Central Reclamation, Phase III

Quarterly EM&A Report No. 22

(November 2008 through January 2009)


1.           Introduction. 1

1.1          Basic Project Information. 1

1.2          Project Organisation and Management Structure. 1

1.3          Works Undertaken. 1

2.           EM&A Requirements. 3

2.1          Summary of Impact EM&A Requirements. 3

2.2          Environmental Quality Performance Limits. 4

2.3          Event Action Plan. 4

3.           Environmental Status. 5

3.1          Implementation of Environmental Measures. 5

3.2          Environmental Monitoring Locations. 5

3.3          Air Quality Monitoring Results. 5

3.4          Noise Quality Monitoring Results. 5

3.5          Water Quality Monitoring Results. 5

3.6          Solid and Liquid Waste Management Status. 5

3.7          Landscape and Visual Audit 5

4.           Environmental Complaint and Non-Compliance. 7

4.1          Environmental Exceedances. 7

4.2          Non-Compliance. 9

4.3          Summary of Actions Taken by the Contractor 9

4.4          Environmental Enquiries. 9

4.5          Environmental Complaints and Prosecutions. 9

4.6          Record of Environmental Complaints and Summons & Prosecutions. 9

5.           Conclusion. 10


List of Annexes

Annex A              Project Organisation/ Contact Information

Annex B              Quality Performance Limits for Air, Noise and Water Quality

Annex C              Event and Action Plans for Air, Noise and Water Quality

Annex D              Monitoring Stations Locations

Annex E              Contractor's Works Programme

Annex F               Graphical Representation of Air Quality Monitoring Results

Annex G              Graphical Representation of Noise Quality Monitoring Results

Annex H              Graphical Representation of Water Quality Monitoring Results

Annex I               Quarterly Assessment of Construction Impacts on Suspended Solids

 

 

 

List of Tables

Table 2.1 - Summary of Impact EM&A Requirements. 3

Table 4.1 - Summary Water Quality Exceedances
from November 2008 to January 2009
. 7

 

 


Abbreviations & Acronyms

ACL

Atkins China Limited

AL

Action Level

CEDD

Civil Engineering and Development Department

CRIII

Central Reclamation Phase III

DO

Dissolved Oxygen

EIA

Environmental Impact Assessment

EIAO

Environmental Impact Assessment Ordinance

EM&A

Environmental Monitoring and Audit

EPD

Environmental Protection Department

ER

Engineer’s Representatives

ET

Environmental Team

IEC

Independent Environmental Checker

LCSD

Leisure and Cultural Services Department

LCSVO-JV

Leighton China State Van Oord Joint Venture

LL

Limit Level

PLA

People's Liberation Army Forces Hong Kong

TDD

Territory Development Department

TSP

Total Suspended Particulates

SS

Suspended Solids

WMP

Waste Management Plan

 


Executive Summary

The Central Reclamation Phase III (CRIII) Works, Contract No. HK 12/02, was awarded to Leighton China State Van Oord Joint Venture (LCSVO-JV) by the Civil Engineering and Development Department (CEDD). (Previously called the Territory Development Department before merger with the Civil Engineering Department on 1st July 2004.)

The works under the Contract HK 12/02 commenced on 28th February 2003.  Contract HK 16/03 for the CRIII Hinterland Drainage Improvement Works was awarded to Wang Kee Construction Co. Ltd., and works for this contract commenced on 17th December 2003.

Atkins China Limited (ACL) has been commissioned by CEDD as the Environmental Team (ET) to undertake the Environmental Monitoring and Audit (EM&A) programme described in the approved EM&A Manual for the CRIII Project.

This is the 22nd quarterly EM&A Report for the works specified in Section 1.3 of the CRIII EIA Report.  This report summarises the monitoring results and audit findings of the EM&A program during the reporting period from 1st November 2008 to 31st January 2009.

Environmental Monitoring and Audit Progress

Air quality, noise and water quality monitoring were conducted during this quarter.  Weekly environmental site inspections were also conducted during this reporting quarter.

Exceedance of Action and Limit Levels

No exceedance in TSP level was recorded at the two monitoring stations during this reporting quarter.

Nineteen exceedances of noise were recorded at the City Hall monitoring station on 12th, 18th, 19th and 22nd November 2008 and 12th January 2009.

