1 Introduction

Leighton Contractors (Asia) Limited (LCAL) has appointed ERM-Hong Kong, Limited (ERM) as the Environmental Team (ET) to implement the Environmental Monitoring and Audit (EM&A) programme for the Permanent Aviation Fuel Facility (the Project) during construction works.

The construction works for PAFF commenced in November 2005 based upon the previous EIA (EIAO Register Number AEIAR-062-2002) conducted and the Environmental Permit EP-139/2002 granted on the 28^th August 2002. Due to minor changes to the detailed layout of the site and the site boundary, application for Variation to the Environmental Permit (VEP) (VEP-133/2004) was submitted to the Director of Environmental Protection (DEP) for approval. The variation to the EP (EP-139/2002/A) was granted by the EPD in February 2004.

However, the decision by the EPD to grant the above Environmental Permit was subject to a Judicial Review. The Judicial Review sided in the favour of the DEP, as did the subsequent Judgement from the Court of Appeal from the High Court for Judicial Review in March 2005. However, the DEP’s decision to grant the EP was quashed by the Judgement of the Court of Final Appeal of July 2006.

The construction works were stopped following the Judgement of the Court of Final Appeal of July 2006. As such, in order to continue with the construction of the project, the project went through the statutory procedures under the EIAO again with a new design in order to obtain an environmental permit. The revised EIA was submitted in 2007 and the environmental permit (EP-262/2007) was granted in May 2007. EP-262/2007 has been amended to EP262/2007/A and issued by the EPD on 30 November 2007.

The construction works and EM&A requirements were resumed on 9^th July 2007 following the latest requirements of the EP-262/2007 and EM&A Manual. Details regarding the EM&A requirements and changes should refer to the updated EM&A Manual. For the marine works, all piling activities were completed before the previous suspension of construction works in 2006.

1.1 Purpose of the Report

This is the fourteenth EM&A Report which summarizes the monitoring results and audit findings for the EM&A programme during the reporting period from 1^st December to 31^st December 2007.

2 Environmental Status

2.1 Project Area

The project area is in Area 38 of Tuen Mun and the pipelines are located in Urmston Road between Tuen Mun Area 38 and Sha Chau. The site is illustrated in Annex A.

2.2 Environmental Sensitive Receivers

No air and noise sensitive receivers were identified close to the project area. However, water sensitive receivers and ecological sensitive receivers were identified in the EIA study, and are shown in Annex B.

2.3 Major Construction Activities

A summary of the major works undertaken in this reporting period is shown in Table 2.1.

Table 2.1 Summary of Works Undertaken During the Reporting Period

Area	Works undertaken
Tuen Mun Area 38	Tank Farm and Bund Wall Construction Permanent Drainage Construction Operational & Fire Services Buildings Construction Jetty Works (Non-piling)
Submarine Pipeline Route	Dredging Operations

Area

Works undertaken

Tuen Mun Area 38

Tank Farm and Bund Wall Construction

Permanent Drainage Construction

Operational & Fire Services Buildings Construction

Jetty Works (Non-piling)

Submarine Pipeline Route

Dredging Operations

2.4 Monitoring Schedule of The Reporting Month

Daily water quality monitoring during dredging activities commenced on 17 December 2007. The monitoring schedule for December 2007 and January 2008 is presented in Annex C.

2.5 Status of Environmental Approval Documents

A summary of the relevant permits, licences, and/or notifications on environmental protection for this Project since July 2007 is presented in Table 2.2.

Table 2.2 Summary of Environmental Licensing, Notification and Permit Status

Permit/ Licenses/ Notification	Reference	Validity Period	Remarks
Environmental Permit	EP-262/2007/A	Throughout Project	Issued on 30 November 2007 (EP-262/2007 issued on 31 May 2007, EP-139/2002 originally granted on 28 August 2002 and EP-139/2002/A granted on 24 February 2004 were superseded)
	EP-262/2007/A	Throughout Project

