Contents

EXECUTIVE SUMMARY  i

Summary of works undertaken during the reporting month  i

Environmental monitoring and audit progress  i

findings of Environmental site audit  ii

Environmental exceedance/ non-conformance, complaint, summons and prosecution  iii

future key issues  iii

1. Introduction  1

1.1 Purpose of the report  1

1.2 structure of the report  1

2. project information  2

2.1 background  2

2.2 general site description  2

2.3 major activities undertaken  3

2.4 project organisation and management structure  3

2.5 status of environmental approval documents  3

3. ENVIRONMENTAL MONITORING AND AUDIT REQUIREMENTS  4

3.1 Environmental monitoring  4

3.2 SITE AUDIT  8

4. monitoring results  11

4.1 air quality  11

4.2 odour  14

4.3 water quality  15

4.4 waste management  17

5. site audit  18

5.1 environmental site audit  18

5.2 landscape and audit  18

6. environmental non-conformance and deficiencies  20

6.1 summary of environmental non-compliance and deficiencies  20

6.2 summary of environmental complaint  23

6.3 summary of environmental summon and successful prosecution  23

7. future key issues  24

7.1 key issues for the coming month  24

8. conclusions  25

Annex A Project layout

Annex B project organisation chart with contact details

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

Annex G Odour Patrol Result

List of Tables

Table 2.1 Summary of Activities Undertaken in the Reporting Period  3

Table 2.2 Summary of Environmental Licensing, Notification and Permit Status  3

Table 3.1 Sampling and Laboratory Analysis Methodology  4

Table 3.2 Emission Limit for CAPCS Stack  5

Table 3.3 Emission Limit for CHP Stack  5

Table 3.4 Emission Limit for ASP Stack  6

Table 3.5 Emission Limit for Standby Flaring Gas Unit ⁽⁾ 6

Table 3.6 Odour Intensity Level  7

Table 3.7 Action and Limit Levels for Odour Nuisance  7

Table 3.8 Event and Action Plan for Odour Monitoring  7

Table 3.9 Discharge Limits for Effluent from the Outlet Chamber of the Effluent Storage Tank  9

Table 3.10 Discharge Limits for Effluent from the Petrol Interceptors  9

Table 4.1 Hourly Average of Parameters Recorded for CAPCS  11

Table 4.2 Hourly Average of Parameters Recorded for CHP 1  11

Table 4.3 Hourly Average of Parameters Recorded for CHP 2  12

Table 4.4 Hourly Average of Parameters Recorded for CHP 3  12

Table 4.5 Hourly Average of Parameters Recorded for ASP  13

Table 4.6 Hourly Average of Parameters Recorded for the Standby Flaring Gas Unit  13

Table 4.7 Results of the Discharge Sample from the Outlet Chamber of the Effluent Storage Tank  15

Table 4.8 Results of the Discharge Sample from the Petrol Interceptor 1  15

Table 4.9 Results of the Discharge Sample from the Petrol Interceptor 2  16

Table 4.10     Results of the Discharge Sample from the OUtlet Chamber of the Effluent Storage Tank (July 2024) 16

Table 4.11 Quantities of Waste Generated from the Operation of the Project  17

Table 6.1 Implementation of Measures/ Actions to Address any Exceedances  20

Table 8.1 Exceedances for Stack Emissions  25

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 111^th Monthly Environmental Monitoring and Audit (EM&A) report presenting the EM&A works carried out during the period from 1 to 31 August 2024 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;

· Ongoing repair works for front roller shutter for Receiving Bay 2 & 3; and

· ASP column 1 Cleaning.

Environmental monitoring and audit progress

air Quality monitoring

Non-compliance of emission limits of Total Odour from CAPCS; NO_x and SO₂ from CHP1; NO_x from CHP2; NO_x, SO₂, NH₃, and HCl from the ASP; and VOCs and HF from the Standby Gas Flaring Unit were recorded during the reporting period.

Odour Patrol

During the reporting period, one (1) Action Level exceedance (detection of Odour Intensity Level 2) was recorded during the independent odour patrol at Location 3 (Biogas Tank Valve Holder) on 9 August 2024.

In accordance with the Event and Action Plan for Odour Monitoring (see Table 3.8), an ad-hoc odour patrol was arranged on 15 August 2024 to confirm the findings, which identified a further three (3) Level 2 exceedances and one (1) Level 3 exceedance, constituting an exceedance of the Limit Level under the EM&A Manual.

Water Quality

All analytes from the outlet chamber of the effluent storage tank sampled on 14 August 2024 were recorded to be in compliance with discharge limits during the reporting period. Additionally, the laboratory report for the Treated Effluent Sample collected on 30 July 2024 was still pending as at the date of submission of the July 2024 Monthly EM&A report. Having now received this lab report, all analytes were recorded to be in compliance with discharge limits during the July 2024 reporting period.

All analytes from the Petrol Interceptor 1 sampling were recorded to be in compliance with discharge limits during the reporting period. Petrol Interceptor 2 sample was collected on 28 August 2024, however the laboratory report and results are still pending as at the date of this report submission. The outstanding Petrol Interceptor 2 data will be presented in the subsequent monthly report once the lab result has been received.

