Contents

Executive Summary

1                      Introduction                                                                           

1.1                   Purpose of the Report                                                      

1.2                   Structure of the Report                                                  

2                      Project information                                                           

2.1                   Background                                                                            

2.2                   General Site Description                                                  

2.3                   Major Activities Undertaken                                          

2.4                   Project Organisation and Management Structure

2.5                   Status of Environmental Approval Documents   

3                      Environmental Monitoring and Audit Requirements

3.1                   Environmental Monitoring                                              

3.1.1                Air Quality                                                                                    

3.1.2                Odour                                                                                            

3.2                   Site Audit                                                                                   

3.2.1                Water Quality                                                                               

3.2.2                Landscape and Visual                                                                

4                      Monitoring Results                                                             

4.1                   Air Quality                                                                               

4.1.1                Commissioning Phase Monitoring                                            

4.1.2                Operation Phase Monitoring                                                      

4.2                   Odour                                                                                         

4.2.1                Operation Phase Monitoring                                                      

4.3                   Water Quality                                                                        

4.3.1                Operation Phase Monitoring                                                      

4.4                   Waste Management                                                              

4.4.1                Operation Phase Monitoring                                                      

5                      Site Audit                                                                                   

5.1                   Environmental Site Audit                                                  

5.1.1                Operation Phase                                                                          

5.2                   Landscape and Visual Audit                                            

6                      Environmental Non-conformance and Deficiencies

6.1                   Summary of Environmental Non-Compliance and Deficiencies       

6.2                   Summary of Environmental Complaint                      

6.3                   Summary of Environmental Summon and Successful Prosecution      

7                      Future Key Issues                                                                 

7.1                   Key Issues for the Coming Month                                 

8                      Conclusions                                                                            

 

 

LIST OF TABLES

Table 2.1    Summary of Activities Undertaken in the Reporting Period

Table 2.2    Summary of Environmental Licensing, Notification and Permit Status

Table 3.1    Sampling and Laboratory Analysis Methodology

Table 3.2    Emission Limit for CAPCS Stack

Table 3.3    Emission Limit for CHP Stack

Table 3.4    Emission Limit for ASP Stack

Table 3.5    Emission Limit for Standby Flaring Gas Unit ()

Table 3.6    Odour Intensity Level

Table 3.7    Action and Limit Levels for Odour Nuisance

Table 3.8    Event and Action Plan for Odour Monitoring

Table 3.9    Discharge Limits for Effluent from the Effluent Storage Tank

Table 3.10  Discharge Limits for Effluent from the Petrol Interceptors

Table 4.1    Hourly Average of Parameters Recorded for CAPCS

Table 4.2    Hourly Average of Parameters Recorded for CHP 1

Table 4.3    Hourly Average of Parameters Recorded for CHP 2

Table 4.4    Hourly Average of Parameters Recorded for CHP 3

Table 4.5    Hourly Average of Parameters Recorded for ASP

Table 4.6    Results of the Discharge Sample from the Effluent Storage Tank

Table 4.7    Results of the Discharge Sample from the Petrol Interceptor 1

Table 4.8    Results of the Discharge Sample from the Petrol Interceptor 2

Table 4.9    Quantities of Waste Generated from the Operation of the Project

Table 8.1    Exceedances for Stack Emissions

 

LIST OF ANNEXES

Annex A

Location of Project

Annex B

Project Organisation Chart and Contact Detail

Annex C

Implementation Schedule of Mitigation Measures

Annex D

Waste Flow Table

Annex E

Environmental complaint, Environmental Summons and Prosecution Log

Annex F

Investigation Report

 

EXECUTIVE SUMMARY

The construction works of No. EP/SP/61/10 Organic Resources Recovery Centre Phase 1 (the Project) commenced on 21 May 2015.  This is the 81st monthly Environmental Monitoring and Audit (EM&A) report presenting the EM&A works carried out during the period from 1 to 28 February 2022 in accordance with the EM&A Manual.  Substantial completion of the construction works was confirmed on 3 December 2018.  In the meantime, the operation phase EM&A programme had commenced in March 2019. Substantial Completion in respect of substantial part of the Works was confirmed on 24 February 2020.  The construction phase EM&A programme was completed in the end of February 2020.

Summary of Works undertaken during the Reporting Month

Works undertaken in the reporting month included:

            Operation of the Project, including organic waste reception, and operation of the pre-treatment facilities, anaerobic digesters, composting facilities, air pollution control systems, on-line emission monitoring system for the Centralised Air Pollution Control Unit (CAPCS), Co-generation Units (CHP)s and Ammonia Stripping Plant (ASP), and the wastewater treatment plant; and

            Fine tuning of the CHPs and modification of the ASP to control the air emission.

Environmental Monitoring and Audit Progress

Air Quality Monitoring

Non-compliance of emission limits of SO2 from CHP 3 and Dust, CO, NOx, VOCs and NH3 from ASP were recorded during the reporting period.  It should be noted that measurements recorded under abnormal operating conditions, e.g. start up and stopping of stacks, unstable operation, test runs and interference of sensor, are disregarded.

 The exceedances of SO2 from CHP 3 occurred due to malfunctioning of the control instrument.  The exceedance of Dust, CO, NOx, VOCs and NH3 from ASP occurred due to system instability caused by the blockage of the stripping column and unstable column and thermal oxidizer temperature of the ASP.

