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 EPD in February 2004.

However, the decision by 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. A further Variation to the Environmental Permit has been approved 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 resumed on 9 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

After the resumption of the construction works and EM&A requirements on 9 July 2007, this is the second EM&A Report which summarizes the monitoring results and audit findings for the EM&A programme during the reporting period from 1 July 2008 to 30 June 2009.

1.2 Key Contact Information

Key contact information of the Project is presented in Table 1.1.

Table 1.1 Contact Information

Name	Position	Telephone	Facsimile	E-mail
Airport Authority Hong Kong – Environmental Permit Holder
Anthony Wong	Assistant General Manager Aviation Logistics	2183 3099	2824 2786	anthony.wong@hkairport.com
Contractor – Leighton (Asia) Construction Limited
Brian Gillon	Project Director	2823 1111	2529 8784	brian.gillon@leightonasia.com
Boyd Merrett	Project Manager	2404 8900	2404 0081	boyd.merrett@leightonasia.com
Franchisee’s Site Representative – ECO Aviation Fuel Development Limited
Philip Siu	Franchisee’s Site Representative	2963 2820	2563 6311	philip.siu@towngas.com
Environmental Team – ERM-Hong Kong Limited
Craig Reid	Environmental Team Leader	2271 3000	2723 5660	craig.reid@erm.com
Independent Environmental Checker – Hyder Consulting Limited
Dr Guiyi Li	Independent Environmental Checker	2911 2233	2805 5028	guiyi.li@hyderconsulting.com

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. Marine dredging operations were completed on 23 January 2009. Table 2.2 presented the cumulative quantity of excavated materials up to that date. The cumulative dredging volume during the reporting period was presented in Figure 2.1.

Table 2.1 Summary of Works Undertaken up to 30 June 2009

Area	Works undertaken
Tuen Mun Area 38	· Tank Farm and Bund Wall Construction · Permanent Drainage Construction · Operational & Fire Services Buildings Construction · Minor Jetty Works (Non-piling)
Submarine Pipeline Route	· Dredging Operations · Completion of installation of main submarine pipeline · Riser connections at seawall and Sha Chau · Backfilling and placing of rock armour over the pipelines

Area

Works undertaken

Tuen Mun Area 38

· Tank Farm and Bund Wall Construction

· Permanent Drainage Construction

· Operational & Fire Services Buildings Construction

· Minor Jetty Works (Non-piling)

Submarine Pipeline Route

· Dredging Operations

· Completion of installation of main submarine pipeline

· Riser connections at seawall and Sha Chau

· Backfilling and placing of rock armour over the pipelines

Table 2.2 Cumulative Quantity of Excavated Materials up to 30 June 2009

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 2008 to 23 January 2009*
Contaminated Mud	0
Uncontaminated Mud	149,147

2.4 Monitoring Schedule of the Reporting Period

Daily water quality monitoring and dolphin monitoring and biweekly Persistent Organic Pollutants (POPs) monitoring during dredging activities were conducted from on 1 September 2008 to 23 January 2009.

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 up to 30 June 2009

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)
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
	GW-RW0054-09	16 February 2009 to 5 August 2009	For land-based and marine works including passenger launch, winch, welding machine, grinder, generator, power pack, tug boat, crane, air compressor, roller, hoist and derrick barge
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
	EP/MD/09-039	1 December 2008 to 31 January 2009	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 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. Up to 30 June 2009, the CLG held meetings on 10 September 2009, 3 December 2009, 12 March 2009 and 10 June 2009.

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

Summary of Environmental Non-compliance

Water quality monitoring during dredging activities recorded exceedances of the Action Limit Level for Depth-averaged Dissolved Oxygen (DO) on 4, 8, 9, 10, 11 and 12 September 2008. There were exceedances of the Action Limit Level for Bottom DO on 9, 10, 11 and 12 September 2008. Exceedances of Action Level of Suspended Solids were found on 4 and 18 September 2008.

A description of the actions taken following these non-compliances is discussed in Section 3.2.

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 C.

