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Job No.: TCS00694/13 |
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Agreement No. CE 45/2008
(CE) Liantang/Heung Yuen Wai Boundary Control Point
and Associated Works |
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Monthly Environmental Monitoring and Audit Report
(No.51) ¡V October 2017 |
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Prepared For |
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Civil Engineering and Development Department (CEDD) |
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Date |
Reference No. |
Prepared By |
Certified By |
13 November 2017 |
TCS00694/13/600/R1307v2 |
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Nicola Hon (Environmental Consultant) |
Tam Tak Wing (Environmental Team Leader) |
Version |
Date |
Remarks |
1 |
9 November 2017 |
First
Submission |
2 |
13 November 2017 |
Amended according to the IEC¡¦s comments on 10
November 2017 |
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executive summary
ES01
This is the 51st monthly EM&A
report presenting the monitoring results and inspection findings for the
reporting period from 1 to 31 October 2017 (hereinafter ¡¥the
Reporting Period¡¦).
Environmental
Monitoring and Audit Activities
ES02
To facilitate the project management and
implementation, Liantang/Heung Yuen Wai Boundary Control Point and Associated Works of the
Project is divided to seven CEDD contracts including Contract 2 (CV/2012/08), Contract
3 (CV/2012/09), Contract 4 (NE/2014/02),
Contract 5 (CV/2013/03), Contract 6 (CV/2013/08) and Contract 7 (NE/2014/03)
and an ArshSD contract (Contract SS C505).
ES03
In the Reporting Period, the major
construction works under Liantang/Heung Yuen Wai Boundary
Control Point and Associated Works of the Project included Contract 2,
Contract 3, Contract 4, Contract
6, Contract 7 and Contract SS C505.
Environmental monitoring activities under the EM&A programme in the
Reporting Period are summarized in the following table.
Environmental Aspect |
Environmental Monitoring Parameters /
Inspection |
Reporting Period |
|
Number of Monitoring Locations to undertake |
Total Occasions |
||
Air Quality |
1-hour
TSP |
9 |
135 |
24-hour
TSP |
9 |
45 |
|
Construction Noise |
Leq(30min) Daytime |
10 |
45 |
Water Quality |
Water in-situ measurement and/or sampling |
WM1
& WM1-C |
13 Scheduled & 1 extra |
WM2A(a)
& WM2A-Cx |
13 Scheduled & 3 extra |
||
WM2B
& WM2B-C |
(*) 13 Scheduled |
||
WM3x
&WM3-C |
13 Scheduled & 0 extra |
||
WM4,
WM4-CA &WM4-CB |
13 Scheduled & 2 extra |
||
Ecology |
Woodland
compensation i)
General Health condition of planted species ii) Survival
of planted species |
9
Quadrats |
0 |
Joint Site Inspection / Audit |
IEC, ET,
the Contractor and RE joint site Environmental Inspection and Auditing |
Contract
2 |
4 |
Contract
3 |
4 |
||
Contract
4 |
4 |
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Contract
6 |
4 |
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Contract
7 |
4 |
||
Contract
SS C505 (#) |
4 |
Note:
Extra monitoring day was due to measurement results exceedance
(#) IEC only joined one (1) event of site inspection for Contract SS
C505.
(*)
Water sampling was unable to
carry out at WM2B and WM2B-C due to shallow water (water depth under 150mm)
Action and Limit (A/L) Levels exceedance
ES04
In the Reporting Period, no air quality and construction noise exceedance and valid noise
complaint were recorded.
For
water quality monitoring, a total of eleven (11) Action level/ Limit Level exceedances were recorded under the Project.
The summary of exceedance in the Reporting Period is shown below.
Environmental Aspect |
Monitoring
Parameters |
Action Level |
Limit Level |
Event
& Action |
|||
NOE
Issued |
Investigation
Result |
Project
related exceedance |
Corrective
Actions |
||||
Air Quality |
1-hour TSP |
0 |
0 |
0 |
-- |
-- |
-- |
24-hour TSP |
0 |
0 |
0 |
-- |
-- |
-- |
|
Construction Noise |
Leq(30min) Daytime |
0 |
0 |
0 |
-- |
-- |
-- |
Water Quality |
DO |
0 |
0 |
0 |
- |
-- |
-- |
Turbidity |
1 |
4 |
5 |
- All exceedances were non-project related. |
0 |
The Contractors were reminded to implement
water quality mitigation measure. |
|
SS |
0 |
6 |
6 |
0 |
Environmental
Complaint
ES05
In
this Reporting Period, one (1) documented environmental complaint was received under
the EM&A Programme. Subsequent
joint site inspection was carried out for investigation of the
complaint and the investigation report revealed that the complaint was not
valid to the project.
