7 Environmental Management Plan (EMP) and

Transcription

Environmental Management Plan
(EMP) and Environmental
Monitoring
7
Environmental
Management
Environmental Monitoring
Plan
(EMP)
7.1
Proposed Environmental Management Plan (EMP)
and
The Environmental Management Plan (EMP) outlined in this chapter establishes a strategy to
manage environmental issues throughout all stages of the development. It also provides a
framework specification upon which the project proponent will set the environmental control
requirements for the proposed project through its tender contract documentation.
This EMP is prepared as a preliminary EMP specification. A final EMP will be prepared after
the EIA approval based on the conditions specified by DOE and before the commencement of
any construction works. This allows comments during the DOE review stage to be taken into
consideration in the final EMP together with the details of the appointed contractor and final,
detailed construction methodology.
7.1.1
Objectives
This EMP is a tool designed to assist the Project Proponent in meeting the requirements of
applicable environmental legislation and regulations in order to achieve best practice
environmental management. It contains a written description of the proposed measures to be
implemented in order to achieve and maintain acceptable levels of environmental impact. In
summary, the objectives of this EMP are:
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
7.1.2
To provide practical and achievable plans for the management of the proposed project,
such that environmental requirements are complied with through monitoring and control
of the predicted impacts;
To provide the Project Proponent and the regulatory authorities with a framework in order
to comply with environmental policies and requirements and confirm that this is happening;
and
To establish an environmental monitoring and audit programme to track environmental
performance, and acts as an early trigger to remediate environmental non-conformance,
if any.
Responsibilities
At the present stage it is anticipated that the EMP implementation will involve the following key
personnel/parties:
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Project Manager (Proponent)
Contractor
Environmental Officer (EO)
Safety, Health and Environment (HSE) Officer
Field Supervisors
Environmental Monitoring (EMP) Consultant
Environmental Auditor
Accredited Laboratory
The roles and responsibilities of the above are described in the following subsections, while
the work flow is indicated in Figure 7.1.
7-1
Figure 7.1
7.1.2.1
EMP Workflow
Project Proponent
The Project Proponent will generally be responsible for:
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7.1.2.2
Ensuring required environmental protection works are included in the relevant tender
documents
Appointment of environmental monitoring consultant and environmental auditor to
implement the EMP
Appointment of the necessary environmental officers, wildlife response management
team, etc.
Ensuring proper and timely submission of relevant environmental reports to the EMP
Consultant for subsequent submission to DOE
Ensuring Contractor(s) fulfil contractual obligations with respect to environmental
protection.
Contractor(s)
The Contractor(s) will generally be responsible for:
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Implementing the approved environmental control and mitigation measures
Compliance with all environmental planning and construction requirements
Complying with all requirements of relevant agencies and their legislation
The key activities and responsibilities involved in the construction are outlined in the following
subsections.
Pre-construction
It is the responsibility of the Construction Contractor to prepare a detailed methods statement
that complies with the conditions of the present EMP; and to provide input to the preparation
of the Final EMP. During the construction phase, the Construction Contractor is also
responsible for reporting detailed work plans for each construction phase to the Environmental
Officer.
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In addition to the environmental considerations, the Construction Contractor is also to consider
the following before commencing work:
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Any best practice measures as prescribed by authorities such as the Department of
Irrigation and Drainage (DID) and the Department of Environment (DOE);
Marine Department requirements in terms of vessel movement and maritime safety; and
Complying with any and all licences and approvals under relevant legislations.
All necessary emergency response requirements, materials and methods and training and
induction to comply with all licenses, approvals and regulations, including:
Marine Navigation Management Plan
Emergency response plan.
During Construction
During construction, the Construction Contractor will be responsible for:
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Reporting detailed work plans for each construction phase to the Environmental Officer
(EO);
Complying will all the provisions of the EMP as applicable; and
Inspecting and monitoring all activities for adherence to proper environmental safeguards
regularly.
This will include routine inspections of the works, reports and/or correspondence relating to
site environmental management issues.
Reporting
The Contractor will be responsible for establishing an Environmental Management File and
associated database for the construction activities that would contain all documentation
pertaining to environmental management of the works. This will be submitted to the Project
Proponent and made available to the Environmental Monitoring Consultant in digital form for
incorporation into the regular Environmental Monitoring Reports to be submitted to the DOE.
All environmental incidents and near misses occurring at work places during Project
implementation period shall be reported immediately to the Project Proponent’s Project
Manager on site. All these incidents / occurrences shall be documented and dealt with in
accordance with the Incident Reporting and Investigation procedures and legislative
requirements.
On-site, the Contractor’s representative shall carry out the initial investigation of any incident
in conjunction with the Contractor’s HSE Officer(s). The Contractor’s Site Manager is
responsible for ensuring that appropriate investigation is conducted and close out actions
implemented as necessary. On-site and all personnel shall be made aware of the incidents
and actions to prevent re-occurrence. Any resulting Environmental / HSE Alerts produced by
the Contractor and their Subcontractors shall be shared with all parties on-site to prevent reoccurrence of similar events.
7.1.2.3
Project Manager
The Project Manager will generally be responsible for the following environmental
management aspects:
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Implementing and enforcing appropriate environmental, safety and health practices at the
Project work area;
Ensuring that all planning on-site considers the safety of personnel and the protection of
the environment;
To ensure compliance with applicable regulations, as outlined in the final approved EMP;
Coordinating and implementing the environmental control measures as detailed in the final
approved EMP;
Assigning on-site environmental personnel to oversee implementation of the mitigation
measures, and ensure compliance with environmental requirements;
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7.1.2.4
Overseeing the Environmental Monitoring Programme;
Liaising with the relevant government departments as required; and
Seeking the advice of the EMP Consultant regarding any environmental issues of concern.
Environmental Officer (EO)
The Environmental Officer (EO) works closely with the appointed contractors (and the EMP
Consultant) to formulate the Final EMP prior to start of construction. This is continued during
the construction phase to allow continuous refining of work methods and procedures to ensure
environmental quality objectives are met, and work schedules and production is optimised.
DOE require the EO to be full time on site. The expected responsibilities of the EO include the
following:
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7.1.2.5
Coordinate implementation of the environmental management programme;
Direct environmental awareness inductions and material distribution;
Perform regular internal audits of sub-Contractor’s implementation on the environmental
protection activities including waste management, housekeeping and erosion and
sediment control measures;
Maintain an independent Environmental Management File and associated database for all
activities pertaining to environmental management of the works, and in particular audit
schedules and outcomes; and
Coordinate environmental incident investigations and report findings to the Project
Manager.
Health, Safety and Environment Officer
The duties of the Health, Safety and Environment (HSE) Officer are as such:
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7.1.2.6
To advise and coordinate all matters pertaining to safety, health and environmental
management associated with the construction activity on-site;
To ensure compliance with applicable legislation and guidelines;
To ensure all emergency control equipment, safety equipment and environmental
protection measures on-site are properly implemented;
To investigate and report environmental incidents and non-conformances to the Project
Manager and the EO;
To ensure good communication between the Project team and government agencies with
respect to the environment matters; and
To collect, update and maintain proper records on safety, health and environmental
incidences.
Field Supervisors
The general responsibilities of the Field Supervisors are as such:
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7.1.2.7
Conduct pre-task evaluations of work scope and the area;
Obtain daily-required permits and ensure compliance to permit conditions;
Ensure employees are trained for their duties as per the project safety program;
Conduct pre-job safety briefings prior to starting work and ensure employee's
understanding;
Conduct specific equipment and personal protective equipment (PPE) inspection;
Actively involve employees in the project safety program;
Enforce project policies and procedures;
Assist in incident investigations.
Environmental Monitoring / EMP Consultant
The general responsibilities of the Environmental Monitoring Consultant are as such:
