13.               Reporting

Introduction

 

13.1            Reports can be provided in an electronic medium upon agreeing the format with the ER and EPD.  This would enable a transition from a paper / historic and reactive approach to an electronic / real time proactive approach.  All the monitoring data (baseline and impact) should also be submitted in an electronic medium.  Sample data sheets for noise and air quality monitoring are shown in Appendix B.

13.2            Types of reports that the ET Leader should prepare and submit include baseline monitoring report, monthly EM&A report and final EM&A review report.  In accordance with Annex 21 of the EIAO-TM, a copy of the monthly and final review EM&A reports should be made available to the Director of Environmental Protection.

 

Baseline Monitoring Report

 

13.3            The ET Leader should prepare and submit a Baseline Environmental Monitoring Report within 10 working days of completion of the baseline monitoring.  Copies of the Baseline Environmental Monitoring Report should be submitted to the Contractor, the IEC, the ER and the EPD.  The ET Leader should liaise with the relevant parties on the exact number of copies they require.  The report format and baseline monitoring data format should be agreed with the EPD prior to submission.

13.4            The baseline monitoring report should include at least the following:

(i)        up to half a page executive summary;

(ii)       brief project background information;

(iii)      drawings showing locations of the baseline monitoring stations;

(iv)       monitoring results (in both hard and diskette copies) together with the following information:

Ÿ          monitoring methodology

Ÿ          name of laboratory and types of equipment used and calibration details

Ÿ          parameters monitored

Ÿ          monitoring locations (and depth)

Ÿ          monitoring date, time, frequency and duration

Ÿ          QA/QC results and detection limits

(v)       details on influencing factors, including:

Ÿ          major activities, if any, being carried out on the Site during the period

Ÿ          weather conditions during the period

Ÿ          other factors which might affect the results

(vi)       determination of the Action and Limit Levels (AL levels) for each monitoring parameter and statistical analysis of the baseline data, the analysis should conclude if there is any significant difference between control and impact stations for the parameters monitored;

(vii)      revisions for inclusion in the EM&A Manual; and

(viii)     comments and conclusions.

 


Monthly EM&A Reports

 

13.5            The results and findings of all EM&A works required in this Manual should be recorded in the monthly EM&A reports prepared by the ET Leader and endorsed by IEC.  The EM&A report should be prepared and submitted within 10 working days of the end of each reporting month, with the first report due in the month after construction commences.  Copies of each monthly EM&A report should be submitted to each of the four parties: the Contractor, ER, IEC and EPD.  Before submission of the first EM&A report, the ET Leader should liaise with the parties on the exact number of copies and format of the monthly reports in both hard copy and electronic medium requirement. 

13.6            The ET Leader should review the number and location of monitoring stations and parameters every six months, or on as needed basis, in order to cater for any changes in the surrounding environment and the nature of works in progress.

 

First Monthly EM&A Report

13.7            The first monthly EM&A Report should include at least but not limited to the following:

(i)        executive summary (1-2 pages):

Ÿ          breaches of Action and Limit levels;

Ÿ          complaint log;

Ÿ          notifications of any summons and successful prosecutions;

Ÿ          reporting changes; and

Ÿ          future key issues.

(ii)       basic project Information:

Ÿ          project organization including key personnel contact names and telephone numbers;

Ÿ          construction programme;

Ÿ          management structure; and

Ÿ          works undertaken during the month.

(iii)      environmental status:

Ÿ          advice on the status of statutory environmental compliance, the status of compliance with environmental permit (EP) conditions under the EIA Ordinance, submission status under the EP and implementation status of mitigation measures;

Ÿ          works undertaken during the month with illustrations (such as location of works, etc); and

Ÿ          drawing showing the Project area, any environmental sensitive receivers and the locations of the monitoring and control stations.

(iv)       Summary of EM&A requirements:

Ÿ          all monitoring parameters;

Ÿ          environmental quality performance limits (Action and Limit levels);

Ÿ          Event and Action Plans;

Ÿ          environmental mitigation measures, as recommended in the EIA report; and

Ÿ          environmental requirements in contract documents.

(v)       Implementation status:

Ÿ          advice on the implementation status of environmental protection and pollution control/mitigation measures as recommended in the EIA report.