Summary of Environmental Summons

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

3 Environmental Issues and Actions

3.1 Previous Environmental Deficiencies and Follow-up Actions

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

Weekly site inspections were carried out during the reporting period. 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 are presented in previous Monthly EM&A Reports. Key findings are summarised in Table 3.1.

Table 3.1 Environmental Deficiencies (Observations) from Site Inspections during Reporting Period

Key Observations	Follow-up Action
Construction materials at the stockpile area were observed to be loaded without spraying with water	Site workers were deployed to spray water on the construction material during loading and unloading
Sediment plumes were observed at the outfall of the temporary drainage system after a rainstorm	The temporary drainage system was upgraded with the installation geo-textile on the sediment tank
Ponding of rainwater was observed in the construction site	Rainwater was pumped offsite via the temporary drainage system
Stagnant water pools were observed at some locations on site (eg tank farm, chemical waste storage).	The Contractor was reminded to arrange ad hoc water clearance as necessary.
Chemical waste stores were observed to be full	The chemical waste was disposed of via licence chemical waste collector
Excavated materials were not properly covered with tarpaulin sheets to avoid dust generation	The sand pile was covered accordingly
General refuse collection bins were observed to be full outside the site office and operation building	General refuse was cleared
Piles of general and wood waste from construction works were piled up on open areas without proper containers	A suitable waste bin was installed and the refuses were cleared
Oil sheens were observed on ground due to improper storage of equipment and chemicals	Contractor stored equipment and chemicals in suitable containers to avoid leakages
Sediment plumes were observed in the marine area near the water discharge outlet	Contractor cleared sedimentation tank and car wash facility to avoid overflow of silt and dirt

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

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:

· Exceedances of the Action Limit Level for depth-averaged DO were also 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

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 Annex F.

Results showed that during impact monitoring on ebb and flood tides, DO and SS levels at all stations are generally comparable with those levels recorded during the baseline monitoring. It was thus considered likely that the waters upstream 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 D.

3.4 Event and Action Plans

The event and action plans for construction noise, water quality monitoring, dolphin monitoring, cultural heritage, landscape and visual, as stated in the EM&A Manual, are summarized in Annex E.

4 Environmental Monitoring

4.1.1 Air and Noise

Air and Noise monitoring was not required for the project.

4.1.2 Water Quality

In accordance to the EM&A Manual, water quality monitoring was conducted during dredging activities from 1 September 2008 to 23 January 2009. Monitoring data and graphical presentations of the results are included in Annex F.

Results of the monitoring demonstrated that all measured turbidity levels of all Impact Stations were below the Action and Limit (AL) Levels specified in the EM&A Manual. Concentrations of Suspended Solids (SS) were also generally below AL Levels, however, exceedances were noted for 4 and 18 September 2008. Depth-averaged Dissolved Oxygen (DO) did not comply with AL Levels on 4, 8, 9, 10, 11 and 12 September 2008 while Bottom DO did not comply with AL Levels on 9, 10, 11 and 12 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).

Biweekly monitoring of water samples was also conducted for POPs analysis from 1 September 2008 to 23 January 2009. All POPs parameters (ie total Polychorinated Biphenyls (PCBs), total Dichloro-Diphenyl-Trichloroethane (DDTs) and total Polycyclic Aromatic Hydrocarbons (PAHs)) were below detection limits. Monitoring results and QA/QC reports for POPs testing are presented in Monthly Monitoring Reports.

4.1.3 Waste Management

The Contractor’s revised Waste Management Plan (Revision 4) (WMP) was submitted to 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.

4.1.4 Cultural Heritage

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

4.1.5 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 dominated by vegetation which was grown during the project suspension period.

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

4.1.6 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.

4.1.7 Ecology

Dolphin Visual Monitoring

In accordance to EM&A Manual, dolphin monitoring has been undertaken during dredging activities from 1 September 2008 to 23 January 2009.

During the reporting period, 30 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 G.

4.1.8 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 POPs monitoring during construction of the Project. The updated EM&A Manual was revised accordingly to the comments received from the EPD on 16 January 2009 and was submitted to the EPD on 1 April 2009.

