Contents

Executive Summary

1                             inTroduction                                                                         

1.1                         Purpose of the Report                                                       

1.2                         Structure of the Report                                                  

2                             Project information                                                          

2.1                         Background                                                                            

2.2                         General Site Description                                                  

2.3                         Major Activities Undertaken                                         

2.4                         Project Organisation and Management Structure

2.5                         Status of Environmental Approval Documents  

3                             Environmental Monitoring and Audit Requirements   

3.1                         Environmental Monitoring                                           

3.1.1                     Air Quality                                                                                    

3.1.2                     Odour                                                                                            

3.2                         Site Audit                                                                                  

3.2.1                     Water Quality                                                                               

3.2.2                     Landscape and Visual                                                                   

4                             Monitoring Results                                                            

4.1                         Air Quality                                                                               

4.1.1                     Commissioning Phase Monitoring                                               

4.1.2                     Operation Phase Monitoring                                                        

4.2                         Odour                                                                                        

4.2.1                     Operation Phase Monitoring                                                        

4.3                         Water Quality                                                                        

4.3.1                     Operation Phase Monitoring                                                        

4.4                         Waste Management                                                              

4.4.1                     Operation Phase Monitoring                                                        

5                             Site Audit                                                                                  

5.1                         Environmental Site Audit                                                

5.1.1                     Operation Phase                                                                           

5.2                         Landscape and Visual Audit                                            

6                             Environmental Non-conformance                             

6.1                         Summary of Environmental Non-Compliance       

6.2                         Summary of Environmental Complaint                    

6.3                         Summary of Environmental Summon and Successful Prosecution     

7                             Future Key Issues                                                                  

7.1                         Key Issues for the Coming Reporting Period         

8                             Conclusions                                                                           

LIST OF TABLES

Table 2.1          Summary of Activities Undertaken in the Reporting Period

Table 2.2          Summary of Environmental Licensing, Notification and Permit Status

Table 3.1          Sampling and Laboratory Analysis Methodology

Table 3.2          Emission Limit for CAPCS Stack

Table 3.3          Emission Limit for CHP Stack

Table 3.4          Emission Limit for ASP Stack

Table 3.5          Emission Limit for Standby Flaring Gas Unit ()

Table 3.6          Odour Intensity Level

Table 3.7          Action and Limit Levels for Odour Nuisance

Table 3.8          Event and Action Plan for Odour Monitoring

Table 3.9          Discharge Limits for Effluent

Table 4.1          Hourly Average of Parameters Recorded for CAPCS

Table 4.2          Hourly Average of Parameters Recorded for CHP 1

Table 4.3          Hourly Average of Parameters Recorded for CHP 2

Table 4.4          Hourly Average of Parameters Recorded for CHP 3

Table 4.5          Hourly Average of Parameters Recorded for ASP

Table 4.6          Results of the Discharge Sample Collected on 2 march 2020

Table 4.7          Results of the Discharge Sample Collected on 8 April 2020

Table 4.8          Results of the Discharge Sample Collected on 6 May 2020

Table 4.10        Quantities of Waste Generated from the Operation of the Project

 

 LIST OF ANNEXES

Annex A

Location of Project

Annex B

Project Organisation Chart and Contact Detail

Annex C

Calibration Certification for the On-line Stack

Monitoring System

Annex D

Implementation Schedule of Mitigation Measures

Annex E

Waste Flow Table

Annex F

Environmental complaint, Environmental Summons and Prosecution Log

Annex G

Investigation Report

Annex H

Odour Patrol Result

 

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 22nd quarterly Environmental Monitoring and Audit (EM&A) report presenting the EM&A works carried out during the period from 1 September 2020 to 30 November 2020 in accordance with the EM&A Manual.  Substantial completion of the construction works was confirmed on 3 December 2018.  In the meantime, the operation phase EM&A programme had commenced in March 2019. Substantial Completion in respect of substantial part of the Works was confirmed on 24 February 2020.  The construction phase EM&A programme was completed in the end of February 2020.

