Technical
Memorandum
Annex 21: CONTENTS OF AN ENVIRONMENTAL MONITORING AND AUDIT (EM&A) PROGRAMME
This annex describes
the commonly adopted approaches for carrying out an EM&A programme.
The following are the key steps in an EM&A programme:
Environmental
Monitoring
- the systematic
collection of environmental data through a series of repetitive measurements.
A number of different monitoring activities are identified below:
- Baseline
Monitoring refers to the measurement of environmental parameters
during a representative pre-project period for the purpose of determining
the nature and ranges of natural variation and to establish, where
appropriate, the nature of change;
- Impact
Monitoring involves the measurement of environmental parameters
during project construction and implementation so as to detect changes
in these parameters which can be attributed to the project; and
- Compliance
Monitoring unlike the previous monitoring activities, takes
the form of periodic sampling and/or continuous measurement of environmental
parameters, levels of waste discharge or process emissions to ensure
that regulatory requirements are observed and standards met. (Surveillance
and inspection may also form a part of this activity but need not
necessarily involve measurement of a repetitive activity).
- the organization
and interpretation of the environmental monitoring data to establish
a record of change associated with the implementation of a project or
the operation of an organisation;
- the process of
verification that all or selected parameters measured by an environmental
monitoring programme are in compliance with regulatory requirements,
internal policies and standards, and established environmental quality
performance limits;
- the comparison
of project impact predictions with actual impacts for the purpose of
assessing the accuracy of predictions;
- the assessment
of the effectiveness of the environmental management systems, practices
and procedures;
- event and action
plans shall be included and linked to the environmental quality performance.
The determination of the degree and scope of any necessary remedial
measures in case of exceedance of compliance, for which environmental
monitoring forms the basis, or the recommendation of environmental controls
and operations in the event that the organisation's environmental objectives
are not achieved;
- for projects
which are assessed to have potential impacts on nearby fish culture
zones, the part of EM&A programme to address such impacts shall
be approved by Director of Agriculture & Fisheries (DAF). A copy
of the manual as well as the regular and summary reports shall be made
available to DAF; and
- the environmental
monitoring and audit work shall be carried out by qualified personnel.
Environmental
Quality Performance Limits
For the purpose of
environmental monitoring and audit, environmental quality performance
limits are normally in the form of a set of action / limit levels, which
are defined as:
- Action Levels
- the levels beyond which there is an indication of a deteriorating
ambient environmental quality. Appropriate remedial actions may be necessary
to prevent the environmental quality from going beyond the limit levels,
which would be unacceptable.
- Limit Levels
- the levels stipulated in relevant pollution control ordinances, this
technical memorandum, or the Hong Kong Planning Standards and Guidelines,
or other appropriate criteria established by the Director of Environmental
Protection for a particular project, beyond which the works shall not
proceed without appropriate remedial action, including a critical review
of plant and work methods.
In addition to the
action/limit levels, a trigger level below the action level may be set
up to provide early warning of deteriorating environmental quality that
may exceed the action level.
Environmental
Monitoring and Audit Documentation
For the purpose of
EM&A, the following documents are normally required by the Director:
- EM&A Manual
The Manual shall
be a stand-alone document and shall include the following:
- project background
including organisation and programme;
- purpose of
the manual;
- an implementation
schedule, summarizing all recommended environmental mitigation measures
with reference to the programme for their implementation. The measures
shall include those identified at detailed design, contract preparation,
construction, and operation stages of the project;
- drawings
showing all environmentally sensitive receivers;
- an EM&A
programme for the construction of the project including:
- responsibility
for EM&A work;
- EM&A
organization and management structure;
- EM&A
methodology;
- equipment
to be used and calibration required;
- locations,
parameters, frequency and duration for baseline, impact and
compliance monitoring;
- environmental
quality performance limits (Action and Limit levels);
- Event-Action
plans and decision audit flow charts;
- procedures
for reviewing the monitoring results;
- compliance
audit procedures and follow-up;
- implementation
programme and impact prediction review procedures;
- site inspection,
deficiency and action reporting procedures;
- complaint/consultation
procedures; and
- reporting
format and procedures.
- Baseline Monitoring
Report
The report shall
include at least the following:
- drawings
showing locations of the baseline monitoring stations;
- monitoring
results (in both hard and diskette copies) together with the following
information:
- monitoring
methodology;
- equipment
used and calibration details;
- parameters
monitored;
- monitoring
locations (and depth);
- monitoring
date, time, frequency and duration;
- details on
influencing factors, including:
- major
activities, if any, being carried out on the site during the
period;
- weather
conditions during the period;
- other
factors which might affect the results;
- determination
of the action and limit levels for each monitoring parameter and
statistical analysis of the baseline data;
- revisions
for inclusion in the EM&A Manual.
- Regular and
Summary EM&A Reports
The results and
findings of each audit shall be documented in regular EM&A reports
prepared by the Applicant. EM&A reports shall include at least
the following : (* Where applicable, items which have already been
included in the EM&A Manual need not be repeated in each EM&A
report unless there are substantial amendments.)
- 1-2 pages
executive summary;
- * basic project
information including a synopsis of the project organisation, programme
and management structure, and the work undertaken during the month;
- * a brief
summary of EM&A requirements including:
- all monitoring
parameters;
- environmental
quality performance limits;
- Event-Action
Plans;
- environmental
mitigation measures, as recommended in the EIA report;
- environmental
requirements in contract documents.
- advice on
the implementation status of environmental protection, mitigation
and pollution control measures, as recommended in the project EIA
report, summarised in the updated implementation schedule;
- * drawings
showing the project area, any environmental sensitive receivers
and the locations of the monitoring and control stations;
- monitoring
results (in both hard and diskette copies) together with the following
information:
- monitoring
methodology;
- equipment
used and calibration details;
- parameters
monitored;
- monitoring
locations (and depth);
- monitoring
date, time, frequency, and duration;
- graphical
plots of trends of monitored parameters over the past four reporting
periods for representative monitoring stations annotated against
the following:
- major
activities being carried out on site during the period;
- weather
conditions during the period; and
- any other
factors which might affect the monitoring results;
- a summary
of non-compliance (exceedances) of the environmental quality performance
limits;
- a review
of the reasons for and the implications of noncompliance including
review of pollution sources and working procedures;
- a description
of the actions taken in the event of noncompliance and deficiency
reporting and any follow-up procedures related to earlier noncompliance;
- a summary
record of all complaints received (written or verbal) for each media,
including locations and nature of complaints, liaison and consultation
undertaken, actions and follow-up procedures taken and summary of
complaints;
- a summary
record of notification of summons, successful prosecutions for breaches
of environmental protection/pollution control legislation, and actions
taken to rectify such breaches;
- a forecast
of the works programme, impact predictions and monitoring schedule
for the next three months; and
- comments,
recommendations and conclusions for the monitoring period.
|
