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. A further Variation to the Environmental Permit has been approved to allow dredging works to continue until 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/B 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 twenty-third EM&A Report which summarizes the monitoring results and audit findings for the EM&A programme during the reporting period from 1 September to 30 September 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. Dredging operation has been suspended from 1 April to 31 August 2008 and was resumed on 1 September 2008. Table 2.2 presented the cumulative quantity of excavated materials up to 30 September 2008. Daily and cumulative dredging production rates are illustrated in Figure 2.1.

Table 2.1 Summary of Works Undertaken During the Reporting Period

Area	Works undertaken
Tuen Mun Area 38	Tank Farm, Roof Truss 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, Roof Truss 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 Marine Sediments up to 30 September 2008

Type of Excavated Materials	Cumulative Bulk Volume (m³)
*From 17 December 2007 to 31 March 2008*
Contaminated Mud	105,974
Uncontaminated Mud	97,815

*From 1 September to 31 September 2008*
Contaminated Mud	3,107
Uncontaminated Mud	0

2.4 Monitoring Schedule of The Reporting Month

Daily water quality monitoring (except public holidays and weekends) during dredging activities recommenced on 1 September 2008. The monitoring schedule for September 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/B	Throughout Project	Issued on 27 February 2008 (EP-262/2007/A 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/B	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
	GW-RW0094-08	1 March to 31 March 2008	For marine dredging operation including grab dredger, tug boat, split hopper barge and motor sampan
	GW-RW0312-08	04 July 2008 to 22 December 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
	GW-RW0313-08	04 July 2008 to 19 December 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-RW0373-08	1 August 2008 to 20 January 2009	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, generators, stirrer, jet chisel, water jet machine and dehumidifier
	GW-RW0368-08	1 September to 30 November 2008	For marine dredging operation including grab dredger, tug boat, split hopper barge and motor sampan
Marine Dumping Permit	EP/MD/08-064	13 December 2007 to 29 February 2008	For Type 1 – Open Sea 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
	EP/MD/08-090	3 March to 31 March 2008	For Type 1d & Type 2 marine disposal
	EP/MD/08-091	3 March to 31 March 2008	For Type 1 – Open Sea Disposal
	EP/MD/09-018	1 September to 30 September 2008	For Type 1d & Type 2 marine disposal
	EP/MD/09-032	1 October to 31 October 2008	For Type 1d & Type 2 marine disposal
	EP/MD/09-017	1 September to 30 November 2008	For Type 1 – Open Sea 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, a meeting was organised by the CLG on 10 September 2008.

The details of the CLG (including Membership and its Terms of Reference) 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 the Action Limit Levels for Depth-averaged Dissolved Oxygen (DO) on 4, 8, 9, 10, 11 and 12 September 2008. There were exceedances of the Action Limit Levels for Bottom DO on 9, 10, 11 and 12 September 2008. Exceedance of the Action Level of Suspended Solids was found on 4 and 18 September 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 was 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, 12, 18, and 26 September 2008. Overall, the site was in good orderly manner and no non-compliances were 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 that generated excessive noise were observed during the audit.

· All air compressors inspected 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 observed during the audits.

· During the site inspections on stagnant water ponds were observed inside the operation building and near the chemical waste storage at the surcharge area (5 September 2008), in the chemical waste storage near the operation building (12 and 18 September 2008) and in a trough near the pump platform (18 September 2008). The Contractor was recommended to clear stagnant water as soon as possible.

· During the site inspection on 5 September 2008, silt curtains were not properly installed in the dredging area. Sediment plumes were observed beyond the silt curtains in the dredging area. The Contactor was recommended to ensure silt curtains were properly installed prior to all dredging activities.

· During the site inspections on 12 September 2008, oil sheens were observed on the sea surface near the operation building. The Contractor was recommended to arrange clearance of oil sheens as soon as possible.

· During the site inspections on 18 September 2008, reddish sediment plumes were observed in the water at the discharge outlet near the operation building. Reddish water puddles were observed on the access road in the tank farm area on the same day. The Contractor was recommended to check the efficiency of sedimentation facilities and to review the effluent discharge arrangements in the tank farm area.

· During the site inspection on 26 September 2008, sediment plumes were observed on the rear end of the hopper barge. The Contractor was recommended to stop dredging operations immediately, to investigate the cause of sediment plumes and to implement appropriate mitigation measures.

Waste Management

· During the site inspection on 5 September 2008, chemical wastes were stored on the deck of the hopper barge without spillage preventive measures and labels. On 12 September 2008, a diesel engine was put on the deck without spillage preventive measures. On 26 September 2008, drums of chemical wastes were placed on the deck of the dredging barge without spillage preventive measures. The Contractor was recommended to store diesel-operated machineries and chemical wastes in bunded areas to avoid potential spillages.