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7.1.2.8
Oversee the conduct of periodic environmental monitoring to ensure the implementation
of the recommended mitigation measures as per the EIA approval conditions and assess
the impact or efficacy of the mitigation measures;
To provide advice to the Project Manager on related issues arising from the EMP
implementation;
Advise the project proponent on the adequate mitigation measures needed to minimise or
prevent the occurrence of adverse environmental impacts.
Accredited Laboratory
All analyses and reports concerning environmental monitoring/samples shall be carried out by
laboratories accredited under Skim Akreditasi Makmal Malaysia (SAMM).
7.1.2.9
Training and Awareness
In order to effectively implement the measures outlined in the EMP, staff, contractors and
subcontractors need to be made aware of the existence of the EMP and its requirements.
Awareness activities are to include induction training and the logging of same for all staff
outlining all aspects of:
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7.1.3
Safety and security;
Protected wildlife and management procedures;
Responsibilities and reporting procedures on-site;
Equipment operation;
First aid;
Work procedures;
Scheduled waste handling;
Spill response training; and
Awareness of the EMP.
Review and Update of EMP
A copy of the Final EMP will be required to be kept on-site and be easily obtainable by the
public at all times. During the construction works, the Project Proponent’s Project Manager
will hold an additional copy. The EMP should be regularly reviewed in relation to conditions
encountered and updated as appropriate.
7.2
Proposed Monitoring Programmes
The proposed monitoring programme comprises of three types of monitoring, as defined in
Table 7.1. These monitoring programmes cover both the construction and operation phases.
Table 7.1
Types of monitoring programme
Type of Monitoring
Definition
Performance monitoring
Performance monitoring involves monitoring the performance of
environmental management and pollution control systems and
other mitigation measures were ever applicable. This mainly is
based on meeting existing Malaysian Guidelines, Standards and
legislations.
Compliance monitoring
Compliance monitoring aims to ensure the required mitigation
measures are being implemented on site.
Impact monitoring
This monitoring aims to identify actual (residual) impacts, and
hence to determine the efficacy of mitigation measures.
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7.2.1
Performance Monitoring
7.2.1.1
Management of Suspended Sediments during Reclamation and Dredging
(Phase 4)
As set out in Section 6 above the key environmental impacts during the construction phase is
the sediment plumes that are generated when capital dredging and reclamation works are
carried out, and particularly so when undertaken simultaneously. To manage these impacts it
is proposed to use sediment spill control and monitoring (referred to hereafter as feedback
monitoring).
Performance Standard
Performance to the following management objective is required for TSS at Tg. Tuan corals:
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Excess TSS > 25 mg/L for 1-5% of the time; OR
Excess TSS > 10 mg/L for 1-20% of the time; OR
Excess TSS > 5 mg/L for 5-50% of the time.
Feedback Monitoring
Feedback monitoring has been effectively utilised at a number of sites in Southeast Asia. It is
considered international best practice for the environmental control of dredging and
reclamation operations by PIANC (see report on Dredging and Port Construction around Coral
Reefs /1/). The intention of this monitoring and management plan is to ensure that the
suspended sediment limits set above for the sensitive receptors are met, whilst at the same
time allowing the maximum possible dredging rates.
Initial modelling at this EIA stage indicates that a dredging rate of around 20,000 m 3 per day
will meet these objectives; however, the purpose of the feedback monitoring is to ensure
compliance with the performance standards, and this rate may be adjusted through adaptive
management based on the actual site conditions during the dredging (sediment type, season,
waves etc.).
This monitoring and management plan includes the following key elements:
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1
Monitor the dredger location and reclamation activities and measure suspended sediment
concentrations in the overflow water and flow rate to calculate spill volumes and sediment
loads from each dredging cycle that are applied to estimate daily spill volumes. This is
carried out daily and will involve sampling by the dredger contractor of overflow water
from each hopper barge once overflow starts.
2
Monitor suspended sediment concentrations in the vicinity of the project area on a daily
basis during periods when dredging or reclamation is being carried out and online
measurement of suspended concentrations at high frequency (5 to 15 minutes) to ensure
that TSS thresholds are met. If the suspended sediments concentrations are shown to
exceed the allowable limits, the allowable sediment spill is modified to prevent this based
on modelling estimates as set out in (3) below.
3
To carry out predictive modelling of the sediment spills from the dredging and reclamation
activities at least three (3) times a week; based on the current dredging works and
proposed activities. This includes hindcast modelling (past events) to quantify the spatial
and temporal evolution of the sediment plume allowing action to be taken if the prespecified threshold values are being exceeded. The hindcast numerical modelling results
are constantly compared to measured data to confirm the predictions are accurate and
provide a good description of the sediment spill occurring during the dredging and
reclamation activities that have taken place. The forecasting modelling of the sediment
plume allows the spill budget to be adjusted to maximise reclamation and dredging
production, while at the same time meeting environmental quality objectives.
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Monitoring
The basic processes of feedback monitoring and its cyclic nature are illustrated in Figure 7.2.
Figure 7.2
Flow diagram illustrating the feedback monitoring process.
The main advantages of Feedback Monitoring are:
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Control measurements are targeted at the spill from the dredger, the source of the
sediment spill, without the uncertainties normally encountered by only relying on fixed
turbidity sensors at the receptor areas. Such sensor measurements cannot differentiate
between loading produced from the dredging and natural variability in the background
conditions whereas model predictions can and a high degree of accuracy;
Sediment plume models (numerical models) can keep a running balance of cumulative
impact levels based on actual production and measured spill against the pre-determined
threshold limits. Action can then be taken in advance of any negative impacts occurring in
the field;
The use of a sediment plume hindcast model allows complex reclamation and dredging
schedules to be addressed resulting in accurate assessment of cumulative impacts
(reclamation and capital dredging occurring at the same time for example), and the
definitions of spill budgets that are adaptive to changes in area usage, equipment numbers
and equipment size;
The models give a spatial picture at all receptor sites, not just the locations where
instrumentation is deployed as per traditional monitoring methods. Coverage is thus more
rigorous; and
The use of spill measurements and modelling allows the monitoring and management
system to be responsive to changes in conditions (e.g. seasonal effects) and work
schedules, which is not possible utilising traditional impact assessment and monitoring
methods.
7-7
Suspended Sediment Plume Monitoring Stations
Pre-Construction (Before Dredging)
As part of the implementation process of Feedback Monitoring, suspended sediment sampling
shall be carried out to establish a baseline prior to capital dredging works as detailed in Table
7.2.
Table 7.2
Suspended sediment monitoring programme for pre-construction stage
Parameter
Proposed Monitoring Programme
Stations
Frequency
Spatial variability in
suspended sediment
concentration
Six (6) fixed stations for three (3)
depths (i.e. surface, middle,
bottom)
Daily for two (2) weeks
immediately before
reclamation/dredging works
commence to provide a baseline
on background suspended
sediment concentrations
Temporal changes in
suspended solids
concentrations and
turbidity
Two (2) online monitoring
stations
Minimum of two (2) weeks before
the start of reclamation/dredging
works. During this period,
suspended sediment samples
will be taken at these locations to
allow the relationship between
Turbidity and Total Suspended
Sediment Concentrations to be
established.
The feedback numerical modelling shall be run during this period based on the Contractor’s
proposed initial reclamation/dredging rates to set initial sediment load limits
Dredging and Reclamation
During reclamation and dredging works for all phases, the monitoring outlined in Table 7.3 is
recommended. The locations of the monitoring stations are shown in Figure 7.3 while the
coordinates are given in Table 7.5.
Table 7.3
Proposed suspended sediment (SS) plume monitoring during reclamation and dredging
(Phase 4).
Parameter
Proposed Monitoring Programme
Stations
Frequency
Turbidity/TSS
Online instrumentation at two (2)
monitoring points for two (2)
depths (i.e. middle and bottom).
Continuous with minimum of 30”
recording intervals
Suspended sediment
concentration
Six (6) fixed stations for three (3)
depths (i.e. surface, middle,
bottom)
Daily
Suspended sediment
concentration
Two (2) mobile stations at each
reclamation outlet location
(release location from bunded
area):
Daily
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at overflow outlet; and
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within 200 m of outlet.
In addition to the above, monitoring of suspended sediment from dredging activity involves a
number of key activities as detailed in Table 7.4.
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Table 7.4
Suspended sediment monitoring programme for dredging activity
Monitoring Activity
Proposed Monitoring
Monitoring of
Overflow and
Discharge Water
from barges

Suspended sediment concentrations to be measured in the overflow or
discharge water from the TSHD and flow rate calculated to estimate the
sediment load spilled.