Waste Management

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

1,200L of chemical waste (spent lube oil) were disposed of at CWTC in August 2024.

1,160.32 tonnes of waste generated from pre-treatment process from the operation of the Project were disposed of at landfill. Among the waste generated from pre-treatment process from the operation of the Project, 0.000 tonnes of metals, 0.000 tonnes of papers/cardboard packing and 0.000 tonnes of plastics were sent to recyclers for recycling during the reporting period.

Around 3.110 tonnes of general refuse from the operation of the Project were disposed of at landfill. Among the general refuse from the operation of the Project, 0.001 tonnes of metals, 0.035 tonnes of papers/cardboard packing and 0.002 tonnes 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 Monitoring Team (MT). The Independent Environmental Checker (IEC) was also present at the joint inspections on 19 August 2024.

During the site inspection, it was noted that both internal and external doors of the Tipping Hall of Bay #2 and Bay #3 for keeping negative pressure of the waste storage area were found to be broken. The waste storage area was opened and suspected to be not operating under negative pressure. Odour was observed around the area. Additionally, orange/ brown-coloured stains were observed on the ground and exterior wall of the Main Building in a temporary chemical storage area. Various chemicals (i.e. FeCl₃ and H₂SO₄) in containers were observed. The chemicals were all observed marked with chemical labels and secondary containment, however it was noted that due to the heavy rain, the secondary containments were overflowing onto the ground surface and the front drain.

Both of these observations are considered as possible non-compliances under the EM&A Manual, and the MT informed the IEC accordingly via email on 20 August 2024. The IEC also informed the authority via email on 21 August 2024. The Investigative Reports (IRs) of these possible non-compliances are under review as at the date of this EM&A report submission and will be presented once finalised in the subsequent monthly report.

Apart from the above, 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, complaint, summons and prosecution

Exceedances for the air emission limits for CAPCS, CHPs, ASP, and Standby Gas Flaring Unit, as well as exceedances against the Action Level and Limit Level for odour nuisance were recorded during the reporting period.

No complaint was received during the reporting period.

future key issues

Activities to be undertaken in the next reporting month include:

· Operation of the Project; and

· Ongoing repair works for front roller shutter for Receiving Bay 2 & 3.

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 111^th EM&A report which summarises the monitoring results and audit findings for the EM&A programme during the reporting period from 1 to 31 August 2024.

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 165.26 tonnes and treated an average of 127.83 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 de-sulphurisation, the standby flare, the CHPs, the ASP, and the biological wastewater treatment plant (165.26 t/d SSOW received);

· Ongoing repair works for front roller shutter for Receiving Bay 2 & 3; and

· ASP column 1 Cleaning.

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 is 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 (CHPs) and the ammonia stripping plant (ASP) during the commissioning and operation phase. The most recent sensor calibration for the CAPCS system was carried out on 15 January 2024 for VOCs and 19 January 2024 for H₂S. The most recent span calibrations for the CEMS systems (CHP1, CHP2, CHP3, and ASP) were carried out on 28 May 2024. Annual CAPCS calibration was carried out from 10 to 12 October 2023.

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	· ASP
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/Nm^3) ^(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/Nm^3

Table 3.3  Emission Limit for CHP Stack

Parameter	Maximum Emission Level (mg/Nm^3) ^(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/Nm^3) ^(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 ([2])

Parameter	Maximum Emission Level (mg/Nm^3) ^(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 ([3]).

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 by Person-in-charge of Odour Monitoring:	Action by 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 weeks; 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 is to be sampled monthly from the outlet chamber of the Effluent Storage Tank, while effluent discharge is 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 Outlet Chamber of the Effluent Storage Tank

Parameter	Discharge Limit (mg/L)
Flow Rate (m^3/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 with Section B2 of the Effluent Discharge Licence under the WPCO. (b) Parameters required to be monitored and reported by the Contractor in accordance with Section B2 of the Effluent Discharge Licence under the WPCO. (c) Range.

Table 3.10    Discharge Limits for Effluent from the Petrol Interceptors

Parameter	Discharge Limit (mg/L)
Flow Rate (m^3/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 4.8 and Table 4.9. (b) Parameter not required to be reported in accordance with Section B2 of the Effluent Discharge Licence under the WPCO. (c) Parameters required to be reported in accordance with 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 OPERATION PHASE MONITORING

The concentrations of concerned air pollutants emitted from the stacks of the CAPCS, CHPs, ASP, and the Standby Flaring Gas Unit during the reporting period are monitored on-line by the continuous environmental monitoring system (CEMS). During the reporting period, the Standby Flaring Gas Unit operated on 23 August 2024.

With reference to the emission limits shown in Tables 3.2, 3.3, 3.4, and 3.5, the hourly average concentrations and the number of exceedances of the concerned air emissions monitored for the CAPCS, CHPs, ASP and the Standby Flaring Gas Unit during this reporting period are presented in Tables 4.1 to 4.6. 