(vi)       monitoring results (in both hard and diskette copies) together with the following information:

Ÿ          monitoring methodology;

Ÿ          name of laboratory and types of equipment used and calibration details;

Ÿ          parameters monitored;

Ÿ          monitoring locations (and depth);

Ÿ          monitoring date, time, frequency and duration;

Ÿ          graphical plots of the monitoring parameters in the month annotated against the following;

(a)      major activities being carried out on site during the period;

(b)      weather conditions during the period;  

(c)      any other factors which might affect the monitoring results; and

(d)      QA/QC results and detection limits.

(vii)      report on non-compliance, complaints, notifications of summons and status of prosecutions:

Ÿ          record of all non-compliance (exceedances) of the environmental quality performance limits (Action and Limit levels);

Ÿ          record of all complaints received (written or verbal) for each media, including locations and nature of complaints investigation, liaison and consultation undertaken, actions and follow-up procedures taken, results and summary;

Ÿ          record of all notification of summons and successful prosecutions for breaches of current environmental protection / pollution control legislation, including locations and nature of the breaches, investigation, follow-up actions taken, results and summary;

Ÿ          review of the reasons for and the implications of non-compliance, complaints, summons and prosecutions including review of pollution sources and working procedures; and

Ÿ          description of the actions taken in the event of non-compliance and deficiency reporting and any follow-up procedures related to earlier non-compliance.

(viii)     Others:

Ÿ          an account of the future key issues as reviewed from the works programme and work method statements;

Ÿ          advice on the solid and liquid waste management status;

Ÿ          compare and contrast the EM&A data in the month with the EIA predictions and annotate with explanation for any discrepancies; and

Ÿ          comments (for examples. effectiveness and efficiency of the mitigation measures), recommendations (for example, any improvement in the EM&A programme) and conclusions.

 

Subsequent Monthly EM&A Reports

 

13.8            Subsequent monthly EM&A reports during construction phase should include the following:

(i)        executive summary (1-2 pages):

Ÿ          breaches of Action and Limit levels;

Ÿ          complaint log;

Ÿ          notifications of any summons and successful prosecutions;

Ÿ          reporting changes; and

Ÿ          future key issues.

(ii)       basic project Information:

Ÿ          project organization including key personnel contact names and telephone numbers;

Ÿ          construction programme;

Ÿ          management structure; and

Ÿ          works undertaken during the month.

(iii)      environmental status:

Ÿ          advice on the status of statutory environmental compliance, the status of compliance with environmental permit (EP) conditions under the EIA Ordinance, submission status under the EP and implementation status of mitigation measures;

Ÿ          works undertaken during the month with illustrations (such as location of works, etc); and

Ÿ          drawing showing the Project area, any environmental sensitive receivers and the locations of the monitoring and control stations.

 (vi)      implementation status:

Ÿ          advice on the implementation status of environmental protection and pollution control/mitigation measures as recommended in the EIA report.

(v)       monitoring results (in both hard and diskette copies) together with the following information:

Ÿ          monitoring methodology;

Ÿ          name of laboratory and types of equipment used and calibration details;

Ÿ          parameters monitored;

Ÿ          monitoring locations (and depth);

Ÿ          monitoring date, time, frequency and duration;

Ÿ          graphical plots of the monitoring parameters in the month annotated against the following;

(a)      major activities being carried out on site during the period;

(b)      weather conditions during the period;

(c)      any other factors which might affect the monitoring results; and

(d)      QA/QC results and detection limits.

(vi)       report on non-compliance, complaints, notifications of summons and status of prosecutions:

Ÿ          record of all non-compliance (exceedances) of the environmental quality performance limits (Action and Limit levels);

Ÿ          record of all complaints received (written or verbal) for each media, including locations and nature of complaints investigation, liaison and consultation undertaken, actions and follow-up procedures taken, results and summary;

Ÿ          record of all notification of summons and successful prosecutions for breaches of current environmental protection / pollution control legislation, including locations and nature of the breaches, investigation, follow-up actions taken, results and summary;

Ÿ          review of the reasons for and the implications of non-compliance, complaints, summons and prosecutions including review of pollution sources and working procedures; and

Ÿ          description of the actions taken in the event of non-compliance and deficiency reporting and any follow-up procedures related to earlier non-compliance.