Water Quality

No non-compliance to the effluent discharge limit stipulated in the discharge licence issued by the EPD under the Water Pollution Control Ordinance was recorded during this reporting period

Waste Management

Waste generated from the operation of the Project includes chemical waste, waste generated from pre-treatment process and general refuse. 

No chemical waste was collected by licenced waste collector from the operation of the Project.

260.57 tonnes of waste generated from pre-treatment process from the operation of the Project was disposed of at landfill.  Among the recyclable waste generated from pre-treatment process from the operation of the Project, 0.00 tonne of metals, 0.00 tonnes of papers/ cardboard packing and 0.00 tonne of plastics were sent to recyclers for recycling during the reporting period.

Around 2.42 tonnes of general refuse from the operation of the Project was disposed of at landfill.  Among the recycled general refuse from the operation of the Project, 0.00 tonne of metals, 0.00 tonne of papers/ cardboard packing and 0.00 tonne of plastics were sent to recyclers for recycling during the reporting period.

Findings of Environmental Site Audit

A summary of the monitoring activities undertaken in this reporting period is listed below:

        Joint Environmental Site Inspections

1 time

1 monthly joint environmental site inspection was carried out by the representatives of the Contractor and the MT.  The IEC was also present at the joint inspections on 14 February 2022.  The environmental control/ mitigation measures (related to air quality, water quality, waste (including land contamination prevention), hazard-to-life and landscape and visual) recommended in the approved EIA Report and the EM&A Manual were properly implemented by the Contractor during the reporting month. 

Environmental Exceedance/Non-conformance/Compliant/Summons and Prosecution

Exceedances for the air emission limits for the CHP and ASP stacks were recorded during the reporting period.

No complaint/ summon/prosecution was received in this reporting period.

Future Key Issues

Activities to be undertaken in the next reporting month include:

            Operation of the Project.

            Fine tuning of the CHPs and modification of the ASP to control the air emission. 


 

 

 

1             Introduction

ERM-Hong Kong, Limited (ERM) was appointed by OSCAR Bioenergy Joint Venture (the Contractor) as the Environmental Team (ET) to undertake the construction Environmental Monitoring and Audit (EM&A) programme for the Contract No. EP/SP/61/10 of Organic Waste Treatment Facilities Phase I, which the project name has been updated to Organic Resources Recovery Centre (Phase I) (the Project) since November 2017.  ERM was also appointed by the Contractor to undertake the operation EM&A programme starting 1 March 2019.

1.1                          Purpose of the Report

This is the 81st EM&A report which summarises the monitoring results and audit findings for the EM&A programme during the reporting period from 1 to 28 February 2022.

1.2                          Structure of the Report

The structure of the report is as follows:

Section 1:  Introduction

It details the scope and structure of the report.

 

Section 2:  Project Information

It summarises the background and scope of the Project, site description, project organisation and status of the Environmental Permits (EP)/licences.

 

Section 3:  Environmental Monitoring and Audit Requirements

It summarises the environmental monitoring requirements including monitoring parameters, programmes, methodologies, frequency, locations, Action and Limit Levels, Event/Action Plans, as well as environmental audit requirements as recommended in the EM&A Manual and approved EIA report.

 

Section 4:  Monitoring Results

It summarises monitoring results of the reporting period.

 

Section 5:  Site Audit

It summarises the audit findings of the environmental as well as landscape and visual site audits undertaken within the reporting period.

 

Section 6:  Environmental Non-conformance

It summarises any exceedance of environmental performance standard, environmental complaints and summons received within the reporting period.

 

Section 7:  Further Key Issues

It summarises the impact forecast for the next reporting month.

 

Section 8:  Conclusions

 

2                             Project information

2.1                          Background

The Organic Resources Recovery Centre (ORRC) Phase I development (hereinafter referred to as the Project) is to design, construct and operate a biological treatment facility with a capacity of about 200 tonnes per day and convert source-separated organic waste from commercial and industrial sectors (mostly food waste) into compost and biogas through proven biological treatment technologies.  The location of the Project site is shown in Annex A.

The environmental acceptability of the construction and operation of the Project had been confirmed by findings of the associated Environmental Impact Assessment (EIA) Study completed in 2009.  The Director of Environmental Protection (DEP) approved this EIA Report under the Environmental Impact Assessment Ordinance (EIAO) (Cap. 499) in February 2010 (Register No.: AEIAR-149/2010) (hereafter referred to as the approved EIA Report).  Subsequent Report on Re-assessment on Environmental Implications and Report on Re-assessment on Hazard to Life Implications were completed in 2013, respectively.

An Environmental Permit (EP) (No. EP-395/2010) was issued by the DEP to the EPD (Project Team), the Permit Holder, on 21 June 2010 and varied on 18 March 2013 (No. EP-395/2010/A) and 21 May 2013 (No. EP-395/2010/B), respectively.  The Design Build and Operate Contract for the ORRC Phase 1 (Contract No. EP/SP/61/10 Organic Resources Recovery Centre (Phase 1) (the Contract)) was awarded to SITA Waste Services Limited, ATAL Engineering Limited and Ros-Roca, Sociedad Anonima jointly trading as the OSCAR Bioenergy Joint Venture (OSCAR or the Contractor).  A Further EP (No. FEP-01/395/2010/B) was issued by the DEP to the OSCAR on 16 February 2015.  Variation to both EPs (Nos. EP-395/2010/B and FEP-01/395/2010/B) were made in December 2015.  The latest EPs, Nos. EP-395/2010/C and FEP-01/395/2010/C, were issued by the DEP on 21 December 2015.

