The primary reporting function, undertaken within the EM&A programme, will be the issuance of formal exceedance notifications, corrective actions and ongoing feedback between the ET Leader, the Contractor and the Engineer. Reporting will be driven by the results of the monitoring and audit programme and will be recorded through written correspondence, site inspections and minutes and notes of meetings.
In addition, periodic reviews of the EM&A process and subsequent revisions to the EM&A Manual, as appropriate, will be prepared and circulated to relevant personnel within the Contractor’s Project Team as a means of gauging site staff and contractor performance. The periodic reviews will comprise Monthly, Biannual and Annual EM&A Reports; these reports will be copied to the EPD for comment. The exact details of the frequency, distribution and time frame for submission shall be agreed with the EPD prior to the commencement of the works.
The following reporting requirements are based upon a paper documented approach. However, the same information could, upon agreement with the Engineer, the IEC, and EPD, be provided using an electronic medium, such as the EPD’s Specialised Electronic Environmental Monitoring and Audit (SEEMA) software (or a similar alternative). All the monitoring data (baseline and impact) shall also be submitted on diskettes in an agreed format.
15.2
Baseline Monitoring Report
The ET Leader shall prepare and submit a draft Baseline Environmental Monitoring Report within 10 working days of the completion of the baseline monitoring. Copies of the Baseline Report shall be submitted to all parties for agreement; the Contractor, IEC, Engineer and the EPD. The exact number of copies required by each party will be established through liaison. The draft report will be supported by the baseline monitoring data in electronic format, along with information covering the monitoring locations and conditions, equipment and protocols. The agreed baseline report will then be reissued as a stand alone report.
The form and content of the report and the representation of baseline monitoring data shall be in a format to the satisfaction of EPD and include, but not 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.
(f) 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;
(g) determination of the Action and Limit Levels (AL levels) for each monitoring parameter and statistical analysis of the baseline data; the analysis shall conclude if there is any significant difference between control and impact stations for the parameters monitored;
(h) revisions for inclusion in the EM&A Manual; and
(i) comments and conclusions.
The results and findings of all EM&A work required in the Manual shall be recorded in the monthly EM&A Reports and be prepared by the ET Leader. The reports shall be submitted to the IEC to be endorsed and copied to the EPD within ten working days of the end of each calendar month, with the first report due in the month after construction works commence. Copies shall also be submitted to the Contractor, IEC and Engineer for information. The ET Leader shall liaise with the relevant parties to confirm the exact number and format of monthly reports in both hard copy and electronic format.
The report shall include, but not be limited to, the following elements:
15.3.1 First Monthly EM&A Report
The first monthly EM&A report shall include at least but not be limited to the following :
(a) Executive Summary (1-2 pages)
· Breaches of AL levels;
· Complaint Log;
· Notifications of any summons and successful prosecutions;
· Reporting Changes;
· 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 material 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 including:
· All monitoring parameters;
· Environmental quality performance limits (Action and Limit levels);
· Event-Action Plans;
· Environmental mitigation measures, as recommended in the project EIA study final report;
· 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 project EIA study report, 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 trends of 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; and
· Any other factors which might affect the monitoring results;
· 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 notifications of summons and successful prosecutions for breaches of the current environmental protection/pollution control legislation’s, 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 summarising the EM&A of the period.
15.3.2 Subsequent Monthly EM&A Reports
The subsequent monthly EM&A reports shall include the following:
(a) Executive Summary (1-2 pages)
· Breaches of AL levels
· Complaint Log
· Notifications of any summons and successful prosecutions;
· Reporting Changes
· 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 project EIA study report, 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 trends of 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; and
· Any other factors which might affect the monitoring results;
· 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 notifications of summons and successful prosecutions for breaches of the current environmental protection/pollution control legislation’s, 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.
(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
15.4
Annual and Bi-annual Reports
In addition to the Monthly Reports, Annual and Bi-annual Reports will be issued which will provide a general summary of the progress of the Project EM&A to date. The reports shall be produced by the ET Leader and should generally be around 5 pages (including about 3 of text and tables and 2 of figures), should contain at least the following information:
(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 project EIA study final report;
(d) advice on the implementation status of environmental protection and pollution control/mitigation measures, as recommended in the project EIA study report, 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 notification of summons and successful prosecutions for breaches of the current environmental protection/pollution control legislation’s, 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.
15.5
Final EM&A Summary Report
The EM&A programme shall be terminated upon completion of those construction activities that have the potential to result in a significant environmental impact.
Prior to the proposed termination, it may be advisable to consult relevant local communities (such as village representatives/committees and/or District Boards). The proposed termination should only be implemented after the proposal has been endorsed by the Contractor, the Engineer and the project proponent, and following final approval from the Director of Environmental Protection.
The final EM&A summary report shall include, inter alia, the following:
(a) an executive summary;
(b) basic project information including a synopsis of the project organisation, programme, contracts 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 project EIA study final report;
(d) advice on the implementation status of environmental protection and pollution control/mitigation measures, as recommended in the project EIA study report, 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; and
· the return of ambient environmental conditions in comparison with baseline data;
(g) compare and contrast the EM&A data with the 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 notification of summons and successful prosecutions for breaches of the current environmental protection/pollution control legislation’s, locations and nature of the breaches, investigation, follow-up actions taken and results;
(p) review the practicality and effectiveness of the 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 EIA findings.
Documentation such as the monitoring field records, laboratory analysis records, site inspection forms, etc. are not required to be included in the monthly EM&A reports for submission. However, such documents shall be well kept by the ET Leader and Contractor, as appropriate, and shall be available for inspection upon request. All relevant information shall be clearly and systematically recorded in the documents. The monitoring data shall also be recorded in magnetic media form, and the software copy can be available upon request. The water quality data software format shall be agreed with EPD. All the documents and data shall be kept for at least one year after completion of the construction contract.
15.7
Interim Notification of Environmental Quality Limit Exceedances
Interim notifications of exceedances of Limit levels will be issued to the EPD within 24 hours of the identification of an exceedance. The Monthly Reports will contain all available details concerning measures exceedances and complaints, their causes and those steps taken to control impacts and prevent their recurrence. A suggested format for a complaints proforma is in Annex D (Record Sheet 1.3).