11.1.1 The following reporting requirements are based upon a paper-documented approach. However, the same information 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. This Manual also require the electronic reporting of EM&A information as outlined in Section 11.5.
11.2 Baseline Monitoring Report
11.2.1 The ET leader shall 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 shall be submitted to each of the four parties: the Contractor, the IEC, the ER and the EPD. The ET Leader shall liaise with the relevant parties on the exact number of copies they want. The format and content of the report and the representation of baseline monitoring data shall be in a format to the satisfaction of EPD.
11.2.2 The baseline monitoring report should include, but not be limited to the following:
(a) up to half a page executive summary;
(b) brief project background information;
(c) drawings showing locations of the baseline monitoring stations;
(d) an updated construction programme with milestones of environmental protection/mitigation activities annotated;
(e) monitoring results (in both hard and diskette copies) together with the
following information:
- monitoring methodology;
- name of laboratory and types of equipment used and calibration details;
- parameters monitored;
- monitoring locations (and depth);
- monitoring date, time, frequency and duration;
- QA/QC results and detection limits.
(e) 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;
(f) 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 statistical difference between control and impact stations for the parameters monitored;
(g) revisions for inclusion in the EM&A Manual; and
(h) comments and conclusions.
11.3.1 The results and findings of all EM&A work required in this Manual should be recorded in the monthly EM&A reports prepared by the ET Leader. The EM&A report shall be prepared by ER and endorsed by IEC and submitted within 10 working days of the end of each reporting month, with the first report due in the month after construction commences. A maximum of 4 copies of each monthly EM&A report should be submitted to each of the four parties: the Contractor, the IEC, the ER and the 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.
11.3.2 The ET leader should review the number and location of monitoring stations and parameters to monitor every 6 months or on an as needed basis in order to cater for the changes in surrounding environment and nature of works in progress.
First Monthly EM&A Report
11.3.3 The first monthly EM&A report should include at least but not be limited to the following:
(a) Executive summary in 1-2 pages
- breaches of AL Levels;
- complaint log;
- notifications of any summons and successful prosecutions;
- reporting changes; and
- future key issues.
(b) Basic project information
- project organisation including key personnel contact names and telephone
numbers;
- construction programme with fine tuning of construction activities showing the
inter-relationship with environmental protection/mitigation measures for the
month;
- management structure; and
- works undertaken during the month.
(c) Environmental status
- works undertaken during the month with illustrations (such as location of
works, daily dredging/filling rates, percentage fines in the fill materials
used); and
- drawing showing the project area, any environmental sensitive receivers and
the locations of the monitoring and control stations.
(d) Summary of EM&A requirements
- all monitoring parameters;
- environmental quality performance limits (Action and Limit levels);
- Event / Action Plans;
- environmental mitigation measures, as recommended in the Final EIA; and
- environmental requirements in contract documents.
(e) Implementation status
Advice on the implementation status of environmental protection and pollution
control/mitigation measures including measures for ecological and visual
impacts, as recommended in the Final EIA, summarised in the updated
implementation schedule.
(f) Monitoring results
To provide monitoring results (in both hard and diskette copies) together with
the following information:
- monitoring methodology;
- name of laboratory and types of equipment used and calibration details;
- parameters monitored;
- monitoring locations (and depth);
- monitoring date, time, frequency, and duration;
- weather conditions during the period;
- graphical plots of the monitored parameters in the month annotated against;
- the major activities being carried out on site during the period;
- weather conditions that may affect the results;
- any other factors which might affect the monitoring results; and
- QA/QC results and detection limits.
(g) Report on non-compliance, complaints, notifications of summons and
successful prosecutions
- record of all non-compliance (exceedances) of the environmental quality
performance limits (Action and Limit Levels);
- 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;
- record of all notifications of summons and successful prosecutions for
breaches of the current environmental protection/pollution control legislations,
including locations and nature of the breaches, investigation, follow-up actions
taken, results and summary;
- review of the reasons for and the implications of non-compliance, complaints,
summons and prosecutions including review of pollution sources and working
procedures; and
- description of the actions taken in the event of non-compliance and deficiency
reporting and any follow-up procedures related to earlier non-compliance.
