Contract No: HK/2011/07 Wanchai
Development Phase II and Central Wanchai Bypass Sampling, Field Measurement and Testing Work (Stage 2) Environmental Permit
no. EP-376/2009 Monthly
Environmental Monitoring & Audit Report
- May 2015 -
|
CLIENTS: |
|
Civil Engineering and
Development Department |
Lam Geotechnics Limited 11/F Centre Point 181-185
Gloucester Road, Wanchai, H.K. Telephone:
(852) 2882-3939 Facsimile:
(852) 2882-3331 E-mail:
info@lamenviro.com Website:
http://www.lamenviro.com |
|
|
|
|
|
Certified
by: |
|
Raymond
Dai Environmental
Team Leader |
|
DATE: |
|
June 2015 |
2.2 Scope
of the Project and Site Description
2.3 Project
Organization and Contact Personnel
3 status of regulatory compliance
3.1 Status
of Environmental Licensing and Permitting under the Project
5.2 Air
Quality Monitoring Results
6.3 Review
of the Reasons for and the Implications of Non-compliance
6.4 Summary
of action taken in the event of and follow-up on non-compliance
7 Cumulative Construction Impacts due to the Concurrent Projects
9 Complaints,
Notification of Summons and Prosecution
lIST OF TABLES
Table 2.1 Schedule 2 Designated Projects under this
Project
Table 2.2 Contact Details of Key Personnel
Table 3.2 Cumulative Summary of Valid Licences and Permits under Contract no.
HK/2012/08
Table 3.3 Summary of submission status under FEP-01/376/2009 Condition
Table 4.1 Continuous Noise Monitoring Stations
Table 4.2 Air Quality Monitoring Stations
Table 5.1 Continuous Noise Monitoring Stations for Contract no. HK/2012/08
Table 5.2 Air Quality Monitoring Station for Contract no. HK/2012/08
Table 5.3 Details
of Waste Disposal for Contract no. HK/2012/08
Table 8.1 Summary of Environmental Inspections for Contract no. HK/2012/08
Table 9.1 Cumulative Statistics on Complaints
Table 9.2 Cumulative Statistics on Successful Prosecutions
LIST OF FIGURES
Figure 2.1 Project Layout
Figure 2.2 Project Organization Chart
Figure 4.1 Locations of
Environmental Monitoring Stations
lIST OF APPENDIces
Appendix 3.1 Environmental Mitigation Implementation Schedule
Appendix 4.1 Action and Limit Level
Appendix 4.2 Copies of Calibration Certificates
Appendix 5.1 Monitoring Schedule for Reporting Month and Coming month
Appendix 5.2 Continuous Noise Monitoring Results and
Graphical Presentations
Appendix 5.3 Air Quality
Monitoring Results and Graphical Presentations
Appendix 6.1 Event Action Plans
Appendix 6.2 Notification
of Exceedance
Appendix 9.1 Complaint Log
Appendix 10.1 Construction Programme of Individual Contracts
Contract no.
HK/2012/08 – Wan Chai Development Phase II – Central- Wan Chai Bypass at Wan
Chai West
·
Site preparation works
·
Utilities
Noise Monitoring
Air Quality
Monitoring
Complaints,
Notifications of Summons and Successful Prosecutions
Site Inspections and
Audit
Future Key Issues
Contract no. HK/2012/08 – Wan Chai Development
Phase II – Central- Wan Chai Bypass at Wan Chai West
·
Utilities
1.1.1.
Lam Geotechnics Limited (LGL) has been appointed take up the role as the
Environmental Team (ET) under Environmental Permit no. EP-376/2009 and Further
Environmental Permit no. FEP-01/376/2009 to implement the Environmental
Monitoring and Audit (EM&A) programme as stipulated in the EM&A Manual
of the approved Environmental Impact Assessment (EIA) Report for Wan Chai
Development Phase II and Central-Wan Chai Bypass (Register No.: AEIAR-458/2008).
1.1.2.
This report documents the finding of EM&A
works for Environmental Permit (EP) no. EP-376/2009
and Further Environmental Permit no. FEP-01/376/2009, during the period of May 2015. The
cut-off date of reporting is the 27th of each reporting month.
Section 1 Introduction – details the scope and structure of the report.
Section 2 Project
Background – summarizes background and
scope of the project, site description, project organization and contact
details of key personnel during the reporting period.