4.1.9 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 Review of the EM&A and Impact Assessment Predictions

Dredging operation was carried out for pipleline installation during the period from 1 September 2008 to 23 January 2009. Monitoring data of suspended solids (SS) concentrations collected are compared with the impact assessment predictions in the EIA Report. As stated in the EIA report, the predicted allowable maximum contribution on suspended sediment concentration from dredging activity will be 30% increase of the background concentration. Tables 5.1 and 5.2 show the comparison between the monthly mean value of the impact monitoring data and the average values of the baseline monitoring.

Table 5.1 Average Suspended Solids Concentrations (SS, mg/L) calculated from Baseline Monitoring and Monthly Average Values calculated from Impact Monitoring at Impact Stations during mid-ebb. Exceedance of EIA prediction was not observed.

Stations	Suspended Solid Concentrations (mg/L)
	Baseline monitoring (Average)	EIA Prediction (Baseline values x 130%)	Impact Monitoring (Average)
	Baseline monitoring (Average)	EIA Prediction (Baseline values x 130%)	Sep 08	Oct 08	Nov 08	Dec 08	Jan 09
MPB1	13.76	17.89	9.00	6.51	7.83	6.16	7.34
MPB2	14.57	18.94	8.54	6.81	8.01	6.30	7.72
MP	13.33	17.33	8.60	6.73	7.47	6.03	7.35
IMO1*	11.81	15.35	9.66	6.97	7.81	6.32	7.34
IMO2*	11.81	15.35	8.29	6.68	7.50	6.26	7.30

*Note: baseline monitoring was not applicable to these stations and hence data was compared against the average value of all baseline monitoring data.

Table 5.2 Average Suspended Solids Concentrations (SS, mg/L) calculated from Baseline Monitoring and Monthly Average Values calculated from Impact Monitoring at Impact Stations during mid-flood. Exceedance of EIA prediction was not observed.

Stations	Suspended Solid Concentrations (mg/L)
	Baseline monitoring (Average)	EIA Prediction (Baseline values x 130%)	Impact Monitoring (Average)
	Baseline monitoring (Average)	EIA Prediction (Baseline values x 130%)	Sep 08	Oct 08	Nov 08	Dec 08	Jan 09
MPB1	13.50	17.55	9.40	6.81	7.94	6.16	6.86
MPB2	18.31	23.80	8.36	6.57	7.82	6.20	7.04
MP	10.86	14.11	9.90	6.77	7.30	6.11	7.10
IMO1*	13.21	17.17	8.42	6.83	7.47	6.11	7.50
IMO2*	13.21	17.17	9.39	7.01	7.49	6.10	7.18

*Note: baseline monitoring was not applicable to these stations and hence data was compared against the average value of all baseline monitoring data.

During the reporting period, monthly average of measured elevations of SS at the monitoring stations during both mid-ebb and mid-flood did not exceed 130% of the baseline levels, which was in line with previous predictions. This implied that dredging activities did not cause unacceptable elevations of SS in water.

6 Future Key Issues and Conclusion

6.1 Key Issues for the Next Reporting Period

Key issued to be considered in the next reporting period will be:

· dust release and suppression from on-site works;

· backfilling of rock armour over pipelines.

6.2 Impact Prediction for the Next Reporting Period

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

6.3 Works and Monitoring Schedule for the Next Reporting Period

Work programme for the next reporting period 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 backfilling works. Weekly site inspections will be undertaken by the ET as per the EM&A requirements.

It is expected that the majority of the remaining construction works will be completed by June 2010 and pre-commissioning works such as hydrotesting and electricity/mechanical checks will commence in March 2010.

6.4 Conclusion

The EM&A works were conducted throughout the annual reporting period and the relevant monitoring was conducted in accordance with the EP’s requirements. Mitigation measures were used to minimise the environmental impacts, where appropriate. Some environmental deficiencies were observed during the site inspections and the Contractor implemented corrective action to mitigate the issues. Overall, the site was considered to be in an orderly manner.

It is concluded the current EM&A programme, including the monitoring programme and the mitigation measure herein, is sufficient to monitor the environmental performance of the project works.

Breaches of all Action and Limit Levels

Complaint Log

Notifications of any Summons and Successful Prosecutions

Future Key Issues

Conclusion