Four (4) overflow samples shall be taken from each hopper load; these
shall be equally spaced through the discharge period. The total
suspended sediment concentration will be analysed in these samples.

Initial results of the measured suspended sediment concentrations shall
be available to the Contractor within 48 hours of the sample being
taken.
Forecast / Hindcast
Model
Figure 7.3
The forecast / hindcast model shall be run three (3) times a week during the
reclamation/dredging works.
Locations of the sediment plume monitoring stations during dredging and reclamation
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Table 7.5
7.2.1.2
Geographic coordinates for fixed and online monitoring station in WGS 1984 (decimal
degrees)
Station
Longitude (E°)
Latitude (N°)
Description
S1
102.005585
2.407569
Upstream control station for Sg. Linggi
S2
101.979776
2.392528
Sg. Linggi rivermouth. Sensitive receptor aquaculture
S3
101.94155
2.40656
Tg. Selamat. Sensitive receptor – mussel farm
S4
101.857859
2.403313
Tg. Tuan. Sensitive receptor – hard coral
S5
101.91922
2.35816
Linggi offshore. Sensitive receptor – mixed soft and
hard coral
S6
101.998553
2.359024
Tg. Dahan. Sensitive receptor – hard coral
ON1
101.93163
2.397879
Online turbidity monitoring station north of
reclamation area
ON2
101.976052
2.365511
Online turbidity monitoring station south of
reclamation area
Sewage Treatment Plant (STP) Effluent Monitoring during Operations
Water pollution control monitoring consists of performance monitoring of effluent treatment
system (for treating sewage or industrial effluent). The current project plan includes a new
sewage treatment plant (STP) where the sewage from the proposed development will be
treated and will be discharged through a marine outfall. The treated sewage is to be discharged
following treatment to Standard B of the Environmental Quality (Sewage) Regulations 2009.
Monitoring Schedule
The sewage quality monitoring shall be carried out monthly from the start of the STP operation
as required under Regulation 10 of Environmental Quality (Sewage) Regulations 2009.
Monitoring Stations
Water sample shall be undertaken at the STP marine outfall post all treatment and prior to the
point of discharge as shown in Figure 7.4.
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Figure 7.4
STP treated sewage discharge location.
Parameters
The parameters to be analysed for samples collected from the STP discharge are listed in
Table 7.6, following the Standard B of the Environmental Quality (Sewage) Regulations 2009.
Table 7.6
Standard B, Second Schedule of the Environmental Quality (Sewage) Regulations 2009
Parameter
Unit
Standard B
BOD5 at 20C
mg/L
50
COD
mg/L
200
Total Suspended Solids
mg/L
100
Oil and Grease
mg/L
10
Ammoniacal-N (river)
mg/L
20.0
Nitrate-N (river)
mg/L
50.0
Phosphorous (lake*)
mg/L
10.0
MPN/100mL
300
E.coli#
7-11
# Based
on DOE Notice 3/2014 - May 2014
7.2.2
Compliance Monitoring
7.2.2.1
Compliance with Environmental Requirements
Environmental Legislation
The required environmental legislation to be complied with by the project proponent and its
contractors at all times are detailed in Table 7.7.
Table 7.7
Relevant environmental legislation to be complied with by the project
Sector
Federal Legislation

Environmental Quality Act 1974 (Act 127)

Environmental Quality (Prescribed Activities) (Environmental Impact Assessment)
Order 2015

Environmental Quality (Industrial Effluent) Regulations 2009
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Environmental Quality (Sewage) Regulations 2009
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Merchant Shipping (Oil Pollution) Act 1994 (Act 515)
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Malaysian Maritime Enforcement Agency Act 2004 (Act 633)
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Environmental Quality (Clean Air) Regulations 2014
Noise
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Erosion control
Land Conservation Act 1960 (Revised 1989) (Act 385)
Water
Air
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Order 2015
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Land Development Act 1956 (Revised 1991) (Act 474)
Drainage
Coral
Mangrove
Fisheries
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Order 2015
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Continental Shelf Act 1966 (Act 83)
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Fisheries Act 1985 (Act 317)
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Exclusive Economic Zone Act 1984 (Act 311)
Avifauna
Wildlife Conservation Act 2010 (Act 716)
Marine
megafauna
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Wildlife Conservation Act 2010 (Act 716)
Turtle
Melaka Fisheries (Turtles and Turtle Eggs) Rules 1989
Navigation
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Port Authorities Act 1963 (Revised 1992)
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Merchant Shipping (Oil Pollution) Act 1994 (Act 515)
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Malaysian Maritime Enforcement Agency Act 2004 (Act 633)
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Sector
Federal Legislation
Fisheries
activities
Tourism
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Fishermen’s Association Act 1971 (Act 44)
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Lembaga Kemajuan Ikan Malaysia Act 1971 (Act 49)
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Continental Shelf Act 1966 (Act 83)

Tourism Industry Act 1992 (Act 482)
Physical
development
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Order 2015
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Order 2015
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Land use
Environmental Standards and Guidelines
The relevant environmental standards and guidelines to be adhered to by the project during
construction and operation are detailed in Table 7.8.
Table 7.8
7.2.2.2
Relevant environmental standards and guidelines to be complied with by the project
Component
Standard/Guidelines
Applicable
Limit/Parameters
Water quality – DO, Oil and
grease
Class 2 of MMWQCS
Class 2
General air quality
Malaysian Ambient Air Quality
Standard
Limits to be observed are for
PM2.5, PM10, SO2, NO2, CO
Air quality – VOC
Ontario Ambient Air Quality
Criteria
400 µg/m3 (1 hour averaging
time)
Noise
The Planning Guidelines for
Environmental Noise Limits and
Control
At settlements:

Day time (7 am to 10
pm): 55 dBA

Night time (10 pm to 7
pm): 45 dBA
Management of Suspended Sediments during Construction
Compliance monitoring activities for the control of suspended sediments during reclamation
works (Phases 1 - 4) are outlined in Table 7.9.
Table 7.9
Compliance monitoring activities for suspended sediment control
Required activity
Auditing and Reporting
Frequency
Construction of perimeter bund
Layout plan and photographs of the bund
and temporary protection.
During
reclamation and
when needed
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7.2.2.3
Required activity
Auditing and Reporting
Frequency
Inspection and maintenance of
bund to be carried out monthly
/ after storm event
Environmental Officer to keep a log of
regular inspection and any maintenance
events, including photographs with a date
stamp
Monthly and after
major storm
events
Installation of silt curtain
around perimeter bund
Layout plan and photographs of the silt
curtains
During
reclamation and
when needed
Inspection and maintenance of
silt curtain
Environmental Officer to keep a log of
regular inspection and any maintenance
events, including photographs with a date
stamp
Throughout
reclamation
activity and when
needed
Ambient Water Quality
Compliance measures relating to mitigating the water pollution are outlined in Table 7.10 with
the relevant monitoring requirements.
Table 7.10
7.2.2.4
Water pollution control measures and methods for monitoring compliance during
construction phase
Required activity
Frequency
Discharge of floatables, chemicals,
or other polluting substances from
dredge and other construction
vessels, at the reclamation site
offices and workers’ quarters are
not allowed; collection of such
wastes shall be made on a regular
basis and disposal of any
prescribed substances shall follow
existing State/Federal regulations
Layout plan and photographs of the oily
waste temporary storage area(s),
garbage disposal site and sewage facility
at reclamation site
At construction
start and as
required
Site inspection by contractor
Weekly
Log of scheduled waste disposal
As required
Adequate and well-maintained
sanitary provisions for on-site
workers quarters and offices.
Site inspection by Environmental
Manager
Monthly
Adequate containers/bins shall be
provided for solid wastes
Site inspection by Environmental
Manager
Monthly
Discharge of oily wastewater from
sea vehicles’ engine rooms should
be channelled into an oil separator.
The waste oil should then be stored
in slop tanks and managed as
schedule waste.
Requirement to be included in tender
documents.
Contractors to keep a log of scheduled
waste disposal
Preconstruction.
As required.
Any temporary onsite diesel storage
areas should be located at least 30
m away from the waterfront to
prevent accidental spillage into the
marine environment.
Layout plan and photographs of storage
areas.
At construction
start and as
required
Site inspection by contractor
Weekly
Air Quality
Construction
The compliance monitoring for the recommended air emissions abatement measures are
detailed in Table 7.11.
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Table 7.11
Air emissions abatement measures and related compliance monitoring during the
construction phase
Required activity
Frequency
Construction machinery shall be
maintained according to national
standards for emissions.
Equipment/ vehicle maintenance log to
be kept by contractors
As required
Spraying of bare surfaces
Layout plan and photographs of wet dust
suppression system
At construction
start
Road and site watering
Access road to be watered
As required
Stabilisation of access point and
main haul roads within site
Layout plan and description of
stabilisation works
Monthly
Access point and main haul roads
within site to be inspected monthly
and maintained as necessary.
Photographic record.
Monthly
Lorries transporting the earth fill
shall cover the loads with tarpaulin
Site inspection
Monthly
Wheels of construction vehicles
leaving the site shall be clean
Layout plan and photographs of washing
bay system
At construction
start
Site inspection
Monthly
Public complaints
As required
Site inspection
Daily
Public complaints
As required
No open burning on site
Operations
The compliance monitoring during operation is to ensure that all air emissions during
operations comply with the guidelines of the Environmental Quality (Clean Air) Regulations
2014.
7.2.2.5
Noise
Noise abatement measures and the proposed monitoring of compliance with these measures
are outlined Table 7.12.
Table 7.12
Noise management measures and compliance monitoring
Required activity
Frequency
Construction machinery shall be
fitted with noise suppressors
recommended by the
manufacturer
Machinery/equipment specifications list
To be included in
contract
Installation of enclosures around
power generators and other
noisy machinery.
Layout plan and photographs of physical
noise barriers and equipment enclosures
At construction
start and when
necessary
7-15
7.2.2.6
Required activity
Frequency
Noise complaint register