Under the requirements of Condition 5 of the EP (No. FEP-01/395/2010/C), an Environmental Monitoring and Audit (EM&A) programme as set out in the approved EM&A Manual (hereinafter referred to as EM&A Manual) is required to be implemented during the construction and operation of the Project.  ERM-Hong Kong, Ltd (ERM) has been appointed by OSCAR as the Environmental Team (ET) for the construction phase EM&A programme and the Monitoring Team (MT) for the operation phase EM&A programme for the implementation of the EM&A programme in accordance with the requirements of the EP and the approved EM&A Manual.

The construction works commenced on 21 May 2015.  The construction phase EM&A programme was completed in the end of February 2020.  The operation phase of the EM&A programme commenced on 1 March 2019 ([1]).  

2.2                          General Site Description

The Project Site is located at Siu Ho Wan in North Lantau with an area of about 2 hectares.  The layout of the Project Site is illustrated in Annex A.  The facility received an average of 106.22 tonnes and treated an average of 96.91 tonnes of source separated organic waste per day during the reporting month.

2.3                          Major Activities Undertaken

A summary of the major activities undertaken in the reporting period is shown in Table 2.1.  

Table 2.1        Summary of Activities Undertaken in the Reporting Period

Activities Undertaken in the Reporting Period 

           Systems being operated waste reception, pre-treatment, CAPCS extraction, the digesters, the centrifuge, the composting tunnels, the desulphurisation, the emergency flare, the CHPs, the ASP and the biological waste water treatment plant (106.22 t/d SSOW received); and

           Fine tuning of the CHPs and modification of the ASP to control the air emission.

2.4                          Project Organisation and Management Structure

The project organisation chart and contact details are shown in Annex B.

2.5                          Status of Environmental Approval Documents

A summary of the valid permits, licences, and/or notifications on environmental protection for this Project is presented in Table 2.2.

Table 2.2        Summary of Environmental Licensing, Notification and Permit Status

Permit/ Licences/ Notification

Reference

Validity Period

Remarks

Environmental Permit

FEP-01/395/2010/C

 

Throughout the Contract

Permit granted on 21 December 2015

Effluent Discharge Licence

WT00038391-2021

7 July 2021 30 June 2026

Approved on 7 July 2021

Chemical Waste Producer Registration

WPN 5213-961-O2231-02

Throughout the implementation of the Project

Approved on 10 November 2017

Waste Disposal Billing Account

Account number: 702310

Throughout the Contract

-

3                             Environmental Monitoring and Audit Requirements

3.1                          Environmental Monitoring

The air quality (including odour) monitoring to be carried out during the commissioning and operation phase of the Project are described below.  Although water quality monitoring is not required for the operation phase under the EM&A programme, there are water quality monitoring requirement under the Water Discharge Licence of the plant under the Water Pollution Control Ordinance (WPCO).  As part of this EM&A programme, the monitoring results will be reviewed to check the compliance with the WPCO requirements.

3.1.1     Air Quality

According to the EM&A Manual and EP requirements, stack monitoring are required during the commissioning and operation phase of the Project. 

On-line monitoring (using continuous environmental monitoring system (CEMS) shall be carried out for the centralised air pollution unit (CAPCS), cogeneration units (CHP) and the ammonia stripping plant (ASP) during the commissioning and operation phase.  The last calibration was carried out on 15 June 2021 ([2]).

The monitoring data is transmitted instantaneously to EPD (Regional Office) by telemetry system.

When the on-line monitoring for certain parameter cannot be undertaken, monitoring will be carried out using the following methodology approved by the EPD.

Table 3.1        Sampling and Laboratory Analysis Methodology

Parameters

Method

Stacks to be Monitored

Gaseous and vaporous organic substances (including methane)

USEPA Method 18

      CAPCS

      CHP

      ASP

Particulate

USEPA Method 5

      CAPCS

      CHP

      ASP

Carbon monoxide (CO)

USEPA Method 10

      CHP

      ASP

Nitrogen oxides (NOx)

USEPA Method 7E

      CHP

      ASP

Sulphur dioxide (SO2);

USEPA Method 6

      CHP

      ASP

Hydrogen chloride (HCl)

USEPA Method 26A

      CHP

      ASP

Hydrogen fluoride (HF)

USEPA Method 26A

      CHP

      ASP

Oxygen (O2);

USEPA Method 3A

      CAPCS

      CHP

      ASP

Velocity and Volumetric Flow

USEPA Method 2

      CAPCS

      CHP

      ASP

Ammonia (NH3)

USEPA CTM 027

      ASP

Odour (including NH3 and H2S)

EN 13725

      CAPCS

Water vapour content (continuous measurement of the water vapour content should not be required if the sample exhaust gas is dried before the emissions are analysed)

USEPA Method 4

      CAPCS

      CHP

      ASP

Temperature

USEPA Method 4

      CAPCS

      CHP

      ASP

With reference to the EM&A Manual, the air emission of the stacks shall meet the following emission limits as presented in Tables 3.2 to 3.5.

