EXECUTIVE SUMMARY
1.
This is the 3rd
Environmental Monitoring and Audit (EM&A) Report prepared by the
Environmental Team (ET), Cinotech Consultants Ltd., for Contract No. ED/2018/04
“Trunk Road T2 and Infrastructure Works for Developments at the Former South
Apron”. This report summarized the monitoring results and
audits findings of the EM&A programme under the issued Environmental Permit
(EP) No. EP-451/2013 and in accordance with the EM&A Manual (AEIAR-174/2013) during
the reporting month of May 2020.
2.
The main works undertaken
during the reporting period are as follows:
Kai Tak:
·
Contractor’s and SOR (Modular Integrated Construction (MIC)) Site Offices in Portion A3;
·
CLC building fabrication;
·
GI Works for the D-wall works
at the Depressed Road;
·
Depressed Road – Sheet Piling;
·
Depressed Road – Diaphragm
Wall;
·
Launching Shaft / C&C
Tunnel CSM;
·
Launching Shaft / C&C
Tunnel Diaphragm Wall; and
·
Ground improvement works for
PWCL at Portion N3
Cha Kwo Ling:
·
East Portal – temporary support
for Tunnel Portal; and
·
East Portal – Horizontal Ground
Investigation
3.
Implementation of the key
mitigation measures during the reporting period are as follows:
Air Quality
·
Water spraying on haul road and
unpaved area was done to minimize dust generation.
Noise
·
Doors of air compressor were
closed during operation to minimize noise nuisance.
Water Quality
·
Manholes are covered and sealed
properly to prevent discharge to the drainage system.
·
An emergency pumping system was
installed to prevent flooding during heavy rain.
Landscape and Visual
·
Decorative screen hoarding was
erected.
4.
Exceedance of Action/Limit levels
during the reporting month (May 2020) and the investigation results and/or
follow-up actions:
Air Quality Monitoring
·
No Action/Limit Level
exceedance for 24-hour TSP was recorded.
Construction Noise
Monitoring
·
No Action/Limit Level
exceedance for day time construction noise monitoring was recorded in the
reporting month.
Landscape and Visual Monitoring
and Audit
·
1 deficiency of the landscape
and visual impact was recorded in the reporting month. The implementation of
landscape and visual and mitigation measures was checked by a Registered
Landscape Architect during the environmental site inspections.
Table I
Summary of Complaint/Summons/Prosecution in the Reporting Month
|
Event
|
Event Details
|
Follow-up/ Remedial Actions
|
Status/ Remarks
|
|
Number
|
Brief Description
|
|
Complaints
Received
|
0
|
-
|
-
|
-
|
|
Notification
of Summons and Prosecutions Received
|
0
|
-
|
-
|
-
|
|
Public
Engagement Activities
|
0
|
-
|
-
|
-
|
5.
The key works or activities
will be anticipated in the next reporting period are as follows:
Table II
Summary Table for Site Activities in the next Reporting Period
|
Site Activities (June 2020)
|
Key
Environmental Issues
|
|
|
|
1. CKL Junction
Improvement works
2. 132kV
substation ELS and Structure Construction at Portion M1
3. Road S20 –
Road & Drain
4. East Portal –
Blast Door Installation
|
(A) / (B) / (C) / (D)
|
|
|
Note:
(A) Dust
generation from haul road, stockpile of dusty materials, exposed site area, excavation
works and rock breaking activities;
(B) Noisy construction activity such as
rock-breaking activities and piling works;
(C) Runoff from exposed slope or site area;
and
(D) Wastewater and runoff discharge from
site.
|
|
1.1
In 2009, Civil
Engineering and Development Department (CEDD) commissioned a Kai Tak
Development (KTD) – Trunk Road T2 and Infrastructure at South Apron
Investigation. The assignment covers the provision of the Trunk Road T2 and its
connections with the Central Kowloon Route (CKR) at the north apron area and
the Tseung Kwan O – Lam Tin Tunnel (TKOLTT) to the south in the Cha Kwo Ling
area.
1.2
The Trunk Road T2 Project
is one of the designated Projects under Schedule 2 of the EIAO proposed in the
KTD. CEDD submitted the Project Profile (No. PP-379/2009) on 24 March 2009 for
application for an EIA study brief for the Trunk Road T2 Project under the
EIAO. Accordingly, an EIA Study Brief (ESB-203/2009) for the Trunk Road T2
Project was issued on 30 April 2009. The Environmental
Impact Assessment (EIA) Report for the Trunk Road T2 Project was approved under
the Environmental Impact Assessment Ordinance (EIAO) on 19 September 2013. The
corresponding Environmental Permit (EP) was issued on 19 September 2013 (EP
no.: EP-451/2013).
1.3
The Contract No.
ED/2018/04 is the main contract of Trunk Road T2 (“T2 Main Works”) which
comprises mainly the design and construction of a dual two-lane trunk road of
approximately 3.0km long with about 2.7km of the trunk road in form of tunnel;
ventilation and administration buildings, environmental protection and
mitigation works and etc. The EM&A programme under this Contract is
governed by the two EPs (EP-451/2013 and EP-458/2013/C) and two EM&A
Manuals (AEIAR-174/2013 and AEIAR-173/2013). The work areas of the T2 Main
Works are shown in Figure 1 and the works
to be executed under this Contract and corresponding EPs are summarized as
follows:
|
Environmental Permit
|
Works Description
|
|
EP-451/2013 –
Trunk Road T2
|
Trunk Road T2
· Construction of highway and sub-sea tunnel connecting
between Central Kowloon Route and Cha Kwo Ling Tunnel
· Western & Eastern Ventilation Buildings
|
|
EP-458/2013/C –
Tseung Kwan O – Lam Tin Tunnel (TKOLTT) and Associated Works
|
Cha Kwo Ling
Tunnel
Construction of
Cha Kwo Ling Tunnel from the end of Trunk Road T2 to the TKOLTT at the
Eastern Ventilation Building
|
Monitoring Works in Kai Tak under EP-451/2013
1.4
Under
Contract No. KL/2014/03 - Kai Tak Development - Stage 3 Infrastructure Works
for Development at the Southern Part of the Former Runway (“T2 Advance Works”),
the baseline monitoring works in Kai Tak under the EM&A Manual
(AEIAR-174/2013) were conducted by the Environmental
Team (ET) for the Contract No. KL/2014/03 at the
approved relocated monitoring locations (EPD reference: EP2/K19/A/21 pt.5),
namely KTD1a, KTD2a & KER1a. During the impact monitoring period,
monitoring locations KTD 2a and KER 1a were relocated to new locations, i.e.