Set up and create public awareness of
noise complaint register (local
telephone number)
Per occurrence

Noise complaints to be recorded in log
book

Complaints to be investigated within
24 hrs following lodgement.

Log book to be included in monitoring
report

Additional mitigation measures to be
implemented where frequent or
repeating noise complaints are
received.
Beach Nourishment between Tg. Che’ Amar and Tg. Bt. Supai
The following compliance documentation shall be provided to the EMP consultant for inclusion
in the Environmental Monitoring/ Environmental Audit reports:
Table 7.13
7.2.2.7
Compliance monitoring program for beach nourishment considerations.
Required Activity
Frequency
Appointment of sea turtle and
terrapin specialists to advise on
beach design
Submit names and qualifications of
appointed specialists.
Prior to beach
nourishment
(phase 1)
Design to take into account sea
turtle and terrapin requirements
for beach sand type; beach
profile.


Design report with recommendations from
turtle and terrapin experts.
As-built engineering report with photographic
documentation
Prior to beach
nourishment and
post nourishment
Sea Turtles
Compliance monitoring for sea turtles is outlined in Table 7.14.
Table 7.14
7.2.2.8
Compliance monitoring program for sea turtles.
Required Activity
Frequency
Establishment of a dedicated
sea turtle monitoring team
Submit team names, qualifications and
completion of training certificates
Prior to
construction
Painted Terrapin
The present state of the scientific knowledge needed to identify impacts on terrapins from the
proposed project as distinct to other impacts critical to the survival of the species is not
available at this time.
Using a precautionary approach to managing any likely impacts is proposed, and is expressed
as the funding of the necessary population and environmental monitoring which can also be
coupled with further research into the life stages of the painted terrapin at Sg. Linggi which are
also not understood but critical to conservation management planning and action. Proposed
research projects include assessing the reproductive biology of the painted terrapin in the Sg.
Linggi area; and the relationship between habitat use and disease. These projects could be
led by a Lead Researcher for the period of the development and into the operational phase,
over a period of 10 years for example, but may also involve numerous students and/or
7-16
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Monitoring
volunteers. In order to demonstrate that this is occurring, the compliance documentation
outlined in Table 7.15 is required.
Table 7.15
7.2.2.9
Compliance auditing programme for painted terrapins
Required Activity
Frequency
Appoint a Lead Terrapin
Researcher, by project
proponent, directly through
EMP Consultant.
Documentation of establishment of the
management team with name of
Terrapin Researcher and anticipated
man-time contribution.
Prior to construction
(T=0) as frequently as
needed thereafter.
Lead Terrapin Researcher to
develop and undertake painted
terrapin research and
monitoring programme
throughout the KLIP project.
Terrapin Research Programme (TRP)
detailing the programme and lead
researchers, interns or volunteers.
TRP to be included as
an integral part of the
finally approved EMP
Population/nesting
monitoring to start prior
to construction and as
frequently as specified
in Section 7.2.3.5.
Proponent to provide sufficient
funding for the Terrapin
Research Programme.
Annual programme report outlining
research and monitoring activities
funded by the Proponent as part of the
EMP.
Annually throughout
construction stage (10
years).
Develop a Species
Conservation Strategy for Sg
Linggi population. Led by Lead
Researcher, appointed by the
project proponent, action to be
taken by PERHILITAN under
Malacca State Government.
To facilitate a group of relevant
stakeholders, researchers,
conservationists, and moderators meet
and develop the initial draft of the
conservation strategy. Strategy to be
signed off by all participants and draft
to be presented to PERHILITAN within
the first 6 months of the project.
A first draft within the
first six months and
reviewed thereafter
annually.
Fishermen
Specific activities and compliance monitoring are listed in Table 7.16.
Table 7.16
Compliance monitoring programme for mitigation of impacts to fisheries activities
Required Activity
Monitoring Programme
Frequency
Establishment of Fishermen’s
Working Group by EO.
Members include fishermen
and aquaculture operators.
To submit committee members names and
minutes of meetings
Prior to
construction start/
then quarterly.
EO to inform fishermen and
local fishermen associations
(i.e. Fishermen Working Group
- FWG) of work schedules,
safety buffer zones and
restricted areas before each
construction phase and when
required (e.g. any change in
schedules, activities, etc.) and a
reminder for any of their own
responsibilities.

To submit schedule to Marine
Department and schedule to be
included in the EMP report
At construction
start/ then
quarterly

To submit minutes of the consultations
between fishermen working group and
proponents.
7-17
Required Activity
Monitoring Programme
Frequency
Appropriate compensation for
affected fishermen’s loss of
income and fishing grounds,
includes aquaculture operators.
Negotiations to be conducted together with
the Department of Fisheries, Fishermen’s
Kuala Linggi, Tg. Dahan, Kampung Tengah
and Fisheries Association of Telok Kemang
Settlement should be agreed upon prior to
construction.
To be settled prior
to the start of
construction.
Provide assistance to the
affected fishermen who want to
continue fishing (i.e. new jetty,
fishing gear, travel cost, etc.)

