7.4 Operational Phase Monitoring Reports

7.5 Data Keeping

7.6 Interim Notifications of Environmental Quality Limit Exceedances

Appendices

Appendix D EM&A Guidelines for Development Projects in Hong Kong

7. reporting

7.1 General

7.1.1.1 The reporting requirements of EM&A information are based upon a paper-documented approach. However, the same information can be provided in an electronic medium upon agreeing the format with the IEC, the SOR, DSD and EPD for construction and operation phases. This would enable a transition from a paper / historic and reactive approach to an electronic / real time proactive approach.

7.1.1.2 For construction phase EM&A, types of reports that the ET Leader shall prepare and submit include baseline monitoring report, monthly EM&A report, quarterly EM&A summary report and final EM&A review report. In accordance with Annex 21 of the EIAO-TM, a copy of the monthly, quarterly summary and final review EM&A reports shall be submitted to the Director of Environmental Protection. The exact details of the frequency, distribution and time frame for submission shall be agreed with the IEC, the SOR, DSD and EPD prior to commencement of works. Real-time reporting of monitoring data should be provided through a dedicated internet website.

7.2 Baseline Monitoring Report

7.2.1.1 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 the Contractor, the IEC, the SOR, DSD and EPD. The ET Leader shall liaise with the relevant parties on the exact number of copies they require.

7.2.1.2 The baseline monitoring report shall 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:

· 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

· quality assurance (QA) / quality control (QC) results and detection limits

(v) details of 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 results

(vi) determination of the Action and Limit 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

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

(viii) comments, recommendations and conclusions.

7.3 Monthly EM&A Reports

7.3.1.1 The results and findings of all EM&A work required in the Manual shall be recorded in the monthly EM&A reports prepared by the ET Leader. The EM&A report shall be prepared and submitted within 10 working days of the end of each reporting month, with the first report due the month after construction commences. Each monthly EM&A report shall be submitted to the following parties: the Contractor, the IEC, the SOR, DSD and EPD. Before submission of the first EM&A report, the ET Leader shall liaise with the parties on the required number of copies and format of the monthly reports in both hard copy and electronic medium.

7.3.1.2 The ET leader shall 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

7.3.1.3 The first monthly EM&A report shall include at least but not limited to the following:

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

· breaches of Action and Limit levels

· complaint log

· notifications of any summons and successful prosecutions

· reporting changes

· future key issues

(ii) basic project information:

· project organisation including key personnel contact names and telephone numbers

· construction programme

· management structure

· works undertaken during the month

(iii) environmental status:

· works undertaken during the month with illustrations (such as location of works etc)

· drawings showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations (with co-ordinates of the monitoring locations)

· advice on status of compliance with environmental permit including the status of submissions under the environmental permit

(iv) a brief 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

(v) implementation status:

· advice on 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) 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

· 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 monitoring results

- any other factors which might affect the monitoring results

- QA/QC results and detection limits

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

· record of change established from the organisation and interpretation of monitoring results in the month

· 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 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

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

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

(viii) others

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

· 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 during the month including waste generation and disposal records

· comments including effectiveness of the environmental management systems, practices, procedures and mitigation measures), recommendations (for example, any improvement in the EM&A programme) and conclusions

(vii) appendix

· Action and Limit levels

· graphical plots of trends of monitored parameters at key stations over the reporting period for representative monitoring stations annotated against the followings:

- major activities being carried out on site during the period

- weather conditions during the period

- any other factors that 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

Subsequent Monthly EM&A Reports

7.3.1.4 Subsequent monthly EM&A reports shall include the following:

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

· breaches of Action and Limit levels

· complaints log

· notifications of any summons and successful prosecutions

· reporting changes

· future key issues

(ii) 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 (such as location of works etc.) including key personnel contact names and telephone numbers

· drawing showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations

· advice on status of compliance with environmental permit including the status of submissions under the environmental permit

(iii) implementation status:

(iv) 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

· 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 monitoring results

- any other factors which might affect the monitoring results

- QA / QC results and detection limits

(v) report on change, non-compliance, complaints, and notifications of summons and successful prosecutions:

· record of change established from the organisation and interpretation of monitoring results in the month

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

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

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

(vi) others

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

· 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 during the month including waste generation and disposal records

(vii) appendix

· Action and Limit 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:

- major activities being carried out on site during the period

- weather conditions during the period

- any other factors that 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

7.3.1.5 Some information concerning the EM&A works, such as the EM&A requirements would remain unchanged throughout the EM&A programme. In the subsequent Monthly EM&A Reports, the First Monthly EM&A Report can be referred instead of repeating the description of the unchanged information.

Quarterly EM&A Summary Reports

7.3.1.6 A quarterly EM&A summary report shall be produced and shall contain at least the following information. Apart from these, the first quarterly summary report should also confirm if 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.

(i) up to half a page executive summary

(ii) basic project information including a synopsis of the project organisation, programme, contacts of key management, and a synopsis of works undertaken during the quarter

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

· monitoring parameters

· environmental quality performance limits (Action and Limit levels)

· environmental mitigation measures, as recommended in the project EIA Final Report

(iv) advice on the implementation status of environmental protection and pollution control / mitigation measures, as recommended in the project EIA Final Report, summarised in the updated implementation schedule

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

(vi) graphical plots of any trends in monitored parameters over the past four 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

· any other factors which might affect the monitoring results

(vii) advice on the solid and liquid waste management status during the quarter including waste generation and disposal records

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

(ix) a brief review of the reasons for and the implications of any non-compliance, including a review of pollution sources and working procedures

(x) a summary description of actions taken in the event of non-compliance and any follow-up procedures related to any earlier non-compliance

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

(xii) comments (for examples, a review of the effectiveness and efficiency of the mitigation measures); recommendations (for example, any improvement in the EM&A programme) and conclusions for the quarter

(xiii) proponents' contacts and any hotline telephone number for the public to make enquiries.

Final EM&A Review Report

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

7.3.1.8 The proposed termination should only be implemented after the proposal has been endorsed by the IEC, the SOR and the DSD followed by final approval from the Director of Environmental Protection.

7.3.1.9 The final EM&A summary report should include, inter alia, the following information:

(i) an executive summary

(ii) basic project information including a synopsis of the project organisation, contacts of key management, and a synopsis of work undertaken during the entire construction period

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

· monitoring parameters

· environmental quality performance limits (Action and Limit levels)

· environmental mitigation measures, as recommended in the project EIA study final report

(iv) advice on the implementation status of environmental and pollution control/mitigation measures, as recommended in the project EIA study final report, summarised in the updated implementation status proformas

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

(vi) graphical plots of the trends of monitored parameters over the construction period for representative monitoring stations, including the post-project monitoring annotated against:

· the major activities being carried out on site during the period

· weather conditions during the period

· any other factors which might affect the monitoring results

· the return of ambient environmental conditions in comparison with baseline data

(vii) compare and contrast the EM&A data with the EIA predictions and annotate with explanation for any discrepancies

(viii) provide clear-cut decisions on the environmental acceptability of the project with reference to the specific impact hypothesis

(ix) advice on the solid and liquid waste management status

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

(xi) a brief review of the reasons for and the implications of non-compliance including review of pollution sources and working procedures

(xii) a summary description of the actions taken in the event of non-compliance and any follow-up procedures related to earlier non-compliance

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

(xiv) review the monitoring methodology adopted and with the benefit of hindsight, comment its effectiveness (including cost effectiveness)

(xv) 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

(xvi) 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

(xvii) a conclusion to state the return of ambient and/or the predicted scenario as per EIA findings

7.4 Operational Phase Monitoring Reports

7.4.1.1 For the operation phase EM&A, the Environmental Team shall prepare and submit Water Quality Monitoring Report for each emergency discharge event and Odour Monitoring Report to report the odour monitoring results. The exact details of the frequency, distribution and time frame for submission shall be agreed with the IEC, the SOR, DSD and EPD prior to commencement of works.