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/Nm^3)	Emission Limit (mg/Nm^3)	Exceedance Identified	Remarks
VOCs (including methane) ^(a)	0 – 2.94	680	Nil	Nil
Dust (or TSP)	0 – 0	6	Nil	Nil
Odour (including NH3 & H2S) ^(b)	0 – 964.56	220	Identified ^(c)	Pending ^(d)
Notes: (a) The VOCs emission limit includes methane as biogas is adopted, as fuel in the combustion process. (b) The odour unit is ou/Nm^3. (c) Dates with Odour exceedances (number of exceedances on that day) were identified on 26(13), 27(6), 28(12), 29(21), 30(9), and 31(6) August 2024. (d) Exceedance explanations remain pending from the Contractor as at the date of submission of this EM&A report; updates will be provided in the subsequent monthly EM&A report once received.

Table 4.2  Hourly Average of Parameters Recorded for CHP 1

Parameter	Range of Hourly Average Conc. (mg/Nm^3)^(a)	Emission Limit (mg/Nm^3)	Exceedance Identified	Remarks
Dust (or TSP)	0 – 7	15	Nil	Nil
Carbon Monoxide	0 – 84	650	Nil	Nil
NOx	0 – 547	300	Identified ^(c)	System unstable (e.g. low efficiency)
SO2	0 – 74	50	Identified ^(d)	System unstable (e.g. low efficiency)
VOCs (including methane) ^(b)	0 – 882	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. (c) Dates with NOx exceedances (number of exceedances on that day) were identified on 1(21), 2(23), 3(24), 4(24), 5(23), 6(24), 7(24), 8(24), 9(24), 10(24), 11(18), 12(24), 13(24), 14(24), 15(24), 16(24), 17(24), 18(24), 19(24), 20(24), 21(21), 22(24), 23(24), 24(24), 25(24), 26(24), 27(24), 28(24), 29(24), 30(24), and 31(23) August 2024. (d) Dates with SO2 exceedances (number of exceedances on that day) were identified on 8(6), 9(21), 10(24), 11(10), 12(13), 13(14), 14(20), 16(11), 17(8), 18(13), 19(15), 28(6), 29(10), and 30(4) August 2024.

Table 4.3  Hourly Average of Parameters Recorded for CHP 2

Parameter	Range of Hourly Average Conc. (mg/Nm^3) ^(a)	Emission Limit (mg/Nm^3)	Exceedance Identified	Remarks
Dust (or TSP)	0 – 8	15	Nil	Nil
Carbon Monoxide	0 – 60	650	Nil	Nil
NOx	0 – 461	300	Identified ^(c)	System unstable (e.g. low efficiency)
SO2	0 – 48	50	Nil	Nil
VOCs (including methane) ^(b)	0 – 569	1,500	Nil	Nil
HCl	0 – 1	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. (c) Dates with NOx exceedances (number of exceedances on that day) were identified on 1(8), 2(21), 3(18), 4(23), 5(15), 6(9), 8(17), 9(24), 10(18), 11(2), 12(7), 13(6), 14(10), 15(1), 20(2), 21(5), 22(13), 23(12), 24(2), 25(1), 27(2), and 28(4) August 2024.

Table 4.4  Hourly Average of Parameters Recorded for CHP 3

Parameter	Range of Hourly Average Conc. (mg/Nm^3) ^(a)	Emission Limit (mg/Nm^3)	Exceedance Identified	Remarks
Dust (or TSP)	0 – 0	15	Nil	Nil
Carbon Monoxide	0 – 0	650	Nil	Nil
NOx	0 – 0	300	Nil	Nil
SO2	0 – 0	50	Nil	Nil
VOCs (including methane) ^(b)	0 – 0	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.

Table 4.5  Hourly Average of Parameters Recorded for ASP

Parameter	Range of Hourly Average Conc. (mg/Nm^3) ^(a)	Emission Limit (mg/Nm^3)	Exceedance Identified	Remarks
Dust (or TSP)	0 – 5	5	Nil	Nil
Carbon Monoxide	0 – 96	100	Nil	Nil
NOx	0 – 970	200	Identified ^(c)	System unstable (e.g. low efficiency)
SO2	0 – 210	50	Identified ^(d)	System unstable (e.g. low efficiency)
VOCs (including methane) ^(b)	0 – 20	20	Nil	Nil
NH3	0 – 318	35	Identified ^(e)	System unstable (e.g. low efficiency)
HCl	0 – 26	10	Identified ^(f)	System unstable (e.g. low efficiency)
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. (c) Dates with NOx exceedances (number of exceedances on that day) were identified on 1(23), 2(19), 3(5), 4(4), 6(8), 7(21), 8(17), 9(3), 10(12), 11(1), 12(8), 13(13), 14(10), 15(5), 16(9), 17(10), 18(7), 19(11), 20(11), 21(5), 22(8), 23(14), 24(13), 25(1), 26(2), 27(15), 28(15), 29(11), 30(23), and 31(23) August 2024. (d) Dates with SO2 exceedances (number of exceedances on that day) were identified on 6(9), 7(24), 8(18), 9(3), 10(24), 11(24), 12(21), 13(19), 14(24), 15(12), 16(18), 17(23), 18(24), 19(20), 20(21), 21(15), 22(23), 23(8), 28(14), 29(24), and 30(21) August 2024. (e) Dates with NH3 exceedances (number of exceedances on that day) were identified on 1(1), 2(5), 3(2), 4(5), 5(22), 6(20), 7(16), 8(18), 10(2), 11(8), 12(13), 13(6), 14(4), 15(8), 16(7), 17(9), 18(10), 19(9), 20(8), 21(7), 22(2), 23(7), 24(6), 25(1), 26(2), 27(15), 28(7), 29(16), 30(1), and 31(1) August 2024. (f) Dates with HCl exceedances (number of exceedances on that day) were identified on 6(2), 7(1), 8(1), 11(1), and 13(1) August 2024.

