phase monitoring programme as discussed above are used for the compliance monitoring programme. Samples would be taken, for each of these locations as shown in Figure 3.1, at 1m below the surface, at mid-depth and 1m above the bottom of the lake. Exact locations of these sampling points are given by the following coordinates:

Sampling Point WM1: X = 821821.66; Y = 820493.99

Sampling Point WM2: X = 822034.44; Y = 820369.10

Sampling Point WM3: X = 821839.52; Y = 820377.60

Sampling Point WM4: X = 821932.82; Y = 820278.32

Sampling Point WM5: X = 821915.76; Y = 820184.51

3.6 Compliance Monitoring Frequency and Duration

Monitoring data will be collected once per week during the first year of operation of the WRC. If there are repeated low levels of pollution, the frequency and parameters may be reduced subject to agreement with the EPD.

3.7 Compliance Assessment

In order to maintain the beneficial uses for the lake (irrigation and recreation) it is necessary that the water quality be maintained above certain standards. The water quality standards for the Artificial Lake of the Water Recreation Centre at Penny’s Bay have been extracted from Table 5.9h of the EIA Report (Register No.: AEIAR-032/2000) and the Environmental Permit No. EP-138/2002/C. Table 3.1 provides details of the water quality standards while Table 3.2 gives the action and limit levels. For parameters without Water Quality criteria, they will be assessed by trend analysis i.e. by comparing several consecutive monitoring results and determining whether a trend of increasing concentration is occurring over time. When it is determined by the ETL and verified by the IEC that there is a trend of increasing concentrations of pollutants in the lake water, the actions triggered by exceedance of Action Level as listed in the Event Action Plan (Table 3.3) will be undertaken. If there are repeated low levels of pollution, the frequency and parameters may be reduced subject to agreement with the EPD.

Table 3.1 Water Quality Standards

Water Quality Parameter	Standard
(a) Aesthetic appearance	· no objectionable odours or discolouration of waters;
	· no tarry residues, floating wood, articles made of glass, plastic or rubber;
	· no visible mineral oil or lasting foam on the surface;
	· no recognisable sewage-derived debris;
	· no floating, submerged and semi-submerged objects of a size likely to cause interference with the free movement of vessels or cause damage to vessels; and
	· no objectionable deposits.
(b) Bacteria	<180 cfu 100 mL^-1 of E.coli, measured as geometric mean.
(c) Dissolved oxygen	>4 mg L^-1
(d) pH	within the range of 6 - 9
(e) Temperature	No discharges or human activities shall cause the natural daily temperature range to change by more than 2^oC
(f) Salinity	No discharges or human activities shall cause the natural daily temperature range to change by more than 10%
(g) Suspended solids	< 25 mg L^-1, measured as annual median
(h) Ammonia	< 0.021 mg L^-1, as unionised form, calculated as annual average.
(i) Nutrient	Not to be present in quantities sufficient to cause excessive or nuisance growth of algae or other aquatic plants.
(j) 5-day BOD	<5 mg L^-1
(k) COD	<30 mg L^-1
(l) Dangerous substances	Not in a quantity sufficient to pose a risk to any beneficial uses of the aquatic environment

Table 3.2 Action and Limit Levels

Parameter	Action Level	Limit Level
DO	< 4.2 mg/L	> 4 mg/L
pH	< 6.3 or > 8.5	Within the range 6-9
Temperature	N/A	Within a daily range of 2^oC
SS	< 23.75 mg/L, measured as annual median	< 25 mg/L measured as annual median
Ammonia Nitrogen	< 0.01995 mg/L for unionised form, as annual average	< 0.021 mg/L for unionised form, as annual average
E. Coli	< 171 cfu per 100mL, geometric mean for last 5 measurements	< 180 cfu per 100mL, geometric mean for last 5 measurements
5-day BOD	< 4.75 mg/L	< 5 mg/L
COD	< 28.5 mg/L	< 30 mg/L

3.8 Event and Action Plan

In the event that one or more of the water quality parameters exceed the limit level then the follow actions given in Table 3.3 should be taken.