Section 3 Status of Regulatory Compliance – summarizes the status of valid Environmental Permits /
Licenses during the reporting period.
Section 4 Monitoring
Requirements – summarizes all monitoring
parameters, monitoring methodology and equipment, monitoring locations, monitoring
frequency, criteria and respective event and action plan and monitoring
programmes.
Section 5 Monitoring
Results – summarizes the monitoring
results obtained in the reporting period.
Section 6 Compliance Audit – summarizes
the auditing of monitoring results, all exceedances environmental
parameters.
Section 7 Cumulative Construction Impact due
to the Concurrent Projects – summarizes the relevant cumulative
construction impact due to the concurrent activities of the concurrent Projects.
Section 8 Environmental
Site Audit – summarizes the findings of
weekly site inspections undertaken within the reporting period, with a review of any relevant follow-up actions within the reporting period.
Section 9 Complaints,
Notification of summons and Prosecution – summarizes the cumulative statistics on complaints, notification of summons and
prosecution
Section 10 Conclusion
2.1.1
Wan Chai Development phase II and Central-Wan
Chai Bypass (hereafter called “the Project”) are Designated Project (DP) under
the Environmental Impact Assessment Ordinance (Cap. 499) (EIAO). The
Environmental Impact Assessment (EIA) Report for Wan Chai Development phase II
and Central-Wan Chai Bypass (Register No.: AEIAR-125/2008) has been approved on
11 December 2008.
2.2.1.
The design and construction of Wan Chai
Development Phase II and Central Wanchai Bypass involves the construction and
operation of primary and district distributor roads that is shown at Figure 2.1.
2.2.2.
The key purpose of the study area encompasses the Wan Chai harbourfront area. The area starts
at the boundary of Central Reclamation Phase III (CRIII) at the west and
connects to the existing Hung Hing Road at the east. The scope of the project includes:
·
A
dual 2-lane primary distributor road, Road P2, approximately 0.6km in length;
and
·
Other
new primary and district distributor roads connecting to the slip roads of the
Central-Wan Chai Bypass with a total length of approximately 0.7km.
2.2.3.
The project also contains various Schedule 2 DP that, under the EIAO,
require Environmental Permits (EPs) to be granted by the DEP before they may be
either constructed or operated. Table 2.1 summarises the DP under
this Project. Figure
2.1 shows the locations of these Schedule 2 DP.
Table
2.1 Schedule
2 Designated Projects under this Project
Item |
Designated Project |
EIAO Reference |
DP2
|
Road
P2 and other roads which are classified as primary/district distributor roads
|
Schedule
2, Part I, A.1 |
2.2.4.
The designated project work II (DP2) was
awarded to China State-Leader Joint Venture HK/2012/08 as part of the Project
works by the Civil Engineering and Development Department (CEDD). The construction work under Contract no. HK/2012/08 was commenced on 13 May 2015.
2.3.1
Civil
Engineering and Development Department is the overall project controllers for the Central Reclamation Phase III Project. For
the construction phase of the Project, Project Engineer, Contractor(s),
Environmental Team and Independent Environmental Checker are appointed to
manage and control environmental issues.
2.3.2
The
proposed project organization and lines of communication with respect to
environmental protection works are shown in Figure
2.2. Key personnel and contact particulars are
summarized in Table 2.2:
Table 2.2 Contact Details
of Key Personnel
Party |
Role |
Post |
Name |
Contact No. |
Contact Fax |
AECOM |
Engineer’s
Representative for WDII |
Principal
Resident Engineer |
Mr.
Frankie Fan |
2587
1778 |
2587 1877 |
Engineer’s
Representative for CWB |
Principal
Resident Engineer |
Mr.
Peter Poon |
3922
3388 |
3912 3010 |
|
China
State- Leader JV |
Contractor
under Contract no. HK/2012/08 |
Project Director |
C.
N. LAI |
9106 5806 |
2877 1522 |
Project Manager |
Mr.
Eddie Chung |
9189
8118 |
|||
Site Agent |
Mr.
Keith Tse |
9037 1839 |
|||
Environmental Officer |
Mr.
James
Ma |
9130 9549 |
|||
Environmental Supervisor |
Mr. Y. L. HO |
9856 5669 |
|||
ENVIRON
Hong Kong
Limited |
Independent Environmental
Checker (IEC) |
Independent Environmental
Checker (IEC) |
Mr.