(h) Others
- an account of the future key issues as reviewed from the works programme and
work method statements;
- advice on the solid and liquid waste management status; and
- submission of implementation status proforma, proactive environmental
protection proforma, regulatory compliance proforma, site inspection proforma,
data recovery schedule and complaint log summarizing the EM&A of the period.
Subsequent Monthly EM&A Reports
11.3.4 The subsequent monthly EM&A reports should include the following:
(a) Executive summary (1-2 pages)
- breaches of AL levels;
- complaint log;
- notifications of any summons and successful prosecutions;
- reporting changes; and
- future key issues.
(b) Environmental status
- construction programme with fine tuning of construction activities showing the
inter-relationship with environmental protection/mitigation measures for the
month;
- works undertaken during the month with illustrations including key personnel
contact names and telephone numbers; and
- drawing showing the project area, any environmental sensitive receivers and
the locations of the monitoring and control stations.
(c) Implementation status
Advice on the implementation status of environmental protection and pollution
control/mitigation measures including measures for ecological and visual
impacts, as recommended in the Final EIA, summarised in the updated
implementation schedule.
(d) Monitoring results
To provide monitoring results (in both hard and diskette copies) together with
the following information:
- monitoring methodology;
- name of laboratory and types of equipment used and calibration details
- parameters monitored;
- monitoring locations (and depth);
- monitoring date, time, frequency, and duration;
- weather conditions during the period;
- graphical plots of the monitored parameters in the month annotated against;
- the major activities being carried out on site during the period;
- weather conditions that may affect the results;
- any other factors which might affect the monitoring results; and
- QA/QC results and detection limits.
(e) Report on non-compliance, complaints, notifications of summons and
successful prosecutions
- record of all non-compliance (exceedances) of the environmental quality
performance limits (Action and Limit Levels);
- 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;
- record of all notifications of summons and successful prosecutions for
breaches of the current environmental protection/pollution control legislations,
including locations and nature of breaches, investigation, follow-up actions
taken, results and summary;
- review of the reasons for and the implications of non-compliance, complaints,
summons and prosecutions including review of pollution sources and working
procedures; and
- a description of the actions taken in the event of non-compliance and
deficiency reporting and any follow-up procedures related to earlier
non-compliance.
(f) Others
- an account of the future key issues as reviewed from the works programme and
work method statements; and
- advice on the solid and liquid waste management status.
(g) Appendix
- AL levels
- graphical plots of trends of monitored parameters at key stations over the
past four reporting periods for representative monitoring stations annotated
against the following:
i) major activities being carried out on site during the period;
ii) weather conditions during the period; and
iii) any other factors which might affect the monitoring results
- monitoring schedule for the present and next reporting period
- cumulative statistics on complaints, notifications of summons and successful
prosecutions
- outstanding issues and deficiencies
Quarterly EM&A Summary Reports
11.3.5 The quarterly EM&A summary report which should generally be around 5 pages (including about 3 of text and tables and 2 of figures) should contain at least the following listed information. Apart from these, the first quarterly summary report should also confirm that the monitoring work is proving effective and that it is generating data with the necessary statistical power to categorically identify or confirm the absence of impact attributable to the works:
(a) up to half a page executive summary;
(b) basic project information including a synopsis of the project organisation, programme, contacts of key management, and a synopsis of work undertaken during the quarter;
(c) a brief summary of EM&A requirements including:
- monitoring parameters;
- environmental quality performance limits (Action and Limit levels); and
- environmental mitigation measures, as recommended in the Final EIA;
(d) advice on the implementation status of environmental protection and pollution control/mitigation measures, as recommended in the Final EIA, summarised in the updated implementation schedule;
(e) drawings showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations;
(f) graphical plots of the trends of monitored parameters over the past 4
months (the last month of the previous quarter and the present quarter) for
representative monitoring stations annotated against;
- the 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;
(g) advice on the solid and liquid waste management status;