Table 3.3 Event and Action Plan

Exceedance	ETL	HKITP	IEC
Action Level
1. Exceedance for one sample	1. Repeat in-situ measurement to confirm findings. 2. Identify the source(s) of impact (e.g. intake water). 3. Inform HKITP and IEC. 4. Check monitoring data, all monitoring equipment and monitoring methods; consider changes of monitoring methods. 5. Discuss mitigation measures with HKITP and IEC. 6. Repeat measurement on next day of exceedance.	1. Discuss with IEC and ETL on WRC operations or any changes to the operations that may have an impact on the water quality. 2. Rectify unacceptable practice and propose mitigation measures. 3. Make agreement on the mitigation measures to be implemented. 4. Implement the agreed mitigation measures.	1. Discuss with ETL and HKITP on WRC operations or any changes to the operations that may have an impact on the water quality, and discuss possible mitigation measures. 2. Review proposals on mitigation measures by HKITP. 3. Assess the effectiveness of the implemented mitigation measures.
2. Exceedance for two or more consecutive samples	1. Repeat in-situ measurement to confirm findings. 2. Identify the source(s) of impact (eg intake water). 3. Inform HKITP and IEC. 4. Check monitoring data, all monitoring equipment and monitoring methods; consider changes of monitoring methods 5. Discuss mitigation measures with HKITP and IEC. 6. Ensure mitigation measures are implemented. 7. Prepare to increase monitoring frequency to assess efficacy of remedial measures. 8. Repeat measurement on next day of exceedance.	1. Discuss with IEC and ETL on WRC operations or any changes to the operations that may have an impact on the water quality. 2. Rectify unacceptable practice and propose mitigation measures. 3. Make agreement on the mitigation measures to be implemented. 4. Implement the agreed mitigation measures 5. Assess the effectiveness of the implemented mitigation measures	1. Discuss with HKITP and ETL on WRC operations or any changes to the operations that may have an impact on the water quality, and discuss possible mitigation measures. 2. Review proposals on mitigation measures by HKITP. 3 .Assess the effectiveness of the implemented mitigation measures
Limit Level
1. Exceedance for one sample	1. Repeat measurement to confirm findings. 2. Identify the source(s) of impact (eg intake water). 3. Inform HKITP and IEC. 4. Check monitoring data, all monitoring equipment and monitoring methods; consider changes of monitoring methods 5. Discuss mitigation measures with HKITP and IEC. 6. Ensure mitigation measures are implemented. 7. Increase monitoring frequency to daily until no exceedance of Limit Level.	1. Inform EPD of exceedance. 2. Discuss with IEC and ETL on WRC operations or any changes to the operations that may have an impact on the water quality. 3. Rectify unacceptable practice and propose mitigation measures. 4. Make agreement on the mitigation measures to be implemented. 5. Implement the agreed mitigation measures 6. Assess the effectiveness of the implemented mitigation measures	1. Discuss with HKITP and ETL on WRC operations or any changes to the operations that may have an impact on the water quality, and discuss possible mitigation measures. 2. Review proposals on mitigation measures by HKITP. 3. Assess the effectiveness of the implemented mitigation measures
2. Exceedance for two or more consecutive samples	1. Repeat measurement to confirm findings. 2. Identify the source(s) of impact (eg intake water). 3. Inform HKITP and IEC. 4. Check monitoring data, all monitoring equipment and monitoring methods; consider changes of monitoring methods 5. Discuss mitigation measures with HKITP and IEC. 6. Ensure mitigation measures are implemented. 7. Increase monitoring frequency to daily until no exceedance of Limit Level for two consecutive days.	1. Inform EPD of exceedance. 2. Discuss with IEC and ETL on WRC operations or any changes to the operations that may have an impact on the water quality. 3. Rectify unacceptable practice and propose mitigation measures. 4. Make agreement on the mitigation measures to be implemented. 5. Implement the agreed mitigation measures 6. Assess the effectiveness of the implemented mitigation measures 7. Consider to slow down or to stop all or part of the water-based activities until no exceedance of Limit level.	1. Discuss with HKITP and ETL on WRC operations or any changes to the operations that may have an impact on the water quality, and discuss possible mitigation measures. 2. Review proposals on mitigation measures by HKITP. 3. Assess the effectiveness of the implemented mitigation measures

