Issue No.	:	Final
Issue Date	:	January 2024
Project No.	:	1709

Environmental monitoring and audit (em&a) Manual

for

Construction of Annex Block at Hong Kong Observatory Headquarters, Tsim Sha Tsui

Prepared by

Allied Environmental Consultants Ltd.

Commercial-in-confidence

Document Verification

Project Title		Construction of Annex Block at Hong Kong Observatory Headquarters, Tsim Sha Tsui			Project No.
					1709
Document Title		Environmental Monitoring and Audit (EM&A) Manual
Issue No.	Issue Date	Description	Prepared by	Checked by		Approved by
Final	Jan 2024	Issue 1	Various	Cathy Man (HKIQEP-PM0351)		Grace Kwok (HKIQEP-FF0002)

1 Introduction

1.1 Project Background

1.1.1 The Project is for construction of a new Annex Block, and refurbishment of the existing Red House at Hong Kong Observatory (HKO) Headquarters in Tsim Sha Tsui to (i) meet the existing shortfall in office space and functional areas for operation needs of the HKO; (ii) provide space for developing HKO’s essential operation and services; and (iii) provide space for organizing public education and outreach activities relating the HKO’s work.

1.1.2 The Project is planned to construct on a piece of land located at the southern side of HKO Headquarters which is a Declared Monument under the Antiquities and Monuments Ordinance (Cap.53) at 134A Nathan Road, Tsim Sha Tsui. The site location of the Project is shown in Figure 1.1.

1.1.3 The Project is classified as a Designated Project (DP) under Item Q.1, Part I of Schedule 2 of the Environmental Impact Assessment Ordinance (EIAO).

1.1.4 Allied Environmental Consultants Limited was commissioned by Architectural Services Department (ArchSD) to conduct the EIA study. The EIA Study Brief (No: ESB-347/2021) for the Project includes the requirement to prepare an Environmental Monitoring and Audit (EM&A) programme. This EM&A manual is prepared in accordance with Annex 21 of the Technical Memorandum on EIA Process and the Project Study Brief for the Project and follows the approach recommended in the EM&A Guidelines for Development Projects in Hong Kong

1.2 Project Scope and Location

1.2.1 Location Plan of the Project is shown in Figure 1.1. The scope of the Project would comprise:

(a) Construction of a new Annex Block at HKO Headquarters,

(b) Refurbishment works to convert the existing Red House into a History Room for showing the history of HKO;

(d) Minor public utility works and minor maintenance works to roads, slopes and utilities connecting to the existing HKO Headquarters .

1.3 Tentative Construction Programme

1.3.1 The construction of the Project is tentatively to commence in period from 2025 to 2029 depending on the design process. The preliminary construction programme of the Project is shown in Appendix 1.1.

1.4 Purpose of EM&A Manual

1.4.1 The purpose of this Environmental Monitoring and Audit (EM&A) Manual (hereafter referred to as “this Manual”) is to

· Guide the setup of an EM&A programme to ensure the compliance with the EIA study recommendations;

· Specify the requirements for monitoring equipment;

· Propose environmental monitoring points, monitoring frequency etc.;

· Propose Action and Limit Levels; and

· Propose Event and Action Plans.

1.4.2 This Manual outlines the monitoring and auditing programme for the construction and operation of the Project and provides systematic procedures for monitoring, auditing and minimizing environmental impacts.

1.4.3 Hong Kong environmental regulations and the Hong Kong Planning Standards and Guidelines (HKPSG) have served as environmental standards and guidelines in the preparation of this Manual. In addition, this Manual has been prepared in accordance with the requirements stipulated in Annex 21 of the Technical Memorandum on the EIA Process (EIAO-TM).

1.4.4 The Manual contains the following information:

· Responsibilities of the Contractor, the Engineer or Engineer’s Representative (ER), Environmental Team (ET), and the Independent Environmental Checker (IEC) under the context of EM&A;

· Project organisation for the EM&A works;

· The basis for, and description of the broad approach underlying the EM&A programme;

· Details of the methodologies to be adopted, including all laboratories and analytical procedures, and details on quality assurance and quality control programme;

· The rationale on which the environmental monitoring data will be evaluated and interpreted;

· Definitions of Action and Limit levels;

· Establishment of Event and Action Plans;

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

· Requirements for presentation of environmental monitoring and audit data and appropriate reporting procedures.

1.4.5 For the purpose of this Manual, the ER shall refer to the Engineer as defined in the Construction Contract, in cases where the Engineer’s powers have been delegated to the ER, in accordance with the Construction Contract. The ET leader, who shall be responsible for and in charge of the ET, shall refer to the person delegated the role of executing the EM&A requirements.

1.5 Project Organization

Background

1.5.1 The roles and responsibilities of various parties involved in the EM&A process and the organisation structure of the parties responsible for implementing the EM&A programme are outlined below.

Engineer or Engineer’s Representative (ER)

1.5.2 The ER is responsible for overseeing the construction works and ensuring the works to be undertaken by the Contractor in accordance with the specifications and contractual requirements. The duties and responsibilities of the ER with respect to the EM&A include:

· Supervise the Contractor’s activities and ensure that the requirements in this Manual are fully complied with;

· Inform the Contractor when action is required to reduce impacts in accordance with the Event and Action Plans;

· Participate in joint site inspections and audits undertaken by the ET; and

· Adhere to the procedures for carrying out complaint investigations.

