4                         Air Quality Assessment

4.1                   Introduction

This Section presents an assessment of the potential air quality impacts associated with the construction and operation of the proposed biodiesel plant at Tseung Kwan O Industrial Estate (TKOIE).

Dust nuisance and stack emissions are the potential air quality impacts during the construction and operation phases, respectively.  Air Sensitive Receivers (ASRs) have been identified and potential air quality impacts were evaluated.  Where necessary, mitigation measures are recommended to minimize the impacts and ensure compliance with the air quality criteria.

4.2                   Legislation Requirements and Evaluation Criteria

4.2.1             Air Pollutants Covered by Hong Kong Air Quality Objectives (HKAQOs)

The principal legislation for the management of air quality in Hong Kong is the Air Pollution Control Ordinance (APCO) (Cap. 311).  Under the APCO, the Hong Kong Air Quality Objectives (AQOs), which are presented in Table 4.2a, stipulate the statutory limits for air pollutants and the maximum allowable numbers of exceedences over specific periods.

Table 4.2a      Hong Kong Air Quality Objectives (mg m-3) (a)

Air Pollutant

Averaging Time

 

1 Hour (b)

24 Hour (c)

3 Months (d)

1 Year (d)

Total Suspended Particulates (TSP)

-

260

-

80

Respirable Suspended Particulates (RSP) (e)

-

180

-

55

Sulphur Dioxide (SO2)

800

350

-

80

Nitrogen Dioxide (NO2)

300

150

-

80

Carbon Monoxide (CO)

30,000

-

-

-

Photochemical Oxidants (as ozone (O3)) (f)

240

-

-

-

Lead (Pb)

-

-

1.5

-

Notes:

(a)     Measured at 298K (25°C) and 101.325 kPa (one atmosphere)

(b)     Not to be exceeded more than three times per year

(c)     Not to be exceeded more than once per year

(d)     Arithmetic means

(e)     Suspended airborne particulates with a nominal aerodynamic diameter of 10 micrometres or smaller

(f)       Photochemical oxidants are determined by measurement of ozone only

In addition, the Technical Memorandum of Environmental Impact Assessment Ordinance (EIAO-TM) stipulates an hourly TSP criterion of 500 mg m-3 for construction dust impact assessment and an odour criterion of 5 Odour Unit (OU) in 5-second averaging time for the odour impact assessment.

The measures stipulated in the Air Pollution Control (Construction Dust) Regulations should be followed to reduce dust impacts.

Should the fuel consumption rate of a premises/process with a chimney emission exceed the specified fuel consumption rates stated in the Air Pollution Control (Furnaces, Ovens and chimneys) (Installation and Alternation) Regulations, an approval for chimney installation/alternation should be obtained from the EPD prior to the operation.

Should the total quantity of organic liquid to be stored in tanks exceed 100 tonnes per annum, a licence must be obtained under the Air Pollution Control (Specified Process) Regulation and the control measures set out in the Guidance Note on the Best Practicable Means for Organic Chemical Works (Bulk Storage of Organic Liquids) (BPM 25/2) should be followed.

4.2.2             Air Pollutants Not Covered by HKAQOs

For those pollutants not covered by the HKAQOs, health risk criteria recommended in the international guidelines, such as those promulgated by the World Health Organisation (WHO), the United States Environmental Protection Agency (US EPA) and the California Air Resources Board (CARB) have been considered.  The criteria/guideline values were selected in the following order of preference:

·           WHO;

·           US EPA; and

·           CARB.

Cancer Health Risk Assessment

Of the non-criteria substances emitted during the operation, acetaldehyde is considered carcinogenic.  Table 4.2b shows the Unit Risk Factors (URFs) for the carcinogenic substances considered in this assessment.

Table 4.2b      Guideline Unit Risk Factor for Carcinogenic Substance

Substance

Unit Risk Factor (mg m-3)-1

Acetaldehyde

2.7x10-6 (a)

Note:

(a)     The unit risk factor (URF) of acetaldehyde [i.e. (1.5-9 x 10-7) (mgm-3)-1] is available in Guidelines for Air Quality, WHO, Geneva, 1999 (http://aix.meng.auth.gr/AIR-EIA/METHODS/AQGuide/aqguide3.pdf).  With reference to the USEPA-IRIS - online data as in Sept 2008 (http://www.epa.gov/iriswebp/iris/subst/0290.htm) and California Environmental Protection Agency, Air Resources Board (ARB)/Office of Environmental Health Hazard Assessment (OEHHA) – On-line data as in Sept 2008 (http://www.oehha.org/air/hot_spots/pdf/TSDlookup2002.pdf), the URFs of acetyldehyde are 2.2x10-6/mgm-3 and 2.7x10-6/mgm-3, respectively.  The highest URF, ie, 2.7x10-6/mgm-3 is adopted in the assessment as a conservative approach.

The risk assessment guidelines for assessing the carcinogenic health risk from exposure to air toxic are summarised in Table 4.2c.

Table 4.2c      Risk Assessment Guidelines for the Assessment of Carcinogenic Health Risks

Acceptability of Cancer Risk

Estimated Individual Lifetime Cancer Risk Level

Significant

> 10-4

Risk should be reduced to As Low As Reasonably Practicable (ALARP)

> 10-6 – 10-4

Insignificant

£ 10-6

Non-Cancer Health Risk Assessment

Acetaldehyde has the potential to cause chronic impacts from long term exposure whereas methanol has the potential to cause both acute and chronic impacts to humans from short term and long term exposures.  The chronic reference concentration of acetaldehyde and the acute and chronic reference concentrations of methanol are summarised in Table 4.2d.

Table 4.2d      Guideline Values for Chronic and Acute Reference Concentrations

Substance

Chronic Reference Concentration (RCc) (Annual Average in mg m-3)

Acute Reference Concentration (RCA) (Hourly in mg m-3)

Acetaldehyde

9 (a)

- (b)

Methanol

4,000 (c)

2.8x104 (d)

Notes:

(a)     The RCcs for acetaldehyde are both 9 mgm-3 with reference to the USEPA-IRIS - online data as in Sept 2008 (http://www.epa.gov/iriswebp/iris/subst/0290.htm) and California Environmental Protection Agency, Air Resources Board (ARB)/Office of Environmental Health Hazard Assessment (OEHHA) – On-line data as in Sept 2008 (http://www.oehha.org/air/hot_spots/pdf/TSDlookup2002.pdf).  RCc for acetaldehyde (ie, 50 mg m-3) is available in Guidelines for Air Quality, WHO, Geneva, 1999 (http://aix.meng.auth.gr/AIR-EIA/METHODS/AQGuide/aqguide3.pdf).  More stringent RCc for acetaldehyde of 9 mgm-3 is adopted in the assessment as a conservative approach..

(b)     No acute reference concentrations of acetyldehyde are available in WHO, CARB/OEHHA or USEPA-IRIS database.

(c)     The RCc for methanol is 4,000 mgm-3 with reference to California Environmental Protection Agency, Air Resources Board (ARB)/Office of Environmental Health Hazard Assessment (OEHHA) – On-line data as in Sept 2008 (http://www.oehha.ca.gov/air/chronic_rels/AllChrels.html).  No RCc for methanol is available in USEPA-IRIS database and WHO guidelines.