Table 4.6  Hourly Average of Parameters Recorded for the Standby Flaring Gas Unit

Parameter	Range of Hourly Average Conc. (mg/Nm^3) ^(a) (c)	Emission Limit (mg/Nm^3)	Exceedance Identified	Remarks
Dust (or TSP)	0 – 0	5	Nil	Nil
Carbon Monoxide	0 – 17	100	Nil	Nil
NOx	0 – 3	200	Nil	Nil
SO2	0 – 4	50	Nil	Nil
VOCs (including methane) ^(b)	0 – 37	20	Identified ^(c)	Unstable operation (low temperature)
HCl	0 – 0	10	Nil	Nil
HF	0 – 2	1	Identified ^(d)	Unstable operation (low temperature)
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 VOCs exceedances (number of exceedances on that day) was identified on 23(1) August 2024. (d) Date with HF exceedances (number of exceedances on that day) was identified on 23(1) August 2024.

4.2 odour

4.2.1 OPERATION PHASE MONITORING

Odour patrol was conducted by the independent odour patrol team of ALS Technichem (HK) Pty Ltd on 9 August 2024. According to the EM&A Manual, it is considered an Action Level exceedance if the odour intensity recorded by the panellists is Level 2 or above. During the reporting period, one (1) Action Level exceedance (detection of Odour Intensity Level 2) was recorded during the independent odour patrol at Location 3 (Biogas Tank Valve Holder) on 9 August 2024.

In accordance with the Event and Action Plan (EAP) for Odour Monitoring (see Table 3.8), an ad-hoc odour patrol was arranged on 15 August 2024 to confirm the findings, which identified a further three (3) Level 2 exceedances and one (1) Level 3 exceedance, constituting an exceedance of the Limit Level under the EM&A Manual. The Level 3 odour exceedance was identified at Location 2 (Tipping Hall, morning patrol), while the Level 2 odour exceedances were identified at Location 1 (Tipping Hall, morning patrol), Location 2 (Tipping Hall, afternoon patrol), and Location 3 (Biogas Tank Valve Holder, afternoon patrol). The source of these odour exceedances identified by the Contractor was the open doors of the Tipping Hall/ waste storage area, whose roller shutter doors had malfunctioned. The odour patrol results for both regular and ad-hoc odour monitoring are shown in Annex G.

As remedial actions, the Contractor installed 2 pieces of canvas to replace the broken shutter doors of Bay #2 and Bay #3 and also continued with maintenance of the broken shutter doors. Installation of the inner shutter doors of Bay #2 and Bay #3 commenced on 19 August 2024 and completed on 5 September 2024. The repaired shutter doors are expected to be fully completed in October 2024. Finally, the Contractor also added additional fans with artificial flavouring to help mitigate the odour.

4.3 water quality

4.3.1 OPERATION PHASE MONITORING

Effluent discharge is sampled from the outlet chamber of 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 outlet chamber of the Effluent Storage Tank collected on 14 August 2024 are recorded in Table 4.7 and the results from the Petrol Interceptors are recorded in Tables 4.8 – 4.9. Sample from Petrol Interceptor 2 was collected on 28 August 2024, but the laboratory report and result remain pending as at the date of this EM&A report submission. The outstanding Petrol Interceptor 2 data will be presented in the subsequent monthly report once the lab results has been received.

The laboratory report for the Treated Effluent Sample collected on 30 July 2024 was still pending as at the date of submission of the July 2024 Monthly EM&A report. Having now been received, these results are presented below in Table 4.10.

Table 4.7  Results of the Discharge Sample from the Outlet Chamber of the Effluent Storage Tank

Parameter	Discharged Effluent Concentration (mg/L)	Discharge Limit (mg/L)	Compliance with Discharge Limit
Flow Rate (m^3/day)^(a)	336 ^(e) (f)	645	Yes
pH (pH units)^(b)	7.9 – 8.5 ^(e)	6 - 10^(c)	Yes
Suspended Solids ^(b) (d)	98 ^(d)	800	Yes
Biochemical Oxygen Demand (5 days, 20°) ^(b) (d)	30 ^(d)	800	Yes
Chemical Oxygen Demand ^(b) (d)	768 ^(d)	2,000	Yes
Oil & Grease ^(b) (d)	<5 ^(d)	40	Yes
Total Nitrogen ^(b) (d)	84.7 ^(d)	200	Yes
Total Phosphorus ^(b) (d)	29.2 ^(d)	50	Yes
Surfactants (total)^(b) (d)	<1.0 ^(d)	25	Yes
Notes: (a) Parameter not required to be reported in accordance with Section B2 of the Effluent Discharge Licence under the WPCO. (b) Parameters required to be reported in accordance with Section B2 of the Effluent Discharge Licence under the WPCO. (c) Daily Range. (d) Effluent sample collected on 14 August 2024. (e) Data collected daily. (f) Maximum daily volume of wastewater discharged during the month.

