The construction works for the Permanent Aviation Fuel Facility resumed on 9^th July 2007. This sixteenth monthly Environmental Monitoring and Audit (EM&A) report presents the EM&A works carried out during the period from 1^st February to 29^th February 2008 in accordance with the EM&A Manual.

Breaches of all Action and Limit Levels

Daily exceedance of Action Levels of Turbidity was found between 1^st to 20^th February 2008 (with the exception of 11^th February 2008) prior to the introduction of the amended Action Level in accordance with the revised Final Baseline Monitoring Report for water quality. Following this amendment, no exceedances of Depth-averaged Turbidity were recorded for the remainder of the monitoring month. Occasional exceedances of Action Limit Levels of Suspended Solids were found on 10, 12, 13 and 24 February 2008. Following review of data in accordance with the procedures specified in the EM&A Manual, these exceedances were considered due to natural fluctuation from the Pearl River discharge rather than the Project Works.

Complaint Log

No environmental complaints were received during the reporting period.

Notifications of any Summons and Successful Prosecutions

No environmental summon or prosecutions were received in this reporting period.

Reporting Changes

There were no reporting changes in the reporting period.

Future Key Issues

· Dust release and suppression;

· Dredging activities; and,

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

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.

The decision by the EPD to grant the above Environmental Permit was, however, 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 EP-262/2007/A and issued by the EPD on 30 November 2007.

It should be noted that at the time of reporting, a further Variation to the Environmental Permit has been approved, primarily to allow for dredging works to continue during March 2008. As such, EP-262/2007/A has been amended to EP-262/2007/B and issued by the EPD on 27 February 2008.

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 sixteenth EM&A Report which summarizes the monitoring results and audit findings for the EM&A programme during the reporting period from 1^st February to 29^th February 2008.

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 2.2 presented the cumulative quantity of excavated materials up to 29^th February 2008. The cumulative dredging volume during the reporting period was presented in Figure 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

Table 2.2 Cumulative Quantity of Excavated Materials up to 29^th February 2008

Type of Excavated Materials	Cumulative Bulk Volume (m³)
Contaminated Mud	63,292
Uncontaminated Mud	89,543

2.4 Monitoring Schedule of The Reporting Month

Daily water quality monitoring during dredging activities commenced on 17 December 2007. A marine archaeological Watching Brief of two sub-surface anomalies was also implemented from 21^st to 28^th February 2008 during the dredging of the surrounding seabed located within the route of the twin pipelines from the PAFF tank farm at Tuen Mun Area 38 to Sha Chau. The monitoring schedule for February and March 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 2.3.

Table 2.3 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 the 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, there was no meeting or site visit organised by the CLG.

The details of the 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

Water quality monitoring during dredging activities recorded exceedance of Action Levels of Depth-averaged Turbidity with exception of 11^th February 2008. There was exceedance of the Action Levels of Depth-averaged Suspended Solids (SS) on the 10, 12, 13 and 24 February 2008. A description of the actions taken following these non-compliances is discussed in Section 3.2.

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, 15, 22 and 29 February 2008. 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

· During the site inspection on 5 February 2008, oil stains were spotted on seawater around the Grab Dredger (DG4503). The contractor was recommended to clean up the oil stains and investigate the cause of incidence to avoid further leakages.

· 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 22 February 2008, piles of general wastes from construction works inside the oil tanks were spotted on roadsides without proper containers. The Contractor was recommended to arrange a suitable waste bin for temporary collection of wastes in accordance to the waste management plan developed from the approved EIA.

· During the site visit on 1 February 2008, chemical storage barrels on dredger GD4503 were not stored properly. The Contractor was recommended to ensure proper chemical management in accordance with the procedures presented in the EIA.

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, with exception of 11^th February 2008. There was exceedance of the Action Levels of Depth-averaged Suspended Solids (SS) on the 10, 12, 13 and 24 February 2008. Details of exceedance were presented in the monitoring results Annex G. Descriptions of the actions taken following identification of 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 2007 and 4, 5 January 2008 (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.

During impact monitoring on both ebb and flood tides, turbidity and SS levels at all stations are generally comparable with those levels recorded during the baseline monitoring. 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.

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.

3.2.1 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 (ET) and the Independent Environmental Checker (IEC) resulted in an amendment made to the Action Level for the monitoring of Turbidity for the Project, such that the Action Level of Turbidity be amended to follow the same principle as that currently applied to DO and SS. This amendment was introduced on 1^st March 2008, following the submission of the revised Final Baseline Monitoring Report for water quality to the EPD on 20 February 2008 and later under the EIAO register on 29 February 2008. As such, the compliance of depth-averaged Turbidity from that date onwards has been checked against the revised Action Levels.

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 10, 12, 13 and 24 February 2008. Turbidity levels were, however, above Action Levels on a daily basis (except on 11 and 17 February 2008) 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).

4.3 POPs Monitoring

Biweekly monitoring of water samples was conducted for POPs analysis. At the time of this report, results were available for 23 January and 6 February 2008. All POPs parameters (ie total PCBs, total DDTs and total PAHs) were below detection limits. Monitoring results and QA/QC reports for POPs testing are presented in Annex H.

The remaining results of February’s monitoring will be presented in the next Monthly Monitoring Report once they become available.

4.4 Waste Management

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

4.5 Cultural Heritage

In accordance with the EM&A Manual, a marine archaeological Watching Brief of two sub-surface anomalies was implemented from 21^st to 28^th February 2008 during the dredging of the surrounding seabed located within the route of the twin pipelines from the PAFF tank farm at Tuen Mun Area 38 to Sha Chau.

The watching process consisted of monitoring the dredging of sediments to the recorded sub-surface depths of the anomalies, followed by a diver inspection of the uncovered seabed within the trench.

Material found in the location of the two anomalies consisted of urban waste, trash and recently quarried granite and feldspar rocks. No archaeological sites or relics were found and it is considered by the licensed Marine Archaeologist that the anomalies have no cultural heritage significance. No additional mitigation measures were thus required to be implemented by the PAFF project in regard to the anomalies SS1 and SS2.

The details and findings of this watching process will be presented in the Watching Brief Report and submitted separately to EPD and AMO for review.

4.6 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.

4.7 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.

4.8 Ecology

Dolphin Visual Monitoring

In accordance with EM&A Manual, dolphin monitoring has been undertaken during dredging activities since 17 December 2007. During the reporting period, a total of eleven dolphin sightings were recorded. Appropriate action was taken in accordance with the EM&A Manual. The sighting locations and field records are presented in Annex I.

4.9 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. Comments were received from the EPD on 22 January 2008. The ET will update the EM&A Manual accordingly within the next reporting period.

4.10 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 was submitted to the EPD on 20^th February 2008 with no further comments received and later placed under the EIAO register.

5 Future Key Issues

5.1 Key Issues for the Next One Month

As noted in Section 1, the VEP-262/2007/A has allowed for dredging to continue through the next reporting period, ie March 2008. As such, 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 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.

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 and dolphin monitoring will be undertaken in accordance with the EM&A Manual.