Table 3.2        Emission Limit for CAPCS Stack

Parameter

Emission Level (mg/Nm3) (a)

VOCs (including methane)

680

Dust (or Total Suspended Particulates (TSP))

6

Odour (including NH3 & H2S)

220 (b)

Notes:

(a)   Hourly average concentration

(b)   The odour unit is OU/Nm3

Table 3.3        Emission Limit for CHP Stack

Parameter

Maximum Emission Level (mg/Nm3) (a) (b)

Dust (or Total Suspended Particulates)

15

Carbon Monoxide

650

NOx

300

SO2

50

NMVOCs (c)

150

VOCs (including methane) (d)

1,500

HCl

10

HF

1

Notes:

(a)  All values refer to an oxygen content in the exhaust gas of 6% and dry basis.

(b)  Hourly average concentration

(c)  NMVOCs should be monitored by gas sampling and laboratory analysis at an agreed interval.  For the first 12 months (starting from August 2019), monitoring should be carried out at quarterly intervals. The monitoring frequency should then be reduced to half-yearly for next 12 months (starting from August 2020).  The monitoring of NMVOCs ended in August 2021.

(d)  The VOCs emission limit include methane as biogas is adopted as fuel in the combustion process.

Table 3.4        Emission Limit for ASP Stack

Parameter

Maximum Emission Level (mg/Nm3) (a) (b)

Dust (or Total Suspended Particulates)

5

Carbon Monoxide

100

NOx

200

SO2

50

VOCs (including methane) (c)

20

NH3

35

HCl

10

HF

1

Notes:

(a)     All values refer to an oxygen content in the exhaust gas of 11% and dry basis.

(b)     Hourly average concentration

(c)      The VOCs emission limit include methane as biogas is adopted as fuel in the combustion process.

Table 3.5        Emission Limit for Standby Flaring Gas Unit ([3])

Parameter

Maximum Emission level (mg/Nm3) (a) (b)

Dust (or Total Suspended Particulates)

5

Carbon Monoxide

100

NOx

200

SO2

50

VOCs (including methane) (c)

20

HCl

10

HF

1

Notes:

(a)   All values refer to an oxygen content in the exhaust gas of 11% and dry basis.

(b)   Hourly average concentration

(c)    The VOCs emission limit include methane as biogas is adopted as fuel in the combustion process.

3.1.2     Odour

To determine the effectiveness of the proposed odour mitigation measures and to ensure that the operation of the ORRC1 will not cause adverse odour impacts, odour monitoring of the CAPCS stack (see Section 3.1.1) and odour patrol will be carried out.

Odour patrol shall be conducted by independent trained personnel/ competent persons in summer months (i.e. from July to September) for the first two operational years of ORRC1 at monthly intervals along an odour patrol route at the Project Site boundary as shown in Annex A([4]). 

The perceived odour intensity is divided into 5 levels.  Table 3.6 describes the odour intensity for different levels.

Table 3.6        Odour Intensity Level

Level

Odour Intensity

0

Not detected. No odour perceived or an odour so weak that it cannot be easily characterised or described

1

Slight identifiable odour, and slight chance to have odour nuisance

2

Moderate identifiable odour, and moderate chance to have odour nuisance

3

Strong identifiable, likely to have odour nuisance

4

Extreme severe odour, and unacceptable odour level

Table 3.7 shows the action level and limit level to be used for odour patrol. Should any exceedance of the action and limit levels occurs, actions in accordance with the event and action plan in Table 3.8 should be carried out.

Table 3.7        Action and Limit Levels for Odour Nuisance

Parameter

Action Level

Limit Level

Odour Nuisance (from odour patrol)

When one documented compliant is received (a), or Odour Intensity of 2 is measured from odour patrol.

Two or more documented complaints are received (a) within a week; or

Odour intensity of 3 or above is measured from odour patrol.

Note:

(a)     Once the complaint is received by the Project Proponent (EPD), the Project Proponent would investigate and verify the complaint whether it is related to the potential odour emission from the ORRC1 and its on-site wastewater treatment unit.

Table 3.8        Event and Action Plan for Odour Monitoring

Event

Action

 

Person-in-charge of Odour Monitoring

Project Proponent (a)

Action Level

 

 

Exceedance of action level (Odour Patrol)

1. Identify source/reason of exceedance;

2. Repeat odour patrol to confirm finding.

1. Carry out investigation to identify the source/reason of exceedance.   Investigation should be completed within 2 weeks;

2. Rectify any unacceptable practice;

3. Implement more mitigation measures if necessary;

4. Inform Drainage Services Department (DSD) or the operator of the Siu Ho Wan Sewage Treatment Works (SHWSTW) if exceedance is considered to be caused by the operation of the SHWSTW.

5. Inform North Lantau Refuse Transfer Station (NLTS) operator if exceedance is considered to be caused by the operation of NLTS.