4. waste Management

The waste management during the operation of the WRC has been detailed in a Waste Management Plan submitted separately to EPD.

Waste audits will be conducted periodically to ensure the wastes arising from the operation of the WRC are handled, stored, collected, disposed of in accordance with the waste management plan.

The record of waste handling and disposal will be reported in the monthly EM&A report. Since the waste management of the WRC will be undertaken as part of the overall Theme Park Resort waste management scheme, it may be impractical to isolate the reporting of the amount of waste handled in the WRC. In this event, the reporting of the waste handling and disposal for the WRC will be provided in the Theme Park EM&A report and it will be stated clearly in the WRC EM&A report of the reporting arrangement.

5. AUditing

5.1 Site Inspections

Site inspections provide a direct means to track and ensure the enforcement of specified environmental protection and pollution control measures. The ETL will undertake site inspections at regular intervals to ensure that the compliance of the conditions of the EP and relevant EIA findings and recommendations are being checked and audited. Additionally, the ETL shall be responsible for defining the scope of the inspections, detailing any deficiencies that are identified, and reporting any necessary action or mitigation measures that were implemented as a result of the inspection.

The ETL will carry out site inspections at least once per week, the focus of which will include:

· the general environmental conditions in the vicinity of the WRC; and

· the measures recommended in the implementation schedule of the EIA report and the EPs applicable to HKITP’s operation of the WRC, which are summarized in Table 5.1 below.

During such inspections, the ETL may make reference to any or all of the following:

· the EIA Report and its EM&A recommendations on environmental protection and pollution control mitigation measures;

· ongoing results of the EM&A programme;

· the relevant environmental protection and pollution control laws; and

· results of previous site inspections undertaken.

Following each such inspection, the ETL will: -

· provide the audit results and the associated recommendations to the relevant operations manager as appropriate, for reference and for taking of immediate action

Ad hoc site inspections will also be carried out by the ETL if significant environmental problems are identified during the regular inspections. Inspections may also be conducted subsequent to receipt of an environmental complaint, or as part of the associated investigation work.

5.2 Environmental Complaint

The following procedures apply when environmental complaints are received:

· all enquiries concerning the environmental performance of the WRC, irrespective of how they are received, must be immediately directed to the ETL and HKITP; and

· other formal written complaints will be referred to the ETL, who will co-ordinate investigations, in accordance with procedures to be set up by the ET for handling, investigation and record of same.

The ETL will implement the following complaint investigation procedures upon receipt thereof: -

· ETL will inform HKITP immediately, verbally and follow up in writing, upon receipt of all enquiries and complaints directed to the ET, providing sufficient details on the locations, nature and date of the enquiries/complaints, originator(s) of the enquiries/complaints, originator(s)’ contact number and address, and other relevant details;

· ETL will log the details of the complaints onto the complaint database;

· ETL will investigate and identify the source of the problem and to determine its validity, and to review the reasons for and the implications of enquiries/complaints including review of pollution sources and operation procedures;

· ETL will consider if additional monitoring is necessary, to verify the existence and severity of the alleged complaint;

· ETL will propose and discuss with HKITP their recommendations of actions to be taken to address/mitigate against the enquiries/complaints, and any follow-up procedures.

· ETL will record each complaint, investigation, subsequent actions and results in the monthly EM&A Reports, as per the reporting guidelines in Section 5.

.