The exceedances on the 12th November 2008 may have been caused by concurrent operation of both backhoe and drilling activities. ET communicated this with the Contractor on 13th November 2008 (approx. 13:10). The noise exceedances were investigated and it was suggested that the Contractor schedule the construction activities at the former Queen’s Pier carefully.

 

The noise exceedances between the 18th and 19th November 2008 may have been caused by the concurrent operation of drilling activities in the works area of the former Queen’s Pier. ET communicated this with the Contractor representative on 19th September 2008 (approx. 16:20). The noise exceedance was investigated and it was suggested that the drilling works at the former Queen’s Pier should be scheduled and operated carefully.

 

The noise exceedance on the 22nd November 2008 may have been due to the pre-boring works encountering the former seawall at the former Queen’s Pier. The ET communicated this with the Contractor representative on 26th November 2008 (approx. 14:30). The noise exceedance was investigated and it was suggested that the Contractor schedule the construction activities at the former Queen’s Pier carefully.

 

For the noise exceedances outlined above, it was also suggested that short breaks between noisy activities be taken as far as practicable. The Contractor was reminded to provide clear guidelines for the frontline staff to prevent the undertaking of activities such as drilling without short breaks in the former Queen’s Pier works area.

 

Three noise exceedances were also recorded on 17th November 2008. However, the investigation revealed that a pre-war bomb was detonated several times at the Tamar site during this time. As such, the noise exceedances were considered to be attributed to the pre-war bomb detonation rather than the project works, with no immediate actions considered necessary.

On 12th January 2009, activities involving the Ceremonial Opening of the Legal Year 2009 were observed in front of City Hall during the period 13:00 to 15:00 hours where two exceedances were recorded. Following this, decoration dismantling activities were observed, starting after 16:00 hours, where one exceedance was recorded. The exceedances have been investigated and as such, are considered to be attributed to other external factors and unlikely to be related to project works.

Water quality exceedances were recorded on 19 sampling days in this reporting quarter.  All exceedances have been investigated.   All exceedances of Action/Limit Level for DO were considered to have not been related to the Project works. All exceedances of Action/Limit Level for SS were considered to have not been related to the Project works.

Complaint Log

There were no complaints received in relation to environment impact during this reporting quarter.

Notifications of Summons and Prosecutions

There were no notifications of summons or prosecutions received during this reporting quarter.


Site Inspection and Audit

Weekly environmental site inspections were carried out during this quarter.  Minor deficiencies noted during the site inspections were rectified by the Contractor upon receipt of notification. The observations and findings are outlined below:

6th November 2008

The silt curtain at the mouth of FRAE was observed as not fully attached during site inspection. The Contractor was reminded to ensure the silt curtain is installed properly.

13th November 2008

A part of the access road was observed dry with dust emission at IRAW. The contractor was reminded to prevent dust emission from the access roads by watering.

27th November 2008

Some stockpiles of fine materials at FRAW were not covered entirely by sheeting. The Contractor was reminded to prevent dust emissions by ensuring stockpiles of dusty materials are covered entirely by sheeting.

 

4th December 2008

Notification was provided by RE to the Contractor on 2nd December where it was reported that the silt curtain at FRAW was not installed appropriately resulting in leakage of silt. Remedial action took place by the Contractor whereby the silt curtain was properly installed. Appropriate installation was further clarified during the site inspection with no discolouration of water outside the silt curtain observed.

11th December 2008

Muddy discharge was observed in culvert J near the works area of the underpass. The muddy discharge was trapped by various silts curtains in the vicinity of culvert J and no muddy discharge was seen to have dispersed to the Harbour. The Contractor was reminded to provide additional silt curtains to ensure such muddy discharge is localised, if muddy discharge is unavoidable. Further to this, notification was provided by the Contractor on 12th December 2008 whereby it was informed that no further muddy discharge was observed on the same day

The notification was provided by RE to the Contractor on 11th December where it was reported that a large amount of muddy water was being discharged into Culvert F Temporary Diversion Channel from various work fronts along the channel. The follow-up observation to this was conducted with the IEC during this site inspection whereby no muddy water was observed. Further to this, remedial action took place by the Contractor whereby 2 additional silt curtains were installed at culvert F near the General Post Office for precaution. It was reported by the Contractor on 12th December 2008 that further to such installation, no muddy discharge was dispersed to the Harbour.