Table 4.8  Results of the Discharge Sample from the Petrol Interceptor 1

Parameter	Discharged Effluent Concentration (mg/L)	Discharge Limit (mg/L)	Compliance with Discharge Limit
Suspended Solids^(b)	4 ^(a)	30	Yes
Chemical Oxygen Demand ^(c)	9 ^(a)	80	Yes
Oil & Grease ^(c)	<5 ^(a)	20	Yes
Surfactants (total)^(b)	<1.0 ^(a)	15	Yes
Notes: (a) Sample collected on 21 August 2024. (b) Parameter not required to be reported in accordance with Section B2 of the Effluent Discharge Licence under the WPCO. (c) Parameters required to be reported in accordance with Section B2 of the Effluent Discharge Licence under the WPCO.

Table 4.9  Results of the Discharge Sample from the Petrol Interceptor 2

Parameter	Discharged Effluent Concentration (mg/L)	Discharge Limit (mg/L)	Compliance with Discharge Limit
Suspended Solids^(b)	pending ^(a)	30	-
Chemical Oxygen Demand ^(c)	pending ^(a)	80	-
Oil & Grease ^(c)	pending ^(a)	20	-
Surfactants (total)^(b)	pending ^(a)	15	-
Notes: (a) Sample collected on 28 August 2024; the pending data will be presented in the subsequent monthly report once the lab results has been received. (b) Parameter not required to be reported in accordance with Section B2 of the Effluent Discharge Licence under the WPCO. (c) Parameters required to be reported in accordance with Section B2 of the Effluent Discharge Licence under the WPCO.

Table 4.10 Results of the Discharge Sample from the Outlet Chamber of the Effluent Storage Tank (July 2024)

Parameter	Discharged Effluent Concentration (mg/L)	Discharge Limit (mg/L)	Compliance with Discharge Limit
Flow Rate (m^3/day)^(a)	255 ^(e) (f)	645	Yes
pH (pH units)^(b)	8.0 – 8.5 ^(e)	6 - 10^(c)	Yes
Suspended Solids ^(b) (d)	63 ^(d)	800	Yes
Biochemical Oxygen Demand (5 days, 20°) ^(b) (d)	9 ^(d)	800	Yes
Chemical Oxygen Demand ^(b) (d)	339 ^(d)	2,000	Yes
Oil & Grease ^(b) (d)	<5 ^(d)	40	Yes
Total Nitrogen ^(b) (d)	85.8 ^(d)	200	Yes
Total Phosphorus ^(b) (d)	32.6 ^(d)	50	Yes
Surfactants (total)^(b) (d)	<1.0 ^(d)	25	Yes
Notes: (a) Parameter not required to be reported in accordance with Section B2 of the Effluent Discharge Licence under the WPCO. (b) Parameters required to be reported in accordance with Section B2 of the Effluent Discharge Licence under the WPCO. (c) Daily Range. (d) Effluent sample collected on 30 July 2024; lab result was pending as at date of previous EM&A report submission and is now presented above. (e) Data collected daily. (f) Maximum daily volume of wastewater discharged during the month.

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 ([4]). 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 4.11.

Table 4.11    Quantities of Waste Generated from the Operation of the Project

Month / Year	Chemical Waste	Waste Generated from Pre-treatment Process		General Refuse
	Disposed of at CWTC	Disposed of at Landfill ^(a)	Recycled ^(b)	Disposed of at Landfill ^(a)	Recycled ^(c)
August 2024	1,200 L ^(d)^(e)	1,160.32 tonnes	0.000 tonnes	3.110 tonnes^(e)	0.038 tonnes
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, 0.000 tonnes of metals, 0.000 tonnes of papers/cardboard packing and 0.000 tonnes of plastics were sent to recyclers for recycling during the reporting period. (c) Among general refuse, 0.001 tonnes of metals, 0.035 tonnes of papers/cardboard packing and 0.002 tonnes of plastics were sent to recyclers for recycling during the reporting period. (d) 1,200L of chemical waste (spent lube oil) was disposed of at CWTC in August 2024. (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 19 August 2024 covered the operation phase environmental site audit. Joint site inspection was conducted by representatives of the Contractor, IEC, and the MT 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:

19 August 2024

· During the site audit, it was noted that both internal and external doors of the Tipping Hall of Bay #2 and Bay #3 for keeping negative pressure of the waste storage area were found to be broken. The waste storage area was opened and suspected not operating under negative pressure. Odour was observed around the area.

This observation was considered as a potential non-compliance, and the MT informed the IEC accordingly via email on 20 August 2024. The IEC also informed the authority via email on 21 August 2024. The Investigative Report of this potential non-compliance is under review as at the date of this EM&A report submission and will be presented once finalised in the subsequent monthly report.

· During the site audit, orange/ brown-coloured stains were observed on the ground and exterior wall of the Main Building in a temporary chemical storage area. Various chemicals (i.e. FeCl₃ and H₂SO₄) in containers were observed. The chemicals were all observed marked with chemical labels and secondary containment, however it was noted that due to the heavy rain, the secondary containments were overflowing onto the ground surface and the front drain. The orange/ brown-coloured staining was suspected to be caused by the iron-containing chemicals (FeCl₃) and/ or low pH due to the acid (H₂SO₄). Caps of the chemical tanks were not closed. Overflow occurred during heavy rain.