Summary of Works undertaken during the Reporting Month

Works undertaken in the reporting month included:

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

·            Process fine-tune, including adjustment of the ASP with new treatment media, modification of Continuous Environmental Monitoring System (CEMS) and Supervisory Control and Data Acquisition System (SCADA) rectification and improvement works following equipment failures and the alteration of different operation modes and measures to adapt to the high variation of SSOW nature and sources.

Environmental Monitoring and Audit Progress

Air Quality Monitoring

Exceedances on NOx and SO2 from CHP and NOx and NH3 from ASP were recorded on the on-line monitoring system in September 2020.  Exceedances on Odour (NH3 & H2S) from CAPCS, NOx from CHP and CO, NOx, VOC (including methane) and NH3 from ASP were recorded on the on-line monitoring system in October 2020.  Exceedances on Odour (NH3 & H2S), NOx from CHP and CO, NOx, VOC (including methane) and NH3 from ASP were recorded on the on-line monitoring system in November 2020.  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. 

Exceedances in emission parameters of CAPCS, CHP and ASP were found to be a result of problems with system maintenance at CAPCS, low biogas loading at CHP and incomplete combustion of biogas at ASP.

The Contractor has implemented mitigation measures to control the exceedance (including continuous monitoring of CAPCS, arranging for the supplier of CHP to perform on-site adjustment to improve CHP performance and tuning the thermal combustion unit of the ASP to optimise combustion efficiency and overall performance).

The Contractor is recommended to closely monitor the processes of the modification of the ASP and the post-modification monitoring of emission level to avoid any exceedance. 

Odour

Odour patrols were conducted by the independent odour patrol team of ALS Technichem (HK) Pty Ltd on 4 September 2020.  No Level 2 Odour Intensity was recorded during odour patrols.

Water Quality

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

Waste Management

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

400 L of chemical waste was collected by licenced waste collector from the operation of the Project.

2,108.59 tonnes of waste generated from pre-treatment process from the operation of the Project was disposed of at landfill.  Among the recyclable waste generated from pre-treatment process from the operation of the Project, 0.00 tonnes of metals, 8.99 tonnes of papers/ cardboard packing and 0.00 tonnes of plastics were sent to recyclers for recycling during the reporting period.

Around 8.64 tonnes of general refuse from the operation of the Project was disposed of at landfill.  Among the recycled general refuse from the operation of the Project, 0.00 tonnes of metals, 0.00 tonnes of papers/ cardboard packing and 0.00 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

3 times

·        Landscape & Visual Inspections

3 times

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

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

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

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

Future Key Issues

Activities to be undertaken in the next reporting month include:

·            Operation of the Project.

·            Modification of the CHP and ASP to control the air emission. 


 

 

 

1                                          inTroduction

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

1.1                                       Purpose of the Report

This is the 22nd Quarterly EM&A report which summarises the monitoring results and audit findings for the EM&A programme during the reporting period from 1 September 2020 to 30 November 2020.

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

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.  

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); and

·           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.

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

 

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.  Although water quality monitoring is not required for the operation phase under the EM&A programme, there are water quality monitoring requirement under the Water Discharge Licence of the plant under the Water Pollution Control Ordinance (WPCO).  As part of this EM&A programme, the monitoring results will be reviewed to check the compliance with the WPCO requirements.

3.1.1                                 Air Quality

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

On-line monitoring (using continuous environmental monitoring system (CEMS) shall be carried out for the centralised air pollution unit (CAPCS), cogeneration units (CHP) and the ammonia stripping plant (ASP) during the commissioning and operation phase.  The calibration certificate for the on-line monitoring equipment is provided in Annex C.