18th December 2008

Patches of soil contaminated with oil were observed due to machine maintenance in the works area of the former Queen’s Pier. The Contractor was reminded to collect and dispose of the contaminated soils as chemical waste.

24th December 2008

Part of the access roads was observed dry with dust emissions in the works area of former Queen’s Pier. The Contractor was reminded to prevent dust emissions from the access roads by sufficient watering.

 

 8th January 2009

The loading area was observed dry with dust emission at IRAE. The Contractor was reminded to prevent dust emissions from the works area by sufficient watering.

15th January 2009

N/A

22nd January 2009

The Contractor was reminded to cover the stockpiles of dusty material for the prevention of dust emission during the public holiday period.

29th January 2009

N/A

 


1.                  Introduction

1.1              Basic Project Information

The Main Works Contract HK 12/02 for CRIII commenced on 28th February 2003 and was awarded to Leighton-China State-Van Oord Joint Venture (LCSVO-JV) for the construction of the CRIII Engineering Works.  The main construction works that were identified in the EIA Report for the Project, requiring environmental monitoring and audit, have commenced.

This is the 22nd quarterly EM&A Report for the works specified in Section 1.3 of the CRIII EIA Report.  This report summarises the monitoring results and audit findings of the EM&A program during the reporting period from 1st November 2008 to 31st January 2008.

The Contractor's works programme for the quarter is provided in Annex E.

1.2              Project Organisation and Management Structure

Atkins China Limited (ACL) has been commissioned by CEDD as the Environmental Team (ET) to undertake the Environmental Monitoring and Audit (EM&A) programme described in the approved EM&A Manual and required under Clause 4 of the Variation of Further Environmental Permit (No. EP-01/122/2003/A) issued to Leighton-China State-Van Oord Joint Venture in December 2007 for the CRIII Project.  A variation of the Further Environmental Permit for the Project (EP-01/122/2003/B) was granted on 26th May 2008.  This was then superseded by another variation of Further Environmental Permit for the Project (No. EP-01/122/2003/C) granted on 17th July 2008.  The CRIII Project Organisation is shown in Annex A.

1.3              Works Undertaken

The works undertaken in the project area requiring environmental monitoring and audit as identified in the EIA Report (not including Chai Wan Basin) during this reporting quarter include:

·         Rockfilling and geotextile layer behind the seawall in FRAW;

·         Type A filling in FRAW and FRAE above +2.5mPD;

·         Surcharging in FRAW and FRAE;

·         Rockfilling behind the seawalls in FRAE;

·         Installation of seawall blocks in FRAE & FRAW;

·         Construction of cantilever slab at caisson;

·         Pre-drilling and piling for Culvert F;

·         Sheet piling, Excavation and Structural works for Culvert F;

·         Structural works for Public Pier East (Pier No.10);

·         Structural works for the MTRC 40 metre EOT;

·         Remedial and outstanding works at and around Piers 7 & 8, Public Pier West and the CTB;

·         General filling works above +2.5 mPD in IRAE;

·         Construction of storm and foul drainage and gullies in hinterlands for Road P2, Road D7, Road D8 and Road D9 and adjacent to the GPO;

·         Structural works for Eastern tunnel and Pump Sump and sheetpiling for Western Ramp at Road P2 Underpass;

·         Roadworks along Lung Wui Road, Tim Wa Avenue (Road D8) and Road P2;

·         Excavation and structural works for Culvert K extension ;

·         Precasting for Culvert K, seawall blocks and retaining wall (offsite);

·         Installation of cooling water mains for Tamar Development Project at IRAE;

·         Reinstatement works for Culvert J; and

·         Construction of New ER Office.

 

 

 

 


2.                  EM&A Requirements

2.1              Summary of Impact EM&A Requirements

The EM&A programme requires environmental monitoring for air quality, noise, waster quality, waste management and landscape and visual aspects as specified in the CRIII Project EIA.  The EM&A requirements for each issue area are described in subsequent sections including:

·         All required monitoring parameters;

·         Action and Limit Levels; and

·         Event-Action Plans.

A summary of impact EM&A requirements is presented in Table 2-1.