(d)     The RCA for methanol is 2.8x104 mgm-3 with reference to California Environmental Protection Agency, Air Resources Board (ARB)/Office of Environmental Health Hazard Assessment (OEHHA) – On-line data as in Sept 2008 (http://www.oehha.ca.gov/air/acute_rels/allAcRELs.html).  No RCA for methanol is available in USEPA-IRIS database and WHO guidelines.

The risk assessment guidelines also recommend criteria to assess the acceptability of chronic and acute non-cancer health risks and these are summarised in Tables 4.2e and 4.2f, respectively.

Table 4.2e      Acceptability of Chronic Non-Cancer Health Risks

Acceptability

Assessment Results (a)

Chronic non-cancer risks are considered “Insignificant

ACA £ RCc

Chronic non-cancer health risks are considered “Significant”.  A more detailed assessment of the control requirements and further mitigation measures are needed.

ACA > RCc

Note:

(a)     ACA and RCc represent annual average concentration and chronic reference concentration, respectively.

Table 4.2f       Acceptability of Acute Non-cancer Health Risks

Acceptability

Assessment Results (a)

Acute non-cancer risks are considered “Insignificant

ACHM £ RCA

Acute non-cancer health risks are considered “Significant”.  A more detailed assessment of the control requirements and further mitigation measures are needed.

ACHM > RCA

Note:

(a)     ACHM and RCA represent hourly average and acute reference concentrations, respectively.

4.3                   Baseline Conditions and Identification of Air Sensitive Receivers

4.3.1             Baseline Conditions

The Site is located at the southwest of the TKOIE on Chun Wang Street.  Gammon Skanska is located immediately south of the Site.  To the west and north of the Site are sea and vacant land, respectively.  The SENT Landfill is located at about 680m from the south-east of the Site.  The local air quality is dominated by emissions from facilities in the TKOIE, vehicle exhaust emissions from Chun Wang Street and Wan Po Road and background air quality in the Pearl River Delta.

There is no EPD Air Quality Monitoring Station (AQMS) operating the in Tseung Kwan O area.  The nearest EPD’s AQMS is located at Kwun Tong.  The means of the annual average air pollutant concentrations recorded at the Kwun Tong AQMS from 2003 to 2007 are adopted to establish the background air quality of the Study Area (see Table 4.3a).


Table 4.3a      Background Air Pollution Concentrations

Air Pollutant

Background Concentration

TSP

79 (a)

RSP

56 (a)

NO2

63 (a)

SO2

19 (a)

CO

1,181 (b)

Notes:

(a)     Annual average data on air pollutant concentrations measured at the EPD Kwun Tong AQMS from 2003 – 2007 (http://www.epd-asg.gov.hk/english/report/aqr.php).

(b)     Since no CO data is recorded at EPD Kwun Tong AQMS, therefore, the annual average CO data recorded at Mongkok AQMS from 2003-2007 is used.

4.3.2             Identification of Air Sensitive Receivers

Within the Study Area (ie 500m from the Site boundary), the land uses are all industrial.  No residential dwellings have been identified within 500m of the site boundary.  The nearest residential use (LOHAS Park), which is under construction, is located at about 0.8 km from the site boundary.  Representative ASRs were identified in line with the requirements set out in the EIA Study Brief (ESB-199/2004) and Annex 12 of the EIAO-TM and they are summarised in Table 4.3b and illustrated in Figure 4.3a.  The list includes existing and planned buildings within TKOIE, Areas 85 and 86.  Planned developments were identified with reference to the latest Outline Zoning Plans (No. S/TKO/16 gazetted in June 2008).

Table 4.3b      Representative Air Sensitive Receivers (ASRs)

ASR

Location

Type of Uses (a)

Approx. Distance from the nearest Project Site Boundary (m)

Approx. Max. Height of Building
(m above ground)

A1

Gammon Skanka

I

30

30

A2

Proposed Industrial Sites (No committed uses at the time of preparation of EIA)

I

25

30

A3

Hong Kong Trade Development Council Exhibition Services & Logistic Centre

C

140

30

A4

Hong Kong Aero Engine Services Ltd

I

310

30

A5

HAECO

I

440

30

A6-1

Asia Netcom HK Limited

I

255

30

A6-2

Asia Netcom HK Limited

I

345

30

A7

Mei Ah Centre

I

420

30

A8

Wellcome Co. Ltd (Storage)

I

345

30

A9

Hitachi Tseung Kwan O Centre

I

450

30

A10

Next Media Apple Daily

I

450

30

A11

Hong Kong Oxygen Acetylene Co. Ltd

I

355

30

A12-1

TVB City

I

510

30

A12-2

TVB City

I

550

30

A12-3

TVB City

I

560

30

A13

Yan Hing Industrial Building

I

515

30

A14

Next Media Apple Daily

I

530

30

A15

Avery Dennison

I

540

30

A16

Varitronix Limited

I

530

30

A17

Committed HSBC Office

C

700

30

A18

Eastern Pacific Electronics

I

780

30

A19

Committed Tung Wah Group of Hospital Aided Primary & Secondary School

G/IC

820

30

A20-1

LOHAS Park - 1

CDA

800

200

A20-2

LOHAS Park - 2

CDA

820

200

A20-3

LOHAS Park - 3

CDA

930

200

A21

Chiaphua-Shinko Centre

I

1,300

30

Note:

(a)       I = Industrial premises, C = Commercial premises, G/IC = Government/Institution/Community and CDA = Comprehensive Development Area

4.4                   Potential Sources of Impacts

4.4.1             Construction Phase

The Project Site is currently a vacant lot which has been formed by reclamation as part of the TKOIE development.  The construction works will last for about 13 months from March 2009, tentatively.  Foundation works will last for about 3 months.  A detailed construction programme is presented in Figure 3.2f. 

The total site area is about 18,000 m2.  Since the site has been formed, no major earthworks will be required for site formation.  Minor excavation works will be required for the construction of foundation works and site utilities.  Driven steel H piles with reinforced concrete pile caps will be used for the foundations of the buildings.  All excavated materials generated from foundation works and site levelling works will be reused on site.  The storage tanks and process equipment will be pre-fabricated off-site and assembled on-site using hydraulic and tower cranes and hence minimal dust will be generated from this activity.  About 4 to 5 trucks will be operating on site at the same time during the foundation works, and building and civil works.  According to the construction programme, there is no overlapping of the foundation works, and building and civil works.   

Dust generated from the excavation works and gaseous emissions from diesel-driven construction equipment are the major concerns during the construction phase.  As only minor excavation works will be required, the potential dust emissions will be minimal with the implementation of the dust control measures stipulated in the Air Pollution Control (Construction Dust) Regulation. The reinforced concrete buildings will be constructed on site using ready-mix concrete and conventional construction methods.  Limited dust will be emitted from the concreting works and assembling of the pre-fabricated units of the storage tanks and processing system.   

Due to the small site area, the number of diesel-driven construction plant and equipment operating simultaneously on-site will be limited.  The potential gaseous emissions from these plant and equipment are expected to be minimal and unlikely to cause adverse air quality impacts.

The jetty for the reception of marine vessels during the operation phase will be constructed by piled deck (see Figure 2.2b) and no dredging of marine sediment will be required.  Marine piles will be drilled through the existing rubble mound seawall to competent bearing strata by a piling rig mounted barge.  The bored piles will be filled with concrete prior to placement of trellis beam and pre-cast concrete panels.  The dust and air emissions generated from the marine works will be minimal.