The Contractor

1.5.3 The Contractor should report to the ER. The duties and responsibilities of the Contractor are:

· Comply with the relevant contract conditions and specifications on environmental protection;

· Implement the EIA recommendations and requirements;

· Provide assistance to ET in carrying out relevant monitoring and audit;

· Participate in the site inspections by the ET as required, and undertake any corrective actions;

· Provide information / advice to ET regarding works activities which may contribute, or be continuing to the generation of adverse environmental conditions;

· Submit proposals on mitigation measures in case of exceedances of Action and Limit levels in accordance with the Event and Action Plans;

· Implement measures to reduce impact where Action and Limit levels are exceeded; and

· Adhere to the procedures for carrying out complaint investigations.

Environmental Team (ET)

1.5.4 An ET with an ET Leader shall be employed to conduct the EM&A programme before the commencement of construction of the Project. The ET Leader or the ET shall be an independent party from the IEC and the Contractor and have relevant professional qualifications, or have sufficient relevant EM&A experience subject to approval of the Environmental Protection Department (EPD).

1.5.5 The ET should be led and managed by an ET leader, who should possess at least 7 years of experience in EM&A or environmental management. The ET should monitor the mitigation measures implemented by the Contractor on a regular basis to ensure the compliance with the intended aims of the mitigation measures.

1.5.6 The duties and responsibilities of the ET are:

· Set up all the required environmental monitoring stations;

· Monitor various environmental parameters as required in this Manual;

· Analyze the environmental monitoring and audit data, review the success of EM&A programme, confirm the adequacy of mitigation measures implemented and the validity of the Environmental Impact Assessment (EIA) predictions, and to identify any adverse environmental impacts arising;

· Carry out site inspection to investigate and audit the Contractors’ site practice, equipment and work methodologies with respect to pollution control and environmental mitigation measures, and take proactive actions to pre-empt problems;

· Audit and prepare audit reports on the environmental monitoring data and site environmental conditions;

· Report on the environmental monitoring and audit results to the IEC, Contractor, and the ER or its delegated representative;

· Recommend suitable mitigation measures to the Contractor in the case of exceedance of Action and Limit levels in accordance with the Event and Action Plans;

· Undertake regular on-site audits / inspections and report to the Contractor and the ER of any potential non-compliance;

· Follow up and close out non-compliance actions;

· Advise the Contractor on environmental improvement, awareness, enhancement matters, etc., on site; and

· Adhere to the procedures for carrying out environmental complaint investigation.

Independent Environmental Checker (IEC)

1.5.7 The IEC should be employed by the Project Proponent / Engineer prior to the commencement of the Project. The IEC shall be an independent party from the Contractor and the ET and should possess at least 7 years of experience in EM&A and/or environmental management. The main duties and responsibilities of the IEC are:

· Review the EM&A works performed by the ET (at not less than monthly intervals) ;

· Audit the monitoring activities and results (at not less than monthly intervals);

· Validate and confirm the accuracy of monitoring results, monitoring equipment, monitoring locations, monitoring procedures and locations of sensitive receivers;

· Review the EM&A reports submitted by the ET;

· Review the proposal on mitigation measures submitted by the Contractor in accordance with the Event and Action Plans;

· Check the mitigation measures submitted by the Contractor in accordance with the Event and Action Plans;

· Check the mitigation measures that have been recommended in the EIA and this Manual, and ensure they are properly implemented in a timely manner, when necessary; and

· Report the findings of site inspections and other environmental performance reviews to ER and EPD.

1.5.8 Sufficient and suitably qualified professional and technical staff shall be employed by the respective parties to ensure full compliance with their duties and responsibilities as required under the EM&A programme for the duration of the Project.

1.6 Structure of EM&A Manual

1.6.1 Following this introductory section, the structure of this Manual is set out as below:

· Section 2 sets out the EM&A requirements for air quality impact;

· Section 3 sets out the EM&A requirements for noise impact;

· Section 4 sets out the EM&A requirements for water quality and sewerage impact;

· Section 5 sets out the EM&A requirements for waste management implications;

· Section 6 sets out the EM&A requirements for impact on cultural heritage;

· Section 7 sets out the EM&A requirements for landscape and visual impact;

· Section 8 describes the scope and frequency of the environmental site audits and sets out the system of handling complaints; and

· Section 9 details the EM&A reporting requirements.

3 Noise

3.1 Introduction

3.1.1 Potential noise impacts arising from the construction and operation of the Project were assessed in the EIA Report. Noise monitoring is proposed to be conducted during construction phase.

3.1.2 Construction noise mitigation measures would be required to reduce noise levels to the stipulated standard. A noise monitoring and audit programme should be undertaken to confirm such mitigation measures would be implemented properly. Construction Noise Management Plan (CNMP) shall be prepared and submitted to the Director of EP no later than 2 months before the issuance of the tender of the Project and before commencement of the project implementation. The CNMP shall be prepared and checked by Certified Noise Modelling Professional as recognized by Hong Kong Institute of Qualified Environmental Professionals Limited (HKIQEP) or equivalent.

3.1.3 For fixed plant noise impact, a noise commissioning test should be conducted to ensure fixed plant noise impact would comply with the relevant noise standards. No noise monitoring during operation phase is required.

3.1.4 The EM&A requirements, methodology, equipment, monitoring locations and protocols for the noise impacts during the construction phase of the Project are presented in this Section.

3.2 Construction Phase Monitoring

Noise Parameters

3.2.1 The construction noise level should be measured in terms of the 30-minute A-weighted equivalent continuous sound pressure level (L_eq). L_{eq (30 min)}should be used as the monitoring parameter for the time period between 0700 and 1900 hours on normal weekdays.