KTD 2b and KER 1b (EPD reference: ( ) in EP2/K19/A/21 pt. 6 and ( ) in
EP2/K19/A/21 pt. 5) respectively. Location KTD2b was
then further relocated to location KTD2c, the proposal of such relocation was
submitted to EPD on 24 March 2020 and was approved by EPD on 6 April 2020 (EPD
reference: ( ) in EP2/K19/A/21 pt.7). The aforementioned relocation was
effective from 9 April 2020. Impact monitoring within the Kai Tak area shall
be conducted by the ET of Contract No. ED/2018/04 upon cessation of such
monitoring by Contract No. KL/2014/03. The data obtained from the impact
monitoring works completed by the ET of Contract No. KL/2014/03 will be adopted
in this report.
Monitoring
Works in Cha Kwo Ling under EP-451/2013
1.5
The
environmental impact of the remaining works in Cha Kwo Ling, under EP-451/2013,
shall be monitored at the two proposed stations, namely CKL1, CKL2, in
accordance to the EM&A Manual (AEIAR-174/2013). The impact monitoring for the two
proposed stations shall be conducted by the ET of T2 Main Works.
1.6
Cinotech
Consultants Ltd. was designated as the Environmental Team (ET) to
undertake the EM&A works
for “Trunk Road T2 and Infrastructure Works for Developments at the Former
South Apron” (hereinafter called the “Project”).
1.7
This is
the 3rd Monthly EM&A Report which summarises the impact monitoring results and audit
findings for the EM&A programme during the reporting period in May 2020.
1.8
Different Parties with
different levels of involvement in the Project organization include:
·
Permit Holder – Civil
Engineering and Development Department (CEDD)
·
Supervisor Representative –
Hyder-Meinhardt Joint Venture (HMJV)
·
Environmental Team (ET) –
Cinotech Consultants Limited (Cinotech)
·
Independent Environmental
Checker (IEC) – Ramboll Hong Kong Limited (Ramboll)
·
Contractor – Bouygues Travaux
Publics (BTP)
1.9
The key contacts of the Project are shown in Table 1.1.
Table 1.1 Key Project Contacts
|
Party
|
Role
|
Contact
Person
|
Phone No.
|
|
CEDD
|
Permit Holder
|
Mr. Wong Chi Wai, Tommy
|
3842 7111
|
|
HMJV
|
Supervisor Representative
|
Mr. Joe Nam
|
3742 3820
|
|
Cinotech
|
Environmental Team
|
Mr. KS Lee (ETL)
|
2151 2091
|
|
Ms. Karina Chan
|
2157 3880
|
|
Ramboll
|
Independent Environmental Checker
|
Mr. Ray Yan (until 22 May 2020)
|
3465 2836
|
|
Mr. Manson Yeung (from 23 May 2020)
|
3465 2888
|
|
BTP
|
Contractor
|
Mr. Bryan Lee
|
5588 3891
|
1.10
The Organizational Structure for Environmental Management is shown in Figure 1.2.
1.11
The major site activities
undertaken in the reporting month included:
Kai Tak:
·
Contractor’s and SOR (Modular
Integrated Construction (MIC)) Site Offices in Portion A3;
·
CLC building fabrication;
·
GI Works for the D-wall works
at the Depressed Road;
·
Depressed Road – Sheet Piling;
·
Depressed Road – Diaphragm
Wall;
·
Launching Shaft / C&C
Tunnel CSM;
·
Launching Shaft / C&C
Tunnel Diaphragm Wall; and
·
Ground improvement works for
PWCL at Portion N3
Cha Kwo Ling:
·
East Portal – temporary support
for Tunnel Portal; and
·
East Portal – Horizontal Ground
Investigation
1.12
The EM&A programme requires
construction noise, air quality monitoring and environmental site audit, etc.
The EM&A requirements for each parameter are described in the following
sections, including:
·
All monitoring parameters;
·
Action and Limit levels for all
environmental parameters;
·
Event Action Plans;
·
Environmental mitigation
measures, as recommended in the Project EIA Report.
1.13
The advice on the
implementation status of environmental protection and pollution
control/mitigation measures is summarized in Section 10 of this report.
1.14
This report presents the
monitoring results, observations, locations, equipment, period, methodology and
QA/QC procedures of the monitoring parameters of the required environmental
monitoring works and audit works for the Project in May 2020.
1.15
All permits/licenses obtained for the Project are summarized
in Table 1.3.
Table
1.3 Summary of Environmental License
and Permit
|
Permit
/ License No.
|
Valid
Period
|
Status
|
|
From
|
To
|
|
Environmental
Permit (EP)
|
|
EP-451/2013
|
19 Sep 2013
|
N/A
|
Valid
|
|
EP-458/2013/C
|
20 Jan 2017
|
N/A
|
Valid
|
|
Notification pursuant to Air Pollution
(Construction Dust) Regulation
|
|
Ref. No.: 451120
|
20 Nov 2019
|
N/A
|
Valid
|
|
Billing Account for Construction Waste
Disposal
|
|
A/C No.: 7036016
|
09 Dec 2019
|
N/A
|
Valid
|
|
Construction Noise Permit
|
|
CNP No. (For Portion Depressed Road):
GW-RE0287-20
|
28 Apr 2020
|
24 Oct 2020
|
Valid
|
|
CNP No. (For Portion A3): GW-RE0293-20
|
28 Apr 2020
|
25 Oct 2020
|
Valid
|
|
CNP No. (For Launching Shaft and Barging
Point): GW-RE0326-20
|
11 May 2020
|
25 Oct 2020
|
Valid
|
|
CNP No. (For Portion T1): GW-RE0401-20
|
21 May 2020
|
20 Aug 2020
|
Valid
|
|
CNP No. (For Portion Q): GW-RE0337-20
|
08 May 2020
|
07 Nov 2020
|
Valid
|
|
Wastewater Discharge License
|
|
Nil
|
|
Chemical Waste Producer License
|
|
WPN: 5213-286-B2557-03
|
09 Mar 2020
|
N/A
|
Valid
|
2.1
According to the EM&A
Manual (AEIAR-174/2013), 24-hour
Total Suspended Particulates (TSP) monitoring was conducted to monitor the air
quality for this Project. For regular impact monitoring, a sampling frequency
of at least once in every six days at all of the monitoring stations for
24-hour TSP monitoring. In case of complaints, 1-hour TSP monitoring should be
conducted at least three times in every six days when the highest dust impacts
are likely to occur. Appendix A shows the established Action/Limit
Levels for the environmental monitoring works.