With the implementation of dust suppression measures stipulated under the Air Pollution Control (Construction Dust) Regulation and the adoption of good site practices, the potential dust impacts will be controlled to within the relevant standards as stipulated in Section 1 of Annex 4 of the EIAO-TM.  No adverse impacts are anticipated.

4.4.2             Operation Phase

Potential air pollution sources from the biodiesel plant during the operation phase include the following:

·           Emissions from fuel combustion in the boilers;

·           Emissions from the standby biogas flare (if in operation);

·           Organic emissions from the Process Building;

·           Odour from final air scrubber which will scrub all the pre-treated exhaust gas from the unloading and treatment of Grease Trap Waste (GTW) and the on-site wastewater treatment plant; and

·           Vehicular emissions due to additional traffic associated with the operation of the biodiesel plant.

To assess potential cumulative air quality impacts, the emissions from the adjacent major stacks within the TKOIE were also considered.

Emissions from Fuel Combustion

The boilers are a dual-fuel fired boiler (which could utilise gas (eg biogas) or fuel oil (eg gas oil, or a mixture of gas oil and bio-heating oil (hereafter called oil mixture) ([1])) for production of steam for the biodiesel process and thermal oil system.  The Project Proponent is committed to use an appropriate fuel or a mixture of fuels which will comply with the new emission limits stipulated in the Air Pollution Control (Fuel Restriction) (Amendment) Regulation taking effect on 1 October 2008.  About 21.5 tonnes of the oil mixture will be required per day (which is equivalent to about 920 m3 of biogas per hour).  Under normal operation, biogas (a high energy value, 36.44 MJ Nm-3) generated from the IC Reactor of the wastewater treatment plant (an average of about 80 m3 hr-1 of biogas generated) will be used as the priority fuel which will be supplemented by oil mixture or gas oil.

The major air pollutants from the combustion of biogas and oil mixture (or gas oil) are expected to be carbon monoxide (CO), nitrogen dioxide (NO2) and a limited quantity of non-methane organic compounds (NMOCs) (if biogas is combusted) and sulphur dioxide (SO2).  The air pollutants will be emitted at a minimum exit velocity of 7 m s-1 and temperature of 100°C through a 31m stack with a diameter of 0.75m.

With reference to the emission factors for NO2, CO, SO2 and NMOCs established for biogas and oil mixture, a comparison of the emission rates from the boiler is summarised in Table 4.4a.


Table 4.4a      Comparison of NO2, CO, SO2 and NMOCs Emissions from Combustion of Biogas and Oil Mixture at Boiler

Parameter

Boiler

 

Biogas

Oil Mixture (Mixture of Gas Oil (80%) and Bioheating Oil (20%))

Stack Height (m above ground)

31

Stack Diameter (m)

0.75

Exhaust Velocity (m s-1)

7 (minimum)

Exhaust Temperature (°C)

100 (minimum)

Exhaust Flow Rate (m3hr-1)

11,133

Fuel Consumption (tonnes day-1)

-

21.5

Maximum Volume of Biogas (equivalent) & Oil Mixture Consumed (m3 hr-1)

920.7 (a)

0.995 (b)

Emission Factor for Biogas at Exhaust Temperature (mg m-3) (c) (d)

NOx

109.8

-

 

CO

36.6

-

 

H2S

10 (i)

-

 

NMOCs

3.7

-

Emission Factor for Oil Mixture (kg m-3) (f)

NOx

-

2.4

 

CO

-

0.6 (e)

 

SO2

-

0.864

Emission Rate (g s-1) (g) (h)

NOx

0.34

0.66

 

NO2

0.07

0.13

 

CO

0.11

0.17

 

SO2

0.01(j)

0.24

 

NMOCs

0.01

-

Notes:

(a)     Equivalent to oil mixture consumed.  Under normal operation, the actual biogas consumption is only about 80 m3 hr-1 produced from the IC Reactor based on the design capacity.

(b)     The density of oil mixture is about 900 kg m-3.

(c)     Due to the nature of biogas, the emission factor of biogas is assumed to be similar to that of landfill gas.

(d)     The emission factors of biogas were converted to that under exhaust gas condition.  The original emission factors of biogas used are reference to UK Guidance on the Management of Landfill Gas (http://www.environment-agency.gov.uk/commondata/acrobat/lftgn05_flares_936497.pdf) and are adjusted by the exhaust temperature.  Please also refer to Annex A1.

(e)     Reference to USEPA AP-42, Section 1.3, Table 1.3-1 (http://www.epa.gov/ttn/chief/ap42/ch01/final/c01s03.pdf).

(f)       Reference to Amendment of Air Pollution Control (Fuel Restriction) Regulation in June 2008.

(g)     The emission rate of air pollutants from combustion of oil mixture were calculated based on the volume of oil consumed.  The emission rate of air pollutants from combustion of biogas were calculated based on the exhaust flow rate.  Emission rate of air pollutant from combustion of oil mixture = emission factor (oil mixture) x volume of oil mixture consumed.  For example, NOx emission rate from combustion of oil mixture = (2.4x106 mg m-3) x (0.995 m3 hr-1) / (1,000 x 3,600) = 0.66 g s-1.  Emission rate of air pollutant from combustion of biogas = emission factor (biogas) x exhaust flow rate.  For example, NOx emission rate from combustion of biogas = (109.8 mg m-3) x (11,133 m3 hr-1) / (1,000 x 3,600) = 0.34 g s-1

(h)     Refer to Annex A1 for detailed emission rate calculation.

(i)       The emission factor of H2S (in ppm) in biogas is measured at 30°C and given by the plant design engineer.

(j)       The emission rate of SO2 from is calculated based on the equivalent biogas consumption rate of about 920.7 m3 hr-1.

It should be noted that there have been a number of research studies determine the NOx emissions from biodiesel compared with petroleum based diesel oil.  There is no commonly-agreed NOx emission factor for the combustion of biodiesel. 

Testing emissions from the combustion of biodiesel in a similar boiler was conducted by BDI.  A summary of the testing results is presented in Annex A2.  The testing results show that the NOx emissions range from 0.83 kg hr-1 to 1.01 kg hr-1 (ie, 0.23 g s-1 to 0.28 g s-1).  Compared to the emission factors given in Table 4.4a (which are based on the emission rates of petroleum based diesel oil), the NOx emissions analysed from the emission test are much lower.  Therefore, the assessment is considered conservative. 

Comparing the pollutant emission rates of biogas and oil mixture (see Table 4.4a), it is evident that the emission rates for the combustion of oil mixture are higher.  As a conservation assumption, it is assumed that the boilers will consume only oil mixture. 

Emissions from Standby Biogas Flare

Under normal operation, all the biogas generated from the IC reactor will be used as fuel for the boilers.  However, when the boilers are under maintenance, all the biogas generated will be flared.  The stack of the flare will be installed at about 12.5m above ground and located at to the on-site wastewater treatment plant.  The diameter of stack is about 0.96m and the flue gas flow rate is 1,407 m3 hr-1.

An air scrubber will be installed to remove the majority of the hydrogen sulphide (H2S) in the biogas (down to a maximum of 10 ppm) prior to combustion in the flare or boilers.  NO2, CO, SO2 (from destruction of H2S at high temperature) and NMOCs will be the key air pollutants from the emissions from the biogas flare. 

As a conservative assumption, it was assumed that the flare will be operating at its maximum capacity (ie 150 m3 hr-1 of biogas), the emission rates of NO2, CO, SO2 and NMOCs are summarised in Table 4.4b.