Notification of
Summons and Successful Prosecutions
ES06
No
environmental summons or successful prosecutions were recorded in the Reporting
Period.
Reporting Change
ES07
No reporting changes
were made in the Reporting Period.
ES08
In this Reporting Period, joint site inspection to evaluate the site
environmental performance at Contract 2 has been carried out by
the RE, IEC, ET and the Contractor on 6, 13, 20 and 27 October
2017.
No non-compliance was noted during the site inspection.
ES09
In the Reporting Period, joint site
inspection to evaluate the site environmental performance at Contract
3 has been carried out by the RE, IEC, ET and the Contractor on 3, 12, 18 and 26 October
2017. No non-compliance was noted during the site
inspection.
ES10
In the Reporting Period, joint site
inspection to evaluate
the site environmental performance at Contract 4 has been
carried out by the RE, IEC, ET and
the Contractor on 6, 13, 16 and 27 October
2017. No non-compliance was noted.
ES11
In the Reporting Period, joint site
inspection to evaluate the site environmental performance at Contract
6 has been carried out by the RE, IEC, ET and the Contractor on 3, 12, 19 and 26 October 2017. No non-compliance was noted during the site
inspection.
ES12
In the Reporting Period, joint site
inspection for Contract 7 to evaluate the site environmental performance has
been carried out by the RE, IEC, ET and the Contractor on 6, 13, 17 and 27
October 2017. No non-compliance was noted during the site
inspection.
ES13
In the Reporting Period, joint site
inspection to evaluate the site environmental performance at Contract
SS C505 has been carried out by the RE, ET and the Contractor on 4, 11, 18 and 25 October
2017 in which IEC joined the site inspection on 25
October 2017. No non-compliance was noted during the site
inspection.
Future Key Issues
ES14
During dry season, special attention
should be paid on the potential construction dust impact since most of the construction sites are adjacent
to villages. The Contractor should fully implement the construction dust
mitigation measures as appropriately.
ES15
Preventive measures for
muddy water or other water pollutants from site surface flow to local stream such
as Kong Yiu Channel, Ma Wat Channel, Ping
Yuen River, Kwan Tei River or public area should be
properly maintained. The Contractors should paid special attention on water
quality mitigation measures and fully implement according ISEMM of the EM&A
Manual, in particular for working areas near Ma Wat Channel and Ping Yuen
River.
ES16
In addition, all effluent
discharge shall be ensure to fulfill Technical Memorandum of Effluent
Discharged into Drainage and Sewerage Systems, inland and Coastal Waters criteria
or discharge permits stipulation.
ES17
Construction noise would
be a key environmental issue during construction work of the Project. Noise mitigation measures such as using
quiet plants should be implemented in accordance with the EM&A requirement.