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

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

Table 3.1        Sampling and Laboratory Analysis Methodology

Parameters

Method

Stacks to be Monitored

Gaseous and vaporous organic substances (including methane)

USEPA Method 18

·      CAPCS

·      CHP

·      ASP

Particulate

USEPA Method 5

·      CAPCS

·      CHP

·      ASP

Carbon monoxide (CO)

USEPA Method 10

·      CHP

·      ASP

Nitrogen oxides (NOx)

USEPA Method 7E

·      CHP

·      ASP

Sulphur dioxide (SO2);

USEPA Method 6

·      CHP

·      ASP

Hydrogen chloride (HCl)

USEPA Method 26A

·      CHP

·      ASP

Hydrogen fluoride (HF)

USEPA Method 26A

·      CHP

·      ASP

Oxygen (O2);

USEPA Method 3A

·      CAPCS

·      CHP

·      ASP

Velocity and Volumetric Flow

USEPA Method 2

·      CAPCS

·      CHP

·      ASP

Ammonia (NH3)

USEPA CTM 027

·      ASP

Odour (including NH3 and H2S)

EN 13725

·      CAPCS

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

USEPA Method 4

·      CAPCS

·      CHP

·      ASP

Temperature

USEPA Method 4

·      CAPCS

·      CHP

·      ASP

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

Table 3.2        Emission Limit for CAPCS Stack

Parameter

Emission Level (mg/Nm3) (a)

VOCs (including methane)

680

Dust (or Total Suspended Particulates (TSP))

6

Odour (including NH3 & H2S)

220 (b)

Notes:

(a)    Hourly average concentration

(b)   The odour unit is OU/Nm3

Table 3.3        Emission Limit for CHP Stack

Parameter

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

Dust (or Total Suspended Particulates)

15

Carbon Monoxide

650

NOx

300

SO2

50

NMVOCs (c)

150

VOCs (including methane) (d)

1,500

HCl

10

HF

1

Notes:

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

(b)  Hourly average concentration

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

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

Table 3.4        Emission Limit for ASP Stack

Parameter

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

Dust (or Total Suspended Particulates)

5

Carbon Monoxide

100

NOx

200

SO2

50

VOCs (including methane) (c)

20

NH3

35

HCl

10

HF

1

Notes:

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

(b)      Hourly average concentration

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

Table 3.5        Emission Limit for Standby Flaring Gas Unit ([2])

Parameter

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

Dust (or Total Suspended Particulates)

5

Carbon Monoxide

100

NOx

200

SO2

50

VOCs (including methane) (c)

20

HCl

10

HF

1

Notes:

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

(b)   Hourly average concentration

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

3.1.2                                 Odour

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

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

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

Table 3.6        Odour Intensity Level

Level

Odour Intensity

0

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

1

Slight identifiable odour, and slight chance to have odour nuisance

2

Moderate identifiable odour, and moderate chance to have odour nuisance

3

Strong identifiable, likely to have odour nuisance

4

Extreme severe odour, and unacceptable odour level

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

Table 3.7        Action and Limit Levels for Odour Nuisance

Parameter

Action Level

Limit Level

Odour Nuisance (from odour patrol)

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

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

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

Note:

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

Table 3.8        Event and Action Plan for Odour Monitoring

Event

Action

 

Person-in-charge of Odour Monitoring

Project Proponent (a)

Action Level

 

 

Exceedance of action level (Odour Patrol)

1. Identify source/reason of exceedance;

2. Repeat odour patrol to confirm finding.

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

2. Rectify any unacceptable practice;

3. Implement more mitigation measures if necessary;

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

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

Exceedance of action level (Odour Complaints)

1. Identify source/reason of exceedance;

2. Carry out odour patrol to determinate odour intensity.

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

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

3. Rectify any unacceptable practice;

4. Implement more mitigation measures if necessary;

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

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

Limit Level

 

 

Exceedance of limit level

1. Identify source/reason of exceedance;

2. Inform EPD;

3. Repeat odour patrol to confirm findings;

4. Increase odour patrol frequency to bi-weekly;

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

6. If exceedance stops, cease additional odour patrol.

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

2. Rectify any unacceptable practice;

3. Formulate remedial actions;

4. Ensure remedial actions properly implemented;

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

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

Note:

(a)    Project Proponent shall identify an implementation agent.