Table 4.4b      Emission of NO2, CO, SO2 and NMOCs from Standby Biogas Flare

Parameters

Standby Biogas Flare

Stack Height (m above ground)

12.5

Stack Diameter (m)

0.96

Exhaust Flow Rate (m3 hr-1)

1,407

Exhaust Temperature (°C)

815

Volume of Biogas to be flared off (Designed flare capacity)
(m3 hr-1)

150 (a)

Emission Factor of Biogas at Exhaust Temperature
(mg m-3) (b)

NOx

37.6

 

CO

12.5

 

H2S

10 ppm (c)

 

NMOCs

1.3

Emission Rate (g s-1) (b)

NOx

0.015

 

NO2

0.003

 

CO

0.005

 

SO2

1.07x10-3 (d)

 

NMOCs

4.9x10-4

Notes:

(a)       The design capacity of the flare is 150 m3 hr-1 of biogas.

(b)       Reference to Annex A1 for detailed calculation.

(c)       The emission factor of H2S in biogas is measured at 30°C and given by the plant design engineer.

(d)       SO2 is estimated from the H2S concentration in the biogas.  Reference to Annex A1 for detailed calculation.

Organic Emissions from Process Building

The biodiesel production is carried out inside the Process Building (refer to Section 3 for details of the production process).  A ventilation system is provided and about 50 m3 of process gas will be emitted per hour.  The exhaust gas consists mainly of nitrogen, and water, with a trace amount of methanol (a maximum concentration of 2,000 mg m-3 at 35 to 45 °C) and other trace organics (consisting of dimethyl ether, methyl butyrate and some impurities of methanol such as acetone and acetyldehyde ([2])).

Among of these organics, only acetyldehyde is classified as carcinogenic and has the potential to lead to chronic heath effects.  Methanol has also the potential to cause both chronic and acute health effects.

The emission inventory and exhaust vent pipe design parameters are summarized in Table 4.4c.

Table 4.4c      Emission of Acetyldehyde and Methanol from Process Building

Parameters

Exhaust Pipe of Process Building

 

Acetyldehyde

Methanol

Stack Height (m above ground)

22.8

Stack Diameter (m)

0.15

Exhaust Flow Rate (m3 hr-1)

50

Exhaust Temperature (°C)

35

Maximum Concentration at Stack (mg m-3)

2,000 (a)

2,000

Emission Rate (g s-1) (b)

0.028

0.028

Notes:

(a)       Since the percentage of acetyldehyde in the impurities of methanol is not known, it is assumed that all the impurities of methanol are acetyldehyde for the worst case assessment.

(b)       Refer to Annex A1 for detailed emission rate calculation.

Odour from Unloading and Treatment of GTW and On-site Wastewater Treatment Plant

The unloading and storage of GTW and operation of the wastewater treatment plant have the potential to cause odour nuisance if not properly managed.

Unloading and Treatment of GTW

GTW will be delivered to the biodiesel plant by sealed road tankers.  After weighing, the tankers will be directed to the unloading bays.  GTW will be discharged from the tanker directly to the underground storage tanks in a closed system (via a flexible hose).  The GTW received will be screened in the Belt Filter Room adjacent to the unloading bays to remove food residues and other large objects.   The screenings will be stored in containers inside the Technic Room.  The Belt Filter Room and the Technic Room will be enclosed and provided with a ventilation system which will maintain a slight negative pressure to prevent odour emissions.  The exhaust air from these rooms will be treated by an air scrubbing system (with a removal efficiency of >99.5% ([3])).  The scrubbed air will be diverted to the on-site wastewater treatment plant as the ventilation air for the enclosed wastewater treatment tanks. 

All biodiesel process tanks ([4]), including the GTW storage tanks will be enclosed and the exhaust air will be treated by an air scrubbing system (with a removal efficiency of >99.5%).  The scrubbed exhaust air will be diverted to the on-site wastewater treatment plant as part of the air intake for the aeration process and ventilation air for the enclosed wastewater treatment tanks.  Any residual odorous components in the exhaust air will be scrubbed by the wastewater.  The vent gas of the aeration tank will be cleaned by the final air scrubber (with a removal efficiency of >99.5%) prior to discharge to the atmosphere.

On-site Wastewater Treatment Plant

All wastewater storage and treatment tanks will be enclosed.  After the anaerobic digestion process in the IC Reactor, the Biochemical Oxygen Demand (BOD) of the wastewater will be significantly reduced (by about 80%) and hence the potential for odour nuisance is significantly reduced.  The vent air from the wastewater storage and treatment tanks will be cleaned by the final air scrubber prior to discharge to the atmosphere.

Summary

Figure 4.4a shows the flow rates of the scrubbed exhaust air from the GTW unloading and pre-treatment facilities and on-site wastewater treatment plant.

 

 

 

 

 

 

 

 

 

 

 


Figure 4.4a    Exhaust Air Flow Chart

There is only one emission point for the air scrubbers (which is the final air scrubber of the wastewater treatment plant).  The odour concentration after treatment at the final air scrubber will be controlled at a limit of 257.6 OUm-3.  The exhaust air from the final air scrubber will be dispersed at ambient temperature with a flow rate of 2,800 m3 hr-1.  The details of the stack and odour emission rate are summarised in Table 4.4d.

Table 4.4d      Odour Emission from Final Scrubber

Parameters

Final Scrubber

Stack Height (m above ground)

13.8

Stack Diameter (m)

1.2

Exit Flow Rate (m3 hr-1)

2,800

Exit Temperature (°C)

ambient

Maximum Odour Concentration at Exhaust Point (OU m-3) (a)

257.6

Odour Emission Rate (OU s-1) (b)

200.3

Notes:

(a)       Monitoring will be performed to ensure the odour concentration emitted from the exhaust point will not exceed the maximum odour concentration.  This will be included in the Contract Specification.

(b)       Refer to Annex A1 for detailed odour emission rate calculation.

Emissions from Delivery Trucks

Vehicular emissions induced from the Project are expected to be negligible since additional traffic associated with the operation of the biodiesel plant only constitutes a very small percentage (0.47%) of the total background traffic on Wan Po Road (ie 93 trucks per day compared to AADT of 19,860 in 2006, refer to Section 5.4.2).  It is therefore considered that the potential air quality impact due to additional traffic is negligible and will not cause an adverse air quality impact.

Emissions from Marine Vessels during Berthing

According to Section 3.2.2 and Table 3.2b, PFAD, biodiesel and methanol will be delivered by barge.  It is estimated that about 4 barges will be berthed per week and it takes less than 15 minutes for the marine vessel to travel fro 500m from the approach channel to the jetty and berth.  Therefore, the potential air quality impact during maneuvering of the marine vessel will be transient and negligible.  PFAD and methanol delivered to the Site by barge will be pumped to the storage tanks using dedicated pipelines.   Flexible hoses will be used to connect storage the tanks of the barge to the pipelines at the jetty.  During berthing, the main engine and the auxiliary engine of the vessels will be switched off to minimize the emissions.  The power supply to the marine vessels will be provided by an on-site power supply.  Therefore, no emission is anticipated from the marine vessels during berthing.

4.4.3             Cumulative Impacts

Construction Phase

The operation of TKO Area 137 Fill Bank and existing SENT Landfill and the construction of the TKO Further Development works are identified as concurrent projects during the construction of the biodiesel plant (see Section 3.3).