Exceedance of action level (Odour Complaints)

1. Identify source/reason of exceedance;

2. Carry out odour patrol to determinate odour intensity.

1. Carry out investigation and verify the complaint whether it is related to potential odour emission from the nearby SHWSTW;

2. Carry out investigation to identify the source/reason of exceedance.  Investigation should be completed within 2 weeks;

3. Rectify any unacceptable practice;

4. Implement more mitigation measures if necessary;

5. Inform DSD or the operator of the SHWSTW if exceedance is considered to be caused by the operation of the SHWSTW.

6. Inform NLTS operator if exceedance is considered to be caused by the operation of NLTS.

Limit Level

 

 

Exceedance of limit level

1. Identify source/reason of exceedance;

2. Inform EPD;

3. Repeat odour patrol to confirm findings;

4. Increase odour patrol frequency to bi-weekly;

5. Assess effectiveness of remedial action and keep EPD informed of the results;

6. If exceedance stops, cease additional odour patrol.

1. Carry out investigation to identify the source/reason of exceedance.  Investigation should be completed within 2 week;

2. Rectify any unacceptable practice;

3. Formulate remedial actions;

4. Ensure remedial actions properly implemented;

5. If exceedance continues, consider what more/enhanced mitigation measures should be implemented;

6. Inform DSD or the operator of the SHWSTW if exceedance is considered to be caused by the operation of the SHWSTW.

Note:

(a)   Project Proponent shall identify an implementation agent.

3.2                          Site Audit

Environmental mitigation measures (related to air quality, water quality, waste, land contamination, hazard-to-life, and landscape and visual) to be implemented during the operation phase of the Project are recommended in the approved EIA Report and EM&A Manual and are summarised in Annex C.  Monthly site audits for operation phase will be carried out to check the implementation of these measures.

3.2.1     Water Quality

Compliance audits are to be undertaken to ensure that a valid discharge licence has been issued by EPD prior to the discharge of effluent from the operation of the Project site.  The audit shall be conducted to ensure that the effluent quality is in compliance with the discharge licence requirements.  As stipulated in the operation phase discharge licence, effluent discharge are to be sampled monthly from the Effluent Storage Tank, while effluent discharge are to be sampled bi-monthly from the Petrol Interceptors.  The effluent quality shall meet the discharge limits as described in Table 3.9 and Table 3.10

 Table 3.9      Discharge Limits for Effluent from the Effluent Storage Tank

Parameters

Discharge Limit (mg/L)

Flow Rate (m3/day) (a)

645

pH (pH units) (b)

6-10 (c)

Suspended Solids (b)

800

Biochemical Oxygen Demand (5 days, 20) (b)

800

Chemical Oxygen Demand (b)

2,000

Oil & Grease (b)

40

Total Nitrogen (b)

200

Total Phosphorus (b)

50

Surfactants (total) (b)

25

Notes:

(a)   Flow rate is not a parameter required to be monitored and reported by the Contractor in accordance to Section B2 of the Effluent Discharge Licence under the WPCO. 

(b)   Parameters required to be monitored and reported by the Contractor in accordance to Section B2 of the Effluent Discharge Licence under the WPCO. 

(c)    Range.

 

Table 3.10      Discharge Limits for Effluent from the Petrol Interceptors

Parameters

Discharge Limit (mg/L)

Flow Rate (m3/day)

245 (a)

Suspended Solids (b)

30

Chemical Oxygen Demand (c)

80

Oil & Grease (c)

20

Surfactants (total) (b)

15

Notes:

(a)   The surface runoff flow rate limit was estimated by the overall yearly rainfall data.  As the actual flowrate from the petrol interceptors depends on the weather condition instead of the performance of the petrol interceptor, monitoring and reporting of this parameter is not required.  Hence this parameter is not reported in Table 4.7 and Table 4.8

(b)   Parameter not required to be reported in accordance to Section B2 of the Effluent Discharge Licence under the WPCO. 

(c)    Parameters required to be reported in accordance to Section B2 of the Effluent Discharge Licence under the WPCO. 

3.2.2     Landscape and Visual

In accordance with EM&A Manual, the landscape and visual mitigation measures shall be implemented. 

For operation phase, site inspection shall be conducted once a month for the first year of operation of the Project.  All measures as stated in the implementation schedule of the EM&A Manual (see Annex C), including compensatory planting, undertaken by both the Contractor and the specialist Landscape Sub-Contractor during the first year of the operation phase shall be audited by a Registered Landscape Architect (RLA) to ensure compliance with the intended aims of the measures and the effectiveness of the mitigation measures.  After the one-year maintenance period, the landscape maintenance and monitoring shall be carried out by the Contractor.

 

4                              Monitoring Results

4.1                          Air Quality

4.1.1     Commissioning Phase Monitoring

Monitoring results of air quality parameters from stack emissions of the centralised air pollution control system, the ammonia stripping plant and the cogeneration units will be provided once available to show compliance with the monitoring requirements stated in the EM&A Manual (Rev. F) to support the termination of the commissioning phase EM&A programme. 

4.1.2     Operation Phase Monitoring

The concentrations of concerned air pollutants emitted from the stacks of the CAPCS, CHP, and ASP during the reporting period are monitored on-line by the continuous environmental monitoring system (CEMS).  During the reporting period, there is no need to operate the standby flare and therefore no monitoring of the flare stack was undertaken.

With reference to the emission limits shown in Tables 3.2, 3.3 and 3.4, the hourly average concentrations and the number of exceedances of the concerned air emissions monitored for the CAPCS, CHP and ASP during this reporting period are presented in Tables 4.1 to 4.5.  