3.2                                       Site Audit

Environmental mitigation measures (related to air quality, water quality, waste, land contamination, hazard-to-life, and landscape and visual) to be implemented during the operation phase of the Project are recommended in the approved EIA Report and EM&A Manual and are summarised in Annex D.  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. 

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 D), 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. F) 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)

0 – 639

680

Nil

Nil

Dust (or TSP)

0.2 – 5.3  

6

Nil

Nil

Odour (including NH3 & H2S) (b)

0 – 340

220

Identified (b)

Resuming normal operation after maintenance and calibration.

Notes:

(a)     The odour unit is OU/Nm3.

(b)     Dates with exceedances on Odour (including NH3 & H2S) (number of exceedances on the day) were identified on 17 (1) October and 17 (1) November 2020.

 

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 – 5

15

Nil

Nil

Carbon Monoxide

0 – 491

650

Nil

Nil

NOx

0 – 342

300

Identified (d)

Low biogas loading resulting in low CHP efficiency. Supplier had been arranged to fine-tune the equipment.  Close monitoring of the biogas loading is performed to prevent further exceedance.

SO2

0 – 58

50

Identified (e)

Low biogas loading resulting in low CHP efficiency. Supplier had been arranged to fine-tune the equipment.  Close monitoring of the biogas loading is performed to prevent further exceedance.

NMVOCs (b)

Nil

150

Nil

Nil

VOCs (including methane) (c)

0 – 1,253

1,500

Nil

Nil

HCl

0 – 3

10

Nil

Nil

HF

0.0 – 1.0

1

Nil

Nil

Notes:

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

(b)      No sampling was undertaken at CHP 1 as biogas production rate could not sustain the operation of the CHP stack for the scheduled sampling on 14 August 2020.

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

(d)      Dates with exceedances on NOx (number of exceedances on the day) were identified on 20 (1), 21 (2) and 23 (2) September 2020 and 16 (2) and 17 (11) November 2020.

(e)       1 exceedance on SO2 was identified on 24 September 2020.

 

Table 4.3        Hourly Average of Parameters Recorded for CHP 2

Parameter

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

Max. Emission Limit (mg/Nm3)

Exceedance

Identified

Remarks

Dust (or TSP)

0 – 6

15

Nil

Nil

Carbon Monoxide

0 – 276

650

Nil

Nil

NOx

0 – 432

300

Identified (d)

Low biogas loading resulting in low CHP efficiency. Supplier had been arranged to fine-tune the equipment.  Close monitoring of the biogas loading is performed to prevent further exceedance.

SO2

0 – 44

50

Nil

Nil

NMVOCs (b)

Nil

150

Nil

Nil

VOCs (including methane) (c)

0 – 932

1,500

Nil

Nil

HCl

0 – 0

10

Nil

Nil

HF

0 – 1.0

1

Nil

Nil

Notes:

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

(b)     Bi-annual sampling of NMVOCs was conducted in CHP 2 on 14 August 2020. The hourly average concentration for NMVOC was 2.7 mg/Nm3.  No exceedance was identified. The VOCs emission limit include methane as biogas is adopted as fuel in the combustion process. 

(c)      Dates with exceedances on NOx (number of exceedances on the day) were identified on 16 (13), 17 (24), 18 (24), 19 (22), 20 (17), 21 (10), 25 (11), 26 (21), 27 (2), 28 (8), 29 (15) and 30 (6) September 2020, 1 (15), 2 (2), 3 (5), 4 (13), 5 (17), 6 (12), 7 (23), 8 (18), 9 (7), 14 (1), 16 (5), 17 (4), 18 (17), 19 (10), 20 (5), 21 (4), 23 (3), 24 (2), 25 (3), 26 (20) and 27 (10) October 2020 and 1 (1), 18 (8), 19 (13), 20 (22), 21 (23), 22 (11), 23 (11), 24 (10), 26 (23), 27 (24), 28 (15) and 30 (6) November 2020.

