EA letter to KIA 19.12.08

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Rowland Gunn Our ref: WQ/P.21518/KIST/07

Kent International Airport Your ref:

Manston Date: 19 December 2008

Application to discharge matter other than sewage or trade effluent by Infratil

Airports Europe Ltd. from premises at Kent International Airport, Manston,

Application no: P.215181K15T107

Water Resources Act 1991 (as amended by the Environment Act 1995) Schedule 10

Thank you for your letter received on the 27 October 2008 and the draft copy of your Environmental Management Plan. We have the following comments to make.

In my previous letter I stated that we believe that a Class I full retention interceptor is required I am disappointed therefore to see that the type of interceptor proposed is a bypass interceptor. We do not feel that this provides adequate protection to Pegwell Bay given its sensitivity.

With regard to the sizing of the interceptor please can you provide a map which shows the pipe numbers as referenced in the design documentation.

Echo Apron and Echo Taxiway

The report states that the Echo Apron and Echo Taxiway currently drain to ground. It also states that refueling takes place in these areas. This situation is not acceptable and poses a great risk of pollution to the groundwater and associated public water supply.

Refueling should not take place in areas that drain to ground and therefore refueling must be not take place on Echo Apron and Echo Taxiway.

Orchard House, Endeavour Park, London Road, Addington, West Mailing, Kent, ME19 5SH.

Customer services line: 08708 506 506

Email: enquiries@environment-agency.gov.uk

An appropriate drainage plan needs to be agreed with the Environment Agency and installed in these areas to ensure that any polluted run off does not discharge to ground.

It is important and should be one of the airports priorities to develop and agree with the Environment Agency, appropriate drainage for these areas at the earliest opportunity, only then will refueling activities be acceptable in these areas.

Spill Contingency Plan

The legislation identified in the report is relevant to a spill of hazardous material, but other regulations should also be included, such as:

- Groundwater Regulations 1998- List 1 substances must be prevented from entering groundwater (these include fuel, oil and solvents) and the entry of List 2 substances must be restricted.

- Control of Pollution (Oil Storage) Regulations 2001

A full drainage plan should have been included in the report. This should include details on where each area drains to, details on pollution prevention methods and a full plan showing each area and where they drain to. The plan should also be cross referenced in the spill contingency section. We note that in the report reference has been made to grid squares but no map has been provided.

The Environment Agency should be notified of all spillages or potential pollutions on

0800 807060. This should be done as soon as practicable. As much information as

possible should be provided to the Environment Agency at the time of reporting.

Information likely to be required includes the following:

- type of substance spilled

- estimated volume of spillage

- site plan indicating location of spillage

- how the incident occurred - i.e. spillage whilst refueling or from a leak in a tank.

- What has been done so far to clean it up

- When did the spill occur

The report to be submitted to the Environment Agency following completion of clean up after the incident should also include the above and that identified currently in the report. Depending on the type of incident more information may be required.

Under Emergency Contact Details I recommend that only the Environment Agency Emergency phone number, 0800 807060, should be used not the 08708 506506.

There are two sections in the report which detail minor, medium and major spills. In the first of the two sections the definitions of what makes up the categories of spills is not clear. For example it is not possible to tell that spills which pose a risk to groundwater are not considered to be a minor spill as this is only explained in a later section. Please note that if a spillage occurs near a soakaway, this presents a high risk of pollution of the aquifer. It should also be mentioned under the list of actions that the source of the spillage should be stopped.

In the report it states `Depending on the severity of the incident, other outside bodies may have to be engaged as second level response'. More information should be supplied regarding the companies/organisations to be used and under what circumstances.

Please can you include a section in the report which details how you plan to dispose of any hazardous waste.

The section entitled RFFS needs more detail. Is this the airport tire service? It so what procedures do they have in place for spillages? What equipment do they have to deal with spillages?

In the section regarding Aircraft Fuel it appears that the bowsers are stored full of fuel. Can you confirm where they are stored? What type of surface are they stored on and what pollution prevention measures are provided?

Bulk Fuel installation

A major risk to the groundwater is the existing bulk fuel installations on site, one of which is single skinned. The environmental management plan should identify risks such as this and make proposals for improving the situation. This is important to protect the groundwater. A plan of the airport showing all bulk storage locations should also be included in the report.

It is understood that an investigation has been undertaken in the area surrounding one of the bulk fuel installations, the findings of this should be submitted to the Environment Agency to assess any risk to controlled waters.

If there are any fuel storage tanks that are no longer in use, these should be decommissioned and the ground beneath and surrounding them should be thoroughly investigated to determine if any contamination of the ground and/or groundwater has occurred. Proposed decommissioning works should be included in this plan.