2.2
Five designated monitoring
stations were selected for air quality monitoring programme. Table 2.1 describes the air quality
monitoring locations, which are also depicted in Figure 2.
2.3
According to the approved
alternative baseline air quality monitoring locations (EPD reference:
EP2/K19/A/21 pt.5), the original monitoring locations (KTD1, KTD2 and KER1) are
proposed to be replaced by alternative monitoring locations (KTD1a, KTD2a and
KER1a) for air quality monitoring. During the impact monitoring period,
monitoring locations KTD 2a and KER 1a were relocated to new locations, i.e.
KTD2b and KER 1b (EPD reference: (
) in EP2/K19/A/21 pt. 6 and ( ) in EP2/K19/A/21 pt. 5)
respectively. Location KTD2b was then further relocated to location KTD2c, the
proposal of such relocation was submitted to EPD on 24 March 2020 and was
approved by EPD on 6 April 2020 (EPD reference: ( ) in EP2/K19/A/21 pt.7). The
aforementioned relocation was effective from 9 April 2020.
Table 2.1 Air Quality Monitoring Locations
|
Monitoring
Stations
|
Location
|
|
KTD1a
|
Centre of
Excellence in Paediatrics (Children’s Hospital)
|
|
KTD2c
|
G/IC Zone next
to Kwun Tong Bypass (Next to the Kowloon Bay Sewage Interception Station)
|
|
KER1b
|
Site Boundary
at Cheung Yip Street
|
|
CKL1
|
Flat 121 Cha
Kwo Ling Village
|
|
CKL2
|
Flat 103 Cha
Kwo Ling Village
|
2.4
Table 2.2 summarizes the monitoring
parameters, monitoring period and frequencies of impact air quality monitoring.
The monitoring schedule is shown in
Appendix B.
Table 2.2 Frequency and Parameters of Air Quality
Monitoring
|
Monitoring
Stations
|
Parameter
|
Period
|
Frequency
|
|
KTD1a, KTD2c, KER1b, CKL1 & CKL2
|
1-hour TSP
|
0700 – 1900
|
3
times per 6 days (as
required in case of complaints)
|
|
KTD1a, KTD2c, KER1b, CKL1 & CKL2
|
24-hour TSP
|
24 hours
|
Once every 6 days
|
2.5
High Volume Samplers (HVS) in
compliance with the specification stipulated in the EM&A Manual (AEIAR-174/2013),
Section 2.2.1.4, were used to carry out 24-hour TSP monitoring. Direct reading dust
meter were also used to measure 1-hour average TSP levels. The 1-hour sampling
was determined by HVS to check the validity and accuracy of the results
measured by direct reading method.
2.6
Wind data monitoring equipment
was set at rooftop (about 41/F) of Yau Lai
Estate Bik Lai House, Lam Tin for logging wind speed and
wind direction such that the wind sensors were clear of obstructions or
turbulence caused by building. The wind data monitoring equipment was re-calibrated
at least once every six months and the wind directions were divided into 16
sectors of 22.5 degrees each. Wind data is attached in Appendix
D.
2.7
Table 2.3 summarizes the equipment used
for air quality monitoring by the ET for Contract No. KL/2014/03 and
ED/2018/04. Copies of calibration certificates are attached in Appendix C.
Table
2.3 Air Quality Monitoring
Equipment
|
Equipment
|
Model
|
Quantity
|
|
1-hour TSP Dust
Meter
|
Sibata Model No. LD-3B/ LD-5R
|
N/A(1)
|
|
HVS Sampler
|
TISCH Model: TE-5170
|
5
|
|
Calibrator
|
TISCH Model: TE-5025A
|
2
|
|
Wind Anemometer
|
Davis Weather Monitor II, Model no. 7440
|
1
|
Remarks:
(1)
As no complaint of air quality was received, no
impact 1-hour TSP monitoring was conducted.
1-hour TSP Monitoring
Measuring Procedures
2.8
The measuring procedures of the 1-hour dust
meter are in accordance with the Manufacturer’s Instruction Manual as follows:
(Sibata Model No.: LD-3B/LD-5R)
·
The 1-hour dust meter is placed
at least 1.3 meters above ground.
·
Set POWER to “ON” and make sure
that the battery level was not flash or in low level.
·
Allow the instrument to stand
for about 3 minutes and then the cap of the air sampling inlet has been
released.
·
Push the knob at MEASURE
position.
·
Set time/mode setting to [BG]
by pushing the time setting switch.
Then, start the background measurement by pushing the start/stop switch
once. It will take 6 sec. to complete
the background measurement.
·
Push the time setting switch to
change the time setting display to [MANUAL] at the bottom left of the liquid
crystal display. Finally, push the start/stop switch to stop the measuring
after 1 hour sampling.
·
Information such as sampling
date, time, count value and site condition were recorded during the monitoring
period.
Maintenance/Calibration
2.9
The following maintenance/calibration is required for the 1-hour dust meter:
·
Check and calibrate the meter
by HVS to check the validity and accuracy of the results measured by direct
reading method at 2-month intervals throughout all stages of the air quality
monitoring.
24-hour TSP Monitoring
Instrumentation
2.10
High volume samplers (HVS) (TISCH Model: TE-5170) complete with
appropriate sampling inlets was employed for 24-hour TSP monitoring. The sampler was composed of a motor, a filter
holder, a flow controller and a sampling inlet and its performance
specification complied with that required by USEPA Standard Title 40, Code of
Federation Regulations Chapter 1 (Part 50). Moreover,
the HVS also met all the requirements in Section 2.2 of the Annex II Specification.
2.11
The positioning of the HVS
samplers are as follows:
·
A
horizontal platform with appropriate support to secure the samplers against
gusty wind shall be provided;
·
No
two samplers shall be placed less than 2 meter apart;
·
The
distance between the sampler and an obstacle, such as buildings, must be at
least twice the height that the obstacle protrudes above the sampler;
·
A
minimum of 2 metres of separation from walls, parapets and penthouses is
required for rooftop samplers;
·
A
minimum of 2 metres of separation from any supporting structure, measured
horizontally is required;
·
No
furnace or incinerator flue is nearby;
·
Airflow
around the sampler is unrestricted;
·
The
sampler is more than 20 metres from the dripline;
·
Any
wire fence and gate, to protect the sampler, shall not cause any obstruction
during monitoring;
·
Permission
must be obtained to set up the samplers and to obtain access to the monitoring
stations; and
·
A
secured supply of electricity is needed to operate the samplers.