Chemical Waste Producer Registration	WPN 5111-421-L2174-25	Throughout Project	Issued on 10 November 2005
Notification of Construction Works under Air Pollution Control (Construction Dust) Regulation	H2104/U1D/5542/DG/DH/PL	Throughout Project	Notification on 6 July 2007
Construction Noise Permit	GW-RW0676-07	21 December 2007 to 19 June 2008	For land-based works including air compressors, breakers, excavators, wheeled loaders, mobile cranes, concrete lorry mixers, hand-held pokers, bar benders/cutters, wood saws, grinders, submarine water pump, lorries with crane, dump trucks, rollers, ventilation fans and generators
	GW-RW0677-07	21 December 2007 to 29 February 2008	For marine dredging operation including grab dredger, tug boat, split hopper barge and motor sampan
	GW-RW0678-07	21 December 2007 to 18 June 2008	For marine jetty works including concrete pump derrick barges, hand-held grinders, generators, air compressors, boring machines, water pumps, tug boat, grout mixers and grout pumps
Marine Dumping Permit	EP/MD/08-064	13 December 2007 to 29 February 2008	For Type 1 marine disposal
	EP/MD/08-065	13 December 2007 to 12 January 2008	For Type 1d & Type 2 marine disposal
	EP/MD/08-071	13 January 2008 to 12 February 2008	For Type 1d & Type 2 marine disposal
Wastewater Discharge License	EP760/421/011399/l	15 March 2006 to 31 March 2011	Issued on 15 March 2006

2.6 Community Liaison Group Meeting

According to the EP requirements, a Community Liaison Group (CLG) shall be established within three months after commencement of construction of the Project. The major duty of CLG is to advise on and monitor the proper design, construction and operation of the Project. The CLG comprises representatives from Airport Authority, members of Tuen Mun community and academics. During the reporting month, the CLG held a meeting cum site visit on 7 December 2007.

The details of PAFF CLG (including Membership and its Terms of Reference) and the meeting minutes can be found on the Project website (http://www.paffhk.com).

2.7 Summary of Non-Compliance With The Environmental Quality Performance Limits

2.8 Summary of Environmental Complaints

No environmental complaints were received during the reporting period. A summary of environmental complaints since project commencement is presented in Annex D.

2.9 Summary of Environmental Summons

No summons were received in this reporting period. A summary of legal proceeding since project commencement is presented in Annex D.

3 Environmental Issues and Actions

3.1 Previous Environmental Deficiencies and Follow-up Actions

As no environmental complaint was received over the last reporting period, no follow-up action was required.

Weekly site inspections were carried out by the ET on 5, 13, 17, and 28 December 2007. Overall, the site was in good orderly manner and no non-compliance was found. Environmental deficiencies and follow-up actions/mitigation measures were identified during the inspections, as follows:

Air Quality

· Water tankers were used regularly to wet the road surface to minimize dust emission.

· Site entrance was paved and wheel-washing facility was provided to avoid dust deposit on the public road.

· Main access road within the site (between site office and exit) was paved to avoid dust emission. Other sections of the major access road in the construction area were paved with stones.

Noise

· No noisy activities were conducted during the audit.

· All air compressors on site were operated with a valid noise label.

Water Quality

· Site toilets were provided on site. A soil soakaway system with holding tanks was installed to treat the sewage from the toilets. No effluent discharge out of the site was made.

· The site canteen is no longer in operation and hence no waste water is generated.

Waste Management

· During the site inspection on 28 December 2007, water ponding was found near site entrance. The Contractor was recommended to clear the ponding.

· During the site inspection on 17 and 28 December 2007, stockpiles of excavated materials were found near the site entrance. The Contractor was recommended to cover excavated materials with tarpaulin to avoid fugitive dust generation.

Landscape and Visual

· The transplanted trees at the new site were in good and healthy condition; and,

· The berm was habilitated by vegetation.

Overall, the site was in a good orderly manner. The ET will keep track on the EM&A programme to ensure compliance of environmental requirements and the proper implementation of all necessary mitigation measures.

3.2 Description of Actions Taken in Event of Non-Compliance and Deficiency Reporting

Water quality monitoring during dredging activities recorded daily exceedance of Action Levels of Depth-averaged Turbidity. There was exceedance of the Action Levels of Depth-averaged Suspended Solids (SS) on the 21, 24, 25, 27, 29 and 30 December, and exceedance of the SS Limit Levels on the 27, 29 and 30 December. There was both mid-ebb and mid-flood exceedance for SS on the 24, 25 and 30 of December. Details of exceedance were presented in the monitoring results Annex G. A description of the actions taken followng identification of a non-compliance are discussed in Section 3.