To have a list of fishermen who opt to
continue fishing and submit their details
to the Department of Fisheries (DOF).
A clear cut-off date is compulsory.
To be done before
providing
assistance

Participating fishermen would need to
comply with requirement (i.e. frequency
of fishing activities, to weigh in at
designated fish landing site, etc.)
Quarterly report
Fishermen communities uplift
programmes such
entrepreneurship development
programme or co-operative.
Possibly provide start-up capital
or soft loans.
7.2.3
Impact Monitoring
7.2.3.1
Water Quality
Number of training / education programmes,
number of businesses setup and their
status (success/ failure)
Annual report
An ambient water quality monitoring programme will be carried out throughout the construction
and operational stages. This programme will monitor other parameters of concern such as oil
and grease, BOD, etc. and complements the SS monitoring programme for Phase 4 Feedback
Monitoring outlined in Section 7.2.1.1 above.
Construction Stage Monitoring
Monitoring Schedule
The water quality monitoring shall be carried out monthly during the construction phase,
however, the analysis of heavy metals may be restricted to the first six (6) months of monitoring
if there is no indication of elevated levels during this monitoring period.
Monitoring Stations
Water quality samples shall be obtained at four (4) marine stations and two (2) estuary stations
(at the two estuary stations) at surface (-0.5 m) and bottom (+ 1m) depths. Insitu
measurements will be made at a minimum of 1m intervals through the water column. The
station locations are shown in Figure 7.5 and the corresponding coordinates are given in Table
7.17.
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62801230-RPT-02
Monitoring
Figure 7.5
Water quality monitoring stations
Table 7.17
Geographic coordinates and description of the water quality stations in WGS84 (decimal
degrees).
Station
Longitude (E°)
Latitude (N°)
Description
WQ1
102.005585
2.407569
Upstream control station for Sg. Linggi
WQ2
101.979776
2.392528
Sg. Linggi rivermouth. Sensitive
receptor - aquaculture
WQ3
101.94155
2.40656
Tg. Selamat. Sensitive receptor –
mussel farm
WQ4
101.857859
2.403313
Tg. Tuan. Sensitive receptor – hard
coral
WQ5
101.91922
2.35816
Linggi offshore. Sensitive receptor –
mixed soft and
WQ6
101.998553
2.359024
Tg. Dahan. Sensitive receptor – hard
coral
7-19
Parameters
The parameters to be analysed for samples collected from the water quality monitoring
programme are listed in Table 7.18.
Water quality parameters to be analysed – individual levels of precision will be specified
in the final approved EMP
Table 7.18
Parameters
Measurement
Limit & Unit
Test Method
Physical
Type of
Measurement
Insitu
Temperature
0.1 °C
Calibrated multi-parameter sensor
Conductivity
1 mS/cm
Dissolved Oxygen
0.1 mg/L
pH
pH unit
Salinity
0.01 ppt
Turbidity
1NTU
Total suspended solid
(TSS)
0.5 mg/L
APHA 2540 D
Ammoniacal Nitrogen
0.001 mg/L
APHA 4500 NH3 F*, adjusted for high
chlorinity
Phosphate
0.001mg/L
APHA 4500 P E* adjusted for high
chlorinity
Nitrate
0.001 mg/L
APHA 4500 NO3- E adjusted for high
chlorinity
Chromium Trivalent
(Cr(III))
1 µg/L
In House Method EWI-WC 51*
Cadmium (Cd)
1 µg/L
In House Method EWI-INS (MS) 06
Copper (Cu)
1 µg/L
Nickel (Ni)
1 µg/L
1 µg/L
APHA 3500 Fe-B*
Lead (Pb)
1 µg/L
Manganese (Mn)
1 µg/L
Arsenic (As)
1 µg/L
Mercury (Hg)
1 µg/L
Biological Oxygen
Demand (BOD)
1 mg/L
APHA 5210 B
Chemical Oxygen
Demand (COD)
1 mg/L
APHA 5220 D
Oil and grease
1 mg/L
APHA 5520 B
Ex-situ
Nutrient
Heavy Metals
Iron (II) (Fe
2+)
Organic
Note:
APHA: Standard Methods for the Examination of Water & Wastewater, 21st Edition (2005)
USEPA: United States Environmental Protection Agency
*: Test is not SAMM accredited
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Monitoring
Operations Stage Monitoring
Monitoring Schedule
Water quality monitoring shall be carried out biannually from the completion of the reclamation
up to one (1) year after the commissioning of Phase 4, and annually thereafter.
Monitoring Stations
As per during construction stage (Figure 7.5 and Table 7.17).
Parameters
As per during construction stage (Table 7.18).
7.2.3.2
Coastal Bathymetric Profile Monitoring
In order to monitor the potential impacts of the project on the nearby coastline, bathymetric
profile monitoring is recommended. These profile transects have been selected to cover the
areas where there is potential for erosion/sedimentation and extend from the shoreline beach
area above HAT to the -5 m CD contour to fully cover the active sediment transport area.
Given the benign wave conditions behind the proposed reclamation area it is proposed to
monitor the shore with fifteen coastal profiles as shown in Figure 7.6 with coordinates shown
in Table 7.19. The profiles need to be undertaken using a multi-beam sounder to identify
sediment layers and the data post processed to Chart Datum.
7-21
Figure 7.6
Proposed location of the coastal profile monitoring
Table 7.19
Proposed 15 beach profiles for shoreline monitoring (Coordinates in UTM, metres).
Profile
7-22
Starting Point (UTM-47)
(near shore)
Ending Point (UTM-47)
(offshore)
Easting
Northing
Easting
Northing
L1
828364
266246
827946
265891
L2
829031
266029
829210
265415
L3
829912
265890
829585
265250
L4
830492
265540
830034
265005
L5
830896
264874
830275
264761
L6
830211
264029
830049
263934
L7
830326
263799
830160
263678
L8
830464
263594
830262
263483
L9
830566
263368
830376
263271
L10
830637
263215
830424
263142
62801230-RPT-02
Monitoring
Profile
Starting Point (UTM-47)
(near shore)
Ending Point (UTM-47)
(offshore)
Easting
Northing
Easting
Northing
L11
830630
262932
830491
262784
L12
830898
262607
830730
262427
L13
831568
262349
831517
262040
L14
832738
262085
832616
261823
L15
833670
262199
833661
261829
The frequency of the coastal profile monitoring is:



7.2.3.3
Once before construction starts
Quarterly during construction stage
Biannually upon completion of stage 4 construction
Fish Fauna
Fish fauna monitoring would enable primary and secondary productivity of the area to be
measured as well as provide additional insight into the interpretation of the water quality data.
Frequency and Duration
It is recommended that the biological parameters be monitored as follows:

Quarterly during the reclamation phase. Upon completion of phase 4, the biological
monitoring shall be continuously monitored for at least another two quarters.
Annually during the operation of the marine facilities.

Stations
Seven stations as listed in Table 7.20 and shown in Figure 7.7.
Table 7.20
Geographic coordinates (decimal degrees) of the fish fauna monitoring stations.
Coordinate
Station
Latitude
Longitude
F1
2.406009
102.006226
F2
2.408758
101.94133
F3
2.395839
101.959969
F4
2.360881
101.980429
F5
2.37336
101.868373
F6
2.30834
101.91313
F7
2.311717
102.059405
7-23
Figure 7.7
Location of fish fauna monitoring stations.
Parameters
The primary benchmarks would be no significant decrease in fish fauna at the study area and
the sampling methods used need to reflect an ability to show this difference statistically.
7.2.3.4
Sea Turtles
Monitoring of sea turtles will provide data on all phases of sea turtle life cycles which are known
for Malacca, along with determination of potential impacts, as follows:




Turtle nesting:
Nesting volume
Nesting success
Incubation success
Hatchling orientation and dispersal evaluation;
Turtle Tracking; and
Light monitoring.
These are described further in the following subsections.
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62801230-RPT-02
Monitoring
Turtle Nesting
 At least one baseline season (prior to construction start);
 Each season (i.e. annually) during the 10 year construction period; and
 Two seasons (i.e. annually for two years) post-commissioning.
Stations
Total eight beaches: (i) Kuala Linggi, (ii) Tg. Serai, (iii) Mariam Patah, (iv) Tg. Dahan (impact
beaches), as well as (v) Teluk Gong, (vi) Padang Kemunting, (vii) Pengkalan Balak and (viii)
Pasir Gembur (control beaches)
Parameters
 Nesting volume
Nesting volume (total number of tracks) will enable comparisons with past data sets. This will
be determined by counting nesting tracks on the beaches every morning each season from 01
February to 30 September.
Nests shall be marked for subsequent determination of incubation success, and determine
nesting success (see below). The monitoring shall be recorded via daily data sheets listing
nesting activity and nesting success as determined by a competent authority, cross referenced
with those of DOF Malacca.
 Nesting success
Nesting success (how many emergences result in successful nests) as a measure of effort
and energy expenditure). This will be determined by assessing the nesting success of each
and all of the emergent tracks on the monitoring beaches each season.
 Incubation success
Incubation success (how many eggs develop successfully in each clutch, and how many of
these result in live emergent hatchlings (a measure of reproductive output). This will be
determined by marking successful nests and subsequently excavating this after incubation on
the monitoring beaches each season.
A minimum of 50% of nests on the monitoring beaches shall be enumerated and records shall
include total number of eggs, number of dead eggs (if any), number of hatched eggs and
number of dead hatchlings (if any).
Hatchling orientation and dispersal evaluation
 At least one baseline season (prior to construction start);
 Each season (i.e. annually) during the 10 year construction period; and
 Two seasons (i.e. annually for two years) post-commissioning.
Stations
Total eight beaches: (i) Kuala Linggi, (ii) Tg. Serai, (iii) Mariam Patah, (iv) Tg. Dahan (impact
beaches).
Parameters
 Reports and statistics of mean offset and mean spread angles of hatchlings departing
previously-marked nests
 Reports on hatchling dispersal from impact beaches and control beaches for a minimum
of 30 hatchlings per site
7-25
Turtle Tracking
Satellite tracking of sea turtles to determine potential impacts on their behaviour due to
construction and shipping activities is recommended. The monitoring programmes will involve
tracking post-nesting females using satellite transmitters on sea turtles at the peak of each
nesting season during construction and two seasons post construction, enabling comparisons
between baseline, construction and post-commissioning phases.
Number:
Five post-nesting female turtles
Duration and timing:
Annually at peak of every nesting season over the 10 year construction period and for two
seasons post construction.
Output:
Reports including maps and density graphics for five (5) satellite tracked post-nesting sea
turtles during each season.
Light Monitoring
The sea turtle monitoring programme will also evaluate light levels prior to construction, during
construction and post commissioning at four key sites to provide comparisons across impact
and non-impact beaches.
 Baseline – prior to construction and mobilisation of workforce and equipment

During construction – quarterly

Operations – quarterly for two years following commissioning of the full development.
Stations
Four locations as shown in Figure 7.8. Coordinates are provided in Table 7.21.
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Monitoring
Figure 7.8
Light monitoring stations for turtle impacts.
Table 7.21
Coordinates for turtle light monitoring stations.
Location
Coordinates (decimal degrees)
Longitude (E)
Latitude (N)
Kuala Linggi
101.969161
2.384861
Meriam Patah
101.979763
2.370524
Tg. Dahan
101.989593
2.368653
Control
101.998087
2.367979
Parameters
Ambient light levels at night using a Sky42TM or equivalent with a 360° view of the horizon (not
a standard light meter).
7-27
7.2.3.5
Painted Terrapins
Due to the population status of the painted terrapins in Sg Linggi (Vulnerable) and their
sensitivity to various changes to their environment and habitats, it is crucial to monitor their
behaviour as a result of the changes that take place during the construction and operation
stages. Specific activities and proposed compliance monitoring are listed in Table 7.3.
The most critical impact to the painted terrapin resulting from this KLIP project is the possible
loss of access to nesting beaches at Kuala Linggi, and potentially down to Tg. Serai and Tg.
Dahan. It is of utmost importance that a versatile monitoring programme be put in place prior
to the initiation of project construction.
Stations
Five locations as shown in Figure 7.9 and Table 7.22.
These stations are known painted terrapin nesting beaches, and would be the best indicator
of the health of the painted terrapin population during the construction and operation stages
of the project.
Parameters and Methods
A year-long monitoring programme should be drafted (and repeated or modified where
necessary) as part of the work plan generated by the Lead Terrapin Researcher, that involves
the monitoring of nesting beaches, monitoring of the nesting females, and the monitoring of
the movements of the painted terrapins during the nesting and non-nesting seasons. The
activities of painted terrapins are seasonal, hence different monitoring activities should be
undertaken for the different “seasons.”
Data collected from a long-term beach survey will be used to estimate the population of the
painted terrapins (mark and return estimates), as well as the nesting trend (increasing or
decreasing).
Monitoring activities may include, but not be limited to:



7-28
Nesting Survey
Nesting surveys to be conducted during the nesting season. The purpose of beach
surveys is to document the distribution and landing/nesting of the painted terrapins.
Clutch size
Collection of the terrapin eggs from the nests to determine clutch size.
Mark and recapture
Microchipping of the females (nesting frequency, internesting interval, population
size). Painted terrapins that emerge from the nest should be captured and
microchipped allowing infield identification at any time and also long term trends in
nesting and hatching success, life cycle history and evidence of return to specific
beaches.
An ultrasonic tracking project to determine the movements of the painted terrapins
during the nesting and non-nesting months should be undertaken. These data are
critical as they will show whether the terrapins would continue to nest on nesting
beaches that are affected during the construction and operational phases of the
KLIP. The tracking project may be conducted at the different phases of the project,
in order to assess their behavioural changes to the changes in their environment.
Data collected from this mark-and-recapture monitoring programme will enable an
estimate the population size of the terrapins, and whether the size increases or
decreases over the years. This could be done either by maintaining a presence of
the nesting beaches (suitably trained student interns or volunteers) and interviews
with local egg collectors. This survey should also be conducted during the nesting
season.
62801230-RPT-02
Monitoring
Figure 7.9
Painted Terrapin monitoring stations.
Table 7.22
Geographic coordinates (decimal degrees) of the painted terrapin monitoring stations.
Beach Starting Point
Beach Ending Point
Station
Latitude
7.2.3.6
Longitude
Latitude
Longitude
Estuary (PT1)
2.392649
101.983787
2.406423
102.008975
Tg, Serai (PT2)
2.370872
101.976006
2.373516
101.973814
Teluk Belanga
(PT3)
2.348798
102.039231
2.34478
102.048717
Padang
Kemunting (PT4)
2.316414
102.072025
2.30378
102.075779
Tg. Kling (PT5)
2.222815
102.151021
2.219868
102.153354
Coral Reefs
Coral reefs are among the most important of marine ecosystems and support a wide variety
of biodiversity at the study area. The monitoring of these sensitive habitats will enable the
7-29
health and status of these areas to be measured and any adverse impacts on the habitats due
to the reclamation and operation of the proposed project to be closely monitored.
To ensure the proposed project will not affect these sensitive habitats, the following monitoring
regime is recommended:



Baseline prior to construction start
Quarterly during the reclamation phase.
Quarterly for one year upon completion of each reclamation phase.
The habitats investigated would be the status and health of:


Coral reefs at Tg. Tuan
Coral reefs off Tg. Dahan
Stations
Two (2) stations as shown in Figure 7.10. Coordinates are listed in Table 7.23.
Parameters and Methods
At each site, 10 permanent quadrats (0.5 m x 0.5 m) will be fixed in situ at areas where corals
are present. This will enable accurate repeated surveys to be conducted and valid results
which is representative of the changes from the project over time to be obtained.
Based on these quadrats, quantitative outputs will be obtained to enable clear comparison of
habitat health throughout the project operations. Monitoring data to be obtained will include
percentage of live coral cover and species, coral diseases, and incidences of coral bleaching.
All in all, the prevalence, incidence and mortality rate of the expected disturbances on the reef
will be recorded and analysed. The primary benchmark for this monitoring would be no
significant deterioration of coral reef health at the study area.
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Monitoring
7.2.3.7
Figure 7.10
Location of coral reef monitoring stations.
Table 7.23
Coordinates of the starting points for coral reef monitoring stations (decimal degrees).
Station
Description
Latitude
Longitude
CO1
Tg. Tuan. Sensitive receptor – hard coral
2.4026
101.855716
CO2
Tg. Dahan. Sensitive receptor – hard coral
2.357587
101.999263
Air Quality
Frequency

Construction – quarterly

Operations - annually
Stations
The monitoring of ambient air quality during both construction and operations is proposed as
shown in Figure 7.11. The geographic location of the stations is given in Table 7.24. Note that
the location and number of stations will be finalised in the EMP in accordance with the detailed
7-31
construction schedule to reflect timing of the stages of topside development. It is also noted
that performance monitoring (see Section 7.2.1) will be carried out on the project site itself
during operations.
Figure 7.11
Air quality and noise monitoring stations
Table 7.24
Coordinates of air quality and noise station (decimal degrees).
Station
Longitude
Latitude
AN1
101.966798
2.407112
AN2
101.969907
2.385259
AN3
101.980771
2.37187
AN4
101.960567
2.422009
Parameters
The monitoring and parameters to be analysed during construction and operation phase are
listed Table 7.25.
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Table 7.25
Parameters to be measured in the air quality monitoring
Phase
Monitoring Schedule
Parameters to be measured
Construction
Quarterly