Operating/analytical
procedures for the operation of HVS
2.12
Operating/analytical procedures
for the air quality monitoring are highlighted as follows:
·
Prior to the commencement of
the dust sampling, the flow rate of the high volume sampler was properly set (between 0.6 m3/min.
and 1.7 m3/min.) in accordance with the EM&A manual (AEIAR-174/2013). The flow rate shall be indicated on the
flow rate chart.
·
For
TSP sampling, fiberglass filters with a collection efficiency of > 99% for
particles of 0.3μm diameter were used.
·
The
power supply was checked to ensure the sampler worked properly. On sampling, the sampler was operated for 5
minutes to establish thermal equilibrium before placing any filter media at the
designated air monitoring station.
·
The
filter holding frame was then removed by loosening the four nuts and a weighted
and conditioned filter was carefully centered with the stamped number upwards,
on a supporting screen.
·
The
filter was aligned on the screen so that the gasket formed an airtight seal on
the outer edges of the filter. Then the
filter holding frame was tightened to the filter holder with swing bolts. The
applied pressure should be sufficient to avoid air leakage at the edges.
·
The
shelter lid was closed and secured with the aluminum strip.
·
The
timer was then programmed. Information
was recorded on the record sheet, which included the starting time, the weather
condition and the filter number (the initial weight of the filter paper can be
found out by using the filter number).
·
After
sampling, the filter was removed and sent to the HOKLAS laboratory (ALS
Technichem (HK) Pty Ltd. and Wellab Ltd.) for weighing. The elapsed time was also recorded.
·
Before
weighing, all filters were equilibrated in a conditioning environment for 24
hours. The conditioning environment temperature should be between 25°C and 30°C
and not vary by more than ±3°C; the relative humidity (RH) should be < 50%
and not vary by more than ±5%. A convenient working RH
is 40%.
Maintenance/Calibration
2.13
The following maintenance/calibration is required for the HVS:
·
The
high volume motors and their accessories were properly maintained. Appropriate maintenance such as routine motor
brushes replacement and electrical wiring checking were made to ensure that the
equipment and necessary power supply are in good working condition.
·
High
volume samplers were calibrated at bi-monthly intervals using TE-5025A Calibration Kit
throughout all stages of the air quality monitoring.
Results and Observations
2.14
The impact monitoring works for air quality monitoring locations KTD1a,
KTD2c and KER1b are completed by the ET of Contract No. KL/2014/03, and the
data will be adopted in this report.
2.15
Impact air quality monitoring was conducted at five monitoring stations
as scheduled. The monitoring schedule is shown in Appendix B.
2.16
As no complaint of air quality was received in the reporting month, no
impact 1-hour TSP monitoring was conducted.
2.17
No Action/Limit Level exceedance was recorded for all 24-hour TSP
monitoring in the reporting month.
2.18
The air temperature, relative humidity, and the precipitation data were
obtained from daily extracts of Hong Kong Observatory Climate Information
Service. This weather information for the reporting month is summarized in Appendix D.
2.19
The monitoring data and graphical presentations of 24-hour TSP
monitoring results are shown in Appendix
F.
2.20
According to field observations by ET for Contract No. KL/2014/03 and
ED/2018/04 in the reporting period, the major dust source identified at the
designated air quality monitoring stations are as follows:
Table 2.4 Major Dust Source
during Air Quality Monitoring
|
Monitoring Stations
|
Major Dust Source
|
|
KTD1a - Centre
of Excellence in Paediatrics (Children’s Hospital)
|
·
Loading and
unloading of C&D wastes in the site of Contract No. KL/2014/03;
·
Vehicles movement
in the site of Contract No. KL/2014/03;
·
Construction
activities at the nearby construction sites of New Acute Hospital and Trunk
Road T2; and
·
Road traffic
along Shing Fung Road, Shing Cheong Road, Cheung Yip Street and the Kwun Tong
By-pass.
|
|
KTD 2c - G/IC
Zone next to Kwun Tong Bypass (Next to the Kowloon Bay Sewage Interception
Station)
|
|
KER1b - Site Boundary at Cheung Yip Street
|
|
CKL1 - Flat 121 Cha Kwo Ling Village
|
Road Traffic
along Cha Kwo Ling Road
|
|
CKL2 - Flat 103 Cha Kwo Ling Village
|
Road Traffic
along Cha Kwo Ling Road
|
Comparison
of EM&A Result with EIA Prediction
2.21
The air monitoring data was
compared with the predictions in Table 4.14 of EIA Report, AEIAR-174/2013 (as
approved in 2013) as summarised in Table
2.6.
Table
2.6 Comparison of 24-hr TSP
Monitoring Data with Predictions in EIA Report
|
Monitoring Stations
|
ASR ID
|
Predicted Maximum 24-hr TSP Concentration in EIA Report (AEIAR-174/2013), μg/m3
|
Maximum 24-hr TSP Concentration in the Reporting Month
(May 2020),
μg/m3
|
|
KTD1a - Centre of Excellence in Paediatrics
(Children’s Hospital)
|
KTD3
|
126
|
63
|
|
KTD2c - G/IC Zone next to Kwun Tong Bypass (Next
to the Kowloon Bay Sewage Interception Station)
|
N/A(1)
|
N/A(1)
|
80
|
|
KER1b - Site Boundary at Cheung Yip Street
|
KTD6
|
169
|
68
|
|
CKL1 - Flat 121 Cha
Kwo Ling Village
|
N/A(1)
|
N/A(1)
|
134.2
|
|
CKL2 - Flat 103 Cha
Kwo Ling Village
|
N/A(1)
|
N/A(1)
|
94.3
|
Remarks:
(1)
No 24-hr TSP concentration was predicted in EIA
Report (AEIAR-174/2013)
2.22
In the reporting month, the 24-hour
TSP concentration at KTD1a and KER1b were lower than the prediction in the EIA
Report, AEIAR-174/2013 (as approved in 2013). No
Action/Limit level exceedance was recorded in the reporting period.