It should be noted that measurements recorded under abnormal operating conditions, e.g. start up and stopping of stacks, unstable operation, test runs and interference of sensor, are disregarded.

Table 4.1        Hourly Average of Parameters Recorded for CAPCS

Parameter

Range of Hourly Average Conc. (mg/Nm3)

Emission Limit (mg/Nm3)

Exceedance Identified

Remarks

VOCs (including methane)

0.00 23.73

680

Nil

Nil

Dust (or TSP)

0.00 0.02

6

Nil

Nil

Odour (including NH3 & H2S) (a)

0.00 113.92

220

Nil

Nil

Note:

(a)   The odour unit is OU/Nm3.

 

Table 4.2        Hourly Average of Parameters Recorded for CHP 1

Parameter

Range of Hourly Average Conc. (mg/Nm3) (a)

Max. Emission Limit (mg/Nm3)

Exceedance

Identified

Remarks

Dust (or TSP)

0 - 2

15

Nil

Nil

Carbon Monoxide

0 - 594

650

Nil

Nil

NOx

0 - 292

300

Nil

Nil

SO2

0 - 28

50

Nil

Nil

VOCs (including methane) (b)

0 1,485

1,500

Nil

Nil

HCl

0 - 2

10

Nil

Nil

HF

0 - 1

1

Nil

Nil

Notes:

(a)   All values refer to an oxygen content in the exhaust gas of 6% and dry basis.

(b)    The VOCs emission limit include methane as biogas is adopted as fuel in the combustion process.  

 

Table 4.3        Hourly Average of Parameters Recorded for CHP 2

Parameter

Range of Hourly Average Conc. (mg/Nm3) (a)

Max. Emission Limit (mg/Nm3)

Exceedance

Identified

Remarks

Dust (or TSP)

0 - 15

15

Nil

Nil

Carbon Monoxide

0 389

650

Nil

Nil

NOx

0 0

300

Nil

Nil

SO2

0 15

50

Nil

Nil

VOCs (including methane) (b)

0 774

1,500

Nil

Nil

HCl

0 0

10

Nil

Nil

HF

0 1

1

Nil

Nil

Notes:

(a)   All values refer to an oxygen content in the exhaust gas of 6% and dry basis.

(b)   The VOCs emission limit include methane as biogas is adopted as fuel in the combustion process.

 

Table 4.4        Hourly Average of Parameters Recorded for CHP 3

Parameter

Range of Hourly Average Conc. (mg/Nm3) (a)

Max. Emission Limit (mg/Nm3)

Exceedances

Identified

Remarks

Dust (or TSP)

0 5

15

Nil

Nil

Carbon Monoxide

0 361

650

Nil

Nil

NOx

0 297

300

Nil

Nil

SO2

0 61

50

Identified (c)

De-sulphurization system tripped / Under Maintenance

VOCs (including methane) (b)

0 1,087

1,500

Nil

Nil

HCl

0 0

10

Nil

Nil

HF

0 0

1

Nil

Nil

Notes:

(a)   All values refer to an oxygen content in the exhaust gas of 6% and dry basis.

(b)   The VOCs emission limit include methane as biogas is adopted as fuel in the combustion process. 

(c)    Date with exceedances on SO2 (number of exceedance on the day) was identified on 23 (2) February 2022.

 

Table 4.5        Hourly Average of Parameters Recorded for ASP

Parameter

Range of Hourly Average Conc. (mg/Nm3) (a)

Max. Emission Limit (mg/Nm3)

Exceedances

Identified

Remarks

Dust (or TSP)

0 11

5

Identified (c)

System unstable (e.g. low efficiency, unstable column temperature )

Carbon Monoxide

0 140

100

Identified (d)

System unstable (e.g. low efficiency, unstable column temperature )

NOx

0 394

200

Identified (e)

System unstable (e.g. low efficiency, unstable column temperature )

SO2

0 12

50

Nil

Nil

VOCs (including methane) (b)

0 147

20

Identified (f)

System unstable (e.g. low efficiency, unstable column temperature )

NH3

0 255

35

Identified (g)

System unstable (e.g. low efficiency, unstable column temperature )

HCl

0 0

10

Nil

Nil

HF

0 1

1

Nil

Nil

Notes:

(a)   All values refer to an oxygen content in the exhaust gas of 11% and dry basis.

(b)   The VOCs emission limit include methane as biogas is adopted as fuel in the combustion process.

(c)    Date with exceedances on dust (number of exceedances on the day) was identified on 8 (1) February 2022.

(d)   Date with exceedances on CO (number of exceedances on the day) was identified on 6 (1) February 2022.

(e)   Dates with exceedances on NOx (number of exceedances on the day) were identified on 1 (3), 2 (3), 3 (11), 4 (7), 5 (1), 6 (2), 8 (3), 9 (1), 10 (3), 11 (1), 12 (1), 13 (2), 14 (2), 18 (1), 21 (8) and 28 (9) February 2022.

(f)     Dates with exceedances on VOC (number of exceedances on the day) were identified on 6 (1), 8 (1) and 9 (1) February 2022.