Although dredging operations were undertaken during the reporting period, the exceedances were unlikely to be caused by the Project and were considered to be an isolated case due to the following reasons:

· Exceedance of Action Level of depth-averaged Turbidity was found on 17, 21, 22, 31 December (when no dredging was undertaken), whose values were comparable to those of days with dredging operations

· Depth-averaged DO, bottom DO and depth-averaged SS did not show the same trend of exceedance

As per the requirements of the EM&A Manual, incidents were notified to the Franchisee’s Site Representative, the Contractor and the Independent Environmental Checker upon identification of an exceedance.

The temporal and spatial trend of the results collected during the impact monitoring have been plotted against those collected during the baseline monitoring and are discussed below. Results are illustrated in Figure G3 in Annex G.

Ebb Tide

During impact monitoring on the ebb tide, turbidity and SS levels at all stations, with the exception of Impact Station MP, are generally comparable with those levels recorded during the baseline monitoring. It is noted that there appears to be an increasing trend in both turbidity and SS levels at Station MP between 22 and 30 December (maximum of 40.2 NTU and 37.2 mg/L respectively), however, as this station was located over 1.5 km upstream from the dredging operation, it is considered unlikely that these levels are attributable to Project works. It is more likely that the waters upstream of the works site are influenced by other factors, such as natural fluctuations of turbidity and SS observed in the Pearl River Estuary.

Flood Tide

During impact monitoring on the flood tide, both turbidity and SS levels at all stations, are generally comparable with those recorded during the baseline monitoring. An exception was noted for 27 December where maximum levels were higher than those recorded during other monitoring events. As levels returned to levels comparable with other monitoring events the following day, such fluctuations are not considered to be of a concern.

It is also important to note that the construction works were not carried out continuously over the weeks during the impact monitoring period. On some occasions, there were no marine works undertaken on site during the monitoring period.

Whilst it is noted that there were no apparent spatial trends in the monitoring data, there does appear to be an overall temporal increase in concentrations of monitoring parameters. As this increase is noted to be generally consistent over all monitoring stations, it is considered that this change is likely to be reflective of natural conditions. Nevertheless, such patterns will be examined over the remaining monitoring period to verify whether the trend continues.

3.2.2 Follow-up Action following Non-Compliance

In accordance with the required procedures specified in the EM&A Manual to be taken following the trigger of an Action Level, discussions between the Environmental Team and the Independent Environmental Checker (IEC) have resulted in a recommendation of an amendment to be made to the Action Level for the monitoring of Turbidity for the Project.

3.2.3 Recommendation following Non-Compliance

It is noted that for Dissolved Oxygen (DO) and Suspended Solids (SS) a set Action and Limit Levels have been established taking into consideration both the baseline data as well as the Environmental Protection Departments (EPD) routine water quality monitoring data collected between 1998 and 2006. This value thus takes into account historical fluctuations in ambient conditions and thereby could be considered to be more representative of natural change. Presently, monitoring for Turbidity does not take into account natural spatial and temporal patterns, but is rather restricted to Action Levels that are determined by the water quality data collected at upstream control station on the day of monitoring. It is therefore recommended that the Action Level of Turbidity be amended to follow the same principle as that currently applied to DO and SS.

Steps to potentially amend the Action Level of Turbidity are currently in discussion with the IEC and the EPD and will be presented in the revised Baseline Water Quality Monitoring Report. The progress of these recommendations will be document in the next Monthly Monitoring Report.

3.3 Implementation Status on Environmental Protection Requirements

The implementation status of environmental mitigation measures and requirements as stated in the EIA Report, Environmental Permits and EM&A Manual during the reporting period is summarized in Annex E.

4 Environmental Monitoring

4.1 Air and Noise

Air and Noise monitoring is not required for the project.

4.2 Water Quality

In accordance to the EM&A Manual, during dredging activities, water quality monitoring commenced on 17 December 2007. QA/QC reports for Suspended Solids testing are presented in Annex F. Monitoring data and graphical presentations of the results are included in Annex G.

Results of the monitoring demonstrated that all measured dissolved oxygen levels of all Impact Stations were compliant with the Action and Limit (AL) Levels specified in the EM&A Manual. Concentrations of Suspended Solids (SS) were generally below AL Levels, however, exceedances were noted for 21, 24, 25, 27, 29, 30 December 2007. Turbidity levels were, however, above Action Levels on a daily basis during the reporting month. A review of the above exceedances concluded that these were not attributable to Project works and were likely due to natural variation (see Section 3.2 for further details).