Monitoring Requirements
3.1
According to the EM&A Manual (AEIAR-174/2013), construction noise monitoring was conducted to monitor the
construction noise arising from the construction activities. The regular
monitoring frequency for each monitoring station shall be on a weekly basis and
conduct one set of measurements between 0700 and 1900 hours on normal weekdays.
Appendix A shows the established
Action and Limit Levels for the environmental monitoring works.
Monitoring Locations
3.2
Noise monitoring was conducted
at five designated monitoring stations, namely KTD1a, KTD2c, KER1b, CKL1 and
CKL2 in the reporting period. Table 3.1 and
Figure 2 show the locations of these
stations.
3.3
According to the approved
alternative baseline noise monitoring locations (EPD reference: EP2/K19/A/21
pt.5), the original monitoring locations (KTD1, KTD2 and KER1) are proposed to
be replaced by alternative monitoring locations (KTD1a, KTD2a and KER1a) for
noise monitoring. During the impact monitoring period, monitoring
locations KTD 2a and KER 1a were relocated to new locations, i.e. KTD 2b and
KER 1b (EPD reference: ( ) in EP2/K19/A/21 pt. 6 and ( ) in EP2/K19/A/21 pt. 5)
respectively. Location KTD2b was then further relocated
to location KTD2c, the proposal of such relocation was submitted to EPD on 24
March 2020 and was approved by EPD on 6 April 2020 (EPD reference: ( ) in
EP2/K19/A/21 pt.7).
Table
3.1 Noise Monitoring Stations
|
Monitoring Stations
|
Location
|
|
KTD1a
|
Centre of
Excellence in Paediatrics (Children’s Hospital)
|
|
KTD2c
|
G/IC Zone next to
Kwun Tong Bypass (Next to the Kowloon Bay Sewage Interception Station)
|
|
KER1b
|
Site Boundary
at Cheung Yip Street
|
|
CKL1
|
Flat 121 Cha
Kwo Ling Village
|
|
CKL2
|
Flat 103 Cha
Kwo Ling Village
|
Monitoring
Parameters, Frequency and Duration
3.4
Table 3.2 summarizes the monitoring
parameters, frequency and total duration of monitoring. The noise monitoring schedule is shown in Appendix B.
Table
3.2 Frequency and Parameters of
Noise Monitoring
|
Monitoring Stations
|
Time
Period
|
Duration
|
Frequency
|
Parameter
|
Measurement
|
|
KTD1a
|
0700-1900 hrs on normal weekdays
|
30 minutes
|
Once per week
|
L10(30 min.)
dB(A)
L90(30 min.)
dB(A)
Leq(30 min.)
dB(A)
|
Façade Measurement
|
|
KTD2c
|
Free Field Measurement
|
|
KER1b
|
Free Field Measurement
|
|
CKL1
|
Free Field Measurement
|
|
CKL2
|
Free Field Measurement
|
Monitoring Equipment
3.5
Integrating Sound Level Meter
was used for impact noise monitoring. The meters were Type 1 sound level meter
capable of giving a continuous readout of the noise level readings including
equivalent continuous sound pressure level (Leq) and percentile
sound pressure level (Lx) that also complied with International
Electrotechnical Commission Publications 651:1979 (Type 1) and 804:1985 (Type
1) specifications. Table 3.3 summarizes the noise monitoring equipment
being used by the ET for Contract No. KL/2014/03 and ED/2018/04 within the
reporting period. Copies of calibration certificates are attached in Appendix G.
Table
3.3 Noise Monitoring Equipment
|
Equipment
|
Model
|
Quantity
|
|
Integrating Sound Level Meter
|
Casella CEL-63X Series
|
2
|
|
BSWA308
|
1
|
|
SVAN 959
|
1
|
|
Calibrator
|
Casella CEL-120/1
|
2
|
|
ST-120
|
2
|
Monitoring
Methodology and QA/QC Procedure
3.6
The monitoring procedures are
as follows:
·
The monitoring station was normally be at a point 1m from the exterior
of the sensitive receivers building façade and be at a position 1.2m above the
ground.
·
For free field measurement, the
meter was
positioned away from any nearby reflective surfaces. All records for free field noise levels were
adjusted with a correction of +3 dB(A).
·
The battery condition was checked to ensure the correct functioning of
the meter.
·
Parameters such as frequency
weighting, the time weighting and the measurement time were set as follows:
-
Frequency weighting: A
-
Time weighting: Fast
-
Time measurement: 30 minutes
·
Prior to and after each noise
measurement, the meter was calibrated using a Calibrator for 94.0 dB at 1000
Hz. If the difference in
the calibration level before and after measurement was more than 1.0 dB, the
measurement would be considered invalid and repeat of noise measurement would
be required after re-calibration or repair of the equipment.
·
The wind speed was frequently
checked with the portable wind meter.
·
At the end of the monitoring
period, the Leq, L90 and L10 were recorded.
In addition, site conditions and noise sources were recorded on a standard record sheet.
·
Noise monitoring would be
cancelled in the presence of fog, rain, and wind with a steady speed exceeding 5 m/s, or wind with gusts exceeding 10 m/s. Supplementary monitoring would be provided to ensure sufficient data
would be obtained.
3.7
The microphone head of the
sound level meter and calibrator were cleaned with a soft cloth at quarterly
intervals.
3.8
The sound level meter and
calibrator were checked and calibrated at yearly intervals.
3.9
Immediately prior to and
following each noise measurement the accuracy of the sound level meter was
checked using an acoustic calibrator generating a known sound pressure level at
a known frequency. Measurements were accepted as valid only if the calibration
levels from before and after the noise measurement agree to within 1.0 dB.
Results
and Observations
3.10 The data obtained from the impact monitoring works completed by the
ET of Contract No. KL/2014/03 will be adopted in this report for noise
monitoring locations KTD1a, KTD2c and KER1b.
3.11
Impact noise monitoring was
conducted at five monitoring stations as scheduled. The monitoring schedule is
shown in Appendix B. No Action/Limit
Level exceedance was recorded for all construction noise monitoring in the
reporting month.
3.12
Noise monitoring results and
graphical presentations are shown in Appendix
H.
3.13
According to field observations
by ET for Contract No. KL/2014/03 and ED/2018/04 in the reporting period, the
major noise sources identified at the noise monitoring stations are shown in Table 3.4.
