9 Environmental Monitoring and Audit

9.1 Introduction

This Section elaborates the EM&A requirements for the construction and operation of the Biodiesel Plant, based on the assessment results for the various environmental issues considered.

The objectives of undertaking EM&A for the Project are as follows:

· to provide a database against which the environmental impacts of the Project can be determined;

· to provide an early indication should any of the environmental control measures or practices fail to achieve the acceptable standards;

· to monitor the performance of the Project and the effectiveness of mitigation measures;

· to verify the environmental impacts predicted in this EIA;

· to determine project compliance with regulatory requirements, standards and government policies;

· to take remedial action if unexpected problems or unacceptable impacts arise; and

· to provide data to enable an environmental audit.

With respect to the findings and recommendations of the EIA study, the following sections describe the EM&A requirements during construction and operational phases of the Project. The Implementation Schedule, containing the recommended mitigation measures, monitoring and audit requirements, and implementation agent of the mitigation measures for the Project, is presented in Annex D.

9.2 Air Quality

9.2.1 Construction Phase

As no adverse dust impact is anticipated, no dust monitoring (in terms of TSP) is required. However, monthly site audits will be conducted to ensure the implementation of suitable dust control measures and good site practices recommended in Section 4.7.1.

9.2.2 Operational Phase

Monitoring of the emissions of the boiler stack, biogas flare (if in operation) and process building, and odour concentrations at the final scrubber stack will be carried out. Odour patrols along the Project Site boundary will also be conducted. The purpose of the monitoring is to ensure the emissions from the boiler, biogas flare, process building and final scrubber are operated under its design conditions and emission limits.

Monitoring Parameter, Location and Frequency

The operating conditions (ie exhaust gas temperature and velocity) of the boiler, biogas flare (if in operation), and process building stacks will be monitored at monthly intervals for a period of 12 months after the commissioning of the biodiesel plant. If the monitoring results of the first year monitoring meet the limit level, the monitoring will be reduced to half-yearly intervals for the whole operational stage. For odour monitoring at the final air scrubber, the monitoring will be conducted for the first two operational years of the biodiesel plant. Table 9.2a summarizes the monitoring parameters, locations and frequency of the emissions from these stacks.

Table 9.2a Monitoring Parameters, Locations and Frequency of the Stacks ^(a)

Stacks	Monitoring Frequency	Parameters
Boiler	· Monthly for the first 12 months of operation. If the monitoring results of the first year monitoring meet the limit level, the monitoring will be reduced to half-yearly intervals for the whole operational stage	Laboratory analysis for: · NOx · CO · NMOC · SO2 During measurement: · Exhaust gas temperature · Exhaust gas velocity (m s^-1)
Biogas Flare (if in operation)	· Monthly for the first 12 months of operation. If the monitoring results of the first year monitoring meet the limit level, the monitoring will be reduced to half-yearly intervals for the whole operational stage	Laboratory analysis for: · NOx · CO · NMOC · SO2 During measurement: · Exhaust gas temperature · Exhaust gas velocity (m s^-1)
Process Building	· Monthly for the first 12 months of operation. If the monitoring results of the first year monitoring meet the limit level, the monitoring will be reduced to half-yearly intervals for the whole operational stage	Laboratory analysis for: · Acetyldehyde · Methanol During measurement: · Exhaust gas temperature · Exhaust gas velocity (m s^-1)
Final Air Scrubber	· Monthly for the first 2 years of operation	Laboratory analysis for: · Odour concentration (OU s^-1) During measurement: · Exhaust gas temperature · Exhaust gas velocity (m s^-1)
Note: (a) Monitoring will not be carried out during raining days.

Monitoring Methodology

Table 9.2b summarises the monitoring methodologies for NO_x, CO, NMOCs, SO₂, acetyldehyde, methanol and odour. Monitoring will be carried out according to the requirements set out in the relevant USEPA methods or equivalent methods.

Table 9.2b Monitoring Methodology

Stacks	Parameter	Recommended Method ^(a)
Boiler	· NOx · CO · SO2 · NMOCs · Exhaust gas temperature · Exhaust gas velocity / flow rate	· USEPA Method 7 · USEPA Method 10B · USEPA Method 3 · USEPA Method TO-14 · USEPA 40 CFR Part 60 · USEPA Method 2D
Biogas Flare (if in operation)	· NOx · CO · SO2 · NMOCs · Exhaust gas temperature · Exhaust gas velocity / flow rate	· USEPA Method 7 · USEPA Method 10B · USEPA Method 3 · USEPA Method TO-14 · USEPA 40 CFR Part 60 · USEPA Method 2D
Process Building	· Acetyldehyde · Methanol · Exhaust gas temperature · Exhaust gas velocity / flow rate	· USEPA Method TO-14 · USEPA Method TO-14 · USEPA 40 CFR Part 60 · USEPA Method 2D
Final Scrubber	· Odour · Exhaust gas temperature · Exhaust gas velocity / flow rate	Air sampling · Grab sampling by using Teflon bag Laboratory analysis · Forced-choice Dynamic Olfactometer according to Eurpean Standard Method (EN13725)
Note: (a) Reference to http://www.epa.gov/ttn/emc/promgate.html