Table of Contents
2 Project
Organization and Construction progress
2.1 Construction
Contract Packaging
2.5 Summary of Environmental Submissions
3 Summary
of Impact Monitoring Requirements
3.4 Monitoring
Frequency and Period
3.8 Derivation
of Action/Limit (A/L) Levels
3.9 Data
Management and Data QA/QC Control
4.2 Air
Quality Monitoring Results
5 Construction
Noise Monitoring
5.2 Noise
Monitoring Results (normal daytime)
6.2 Results
of Water Quality Monitoring
8.2 Records
of Waste Quantities
9.2 Findings
/ Deficiencies During the Reporting Month
10 Environmental
Complaint and Non-Compliance
10.1 Environmental
Complaint, Summons and Prosecution
11 Implementation
Status of Mitigation Measures
11.2 Tentative
Construction Activities in the Coming Month
11.3 Key
Issues for the Coming Month
12 Conclusions
and Recommendations
List
of TABLES
Table 2-1 Status
of Environmental Licenses and Permits of the Contracts
Table 3-1 Summary
of EM&A Requirements
Table 3-2 Impact
Monitoring Stations - Air Quality
Table 3-3 Impact
Monitoring Stations - Construction Noise
Table 3-4 Impact
Monitoring Stations - Water Quality
Table 3-5 Air
Quality Monitoring Equipment
Table 3-6 Construction
Noise Monitoring Equipment
Table 3-7 Water
Quality Monitoring Equipment
Table 3-8 Action
and Limit Levels for Air Quality Monitoring
Table 3-9 Action
and Limit Levels for Construction Noise
Table 3-10 Action and Limit
Levels for Water Quality
Table 4-1 Summary
of 24-hour and 1-hour TSP Monitoring Results ¡V AM1a
Table 4-2 Summary
of 24-hour and 1-hour TSP Monitoring Results ¡V AM2
Table 4-3 Summary
of 24-hour and 1-hour TSP Monitoring Results ¡V AM3
Table 4-4 Summary
of 24-hour and 1-hour TSP Monitoring Results ¡V AM4B
Table 4-5 Summary
of 24-hour and 1-hour TSP Monitoring Results ¡V AM5a
Table 4-6 Summary
of 24-hour and 1-hour TSP Monitoring Results ¡V AM6
Table 4-7 Summary
of 24-hour and 1-hour TSP Monitoring Results ¡V AM7a
Table 4-8 Summary
of 24-hour and 1-hour TSP Monitoring Results ¡V AM8
Table 4-9 Summary
of 24-hour and 1-hour TSP Monitoring Results ¡V AM9b
Table 5-1 Summary
of Construction Noise Monitoring Results
Table 5-2 Summary
of Construction Noise Monitoring Results
Table 6-1 Summary
of Water Quality Monitoring Results for Contract 2 and 3
Table 6-2 Summary
of Water Quality Monitoring Results for Contract 6 and SS C505
Table 6-3 Summary
of Water Quality Monitoring Results for Contract 6
Table 6-4 Summary
of Water Quality Monitoring Results for Contract 2 and 6
Table 6-5 Action
and Limit (A/L) Levels Exceedance Recorded
Table 6-6 Summary
of Water Quality Exceedance in the Reporting Period
Table 8-1 Summary
of Quantities of Inert C&D Materials
Table 8-2 Summary
of Quantities of C&D Wastes
Table 9-1 Site
Observations for Contract 2
Table 9-2 Site
Observations for Contract 3
Table 9-3 Site
Observations for Contract 4
Table 9-4 Site
Observations for Contract 5
Table 9-5 Site Observations
for Contract 6
Table 9-6 Site
Observations for Contract SS C505
Table 10-1 Statistical
Summary of Environmental Complaints
Table 10-2 Statistical
Summary of Environmental Summons
Table 10-3 Statistical
Summary of Environmental Prosecution
Table 11-1 Environmental
Mitigation Measures
List of Appendices
Appendix
A Layout Plan of the
Project
Appendix
B Organization Chart
Appendix
C 3-month rolling
construction program
Appendix
D Designated
Monitoring Locations as Recommended in the Approved EM&A Manual
Appendix
E Monitoring
Locations for Impact Monitoring
Appendix
F Calibration
Certificate of Monitoring Equipment and HOKLAS-accreditation Certificate of the
Testing Laboratory
Appendix
G Event and Action
Plan
Appendix
H Impact Monitoring
Schedule
Appendix
I Database of
Monitoring Result
Appendix
J Graphical
Plots for Monitoring Result
Appendix
K Meteorological
Data
Appendix
L Waste Flow Table
Appendix
M Implementation Schedule
for Environmental Mitigation Measures
Appendix
N Investigation
Report for Exceedance
Appendix O Investigation
Report for Complaint
1.1.1
Civil Engineering and Development Department is the Project Proponent and the Permit Holder of Agreement No. CE 45/2008 (CE)
Liantang / Heung Yuen Wai Boundary Control Point and Associated Works,
which is a Designated Project to be implemented under Environmental Permit
number EP-404/2011/D granted on 20 January 2017.
1.1.2
The Project consists of two main components: Construction of a Boundary
Control Point (hereinafter referred as ¡§BCP¡¨); and Construction of a connecting
road alignment. Layout plan of the Project is shown in Appendix A.