Table 3.4 Other Noise Source Identified during
Noise Monitoring
|
Monitoring Stations
|
Major Noise Source
|
|
KTD1a
|
·
Construction
activities (Loading and unloading of C&D waste, travel of vehicles, use
of PME and other plants, and other construction activities) in the site of
Contract No. KL/2014/03; and
·
Road traffic
along Shing Fung Road and Shing Cheong Road.
|
|
KTD2c
|
·
Road
traffic along the Kwun Tong By-pass; and
·
Non-project
related construction activities at the nearby construction sites of New Acute
Hospital and Trunk Road T2.
|
|
KER1b
|
·
Construction
activities (Loading and unloading of C&D waste, travel of vehicles, use
of PME and other plants, and other construction activities) in the site of
Contract No. KL/2014/03;
·
Road traffic
along Cheung Yip Street; and
·
Construction
activities at the nearby construction sites of New Acute Hospital and Trunk
Road T2.
|
|
CKL1
|
Road Traffic
along Cha Kwo Ling Road
|
|
CKL2
|
Road Traffic
along Cha Kwo Ling Road
|
.
3.14
The baseline noise level and
the Noise Limit Level at each designated noise monitoring station are presented
in Table 3.5.
Table 3.5 Baseline Noise Level and Noise Limit
Level for Monitoring Stations
|
Monitoring Stations
|
Baseline Noise Level, dB (A)
(at 0700 – 1900 hrs on normal weekdays)
|
Noise Limit Level, dB (A) (at 0700 – 1900
hrs on normal weekdays)
|
|
KTD1a
|
78
|
75
|
|
KTD2c
|
64
|
|
KER1b
|
65
|
|
CKL1
|
72.4
|
|
CKL2
|
71.4
|
Comparison of EM&A Result with EIA
Prediction
3.15
The noise monitoring data was
compared with the predictions in Table 5.13 of EIA Report (AEIAR-174/2013) as
summarised in Table 3.6.
Table 3.6
Maximum Predicted Mitigated Construction Noise Levels in EIA Report
|
Monitoring Stations
|
NSR ID
|
Maximum Predicted Mitigated Construction Noise
Levels in EIA Report (AEIAR-174/2013), dB(A)
|
Maximum Construction Noise Levels in
the Reporting Month
(May 2020),
Leq (30min) dB(A)
|
|
KTD1a - Centre
of Excellence in Paediatrics (Children’s Hospital)
|
KTD1
|
74
|
68
|
|
KTD2c - G/IC Zone next to Kwun Tong Bypass (Next to the
Kowloon Bay Sewage Interception Station)
|
N/A(1)
|
N/A(1)
|
75
|
|
KER1b - Site
Boundary at Cheung Yip Street
|
KER1
|
75
|
74
|
|
CKL1 - Flat 121 Cha Kwo Ling Village
|
CKL4
|
71
|
73.4
|
|
CKL2 - Flat 103 Cha Kwo Ling Village
|
CKL5
|
69
|
68.9
|
Remarks:
(1)
No Maximum Predicted Mitigated Construction Noise
Levels was predicted in EIA Report (AEIAR-174/2013)
3.16
The results at CKL1 was higher than
the maximum predicted mitigated construction noise level in the EIA Report,
AEIAR-174/2013 (as approved in
2013), this may be due to fluctuations of traffic flow
along Cha Kwo Ling Road throughout the day. The results at KTD1a, KER1b and
CKL2 were lower than the maximum predicted noise level in the EIA Report. No
Action / Limit level exceedance was recorded in the reporting period.
4
Water quality
4.1
According to Section 4.3.1.1 of
EM&A Manual (AEIAR-174/2013), no water quality monitoring is required
during the construction phase.
4.2
According to Section 4.3.1.5 of
EM&A Manual (AEIAR-174/2013), compliance site audits are to be undertaken
by the Engineer and ET and escorted by the Contractor to ensure that a valid
discharge license has been issued by the EPD prior to the discharge of the
effluent from the construction activities of the Project site. Monitoring of
the quality of the treated effluent from the works areas should be carried out
in accordance with the Water Pollution Control Ordinance (WPCO) license. The
audit results reflect whether the effluent quality is in compliance with the
discharge license requirements, the summaries of site audits are attached in Appendix I.
4.3
In the event of non-compliance
the responsibilities of the relevant parties is detailed in the Event / Action
plan attached in Appendix J.
5.1
According to Section 5.3.1.1 of EM&A Manual (AEIAR-174/2013), ET will be required to undertake audit of good site practice for
habitat protection as detailed below. The summaries of site audits are attached
in Appendix I.
·
Avoid damage and disturbance to
the remaining and surrounding natural habitat;
·
Ensure placement of equipment
is within designated areas within the existing disturbed land;
·
Ensure construction activities
are restricted to within the proposed works boundary;
·
Ensure spoil heaps are be
covered at all times;
·
Ensure that disturbed areas are
reinstated immediately after completion of the works; and
·
Ensure enhancement planting
works undertaken.
6.1
According to Section 6.3.1.2 of EM&A Manual (AEIAR-174/2013), no specific fisheries monitoring and audit programme is required
during the construction phase.
6.2
The implementation of the water
quality mitigation measures stated in the Water Quality Impact Assessment
(Refer to Section 6 of the EIA Report (AEIAR-174/2013)) will be audited as part of the EM&A procedures during the
construction period and the details are presented in Section 4.2 of this Report. The summaries of site audits are
attached in Appendix I.
7.1
According to the EM&A Manual (AEIAR-174/2013), a series of mitigation measures were recommended to ameliorate the
landscape and visual impacts of the Project. The mitigation measures for
construction stage are summarized in Table
7.1 below and provided in Appendix K:
Table
7.1 Construction Phase Landscape and
Visual Mitigation Measures
|
ID No.
|
Landscape and Visual
Mitigation Measure
|
|
CM1
|
All works shall be carefully designed to minimize
impacts on existing landscape resources and visually sensitive receivers. Existing
trees within works area shall be retained and protected.
|
|
CM2
|
Existing trees of
good quality and condition that are unavoidably affected by the works should
be transplanted.
|
|
CM3
|
Not used.
|
|
CM4
|
Not used.
|
|
CM5
|
Large temporary stockpiles of excavated material
shall be covered with unobtrusive sheeting to prevent dust and dirt
spreading to adjacent landscape areas and vegetation, and to create a neat and tidy
visual appearance.
|
|
CM6
|
Construction plant and building material shall be
orderly and carefully stored in order to create a neat and tidy visual appearance
|
|
CM7
|
Erection of decorative screen hoarding should be
designed to be compatible with the existing urban context.
|
|
CM8
|
All lighting in construction site shall be carefully
controlled to minimize light pollution and night-time glare to nearby residences
and GIC user. The contractor shall consider other security measures, which shall
minimize the visual impacts.
|
7.2
A specialist Landscape
Sub-Contractor should be employed by the Contractor for the implementation of
landscape construction works and subsequent maintenance operations during the
establishment period. It is proposed that the planting works will be on-site
and the planting should be completed during the construction contract. The
monitoring of the planting establishment should be undertaken for a 12 month
period which could extend throughout the Contractor’s one-year maintenance
period, which will be within the first operational year of the Project.