TKO Area 137 Fill Bank and existing SENT Landfill are located at south and east of the biodiesel plant, respectively and the nearest distance from the existing SENT Landfill to the Project Site is about 700m.  The TKO Area 137 Fill Bank is further away.  Given the large separation distances and different worst case wind directions, it is not anticipated that these concurrent projects will cause adverse cumulative dust impacts.

The TKO Further Development – Infrastructure works site is located at more than 2 km from the biodiesel plant.  It is therefore, not anticipated that it will cause cumulative dust impact to the identified ASRs.

Operation Phase

A chimney survey within the TKOIE was conducted in January 2008 and the major emissions sources within 500m from the Project Site boundary are HAESL and TVB City.  The survey team has approached the operators of the TKOIE to obtain stack emission data.  Only TVB City and HAESL are willing to provide information about their stacks.  In addition, the Consultant has consulted the Hong Kong Science and Technology Parks Corporation (HKSTPC, who manages the TKOIE) regarding the fuel consumption of the premises within the TKOIE.  They confirmed that most of the tenants in the TKOIE are using electricity for their plant operation. 

Interviews with TVB City and HAESL were also conducted to validate the stack operation and its emission inventory.

According to the information provided by TVB City and the public information obtained from the EPD Regional Office (East), the major gaseous emission sources identified at TVB City are the emergency generators.  As the emergency generators will only operate when CLP’s grid is suspended, the operating time of these generators is very limited and is not expected to cause cumulative air quality impacts within the Study Area.

With reference to the EIA Report of HAECO/HAESL Aircraft Engine Test Cell Facility at TKO, NO2, CO and SO2 are the key air pollutants to be emitted during engine testing.  These emission rates and stack characteristics are summarized in Table 4.4e.

Table 4.4e      Stack and Emission Characteristics of HAESL (a)

Stack ID

No. of Stacks

Efflux Velocity
(m s-1)

Stack Diameter (m)

Stack Height Above Ground (m)

Exit Temp. (°C)

Emission Rate (g s-1)

 

NO2

CO

SO2

HAECO / HAESL (b)

1

16.4 for NO2 & SO2;
12 for CO

14.7

40

52

21.2

23.9

1.92

Notes:

(a)       Reference to the EIA Report of HAECO Aircraft Engine Test Cell Facility at TKO.

(b)       It is the equivalent diameter.  The stack is in square shape with an area of 13m x 13m.

These data have been confirmed by HAESL.  The emissions of NO2, CO and SO2 from HAESL are included to assess the cumulative air quality impact during the operation phase.

To assess the potential cumulative air quality impact due to other minor emission sources in TKOIE, the Consultant has made reference to the emission sources and data adopted in the approved EIA Report of Fill Bank at TKO Area 137.  The estimation of the emissions from these sources has taken account of the total fuel consumption of the whole TKOIE which includes potential future emission sources.  The assessment is therefore considered conservative.  The facilities were assumed to operate for 10 hours a day on an annual basis, as detailed in the reference report.  Emission rates of NO2 from the potential sources were similar to those in the TKO 137 Fill Bank EIA, while emission rates of CO and SO2 were calculated with reference to the USEPA Compilation of Air Pollutants Emission Factors, 5th Edition (AP42) (1995) and the SO2 emission limit stipulated in the Air Pollution Control (Fuel Restriction) Regulation Amendment 2008, respectively.  Calculation details of respective emission rates are presented in Annex A1.

No similar odour source is identified within 500m of the Project site boundary and hence, no cumulative odour impact is expected.

4.5                   Assessment Methodology (Operational Air Quality Impact)

Stack Emissions from Boiler Stack, Biogas Flare, Process Building and Existing HAESL

An emission inventory for the boiler stack, Process Building, HAESL stack and other emission sources in TKOIE during normal operation of the biodiesel plant is summarised in Table 4.5a.  It should be noted that the biogas flare will only be operated when the boiler is shut down for maintenance.  Under such a situation, the emission from the biogas flare will be lower than that from the boilers.  However, as the gas exhaust temperature, characteristics and location of biogas flare are different from boiler, the emissions from the biogas flare will also be considered as a separate scenario in the detailed assessment.  The emission inventory for the biogas flare during emergency operation is also summarised in Table 4.5a.  Figure 4.5a illustrates the location of the emission points.

Table 4.5a      Summary of Stack Information and Emission Inventory

Parameter

Boiler Stack

Biogas Flare

Process Building

HAESL Stack

TKOIE Stacks(f)

Operating Hours

24

24

24

24

10

No. of Stack

1

1

1

1

21

Stack Height (m above ground)

31

12.5

22.8

40

10

Stack Diameter (m)

0.75

0.96

0.15

14.7

1.2

Flue Gas Exit Temperature (°K)

373

1,088

308

325

463.15

Flue Gas Exit Velocity (m s-1)

7

0.54

0.79

16.4
(NO2 & SO2);
12 (CO)

9.00

Emission Rates (g s-1) (a)

NOx

0.66

0.015

-

106

 

NO2 (b)

0.13

0.003

-

21.2

0.043 (c)

 

CO

0.17

0.005

-

23.9

0.042(d)

 

SO2

0.24

1.07x10-3

-

1.9

0.06(e)

 

Acetyldehyde

-

 

0.028

-

 

 

Methanol

-

 

0.028

-

 

Notes:

(a)     As shown in Table 4.4a, burning of mixture of gas oil/bioheating oil generates higher emission rates of air pollutants than burning of biogas.

(b)     It is assumed that 20% of NOx emitted from the stacks will be converted to NO2.

(c)     Reference has been made to NO2 emission rates in the Fill Bank at TKO Area 137 EIA Report (EIA – 076/2002)

(d)     CO emission rate is calculated with reference to the USEPA Compilation of Air Pollutants Emission Factors, 5th Edition (AP42) (1995)

(e)     SO2 emission rate is calculated with reference to the SO2 limit stipulated in the Air Pollution Control (Fuel Restriction) Regulation Amendment 2008

(f)       With reference to approach adopted in the approved TKO Area 137 Fill Bank EIA Report

Hourly, daily and annual average NO2, CO and SO2 concentrations, hourly methanol concentration and annual average acetyldehyde and methanol concentrations at different elevations (1.5m to 120m) of the identified ASRs were predicted using an EPD approved air dispersion model, Industrial Source Complex Short-Term (ISCST3).  The meteorological data recorded at the TKO Weather Station in 2003 ([5]) and “rural” mode were used for the model runs as the Project Site is located along the waterfront.

Two scenarios were established for the model run:

Scenario 1 : Under Normal Operation (Emission from Boiler Stack)

Scenario 2 : Under Emergency Operation (Emission from Biogas Flare)

In each scenario, emissions from HAESL and other emission sources in TKOIE are also included in the model to assess the cumulative impact.  Background air pollutant concentrations (refer to Table 4.3a) were added to the modelled cumulative results to assess the total air quality impacts at the ASRs.

Odour Emission from Final Air Scrubber

Table 4.5b summarises the odour emission inventory of the exhaust air after treatment by the final scrubber.