3.2.2 Supplementary information for data auditing and statistical results, such as L₁₀ and L₉₀, should be obtained and recorded for reference. A sample data record sheet is provided in Appendix 3.1 for reference. The ET Leader may modify the data record sheet for this EM&A programme but the format of which should be agreed by the IEC.

Monitoring Equipment

3.2.3 As referred to the Technical Memorandum (TM) issued under the Noise Control Ordinance (NCO), the sound level meters in compliance with the International Electrotechnical Commission Publications 651: 1979 (Type 1) and 804:1985 (Type 1) specifications should be used for conducting the noise monitoring. Immediately prior to and following each noise measurement, the accuracy of the sound level meter should be checked using an acoustic calibrator generating a known sound pressure level at a known frequency. Measurements shall be accepted as valid only if the difference between calibration levels obtained before and after the noise measurement agree to within 1.0 dB.

3.2.4 Noise measurements should not be conducted in the presence of fog, rain, wind with a steady speed exceeding 5 m/s or wind with gusts exceeding 10 m/s. The wind speed should be checked with a portable wind speed meter capable of measuring wind speeds in m/s.

3.2.5 The ET is responsible for the provision of the monitoring equipment and should ensure that sufficient noise measuring equipment and associated instrumentation are available for conducting the baseline monitoring, regular impact monitoring and ad-hoc monitoring. All the equipment and associated instrumentation should be labelled clearly. The equipment installation location shall be proposed by the ET Leader and agreed with the IEC and EPD.

Monitoring Locations

3.2.6 Based on the EIA study, construction noise monitoring should be conducted at the potentially worst affected locations as listed in Table 3.1 and shown in Figure 3.1.

Table 3.1 Designated Noise Monitoring Stations

Identification No.	NSR ID in EIA Report	Monitoring Stations
NM1	NAP101	HKO Quarters No.2 (Within HKOHQ)
NM2	NAP201	HKO Quarters No.1 (Within HKOHQ)
NM3	NAP501	Lok Fun Mansion[SC1]
NM4	NAP601	Carlton Building

3.2.7 The status and location of noise sensitive receivers (NSRs) may change after issuing this Manual. If such cases exist, the ET should propose alternative monitoring locations and seek approval from the IEC and agreement from the EPD on the proposal. The alternative locations should be selected based on the following criteria:

· Locations that are close to the major site activities which are likely to have noise impacts;

· Close to the NSRs; and

· For monitoring locations located in the vicinity of the sensitive receivers, care shall be taken to cause minimal disturbance to the occupants during monitoring.

3.2.8 The monitoring stations should normally be at a point 1 m from the exterior of the facade of the NSR and be at a position 1.2 m above the ground. If there is a problem with access to the normal monitoring position, an alternative position should be chosen, and a correction to the measurement results should be made. For reference, a correction of +3 dB(A) should be made to the free field measurements. The ET shall agree with the IEC on the monitoring position and the corrections adopted. Once the positions for the monitoring stations are chosen, the baseline and impact monitoring should be carried out at the same positions. If changes to the monitoring stations are required upon commencing the baseline monitoring or thereafter, the ET should propose alternative locations based on the above-mentioned criteria and seek approval from the IEC and agreement from EPD on the proposal.

Baseline Monitoring

3.2.9 The ET should carry out the baseline noise monitoring in all of the identified monitoring stations prior to the commencement of the construction works. The baseline noise levels should be measured for a continuous period of at least 14 consecutive days at a minimum logging interval of 30 minutes during daytime between 0700 and 1900, and 5 minutes between 1900 and 0700. The L_eq, L₁₀ and L₉₀ should be recorded at the specified intervals. A schedule on the baseline monitoring should be submitted to the IEC for approval before the baseline monitoring starts.

3.2.10 There should not be any construction activities in the vicinity of the monitoring stations during the baseline monitoring. The source and location of any non-project related construction activities in the vicinity of the monitoring stations during the baseline monitoring should be noted and recorded.

3.2.11 In exceptional case, when baseline monitoring data obtained are insufficient or questionable, the ET Leader shall liaise with the ER, IEC and EPD to agree on an appropriate set of data to be used as a baseline reference.

Impact Monitoring

3.2.12 Noise monitoring should be carried out at all the designated monitoring stations when there are project-related construction activities being undertaken within a radius of 300m from the monitoring stations. Monitoring of L_eq(30min) should be carried out at each station between 0700 and 1900 hours on normal weekdays at a frequency of once a week when construction activities are underway.

3.2.13 If construction works are extended to include works during the hours of 1900 to 0700, additional weekly impact monitoring shall be carried out during evening and night-time works. Applicable permits under NCO shall be obtained by the Contractor.

3.2.14 In case of non-compliance with the construction noise criteria, more frequent monitoring as specified in the Event and Action Plan in Table 3.2 should be carried out. The additional monitoring should be continued until the recorded noise levels show that the non-compliance is rectified or proved to be irrelevant to the roject-related construction activities.

Event and Action Plan

3.2.15 The Action and Limit levels for the construction noise are provided in Table 3.2. Should non-compliance of the noise criteria occur, actions in accordance with the Event and Action Plan in Table 3.3 should be taken.

Table 3.2 Action and Limit Level for Construction Noise Monitoring

Time Period	Action Level	Limit Level
0700 – 1900 hours on any day not being a general holiday	When one documented complaint is received	75 dB(A) for residential premises

Note:

If works are to be carried out during restricted hours and/or percussive piling is to be carried out, the monitoring requirements and conditions stipulated in the construction noise permit (CNP) issued by the Noise Control Authority have to be followed.