7.3
All measures undertaken by both
the Contractor and the specialist Landscape Sub-Contractor during the
construction phase and first year of the operational phase shall be audited by
a Registered Landscape Architect (RLA), as a member of the Environmental Team
(ET), on a regular basis to ensure compliance with the intended aims of the
measures. To fulfil the aforementioned requirements, on-site landscape and
visual mitigation measures were audited by RLA in the reporting month.
7.4
According to Section 7.3.1.2 of
the EM&A Manual (AEIAR-174/2013), site audits shall be undertaken at least
once every two weeks throughout the construction period to monitor and audit
the timely implementation of landscape and visual mitigation measures within
the site boundaries of this Project.
7.5
The broad scope of the audit is
detailed below but should also be undertaken with reference to the more
specific checklist provided in Table 7.2.
The summaries of site audits are attached in Appendix I:
·
The extent of the agreed works areas should be
regularly checked during the construction phase. Any trespass by the Contractor
outside the limit of the works, including any damage to existing trees and soft
landscape areas shall be prohibited;
·
the progress of the engineering works should
be regularly reviewed on site to identify the earliest practical opportunities
for the landscape works to be
undertaken;
·
all existing trees and vegetation within the
study area which are not directly affected by the works are retained and
protected;
·
the methods of protecting existing vegetation
proposed by the Contractor are
acceptable
and enforced;
·
preparation, lifting transport and re-planting
operations for any transplanted trees;
·
all landscaping works are carried out in
accordance with the specifications;
·
the planting of new trees, shrubs, groundcover,
climbers, ferns, grasses and other
plans,
together with the replanting of any transplanted trees are carried out
properly
and within the right season; and
·
all necessary horticultural operations and
replacement planting are undertaken
throughout
the Establishment Period to ensure the healthy establishment and
growth
of both transplanted trees and all newly established plants.
Table
7.2 Construction Phase Audit
Checklist for Landscape and Visual Mitigation
Measures
|
Area of Works
|
Items to be Monitored
|
|
Advance planting
|
Monitoring of
implementation and maintenance of planting, and against possible incursion,
physical damage, fire, pollution, surface erosion, etc.
|
|
Protection of all trees and existing soft landscape areas to be
retained
|
Identification and demarcation of trees / vegetation to be
retained, erection of physical protection (e.g. fencing), monitoring against
possible incursion, physical damage, fire, pollution, surface erosion, etc.
|
|
Clearance of existing vegetation
|
Identification and demarcation of trees / vegetation to be
cleared, checking of extent of works to minimise damage, monitoring of
adjacent areas against possible incursion, physical damage, fire, pollution,
surface erosion, etc.
|
|
Pruning of trees
|
Identification and demarcation of trees / vegetation to be pruned,
monitoring of extent of pruning to minimise damage, timing of operations,
implementation of all stages of preparatory and pruning works, and
maintenance of pruned vegetation, etc.
|
|
Plant supply
|
Monitoring of operations relating to the supply of specialist
plant material (including the collecting, germination and growth of plants
from seed) to ensure that plants will be available in time to be used within
the construction works.
|
|
Soiling, planting, etc.
|
Monitoring of implementation and maintenance of soiling and
planting works and against possible incursion, physical damage, fire,
pollution, surface erosion, etc.
|
|
Site fencing and hoarding
|
Implementation and maintenance, to ensure compliance with agreed
designs and check that it matches the surrounding environment and does not
cause visual intrusion.
|
|
Architectural treatment of engineering works.
|
Implementation and maintenance of mitigation measures, to ensure
compliance with agreed designs as applicable.
|
|
Establishment Works
|
Monitoring of implementation of maintenance operations during
Establishment Period.
|
7.6
In the event of non-compliance the
responsibilities of the relevant parties is detailed in the Event / Action plan
attached in Appendix J.
7.7
In the reporting month, 1
deficiency of the landscape and visual mitigation measures was recorded on 21
May 2020, where physical protections (e.g. fencing) were not observed at some
existing trees in the CKL site. The Contractor was reminded immediately to
protect existing trees properly. The follow-up of such deficiency will be
updated in the next reporting month.
8.1
According to Section 8.3.1.1 of EM&A Manual (AEIAR-174/2013), as a precautionary measure, it is recommended that if any
antiquity or supposed antiquity is discovered during the course of the
excavation works undertaken by the Contractor, the discovery shall be reported
to the AMO immediately and all necessary measures taken to preserve it.
8.2
According to Section 8.3.1.2 of
EM&A Manual (AEIAR-174/2013),
no EM&A is required during the construction and
operational phase.
9.1
According to Section 9.3.1.1 of EM&A Manual (AEIAR-174/2013), the effective management of waste arisings during the construction
phase will be monitored through the site audit programme. Regular audits and site inspections should be carried
out by the Engineer, ET and Contractor to ensure that the recommended good site
practices and other mitigation measures are implemented by the Contractor. The summaries
of site audits are attached in Appendix
I.
9.2
According to Sections 9.3.1.3
and 9.3.1.4 of EM&A Manual (AEIAR-174/2013),
documents including licenses, permits, disposal and recycling records should be
reviewed and audited during site audits for the compliance with the legislation
and contract requirements to ensure proper records are being maintained and
procedures undertaken in accordance with the Waste Management Plan.
10.1
Site audits were carried out on
a weekly basis to monitor the timely implementation of proper environmental management
practices and mitigation measures in the Project site. The summaries of site audits are attached in Appendix I.
10.2
Site audits were conducted on
7, 14, 21 and 28 May 2020 in the reporting month. Site inspection of the IEC
was conducted on 14 May 2020. No non-compliance was observed during the site
audit.