If you have any queries regarding the above please contact me. Yours sincerely

Principal Officer - SEP Water Quality

CC Matt Clarke - Chief Executive Officer, Kent International Airport.


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We have the following comments to make. Interceptor In my previous letter I stated that we believe that a Class I full retention interceptor is required I am disappointed therefore to see that the type of interceptor proposed is a bypass interceptor. We do not feel that this provides adequate protection to Pegwell Bay given its sensitivity. With regard to the sizing of the interceptor please can you provide a map which shows the pipe numbers as referenced in the design documentation. Echo Apron and Echo Taxiway The report states that the Echo Apron and Echo Taxiway currently drain to ground. It also states that refueling takes place in these areas. This situation is not acceptable and poses a great risk of pollution to the groundwater and associated public water supply. Refueling should not take place in areas that drain to ground and therefore refueling must be not take place on Echo Apron and Echo Taxiway. Orchard House, Endeavour Park, London Road, Addington, West Mailing, Kent, ME19 5SH. Customer services line: 08708 506 506 Email: enquiries@environment-agency.gov.uk An appropriate drainage plan needs to be agreed with the Environment Agency and installed in these areas to ensure that any polluted run off does not discharge to ground. It is important and should be one of the airports priorities to develop and agree with the Environment Agency, appropriate drainage for these areas at the earliest opportunity, only then will refueling activities be acceptable in these areas. Spill Contingency Plan The legislation identified in the report is relevant to a spill of hazardous material, but other regulations should also be included, such as: - Groundwater Regulations 1998- List 1 substances must be prevented from entering groundwater (these include fuel, oil and solvents) and the entry of List 2 substances must be restricted. - Control of Pollution (Oil Storage) Regulations 2001 A full drainage plan should have been included in the report. This should include details on where each area drains to, details on pollution prevention methods and a full plan showing each area and where they drain to. The plan should also be cross referenced in the spill contingency section. We note that in the report reference has been made to grid squares but no map has been provided. The Environment Agency should be notified of all spillages or potential pollutions on 0800 807060. This should be done as soon as practicable. As much information as possible should be provided to the Environment Agency at the time of reporting. Information likely to be required includes the following: - type of substance spilled - estimated volume of spillage - site plan indicating location of spillage - how the incident occurred - i.e. spillage whilst refueling or from a leak in a tank. - What has been done so far to clean it up - When did the spill occur The report to be submitted to the Environment Agency following completion of clean up after the incident should also include the above and that identified currently in the report. Depending on the type of incident more information may be required. Under Emergency Contact Details I recommend that only the Environment Agency Emergency phone number, 0800 807060, should be used not the 08708 506506. There are two sections in the report which detail minor, medium and major spills. In the first of the two sections the definitions of what makes up the categories of spills is not clear. For example it is not possible to tell that spills which pose a risk to groundwater are not considered to be a minor spill as this is only explained in a later section. Please note that if a spillage occurs near a soakaway, this presents a high risk of pollution of the aquifer. It should also be mentioned under the list of actions that the source of the spillage should be stopped. In the report it states `Depending on the severity of the incident, other outside bodies may have to be engaged as second level response'. More information should be supplied regarding the companies/organisations to be used and under what circumstances. Please can you include a section in the report which details how you plan to dispose of any hazardous waste. The section entitled RFFS needs more detail. Is this the airport tire service? It so what procedures do they have in place for spillages? What equipment do they have to deal with spillages? In the section regarding Aircraft Fuel it appears that the bowsers are stored full of fuel. Can you confirm where they are stored? What type of surface are they stored on and what pollution prevention measures are provided? Bulk Fuel installation A major risk to the groundwater is the existing bulk fuel installations on site, one of which is single skinned. The environmental management plan should identify risks such as this and make proposals for improving the situation. This is important to protect the groundwater. A plan of the airport showing all bulk storage locations should also be included in the report. It is understood that an investigation has been undertaken in the area surrounding one of the bulk fuel installations, the findings of this should be submitted to the Environment Agency to assess any risk to controlled waters. If there are any fuel storage tanks that are no longer in use, these should be decommissioned and the ground beneath and surrounding them should be thoroughly investigated to determine if any contamination of the ground and/or groundwater has occurred. Proposed decommissioning works should be included in this plan. If you have any queries regarding the above please contact me. Yours sincerely Sarah Hamer Principal Officer - SEP Water Quality CC Matt Clarke - Chief Executive Officer, Kent International Airport.