	Action
Action Level	1. Notify IEC and Contractor. 2. Carry out investigation. 3. Report the results of investigation to the ER, IEC and Contractor. 4. Discuss with the IEC and Contractor and formulate remedial measures. 5. Increase monitoring frequency to check mitigation effectiveness.	1. Review the investigation results submitted by the ET. 2. Review the proposed remedial measures by the Contractor and advise the ER accordingly. 3. Supervise the implementation of remedial measures	1. Confirm receipt of notification of failure in writing. 2. Notify the Contractor. 3. Require the Contractor to propose remedial measures. 4. Ensure remedial measures are properly implemented.	1. Submit noise mitigation proposals to the IEC and ER. 2. Implement noise mitigation proposals.
Limit Level	1. Notify the ER, IEC, Contractor and EPD. 2. Identify sources. 3. Repeat measurements to confirm findings. 4. Increase monitoring frequency. 5. Carry out analysis of Contractor’s working procedures to determine possible mitigation to be implemented. 6. Inform the IEC, ER and Contractor the causes and action taken for the exceedances.	1. Discuss amongst the ER, ET and Contractor on the potential remedial action. 2. Review the Contractor’s remedial action whenever necessary to ensure their effectiveness and advise the ER accordingly.	1. Confirm receipt of notification of failure in writing. 2. Notify the Contractor. 3. Require the Contractor to propose remedial measures. 4. Ensure remedial measures are properly implemented. 5. If exceedance continues, consider what portion of work is responsible and instruct the Contractor to stop that portion of works until the exceedance is abated.	1. Take immediate action to avoid further exceedance. 2. Submit proposals for remedial action to the IEC and ER within 3 working days of notification. 3. Implement the agreed proposals. 4. Submit further proposals if problems still not under control. 5. Stop the relevant portion of works as determined by the ER until the exceedance is abated.

6 cultural heritage impact

6.1 Introduction

6.1.1 Cultural heritage resources within study area have been identified and reviewed through literature review and field surveys. Visual impact to the major heritage resources is not anticipated during construction and operation phases. Direct impact to key historic buildings will be in a controlled manner, which will be at localised locations for the UU diversion works, and restricted to refurbishment works to Red House, with mitigation measures. Indirect vibration/settlement/tilting impact on historic buildings during construction phase will be monitored with monitoring measures.

6.1.2 No SAI is found within the Cultural Heritage Assessment Area (CHAA). The excavation of the Project are mainly located in developed area undergone construction works with high level of ground disturbance, and area unfavourable to cultural deposit accumulation which has no archaeological potential, therefore no adverse archaeological impact due to the proposed works of the Project is anticipated. However, the proposed work area of Underground utilities (UU) diversion work near to the entrance of the 1883 building, which requires excavation of 1.8m from the ground level, is located near to the underground chamber and the stairs connecting the tunnel portal to underground chamber. It is recommended that design proposal, method of works and choice of machinery should be targeted to avoid direct physical impacts to the underground chamber, stair and tunnel portal. Any vibration/ settlement / titling induced from the proposed works should be strictly monitored to ensure no physical damages made to the underground chamber with tunnel portal during the course of works. As a precautionary measure, the Project Proponent is required to inform AMO immediately when any antiquities or supposed antiquities under the Antiquities and Monuments Ordinance (Cap. 53) are discovered during the course of works.

6.1.3 Monitoring measures are required during the construction stage upon commencement of any works till the works completed to ensure the structural integrity of the historic buildings within the HKO Headquarters, including 1883 Building and its annex building, Quarters No. 2 and No. 3, Garage of Quarters No. 2, Underground chamber with tunnel portal, Quarters No. 1, Garage of Quarters No. 1, Garage adjacent to Quarters No. 1, Red House, Substation A, White House No. 2 and White House No. 1. The 3A levels of control criteria (Alert, Alarm and Action) would be adopted for monitoring during the foundation and excavation and lateral support works for the construction of new Annex Block. Checkpoints and markers relating to ground settlement, services settlement, building tilting, vibration and water table would be installed for the monitoring. The concerned limits are proposed in Table 6.1:

Table 6.1 Alert, Alarm and Action Level of Cultural Heritage Monitoring

Monitoring	Alert Level	Alarm Level	Action Level
Ground settlement (mm)	6	8	10
Tilting	1/2000	1/1500	1/1000
Vibration (mm/s)	2	2.5	3

6.1.4 Different sets of monitoring points should be provided in the vicinity of the Project Site and the historic buildings of HKO Headquarters respectively, with locations and frequency to be agreed by AMO. Construction works shall be suspended immediately when a vibration monitoring reading is found to exceed the limit given in the vibration control or monitoring scheme. The investigation report and remedial proposal shall be submitted to Project Team, ArchSD and AMO to examine the construction method and review ground response history of the monitoring record. The construction works shall be resumed after the acceptance of the investigation report and remedial proposal by Project Team, ArchSD and AMO.

6.1.5 Regular inspections of construction activities, works sites and works areas should be conducted to ensure that the recommended mitigation measures are properly implemented.

6.2 Recommendations

6.2.1 According to the EIA Report, cultural heritage mitigation measures are recommended. The Contractor should be responsible for the design and implementation of the measures and practices under the supervision of the ER and monitored by the ET. The mitigation measures should be checked in routine site inspections and regular audits. The implementation schedule for the recommended mitigation measures is presented in Appendix 1.2.