Performance Compliance

The limit levels for NO_x, CO, NMOC and SO₂ emissions from the boiler stack and biogas flare; acetaldehyde and methanol emissions from the stack of process building and odour concentration of the exhaust gas of final air scrubber presented in Table 9.2c will be met. The exhaust gas temperature and velocity will comply with the design parameters of the stacks. In case of non-compliance with the limit levels, more frequent monitoring and actions in accordance with the Event and Action Plan will be implemented.

Table 9.2c Limit Levels for Various Parameters of the Stacks

Stack	Parameters	Limit Level
Boiler	NOx	0.66g s^-1(based on volume of oil consumed)
	CO	0.17g s^-1(based on volume of oil consumed)
	SO2	0.24g s^-1(based on volume of oil consumed)
	NMOC	1.13 x 10^-2g s^-1(if biogas is burnt) at 0^oC, 1 atm
	Exhaust gas pressure	1 atm
	Exhaust gas temperature	100°C (minimum)
	Exhaust gas velocity	7 m s^-1 (minimum)
Biogas Flare	NOx	0.015 g s^-1
(if in operation)	CO	0.005 g s^-1
	SO2	1.07x10^-3 g s^-1
	NMOC	4.9x10^-4 g s^-1
	Exhaust gas pressure	1 atm
	Exhaust gas temperature	815°C (minimum)
	Exhaust gas velocity	0.54 m s^-1 (minimum)
Process Building	Acetyldehyde	0.028 g s^-1
	Methanol	0.028 g s^-1
	Exhaust gas temperature	35°C (minimum)
	Exhaust gas velocity	0.79 m s^-1 (minimum)
Final Scrubber	Odour	200.3 OU s^-1
	Exhaust gas temperature	ambient
	Exhaust gas velocity	0.7 m s^-1 (minimum)

Odour Patrol

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.

The patrol will be conducted a trained personnel/competent person who should have a specific sensitivity to a reference odour (i.e. on reference materials n-butanol with the concentration of 50ppm in nitrogen (v/v)).

The parameter, location and frequency of odour patrol are summarized in Table 9.2d.

Table 9.2d Parameter, Location and Frequency for Odour Patrol

Patrol Location	Patrol Frequency	Parameters
Patrol along Biodiesel Plant Site Boundary	Two times a day, one in the morning and one in the afternoon	Odour Intensity (see Table 9.2e)

The odour intensity detected during the patrol will be categorised as in Table 9.2e.

Table 9.2e Odour Intensity Level

Class	Odour Intensity	Description
0	Not Detected	No odour perceived or an odour so weak that it cannot be easily characterised or described
1	Slight	Identified odour, slight
2	Moderate	Identified odour, moderate
3	Strong	Identified odour, strong
4	Extreme	Severe odour

Odour patrol will be conducted by a trained personnel/competent person patrolling and sniffing along the Project Site boundary to detect any odour. The trained personnel/competent person shall:

· Have their individual odour threshold of n-butanol in nitrogen gas in the range of 20 to 80 ppb/v required by the Europoean Standard Method (EN 13725);

· Be free from any respiratory diseases;

· Not be allowed to smoke, eat, drink (except water) or use chewing gum or sweets 30 minutes before and during the odour patrol; and

· Take great care not to cause any interference with their own perception or that of others by lack of personal hygiene or the use of perfumes, deodorants, body lotions or cosmetics.

The trained personnel/competent person shall use their noise (olfactory sensors) to sniff odours along the patrol route. The main odour emission sources and the areas to be affected by the odour nuisance shall be identified.

Table 9.2f shows the action and limit levels to be used for odour patrol. When the action and limit levels are triggered, investigation will be carried out to identify the cause of exceedance and actions in accordance with the Event and Action Plan will be taken.

Table 9.2f Action and Limit Levels for Odour

Parameter	Action Level	Limit Level
Perceived odour intensity and odour complaint	· Odour intensity ≥ Class 2 received; or · One substantiated complaint received	· Odour intensity ≥ Class 3 recorded on 2 consecutive patrols ^(a) (b)
Notes: (a) Either Class 3-strong or Class 4-extreme odour intensity. (b) The exceedances of the odour intensity do not need to be recorded at the same location.

