15                          Environmental Monitoring and Audit

15.1                   Introduction

15.1.1             The findings and recommendations of the EIA report will constitute a formal commitment by the Project Proponent to achieve the levels of environmental protection.  It also states the Project Proponent’s environmental performance criteria.  In order to ensure the performance commitments are incorporated throughout various implementation phases (e.g. detailed design, tendering, construction and operation of the project), a number of contractual, managerial and administrative mechanisms will be implemented, including:

·        Setting up of a project organization and hierarchy,

·        Development of Environmental Monitoring and Audit (EM&A) programme,

·        Outline of Environmental Mitigation Implementation Schedule,

·        Formulation of Environmental Management Plan which includes Waste Management Plan, and

·        Approval of Contractor’s Work Method Statement.

15.2                   Project Organization

15.2.1             A project organisation consisting of the Independent Environmental Checker (IEC), Contractor’s Environmental Team (ET), Engineer’s Representative (ER), and Contractor shall be formed to take the responsibilities of the environmental protection for this project’s EM&A Manual & Implementation Schedule.

15.2.2             The IEC will be appointed by the Project Proponent to conduct independent auditing on the overall EM&A programme including the implementation of all environmental mitigation, submissions relating to EM&A, and any other submission required under the Environmental Permit (EP).  The organisation, responsibilities of respective parties and lines of communication with respect to environmental protection works are given in the EM&A Manual.

 

15.3                   EM&A Manual & Implementation Schedule

15.3.1             The EM&A is an important aspect in the EIA process that specifies the time frame and responsibilities for the implementation of the environmental mitigation measures identified.  Requirements on environmental monitoring (including baseline and impact monitoring) will be given.

15.3.2             A project specific EM&A Manual has been prepared based on the latest design information available and EPD’s generic EM&A Manual.  The project specific EM&A Manual specifies the following:

·        Organisation, hierarchy and responsibilities of the Contractor, the Engineer or ER, ET, and IEC with respect to the EM&A requirements during construction;

·        Information on project organisation and programming of construction activities for the project;

·        Requirements with respect to the construction schedule and the necessary EM&A programme to track the varying environmental impact;

·        Full details of the methodologies to be adopted, including all field, laboratory and analytical procedures, and details on quality assurance;

·        Procedure for undertaking on-site environmental audits;

·        Definition of Action and Limit levels;

·        Establishment of event and action plans;

·        Requirements of reviewing pollution sources and working procedures required in the event of non-compliance of the environmental criteria and complaints;

·        Requirements for review of EIA predictions, implementation of mitigation measures, and the effectiveness of the environmental protect and pollution control measures adopted; and

·        Presentation requirements for EM&A data and appropriate reporting procedures.

 

 

 

15.4                   EM&A Programme

15.4.1             The aim of implementing the EM&A programme is to ensure compliance with the EIA study recommendations, to assess the effectiveness of the recommended mitigation measures and to identify any further need for additional mitigation measures or remedial action. 

15.4.2             Detailed requirements of the EM&A programme are described in the EM&A Manual. Measurements and activities that shall be conducted in accordance with the requirements in the EM&A Manual are summarised in the follow:

·        Baseline monitoring,

·        Impact monitoring,

·        Remedial actions in accordance with the Event and Action Plan within the time frame in cases where specified criteria in the EM&A Manual are exceeded,

·        Logging and keeping records of the details of monitoring results, and

·        Preparing and submitting monthly EM&A Reports.

15.5                   Environmental Management Plan

15.5.1             A systematic EMP shall be set up by the Contractor to ensure effective implementation of the mitigation measures, monitoring and remedial requirements presented in the EIA, EM&A and EMIS.  The ER and the IEC will audit the implementation status against the EMP and advise the necessary remedial actions required.  These remedial actions shall be enforced by the ER through contractual means.

15.5.2             The EMP will require the Contractor (together with its sub-contractors) to define in detail how to implement the recommended mitigation measures in order to achieve the environmental performance defined in Hong Kong’s environmental legislation and the EIA documentation.

15.5.3             The review of on-site environmental performance shall be undertaken by the ER and the IEC through a systematic checklist and audit once the construction commences.  The environmental performance review programme comprises a regular assessment on the effectiveness of the EMP.  Reference should be made to ETWBTC 19/2005 “Environmental Management on Construction Sites” or its latest versions, and any other relevant Technical Circulars.

15.6                   Construction Method Statement

15.6.1             In case the Contractor would like to adopt alternative construction methods or implementation schedules, it is required to submit details of methodology and equipment to the ER for approval before the work commences.  Any changes in construction method shall be reflected in a revised EMP or the Contractor will be required to demonstrate the manner in which the existing EMP should accommodate the proposed changes.  The Contractor may need to apply for a Further Environmental Permit (FEP) from EPD before commencement of any construction activities.