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 47^th EM&A report which summarises the monitoring results and audit findings for the EM&A programme during the reporting period from 1 to 30 April 2019.

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 end of March 2019 ([1]). The operation phase of the EM&A programme commenced on 1 March 2019.

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 and treated an average of 100 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. The site layout plan is shown in Annex B. The construction programme is shown in Annex C.

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 (about 100-130 t/d SSOW input);

· Process fine-tune – adjustment of the ASP operational parameters with new treatment media, CEMS/SCADA modification and improvement work following equipment failures and the alteration of different operation modes and measures to adapt to the high variation of SSOW nature and sources; and

· Construction of the Visitor Centre.

2.4 Project Organisation and Management Structure

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

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
Notification of Construction Works under the Air Pollution Control (Construction Dust) Regulation	Ref No. 386715	Throughout the Contract	-
Effluent Discharge License	WT00024352-2016	3 June 2016 – 30 June 2021	Approved on 3 June 2016
Construction Noise Permit – P1&P2	GW-RW0538-18 (Superseded CNP GW-RW0229-18)	21 January 2019-20 July 2019	Approved on 31 December 2018
Chemical Waste Producer Registration	WPN 5213-961-O2231-01	Throughout the Contract	Approved on 29 April 2015
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. No monitoring for noise, waste, land contamination, hazard-to-life and landscape and visual are required during construction and operation phases of the Project. Although water quality monitoring is not required for the construction and operation phases 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 calibration certificate for the on-line monitoring equipment is provided in Annex E.

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 (NO_x)	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
NO_x	300
SO₂	50
NMVOCs	150
VOCs (including methane) ^(c)	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) 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 ([2])

Parameter	Maximum Emission level (mg/Nm³) ^{(a) (b)}
Dust (or Total Suspended Particulates)	5
Carbon Monoxide	100
NO_x	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.

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.

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 construction and operation phase of the Project are recommended in the approved EIA Report and EM&A Manual and are summarised in Annex F. Weekly site audits for construction phase and 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. The effluent quality shall meet the discharge limits as described in Table 3.9.

Table 3.9 Discharge Limits for Effluent

Parameters	Discharge Limit (mg/L)
Flow Rate (m³/day)	685
pH (pH units)	6-10 ^(a)
Suspended Solids	800
Biochemical Oxygen Demand (5 days, 20°)	800
Chemical Oxygen Demand	2,000
Oil & Grease	40
Total Nitrogen	200
Total Phosphorus	50
Surfactants (total)	25
Note: (a) Range.

3.2.2 Landscape and Visual

In accordance with EM&A Manual, the landscape and visual mitigation measures shall be implemented. Bi-weekly landscape and visual audit during the construction phase is required to ensure that the design, implementation and maintenance of landscape and visual mitigation measures recommended in the approved EIA Report are fully achieved. The implementation status of the mitigation measures for construction phase is summarised in Annex F.

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 F), 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.

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. E) to support the termination of the construction 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) ^(a)	0 – 19	680	Nil	Nil
Dust (or TSP)	0	6	Nil	Nil
Odour (including NH₃ & H₂S)	0 – 1,522	220 ^(b)	Identified ^(c)	The chemical dosing system of the CAPCS was under optimisation. Manual dosing of the chemical to the system was arranged. The defect was rectified on 10 April 2019. Alkaline dosing system was under urgent maintenance on 25 April 2019.
Notes: (a) On-line monitoring was not available during the reporting period. Mini RAE PID meter that comply with the USEPA method 21 was used to measure VOCs. (b) The odour unit is OU/Nm³. (c) Dates with exceedances on Odour (number of exceedances on the day) were identified on 3 (1), 4 (2), 5 (16), 6 (6), 8 (1) and 9 (2) April 2019.