6. REPORTING

6.1 General

In accordance with the requirement of the environmental Permits (EP-097/2001/B & EP-138/2002/C), the following reporting mechanism will be put in place:-

Four hard copies and one soft copy of the monitoring reports shall be deposited with the Director within two weeks after the completion of each monitoring. The reports shall be certified by the IEC before deposit with the Director. If there are repeated non-compliances with the agreed water quality standards for the Water Recreation Centre recorded in the monitoring, the monitoring programme shall be continued after the first year operation as directed by the Director

Electronic Reporting of EM&A Information

To facilitate public inspection of the monthly EM&A Reports via the EIA Ordinance Internet Website and at the EIA Ordinance Register Office, electronic copies of these Reports shall be prepared in Hyper Text Markup Language (HTML) (version 4.0 or later) and in Portable Document Format (PDF version 4.0 or later), unless otherwise agreed by the Director and shall be submitted at the same time as the hard copies as described in Conditions 5.3 and 5.4 of this Permit. For the HTML version, a content page capable of providing hyperlink to each section and sub-section of the EM&A Reports shall be included in the beginning of the document. Hyperlinks to all figures, drawings and tables in the EM&A Reports shall be provided in the main text from where the respective references are made. All graphics in the report shall be in interlaced GIF format unless otherwise agreed by the Director. The content of the electronic copies of these Reports shall be the same as the hard copies.

The Permit Holder shall, set up a dedicated web site and notify the Director in writing the internet address where the environmental monitoring and project data is to be placed, within six weeks after the commencement of the Project. All environmental monitoring results described in Condition 7.1 above shall be made available to the public via a dedicated web site to be set up by the Permit Holder in the shortest possible time and in no event later than 2 weeks after the relevant environmental monitoring data are collected or become available, unless otherwise agreed with the Director.

The internet website as described in Condition 7.2 above shall enable user-friendly public access to the monitoring data and project data including the EIA report and the environmental permit(s) and project profile of the Project. The internet website shall have features capable of:-

(a) providing access to all environmental monitoring data collected since the commencement of work;

(b) searching by date;

(c) searching by types of monitoring data (air quality and construction waste); and

(d) hyperlinks to relevant monitoring data after searching;

or otherwise as agreed by the Director

6.2 Baseline Monitoring Report

Baseline Monitoring Report is not required in the environmental permits EP-097/2001/B & EP-138/2002/C and EIA (Annex N).

6.3 Monthly EM&A Reports

The results and findings of all EM&A work required by this EM&A Plan will be recorded in the “Monthly EM&A Reports” prepared by ETL and verified by IEC. The reports will be submitted to EPD within two weeks after the end of the reporting month.

The first Monthly EM&A Report shall include the following: -

· an executive summary (1-2 pages) describing and/or providing: -

- Breaches of A/L Levels;

- Complaint Log;

- notifications of any summons and successful prosecutions;

- reporting changes; and

- future key issues; and

· Basic Project Information, including: -

- Project organisation including key personnel contact names and telephone numbers;

- management structure;

· Environmental Status, including: -

- description of the location of any environmental sensitive receivers and monitoring and control stations

· Summary of EM&A requirements, including: -

- A/L Level monitoring parameters;

- environmental quality performance limits (A/L Levels);

- Event-Action Plans;

- environmental mitigation measures, as recommended in the EIA Report; and

· Implementation Status

Advice on the implementation status of environmental protection and pollution control/ mitigation measures, as recommended in the project EIA study report, summarised in the updated implementation schedule.