This observation was considered as a potential non-compliance, and the MT informed the IEC accordingly via email on 20 August 2024. The IEC also informed the authority via email on 21 August 2024. The Investigative Report of this potential non-compliance is under review as at the date of this EM&A report submission and will be presented once finalised in the subsequent monthly report.

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 audit

Inspection of the landscape and visual mitigation measures for the operation phase of the Project was performed on 19 August 2024.

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 19 August 2024. 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 Total Odour from CAPCS; NO_x and SO₂ from CHP1; NO_x from CHP2; NO_x, SO₂, NH₃, and HCl from the ASP; and VOCs and HF from the Standby Gas Flaring Unit 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-sulphurisation system, CHPs, and the ASP; the potential causes for the exceedances were identified. The exceedances of VOCs and HF from the Standby Gas Flaring Unit occurred due to unstable operation (low temperature) required the use of the flare. The exceedances of Total Odour from CAPCS remain under investigation by the Contractor and will be updated in the subsequent monthly EM&A report.

One (1) Action Level exceedance (detection of Odour Intensity Level 2) was recorded during the independent odour patrol at Location 3 (Biogas Tank Valve Holder) on 9 August 2024.

An ad-hoc odour patrol was arranged on 15 August 2024 to confirm the findings, which identified a further three (3) Level 2 exceedances and one (1) Level 3 exceedance, constituting an exceedance of the Limit Level under the EM&A Manual. The Level 3 odour exceedance was identified at Location 2 (Tipping Hall, morning patrol), while the Level 2 odour exceedances were identified at Location 1 (Tipping Hall, morning patrol), Location 2 (Tipping Hall, afternoon patrol, and Location 3 (Biogas Tank Valve Holder, afternoon patrol).

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

An overview of the various measures/ actions to be taken by the Contractor to address any exceedances is summarised in Table 6.1.