 

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 – 9

15

Nil

Nil

Carbon Monoxide

0 – 116

650

Nil

Nil

NOx

0 – 337

300

Identified (d)

Low biogas loading resulting in low CHP efficiency. Supplier had been arranged to fine-tune the equipment.  Close monitoring of the biogas loading is performed to prevent further exceedance.

SO2

0 – 49

50

Nil

Nil

NMVOCs (b)

Nil

150

Nil

Nil

VOCs (including methane) (c)

0 – 1,283

1,500

Nil

Nil

HCl

0 – 4

10

Nil

Nil

HF

0 – 1.0

1

Nil

Nil

Notes:

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

(b)     Sampling was conducted on 11 February 2020. 

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

(d)     Dates with exceedances on NOx (number of exceedances on the day) were identified on 4 (3), 9 (3), 10 (1), 11(1), 12 (2), 16 (1), 17 (4), 18 (5) and 19 (6) October 2020.

 

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)

0.0 – 4.6

5

Nil

Nil

Carbon Monoxide

0 – 789

100

Identified (c)

System instability due to unstable column temperature. System maintenance were performed to maintain operation efficiency

NOx

0 – 513

200

Identified (d)

System instability due to unstable column temperature. System maintenance were performed to maintain operation efficiency

SO2

0 –47

50

Nil

Nil

VOCs (including methane) (b)

0 – 930

20

Identified (e)

System instability due to unstable column temperature. System maintenance were performed to maintain operation efficiency

NH3

0 – 198

35

Identified (f)

System instability due to unstable column temperature. System maintenance were performed to maintain operation efficiency

HCl

0 – 4

10

Nil

Nil

HF

0 – 1

1

Nil

Nil

Notes:

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

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

(c)      Dates with exceedances on CO (number of exceedances on the day) were identified on 11 (1), 20 (1) and 27 (1) October 2020 and 27 (1) November 2020.

(d)     Dates with exceedances on NOx (number of exceedances on the day) were identified on 1 (1), 5 (3), 6 (1), 7 (1), 10 (1), 11 (5), 12 (1), 20 (3), 21 (1), 22 (2), 26 (1), 27 (4) and 31 (1) October 2020 and 2 (2) 3 (1), 5 (5), 6 (4), 9 (1), 14 (1), 19 (3) and 27 (1) November 2020.

(e)     Dates with exceedances on VOC (including methane) (number of exceedances on the day) were identified on 4 (1), 11 (1), 20 (1) and 27 (1) October 2020 and 5 (1), 19 (1), 23 (1) and 27 (4) November 2020.

(f)      Dates with exceedances on NH3 (number of exceedances on the day) were identified on 3 (4), 4 (1), 8 (2), 14 (2), 19 (1), 21 (2), 26 (10), 27 (11) and 28 (1) September 2020, 4 (3), 6 (2), 7 (1), 11 (4), 20 (8), 21 (4), 25 (3) and 29 (4) October 2020 and 1 (2), 8 (4), 9 (3), 13 (5), 18 (1), 19 (2), 23 (2), 27 (5) and 30 (2) November 2020.

4.2                                       Odour

4.2.1                                 Operation Phase Monitoring

September 2020

Odour patrol was conducted by the independent odour patrol team of ALS Technichem (HK) Pty Ltd on 4 September 2020.  According to the EM&A Manual and EP requirements, it is considered an exceedance if the odour intensity recorded by the panellists is Level 2 or above.  During this reporting period, no Level 2 Odour Intensity was recorded.  The odour patrol result is shown in Annex H.

October 2020

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

November 2020

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

4.3                                       Water Quality

4.3.1                                 Operation Phase Monitoring

Effluent discharge was sampled 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 to 4.8.