· Monitoring Results for monitoring undertaken with the following information: -

- monitoring methodology;

- name of laboratory and types of equipment used and calibration details;

- parameters monitored;

- monitoring locations (and depth/height);

- monitoring date, time, frequency, and duration;

- weather conditions during the period;

- graphical plots of trends of monitored parameters in the month annotated against;

- the major activities being carried out on-Site during the period;

- weather conditions that may affect the results; and

- any other factors which might affect the monitoring results;

- QA/QC results and detection limits, including: -

· report on non-compliance, complaints, notifications of summons and successful prosecutions

- record of all non-compliance (exceedances) of the environmental quality performance limits (A/L Levels);

- record of all complaints received (written or verbal), including locations and nature of complaint investigation, liaison and consultation undertaken, actions and follow-up procedures taken, results and summary;

- record of notifications of summons and successful prosecutions for breaches of the 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-compliance, 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.

· The subsequent Monthly EM&A Reports shall include the following:

· an executive summary (1-2 pages) describing and/or providing: -

- Breaches of A/L Levels;

- Complaint Log;

- notifications of any summons and successful prosecutions;

- reporting changes; and

- future key issues; and

· Environmental Status, including: -

- description of the location of any environmental sensitive receivers and monitoring and control stations for any monitoring undertaken by Contractor; and

· Implementation Status – advice on the implementation status of environmental protection and pollution control/mitigation measures, including licence status;

· Monitoring Results for monitoring undertaken with the following information: -

- monitoring methodology;

- name of laboratory and types of equipment used and calibration details;

- parameters monitored;

- monitoring locations (and depth/height);

- monitoring date, time, frequency, and duration;

- weather conditions during the period;

- graphical plots of trends of monitored parameters in the month annotated against;

- the major activities being carried out on-Site during the period;

- weather conditions that may affect the results; and

- any other factors which might affect the monitoring results;

- QA/QC results and detection limits, including: -

· report on non-compliance, complaints, notifications of summons and successful prosecutions

· record of all noncompliance (exceedances) of the environmental quality performance limits (A/L Levels);

· record of all complaints received (written or verbal), including locations and nature of complaint investigation, liaison and consultation undertaken, actions and follow-up procedures taken, results and summary;

· record of notifications of summons and successful prosecutions for breaches of the 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-compliance, 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.

· Appendix

- AL levels

- Graphical plots of trends of monitored parameters at key stations over the past four reporting periods for representative monitoring stations annotated against the following:

· Major activities being carried out on site during the period

· Weather conditions during the period

· Any other factors which might affect the monitoring results

6.4 Datakeeping

Documentation such as the monitoring field records, laboratory analysis records, site inspection forms etc. are not required to be included in the monthly EM&A reports for submission. However, such documents shall be well kept by the ETL and shall be available for inspection upon request. All relevant information shall be clearly and systematically recorded in the documents. All the documents and data shall be kept for at least one year after the completion of the monitoring period.

Appendix A - Lake Liner Details

1. Specification : The lining for the artificial lake is a high density polyethylene (HDPE) which is impermeable and provided between layers of protective geotextile membranes. The bottom geotextile for the HDPE membrane lining system is “Propex 4516”; and the top geotextile membrane is “SNW600”. As advised by the Designer of the WRC, the bottom and top geotextile membranes serve only as a separation layer between the HDPE liner and aggregates at the lake bottom. Technical details of the lining system are included herein Annex A.

2. Life Span of the Liner : As indicated by the Designer of the WRC lake (see attached Annex B), “the expected lifespan of the liner material can be 50 years in a buried application, as in the case in this project.” For the bottom and top geotextile membranes, as they serve only as separating layers, they are subject to minimum stress or loading after placement.

3. Replacement Programme : Also indicated in Annex B, “the actual need for a complete replacement of the HDPE lining materials, basically involving reconstruction of the lake, should be reviewed in future with regular monitoring of water leakage due to natural deterioration of the material. Thus this initial schedule for complete replacement of the HDPE liner as incorporated into the Operational EM&A plan should be subject to review by the Operator in the future”.

Appendix B – Spill Control Plan

1. Introduction

WRC has a total area of about 30 hectares, comprising an artificial lake of about 12 hectares with passive recreation activities such as non-motorised pedal boats. For effective and efficient operation in case of emergency, 2 motorised speed boats will be maintained on site for patrolling and emergency purposes.