10.3
According to Environmental
Permits, the approved EIA Reports (Register No.: AEIAR-174/2013 and
AEIAR-173/2013), and the EM&A Manuals of the Project (AEIAR-174/2013
and AEIAR-173/2013), the mitigation measures detailed
in the documents are recommended to be implemented during the construction
phase. An Environmental Mitigation
Implementation Schedule (EMIS) is provided in Appendix K.
10.4
The ET weekly site inspections
were carried out during the reporting month and the observations and
recommendations are summarized in Table
10.1. Refer to Appendix I for
the site inspection summary reports in the reporting month.
Table 10.1
Observations and Recommendations of Site Audit
|
Parameters
|
Date
|
Observations and Recommendations
|
Follow-up
|
|
Air Quality
|
29 Apr 2020
|
Construction areas (KT
portion) should be watered regularly.
|
Site areas were watered
by the Contractor on 7 May 2020.
|
|
Noise
|
7 May 2020
|
Door of air compressor
should be closed while operating (KT portion).
|
The air compressor
operated with door closed on 14 May 2020.
|
|
Water Quality
|
7 May 2020
|
Manhole should be covered
and sealed (KT portion).
|
Manhole was covered and
sealed with concrete and sand bag on 21 May 2020.
|
|
21 May 2020
|
Water pond was found at
site (CKL portion). Drainage system should be adequately designed for storm
flow.
|
An emergency pumping
system was installed on 28 May 2020.
|
|
Ecology
|
N/A
|
There was no observation
in the reporting period.
|
N/A
|
|
Landscape and Visual
|
21 May 2020
|
Existing tree to be
retained on site (CKL portion) should be protected carefully.
|
To be followed up in the
next reporting period.
|
|
Waste / Chemical
Management
|
N/A
|
There was no observation in
the reporting period.
|
N/A
|
|
Permits /Licences
|
N/A
|
There was no observation
in the reporting period.
|
N/A
|
10.5
The Event and Action Plans for
air quality, construction noise, and landscape and visual are presented in Appendix J.
Air Quality Monitoring
·
No Action/Limit Level
exceedance for 24-hour TSP monitoring was recorded.
Construction Noise
Monitoring
·
No documented complaint on construction
noise was received; no Action Level exceedance for construction noise was
recorded.
·
No Action/Limit Level
exceedance for construction noise monitoring was recorded in the reporting
month.
Landscape and Visual
·
1 landscape and visual
deficiency was recorded.
10.6
According the Section 11.3.2.1
(c) of the EM&A Manual (AEIAR-174/2013), status of required submission
under EP-451/2013 and EP-458/2013/C during the reporting period are summarized
in Table 10.2.
Table 10.2
Status of Required Submission under Environmental Permit
|
EP Condition
|
Submission
|
Submission Date
|
|
EP-451/2013
|
|
Condition 2.3
|
Management Organization
of Main Construction Companies
|
20 January 2020
|
|
Condition 2.4
|
Design Drawing of the
Project
|
20 January 2020
|
|
Condition 2.5
|
Landscape Mitigation
Plan(s)
|
7 May 2020
|
|
Condition 2.10 (a)
|
Supplementary
Contamination Assessment Plan
|
18 December 2015
|
|
Condition 2.10 (b)
|
Supplementary
Contamination Assessment Report
|
6 December 2016
|
|
Condition 3.3
|
Baseline Monitoring
Report (at Kai Tak Area)
|
22 February 2016
|
|
Condition 3.3
|
Baseline Monitoring
Report (at Cha Kwo Ling Area)
|
3 April 2020
|
|
Condition 3.4
|
Monthly EM&A Report
(April 2020)
|
15 May 2020
|
|
EP-458/2013/C
|
|
Condition 2.4
|
Management Organization
of Main Construction Companies
|
3 March 2020
|
|
Condition 2.5
|
Noise Mitigation Plan
|
29 April 2020
|
|
Condition 2.6
|
Waste Management Plan
|
25 April 2020
|
|
Condition 2.7
|
Landscape Mitigation Plan
|
7 May 2020
|
|
Condition 2.10
|
Construction Programme
|
11 May 2020
|
|
Condition 4.3
|
Baseline Monitoring
Report
|
27 October 2016
|
11.1
The summaries of environmental complaint,
warning, summon and notification of successful prosecution for the Project is
presented in Appendix L.
11.2
The summary of exceedance
record in the reporting month is shown in Appendix
M.
11.3
1 deficiency was recorded for
landscape and visual inspections conducted in the reporting month.
Tentative construction
programmes for the next three months are provided in Appendix N.
12.1
Major site activities
undertaken for the coming months are summarized as follows:
·
CKL Junction Improvement works;
·
132kV substation ELS and Structure Construction at
Portion M1;
·
Road S20 – Road & Drain; and
·
East Portal – Blast Door Installation
12.2
Key environmental issues in the
coming months include:
·
Regular watering of construction areas;
·
Doors of air compressors should be closed during
operation;
·
Make sure drainage system is adequately designed to
prevent flooding during periods of heavy rain;
·
Make sure manholes are properly covered and sealed;
and
·
Make sure existing trees are protected properly.
12.3
The tentative environmental
monitoring schedule for the next three months are shown in Appendix B.
13.1
This is the 3rd
Monthly EM&A Report which presents the EM&A works undertaken during the
reporting month in accordance with the EM&A Manual (AEIAR-174/2013) and
the requirement under EP.
Air Quality Monitoring
13.2
No Action/Limit Level exceedance was recorded for 24-hour TSP monitoring
in the reporting month.
Construction Noise Monitoring
13.3
No Action/Limit Level exceedance was recorded for all noise monitoring
in the reporting month.
Site Audit
13.4
4 ET joint weekly environmental
site inspections were conducted in the reporting month.
Complaint, Notification of Summons and Successful Prosecution
13.5
No environmental complaints,
notifications of summons and successful prosecutions were received in the
reporting month.
13.6
According to the environmental
audit performed in the reporting month, the following recommendations were
made:
Air Quality
·
Construction areas should be watered regularly.
Noise
·
Doors of air compressors should
be closed during operation.
Water Quality
·
Manholes should be covered and
sealed properly; and
·
Drainage system should be
adequately designed for storm flow;
Landscape and Visual
·
Existing trees should be protected properly (e.g. via fencing).