David Yeung |
3465
2888 |
3465
2899 |
Lam Geotechnics Limited |
Environmental Team (ET) |
Environmental Team Leader (ETL) |
Mr.
Raymond
Dai |
2882 3939 |
2882 3331 |
2.3.3
In
this reporting month, the principal work activities of the contract is included
as follows:
Contract no. HK/2012/08 – Wan Chai Development
Phase II – Central- Wan Chai Bypass at Wan Chai West
·
Site preparation works
·
Utilities
2.3.4
In
coming reporting month, the principal work activities of the contract is
anticipated as follows:
Contract no.
HK/2012/08 – Wan Chai Development Phase II – Central- Wan Chai Bypass at Wan
Chai West
·
Utilities
3.1.1.
A summary of the current status on licences and/or permits on
environmental protection pertinent to the Project is shown in Table 3.1.
Table 3.1 Summary
of the current
status on licences and/or permits on environmental protection pertinent to the
Project
Permits
and/or Licences |
Reference
No. |
Issued
Date |
Status |
Environmental Permit |
EP-376/2009 |
13 Nov 2009 |
Valid |
Further Environmental Permit |
FEP-01/376/2009 |
31 Mar 2015 |
Valid |
3.1.2.
The current status on licences and/or permits on environmental
protection pertinent for contract no. HK/2012/08 showed in Table 3.2. and Table
3.3
Table
3.2 Cumulative Summary of Valid Licences and Permits
under Contract no. HK/2012/08
Permits and/or Licences |
Reference No. |
Issued Date |
Valid
Period/ Expiry Date |
Status |
Notification
of Works Under APCO |
355439 |
4 Feb 2013 |
N/A |
Valid |
Registration
as a Chemical Waste Producer |
5213-134-C3790-01 |
8 Mar 2013 |
N/A |
Valid |
Billing
Account under Waste Disposal Ordinance |
7016883 |
18 Feb 2013 |
18 Jul 2017 |
Valid |
Water Discharge Licence |
WT00018470-2014 |
6 Mar 2014 |
31 Mar 2019 |
Valid |
Construction Noise Permit |
GW-RS0223-15 |
3 Mar 2015 |
9 Mar 2015 to 8 Sep 2015 |
Valid |
Table 3.3 Summary of submission status under FEP-01/376/2009
Condition
EP Condition |
Submission |
Date of Submission |
Condition 2.9 |
Noise Management Plan (Rev. 0) |
16 Apr 2015 |
Condition 2.10 |
Landscape Plan (Rev. 0) |
21 Apr 2015 |
3.1.3.
Implementation status of the recommended mitigation measures during this
reporting month is presented in Appendix 3.1.
NOISE Monitoring Stations
4.1.1.
The continuous noise monitoring station for the Project is listed and
shown in Table 4.1 and Figure
4.1.. Appendix 4.1 shows the established Action/Limit
Levels for the monitoring works.
Table 4.1 Continuous Noise
Monitoring Stations
District |
Station |
Description |
Wan Chai |
M1a |
Harbour Road Sport Centre |
Noise Monitoring
Parameters, Frequency and Duration
4.1.2. Continuous
24-hour noise monitoring shall be carried out at the
designated monitoring stations. The following is an initial guide on the
regular monitoring frequency for each station on a 24 hours daily basis when
noise generating activities are underway:
·
One
set of measurements between 0700 and 1900 hours on normal weekdays.
·
One
set of measurements between 1900 and 2300 hours on normal weekdays and 0700 and
2300 hours on public holidays.
·
One
set of measurements between 2300 and 0700 hours on next day on every day.
4.1.3. If construction
works are extended to include works during the hours of 1900 – 0700 as well as
public holidays and Sundays, additional weekly impact monitoring shall be
carried out during respective restricted hours periods. Applicable permits
under NCO shall be obtained by the Contractor.
Monitoring Equipment
4.1.4. As
referred to in the Technical Memorandum ™ issued under the NCO, sound level
meters in compliance with the International Electrotechnical Commission
Publications 651: 1979 (Type 1) and 804: 1985 (Type 1) specifications shall be
used for carrying out the noise monitoring. Immediately prior to and following
each noise measurement the accuracy of the sound level meter shall be checked
using an acoustic calibrator generating a known sound pressure level at a known
frequency. Measurements may be accepted as valid only if the calibration level
from before and after the noise measurement agrees to within 1.0 dB.