(h) a summary of non-compliance (exceedances) of the environmental quality performance limits (Action and Limit levels);
(i) a brief review of the reasons for and the implications of non-compliance including review of pollution sources and working procedures;
(j) for project where measurement of suspended solids is required, an quarterly assessment of construction impacts on suspended solids at the project site, including, but not limited to, a comparison of the difference between the quarterly mean and 1.3 times of the ambient mean, which is defined as 30% increase of the baseline data or EPD data, of the related parameters by using appropriate statistical procedures. Suggestion of appropriate mitigation measures if the quarterly assessment analytical results demonstrate that the quarterly mean is significantly higher than the 1.3 on water quality times of the ambient mean (p<0.05);
(k) a summary description of the actions taken in the event of non-compliance and any follow-up procedures related to earlier non-compliance;
(l) a summary record of all complaints received (written or verbal) for each media, liaison and consultation undertaken, actions and follow-up procedures taken;
(m) a summary record of notifications of summons and successful prosecutions for breaches of the current environmental protection/pollution control legislations, locations and nature of the breaches, investigation, follow-up actions taken and results;
(n) comments (e.g. effectiveness and efficiency of the mitigation measures), recommendations (e.g. any improvement in the EM&A programme) and conclusions for the quarter; and
(o) proponents' contacts and any hotline telephone number for the public to make enquiries.
Final EM&A Summary Report
11.3.6 The termination of EM&A programme should be determined on the following basis:
(a) completion of construction activities and insignificant environmental
impacts of the remaining outstanding construction works;
(b) trends analysis to demonstrate the narrow down of monitoring exceedances due
to construction activities and the return of ambient environmental conditions in
comparison with baseline data; and
(c) no environmental complaint and prosecution involved.
11.3.7 The proposed termination may be required to consult related local community such as village representative/committee and/or District Board and the proposal should be endorsed by the IEC, ER and the project proponent prior to final approval from the Director of Environmental Protection.
11.3.8 The Final EM&A summary report should include, inter alia, the following:
(a) an executive summary;
(b) basic project information including a synopsis of the project organisation, programme, contacts of key management, and a synopsis of work undertaken during the entire construction period;
(c) a brief summary of EM&A requirements including:
- monitoring parameters;
- environmental quality performance limits (Action and Limit levels); and
- environmental mitigation measures, as recommended in the Final EIA;
(d) advice on the implementation status of environmental protection and pollution control/mitigation measures, as recommended in the Final EIA, summarised in the updated implementation status proformas;
(e) drawings showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations;
(f) graphical plots of the trends of monitored parameters over the
construction period for representative monitoring stations annotated against;
- the 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;
- the return of ambient environmental conditions in comparison with baseline
data;
(g) compare and contrast the EM&A data with the Final EIA predictions and annotate with explanation for any discrepancies;
(h) provide clear-cut decisions on the environmental acceptability of the project with reference to the specific impact hypothesis;
(i) advice on the solid and liquid waste management status;
(j) a summary of non-compliance (exceedances) of the environmental quality performance limits (Action and Limit levels);
(k) a brief review of the reasons for and the implications of non-compliance
including review of pollution sources and working procedures;
(l) a summary description of the actions taken in the event of non-compliance
and any follow-up procedures related to earlier non-compliance;
(m) a summary record of all complaints received (written or verbal) for each media, liaison and consultation undertaken, actions and follow-up procedures taken;
(n) review the monitoring methodology adopted and with the benefit of hindsight, comment on its effectiveness (including cost effectiveness);
(o) a summary record of notifications of summons and successful prosecutions for breaches of the current environmental protection/pollution control legislations, locations and nature of breaches, investigation, follow-up actions taken and results;
(p) review the practicality and effectiveness of the Final EIA process and EM&A programme (e.g. effectiveness and efficiency of the mitigation measures), recommend any improvement in the EM&A programme; and
(q) a conclusion to state the return of ambient and/or the predicted scenario as per Final EIA findings.