(g)   Dates with exceedances on NH3 (number of exceedances on the day) were identified on 1 (6), 2 (6), 3 (2), 6 (2), 7 (4), 8 (7), 9 (1), 11 (3), 12 (9), 13 (11), 14 (3), 15 (10), 16 (11), 17 (5), 18 (1), 19 (10) and 20 (12) February 2022.

 

4.2                          Odour

4.2.1     Operation Phase Monitoring

No odour patrol was required to be conducted for this reporting period.

4.3                          Water Quality

4.3.1     Operation Phase Monitoring

Effluent discharge was sampled from the Effluent Storage Tank monthly and from the Petrol Interceptor(s) bi-monthly as stipulated in the operation phase discharge licence.  The results of the discharge samples from the Effluent Storage Tank are recorded in Table 4.6 and the results from the Petrol Interceptors are recorded in Table 4.7 and Table 4.8.  

Table 4.6        Results of the Discharge Sample from the Effluent Storage Tank

Parameters

Discharged Effluent Concentration (mg/L)

Discharge Limit (mg/L)

Compliance with Discharge Limit

Flow Rate (m3/day) (a)

0 - 301

645

Yes

pH (pH units) (b) (d)

7.70 8.25

6-10 (c)

Yes

Suspended Solids (b) (d)

203

800

Yes

Biochemical Oxygen Demand (5 days, 20) (b) (d)

101

800

Yes

Chemical Oxygen Demand (b) (d)

1,440

2,000

Yes

Oil & Grease (b) (d)

<5

40

Yes

Total Nitrogen (b) (d)

108

200

Yes

Total Phosphorus (b) (d)

23.2

50

Yes

Surfactants (total) (b) (d)

<1.0

25

Yes

Notes:

(a)   Parameter not required to be reported in accordance to Section B2 of the Effluent Discharge Licence under the WPCO. 

(b)   Parameters required to be reported in accordance to Section B2 of the Effluent Discharge Licence under the WPCO. 

(c)    Daily Average.

(d)   Effluent sample collected on 11 February 2022.

Table 4.7        Results of the Discharge Sample from the Petrol Interceptor 1

Parameters

Discharged Effluent Concentration (mg/L)

Discharge Limit (mg/L)

Compliance with Discharge Limit

Suspended Solids (b)

<2 (a)

30

Yes

Chemical Oxygen Demand (c)

<5 (a)

80

Yes

Oil & Grease (c)

<5 (a)

20

Yes

Surfactants (total) (b)

<1 (a)

15

Yes

Notes:

(a)   Sampling was carried out on 16 February 2022.

(b)   Parameter not required to be reported in accordance to Section B2 of the Effluent Discharge Licence under the WPCO. 

(c)    Parameters required to be reported in accordance to Section B2 of the Effluent Discharge Licence under the WPCO. 

Table 4.8        Results of the Discharge Sample from the Petrol Interceptor 2

Parameters

Discharged Effluent Concentration (mg/L)

Discharge Limit (mg/L)

Compliance with Discharge Limit

Suspended Solids (b)

<2 (a)

30

Yes

Chemical Oxygen Demand (c)

6 (a)

80

Yes

Oil & Grease (c)

<5 (a)

20

Yes

Surfactants (total) (b)

<1 (a)

15

Yes

Notes:

(a)   Sampling was carried out on 16 February 2022.

(b)   Parameter not required to be reported in accordance to Section B2 of the Effluent Discharge Licence under the WPCO. 

(c)    Parameters required to be reported in accordance to Section B2 of the Effluent Discharge Licence under the WPCO. 

4.4                          Waste Management

4.4.1     Operation Phase Monitoring

Wastes generated from the operation of the Project include chemical waste, wastes generated from pre-treatment process and general refuse ([5]).  Reference has been made to the Monthly Summary Waste Flow Table prepared by the Contractor (see Annex D).  With reference to the relevant handling records and trip tickets of this Project, the quantities of different types of waste generated from the operation of the Project in the reporting month are summarised in Table 4.9

Table 4.9        Quantities of Waste Generated from the Operation of the Project

Month / Year

Chemical Waste

Waste Generated from
Pre-treatment Process

General Refuse

 

Disposal of at CWTC

Disposed of at Landfill (a)

Recycled (b) 

Disposed of at Landfill (a)

Recycled (c) 

February 2022

0 L (d)

260.57 tonnes

0 tonnes

2.42 tonnes (e)

0.00 tonne

Notes:

(a)   Waste generated from pre-treatment process and general refuse other than chemical waste and recyclables were disposed of at NENT Landfill by sub-contractors.

(b)   Among waste generated from pre-treatment process, 0.00 tonne of metals, 0.00 tonnes of papers/ cardboard packing and 0.00 tonne of plastics were sent to recyclers for recycling during the reporting period.

(c)    Among general refuse, 0.00 kg of metals, 0.00 kg of papers/ cardboard packing and 0.00 kg of plastics were sent to recyclers for recycling during the reporting period.

(d)   No chemical waste was generated in February 2022.

(e)   It was assumed that four 240-litre bins filled with 80% of general refuse were collected at each collection.  The general refuse density was assumed to be around 0.15 kg/L.

5                             Site Audit

5.1                          Environmental Site Audit

5.1.1     Operation Phase

The monthly inspection for the operation phase of the Project on 14 February 2022 covered the operation phase environmental site audit.  Joint site inspection was conducted by representatives of the Contractor, IEC, and the MT on 14 February 2022 as required for the operation of the Project.