7 Landscape and Visual

7.1 Introduction

7.1.1 The EIA Report has recommended landscape and visual mitigation measures for the construction and operation phases of the Project. This section defines the audit requirements to confirm the recommended landscape and visual impact mitigation measures are effectively implemented.

7.2 Mitigation Measures

7.2.1 The proposed mitigation measure of landscape and visual impacts are presented in the EMIS in Appendix 1.2 of this Manual. The landscape and visual mitigation measures proposed should be incorporated in the detailed landscape and engineering design. The construction phase mitigation measure should be adopted from the commencement of construction and should be in place throughout the entire construction period. Mitigation measures for the operation phase should be adopted during the detailed design and be built as part of the construction works so that they are in place on commissioning of the Project.

7.2.2 Any potential conflict among the proposed mitigation measures, the Project works, and operational requirements should be identified and resolved at early stage. Any change to the mitigation measures should be incorporated in the detailed design.

7.3 Baseline Review for Landscape & Visual Impact

7.3.1 Baseline review to check, record and report the status of the Landscape Resources (LR) and Landscape Character Areas (LCA) within the construction works sites and works areas and the Visually Sensitive Receivers(VSRs) within the visual envelope shall be conducted prior to commencement of any construction works making reference to the LR, LCA and VSRs maps included in the EIA Report.

7.3.2 Any significant change to the status of LR, LCA and VSRs since the EIA shall be identified. The recommended mitigation measures shall be reviewed if such change warrants a change in the design of the mitigation measures.

7.3.3 A baseline monitoring report including photographic record of the site at the time of the Contractor’s possession of the Project Site shall be prepared by the Contractor and approved by the ER. The approved baseline monitoring report including photographic record shall be submitted to the Project Proponent, ET, IEC and EPD for record.

7.4 Audit Requirements

7.4.1 Site audits should be undertaken during the construction phase and the 12-month establishment period (operation phase) of the Project to check that the proposed landscape and visual mitigation measures are properly implemented and maintained as per their intended objectives. The extent of works areas should be regularly checked by the ET, ER and the Contractor to ensure no damage to existing vegetation or trees outside the works limits.

7.4.2 The conditions and growth performance of the implemented compensatory planting should be regularly checked and monitored by a qualified plant specialist of the ET to ensure the effectiveness of the mitigation measures. A specialist landscape subcontractor should be employed for the implementation of tree and landscape works and subsequent maintenance operations during the establishment period.

7.4.3 Monthly Site inspections should be undertaken by the ET during the construction period and once every two months for the 12-month establishment period during operation phase.

7.5 Event and Action Plan

7.5.1 Should non-compliance of the landscape and visual impacts occur, actions should be carried out in accordance with the event and action plan as shown in Table 7.1.

Table 7.1 Event and Action Plan for Landscape and Visual Impact during

Construction Phase

Action Level

IEC

Contractor

Non-conformity on one occasion

1. Inform the IEC and ER.

2. Discuss remedial actions with the IEC, ER and Contractor.

3. Monitor remedial action until rectification has been completed.

1. Check inspection report.

2. Check the Contractor’s working method.

3. Discuss with the ET, ER and Contractor on possible remedial measures.

4. Advise the ER on the effectiveness of the proposed remedial measures.

5. Check implementation of remedial measures.

1. Confirm receipt of notification of non-conformity in writing.

2. Review and agree on the remedial measures proposed by the Contractor.

3. Ensure remedial measures are properly implemented.

1. Identify source and investigate the non-conformity.

2. Amend working methods.

3. Rectify damage and undertake remedial measures or any necessary replacement.

Repeated Non-conformity

1. Identify source.

2. Inform the IEC, ER and Contractor.

3. Discuss remedial actions with the IEC, ER and Contractor.

4. Monitor remedial action until rectification has been completed.

5. If non-conformity stops, cease additional monitoring (site audit).

1. Check inspection report.

2. Check the Contractor’s working method

3. Discuss with the ET, ER and Contractor on possible remedial measures.

4. Advise the ER on effectiveness of proposed remedial measures.

1. Notify the Contractor.

2. In consultation with the ET and ICE, agree with the Contractor on the remedial measures to be implemented.

3. Supervise implementation of remedial measures

1. Identify source and investigate the non-conformity.

2. Implement remedial measures

3. Amend working methods agreed with the ER as appropriate.

4. Rectify damage and undertake remedial measures or any necessary replacement. Stop relevant portion of works as determined by the ER until the non-conformity is abated.

8 Site Environmental Audit and COMPLIANCES

8.1 Site Inspection

8.1.1 Site inspection provides a direct means to trigger and enforce specified environmental protection and pollution control measures. These shall be undertaken regularly and routinely to inspect construction activities in order to ensure that appropriate environmental protection and pollution control mitigation measures are properly implemented. The site inspection is one of the most effective tools to enforce the environmental protection requirements at the works area.

8.1.2 The ET shall be responsible for formulating the environmental site inspection programme as well as the deficiency and action reporting system, and for carrying out the site inspections. The proposal for rectification, if any, should be prepared and submitted to the ET Leader and IEC by the Contractor.