Table 2.1 - Summary of Impact EM&A Requirements

Parameters

Descriptions

Locations

Frequencies

Duration

TSP

24-Hour TSP

2 Locations

Once every 6 days

During dust generating construction works

1-Hour TSP

2 Locations

Three times in every 6 days

During dust generating construction works

Noise

Leq (30 mins), L10, L90,

1 Location

Continuous measurements

Two weeks before Construction and During Construction

Water Quality

Dissolved Oxygen;

Salinity;

Temp;

Suspended Solids;

Turbidity.

16 Locations

3 times a week, Mid-ebb/flood tides

During Marine Works and for 4 weeks after completion of Marine Works

Waste

On-Site Waste Audit

Active Work Sites

Periodically

During Construction

On-Site Waste Inspection

Landscape and Visual

Audits to ensure effective implementation of mitigation measures

During Construction

General Site Conditions

Environmental Site Inspection

Works areas and areas affected by works

Periodically

During Construction

 

Additional water quality monitoring for the “Type A fill” filling works was undertaken by the Contractor (LCSVO-JV) in accordance with Condition 3.3 of Environmental Permit No. EP-01/122/2003/C.  Phase 2 monitoring for filling works at FRAW was as conducted on 5th, 7th and 10th November 2008. “Type A fill” filling works by bottom dumping at FRAW was completed thereafter, therefore the additional Water Quality Monitoring for Type A filling was ceased from 14th November 2008.

 

2.2              Environmental Quality Performance Limits

Environmental Quality Performance Limits for air quality, noise and water quality have been established as part of the Baseline Monitoring Report and are provided in Annex B.

2.3              Event Action Plan

Event Action Plans for air quality, noise and water quality have been developed as part of the Baseline Monitoring Report and are provided in Annex C.

 

 


3.                  Environmental Status

3.1              Implementation of Environmental Measures

The Contractor has implemented relevant mitigation measures listed in the EIA Report, EM&A Manual and Further Environmental Permit.  

3.2              Environmental Monitoring Locations

Drawings showing the project area and locations of the monitoring stations are provided in Annex D. 

3.3              Air Quality Monitoring Results

The graphical plot of air quality monitoring results for this reporting quarter is provided in Annex F. 

3.4              Noise Quality Monitoring Results

The graphical plot of noise monitoring results for this reporting quarter is provided in Annex G.    

3.5              Water Quality Monitoring Results

The graphical plot of water quality monitoring results for this reporting quarter is provided in Annex H.  The water quality monitoring at stations M2A, M3_M5A, M4B and M5B on 17th November 2008 was cancelled due to the detonation of pre-war bomb in the site area.

3.6              Solid and Liquid Waste Management Status

Solid and liquid waste management was implemented according to the Waste Management Plan during this reporting quarter.

3.7              Landscape and Visual Audit

As the works undertaken during this reporting quarter were mainly related to reclamation, buildings and infrastructure works, the landscape and visual impacts are considered to be minimal.

 


4.                  Environmental Complaint and Non-Compliance

4.1              Environmental Exceedances

No exceedance in TSP level was recorded at the two monitoring stations during this reporting quarter.

Nineteen exceedances of noise were recorded at the City Hall monitoring station on 12th, 18th, 19th and 22nd November 2008 and 12th January 2009.

The exceedances on the 12th November 2008 may have been caused by concurrent operation of both backhoe and drilling activities. ET communicated this with the Contractor on 13th November 2008 (approx. 13:10). The noise exceedances were investigated and it was suggested that the Contractor schedule the construction activities at the former Queen’s Pier carefully.

 

The noise exceedances between the 18th and 19th November 2008 may have been caused by the concurrent operation of drilling activities in the works area of the former Queen’s Pier. ET communicated this with the Contractor representative on 19th September 2008 (approx. 16:20). The noise exceedance was investigated and it was suggested that the drilling works at the former Queen’s Pier should be scheduled and operated carefully.

 

The noise exceedance on the 22nd November 2008 may have been due to the pre-boring works encountering the former seawall at the former Queen’s Pier. The ET communicated this with the Contractor representative on 26th November 2008 (approx. 14:30). The noise exceedance was investigated and it was suggested that the Contractor schedule the construction activities at the former Queen’s Pier carefully.

 

For the noise exceedances outlined above, it was also suggested that short breaks between noisy activities be taken as far as practicable. The Contractor was reminded to provide clear guidelines for the frontline staff to prevent the undertaking of activities such as drilling without short breaks in the former Queen’s Pier works area.

