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.

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 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

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

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
Mr Amin Ebrahim	Assistant General Manager Aviation Logistics	2183 3108	2824 2786	ebraa@hkairport.com
Contractor – Leighton (Asia) Construction Limited
Brian Gillon	Project Director	2823 1111	2529 8784	brian.gillon@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 Kwok-leung Pun	Independent Environmental Checker	2911 2233	2805 5028	KwokLeung.Pun@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. Table 2.2 presented the cumulative quantity of excavated materials up to 30^th June 2008. The cumulative dredging volume during the reporting period was presented in Figure 2.1.

Table 2.1 Summary of Works Undertaken up to 30^th June 2008

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) Site Investigation
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

Minor Jetty Works (Non-piling)

Site Investigation

Submarine Pipeline Route

Dredging Operations

Table 2.2 Cumulative Quantity of Excavated Materials up to 30^th June 2008

Type of Excavated Materials	Cumulative Bulk Volume (m³)
Contaminated Mud	105,974
Uncontaminated Mud	97,815

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 17 December 2007 to 31March 2008. A marine archaeological Watching Brief of two sub-surface anomalies was also implemented from 21 to 28 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.

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^th June 2008

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-RW0372-07	25 July 2007 to 24 January 2008	For 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-RW0427-07	28 August 2007 to 27 February 2008	For concrete pump derrick barges, hand-held grinders, generators, air compressors, boring machines, water pumps, tug boat, grout mixers and grout pumps
	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
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
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 2008, the CLG held the meetings on 27 July 2007, 5 October 2007, 7 December 2007, 7 March 2008 and 6 June 2008.

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 daily exceedance of Action Levels of Depth-averaged Turbidity during December, January and February with exception of 16 and 24 January, and 11 February.

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, 11, 23 and 29 January, and 10, 12, 13 and 24 February.

Following a review of the data, a revised Action Limit Level for Turbidity was implemented on 1 March 2008. Only one exceedance of Limit Level of Depth-averaged Dissolved Oxygen was found (19 March 2008).

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

Summary of Environmental Complaints

No environmental complaint was received during the reporting period. A summary of environmental complaints since project commencement is presented in Annex C.

Summary of Environmental Summons

No summons was 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
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:

· Exceedance of Action Level of depth-averaged Turbidity was found on days when no dredging was undertaken, and these values were comparable to those 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 Annex F.

Results showed that 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 was thus considered 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.

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 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 was checked against the revised Action Levels. The development of the amendment is documented in the previous Monthly EM&A Reports.

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 17 December 2007 to 31^st March 2008. Monitoring data and graphical presentations of the results are included in Annex F.

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 with the exception of 19 March 2008. Concentrations of Suspended Solids (SS) were generally below AL Levels, however, exceedances were noted for 21, 24, 25, 27, 29 and 30 December 2007, 11, 23 and 29 January, and 10, 12, 13 and 24 February. Turbidity levels were, however, above Action Levels on a daily basis on December, January and February with exception of 16 and 24 January, and 11 February. 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 17 December 2007 to 31 March 2008. All POPs parameters (ie total Polychorinated Biphenyls (PCBs), total Dichloro-Diphenyl-Trichloroethane (DDTs) and total Polycyclic Aromatic Hydrocarbons (PAHs)) were below detection limits, except the total PAHs of Control Station C1 during mid-flood tidal condition. As C1 is a Control Station, such levels were not considered to be attributable to works. Monitoring results and QA/QC reports for POPs testing are presented in previous 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 on 3 June 2008. The ET reviewed the WMP and offered comments to the Contractor on 16 June 2008. Response to comment (RTC) from the Contractor is now in progress.

4.1.4 Cultural Heritage

In accordance with the EM&A Manual, a marine archaeological Watching Brief of two sub-surface anomalies was implemented from 21 to 28 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.

No archaeological sites or relics were found and it was 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 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

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 two design drawings entitled Fencing and Security Wall Layout Plan (PAFF/LC/02/DWG/C/0176 Revision A) and Fencing and Security Wall Section (PAFF/LC/02/DWG/C/0177 Revision A) to the ET for certification on 30^th July 2007. The ET reviewed the drawings and offered comment on the design of the security walls and bund walls, taking into account of Condition 3.5a of the EP, to the Contractor on 31^st August 2007. Response to comment (RTC) from the Contractor was received by the ET on 19^th September 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 17 December 2007 to 31 March 2008.

During the reporting period, 23 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 6 December 2007 and was submitted to the EPD on 10 December 2007. Comments were received from the EPD on 22 January 2008. The ET will update the EM&A Manual accordingly.

4.1.9 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 December. A revised Final Baseline Monitoring Report was submitted to the EPD on 20 February 2008 with no further comments received and later 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 of 21 to 22 January 2008. 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 indicated in grey shaded cells.

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%)	Dec 07	Jan 08	Feb 08	March 08
MPB1	13.76	17.89	16.96	9.08	10.84	8.25
MPB2	14.57	18.94	11.72	9.38	9.92	7.74
MP	13.33	17.33	12.21	8.50	11.61	8.09
IMO1*	11.81	15.35	11.66	8.80	8.57	7.49
IMO2*	11.81	15.35	10.36	8.24	8.70	7.15
IMO3*	11.81	15.35	-	8.27	9.73	-
IMO4*	11.81	15.35	-	7.37	8.28	-

*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 indicated in grey shaded cells.

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%)	Dec 07	Jan 08	Feb 08	March 08
MPB1	13.50	17.55	22.06	11.55	10.91	8.61
MPB2	18.31	23.80	11.76	9.56	11.39	8.15
MP	10.86	14.11	13.54	8.02	11.51	7.96
IMO1*	13.21	17.17	12.54	9.61	9.21	7.57
IMO2*	13.21	17.17	12.93	9.39	8.99	6.93
IMO3*	13.21	17.17	-	8.10	9.41	-
IMO4*	13.21	17.17	-	6.83	8.43	-

*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 mid-ebb did not exceed 130% of the baseline levels, which was in line with previous predictions. During mid-flood tidal condition, the measured elevations of SS at Impact Station MPB1 in December, however, exceeded the predictions. Such exceedance is more likely due to natural fluctuations of SS observed in the Pearl River Estuary. Moreover, all SS levels recorded at all impact stations in January, February and March 2008 did not exceed the predictions, which can further imply that such exceedance is unlikely due to the project works.

6 Future Key Issues and Conclusion

6.1 Key Issues for the Next Reporting Period

It should be noted that dredging activities have been suspended from 1 April onwards and are tentatively scheduled to resume in September 2008. As such, key issued to be considered in the next reporting period will be:

· Dust release and suppression from on-site works;

· Dredging activities; and.

· Water quality monitoring and dolphin monitoring during dredging activities.

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 dredging operation. Weekly site inspections will be undertaken by the ET as per the EM&A requirements.

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