8.1.3 Regular site inspections shall be carried out at least once per week during the construction phase. The areas of inspection shall not be limited to the environmental situation, pollution control and mitigation measures within the site. It should also review the environmental conditions of locations outside the works area which are likely to be affected, directly or indirectly, by the construction site activities of the Project. The ET shall make reference to the following information in conducting the inspection:

· The EIA and EM&A recommendations on the environmental protection and pollution control mitigation measures;

· On-going results of the EM&A programme;

· The works progress and programme;

· Individual works methodology proposals (which shall include the proposal on associated pollution control measures);

· Contract specifications on environmental protection;

· The relevant environmental protection and pollution control legislation; and

· Previous site inspection results undertaken by the ET and others.

8.1.4 The Contractor shall keep the ER and ET Leader updated with all the relevant environmental related information on the construction contract necessary for him to carry out the site inspections. Site inspection results and associated recommendations for improvements to the environmental protection and pollution control efforts should be recorded and followed up by the Contractor in an agreed time-frame. The Contractor shall follow the procedures and time-frame as stipulated in the environmental site inspection, and the deficiency and action reporting system formulated by the ET, to report on any remedial measures subsequent to the site inspections.

8.1.5 The ER, ET and the Contractor should also carry out ad-hoc site inspections if significant environmental problems are identified. Inspections may also be required subsequent to receipt of a valid environmental complaint, or as part of the investigation work, as specified in the Event and Action Plans for the EM&A programme.

8.2 Compliance with Legal and Contractual Requirements

8.2.1 There are contractual requirements and legislation in Hong Kong on environmental protection and pollution control with which the construction activities must comply.

8.2.2 To ensure the works are in compliance with the contractual requirements, all method statements of major works should be submitted by the Contractor to the ER for approval and to the ET for vetting so as to ensure whether sufficient environmental protection and pollution control measures have been incorporated.

8.2.3 The ER and ET should also review the progress and programme of the construction works in order to check that the relevant environmental legislation has not been violated and that any foreseeable potential for violating laws can be prevented.

8.2.4 The Contractor should regularly provide the update of the relevant documents to the ER and ET, so that the checking can be carried out in good time. Such documents should at least include the updated Works Progress Reports, work programme, application letters for environmental licenses / permits, and copies of all valid licenses / permits. The Contractor’s site diary and environmental records should also be available for inspection by the relevant parties.

8.2.5 After reviewing the document, the ET shall advise the IEC and the Contractor of any non-compliance with legislative requirements on environmental protection and pollution control so that they can timely take follow-up actions as appropriate. If the follow-up actions still result in potential violation of environmental protection and pollution control requirements, the ER and ET should provide further advice to the Contractor to take remedial action to resolve the problem.

8.2.6 Upon receipt of the advice, the Contractor shall undertake immediate actions to correct the situation. The ER and ET shall follow up to ensure that appropriate action has been taken in order to satisfy legal requirements.

8.3 Environmental Complaints

8.3.1 Complaints shall be referred to the ET Leader for action. The ET Leader shall undertake the following procedures upon receipt of any complaint:

· log complaint and date of receipt onto the complaint database and inform the IEC immediately;

· investigate the complaint to determine its validity, and assess whether the source of the problem is due to construction works of the Project;

· identify remedial measures in consultation with the IEC if a complaint is valid and due to the construction works of the Project;

· advise the Contractor if mitigation measures are required;

· review the Contractor’s response to identified mitigation measures, and the updated situation;

· If the complaint is referred by the EPD, submit interim report to EPD on the status of the complaint investigation and follow-up actions within the time frame assigned by the EPD;

· undertake monitoring and audit to verify the situation if necessary, and oversee that circumstances leading to the complaint do not recur;

· report investigation results and subsequent actions to complainant (if the source of complaint is identified through EPD, the results should be reported within the timeframe assigned by EPD); and

· record the complaint, investigation, the subsequent actions and results in the Monthly EM&A Reports.

8.3.2 During the complaint investigation, the Contractor and ER should coordinate with the ET to provide all the necessary information and assistance for the completion of the investigation. If mitigation measures are identified to be required, the Contractor should promptly implement such measures and the ER should ensure that the measures have been carried out properly. A flow chart of the complaint response procedures is shown in Appendix 8.1.

9 Reporting

9.1 Introduction

9.1.1 Reports that the ET should prepare and submit include the Baseline Monitoring Report, Monthly EM&A Reports and Final EM&A Review Report. In accordance with Annex 21 of the EIAO-TM, a copy of the Monthly and Final Review EM&A Reports should be made available to the Director of Environmental Protection (DEP). All monitoring data (baseline and impact) should be submitted in an electronic medium.

9.1.2 Reports 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. All the monitoring data (baseline and impact) shall also be submitted in electronic format.

9.2 Baseline Monitoring Report

9.2.1 The ET should prepare and submit a Baseline Monitoring Report within 10 working days of the completion of the baseline monitoring and then certified by the ET Leader. Copies of the Baseline Monitoring Report should be submitted to the Contractor, IEC, ER and EPD. The ET Leader should liaise with the relevant parties on the exact number of copies required. The report format and baseline monitoring data format shall be agreed with the EPD prior to submission.

9.2.2 The Baseline Monitoring Report should include at least the following information:

· An Executive Summary of up to half a page;

· A brief description of the project background;

· Drawing showing locations of the baseline monitoring stations;

· Monitoring results (in both hard and electronic copies) together with the following information:

- Monitoring methodology;

- Name of laboratory and types of equipment used and calibration details;

- Monitoring parameters;

- Monitoring locations;

- Monitoring date, time, frequency and duration; and

- Quality Assurance (QA)/ Quality Control (QC) results and detection limits.

· Details of the influencing factors, including:

- Major activities, if any, being carried out on-site during the period;

- Weather conditions during the period; and

- Other factors which might affect the monitoring results.