Table 4.6        Results of the Discharge Sample Collected on 10 September 2020

Parameters

Discharged Effluent Concentration (mg/L)

Discharge Limit (mg/L)

Compliance with Discharge Limit

pH (pH units)

7.03 – 7.99 

6-10 (a)

Yes

Suspended Solids

94

800

Yes

Biochemical Oxygen Demand (5 days, 20°)

27

800

Yes

Chemical Oxygen Demand

554

2,000

Yes

Oil & Grease

<5

40

Yes

Total Nitrogen

128

200

Yes

Total Phosphorus

31.2

50

Yes

Surfactants (total)

1.4

25

Yes

Notes:

(a)     Daily Average.

Table 4.7        Results of the Discharge Sample Collected on 30 October 2020

Parameters

Discharged Effluent Concentration (mg/L)

Discharge Limit (mg/L)

Compliance with Discharge Limit

pH (pH units)

6.83 – 7.95

6-10 (a)

Yes

Suspended Solids

96

800

Yes

Biochemical Oxygen Demand (5 days, 20°)

25

800

Yes

Chemical Oxygen Demand

613

2,000

Yes

Oil & Grease

<5

40

Yes

Total Nitrogen

82.6

200

Yes

Total Phosphorus

25.5

50

Yes

Surfactants (total)

<1.0

25

Yes

Notes:

(a)      Daily Average.

Table 4.8        Results of the Discharge Sample Collected on 12 November 2020

Parameters

Discharged Effluent Concentration (mg/L)

Discharge Limit (mg/L)

Compliance with Discharge Limit

pH (pH units)

7.9 – 9.26

6-10 (a)

Yes

Suspended Solids

105

800

Yes

Biochemical Oxygen Demand (5 days, 20°)

63

800

Yes

Chemical Oxygen Demand

604

2,000

Yes

Oil & Grease

<5

40

Yes

Total Nitrogen

80.2

200

Yes

Total Phosphorus

18.0

50

Yes

Surfactants (total)

<1.0

25

Yes

Notes:

(a)      Daily Average.

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

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 ([3]).  Reference has been made to the Monthly Summary Waste Flow Table prepared by the Contractor (see Annex E).  With reference to the relevant handling records and trip tickets of this Project, the quantities of different types of waste generated from the operation of the Project in the reporting month are summarised in Table 4.9

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

Month / Year

Chemical Waste

Waste Generated from
Pre-treatment Process

General Refuse

 

Disposal of at CWTC

Disposed of at Landfill (a)

Recycled (b) 

Disposed of at Landfill (a) (d)

Recycled (c) 

September 2020

400 L

579.64 tonnes

2.36 tonnes

3.00 tonnes (d)

0.00 tonnes

October 2020

0 L

840.75 tonnes

5.83 tonnes

2.76 tonnes (d)

0.00 tonne

November 2020

0 L

688.20 tonnes

0.8 tonnes

2.88 tonnes (d)

0.00 tonne

Notes:

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

(b)   Among waste generated from pre-treatment process, 0.00 tonne of metals, 8.99 tonne of papers/ cardboard packing and 0.00 tonne of plastics were sent to recyclers for recycling during the reporting period.

(c)    Among general refuse, 0.00 tonnes of metals, 0.00 tonnes of papers/ cardboard packing and 0 tonnes of plastics were sent to recyclers for recycling during the reporting period.

(d)   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 inspections of the landscape and visual mitigation measures for the operation phase of the Project covered the operation phase environmental site inspections.  The inspections 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 D).  

Follow-up actions resulting from the site inspections were generally taken as reported by the Contractor.  The Contractor has implemented environmental mitigation measures recommended in the approved EIA Report and EM&A Manual. 

September 2020

The monthly inspection of the landscape and visual mitigation measures for the operation phase of the Project on 28 September 2020 covered the operation phase environmental site audit.  Joint site inspections was conducted by representatives of the Contractor, ER, IEC and the MT on 28 September 2020 as required for the operation of the Project.

October 2020

The monthly inspection of the landscape and visual mitigation measures for the operation phase of the Project on 23 October 2020 covered the operation phase environmental site audit.  Joint site inspections was conducted by representatives of the Contractor, ER, IEC and the MT on 23 October 2020 as required for the operation of the Project.