2. Purpose

The purpose of this plan is to provide for a safe and timely response to accidental spills of fuel, petroleum or other pollutants into the artificial lake. It is the purpose of this document to provide a general overview and description of the clean-up procedures.

3. Potential Spill Sources

The primary sources of spill are from (a) refuelling of the 2 motorised boats, and (b) leakage from the fuel storage.

4. Incident Types

It is anticipated that spills at WRC will be classified into 4 categories dependent on the seriousness of the spills; (a) minor land spills, (b) large land spills, (c) minor water spills, and (d) large water spills. Each type of spill may have varying impact on the WRC operation and may require different response levels to achieve resolution of the incident. Normally, the following measures will be adopted:

· stop the pollution at source

· contain the spill

· recover the spill

· dispose of the recovered oil

5. Spill Response Team

HKDL will establish a Spill Response Team to handle minor spill scenarios. The team is responsible for reporting, containment, and clean up of any small spills using onsite equipment and the procedures discussed in the following sections. The Team will comprise personnel from the following HKDL line-of-business:

· Hong Kong Disneyland (HKDL) Security

· WRC Operator

· Hong Kong Disneyland (HKDL) Environmental Affairs Department

6. Government Departments

HKDL will notify the following departments in case of large spills to handle the emergency situations.

· Penny’s Bay Fire Station of Fire Services Department (FSD)

· Pollution Control Unit of Marine Department (MD)

· Penny’s Bay Police Post of Hong Kong Police Force (HKPF)

· Regional Office (West), Environmental Compliance Division of Environmental Protection Department (EPD)

7. Oil Spill Response Equipment

HKITP will liaise with the relevant authorities and determine the need to maintain stock of the appropriate types of spill response equipment on site which may include the following equipment. HKITP will coordinate with FSD and MD for large spills scenarios.

· mop

· degreaser

· absorbent pads

· containment booms

· oil spill response safety gears

8. Oil Spill Response Procedures

Anyone that has discovered a spill incident should notify HKDL Security, report the incident location. Upon receipt of a call reporting the spill, HKDL Security will visit the spill location, determine the nature and severity of the incident, and dispatch the appropriate responders. HKDL Security will cordon off the affected area and coordinate the emergency response.

8.1 Minor Land Spills

· If the spillage does not pose any immediate safety or health concern or have immediate environmental impact, HKDL Security will notify WRC Operator to the scene to clean up the spillages.

· WRC Operator will mop the area with appropriate cleaning solution or degreaser. Care will be strictly exercised to avoid rinsing materials down the drain.

· Only trained personnel with suitable personal protective equipment (PPE) should be allowed to clean up the spillage.

· Once the cleanup is complete, the resultant slurry should be treated as chemical waste and transferred to suitable and compatible containers for temporary storage prior to ultimate disposal at licensed facilities.

· HKDL Environmental Affairs Department will carry out site inspection to confirm that clean-up procedures are properly implemented in accordance with this Plan.

8.2 Large Land Spills

· If it is a large spill, HKDL Security will notify Penny’s Bay Fire Station of FSD and Penny’s Bay Police Post of HKPF for emergency services.

· HKDL Security will coordinate and allocate adequate resources to contain the spill prior to FSD’s arrival. Absorbent pads will be used to cover the spill.

· HKDL Environmental Affairs Department will report the incident to EPD and will conduct inspection with EPD after the completion of clean-up works to confirm that no further action is required.

8.3 Minor Water Spills

· If the spillage does not pose any immediate safety or health concern, HKDL Security will notify WRC Operator to the scene to clean up the spillages.

· WRC Operator will use absorbent pads to soak up the oil near spill source and booms to limit further spreading and to concentrate the oil for recovery.

· WRC Operator will then recover the spillage by manual skimming.

· Once the cleanup is complete, the recovered floating oil should be treated as chemical waste and transferred to suitable and compatible containers for temporary storage prior to ultimate disposal at licensed facilities. The booms will be decontaminated and maintained for future use.