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 – 3	15	Nil	Nil
Carbon Monoxide	0 – 602	650	Nil	Nil
NO_x	0 – 350	300	Identified ^(e)	CHP setting was fine-tuned for performance optimisation. Continuous re-adjustment for NO_x control of CHP has been carried out.
SO₂	0 – 184	50	Identified ^(f)	Tripping of the desulphurisation column. Continuous monitoring to reduce the duration of tripping.
NMVOCs ^(b)	8 ^(d)	150	Nil	See Annex G for laboratory results
VOCs (including methane) ^{(b) (c)}	919 ^(d)	1,500	Nil	See Annex G for laboratory results
HCl	0 – 1	10	Nil	Nil
HF	0 – 0.5	1	Nil	Nil
Notes: (a) All values refer to an oxygen content in the exhaust gas of 6% and dry basis. (b) Technical issue related to monitoring range of VOCs and methane sensors and the Contractor is solving the problem together with the equipment suppliers. (c) The VOCs emission limit include methane as biogas is adopted as fuel in the combustion process. (d) 1 sampling was conducted during the reporting period because the biogas production rate could not sustain the operation of the CHP stack for the scheduled samplings, hence the second sampling was cancelled. (e) Dates with exceedances on NO_x (number of exceedances on the day) were identified on 14 (1), 21 (3), 22 (3), 23 (3), 27 (1), 29 (1) April 2019. (f) Dates with exceedances on SO₂ (number of exceedances on the day) were identified on 8 (2), 10 (2), 11 (2), 12 (1), 14 (2), 15 (2), 18 (2), 19 (10), 20 (1), 23 (1), 24 (1), 26 (1), 29 (6) April 2019.

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 – 2	15	Nil	Nil
Carbon Monoxide	0 – 347	650	Nil	Nil
NO_x	0 – 408	300	Identified ^(e)	CHP setting was fine-tuned for performance optimisation. Continuous re-adjustment for NO_x control of CHP has been carried out.
SO₂	0 – 177	50	Identified ^(f)	Tripping of the desulphurisation column. Continuous monitoring to reduce the duration of tripping.
NMVOCs ^(b)	13 ^(d)	150	Nil	See Annex G for laboratory results
VOCs (including methane) ^{(b) (c)}	871 ^(d)	1,500	Nil	See Annex G for laboratory results
HCl	0 – 3	10	Nil	Nil
HF	0 – 0.5	1	Nil	Nil
Notes: (a) All values refer to an oxygen content in the exhaust gas of 6% and dry basis. (b) Technical issue related to monitoring range of VOCs and methane sensors and the Contractor is solving the problem together with the equipment suppliers. (c) The VOCs emission limit include methane as biogas is adopted as fuel in the combustion process. (d) 1 sampling was conducted during the reporting period because the biogas production rate could not sustain the operation of the CHP stack for the scheduled samplings, hence the second sampling was cancelled. (e) Dates with exceedances on NO_x (number of exceedances on the day) were identified on 7 (4), 10 (1), 13 (3), 16 (1), 17 (2), 19 (2), 22 (3), 23 (1) and 28 (1) April 2019. (f) Dates with exceedances on SO₂ (number of exceedances on the day) were identified on 1 (1), 13 (3), 16 (5), 19 (5), 20 (1), 22 (2), 25 (2), 27 (2), 28 (2), 29 (1) and 30 (5) April 2019.

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 – 12	15	Nil	Nil
Carbon Monoxide	0 – 396	650	Nil	Nil
NO_x	0 – 409	300	Identified	CHP setting was fine-tuned for performance optimisation. Continuous re-adjustment for NO_x control of CHP has been carried out.
SO₂	0 – 94	50	Identified	Tripping of the desulphurisation column. Continuous monitoring to reduce the duration of tripping.
NMVOCs	Not Available ^(c)	150	Not Available	Nil
VOCs (including methane) ^(d)	Not Available ^(c)	1,500	Not Available	Nil
HCl	0 – 0.5	10	Nil	Nil
HF	0 – 0.5	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) Technical issue related to monitoring range of VOCs and methane sensors and the Contractor is solving the problem together with the equipment suppliers. No sampling was undertaken at CHP3 as biogas production rate could not sustain the operation of the CHP stack for the scheduled samplings. (d) Dates with exceedances on NO_x (number of exceedances on the day) were identified on 5 (1), 12 (1) and 13 (1) April 2019. (e) 1 exceedance was identified on 3 April 2019.