Table 4.5b      Odour Emission Inventory

Parameter

Final Scrubber Exhaust Stack

Operating Hours

24

No. of Stacks

1

Vent Duct Height (m above ground)

13.8

Vent Duct Diameter (m)

1.2

Exhaust Air Exit Temperature (°K)

Ambient temperature

Exhaust Air Exit Velocity (m s-1)

0.7

Odour Concentration at Exhaust Duct (OU m-3)

257.6

Odour Emission Rate (OU s-1)

200.3

An EPD approved air dispersion model, ISCST3, was used to predict the odour concentration at different elevations of the identified ASRs.  Other modeling parameters are similar to those adopted in the stack emission assessment.

The model output corresponds more closely to a maximum 15-minute average concentration.  This matter relates to the Pasquill-Gifford vertical dispersion parameter used in the ISCST model which is fully documented in the Workbook on Atmospheric Dispersion Estimates. 

In order to convert the model outputs to maximum 5-second average concentrations, a two-step conversion process has been defined.

Step 1:

Conversion of the model output to a maximum 3-minute average, using the power law formula proposed by Duffee et al ([6]), which is reproduced below:

 

Where:

Xl = concentration for the longer averaging time;

Xs = concentration for the shorter averaging time;

ts = shorter averaging time;

tl = longer averaging time; and

p = power law exponent, which depends on the Pasquill stability class, and is detailed in Table 4.5c.

Table 4.5c      Power Law Exponents

Pasquill Stability Class

p

A

0.5

B

0.5

C

0.333

D

0.2

E

0.167

F

0.167

Step 2:

To convert 3-minute average to maximum 5-second average concentration, the approach suggested by the Warren Spring Laboratory ([7]) was adopted:

Typical maximum or peak 5-second average concentrations within any 3-minute period appear to be of the order of 5 times the 3-minute average.  During very unstable conditions larger ratios, perhaps 10:1, are more appropriate…..

The resulting factors for converting the model outputs to 5-second averages are presented in Table 4.5d.

Table 4.5d      Factors for Converting Model Outputs to Maximum 5-second Mean Odour Concentration

Pasquill Stability Class

Conversion 15-minute to 3-minute Average

Conversion 3-minute to 5-second Average

Overall Conversion Factor

A

2.23

10

22.3

B

2.23

10

22.3

C

1.70

5

8.50

D

1.38

5

6.90

E

1.31

5

6.55

F

1.31

5

6.55

The overall conversion factors under different stability classes are applied to the model so that the predicted outputs are in 5-second averages. 

Isopleths showing 5-second odour levels are plotted at the different assessment heights.

4.6                   Evaluation of Impacts

Stack Emissions from Boiler Stack, Standby Flare, Process Building and HAESL

NO2, CO and SO2

The maximum hourly, daily and annual average concentrations of NO2 and SO2 and maximum hourly and 8-hour average CO concentrations were predicted at various heights at the identified ASRs.  The highest cumulative maximum hourly, daily and annual average concentrations of NO2 and SO2 and maximum hourly and 8-hour average CO concentrations, taking account of the background air quality, are summarised in Table 4.6a for both scenarios.  The predicted concentrations of these air pollutants at different ASR elevations are summarized in Annex A4.

Table 4.6a      Predicted Highest Cumulative Air Pollutant Concentrations at ASRs

ASR

Highest Hourly Concentration (µg m-3)

Highest 8-hour Concentration (µg m-3)

Highest Daily Average Concentration (µg m-3)

Annual Average Concentration
(
µg m-3)

 

NO2

CO

SO2

CO

NO2

SO2

NO2

SO2

Scenario 1 : Normal Operation (Emission from Boiler Stack)

A1

96.5

1,224

79.5

1,200

72.3

35.7

65.5

23.24

A2

99.0

1,227

84.5

1,205

74.0

39.1

65.2

22.75

A3

77.2

1,200

45.2

1,186

65.3

23.1

63.6

19.76

A4

84.1

1,202

48.4

1,191

66.6

24.0

64.1

20.45

A5

71.2

1,189

30.4

1,184

64.7

20.7

63.6

19.57

A6-1

80.3

1,198

43.1

1,186

65.0

21.7

63.5

19.62

A6-2

209.9

1,324

224.0

1,253

94.2

62.5

65.4

22.24

A7

97.8

1,216

68.4

1,191

66.9

23.7

63.4

19.52

A8

89.0

1,207

54.6

1,191

66.9

23.8

63.6

19.80

A9

69.3

1,189

30.5

1,184

64.4

21.1

63.4

19.42

A10

71.7

1,192

35.1

1,186

65.1

21.5

63.4

19.52

A11

77.0

1,195

39.3

1,190

66.2

24.4

63.9

20.24

A12-1

79.9

1,197

42.5

1,190

66.4

23.8

63.9

19.92

A12-2

84.7

1,202

49.3

1,191

67.2

24.9

64.0

20.39

A12-3

110.3

1,227

85.0

1,208

74.6

35.2

64.2

20.61

A13

74.7

1,192

35.4

1,185

64.9

21.3

63.4

19.47

A14

68.3

1,188

28.8

1,185

64.6

21.0

63.3

19.37

A15

72.0

1,193

35.6

1,184

64.6

21.3

63.3

19.39

A16

73.5

1,194

37.2

1,185

65.0

22.0

63.5

19.65

A17

103.9

1,221

76.0

1,195

68.7

27.0

64.4

20.89

A18

79.3

1,201

47.2

1,188

67.0

25.4

63.6

19.89

A19

91.1

1,209

58.3

1,201

72.3

32.2

64.0

20.39

A20-1

104.1

1,249

92.1

1,196

69.0

26.5

63.4

19.54

A20-2

90.8

1,225

51.0

1,196

68.7

24.1

63.5

19.61

A20-3

128.4

1,291

86.2

1,216

72.7

29.1

63.9

20.08

A21

75.4

1,198

39.4

1,189

66.1

23.8

63.4

19.56

Scenario 2 : Emergency Operation (Emission from Biogas Flare)

A1

80.8

1,198

43.8

1,189

66.5

23.9

63.8

19.97

A2

70.0

1,188

28.8

1,184

64.6

20.6

63.7

19.82

A3

74.0

1,192

34.3

1,185

65.0

21.7

63.5

19.62

A4

84.1

1,202

48.4

1,191

66.6

24.0

64.1

20.42

A5

71.2

1,189

30.4

1,184

64.7

20.4

63.6

19.52

A6-1

80.3

1,198

43.1

1,186

65.0

21.7

63.5

19.57

A6-2

209.9

1,324

224.0

1,253

94.2

62.5

65.4

22.18

A7

95.7

1,213

64.6

1,191

66.7

23.5

63.4

19.46

A8

89.0

1,207

54.6

1,191

66.9

23.8

63.6

19.77

A9

67.6

1,188

24.1

1,184

64.4

20.4

63.3

19.39

A10

69.0

1,190

25.6

1,185

64.5

20.3

63.4

19.47

A11

77.0

1,195

38.5

1,187

65.8

22.9

63.6

19.81

A12-1

79.9

1,197

42.5

1,190

66.4

23.8

63.9

19.84

A12-2

84.7

1,202

49.3

1,191

67.2

24.9

64.0

20.29

A12-3

110.3

1,227

85.0

1,208

74.6

35.2

64.2

20.58

A13

74.7

1,192

35.4

1,185

64.9

21.3

63.4

19.43

A14

67.5

1,185

25.2

1,185

64.6

21.0

63.3

19.35

A15

67.1

1,187

24.7

1,184

64.4

20.5

63.3

19.34

A16

70.3

1,192

27.1

1,185

64.5

20.3

63.4

19.52

A17

103.9

1,221

76.0

1,195

68.7

27.0

64.4

20.84

A18

76.1

1,196

36.6

1,188

65.6

21.0

63.4

19.40

A19

90.9

1,208

57.9

1,201

71.4

30.5

63.9

20.11

A20-1

104.1

1,249

45.4

1,196

68.8

21.7

63.3

19.31

A20-2

90.8

1,225

51.0

1,196

68.3

22.1

63.4

19.39

A20-3

128.4

1,291

86.2

1,216

72.6

28.4

63.9

19.93

A21

75.3

1,198

34.6

1,188

65.0

21.5

63.3

19.35

AQO

300

30,000

800

10,000

150

350

80

80

Notes:

(a)     Background concentrations (NO2 of 63 µg m-3, CO of 1,181 µg m-3 and SO2 of 19 µg m-3) have been included.