1.1.3
The proposed BCP is located at the boundary with Shenzhen near the
existing Chuk Yuen Village, comprising a main
passenger building with passenger and cargo processing facilities and the
associated customs, transport and ancillary facilities. The connecting road alignment consists
of six main sections:
1)
Lin Ma Hang to Frontier Closed Area (FCA) Boundary ¡V this section
comprises at-grade and viaducts and includes the improvement works at Lin Ma
Hang Road;
2)
Ping Yeung to Wo Keng Shan ¡V this section
stretches from the Frontier Closed Area Boundary to the tunnel portal at Cheung
Shan and comprises at-grade and viaducts including an interchange at Ping
Yeung;
3)
North Tunnel ¡V this section comprises the tunnel segment at Cheung Shan
and includes a ventilation building at the portals on either end of the tunnel;
4)
Sha Tau Kok Road ¡V this section stretches from
the tunnel portal at Wo Keng Shan to the tunnel
portal south of Loi Tung and comprises at-grade and
viaducts including an interchange at Sha Tau Kok and
an administration building;
5)
South Tunnel ¡V this section comprises a tunnel segment that stretches from
Loi Tung to Fanling and
includes a ventilation building at the portals on either end of the tunnel as
well as a ventilation building in the middle of the tunnel near Lau Shui Heung;
6)
Fanling ¡V this section comprises the at-grade, viaducts and interchange
connection to the existing Fanling Highway.
1.1.4
Action-United
Environmental Services & Consulting has
been commissioned as an Independent ET to implement the relevant
EM&A program in accordance with the
approved EM&A Manual, as well as the associated duties. As part of the EM&A program,
the baseline monitoring has carried out between 13 June 2013 and 12 July
2013 for all parameters including air quality, noise and water quality
before construction work commencement.
The Baseline Monitoring Report summarized the key findings and the
rationale behind determining a set of Action and Limit Levels (A/L Levels) from
the baseline data. Also, the
Project baseline monitoring report which verified by the IEC has been submitted
to EPD on 16 July 2013 for
endorsement. The major construction
works of the Project was commenced on 16
August 2013 in accordance with the EP Section 5.3 stipulation.
1.1.5
This is 51st monthly EM&A
report presenting the monitoring results and inspection findings for reporting period from 1 to 31 October 2017.
1.2.1
The Monthly Environmental Monitoring and
Audit (EM&A) Report is structured into the following sections:-
Section 1 Introduction
Section 2 Project Organization and Construction
Progress
Section 3 Summary
of Impact Monitoring Requirements
Section 4 Air Quality Monitoring
Section 5 Construction Noise Monitoring
Section 6 Water Quality Monitoring
Section 7 Ecology Monitoring
Section 8 Waste Management
Section 9 Site Inspections
Section 10 Environmental
Complaints and Non-Compliance
Section 11 Implementation
Status of Mitigation Measures
Section 12 Conclusions
and Recommendations
2.1.1
To facilitate the project management and
implementation, the Project would be divided by the following contracts:
¡P
Contract 2 (CV/2012/08)
¡P
Contract 3 (CV/2012/09)
¡P
Contract 4 (NE/2014/02)
¡P
Contract 5 (CV/2013/03)
¡P
Contract 6 (CV/2013/08)
¡P
Contract 7 (NE/2014/03)
¡P
ArchSD Contract No. SS C505
2.1.2
The
details of each contracts is summarized below and the delineation of each contracts is shown in Appendix A.
Contract 2 (CV/2012/08)
2.1.3
Contract 2 has awarded in December 2013 and
construction work was commenced on 19 May 2014. Major Scope of Work of the Contract 2 is
listed below:
¡P
construction of
an approximately 5.2km long dual two-lane connecting road (with about 0.4km of
at-grade road and 4.8km of tunnel) connecting the Fanling Interchange with the
proposed Sha Tau Kok Interchange;
¡P
construction of a
ventilation adit tunnel and the mid-ventilation
building;
¡P
construction of
the north and south portal buildings of the Lung Shan Tunnel and their
associated slope works;
¡P
provision and
installation of ventilation system, E&M works and building services works
for Lung Shan tunnel and Cheung Shan tunnel and their portal buildings;
¡P
construction of
Tunnel Administration Building adjacent to Wo Keng
Shan Road and the associated E&M and building services works; and
¡P
construction of associated
footpath, slopes, retaining structures, drainage, sewerage, waterworks,
landscaping works and other ancillary works.