Table 6.1  Implementation of Measures/ Actions to Address any Exceedances

Monitoring Location	Measures/ Actions to Address any Exceedances	Implementation Timeline & Status
Centralised Air Pollution Unit (CAPCS)	· To address the exceedances for Total Odour (ou/Nm^3) recorded in January 2024 – February 2024 and August 2024, the Contractor ordered a new H2S / ORP sensor to replace the faulty one which was installed on 23 May 2024. · The cleaning of the ventilation pumps was conducted in April 2024.	· All measures have been implemented ^(a).
Cogeneration Unit 1 (CHP 1)	· To address the ongoing NOx exceedances recorded from October 2023 – August 2024, the Contractor ordered 3 new cylinder heads from the supplier to replace the old ones and improve performance which were installed in May 2024. · To address the SO2 exceedances recorded from October 2023 – June 2024 and August 2024, SO2 sampling and testing was completed by a third-party laboratory that showed lower SO2 values than those reported by the CEMS. The lower values measured by the laboratory was attributed to methane gas interference. Based on this study, it was proposed to implement a correction factor in the CEMS to adjust for the methane gas interference. After review by MT and IEC, the correction factor was implemented in May 2024. · To address the HCl exceedances recorded from October 2023 – April 2024 and July 2024, the Contractor implemented in May 2024 fine tuning measures such as reviewing the ignition temperature curve, spark plug condition check and adjusting the intake & exhaust valves on the cylinder to reduce the fluctuations in HCl emissions and keep within the permissible limit. · A CHP expert from Europe visited the ORRC1 facility from 20-24 May to review the performance of the CHPs. · The Contractor will receive additional advanced training from the manufacturer for the operation and maintenance of the equipment. · The Contractor will continue additional maintenance works for the CHPs during the coming month.	· The new cylinder heads were installed in May 2024, and further works are ongoing. · The updated SO2 correction factor was implemented on 17 May 2024. · The fine-tuning measures were implemented during May 2024. · The CHP expert visited in from 20-24 May 2024 and report submitted in June 2024; Contractor began reviewing the report in July 2024. · A further tuning was carried out for the CHP on 12 August 2024. · The Contractor will receive additional training in December 2024.
Cogeneration Unit 2 (CHP 2)	· To address the ongoing NOx exceedances recorded from October 2023 – August 2024, fine tuning of CHP 2 such as reviewing the ignition temperature curve, spark plug condition check and adjusting the intake & exhaust valves on the cylinder was conducted to reduce the fluctuations in NOx emissions and to keep within the permissible limit. · To address the SO2 exceedances recorded from October 2023 – April 2024, SO2 sampling and testing was completed by a third-party laboratory that showed lower SO2 values than those reported by the CEMS. The lower values measured by the laboratory was attributed to methane gas interference. Based on this study, it was proposed to implement a correction factor in the CEMS to adjust for the methane gas interference. After review by MT and IEC, the correction factor was implemented in May 2024. · To address the HCl exceedances recorded from November 2023 and April 2024, the Contractor implemented fine tuning measures such as reviewing the ignition temperature curve, spark plug condition check and adjusting the intake & exhaust valves on the cylinder to reduce the fluctuations in HCl emissions and keep within the permissible limit. · A CHP expert from Europe visited the ORRC1 facility in May 2024 to review the performance of the CHPs. · The Contractor will receive additional advanced training from the manufacturer for the operation and maintenance of the equipment. · The Contractor will continue additional maintenance works for the CHPs during the coming month.	· The fine-tuning measures were implemented in May 2024, and further works are ongoing. · The updated SO2 correction factor was implemented on 17 May 2024. · The CHP expert visited in from 20-24 May 2024 and report submitted in June 2024; Contractor began reviewing the report in July 2024. · A further tuning was carried out for the CHP on 12 August 2024. · The Contractor will receive additional training in December 2024.
Cogeneration Unit 3 (CHP 3)	· To address the ongoing NOx exceedances, fine tuning measures of CHP 3 were implemented such as reviewing the ignition temperature curve, spark plug condition check and adjusting the intake & exhaust valves on the cylinder is being conducted to reduce the fluctuations in NOx emissions and to keep within the permissible limit. · To address the SO2 exceedances recorded from October 2023 – April 2024, SO2 sampling and testing was completed by a third-party laboratory that showed lower SO2 values than those reported by the CEMS. The lower values measured by the laboratory was attributed to methane gas interference. Based on this study, it was proposed to implement a correction factor in the CEMS to adjust for the methane gas interference. After review by MT and IEC, the correction factor was implemented in May 2024. · A CHP expert from Europe visited the ORRC1 facility in May 2024 to review the performance of the CHPs. · The Contractor will receive additional advanced training from the manufacturer for the operation and maintenance of the equipment. · CHP 3 was not operated during August 2024 and had no exceedances for the month. · The Contractor will continue additional maintenance works for the CHPs during the coming month.	· The fine-tuning measures were implemented in May 2024, and further works are ongoing. · The updated SO2 correction factor was implemented on 17 May 2024. · The CHP expert visited in from 20-24 May 2024 and report submitted in June 2024; Contractor began reviewing the report in July 2024. · A further tuning was carried out for the CHP on 12 August 2024. · The Contractor will receive additional training in December 2024.
Ammonia Stripping Plant (ASP)	· To address the ongoing NOx exceedances recorded from October 2023 – August 2024, the Contractor conducted an overhaul of the ASP and arranged for a visit by the supplier to improve the reliability and performance of the system. · To address the ongoing SO2 exceedances recorded from October 2023 – August 2024, SO2 sampling and testing was completed by a third-party laboratory that showed lower SO2 values than those reported by the CEMS. The lower values measured by the laboratory was attributed to methane gas interference. Based on this study, it was proposed to implement a correction factor in the CEMS to adjust for the methane gas interference. After review by MT and IEC, the correction factor was implemented in May 2024. · To address the ongoing NH3 exceedances recorded from October 2023 – August 2024, the Contractor conducted an overhaul of the ASP and arranged for a visit by the supplier. · To address the HCl exceedances recorded from October 2023 – May 2024 and August 2024, the Contractor conducted an overhaul of the ASP and arranged for a visit by the supplier. · To address the ongoing exceedances and loss of control of the louvres for the Thermal Combustion Unit (TCU), the Contractor has approached the Supplier to remedy the situation and is exploring options in the interim to control the system until the automatic situation is rectified in September 2024.	· The overhaul of the ASP was completed 6 May 2024. · The supplier could not visit in June 2024 as planned and will be rescheduled.  · The updated SO2 correction factor was implemented on 17 May 2024. · The automatic situation of the TCU louvres will be rectified by September 2024. · The Contractor is communicating with the supplier and will arrange the visit with the supplier to inspect the ASP at their earliest convenience.
Notes: (a) Further measures to address the ongoing Total Odour exceedances are pending as at the date of submission of this EM&A report; updates will be provided in the subsequent monthly EM&A report once received.

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; and

· Ongoing repair works for front roller shutter for Receiving Bay 2 & 3.

8. conclusions

This EM&A Report presents the EM&A programme undertaken during the reporting period from 1 to 31 August 2024 in accordance with the 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 CAPCS, CHPs, and the ASP were recorded under normal operating conditions during the reporting period as well as for the Standby Gas Flaring Unit under emergency operating conditions (see Table 8.1).

Table 8.1  Exceedances for Stack Emissions

Stack	Exceedances During the Reporting Period
CAPCS	· Exceeded emission limit of Total Odour on 26, 27, 28, 29, 30, and 31 August 2024.
Cogeneration Unit 1 (CHP 1)	· Exceeded emission limit of NOx on 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, and 31 August 2024. · Exceeded emission limit of SO2 on 8, 9, 10, 11, 12, 13, 14, 16, 17, 18, 19, 28, 29, and 30 August 2024.
Cogeneration Unit 2 (CHP 2)	· Exceeded emission limit of NOx on 1, 2, 3, 4, 5, 6, 8, 9, 10, 11, 12, 13, 14, 15, 20, 21, 22, 23, 24, 25, 27, and 28 August 2024.
Cogeneration Unit 3 (CHP 3)	· CHP 3 was not operated during August 2024 and had no exceedances for the month.
Ammonia Stripping Plant (ASP)	· Exceeded emission limit of NOx on 1, 2, 3, 4, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, and 31 August 2024. · Exceeded emission limit of SO2 on 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 28, 29, and 30 August 2024. · Exceeded emission limit of NH3 on 1, 2, 3, 4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, and 31 August 2024. · Exceeded emission limit of HCl on 6, 7, 8, 11, and 13 August 2024.
Standby Gas Flaring Unit	· Exceeded emission limit of VOCs on 23 August 2024. · Exceeded emission limit of HF on 23 August 2024.