4.1.5. Noise
measurements shall not be made in fog, rain, wind with a steady speed exceeding
5 m/s or wind with gusts exceeding 10 m/s. The wind speed shall be checked with
a portable wind speed meter capable of measuring the wind speed in m/s.
4.1.6. The sound
level meter shall be checked using an acoustic calibrator generating a known
sound pressure level at a known frequency before deployment to the site and
during each site visit. Measurements will be accepted as valid only if the
calibration level from before and after the noise measurement agrees to within
1.0 dB.
Air Quality Monitoring
Stations
4.2.1. The air
quality monitoring stations for the Project are listed and shown in Table
4.2 and Figure 4.1.. Appendix 4.1 shows the
established Action/Limit Levels for the monitoring works.
Table 4.2 Air Quality Monitoring Stations
Station ID |
Description |
CMA5b |
Pedestrian Plaza |
CMA6a |
WDII PRE Site Office |
Air QUALITY Monitoring
Parameters, Frequency and Duration
4.2.2. One-hour
and 24-hour TSP levels should be measured to indicate the impacts of
construction dust on air quality. The 24-hour TSP levels shall be measured by
following the standard high volume sampling method as set out in the Title 40
of the Code of Federal Regulations, Chapter 1 (Part 50), Appendix B.
4.2.3. All
relevant data including temperature, pressure, weather conditions, elapsed-time
meter reading for the start and stop of the sampler, identification and weight
of the filter paper, and any other local atmospheric factors affecting or
affected by site conditions, etc., shall be recorded down in detail.
4.2.4. For
regular impact monitoring, the sampling frequency of at least once in every
six-days, shall be strictly observed at all the monitoring stations for 24-hour
TSP monitoring. For 1-hour TSP monitoring, the sampling frequency of at least
three times in every six-days should be undertaken when the highest dust impact
occurs.
Sampling Procedure and
Monitoring Equipment
4.2.5. High
volume samplers (HVSs) in compliance with the following specifications shall be
used for carrying out the 1-hour and 24-hour TSP monitoring:
·
0.6
– 1.7 m3 per minute adjustable flow range;
·
Equipped
with a timing / control device with +/- 5 minutes accuracy for 24 hours
operation;
·
Installed
with elapsed-time meter with +/- 2 minutes accuracy for 24 hours operation;
·
Capable
of providing a minimum exposed area of 406 cm2;
·
Flow
control accuracy: +/- 2.5% deviation over 24-hour sampling period;
·
Equipped
with a shelter to protect the filter and sampler;
·
Incorporated
with an electronic mass flow rate controller or other equivalent devices;
·
Equipped
with a flow recorder for continuous monitoring;
·
Provided
with a peaked roof inlet;
·
Incorporated
with a manometer;
·
Able
to hold and seal the filter paper to the sampler housing at horizontal
position;
·
Easily
changeable filter; and
·
Capable
of operating continuously for a 24-hour period.
4.2.6. Initial
calibration of dust monitoring equipment shall be conducted upon installation
and thereafter at bi-monthly intervals. The transfer standard shall be
traceable to the internationally recognized primary standard and be calibrated
annually. The concern parties such as IEC shall properly document the
calibration data for future reference. All the data should be converted into
standard temperature and pressure condition.
Laboratory Measurement /
Analysis
4.2.7. A clean
laboratory with constant temperature and humidity control, and equipped with
necessary measuring and conditioning instruments to handle the dust samples
collected, shall be available for sample analysis, and equipment calibration
and maintenance. The laboratory should be HOKLAS accredited.
4.2.8. Filter
paper of size 8” x 10” shall be labelled before sampling. It shall be a clean
filter paper with no pinholes, and shall be conditioned in a
humidity-controlled chamber for over 24-hours and be pre-weighed before use for
the sampling.
4.2.9. After
sampling, the filter paper loaded with dust shall be kept in a clean and
tightly sealed plastic bag. The filter paper shall then be returned to the
laboratory for reconditioning in the humidity controlled chamber followed by
accurate weighing by an electronic balance with readout down to 0.1 mg. The
balance shall be regularly calibrated against a traceable standard.