At the time of this report, laboratory analysis of POPs was still in progress. Results of POPs monitoring will be presented in the next Monthly Monitoring Report once they become available.

4.2.1 Waste Management

The Contractor’s revised Waste Management Plan (Revision 4) (WMP) was submitted to the EPD on 20^th September 2007.

4.2.2 Cultural Heritage

Since dredging activity has not reached the sediment removal of 3km (for SS) and 2km (SS2) level during the reporting period, marine archaeological monitoring was not required.

4.2.3 Landscape and Visual

According to the EIA report and EM&A Manual, mitigation measures and site inspection are required during the landscaping/planting works. The berm/landscaping bund was habilitated by vegetation which was grown during the project suspension period. The transplanted trees were in good and healthy condition.

The weekly site inspections included audits on landscape and visual issues to ensure that the site was in orderly acceptable manner.

4.2.4 Land Contamination, Hazard to Life and Fuel Spill Risk

According to the EIA report and EM&A Manual, mitigation measures and design phase audit are required to minimise the risk of fuel spill and hazards. The Contractor will submit the updated design audit plan according to the EP requirements.

Pursuant to Condition 3.5 of the EP, the Contractor submitted three design drawings which address the specific sub-clauses on Condition 3.5a of the EP concerning the containment systems of aviation fuel storage tank farm. The ET and the IEC have provided certification and verification to the drawings respectively and the drawings were submitted to the EPD on 7 November 2007.

Weekly site inspection covered the waste management aspects which included measures to prevent land contamination by chemical wastes.

4.2.5 Ecology

Dolphin Visual Monitoring

In accordance to EM&A Manual, dolphin monitoring has been undertaken during dredging activities since 17 December 2007.

During the reporting period, two dolphin sightings were recorded outside the exclusion zone on 25 December and 28 December, with only one dolphin sighting recorded within the exclusion zone on 21 December. Appropriate action was taken in accordance with the EM&A Manual. The sighting results were presented in Table 4.1.

Table 4.1 Dolphin Sighting Records during the Reporting Period

Date	Time	Sighting Distance from Dredger (m)	Group Size	Beaufort	Boat Association	Observer’s Name
21/12/2007	14:55	90	3	1	None	Richard Huang
25/12/2007	14:00	600	3	1	None	Richard Huang
28/12/2007	09:28	620	1	1	Shrimp trawler	Anton Tsang

4.2.6 EM&A Manual

The EM&A Manual for the Project has been updated by the ET to include the detailed arrangements of setting up a Community Liaison Group, carrying out design audit, and monitoring of Persistent Organic Pollutants during construction of the Project. The updated EM&A Manual was revised accordingly to the comments received from the EPD on 6^th December 2007 and was submitted to the EPD on 10^th December 2007. The ET will keep track on comments received from the EPD, if any, and update the EM&A Manual accordingly.

4.2.7 Baseline Water Quality Monitoring

Baseline water quality monitoring was conducted between 24 October and 30 October 2007 at six designated monitoring stations (three impact stations and three control stations) established for the Project in accordance with the EM&A Manual. The Final Baseline Monitoring Report was submitted to the EPD on 21 November and comments were received from the EPD on 6^th December. A revised Final Baseline Monitoring Report will be submitted to the EPD within the next reporting period.

5 Future Key Issues

5.1 Key Issues for the Next One Month

Key issues to be considered in the next one month will include:

· Dust release and suppression;

· Operation of dredging activities; and

· Water quality monitoring and dolphin monitoring during the dredging activities.

5.2 Impact Prediction for the Next One Month

Provided that environmental mitigation measures including good on-site practises are properly implemented, it is not expected that unacceptable adverse impacts will arise.

Based on the water quality monitoring results recorded to date, it may be expected that further exceedances in Turbidity and possibly Suspended Solids may be recorded. However, as with those recorded so far, it is not expected that such exceedances would be attributable to Project Works. It is noted that actions are underway to potentially revised the Action Limit Levels for Turbidity and progress on these revisions will be summarised in the next Monthly Monitoring Report.

5.3 Works and Monitoring Schedule for the Next One Month

Work programme for the next one month includes jetty platform works (non-piling), site works (construction works for tank farm, operational and fire services buildings, drainages, bund wall, security wall etc) and dredging operation. Weekly site inspections will be undertaken. Water quality, dolphin monitoring and marine archaeological monitoring will be undertaken in accordance with the EM&A Manual.