· Determination of the Action and Limit Levels for each monitoring parameter and statistical analysis of the baseline data which should conclude if there is any significant difference between the control and impact stations for the parameters monitored, where appropriate;

· Revisions for inclusion in the EM&A Manual; and

· Comments, recommendations and conclusions.

9.3 Monthly EM&A Report

9.3.1 The results and findings of the EM&A programme required in this Manual should be recorded in the Monthly EM&A Reports prepared by the ET Leader and endorsed by IEC. The EM&A reports should be prepared and submitted within 10 working days from the end of each reporting month, with the first Monthly EM&A Report due in the month after the construction works commence. Copies of each Monthly EM&A Report should be submitted to the Contractor, ER, IEC and EPD. Before submission of the first Monthly EM&A Report, the ET Leader should liaise with the relevant parties on the exact number of copies and format of the reports in both hard and electronic copies.

9.3.2 The ET should review the number and location of the monitoring stations and parameters every six months, or on an 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

9.3.3 The first Monthly EM&A Report should include at least but not limited to the following information:

· Executive summary (1-2 pages):

- Breaches of the Action and Limit levels;

- Complaint log;

- Notification of any summons and status of prosecutions;

- Reporting changes; and

- Future key issues.

· 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 reporting month.

· Environmental status:

- Advice on the status of the statutory environmental compliance, e.g. EP conditions under the EIAO, submission status under the EP and implementation status of mitigation measures etc.;

- Works undertaken during the reporting month with illustrations (e.g. location of works etc.); and

- Drawings showing the Project Area, environmental sensitive receivers and locations of the monitoring and control stations.

· A brief summary of EM&A requirements including:

- All monitoring parameters;

- Environmental quality performance limits (Action and Limit levels);

- Event and Action Plans;

- Environmental mitigation measures, as recommended in the EIA Report; and

- Environmental requirements in contract documents.

· Implementation status:

- Advice on the implementation status of environmental protection and pollution control/ mitigation measures, as recommended in the EIA Report, summarised in the updated implementation schedule.

· 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;

- Monitoring parameters;

- Monitoring locations;

- Weather conditions during the period;

- Monitoring date, time, frequency and duration;

- Graphical plots of the monitoring parameters in the reporting month annotated against the following information:

(i) Major activities being carried out on site during the reporting period;

(ii) Weather conditions that may affect the monitoring results;

(iii) Any other factors which might affect the monitoring results; and

- QA/QC results and detection limits.

· Reporting non-compliance, complaints, notifications of summons and status of prosecutions:

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

- Records of all complaints received (written or verbal), including locations and nature of complaints investigation, liaison and consultation undertaken, actions and follow-up procedures taken, results and summary;

- Records of all notifications 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;

- The review of the reasons for the implications of non-compliance, complaint, 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 the earlier non-compliance.

· 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;

- A forecast of the works programme, impact predictions and monitoring schedule for the next three months;

- Record of any project changes from the original proposed as described in the EIA (e.g. construction methods, mitigation proposals, design changes etc); and

- Comments (e.g. the effectiveness and efficiency of mitigation measures), recommendations (e.g. any improvement in the EM&A programme) and conclusions.

Subsequent Monthly EM&A Reports

9.3.4 The subsequent Monthly EM&A Reports during the construction phase should include the following information:

· Executive summary (1-2 pages):

- Breaches of the Action and Limit levels;

- Complaint log;

- Notifications of any summons and status of prosecutions;

- Reporting changes; and

- Future key issues.

· Basic project information:

- Project organisation including personnel contact names and telephone numbers;

- Construction programme;

- Management structure;

- Works undertaken during reporting month; and

- Any updates as needed to the scope of works and construction methodologies.

· Environmental status:

- Advice on the status of statutory environmental compliance, status of compliance with EP conditions under the EIAO, submission status under the EP and implementation status of mitigation measures;

- Works undertaken during the reporting month with illustrations (such as location of works, etc.); and

- Drawings showing the Project Area, environmental sensitive receivers and locations of the monitoring and control stations.

· Implementation status:

- Advice on the implementation status of environmental protection and pollution control / mitigation measures, as recommended in the EIA Report.

· 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;

- Monitoring parameters;

- Monitoring locations;

- Weather conditions during the period;

- Monitoring date, time, frequency and duration;

- Graphic plots of the monitoring parameter in the month annotated against the following information;

(i) Major activities being carried out on site during the reporting period;

(ii) Weather conditions that may affect the monitoring results;

(iii) Any other factors which might affect the monitoring results; and

- QA/QC results and detection limits.

· The report on non-compliances, complaints, notifications of summons and status of prosecutions:

- Records of all non-compliance (exceedances) of the environmental quality performance limits (action and Limit levels);

- Records of all complaints received (written or verbal), including the locations and nature of complaints investigation, liaison and consultation undertaken, actions and follow-up procedures taken, results and summary;

- The review of the reasons for and implications of non-compliances, complaints, summons and prosecutions including review of pollution sources and working procedures; and

- Descriptions of the actions taken in the event of non-compliance and deficiency reporting and any follow-up procedures related to the earlier non-compliances.

· Others:

- An account of the future key issues as reviews from the works programme and method statements of works;

- Advice on the solid and liquid waste management status;

- A forecast of the works programme, impact predictions and monitoring schedule for the next three months;

- Comparisons of the EM&A data in the reporting month with the EIA predictions and annotate with explanation for any discrepancies; and

- Comments (e.g. the effectiveness and efficiency of the mitigation measures), recommendations (e.g. any improvement in the EM&A programme) and conclusions.