· HKDL Environmental Affairs Department will carry out site inspection to confirm that clean-up procedures are properly implemented in accordance with this Plan.

8.4 Large Water Spills

· If it is a large water spill, HKDL Security will notify MD for emergency services.

· HKDL Security will coordinate and allocate adequate resources to contain the spill prior to MD’s arrival. Booms will be used to limit further spreading and to concentrate the oil for recovery.

· HKDL Environmental Affairs Department will report the incident to EPD and will conduct inspection with EPD after the completion of clean-up works to confirm that no further action is required.

Appendix C – CEDD’s WRC Water Quality Monitoring Plan Prior to Turnover to HKITP

1. The Contractor plans to use raw water as the only source for the filling of the Lake. A water quality sampling will be carried out at Inlet A to test the water quality and check compliance with EIA requirements prior to the commencement of filling the lake. After the first stage of filling (when water level is at approximately +4.5mPD), water samples will be taken at 5 locations (site sketch no. 91800/SK/C3165 refers) across the lake at 1m above the lake bottom (sampling at +3.5mPD). When the water level reaches +6.5mPD, further samples at the 5 locations across the lake will be taken at 1m below the surface (sampling at 5.5mPD). The full parameters as laid down in EIA report Vol. 3 Annex N Section 7.6 will be tested.

2. As filling proceeds, the Contractor may elect to close Irrigation Main X and draw water from the Lake to operate the irrigation system. This would be possible once the level in the Lake reaches +5.5mPD. It is considered that circulation and movement of the water thus created would benefit water quality in the Lake.

3. Upon completion of the filling operation, when the water level reaches +7.5 mPD (expected to be on or around 3 April 2005 in order that test results will be available by 14 April 2005), water samples will be taken at 5 locations and at 3 depths (sampling at +3.5mPD, +5.0mPD and +6.5mPD) to demonstrate that the full body of water in the lake complies with EIA. The full parameters as laid down in EIA report Vol. 3 Annex N Section 7.6 will be tested. The above procedure is as shown in the Contractor’s revised Method Statement.

4. Thereafter and until the WRC is handed over (assume 22 July 2005), carry out lake water monitoring as per Item 5 or 6 as below. The main purpose of testing is to provide a database and to track the change/trend in water quality

5. Option A - Lake is topped up only by raw water at Inlet A and rainwater directly over the lake:

It is envisaged that results would be consistent, unless water is contaminated by unauthorized discharge of pollutant materials into the Lake. The tentative sampling programme, assuming consistent results of previous testing, would be as follows:

· 22 April – 6 May 2005: weekly (3 no). Extent of water sampling and testing as during filling operation (Item 3 above refers);

· 20 May – 1 July 2005: bi-weekly (4 nos). Extent of water sampling and testing as item 3 during filling operation;

· Slightly before 22 July 2005 – final water sampling and testing as item 3 during filling operation. (this is to allow sufficient time for the laboratory test results to be returned to confirm that the full body of water complies with the EIA requirements)

6. Option B – Lake is topped up by water from the stream courses:

· Before water from the stream courses is allowed to be discharged into the Lake, one water sample at each of the 2 sedimentation ponds shall be taken and tested at weekly interval for 2 consecutive weeks. Permission to discharge into the Lake will be subject to the test results complying with the limits and parameters in the EIA report Vol. 3 Annex N Section 7.6 for 2 consecutive weeks. Thereafter, sampling and testing of the stream water shall be carried out at bi-weekly intervals.

· Weekly testing of lake water as item 5(i) during filling operation shall be carried initially and then change to bi-weekly as item 5(ii) if results are consistent.

· If there is any unexpected change in environment which may affect the water quality of the stream water (for example dirt or dust from a hill fire), the weekly testing as item 6(i) above shall be carried out after the condition is stabilized and prior to allowing stream water into the lake.