4.2.10. All the
collected samples shall be kept in a good condition for 6 months before
disposal.
4.2.11. Current
calibration certificates of equipment are presented in Appendix 4.2.
5.0.1. The
environmental monitoring will be implemented based on the division of works
areas of each designated project managed under different contracts with
separate FEP applied by individual contractors.
Overall layout showing work areas of various contracts, latest status of
work commencement and monitoring stations is shown in Figure 2.1 and Figure 4.1. The
monitoring results are presented in according to the Individual Contract(s).
5.0.2. In the
reporting month, the concurrent contract is:
Contract
no. HK/2012/08 – Wan Chai Development Phase II – Central – Wan Chai Bypass at
Wan Chai West.
5.0.3. The
environment monitoring schedules for reporting month and coming month are
presented in Appendix
5.1.
5.1.1
The proposed division of noise monitoring stations is summarized in Table
5.1 below.
Table 5.1 Continuous Noise Monitoring
Stations for Contract no. HK/2012/08
Location
ID |
District |
Description |
M1a |
Wan
Chai |
Harbour Road Sport Centre |
Remarks: Continuous noise monitoring results
and graphical presentation for ACL3 during restricted hours and night time
period are for information only.
5.1.2
No exceedances
were recorded at M1a – Harbour Road Sport Centre in the reporting month.
5.1.3
Continuous noise monitoring results measured in this reporting period
are reviewed and summarized. Details of continuous noise monitoring results and
graphical presentation can be referred to Appendix
5.2.
5.2.1 The
proposed division of air quality monitoring stations are summarized in Table
5.2 below.
Table 5.2
Air
Quality Monitoring Station for Contract no. HK/2012/08
Station |
Description |
CMA5b |
Pedestrian Plaza |
CMA6a |
WDII PRE Site Office |
5.2.2
No exceedances
were recorded in the reporting month.
5.2.3
The air quality monitoring results measured
in this reporting period are reviewed and summarized. Details of air quality monitoring results and
graphical presentation can be referred in Appendix 5.3.
5.3.1 Inert and
non-inert C&D wastes were disposed in this reporting month. Details of the
waste flow table are summarized in Table 5.3.
Table 5.3 Details of Waste Disposal
for Contract no. HK/2012/08
Waste Type |
Quantity this month |
Cumulative
Quantity-to-Date |
Disposal / Dumping Grounds |
Inert C&D materials disposed, m3 |
NIL |
NIL |
NIL |
Inert C&D materials recycled, m3 |
NIL |
NIL |
NIL |
Non-inert C&D materials disposed, m3 |
NIL |
NIL |
NIL |
Non-inert C&D materials recycled, m3 |
NIL |
NIL |
NIL |
Chemical waste disposed, kg |
NIL |
NIL |
NIL |
6.0.1. The Event
Action Plan for construction noise and air quality are presented in Appendix 6.1.
6.1.1. No exceedance was recorded in this reporting
month.
6.2.1.
No exceedances were recorded in the reporting month.
6.3.1 There was
no non-compliance from the site audits in the reporting period. The
observations and recommendations made in each individual site audit session
were presented in Section 8.
6.4.1 There was
no particular action taken since no non-compliance was recorded from the site
audits in the reporting period.
7.0.1. According
to the Condition 3.4 of the EP-376/2009, this section addresses the relevant
cumulative construction impact due to the concurrent activities of the current
projects including the Central Reclamation Phase III (CRIII), Wan Chai
Development Phase II (WDII), Central-WanChai Bypass (CWB), Island Eastern
Corridor Link projects (IECL) and Wan Chai Development Phase II – Central – Wan
Chai Bypass at Wan Chai East (CWB Tunnel).
7.0.2.
According
to the Final EM&A report of Central Reclamation Phase III (CRIII) for
Contract HK 12/02, the major construction activities were completed by end of
January 2014 and no construction activities were undertaken thereafter and the
water quality monitoring was completed in October 2011. As such, it is considered that there were no
cumulative construction impact due to the concurrent activities of the current
projects with the Central Reclamation Phase III (CRIII) undertaken by
contractor HK12/02 in the reporting month.
7.0.3.
According to the construction programme of Central-Wanchai Bypass at
Wanchai West at the Central Reclamation Phase III area, removal of L-shape wall
and installation of caisson seawall were performed in May 2015 reporting month.