Contract 3 (CV/2012/09)
2.1.4
Contract 3 was awarded in July 2013 and construction
work was commenced on 5 November 2013.
Major Scope of Work of the Contract 3 is listed below:
¡P
construction of
four link roads connecting the existing Fanling Highway and the south portal of
the Lung Shan Tunnel;
¡P
realignment of
the existing Tai Wo Service Road West and Tai Wo Service Road East;
¡P
widening of the
existing Fanling Highway (HyD¡¦s
entrustment works);
¡P
demolishing
existing Kiu Tau vehicular bridge and Kiu Tau footbridge and reconstruction of
the existing Kiu Tau Footbridge (HyD¡¦s entrustment
works); and
¡P
construction of associated
footpath, slopes, retaining structures, drainage, sewerage, waterworks,
landscaping works and other ancillary works.
Contract 4 (NE/2014/02)
2.1.5
Contract
4 has awarded in mid-April 2016 and
construction work was commenced
on 2 May 2017. The scope of work of the Contract 4
includes:
¡P
design, supply,
delivery, installation, testing and commissioning of a traffic control and
surveillance system for the connecting road linking up the Liantang / Heung
Yuen Wai Boundary Control Point and the existing Fanling Highway.
Contract 5 (CV/2013/03)
2.1.6
Contract 5 has awarded in April 2013 and
construction work was commenced in August 2013. Major Scope of Work of the Contract 5 is
listed below:
¡P
site formation of about 23
hectares of land for the development of the BCP;
¡P
construction of an
approximately 1.6 km long perimeter road at the BCP including a 175m long
depressed road;
¡P
associated
diversion/modification works at existing local roads and junctions including
Lin Ma Hang Road;
¡P
construction of pedestrian
subway linking the BCP to Lin Ma Hang Road;
¡P
provision of resite area with supporting infrastructure for reprovisioning of the affected village houses; and
¡P
construction of associated footpath, slopes, retaining structures, drainage,
sewerage, waterworks, landscaping works and other ancillary works.
Contract 6 (CV/2013/08)
2.1.7
Contract 6 has awarded in June 2015 and
construction work was commenced on 23 October 2015. Major Scope of Work of the Contract 6 would
be included below:
construction of an approximately 4.6km long dual two-lane connecting
road (with about 0.6km of at-grade road, 3.3km of viaduct and 0.7km of tunnel)
connecting the BCP with the proposed Sha Tau Kok Road
Interchange and the associated ventilation buildings;
associated diversion/modification works at access roads to the resite of Chuk Yuen Village;
provision of sewage collection, treatment and disposal facilities for
the BCP and the resite of Chuk
Yuen Village;
construction of a pedestrian subway linking the BCP to Lin Ma Hang
Road;
provisioning of the affected facilities including Wo Keng Shan Road garden; and
construction of associated footpath, slopes, retaining
structures, drainage, sewerage, waterworks, landscaping works and other
ancillary works.
Contract 7 (NE/2014/03)
2.1.8
Contract 7 has awarded in December 2015 and
the construction works of Contract 7 was commenced on 15 February 2016. Major Scope of Work of the Contract 7 would
be included below:
construction of the Hong Kong Special
Administrative Region (HKSAR) portion of four vehicular bridge
construction of one pedestrian bridge crossing Shenzhen (SZ) River
(cross boundary bridges)
ArchSD Contract No. SS
C505
2.1.9
SS C505 has awarded in July 2015 and
construction work was commenced on 1 September 2015. Major Scope of Work of the SS C505 would
be included below:
passenger-related facilities including processing
kiosks and examination facilities for private cars and coaches, passenger
clearance building and halls, the interior fitting works for the pedestrian
bridge crossing Shenzhen River, etc.;
cargo processing facilities including kiosks
for clearance of goods vehicles, customs inspection platforms, X-ray building,
etc.;
accommodation for the facilities inside of the
Government departments providing services in connection with the BCP;
transport-related facilities inside the BCP
including road networks, public transport interchange, transport drop-off and
pick-up areas, vehicle holding areas and associated road furniture etc;
a public carpark; and
other ancillary
facilities such as sewerage and drainage, building services provisions and
electronic systems, associated environmental mitigation measure and landscape
works.