November 2020

The monthly inspection of the landscape and visual mitigation measures for the operation phase of the Project on 24 November 2020 covered the operation phase environmental site audit.  Joint site inspections was conducted by representatives of the Contractor, IEC and the MT on 24 November 2020 as required for the operation of the Project.

5.2                                       Landscape and Visual Audit

It was confirmed that the necessary landscape and visual mitigation measures during the operation phase as summarised in Annex D were generally implemented by the Contractor.  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.

September 2020

Inspection of the landscape and visual mitigation measures for the operation phase of the Project was performed on 28 September 2020.

October 2020

Inspection of the landscape and visual mitigation measures for the operation phase of the Project was performed on 23 October 2020.  

November 2020

Inspection of the landscape and visual mitigation measures for the operation phase of the Project was performed on 24 November 2020. 

6                                            Environmental Non-conformance

6.1                                       Summary of Environmental Non-Compliance

September 2020

Non-compliance of emission limits for 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 systems for the CHP and ASP and identified several potential causes for the exceedance.  Remedial and follow-up actions had been recommended to the Contractor to perform accordingly.  The Investigation Report is show in Annex G.

October 2020

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 systems for the CAPCS, CHP and ASP and identified several potential causes for the exceedance.  Remedial and follow-up actions had been recommended to the Contractor to perform accordingly.  The Investigation Report is show in Annex G.

November 2020

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 systems for the CHP and the ASP and identified several potential causes for the exceedance.  Remedial and follow-up actions had been recommended to the Contractor to perform accordingly.  The Investigation Report is show in Annex G.

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 F.

7                                            Future Key Issues

7.1                                       Key Issues for the Coming Reporting Period

Activities to be undertaken for the coming reporting period are:

·     Operation of the Project.

·     Modification of the CHP and ASP to control the air emission. 

8                                            Conclusions

This EM&A Report presents the EM&A programme undertaken during the reporting period from 1 September 2020 to 30 November 2020 in accordance with EM&A Manual (Version F) and requirements of EP (FEP-01/395/2010/C). 

For the operation phase, exceedances of the emission limits for stack monitoring (including CAPCS, CHP and ASP stacks) were 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 (including NH3 & H2S) on 17 October 2020 and 17 November 2020

Cogeneration Unit (CHP)

·    Exceeded emission limit of NOx on 16, 17, 18, 19, 20, 21, 23, 25, 26, 27, 28, 29 and 30 September 2020, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 14, 16, 17, 18, 19, 20, 21, 23, 24, 25, 26 and 27 October 2020 and 1, 16, 17, 18, 19, 20, 21, 22, 23, 24, 26, 27, 28 and 30 November 2020

·    Exceeded emission limit of SO2 on 24 September 2020

Ammonia Stripping Plant (ASP)

·    Exceeded emission limit of CO on 11, 20 and 27 October 2020 and 27 November 2020

·    Exceeded emission limit of NOx on 9, 17, 19 and 25 September 2020 and 2, 3, 4, 5, 9, 19, and 27 November 2020

·    Exceeded emission limit of VOC (including methane) on 4, 11, 20 and 27 October 2020 and 5, 19, 23 and 27 November 2020

·    Exceeded emission limit of NH3 on 3, 4, 8, 14, 19, 21, 26, 27 and 28 September 2020 and 1, 8, 9, 13, 16, 19, 23, 27 and 30 November 2020

Exceedances in emission parameters of CAPCS, CHP and ASP were found to be results of system maintenance at CAPCS, low biogas loading at CHP and incomplete combustion of biogas at ASP.

The Contractor has implemented mitigation measures to control the exceedance including the continuous monitoring of CAPCS, CHP and ASP to optimise overall performance.

Odour patrols were conducted in accordance to the EM&A requirements.  No exceedance of odour intensity limit for the odour patrols. 

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 period. 

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

No complaint/summon/prosecution was received.


 



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

(2)   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.