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 – 4.5	5	Nil	Nil
Carbon Monoxide	0 – 280	100	Identified ^(c)	ASP tripped and stopped. Ongoing optimisation of ASP combustion efficiency has been carried out.
NOx	0 – 217	200	Identified ^(d)	ASP tripped and stopped. Ongoing optimisation of ASP combustion efficiency has been carried out.
SO₂	0 – 102	50	Identified ^(e)	ASP tripped and stopped. Ongoing optimisation of ASP combustion efficiency has been carried out.
VOCs (including methane) ^(b)	0 – 1,773	20	Identified ^(f)	ASP tripped and stopped. Ongoing optimisation of ASP combustion efficiency has been carried out.
NH₃	0 – 2,128	35	Identified ^(g)	ASP tripped and stopped. Ongoing optimisation of ASP combustion efficiency has been carried out.
HCl	0	10	Nil	Nil
HF	0 – 0.5	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) Dates with exceedances on CO (number of exceedances on the day) were identified on 21 (1), 23 (2), 24 (1), 25 (5), 26 (1) and 29 (1) April 2019. (d) Dates with exceedances on NO_x (number of exceedances on the day) were identified on 6 (1), 7 (1), 8 (2), 18 (3), 19 (2), 22 (2), 23 (4), 24 (5) and 26 (3) April 2019. (e) Dates with exceedances on SO₂ (number of exceedances on the day) were identified on 18 (1), 29 (6) and 30 (6) April 2019. (f) Dates with exceedances on VOCs (including methane) (number of exceedances on the day) were identified on 8 (1), 23 (2), 24 (1), 26 (3) April 2019. (g) Dates with exceedances on NH₃ (number of exceedances on the day) were identified on 1 (10), 2 (6), 3 (1), 8 (1), 19 (1), 20 (1), 21 (2), 22 (2), 23 (7), 24 (10), 25 (7), 26 (13), 27 (5), 29 (5) and 30 (4) April 2019

4.2 Odour

4.2.1 Commissioning Phase Monitoring

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

4.2.2 Operation Phase Monitoring

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

4.3 Water Quality

4.3.1 Construction Phase Monitoring

No effluent was discharged from the construction activity in the reporting month, hence it was not necessary to carry out effluent discharge sampling for this reporting period.

4.3.2 Operation Phase Monitoring

Effluent discharge was sampled monthly from the Effluent Storage Tank as stipulated in the operation phase discharge licence. The results of the discharge sample is recorded in Table 4.6.

Table 4.6 Results of the Discharge Sample

Parameters	Discharged Effluent Concentration (mg/L)	Discharge Limit (mg/L)	Compliance with Discharge Limit
pH (pH units)	7.40 - 7.91	6-10 ^(a)	Yes
Suspended Solids ^(b)	37	800	Yes
Biochemical Oxygen Demand (5 days, 20°) ^(b)	47	800	Yes
Chemical Oxygen Demand ^(b)	683	2,000	Yes
Oil & Grease ^(b)	<5	40	Yes
Total Nitrogen ^(b)	59	200	Yes
Total Phosphorus ^(b)	27	50	Yes
Surfactants (total)^(b)	<1.0	25	Yes
Notes: (a) Daily Average. (b) Effluent sample collected on 1 April 2019.

No exceedance of discharge limit was recorded during the reporting period.

4.4 Waste Management

4.4.1 Construction Phase Monitoring

Wastes generated from this Project include inert construction and demolition (C&D) materials (public fill) and non-inert C&D materials (construction waste). Construction waste comprises general refuse, metals and paper/cardboard packaging materials. Metals generated from the construction of the Project are also grouped into construction waste as the materials were not disposed of with others at public fill. Reference has been made to the Monthly Summary Waste Flow Table prepared by the Contractor (see Annex H). With reference to the relevant handling records and trip tickets of this Project, the quantities of different types of waste generated in the reporting month are summarised in Table 4.7.