(b)     The predicted concentrations of these air pollutants at different ASR elevations are summarized in Annex A4.

The predicted cumulative maximum NO2, CO and SO2 concentrations under different averaging times at various heights at ASRs A1 – A19 and A21 are well within the respective AQOs.  The worst affected height is at 30m above ground.  The highest cumulative maximum NO2, CO and SO2 concentrations, including the background air quality, are predicted at 30m above ground; the ASR that is affected the most varies depending on the averaging period.

The maximum contribution of hourly NO2 concentration at the identified ASRs from the operation of the biodiesel plant alone is at ASR A2, which is located immediately at the south of the Project Site.  It is about 34%of the total predicted concentration at A2 (34 µgm-3 contributed from the biodiesel plant operation during normal condition). 

The predicted cumulative maximum NO2, CO and SO2 concentrations under different averaging times at various heights at LOHAS Park (A20) are also well within the respective AQOs. 

Referring the predicted results presented in Table A4-1 of Annex A4, the maximum hourly NO2 concentration at LOHAS Park due to the operation of the biodiesel plant, (ie 39.6 µg m-3, which is about 13.2% of the hourly AQO criterion for NO2), is predicted at 60m above ground.  The predicted hourly NO2 concentrations at this ASR due to the operation of the biodiesel plant reduce with increasing height and at 120m above ground the hourly NO2 concentration reduced to 2.8 µg m-3, which is about 0.9% of the hourly AQO criterion for NO2.  This suggests that at level higher than 120m, the Project contribution to the total hourly NO2 concentrations at LOHAS Park will be negligible and there will be no cumulative impact.  

The highest predicted cumulative maximum hourly NO2 concentrations (including background) at LOHAS Park at 60m and 120m above ground are 114 µg m-3 and 128 µg m-3 respectively, which are well below the AQO criterion.

Figures 4.6a to 4.6e and 4.6h to 4.6j present the isopleths of the cumulative maximum average hourly NO2 concentrations at 1.5m to 30m above ground and 60m, 90m and 120m at LOHAS Park.  Figures 4.6f and 4.6g present the isopleths of the cumulative maximum daily and annual average NO2 concentrations at 30m above ground (the worst affected height) within 500m of Study Area, respectively.  The isopleths show that the impacts comply with the EIAO-TM assessment criterion. 

The assessment indicates that the operation of the proposed biodiesel plant in the TKOIE will not cause adverse air quality impacts to the identified ASRs at TKOIE, Areas 85 and 86.

Acetyldehyde and Methanol

Non-cancer Health Risk Assessment:  The predicted hourly methanol concentration and annual average acetyldehyde and methanol concentrations at different ASR elevations are presented in Annex A4 and the highest predicted results are summarized in Table 4.6b.

Table 4.6b      Predicted Highest Hourly Concentration of Methanol and Annual Average Concentrations of Acetyldehyde and Methanol

ASR

Predicted Highest Hourly Concentrations (µg m-3)

Predicted Highest Annual Average Concentrations (µg m-3)

 

Methanol

Methanol

Acetyldehyde

A1

15.5

1.27

1.27

A2

58.9

2.90

2.90

A3

10.6

0.32

0.32

A4

5.2

0.10

0.10

A5

6.8

0.10

0.10

A6-1

7.1

0.08

0.08

A6-2

6.3

0.08

0.08

A7

5.4

0.06

0.06

A8

7.0

0.05

0.05

A9

6.2

0.04

0.04

A10

3.0

0.04

0.04

A11

7.7

0.16

0.16

A12-1

6.4

0.16

0.16

A12-2

4.0

0.07

0.07

A12-3

5.8

0.07

0.07

A13

5.8

0.05

0.05

A14

6.2

0.04

0.04

A15

3.3

0.03

0.03

A16

6.5

0.06

0.06

A17

2.2

0.05

0.05

A18

5.1

0.11

0.11

A19

5.7

0.10

0.10

A20-1

3.9

0.02

0.02

A20-2

4.6

0.05

0.05

A20-3

1.3

0.03

0.03

A21

4.7

0.06

0.06

Reference Concentration :

2.8x104

4,000

9

The results indicate that the predicted hourly concentration of methanol and annual average concentrations of acetyldehyde and methanol at the identified ASRs are well below the respective reference chronic and acute concentrations.  Hence, the chronic and acute health impacts of acetyldehyde and methanol are considered to be insignificant. 

Cancer Health Risk Assessment:  The calculated individual cancer health risk levels of acetyldehyde at different elevations of the identified ASRs are presented in Annex A4 and the highest individual risk level of ASRs are summarized in Table 4.6c.

Table 4.6c      Individual Cancer Risk of Acetyldehyde

ASR

Predicted Highest Individual Cancer Risk of Acetyldehyde (a)

A1

3.43E-06

A2

7.82E-06

A3

8.61E-07

A4

2.78E-07

A5

2.83E-07

A6-1

2.28E-07

A6-2

2.05E-07

A7

1.67E-07

A8

1.37E-07

A9

9.65E-08

A10

1.10E-07

A11

4.31E-07

A12-1

4.19E-07

A12-2

1.86E-07

A12-3

1.76E-07

A13

1.30E-07

A14

9.77E-08

A15

7.00E-08

A16

1.52E-07

A17

1.44E-07

A18

3.00E-07

A19

2.61E-07

A20-1

5.27E-08

A20-2

1.32E-07

A20-3

7.48E-08

A21

1.63E-07

Note:

(a)       Unit risk factor of acetyldehyde (as presented in Table 4.2b) was used for the calculation.  The individual risk level is calculated by the predicted annual average concentration of acetyldehyde multiplying the unit risk factor.

The calculated individual cancer risk levels of acetyldehyde at different elevations at the identified ASRs are lower than 10-6 except at A1 and A2.  For A1 and A2, the risk should be reduced to As Low As Reasonably Practicable (ALARP).  It should be noted that the assessment conservatively assumed that all the impurities of methanol are acetyldehyde (see Section 4.4.2) and it is expected that the actual risk will be lower than predicted in this assessment.   

Odour Emission from Final Scrubber

The predicted maximum 5-second odour levels at different elevations of ASRs are presented in Annex A4 and the highest predicted odour levels at ASRs are summarized in Table 4.6d.

The predicted 5-second average odour levels at various heights at the identified ASRs are well within the odour criterion (ie 5 OU in 5-second averaging time). 

Figures 4.6k to 4.6o present the isopleths of the predicted maximum 5-second odour levels at different heights of the identified ASRs.  The isopleths show that the odour impacts are localized and comply with the EIAO-TM assessment criterion.  Hence, no adverse odour impact is anticipated.