The audits checked the implementation of the recommended mitigation measures for air quality, landscape and visual, water quality, waste (land contamination) and hazard-to-life stated in the Implementation Schedule (see Annex C).

Key observations during the reporting period are summarised as follows:

14 February 2022

             No particular observation during this inspection.

Other than the above observations, the Contractor has implemented environmental mitigation measures recommended in the approved EIA Report and EM&A Manual. 

5.2                          Landscape and Visual Audit

Inspection of the landscape and visual mitigation measures for the operation phase of the Project was performed on 14 February 2022.  

It was confirmed that the necessary landscape and visual mitigation measures during the operation phase as summarised in Annex C were generally implemented by the Contractor.  No specific observation was found during the joint site inspection on 14 February 2022.  No non-compliance in relation to the landscape and visual mitigation measures was identified during the site audits in this reporting period and therefore no further actions are required.  The ET/MT will keep track of the EM&A programme to check compliance with environmental requirements and the proper implementation of all necessary mitigation measures.

 

 

6                             Environmental Non-conformance and Deficiencies

6.1                         Summary of Environmental Non-Compliance and Deficiencies

Non-compliance of emission limits of SO2 from CHP 3 and Dust, CO, NOx, VOCs and NH3 from ASP were recorded during the reporting period.

The Contractor has reviewed the organic waste treatment processes (i.e. waste reception, waste pre-treatment, anaerobic digesters, and composting processes) and found that they were operated normally during the reporting period.  The Contractor has investigated the de-sulphurization system and the ASP, the potential causes for the exceedance were identified.

The exceedances of SO2 from CHP 3 occurred due to malfunctioning of the control instrument.  Immediate maintenance work was carried out by on-site maintenance team and the issue was fixed on the same day.  The exceedance of Dust, CO, NOx, VOCs and NH3 from ASP occurred due to system instability caused by the blockage of the stripping column and unstable column and thermal oxidizer temperature of the ASP.  The Contractor arranged cleaning of the column packaging during mid-February and further upgrading work in the next reporting month.

The investigation reports of the above exceedance are presented in Annex F.

6.2                         Summary of Environmental Complaint

No complaint was received during the reporting period.

6.3                         Summary of Environmental Summon and Successful Prosecution

No summon/prosecution was received during the reporting period.  The cumulative summons/prosecution log is shown in Annex E.

 

7                             Future Key Issues

7.1                         Key Issues for the Coming Month

Activities to be undertaken for the coming reporting period are:

            Operation of the Project.

            Fine tuning of the CHPs and modification of the ASP to control the air emission. 

 

8                             Conclusions

This EM&A Report presents the EM&A programme undertaken during the reporting period from 1 to 28 February 2022 in accordance with EM&A Manual (Version F) and requirements of EP (FEP-01/395/2010/C). 

For the operation phase, exceedances of the emission limits for the ASP stack monitoring was recorded under normal operating conditions during the reporting period (see Table 8.1).

Table 8.1        Exceedances for Stack Emissions

Stack

Exceedances During the Reporting Period

Cogeneration Units 3 (CHP 3)

    Exceeded emission limit of SO2 on 23 February 2022.

 

Ammonia Stripping Plant (ASP)

    Exceeded emission limit of Dust on 8 February 2022.

    Exceeded emission limit of CO on 6 February 2022.

    Exceeded emission limit of NOx on 1, 2, 3, 4, 5, 6, 8, 9, 10, 11, 12, 13, 14, 18, 21 and 28 February 2022.

    Exceeded emission limit of VOCs on 6, 8 and 9 February 2022.

    Exceeded emission limit of NH3 on 1, 2, 3, 6, 7, 8, 9, 11, 12, 13, 14, 15, 16, 17, 18, 19 and 20 February 2022.

Non-compliance of emission limits of SO2 from CHP 3 and Dust, CO, NOx, VOCs and NH3 from ASP were recorded during the reporting period.  The exceedances of SO2 from CHP 3 occurred due to malfunctioning of the control instrument.  The exceedance of Dust, CO, NOx, VOCs and NH3 from ASP occurred due to system instability caused by the blockage of the stripping column and unstable column and thermal oxidizer temperature of the ASP.      

The environmental control /mitigation measures related to air quality, water quality, waste (including land contamination prevention), hazard-to-life and landscape and visual recommended in the approved EIA Report and the EM&A Manual were properly implemented by the Contractor during the reporting month. 

Monthly landscape and visual monitoring were conducted in the reporting period.  The necessary landscape and visual mitigation measures recommended in the approved EIA Report were generally implemented by the Contractor. 

No complaint/summon/prosecution was received.


 



([1]) As some of the minor items are yet to be closed out in March 2019, the construction phase EM&A programme and Operation Phase EM&A programme were undertaking in parallel in March 2019.

([2])   The CEMS was calibrated in mid-January 2022, the Contractor is pending the calibration report.

([3])    A standby facility.  Only operate when the CHPs are not in operation or when the biogas generated exceeded the utilisation rate of the CHPs.

([4]) The odour patrol route was changed during this reporting period to include sampling points that are frequently visited by visitors and eliminate sampling points that are not visited by visitors.

([5]) Public fill and construction waste may only be generated during maintenance works when there are civil or structural works.