Particulate matter (PM10)
Biannually

Particulate matter (PM2.5)
Biannually

Sulphur Oxides (SOx)

Nitrogen oxides (NOx)

Carbon Monoxide (CO)

Volatile Organic Compounds
(VOCs)
Operations
7.2.3.8
Ambient Noise
Frequency

Baseline – once before construction start

Construction – quarterly

Operations - biannually
Stations
Noise monitoring during the construction and operation phases will be carried out at the same
locations as the air quality stations shown in Figure 7.11 and Table 7.24 above. Note that the
location and number of stations will finalised in the EMP in accordance with the detailed
construction schedule to reflect timing of the stages of topside development.
Parameters
Parameters to be recorded for ambient noise level monitoring during construction and
operation are:



Equivalent Continuous Sound (Leq)
Maximum sound pressure level over monitoring period (Lmax)
Statistical indices (L90, L10)
“A” weighted noise levels should be monitored at each station over at least 24 hours
continuously (12-hours day and 12-hours night) using a pre-calibrated precision integrating
noise meter.
7.2.3.9
Fisheries Activities

Three sample sets prior to construction start/ then monthly for first 12 months;

Thereafter quarterly during the reclamation / dredging and reclamation phase and up to 6
months upon completion of construction.

Half yearly during the operation of the marine facilities.
Stations
Three fish landing areas around the project site.
7-33
Methodology
Examine landings in terms of volume and species diversity. This shall be undertaken through
interviews with fishmongers and selected fishermen supported by data from the Department
of Fisheries. This is to establish causes and enable remedial action to be taken at the earliest
possible.
7.2.3.10
Social Impact
Impact monitoring in the socioeconomic sense refers to ongoing community consultation with
respect to issues identified as potentially significant during the EIA study, and also to
determine whether any other unforeseen problems emerge following construction start.
Methodology
Community/ Community Leaders Working Group (CWG)
It is proposed that the project proponent assign a liaison person, to facilitate a committee of
the Community/ Community Leaders Working Group. With constant community engagement
through the working group, project information disbursement will be more effective while
community concerns can be addressed through collective efforts.
Grievance Mechanism
Besides through the Community/ Community Leaders Working Group, it is proposed that the
project proponent prepare a grievance mechanism to look into complaints by the affected
communities directly. Complaint centres can be set up at areas where the local community
can voice their concerns with respect to the project activities. These can be located at the site
office, RTC Kuala Linggi, Fishermen Association Melaka Barat office at Kuala Sungai Baru
and Fishermen Association of Teluk Kemang at Kampung Telok. All complaints are required
to be registered. The complaints register will need to record the date of the complaint, nature
of complaint, date and nature of response, follow up action and resolution date. All entries
into this complaints register will be summarised in the Environmental Monitoring reports.
Details of the proposed monitoring elements are given in Table 7.26. All monitoring is the
responsibility of the project proponent, who may also assign the tasks to its contractors and
subcontractors (but remains the responsibility of the project proponent), unless otherwise
specified.
Table 7.26
7-34
Socio economic feedback monitoring programme (interviews, stakeholder groups)
Parameter
Indicator
Employment opportunities
Number of local residents employed by the
Contractor
Negative Health and safety of the local community
from water pollution and air quality from Project
operations
Public complaints logged
Loss of livelihoods, reduced access to resources.
Impacts on fishing community as reported
through FWG; Public complaints logged
Overwhelming of local communities due to influx of
people seeking jobs
Pressure on existing infrastructure and amenities of
the study area
Public complaints logged; as reported through
CWG
Increase in crime and violence in the area.
Public complaints logged; dialogue with local
authorities
Disruption to existing recreational & tourism activity
Potential dissatisfaction or conflicts among local
residents as a result of unrealised employment
expectations
62801230-RPT-02
Monitoring
7.2.4
Parameter
Indicator
Traffic congestion at Project access roads
Public complaints logged, reporting on number
of vehicles per day to and from development
site based on security log
Social or cultural problems due to interaction of
traditional villagers with construction workforce
Increase in housing prices
General property assessment of housing
Reporting Requirements
During construction works it is proposed that quarterly Environmental Monitoring Reports
documenting the monitoring activities and findings as outlined in the previous sections are
submitted to DOE Malacca. However, during dredging and reclamation (Phase 4) this should
be increased to monthly to report the findings of the more frequent monitoring activities at this
stage.
During operations, bi-annual reporting is required.
7.3
Emergency Response Plan (ERP)
An Emergency Response Plan (ERP) will be established for both construction and operational
stages. The ERP shall address at least the following:



Marine collision
Oil Pollution Emergency Plan
Fire on the vessel(s) or on the marine facilities
Fire and chemical spill drills should be conducted regularly for all associated facilities’ to
ensure that all members of the Emergency Response Team are well prepared and understand
their individual roles and accountability during a fire or chemical spill incident.
Operations will be suspended or otherwise amended immediately if an environmental incident
occurs that may be exacerbated by continued operations.
7.3.1




7.3.2
SOP/EOP to be submitted to Marine Department and other relevant authorities prior to
commencement of construction and operations.
Monitor and record incidents, including “near hits” and incorporate into RRP review and
update.
All equipment required in the implementation of the emergency response plan must be on
site and maintained on schedule in order to respond to any emergency such as oil spill
effectively and efficiently.
Inspection and verification of the emergency response equipment and gear (firefighting
equipment, oil spill response equipment etc.) to be conducted bi-annually.
Oil Spill
In the event that oil products are spilled into the sea or an oil slick is observed, the
Captain/Vessel master and/or port operation manager shall be notified immediately by the
person observing the oil spill, giving the following information so that the necessary steps
can be taken:
 Location of incident;
 Type and size of spill; and
7-35

Other relevant information
If considered a Tier 1 spill (Local and low volume) the Captain/Vessel Master and/or Port
Operation Manager is responsible for the compliance and execution of the Oil Spill
Contingency/Response Plan, where applicable. Steps to be taken will include:



Stop the spill source immediately;
Remove floating oil with absorbent or skimming; and
Deploy containment booms to control flow dispersion of spillage.
If the oil spill is too large for a Tier 1 response, Tier 2 (state level) or Tier 3 (regional level) will
be activated, where by DOE Malaysia will be notified by the Contractor, and may be required
to stay involved in the clean-up process. The Existing Port has Tier 1 response capability but
has a policy of making its vessels available for Tier 2./3. All maritime contractors need to be
notified that the nearest stockpile, as listed in the National Oil Spill Contingency Plan for this
project is in Port Dickson and managed by Petroleum Industry of Malaysia Mutual Aid Group.
Responsibility for contacting them sits with DOE, unless a request is for Tier 1.
7.3.3
Collision at Sea
In all cases, the Captain / Vessel Master from colliding vessel have the final responsibility for
the safety of the vessel and people on board as required under international law (COLREGS).
Immediately after the collision or as soon as a real danger of collision is known to exist, the
Captain/Vessel Master has the prevailing authority to order the termination of all operations
and to choose all necessary means with regard to the security of the vessel and crew and
needs to act accordingly as required in the COLREGS and in accordance with good seamen
ship.
7.4
Project Closure
7.4.1
Design for Decommissioning
It is important to anticipate the decommissioning activities and incorporate them in the design
phase. “Design for decommissioning” principles are recommended.
The “design for decommissioning” is a proactive approach and includes the following
considerations during the planning stage:





Using materials that are easy to recycle or reuse.
Using modular designs to make it easier to assemble, disassemble and transport parts of
the facilities
Minimising the use of hazardous materials.
Minimising the amount of contaminated material or hazardous waste that will be generated
upon decommissioning.
Make arrangements for ongoing servicing of site specific navigations markers
Establishing the contractual liabilities of the Operators (i.e. purchaser/ developer of lots); i.e.
the company should be responsible for pollution caused by their own operations, such that the
Operator should:


7-36
Consider any insurance requirements
Make provisions for future costs
62801230-RPT-02
Monitoring
7.4.2
Project Abandonment or Decommissioning
In the event of project closure or abandonment, the compliance monitoring to be implemented
varies depending on the stages the project is in and may include the activities outlined in Table
7.27. The required decommissioning plan following any period of operations is described
further in Section 7.4.3.
Table 7.27
Compliance audit for project closure or abandonment (monthly during decommissioning).
Required activity
Abandonment during Construction
Removal of construction machinery
List of machineries and site inspection with
photographic evidence
Removal of construction waste
Site inspection and photographic evidence
Appropriate management and disposal of
scheduled wastes
Site inspection and photographic evidence of
collection area; log of disposal / chain of custody
Construction of revetment/bund wall to
stabilise reclaimed area.
Layout plan and photographic evidence
Landscaping of exposed areas
Site inspection and photographic record.
Decommissioning following Operations
Preparation of Decommissioning Plan
Submission / notification to relevant authorities
Dismantling and removal of tanks, pipes and
other equipment or structures
Site inspection and photographic record.
Disposal or decontamination of equipment,
structures and soils
7.4.3
Removal of all hazardous wastes
Site inspection and photographic evidence of
collection area; log of disposal / chain of custody
Soil contamination survey and remediation
plan
Contamination surveys to be carried out and
remediation plan developed as required
Rehabilitating the facility
Rehabilitation plan; progress reports
Maintenance of park such as housekeeping
and landscaping, site specific navigation and
other hazard warnings
Site inspection and photographic record
Decommissioning Plan
Decommissioning includes dismantling, demolition and disposal of buildings and
infrastructure. The Decommissioning Plan shall take due consideration of the regulatory
framework with respect to the specific activity including:

Identification of all legal requirements and consultations with the appropriate authorities at
an early stage in the decommissioning planning phase.

Notifications: appropriate notifications need to be made to DOE when decommissioning
activities are planned. Additional pollution prevention measures or remediation may be
required depending on the planned future uses of the land.
The Decommissioning Plan shall include a contamination assessment requirement whereby
the Operator shall assess the state of soil contamination by the relevant hazardous substances
used, produced or released as a result of the operations and compare with the baseline
7-37
conditions. In the event of significant environmental damage, the Operator shall adopt
measures and develop practices for remediation of land damage aiming at reaching the
baseline condition. Depending on the outcome of the environmental risk assessment and
degree of environmental damage cause, the Operator shall take the necessary actions aimed
at the removal, control, containment or reduction of relevant hazardous substances,
The Operator shall adopt general HSE guidelines for prevention and control of health and
safety impacts.
The key topics to address in the Decommissioning Plan include:






Noise and vibration (e.g. during use of cranes, transportation of materials and people
Soil erosion and sedimentation control in the event of excavation activities
Air quality (decommissioning activities may generate emissions of fugitive dust,
uncontrolled release of hazardous materials or gases);
Hazardous materials (release of petroleum based products such as lubricants, hydraulic
fluids, PCBs, oil etc. during storage, transport or use in equipment, spill clean-up material,
etc.).
Solid waste (release of non-hazardous materials such as scrap and cement building
materials).
Environmental monitoring and reporting to be undertaken (e.g. storage tank emissions to
air and water, effluent discharges, and waste disposal).
After the site is closed the Operator remains responsible for monitoring, reporting and
corrective measures until the site is returned to the satisfactory state.
7.5
Final EMP Requirements
Prior to start of works, an EMP document is to be submitted and approved by DOE including:



Contractual responsibilities and liabilities.
Details of dredging plan.
Emergency Response Plan (specific to the Contractor’s equipment and methodologies).
This should cover emergency preparedness to manage any of the following:
Marine works
Marine collision at dredging area
Fire on vessel
Wildlife incident (marine megafauna strikes or entrainment).
In addition, given its intended purpose as a stand-alone document, the Final EMP should also
contain:




7-38
A description of the proposed dredging, construction and operational activities and
associated development;
A summary of the potential environmental impacts from the project;
Environmental management (mitigation) measures which will be addressed during the
proposed works; and
Roles and responsibilities for implementation of the EMP and reporting requirements.
62801230-RPT-02
Study Findings
8
Study Findings
This Schedule 2 EIA Report has assessed the potential environmental impacts associated
with the Proposed Reclamation and Development of Kuala Linggi International Port (KLIP) at
Kuala Linggi, Malacca, Malaysia. The assessment has covered the impacts arising from the
construction and operations of the proposed project, including the reclamation of land, capital
dredging, and construction of the marine and onshore facilities and finally the general
operations of the port.
The assessment of impacts is based on a review of the project activities as described by the
project proponent and addresses the issues identified during the EIA scoping phase as
presented in the revised TOR. The assessment acknowledges that any development will have
effects on the biophysical and socioeconomic environment of both a negative, and in some
cases, a positive nature.
The location of this project places it in close juxtaposition to a number of environmentally
sensitive areas. The nature of the reclamation is such that it will lead to an irreversible change
in the area to be developed. The original physical, biological resources and productivity within
the project footprint will be lost permanently and this not only represents a loss of habitat but
also part of an important fishery resource for the local fishermen.
The coastline fronting the project is actively eroding and this is leading to the loss of turtle
nesting areas. It is concluded, however, that the reclamation footprint to create the port will
diminish, if not reverse, this erosional process and facilitate the restoration of the beach. Apart
from that, it is proposed that beach nourishment be carried out for the beach area fronting the
project area as a mitigating measure to address potential erosion in this area during the course
of the project construction.
One of the primary concerns during the reclamation and dredging works for the project is the
impact of suspended sediments on the marine environment. This has been addressed though
the control of production rate ensured by intensive compliance and impact monitoring in order
to reduce impacts on corals and marine fauna to acceptable levels.
Another key issue that emerged from the assessments relate to the potential impact on sea
turtles and painted terrapins. Both species are of international conservation significance and
their conservation is a major concern for both Federal and State Governments. The impact
assessment, for the painted terrapin in particular, has been hampered by the lack of
knowledge of the biology, life-cycle and distribution of this species in the study area and
beyond. While no severe impacts are predicted as a result of the changes to the physical
environment, the impact assessment reflects the uncertainties surrounding the present
conservation status of these key species and the likely impacts on them. In particular
uncertainties remain with respect to the location and abundance of the terrapin’s nesting
locations and its behavioural responses to disturbance related to construction activity and
potential, partial obstruction to customary migration routes due to the project footprint.
Similarly, their response to potential slight changes in nesting beach conditions whereby the
deposition of fines on the Kuala Linggi beach immediately around the project site remains an
uncertainty.
In order to address these uncertainties and risks, the environmental management plan
incorporates comprehensive monitoring of sea turtles and terrapins throughout the ten year
construction phase and beyond, that will not only assist in management of potential impacts
of this proposed project during its implementation, but will also contribute to the body of
knowledge of these species to support conservation efforts in Sg. Linggi, the Malacca region
and elsewhere in Malaysia.
Impacts on the human environment relate primarily to the local fishermen. A range of mitigation
measures have been proposed, including compensation, provision of artificial reefs, and
8-1
training opportunities to ensure alternative resources or livelihoods are available to the
affected fishermen. Other impacts to the wider community have been shown to be minor - the
air quality assessments and QRA carried out for the project has determined that the buffer
zone is sufficient to accommodate the required safety separation between the project and the
land use and prevent impacts to human health in the surrounding areas, while the employment
and entrepreneurial opportunities proffered by the project is expected to result in significant
benefits to the local community as well as the state and national economy.
In conclusion, the EIA study has found that, with the incorporation of the recommended
mitigation measures and implementation of the Environmental Management Plan, the project
can be implemented with acceptable environmental impacts and risk and an overall positive
outcome.
8-2
62801230-RPT-02
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DRAWINGS
No 1
No 2
No 3
No 4
No 5
No 6
No 7
Project Location
Land Use 5 km
ESA 10 km
ESA 5 km
Physical Monitoring Stations
Biological Monitoring Stations (Land)
Biological Monitoring Stations (Marine)

7 Environmental Management Plan (EMP) and

Transcription

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