Table 4.6d      Highest Predicted Maximum 5-second Odour Levels

ASR

Predicted Maximum 5-second Odour Level (Odour Unit)

A1

2.7

A2

2.2

A3

1.0

A4

1.2

A5

0.9

A6-1

0.6

A6-2

1.1

A7

0.9

A8

0.6

A9

0.5

A10

0.3

A11

0.5

A12-1

0.7

A12-2

0.5

A12-3

0.2

A13

0.3

A14

0.2

A15

0.3

A16

0.4

A17

0.4

A18

0.1

A19

0.1

A20-1

0.1

A20-2

0.3

A20-3

0.3

A21

0.1

5-second Odour Criterion :

5

4.7                   Mitigation Measures

4.7.1             Construction Phase

Although the construction dust impact is expected to be minimal, the following dust control measures stipulated in the Air Pollution Control (Construction Dust) Regulation will be implemented to further reduce the fugitive dust emission as much as possible:

·           Dust control measures such as water spaying on roads and dusty areas, covering of lorries by impervious sheets and controlling of the falling height of fill materials will be implemented;

·           Effective dust screens, sheeting or netting will be provided to enclose the scaffolding from the ground level of the facility during the building construction;

·           All debris and materials will be covered or stored in a sheltered debris collection area; 

·           Hoarding from ground level will be provided along the entire length of the site boundary except for a site entrance or exit;

·           Every stockpile of dusty materials will be covered entirely by impermeable sheeting or placed in an area sheltered on the top and the 3 sides.

Good site practices such as regular maintenance and checking of the diesel powered mechanical equipment will be adopted to avoid any black smoke emissions and to minimize gaseous emissions.

4.7.2             Operation Phase

No mitigation measures will be required.

4.8                   Residual Impacts

4.8.1             Construction Phase

No adverse residual impact is anticipated after the implementation of the recommended mitigation measures described in Section 4.7.1.

4.8.2             Operation Phase

No adverse residual impact is anticipated.

4.9                   Environmental Monitoring and Audit

4.9.1             Construction Phase

As the scale of construction works is small, no dust monitoring (in terms of TSP) is required.  However, regular site audit (ie monthly) will be performed to ensure the implementation of suitable dust control measures and good site practices recommended in Section 4.7.1.

4.9.2             Operation Phase

NOx, CO, SO2 and NMOC concentrations in the flue gas of the stacks of the boilers and biogas flare (if in operation), methanol and acetyldehyde concentrations in the vent gas of process building will be monitored on monthly basis for the first year of the operation.  If the results of the first year monitoring meet the limit levels, the monitoring will be reduced to half-year intervals for the operational stage.  Exhaust gas temperature and exhaust gas velocity will also be monitored at the same frequency. 

Odour concentration at the stack of the final air scrubber will be monitored on monthly basis for the first two years of the operation.  Exhaust gas temperature and exhaust gas velocity of the final scrubber will also be monitored at the same frequency. 

Odour patrol will be carried out along the Project Site boundary on monthly basis during the first year of the operation of the biodiesel plant.  If there is no exceedance of action limit or there is no substantiated odour compliant during the first year of operation, the monitoring frequency will be reduced to quarterly intervals in the second year of the operation.  During the second year of operation, if the action level is triggered, the frequency will be resumed to monthly until compliance with the action level for three consecutive months is obtained and the frequency will be reduced to quarterly interval thereafter.  If the action level is not triggered for four consecutive quarterly monitoring, the monitoring can be terminated

Detailed monitoring programme and requirements are presented in Section 9.2.

4.10               Conclusions

4.10.1         Construction Phase

The Site has been formed and is currently vacant.  No major earthworks will be required for the site formation works and only minor excavation works will be required for the construction of the foundation works and site utilities.  The storage tanks and process equipment will be pre-fabricated off-site and assembled on site using hydraulic and tower cranes and hence minimal dust will be generated from this activity.  Dust generated from the minor excavation works and concreting works for the construction of site buildings will be minimal.  The dust and air emissions generated from the marine works will be minimal.

The jetty will be constructed by piled deck and no dredging of marine sediment will be required.  Marine piles will be drilled through the existing rubble mound seawall to competent bearing strata by a piling rig mounted barge.  The bored piles will be filled with concrete prior to placement of trellis beam and pre-cast concrete panels.  The dust and air emissions generated from the marine works will be minimal.

With the implementation of dust suppression measures stipulated under the Air Pollution Control (Construction Dust) Regulation and the adoption of good site practices, no adverse construction dust impact is anticipated.  Dust monitoring during the construction phase is therefore considered not necessary.

Monthly site audits will be conducted to ensure the implementation of suitable dust control measures and good site practices during the construction phase.

4.10.2         Operational Phase

The stacks of the boiler and biogas flare (if in operation), and the exhaust of the Process Building are the major emission sources associated with the operation of the biodiesel plant.  Nitrogen dioxide (NO2), carbon monoxide (CO), sulphur dioxide (SO2), non-methane organic compounds (NMOC) are the principal emission of concerns of the boiler and biogas flare stacks, and methanol and acetyldehyde (as one of the impurities of methanol) are the principal emissions of concerns for the exhaust of the Process Building.  The assessment indicates that the operation of the proposed biodiesel plant together with the existing air emission sources in the TKOIE, will not cause adverse air quality impacts at the identified ASRs.  The predicted concentrations of pollutants are well below the respective criteria.

The potential odour impact due to the discharge of exhaust air from the final air scrubber of the on-site wastewater treatment plant has been evaluated.  After scrubbing, the odour concentration will be significantly reduced and will not cause adverse odour impacts to the identified ASRs.

The concentrations of NOx, CO, SO2 and NMOC in the flue gas of the stacks of the boiler and biogas flare (if in operation) and the concentrations of methanol and acetyldehyde from the exhaust pipe of process building will be monitored for during the operation of the biodiesel plant.

Odour concentration at the stack of the final air scrubber will be monitored for the first two years of operation of the biodiesel plant and odour patrols along the Project Site boundary will also be carried out to confirm that the operation of biodiesel plant will not cause adverse odour impacts.

With the implementation of proper design, the recommended mitigation measures and monitoring programme, it is concluded that the construction and operation of the biodiesel plant will not cause adverse air quality impacts and will comply with the EIAO-TM requirements.


 



([1]) Bio-heating oil is a lower grade biodiesel.  The physical properties of bio-heating oil could be referred to Annex E.  To meet the SO2 emission limit stated in the amendment of the Air Pollution Control (Fuel Restriction) Regulation, which was in place in June 2008, a mixture of gas oil (light diesel oil) (80%) and bioheating oil (20%) will be used as fuel for the boiler operation. 

([2])      The maximum total concentration of all the organics is 2,000 mg m-3.

([3])     It should be noted that a number of commercially available air scrubbing systems could achieve a H2S removal efficiency higher than 99.5%.  To be conservative, an odour removal efficiency of 99.5% is assumed in the assessment.

([4])     Except for the storage tanks of acids (sulphuric acid and phosphoric acid), base and methanol as these materials are not cause odour nuisance.

([5])     More than 90% raw meteorological data obtained from the HKO are valid.

([6]) RA Duffee, MA O'Brien & N Ostojic, Odour Modelling - Why and How, Air & Waste Management Association.

([7])   Warren Spring Laboratory, "Odour Control - A Concise Guide", 1980