As no project related exceedance were recorded during the reporting
period, cumulative construction impact due to the concurrent activities of the
current projects with the Central Reclamation Phase III (CRIII) was considered
as insignificant.
7.0.4. According
to the construction programme of Wan Chai Development Phase II, Central-Wan
Chai Bypass and Island Eastern Corridor Link projects, the major construction
activities under Wan Chai Development Phase II were marine works at HKCEC area,
tunnel works and foundation works at Wan Chai East and temporary reclamation at
Wan Chai West. The major construction activities under Central-Wan Chai Bypass
and Island Eastern Corridor Link Projects were bridge construction and road
works at Central Interchange, land based bored pilling works and ELS works at
Victoria Park, D- wall construction and ELS at TS3, IEC demolition and tunnel
works at North Point area in the reporting month.
7.0.5. No significant air impact from construction activities was anticipated
in the reporting month. Besides, no project related exceedance was recorded
during the water, air and noise environmental monitoring events in the
reporting month. Thus, it is evaluated that the cumulative construction impact
from the concurrent projects including Central Reclamation Phase III (CRIII),
Wan Chai Development Phase II (WDII), Central-WanChai Bypass (CWB), Island
Eastern Corridor Link projects (IECL) was insignificant.
8.0.1.
Two site inspections for
Contract no. HK/2012/08
were carried out in the reporting month on 19 and 27 May
2015. The results of inspection
and outcome are summarized in Table
8.1.
Table 8.1 Summary
of Environmental Inspections for Contract no. HK/2012/08
Item |
Date |
Observations |
Action taken by Contractor |
Outcome |
150519_01 |
19-May-15 |
Cement bags on site shall be covered to avoid any potential dust
emission. |
Cement bags were covered by impermeable sheet. |
Completion
as observed on 27 May 2015 |
150519_02 |
19-May-15 |
Construction effluent shall be collected and water bund shall be
provided at HKCEC2W existing seawall to mitigate water contamination from
direct discharge. |
The source of generating construction effluent has been diverted
on site to mitigate water contamination from direct discharge. |
Completion
as observed on 27 May 2015 |
150519_03 |
19-May-15 |
Floating refuses at the water channel shall be cleaned regularly. |
Floating refuses were collected at the water channel. |
Completion
as observed on 27 May 2015 |
150527_01 |
27-May-15 |
Construction effluent and soft material on existing seawall at
Zone D shall be cleaned up to prevent runoff impact to the waterbody. |
Construction effluent and soft material on existing seawall at
Zone D has been cleared. |
Completion
as observed on 2 June 2015 |
9.0.1. No
environmental complaint was received in the reporting period.
9.0.2.
The details of cumulative complaint log and updated summary of
complaints are presented in Appendix 9.1
9.0.3. Cumulative
statistic on complaints and successful prosecutions are summarized in Table
9.1 and Table 9.2 respectively.
Table 9.1 Cumulative Statistics on
Complaints
Reporting
Period |
No.
of Complaints |
May 2015 |
0 |
Total |
0 |
Table 9.2 Cumulative
Statistics on Successful Prosecutions
Environmental
Parameters |
Cumulative
No. Brought Forward |
No.
of Successful Prosecutions this month (Offence Date) |
Cumulative
No. Project-to-Date |
Air |
0 |
0 |
0 |
Noise |
0 |
0 |
0 |
Water |
0 |
0 |
0 |
Waste |
0 |
0 |
0 |
Total |
0 |
0 |
0 |
10.0.1. The
EM&A programme was carried out in accordance with the EM&A Manual
requirements, minor alterations to the programme proposed were made in response
to changing circumstances.
10.0.2. The
scheduled construction activities and the recommended mitigation measures for
the coming month are listed in Table 10.1. The construction
programmes of individual contracts are provided in Appendix 10.1.
Table
10.1 Summary of Key Construction Activities of Individual Contract(s) to be commenced
in Coming Reporting Month
Contract No. |
Key Construction
Works |
Recommended Mitigation Measures |
HK/2012/08 |
·
Utilities |
·
Dust
control during dust generating works; ·
Implementation
of proper noise pollution control; and ·
Provision
of protection to ensure no runoff out of site area or direct discharge into
public drainage system. |