Event and Action Plan

The Project Proponent and the Contractor will take the actions in accordance with the Event and Action Plan in Table 9.2g when the action or limit levels are exceeded.

Table 9.2g Event and Action Plan for Air Quality Monitoring During Operational Phase

Event	Action
Exceedance of Limit Level of stack emission	· Repeat measurement to confirm findings · Identify source(s) and investigate the cause(s) of exceedance · Rectify any unacceptable performance · Propose and implement remedial measures or amend design as required
Exceedance of Action Level for odour	· Identify source/reason of exceedance or complaint · Rectify any unacceptable practice · Amend working methods as required · Implement amended working methods, if necessary
Exceedance of Limit Level for Odour	· Identify source/reason of exceedance or complaint · Rectify any unacceptable practice · Propose and implement remedial measures or amend design as required

9.3 Noise

9.3.1 Construction Phase

The EIA study predicted that the noise levels at the identified representative NSRs due to the construction activities of the Project were well below the respective noise criteria and no NSRs would be adversely affected by the construction noise, given a large separation distance (more than 700m) between the NSRs and the Project Site. Noise monitoring during construction phase is considered not necessary. However, monthly site inspections will be carried out during construction to audit the compliance of the Contractor with regard to noise control and to recommend further mitigation measures if found to be necessary.

9.3.2 Operational Phase

No adverse noise impacts were predicted at the identified representative NSRs during the operational phase and hence no operational phase monitoring is required.

9.4 Water Quality

9.4.1 Construction Phase

The impact assessment (see Section 6.5) has evaluated that there would be no adverse water quality impacts arising from the construction activities on the Water Sensitive Receivers (WSRs) within the Study Area.  As a result, it is considered that environmental monitoring of water quality is not required. Nevertheless, monthly site inspections will be undertaken to ensure that the recommended mitigation measures are properly implemented during construction.   The site audit frequency will be increased to weekly intervals during the piling works.

9.4.2 Operational Phase

The impact assessment (see Section 6.6) indicates that adverse water quality impacts on the WSRs within the Study Area are not expected from the operational activities. However, to ensure that the stormwater or effluent discharged from the Project Site will comply with the discharge standards, the quality of the stormwater/effluent will be monitored at the terminal manholes of the stormwater and foul water drainage systems on a monthly basis. Parameters to be monitored will include:

· Stormwater discharge from the site: Oil and grease and suspended solids;

· Treated effluent from the WWTP: Parameters listed in Table 1 of the Technical Memorandum on Standards for Effluents Discharged to Drainage and Sewerage Systems, Inland and Coastal Water or those specified in the WPCO licence.

If the monitoring results indicate exceedance of relevant effluent standards (stormwater or treated effluent) to be agreed with the Authority, the actions stipulated in Table 9.4a should be taken.

Table 9.4a Event and Action Plan for Water Quality Monitoring During Operational Phase

Event	Action
Exceedance of relevant effluent standards (stormwater or treated effluent)	· Repeat measurement to confirm findings · Identify source(s) and investigate the cause(s) of exceedance · Rectify any unacceptable performance · Propose and implement remedial measures or amend design as required

9.5 Marine Ecology

9.5.1 Construction Phase

No dredging of marine sediment will be required for the marine works. Potential impacts to marine ecological resources arising from the construction works will be associated mainly with the construction of the jetty by piling. The jetty will be constructed in the form of a piled deck. Bore piles will be driven through the existing rubble mound seawall. There will be a direct loss of a small stretch of low ecological value intertidal and subtidal hard-substrata habitats associated with the artificial seawall. However, the pile surfaces can serve as artificial habitats for settlement and re-colonisation of marine assemblages. Residual impacts are expected to be low.

Other potential impacts to marine ecological resources, which may be caused by changes in water quality and hydrodynamic regime, and accidental spillage of raw materials and biodiesel during the construction and operation of the biodiesel plant, will be negligible and minimal with the implementation of the recommended mitigation measures and good site practices.

No environmental monitoring is thus considered necessary during the construction and operation phases of the Project. Monthly site inspections will be carried out during construction phase.

9.6 Risk Management

It is recommended that the mitigation measures recommended in Section 8.9 should be audited during the detailed design stage and before the operation of the plant to ensure that:

· they have been properly incorporated into the design of the plant;

· control and management measures are clearly described in the detailed Emergency Response Plan; and

· be properly installed and implemented.