2.2.1
The project organization is shown in Appendix B. The
responsibilities of respective parties are:
Civil
Engineering and Development Department (CEDD)
2.2.2
CEDD is the Project Proponent and the Permit Holder of the EP of the development
of the Project and will assume overall responsibility for the project. An
Independent Environmental Checker (IEC) shall be employed by CEDD to audit the
results of the EM&A works carried out by the ET.
Architectural
Services Department (ArchSD)
2.2.3
ArchSD acts as
the works agent for Development Bureau (DEVB), for Contract SS C505 Liantang/ Heung Yuen Wai Boundary Control Point (BCP) ¡V BCP
Buildings and Associated Facilities.
Environmental
Protection Department (EPD)
2.2.4
EPD is the statutory enforcement body for
environmental protection matters in Hong Kong.
Ronald Lu
& Partners (Hong Kong) Ltd (The Architect)
2.2.5
Ronald Lu & Partners (Hong Kong) Ltd is
appointed by ArchSD as an Architect for Contract SS
C505 Liantang/ Heung Yuen Wai Boundary Control Point
(BCP) ¡V BCP Buildings and Associated Facilities. It responsible for overseeing the
construction works of Contract SS C505 and for ensuring that the works are
undertaken by the Contractor in accordance with the specification and contract
requirements. The duties and responsibilities of the Architect with respect to
EM&A are:
Monitor the Contractors¡¦ compliance with
contract specifications, including the implementation and operation of the
environmental mitigation measures and their effectiveness
Monitor Contractors¡¦ and ET¡¦s compliance with
the requirements in the Environmental Permit (EP) and EM&A Manual
Facilitate ET¡¦s implementation of the EM&A
programme
Participate in joint site inspection by the ET
and IEC
Oversee the implementation of the agreed Event
/ Action Plan in the event of any exceedance
Adhere to the procedures for carrying out
complaint investigation
Liaison with DSD, Engineer/Engineer¡¦s
Representative, ET, IEC and the Contractor of the ¡§Construction of the DSD¡¦s
Regulation of Shenzhen River Stage 4 (RSR 4)¡¨ Project discussing regarding the
cumulative impact issues.
Engineer
or Engineers Representative (ER)
2.2.6
The ER is responsible for overseeing the
construction works and for ensuring that the works are undertaken by the
Contractor in accordance with the specification and contract requirements. The
duties and responsibilities of the ER with respect to EM&A are:
¡P
Monitor the Contractors¡¦ compliance with
contract specifications, including the implementation and operation of the
environmental mitigation measures and their effectiveness
¡P
Monitor Contractors¡¦s,
ET¡¦s and IEC¡¦s compliance with the requirements in the Environmental Permit
(EP) and EM&A Manual
¡P
Facilitate ET¡¦s implementation of the
EM&A programme
¡P
Participate in joint site inspection by the
ET and IEC
¡P
Oversee the implementation of the agreed
Event / Action Plan in the event of any exceedance
¡P
Adhere to the procedures for carrying out
complaint investigation
¡P
Liaison with DSD, Engineer/Engineer¡¦s
Representative, ET, IEC and the Contractor of the ¡§Construction of the DSD¡¦s Regulaiton of Shenzhen River Stage 4 (RSR 4)¡¨ Project
discussing regarding the cumulative impact issues.
The
Contractor(s)
2.2.7
There will be one contractor for each
individual works contract. Once the contractors are appointed, EPD, ET and IEC
will be notified the details of the contractor.
2.2.8
The Contractor for Contracts under CEDD
should report to the ER. For ArchSD Contract, the
Contractor should report to the Architect or Architect¡¦s Representative (AR).
The duties and responsibilities of the Contractor are:
¡P
Comply with the relevant contract conditions
and specifications on environmental protection
¡P
Employ an Environmental Team (ET) to
undertake monitoring, laboratory analysis and reporting of EM &A Facilitate
ET¡¦s monitoring and site inspection activities
¡P
Participate in the site inspections by the ET
and IEC, and undertake any corrective actions
¡P
Provide information / advice to the ET
regarding works programme and activities which may contribute to the generation
of adverse environmental impacts
¡P
Submit proposals on mitigation measures in
case of exceedances of Action and Limit levels in accordance with the Event /
Action Plans
¡P
Implement measures to reduce impact where
Action and Limit levels are exceeded
¡P
Adhere to the procedures for carrying out
complaint investigation