(vii)      others:

Ÿ          an account of the future key issues as reviewed from the works programme and work method statements;

Ÿ          advice on the solid and liquid waste management status;

Ÿ          compare and contrast the EM&A data in the month with the EIA predictions and annotate with explanation for any discrepancies; and

Ÿ          comments (for examples. effectiveness and efficiency of the mitigation measures), recommendations (for example, any improvement in the EM&A programme) and conclusions.

(viii)     appendix:

Ÿ          Action and Limit levels;

Ÿ          graphical plots of trends of monitored parameters at key stations over the past four reporting periods for representative monitoring stations annotated against the following:

(a)      major activities being carried out on site during the period;

(b)      weather conditions during the period; and

(c)      any other factors that might affect the monitoring results.

Ÿ          monitoring schedule for the present and next reporting period;

Ÿ          cumulative statistics on complaints, notifications of summons and successful prosecutions;

Ÿ          outstanding issues and deficiencies.

 

 

Final EM&A Review Report - Construction Phase

 

13.9            The EM&A program should be terminated upon completion of those construction activities that have the potential to result in a significant environmental impact.

13.10        Prior to the proposed termination, it may be advisable to consult relevant local communities.  The proposed termination should only be implemented after the proposal has been endorsed by the IEC, the Engineer and the Project Proponent followed by final approval from the Director of Environmental Protection.

13.11        The ET Leader should prepare and submit a final EM&A report within 14 working days after the completion of those construction activities that have the potential to result in a significant environmental impact.  The final EM&A report should contain at least the following information:

(i)        executive summary (1 - 2 pages);

(ii)       drawings showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations;

(iii)      basic project information including a synopsis of the project organisation, contacts of key management, and a synopsis of work undertaken during the course of the project or past twelve months;

(iv)       a brief summary of EM&A requirements including:

Ÿ          environmental mitigation measures, as recommended in the project EIA Report;

Ÿ          environmental impact hypotheses tested;

Ÿ          environmental quality performance limits (Action and Limit levels);

Ÿ          all monitoring parameters; and

Ÿ          Event-Action Plans;

(v)      a summary of the implementation status of environmental protection and pollution control / mitigation measures, as recommended in the project EIA Report, summarised in the updated implementation schedule;

(vi)       graphical plots and the statistical analysis of the trends of monitored parameters over the course of the project, including the post-project monitoring for all monitoring stations annotated against:

Ÿ          the major activities being carried out on site during the period;

Ÿ          weather conditions during the period; and

Ÿ          any other factors which might affect the monitoring results;

(vii)      a summary of non-compliance (exceedances) of the environmental quality performance limits (Action and Limit levels);

(viii)     a review of the reasons for and the implications of non-compliance including review of pollution sources and working procedures as appropriate;

(ix)      a description of the actions taken in the event of non-compliance;

(x)       a summary record of all complaints received (written or verbal) for each media, liaison and consultation undertaken, actions and follow-up procedures taken;

(xi)      a summary record of notifications of summons and successful prosecutions for breaches of the current environmental protection / pollution control legislation, locations and nature of the breaches, investigation follow-up actions taken and results;

(xii)     a review of the validity of EIA predictions and identification of shortcomings in EIA recommendations; and

(xiii)     comments (for examples, a review of the effectiveness and efficiency of the mitigation measures and of the performance of the environmental management system, that is, of the overall EM&A programme);

(xiv)     recommendations and conclusions (for example, a review of success of the overall EM&A programme to cost-effectively identify deterioration and to initiate prompt effective mitigation action when necessary).

 

Data Keeping

13.12        No site-based documents (such as monitoring field records, laboratory analysis records, site inspection forms, etc.) are required to be included in the EM&A reporting documents.  However, any such document should be properly maintained by the ET Leader / Monitoring Team and be ready for inspection upon request.  All relevant information should be clearly and systematically recorded in the document.  Monitoring data should also be recorded in magnetic media form, and the software copy must be available upon request. All documents and data should be kept for at least one year following completion of construction phase EM&A for each construction contract.

 

Interim Notifications of Environmental Quality Limit Exceedances

13.13        With reference to the Event and Action Plan, when the environmental quality performance limits are exceeded, the ET Leader should immediately notify the IEC and EPD, as appropriate.  The notification should be followed up with advice to IEC and EPD on the results of the investigation, proposed actions and success of the actions taken, with any necessary follow-up proposals.  A sample template for the interim notification is presented in Appendix E.