· Appendices:

- Action and Limit levels;

- Graphical plots of trends of the monitored parameters at key stations over the past four reporting periods for the representative monitoring stations annotated against the following information:

(i) Major activities being carried out on site during the reporting period;

(ii) Weather conditions during the reporting period;

(iii) Any other factors that might affect the monitoring results;

(iv) Monitoring schedule for the present and next reporting period;

(v) Cumulative statistics on complaints, notifications of summons and successful prosecutions; and

(vi) Outstanding issues and deficiencies.

Final EM&A Review Report

9.3.5 The EM&A programme for construction phase should be terminated upon the completion of the construction activities that have the potential to cause significant environmental impacts, while the EM&A Programme for operation phase could be terminated upon the completion of operation phase monitoring (i.e. 12-month establishment period).

9.3.6 The proposed termination should only be implemented after the proposal has been endorsed by the IEC, the ER and the Project Proponent followed by the approval from the Director of Environmental Protection.

9.3.7 The ET Leader should prepare and submit the Final EM&A Review Report after the completion of the construction activities that have the potential to cause significant environmental impacts. The Final EM&A Review Report should contain at least the following information:

· Executive summary (1-2 pages);

· Drawings showing the Project Area, environmental sensitive receivers and locations of the monitoring and control stations;

· The basic project information including a synopsis of the project organisation, contacts of key management, and a synopsis of works undertaken during the course of the Project or past 12 months;

· A brief summary of EM&A requirements including:

- Environmental mitigation measures implemented as recommended in the EIA Report;

- Environmental impact hypotheses tested;

- Environmental quality performance limits (Action and Limit levels);

- All monitoring parameters; and

- Event and Action Plans.

· A summary of the implementation status of environmental protection and pollution control/ mitigation measures for construction phase, as recommended in the EIA Report, summarised in the updated environmental mitigation implementation schedule;

· Graphical plots and statistical analysis of the trends of the monitored parameters over the course of the Project, including the post-project monitoring for all monitoring stations annotated against:

- Major activities being carried out on site during the reporting period;

- Weather conditions during the reporting period; and

- Any other factors which might affect the monitoring results.

· A summary of non-compliance (exceedances) of the environmental quality performance limits (Action and Limit levels);

· A review of the reasons for and implications of non-compliance including the review of pollution sources and working procedures as appropriate;

· A description of the action taken in the event of non-compliance;

· A summary record of all complaints received (written or verbal), liaison and consultation undertaken, action and follow-up procedures taken and results;

· A summary record of the notifications of summons and successful prosecutions for breaches of the current environmental protection/pollution control legislation, locations and nature of the breaches, follow-up investigation taken and results;

· A review of the validity of EIA predictions for construction phase and identification of shortcomings in the recommendations of the EIA study;

· Comments (e.g. a review of the effectiveness and efficiency of the mitigation measures and of the performance of the environmental management system, i.e., of the overall EM&A programme); and

· Recommendations and conclusions (e.g. a review of the success of the overall EM&A programme to cost-effectively identify deterioration and to initiate prompt effective mitigation action when necessary).

9.4 Data Keeping

9.4.1 No site-based documents (e.g. the monitoring field records, laboratory analysis records, site inspection form, etc.) are required to be included in the EM&A reporting documents. However, any such documents should be properly maintained by the ET and be ready for inspection upon request. All relevant information should be clearly and systematically recorded in the document. Monitoring data should also be recorded in magnetic media form, and the electronic copy must be available upon request. All documents and data should be kept for at least one year following the completion of the construction contract.

9.5 Interim Notification of Environmental Exceedance

9.5.1 With reference to the Event and Action Plans, when the environmental quality performance limits are exceeded, the ET should immediately notify the Contractor, ER, IEC and EPD, as appropriate. The notification should be followed up with advice to the IEC and 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 notification is presented in Appendix 9.1 of this Manual.

Figure 1.1	Site Location Plan
Figure 3.1	Locations of Designated Noise Monitoring Stations

Appendix 1.1	Tentative Programme of the Project
Appendix 1.2	Environmental Mitigation Implementation Schedule (EMIS)
Appendix 3.1	Sample Data Record Sheet for Noise Monitoring
Appendix 8.1	Flow Chart of Complaint Response Procedures
Appendix 9.1	Interim Interim Report Log on Non-compliance of Action/ Limit Level

1 Introduction

1.2 Project Scope and Location

1.4 Purpose of EM&A Manual

1.5 Project Organization

Background

Engineer or Engineer’s Representative (ER)

The Contractor

Environmental Team (ET)

Independent Environmental Checker (IEC)

1.6 Structure of EM&A Manual

2.2 Mitigation Measures

2.3 Audit Requirements

3.2 Construction Phase Monitoring

Noise Parameters

Monitoring Equipment

Monitoring Locations

Baseline Monitoring

Impact Monitoring

Event and Action Plan

Construction Phase

Operation Phase

Fixed Plant Noise – MVAC equipment and other fixed noise sources

4 Water Quality and sewerage

Construction Phase

Operation Phase

5 Waste Management Implications

5.2 Mitigation Measures

Construction Phase

Operation Phase

5.3 Audit Requirements

6 cultural heritage impact

6.2 Recommendations

7.5 Event and Action Plan

9.2 Baseline Monitoring Report

First Monthly EM&A Report

Subsequent Monthly EM&A Reports

Final EM&A Review Report