11.4.1 All documentation is required to be filed in a traceable and systematically manner. Site document, such as, monitoring field records, laboratory analysis records, meeting minutes, correspondences etc., should be cross-referenced by the ET leader and be ready for inspection upon request. All EM&A results and findings should be documented in the EM&A reports prepared by the ET and endorsed by the IEC prior to disseminate to the Contractor, ER and the DEP. The content and frequency of the EM&A reporting shall be determined in the EIA stage.
11.4.2 All documentation to the DEP should be in paper form and/or electronic form (in the format in agreement with the DEP) upon request. Prior to submission, the water quality data software format shall be agreed with EPD. All documents and data should be kept for at least one year after the completion of the construction contract. All submissions namely reports, data, and correspondences, etc., to the DEP should be liable to use freely for the purposes of communicating environmental data and the owner of information shall claim no copyright. Any request to treat all or part of a submission in confidence would be respected, but if no such request is made it would be assumed that the submission is not intended to be confidential.
11.5 Interim Notifications of Environmental Quality Limit Exceedances
11.5.1 With reference to Event/Action Plans in this Manual, when the environmental quality limits are exceeded, the ET leader should immediately notify the ER and EPD, as appropriate. The notification should be followed up with advice to EPD on the results of the investigation, proposed action and success of the action taken, with any necessary follow-up proposals. A sample template for the interim notifications is shown in Appendix B.
11.6 Electronic Reporting of EM&A Information
11.6.1 The use of an electronic communication and data recording system for the EM&A programme would facilitate the rapid and effective communication of the site environmental status, as well as serving as a management tool for the Contractors. This can achieve real-time monitoring and notify the Engineer any exceedance of the pre-set environmental quality so as to trigger immediate remedial actions, thus increasing the efficiency in resolving the environmental problems. The system will also track the actions undertaken by relevant parties. The system could also function as a database for the entry of all recorded monitoring and audit information.
11.6.2 In addition, the system could:
· automatically issues Notifications of Exceedances and track their completion;
· instigate Event and Action Plans and track their completion;
· store details of complaints;
· store details of licenses, permits and notify forthcoming expiry dates;
· store construction/operation activity details and other relevant site
information and link these to the EM&A Implementation Schedule; and
· allow retrieval of electronic versions of the EM&A Manual and other
documents.
11.6.3 To facilitate the public inspection of the Baseline Monthly Report and monthly EM&A Reports, via the EIAO Internet Website and at the EIAO Register Office, electronic copies of this Reports shall be prepared in Hyper Text Markup Language (HTML) (version 4.0 or later) and in Portable Document Format (PDF version 4.0 or later), unless otherwise agreed by EPD and shall be submitted at the same time as the hard copies. For the HTML version, a content page capable of providing hyperlink to each section and sub-section of the EM&A Reports shall be included in the beginning of the document. Hyperlinks to all figures, drawings and tables in the EM&A Reports shall be provided in the main text from where the respective references are made. All graphics in the report shall be in interlaced GIF format unless otherwise agreed by the EPD. The content of the electronic copies of the EM&A Reports must be the same as the hard copies.
11.6.4 All environmental monitoring data as described in the EM&A Manual shall be made available to the public via internet access in the form of a website, in the shortest possible time and in no later than 2 weeks after the relevant environmental monitoring data are collected or become available, unless otherwise agreed with EPD. EPD shall be notified in writing within 6 weeks after the commencement of works the Internet address where the environmental monitoring data are to be placed. The Internet address and the environmental monitoring data shall be made available to the public via the EIAO Internet Website and the EIAO Register Office.
11.6.5 The internet website as described above shall enable user friendly public access to the monitoring data and with features capable of:
· providing access to all environmental monitoring data collected since the
commencement of works;
· searching by data;
· searching by types of monitoring data (air quality and noise); and
· hyperlinks to relevant monitoring data after searching,
or otherwise as agreed by the EPD.