 

Three noise exceedances were also recorded on 17th November 2008. However, the investigation revealed that a pre-war bomb was detonated several times at the Tamar site during this time. As such, the noise exceedances were considered to be attributed to the pre-war bomb detonation rather than the project works, with no immediate actions considered necessary.

On 12th January 2009, activities involving the Ceremonial Opening of the Legal Year 2009 were observed in front of City Hall during the period 13:00 to 15:00 hours where two exceedances were recorded. Following this, decoration dismantling activities were observed, starting after 16:00 hours, where one exceedance was recorded. The exceedances have been investigated and as such, are considered to be attributed to other external factors and unlikely to be related to project works.

Water quality exceedances were recorded on 19 sampling days in this reporting quarter.  All exceedances have been investigated.   All exceedances of Action/Limit Level for DO were considered to have not been related to the Project works. All exceedances of Action/Limit Level for SS were considered to have not been related to the Project works.

The water quality exceedances during this reporting quarter are summarised in Table 4.1.

 Table 4.1 - Summary Water Quality Exceedances from November 2008 to January 2009

 

 

Date

Tide

Parameter

Exceedance

Station

Water Quality Monitoring in Accordance with EM&A Manual

3rd November 2008

Mid-ebb

DO

AL

M1A, M2A, M3_M5A, M4B, M5B, M6, M10(B), M11 and M12

Mid-flood

DO

AL

M2A, M3_M5A, M4B, M5B, M6, M10(B), M11 and M12

SS

AL

M5B

5th November 2008

Mid-ebb

DO

AL

M1A, M2A, M3_M5A, M4B, M5B, M6, M10(B), M11 and M12

Mid-flood

DO

AL

M1A, M2A, M3_M5A, M4B, M5B, M6, M10(B), M11 and M12

7th November 2008

Mid-ebb

DO

AL

M1A, M2A, M3_M5A, M4B, M5B, M6, M8(S/M), M8(B), M10(B), M11 and M12

Mid-flood

DO

AL

M1A, M2A, M3_M5A, M4B, M5B, M6, M8(S/M), M8(B), M10(S/M), M10(B), M11 and M12

10th November 2008

Mid-ebb

DO

AL

M2A, M4B, M5B, M6m M8(B) and M12

Mid-flood

DO

AL

M1A, M2A, M3_M5A, M4B, M5B, M6, M8(B), M11 and M12

SS

AL

M5B

12th November 2008

Mid-ebb

DO

AL

M6 and M12

Mid-flood

DO

AL

M6

SS

AL

M6

14th November 2008

Mid-ebb

DO

AL

M6, M11 and M12

SS

AL

M6 and M12

Mid-ebb

DO

AL

M8(B)

SS

AL

M3_M5A and M12

17th November 2008

Mid-flood

DO

AL

M10(B)

SS

AL

M1A and M11

19th November 2008

Mid-flood

DO

AL

M8(B)

SS

AL

M1A

24th November 2008

Mid-ebb

DO

AL

M1A, M2A, M3_M5A, M4B, M5B, M6, M8(B), M10(B), M11 and M12

Mid-flood

DO

AL

M1A, M2A, M3_M5A, M4B, M5B, M6, M8(B), M10(B), M11 and M12

26th November 2008

Mid-ebb

DO

AL

M1A, M2A, M3_M5A, M4B, M5B, M6, M11 and M12

Mid-flood

DO

AL

M1A, M2A, M3_M5A, M4B, M5B, M6, M8(B), M11 and M12

1st December 2008

Mid-flood

SS

AL,LL

M6 and M12

3rd December 2008

Mid-ebb

DO

AL

M6

5th December 2008

Mid-ebb

DO

AL

M6

8th December 2008

Mid-ebb

DO

AL

M2A

10th December 2008

Mid-ebb

DO

AL

M1A, M2A, M4B and M5B

Mid-flood

DO

AL

M6 and M12

12th December 2008

Mid-ebb

DO

AL

M6 and M12

Mid-flood

DO

AL

M1A, M6, M10(B), M11 and M12

19th December 2008

Mid-ebb

DO

AL

M4B, M5B, M6 and M12

Mid-flood

DO

AL

M2A, M4B, M6 and M12

22nd December 2008

Mid-ebb

DO

AL

M6 and M12

Mid-flood

DO

AL

M6

5th January 2009

Mid-ebb

DO

AL

M6

 

Additional Water Quality Monitoring Conducted by the Contractor

12th November 2008

Mid-ebb

SS

AL

Combined marine impact monitoring station (AM1-AM3)

A statistical analysis (presented in Annex I) of the suspended solids monitoring results found that the quarterly mean is significantly less than 1.3 times of the ambient mean recorded during the baseline period.  This indicates that the Project construction works did not cause adverse impacts during the reporting period with respect to the baseline condition.