Non-compliance of emission limits of Total Odour from CAPCS, NO_x and SO₂ from CHP1; NO_x from CHP2; NO_x, SO₂, NH₃, and HCl from the ASP; and VOCs and HF from the Standby Gas Flaring Unit were recorded during the reporting period. The exceedances of NO_x and SO₂ from the CHPs, as well as NO_x, SO₂, NH₃, and HCl from the ASP occurred due to system instability. The exceedances of VOCs and HF from the Standby Gas Flaring Unit occurred due to unstable operation (low temperature). The exceedances of Total Odour from CAPCS remain under investigation by the Contractor and will be updated in the subsequent monthly EM&A report.

One (1) Action Level exceedance (detection of Odour Intensity Level 2) was recorded during the independent odour patrol at Location 3 (Biogas Tank Valve Holder) on 9 August 2024.

An ad-hoc odour patrol was arranged on 15 August 2024 to confirm the findings, which identified a further three (3) Level 2 exceedances and one (1) Level 3 exceedance, constituting an exceedance of the Limit Level under the EM&A Manual. The Level 3 odour exceedance was identified at Location 2 (Tipping Hall, morning patrol), while the Level 2 odour exceedances were identified at Location 1 (Tipping Hall, morning patrol), Location 2 (Tipping Hall, afternoon patrol, and Location 3 (Biogas Tank Valve Holder, afternoon patrol). The source of these odour exceedances identified by the Contractor was the open doors of the Tipping Hall/ waste storage area, whose roller shutter doors had malfunctioned.

As remedial actions, the Contractor installed 2 pieces of canvas to replace the broken shutter doors of Bay #2 and Bay #3 and also continued with maintenance of the broken shutter doors. Installation of the inner shutter doors of Bay #2 and Bay #3 commenced on 19 August 2024 and completed on 5 September 2024. The repaired shutter doors are expected to be fully completed in October 2024. Finally, the Contractor also added additional fans with artificial flavouring to help mitigate the odour.

All analytes from the outlet chamber of the effluent storage tank sampled on 14 August 2024,  were recorded to be in compliance with discharge limits during the reporting period. Additionally, the laboratory report for the Treated Effluent Sample collected on 30 July 2024 was still pending as at the date of submission of the July 2024 Monthly EM&A report. Having now been received, all analytes were recorded to be in compliance with discharge limits during the reporting period.

All analytes from the Petrol Interceptor 1 sampling were recorded to be in compliance with discharge limits during the reporting period. Petrol Interceptor 2 sample was collected on 28 August 2024, however the laboratory report and results are still pending as at the date of this report submission. The outstanding Petrol Interceptor 2 data will be presented in the subsequent monthly report once the lab results has been received.

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-sulphurisation system, CHPs, and the ASP; the potential causes for the exceedance were identified. The exceedances at the Standby Gas Flaring Unit occurred due to unstable operation (low temperature). The exceedances of Total Odour from CAPCS remain under investigation by the Contractor and will be updated in the subsequent monthly EM&A report.

During the monthly site audit on 19 August 2024, it was noted that both internal and external doors of the Tipping Hall of Bay #2 and Bay #3 for keeping negative pressure of the waste storage area were found to be broken. The waste storage area was opened and suspected not operating under negative pressure. Odour was observed around the area. This observation was considered as a potential non-compliance, and the MT informed the IEC accordingly via email on 20 August 2024. The IEC also informed the authority via email on 21 August 2024. The Investigative Report of this potential non-compliance is under review as at the date of this EM&A report submission and will be presented once finalised in the subsequent monthly report.

Also during the monthly site audit, orange/ brown-coloured stains were observed on the ground and exterior wall of the Main Building in a temporary chemical storage area. Various chemicals (i.e. FeCl₃ and H₂SO₄) in containers were observed. The chemicals were all observed marked with chemical labels and secondary containment, however it was noted that due to the heavy rain, the secondary containments were overflowing onto the ground surface and the front drain. The orange/ brown-coloured staining was suspected to be caused by the iron-containing chemicals (FeCl₃) and/ or low pH due to the acid (H₂SO₄). Caps of the chemical tanks were not closed. Overflow occurred during heavy rain. This observation was considered as a potential non-compliance, and the MT informed the IEC accordingly via email on 20 August 2024. The IEC also informed the authority via email on 21 August 2024. The Investigative Report of this potential non-compliance is under review as at the date of this EM&A report submission and will be presented once finalised in the subsequent monthly report.

Apart from the above observations, 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.

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([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]) A standby facility; only operates when the CHPs are not in operation or when the biogas generated exceeded the utilisation rate of the CHPs.

([3]) 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.

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