· During the site inspection on 5 September 2008, the construction waste skip in the tank farms area was observed to be full. The Contractor was recommended to arrange waste clearance as soon as possible.

· During the site inspection on 5 and 12 September 2008, drums of oil products behind the workshop were placed on ground without drip trays. The Contractor was recommended to provide drip trays for temporary storage of oil products to avoid potential spillages.

· During the site inspection on 12 September 2008, it was observed that wastes were piled up on ground next to the operation building. The Contractor was recommended to replace refuse bin for temporary storage of general refuse as soon as possible.

· During the site inspection on 26 September 2008, oil was observed on the floor near the diesel storage tank behind the workshop and near the sedimentation tank in the tank farms area. The Contractor was recommended to clear spillages as soon as possible.

Landscape and Visual

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

· The berm was habilitated by vegetation.

With the exception of the above observations, 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 exceedance of the Action Limit Levels for Depth-averaged Dissolved Oxygen (DO) on 4, 8, 9, 10, 11 and 12 September 2008. There were exceedances of the Action Limit Levels for Bottom DO on 9, 10, 11 and 12 September 2008. Exceedance of the Action Level of Suspended Solids was found on 4 and 18 September 2008. Details of exceedance were presented in the monitoring results as Annex G.

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 the Action Limit Levels for depth-averaged DO was found on 8 September (when no dredging was undertaken). These values were comparable to those of days with dredging operations; and,

· Depth-averaged Turbidity did not show the same trend of exceedances indicating no potential relationship to a sediment plume generated by dredging activities.

The exceedance was hence considered to be isolated case and may be due to the regional natural fluctuation.

As per the requirements of the EM&A Manual, incident was 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.

Dissolved Oxygen

During impact monitoring, depth-averaged DO and bottom DO levels at all stations are generally comparable with those levels recorded during the baseline monitoring. It is noted that there appeared to be a decreasing trend in both DO levels at Impact Stations between 8 and 12 September, however, as this pattern was also observed in both upstream and control stations, it is considered unlikely that these levels are attributable to Project works.

Suspended Solids

During impact monitoring on the flood tide, SS levels at all stations were found to be generally comparable with those recorded during the baseline monitoring. An exception was noted on 4 and 18 September 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 but rather isolated events. Furthermore, it is noted that upstream Control Station C2 also recorded similar high levels on 5 September at mid ebb, indicating potentially natural fluctuations.

Based on the above, it is likely that the waters in the vicinity of the works site are influenced by other factors, such as natural fluctuations of DO and SS observed in the Pearl River Estuary.

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, water quality monitoring recommenced on 1 September 2008 alongside dredging activities. 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 turbidity levels of all Impact Stations were compliant with the Action and Limit (AL) Levels specified in the EM&A Manual. Exceedance of the Action Limit Levels for Depth-averaged Dissolved Oxygen (DO) was found on 4, 8, 9, 10, 11 and 12 September 2008 while exceedance of the Action Limit Levels for Bottom DO was found on 9, 10, 11 and 12 September 2008. Exceedance of the Action Level of Suspended Solids was found on 4 and 18 September 2008. 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 POPs in water samples was conducted on 3 and 17 September for POPs analysis. 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.

4.4 Waste Management

The Contractor’s revised Waste Management Plan (Revision 4) (WMP) was submitted to the EPD on 20 September 2007. Pursuant to EP Condition 3.3, the Contractor submitted the updated and revised WMP (Revision 5) to the ET. The revised WMP has been certified by the ET and IEC.

4.5 Cultural Heritage

The Watching Brief Report, verified by the Independent Environmental Checker, was submitted to the EPD and AMO on 9 May 2008.

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

The ET and IEC verified updated design audit plan was 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 1 September 2008. During the reporting period, a total of 11 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. No further actions regarding the EM&A manual were required during the reporting month.

4.10 Baseline Water Quality Monitoring

The Final Baseline Monitoring Report was submitted to the EPD on 20 February 2008 and placed under the EIAO register.

5 Future Key Issues

5.1 Key Issues for the Next One Month

It should be noted that dredging activities have been resumed from 1 September 2008. As such, the key issues to be considered in the next one month will be:

· 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 Dissolved Oxygen 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.

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, pump platform, drainages, bund wall, security wall etc) and dredging operations. Weekly site inspections will be undertaken. Water quality and dolphin monitoring will be undertaken in accordance with the EM&A Manual.