4.2              Non-Compliance

No non-compliance with regard to site environmental audit was recorded during the reporting period.

4.3              Summary of Actions Taken by the Contractor

The Contractor has implemented the following measures to prevent air and water quality impacts:

·         Contractor has implemented their Drainage Management Plan to Control Site Run-off for the wet season – actions completed and underway include: repair and improvement of existing bunds/sandbags on the edge of the reclamation; installation of additional bunds; compaction of soil surface and paths where possible to prevent erosion, creation of drainage channels and soak pits; 

·         Provision of a single WetSep flocculation based water treatment plant and additional settlement tanks to remove suspended solids from discharge waters;

·         Provision of catch pits to collect spill over from wheel washing facilities and increased frequency of cleaning of catch-pits; and

·         Water browsing of haul roads and other areas of the site and covering of stockpiles.

4.4              Environmental Enquiries

No environmental enquiries were received during this reporting quarter.

4.5              Environmental Complaints and Prosecutions

No environmental complaints were received during this reporting quarter.

4.6              Record of Environmental Complaints and Summons & Prosecutions

There was no record of environmental complaints during this reporting quarter.

There were no notifications of summons and prosecutions during this reporting quarter.

 

 

 


5.                  Conclusion

During the environmental site inspections conducted within this reporting quarter, no non-compliances were noted and no prosecutions were received during this reporting quarter.

No exceedance in TSP level was recorded at the two monitoring stations during this reporting quarter.

Nineteen exceedances of noise were recorded at the City Hall monitoring station on 12th, 18th, 19th and 22nd November 2008 and 12th January 2009.

The exceedances on the 12th November 2008 may have been caused by concurrent operation of both backhoe and drilling activities. ET communicated this with the Contractor on 13th November 2008 (approx. 13:10). The noise exceedances were investigated and it was suggested that the Contractor schedule the construction activities at the former Queen’s Pier carefully.

 

The noise exceedances between the 18th and 19th November 2008 may have been caused by the concurrent operation of drilling activities in the works area of the former Queen’s Pier. ET communicated this with the Contractor representative on 19th September 2008 (approx. 16:20). The noise exceedance was investigated and it was suggested that the drilling works at the former Queen’s Pier should be scheduled and operated carefully.

 

The noise exceedance on the 22nd November 2008 may have been due to the pre-boring works encountering the former seawall at the former Queen’s Pier. The ET communicated this with the Contractor representative on 26th November 2008 (approx. 14:30). The noise exceedance was investigated and it was suggested that the Contractor schedule the construction activities at the former Queen’s Pier carefully.

 

For the noise exceedances outlined above, it was also suggested that short breaks between noisy activities be taken as far as practicable. The Contractor was reminded to provide clear guidelines for the frontline staff to prevent the undertaking of activities such as drilling without short breaks in the former Queen’s Pier works area.

 

Three noise exceedances were also recorded on 17th November 2008. However, the investigation revealed that a pre-war bomb was detonated several times at the Tamar site during this time. As such, the noise exceedances were considered to be attributed to the pre-war bomb detonation rather than the project works, with no immediate actions considered necessary.

On 12th January 2009, activities involving the Ceremonial Opening of the Legal Year 2009 were observed in front of City Hall during the period 13:00 to 15:00 hours where two exceedances were recorded. Following this, decoration dismantling activities were observed, starting after 16:00 hours, where one exceedance was recorded. The exceedances have been investigated and as such, are considered to be attributed to other external factors and unlikely to be related to project works.

Water quality exceedances were recorded on 19 sampling days in this reporting quarter.  All exceedances have been investigated.   All exceedances of Action/Limit Level for DO were considered to have not been related to the Project works. All exceedances of Action/Limit Level for SS were considered to have not been related to the Project works.