Table 4.7 Quantities of Waste Generated from the Construction of the Project

Month / Year	Quantity
	Total Inert C&D Materials Generated ^(a)	Non-inert C&D Materials ^(b)
	Total Inert C&D Materials Generated ^(a)	C&D Materials Recycled ^(c)	C&D Waste Disposed of at Landfill ^(d)	Chemical Waste
April 2019	199.71 tonnes	0.00 kg	2.92 tonnes	0.00 L
Notes: (a) Inert C&D materials (public fill) include bricks, concrete, building debris, rubble and excavated spoil. In total, 199.71 tonnes of inert C&D material were generated from the Project. The detailed waste flow is presented in Annex H. (b) Non-inert C&D materials (construction wastes) include metals, paper / cardboard packaging waste, plastics and other wastes such as general refuse. Metals generated from the Project were grouped into construction wastes as the materials were not disposed of with others at the public fill. (c) 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) Construction wastes other than metals, paper/cardboard packaging, plastics and chemicals were disposed of at NENT Landfill by subcontractors.

4.4.2 Operation Phase Monitoring

Wastes generated from the operation of the Project include chemical waste, wastes generated from pre-treatment process and general refuse ([3]). Reference has been made to the Monthly Summary Waste Flow Table prepared by the Contractor (see Annex H). 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 4.8.

Table 4.8 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)
April 2019	0 L	455.60 tonnes	0.00 tonnes	1.27 tonnes ^(d)	0.00 kg
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 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. (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) It was assumed that two 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 Construction Phase

Joint site inspections were conducted by representatives of the Contractor and the ET on 26 and 30 April 2019 as required for the construction of the Project. The IEC was present at the joint inspection on 30 April 2019.

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 F).

Follow-up actions resulting from the last site inspections were generally taken as reported by the Contractor.

Key observations during the reporting period are summarised as follows:

26 April 2019

· No particular observation during this inspection.

30 April 2019

· There was no display of any approval/exemption label for the non-road mobile machinery (i.e. excavator) used. The contractor was advised to provide the approval/exemption label in accordance to the Air Pollution Control (Non-road Mobile Machinery) (Emission) Regulation.

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

5.1.2 Operation Phase

The monthly inspection of the landscape and visual mitigation measures for the operation phase of the Project on 25 April 2019 covered the operation phase environmental site audit. Joint site inspections was conducted by representatives of the Contractor, IEC and the MT on 25 April 2019 as required for the operation of the Project.

Follow-up actions resulting from the last site inspections were generally taken as reported by the Contractor.

Key observations during the reporting period are summarised as follows:

25 April 2019

· A chemical waste container without label was observed in the laboratory. The contractor was advised to clearly label the container in accordance to the Code of Practice.

Other than the above observation, 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 construction phase of the Project was performed on 30 April 2019. Inspection of the landscape and visual mitigation measures for the operation phase of the Project was performed on 25 April 2019.

It was confirmed that the necessary landscape and visual mitigation measures during the construction and operation phase as summarised in Annex F were generally implemented by the Contractor. No specific observation was found during site inspections on 25 and 30 April 2019. 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

6.1 Summary of Environmental Non-Compliance

Non-compliance of emission limits for CAPCS, CHP and 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 air pollution control system of the CAPCS, CHP and ASP and the combustion system for the CHP and the ASP and identified the following potential causes for the exceedance.

(a) There were breakdowns of the automatic chemical dosing system of the CAPCS. As a result, it could not effectively remove the odorous gases (e.g. NH3 and H2S) and caused exceedances of odour limits for the CAPCS;

(b) CHP setting was undergoing fine-tuning for performance optimisation. Therefore, it could not effectively remove NO_x at a certain period of time which leads to the exceedance for NO_x limit for the CHP stacks;

(c) Tripping of the desulphurisation column resulting in the incomplete desulphurisation of biogas that leads to the exceedances of SO₂ limits for CHP stacks; and

(d) Tripping and stopping of the ASP and the ongoing performance optimisation of the ASP result in the incomplete combustion of biogas. The unstable emission leads to the exceedances of CO, NO_x, SO₂, VOCs and NH₃in ASP.

For item (a), the Contractor has arranged manual dosing of the chemical to the system to minimise the exceedances in odour in the CAPCS. The Contractor has contacted the supplier of the chemical dosing system to carry out repairing works so that the system can function properly.