Water Quality Monitoring Report

7.4.1.2 Water Quality Monitoring Report shall be prepared for each emergency discharge event. The report shall be submitted to DSD, EPD and LCSD within 10 days after the laboratory testing result for the last sample collected during the monitoring period is available. The findings of the water quality monitoring results including data presentation, statistical analysis, discussion, conclusion and recommendation shall be provided in the Water Quality Monitoring Report. Water Quality Monitoring Report shall include the following:

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

· breaches of Water Quality Objectives at Water Sensitive Receivers (e.g. bathing beaches)

· complaints log

· reporting changes

· future key issues

(ii) environmental status:

· drawing showing the project area, any environmental sensitive receivers and the locations of the monitoring stations

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

· monitoring methodology

· Name of laboratory and types of monitoring equipment used and calibration details

· parameters monitored

· monitoring locations

· monitoring date, time, frequency, and duration

· weather conditions during the period

· the major activities being carried out on site during the period (i.e. emergency discharge quantity & quality, duration, locations)

· any other factors which might affect the monitoring results

· QA / QC results and detection limits

(iv) report on change, non-compliance, complaints:

· interpretation of monitoring results in the monitoring period

· record of all non-compliance (exceedances) of the environmental quality performance limits

· compare the impact monitoring data with the baseline data to identify the degree of impact caused by the emergency discharge (if any) and determine when the normal water quality conditions are restored after the emergency discharge is ceased.

(v) others

· compare and contrast the water quality monitoring data in the monitoring period with the EIA predictions and annotate with explanation for any discrepancies

Odour Monitoring Report

7.4.1.3 The Odour Monitoring Report shall be prepared and submitted to DSD, EPD and other relevant departments within 30 days from availability of the test results for the operation phase monitoring. The findings of the odour monitoring results including data presentation, result analysis, discussion, conclusion and recommendation shall be provided in the Odour Monitoring Report. Odour Monitoring Report shall include the following:

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

· breaches of Action and Limit levels

· complaints log

· reporting changes

· future key issues

(ii) environmental status:

· drawing showing the project area, any environmental sensitive receivers and the locations of the monitoring stations

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

· monitoring methodology

· types of monitoring equipment used and calibration details

· parameters monitored

· monitoring locations

· monitoring date, time, frequency, and duration

· weather conditions during the period

· the major activities being carried out on site during the period

· any other factors which might affect the monitoring results

· QA / QC results and detection limits

(iv) report on change, non-compliance, complaints:

· interpretation of monitoring results

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

· review of the reasons for and the implications of non-compliance, complaints including review of pollution sources and working procedures

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

(v) others

· compare and contrast the odour monitoring data with the EIA predictions and annotate with explanation for any discrepancies

· comments including effectiveness of the odour control systems and mitigation measures, recommendations and conclusions

7.5 Data Keeping

7.5.1.1 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 shall be well kept by the ET Leader / ET and be ready for inspection upon request. All relevant information shall be clearly and systematically recorded in the document. Monitoring data shall also be recorded in magnetic media form, and the software copy must be available upon request. Data format shall be agreed with the IEC, the SOR, DSD and EPD for construction and operation phases. All documents and data shall be kept for at least one year following completion of the construction contract and one year after the completion of operation phase monitoring for construction phase EM&A and operation phase EM&A, respectively.

7.6 Interim Notifications of Environmental Quality Limit Exceedances

7.6.1.1 For construction phase EM&A, with reference to the Event and Action Plan, when the environmental quality performance limits are exceeded, the ET Leader shall immediately notify the IEC, the SOR, DSD and EPD, as appropriate. The notification shall be followed up with advice to the IEC, the SOR, DSD 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 notifications based on the one presented in EM&A Guidelines for Development Projects in Hong Kong, is shown in Appendix D. The ET Leader may modify the interim notification form for this EM&A programme, of which the format should be approved by the SOR and agreed by the IEC.