For item (b), continuous optimisation of CHP and re-adjustment of NO_x control for CHP has been carried out. It is expected to complete in the next reporting period.

For item (c), routine maintenance of the desulphurisation column, e.g. cleaning of sensors, has been carried out. Continuous monitoring of the desulphurisation column will remain in place to reduce the duration of tripping which causes exceedances in SO₂ in CHP stacks.

For item (d), the Contractor will continue to fine-tune the thermal combustion unit of the ASP in order to restore the combustion efficiency so that the concerned pollutants will be effectively destroyed.

The investigation report is presented in Annex J.

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 I.

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.

· Contractor should resolve the technical issue related to the on-line monitoring of methane emission (hence the calculation of the NMVOC concentration) from the CHP stacks as soon as possible and undertake gas sampling and laboratory analysis of NMVOC at agreed interval when the on-line monitoring equipment for methane is not available.

· Implementation of measures to further rectify the abnormal operating conditions for the CAPCS, CHP and ASP.

· Continue construction of the Visitor Centre.

8 Conclusions

This EM&A Report presents the EM&A programme undertaken during the reporting period from 1 to 30 April 2019 in accordance with EM&A Manual (Version E) and requirements of EP (FEP-01/395/2010/C).

No air quality, noise and water quality monitoring is required under the construction EM&A requirements.

For the operation phase, 1 exceedance of the emission limits for stack monitoring (including CAPCS, CHP and ASP stacks) 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
Centralised Air Pollution Control Unit (CAPCS)	· Exceeded emission limit of Odour on 3 to 6, 8 and 9 April 2019
Cogeneration Unit (CHP)	· Exceeded emission limit of NO_x on 5, 7, 10, 12 to 14, 16 to 17, 19, 21 to 23 and 27 to 29 April 2019 · Exceeded emission limit of SO₂ on 1, 8, 10 to 12, 14 to 16, 18 to 20 and 22 to 30
Ammonia Stripping Plant (ASP)	· Exceeded emission limit of CO on 21, 23 to 26 and 29 April 2019 · Exceeded emission limit of NO_x on 6 to 8, 18 to 19, 22 to 24 and 26 April 2019 · Exceeded emission limit of SO₂ on 18 and 29 to 30 April 2019 · Exceeded emission limit of VOCs on 8, 23 to 24 and 26 April 2019 · Exceeded emission limit of NH₃ on 1 to 3, 8, 19 to 27 and 29 to 30 April 2019

Exceedances in emission parameters of CAPCS, CHP and ASP were found to be a result of problems with the chemical dosing system of the air pollution control systems of the CAPCS, continuous fine-tuning of CHP setting, incomplete desulphurisation of biogas which fed to the CHPs, and tripping and stopping of ASP and the incomplete thermal combustion of the thermal combustion unit of the ASP.

The Contractor has implemented mitigation measures to control the exceedance (including the arrangement of supplier of the dosing system for the CAPCS to repair the dosing system and manual dosing of chemical to the CAPCS until the problems of the automatic dosing system is fixed; re-adjustment for NO_x control for CHP; continuous monitoring and routine maintenance of the desulphurisation column is carried out ; and tuning the thermal combustion unit of the ASP to optimise combustion efficiency and overall performance).

No non-compliance to the effluent discharge limit was recorded during this reporting period.

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.

Bi-weekly landscape and visual monitoring was 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 incident occurred during reporting period.

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

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

*Annex A*	*Location of Project*
*Annex B*	*Works Location*
*Annex C*	*Construction Programme*
*Annex D*	*Project Organisation Chart and Contact Detail*
*Annex E*	*Calibration Certification for the On-line Stack* *Monitoring System*
*Annex F*	*Implementation Schedule of Mitigation Measures*
*Annex G*	*Laboratory Results for NMVOCs and VOCs (including methane) for CHP 1 & CHP 2*
*Annex h*	*Waste Flow Table*
*Annex I*	*Environmental complaint, Environmental Summons and Prosecution Log*
*Annex J*	*Investigation Report*

· Joint Environmental Site Inspections	3 times
· Landscape & Visual Inspections	2 times