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Contents

1                      Introduction                                                                           

1.1                   Purpose of The Manual                                                      

1.2                   Project Description                                                           

1.3                   Objectives of the EM&A Programme                            

1.4                   Scope of The EM&A Programme                                      

1.5                   Organisation and Structure of the EM&A Programme   

1.6                   Structure of the EM&A Manual                                     

2                      EM&A General Requirements

2.1                   Introduction                                                                           

2.2                   EM&A                                                                                            

3                      aIR qUALITY                                                                               

3.1                   Introduction                                                                           

3.2                   Dust                                                                                             

3.3                   Ambient VOCs, Ammonia and H2S                                      

3.4                   Emissions of the Thermal Oxidiser                               

3.5                   Emissions of Landfill Gas Flare                                   

3.6                   Emissions of LFG Generator                                            

3.7                   ODOUR                                                                                         

3.8                   Event and Action Plan                                                        

3.9                   Meteorological Data                                                         

4                      Water quality                                                                        

4.1                   Introduction                                                                           

4.2                   Surface Water                                                                       

4.3                   Groundwater                                                                         

4.4                   Leachate                                                                                   

4.5                   Event and Action Plan for Water Quality Monitoring    

5                      Landfill Gas                                                                            

5.1                   Introduction                                                                           

5.2                   Methodology and Criteria                                              

5.3                   Monitoring Parameters, Locations and Frequency

5.4                   Monitoring Equipment                                                        

5.5                   Laboratory Measurement / Analysis                          

5.6                   Compliance Requirements                                                

6                      Noise                                                                                           

6.1                   Introduction                                                                           

6.2                   Methodology and Criteria                                              

6.3                   Monitoring Equipment                                                        

6.4                   Monitoring Locations                                                        

6.5                   Baseline Monitoring                                                           

6.6                   Impact Monitoring                                                                

6.7                   Event and Action Plan                                                        

7                      Waste Management                                                              

7.1                   General                                                                                     

7.2                   Mitigation Measures                                                           

7.3                   Site Audit/Inspection                                                           

8                      Ecology

8.1                   Introduction                                                                           

8.2                   Mitigation Measures                                                           

8.3                   Compensation                                                                         

8.4                   Environmental Monitoring and Audit                         

9                      Landscape and Visual                                                         

9.1                   Introduction                                                                           

9.2                   Mitigation Measures                                                           

9.3                   Design Phase Audit                                                               

9.4                   Construction Phase Audit                                               

9.5                   Operation/Restoration Phase Audit                           

9.6                   Aftercare Phase Audit                                                      

10                    Site environmental Audit                                                  

10.1                 Site Inspection                                                                       

10.2                 Environmental Management Plan                                

10.3                 Compliance with Legal and Contractual Requirements

10.4                 Environmental Complaints                                              

10.5                 Log-Book                                                                                   

11                    Reporting                                                                                 

11.1                 General                                                                                     

11.2                 Baseline Monitoring Report                                           

11.3                 Monthly EM&A Reports                                                      

11.4                 Quarterly EM&A Summary Reports                              

11.5                 Annual EM&A Review Report                                            

11.6                 Final EM&A Summary Report                                            

11.7                 Data Keeping                                                                           

ANNEXES     

Annex A       Implementation Schedule

Annex B         Complaint and Monitoring Proforma

 

 

1          Introduction

1.1                                                         Purpose of The Manual

1.1.1  Background

The Environmental Impact Assessment (EIA) Report and the associated Environmental Monitoring and Audit (EM&A) Manual for the construction, operation, restoration and aftercare of the South East New Territories Landfill Extension (SENTX) (hereafter referred to as “the Project”) have been approved under the Environmental Impact Assessment Ordinance (EIAO) in May 2008 (Register No.: AEIAR-117/2008).  Since then, the Hong Kong SAR Government has decided to reduce the scale of the design scheme of SENTX assessed in the approved EIA Report and SENTX will only receive construction waste.  In line with the changes proposed by EPD, the landfill contractor for SENTX, Green Valley Landfill Limited (GVL), has developed a final scheme for SENTX (hereafter “the latest scheme”) in 2016.  This latest design complies with the requirements in the Technical Memorandum of the Environmental Impact Assessment Process (EIAO-TM) and the current Environmental Permit (EP-308/2008/B).

This updated EM&A Manual has taken into account the findings and recommendation of the approved EIA Report and with updates taken from the current EP and the latest design to reflect the necessary environmental monitoring and audit (EM&A) requirements associated with the construction, operation/ restoration and aftercare of the SENTX under the latest design. 

This updated Manual has been prepared with reference to the approved EM&A Manual prepared in May 2008, the current EP, the latest design and the EIAO-TM.  The purpose of the Manual is to provide information, guidance and instruction to personnel charged with environmental duties and those responsible for undertaking EM&A work during construction, operation/restoration and aftercare phases of the SENTX.  It provides systematic procedures for the environmental monitoring and auditing of the potential environmental impacts that may arise from the Project.

1.2                                                         Project Description

1.2.1  Background

The existing waste disposal facility in the South-east New Territories is the SENT Landfill at Tseung Kwan O (TKO).   The Hong Kong SAR Government has identified a 13 ha site at TKO Area 137 for the extension of the SENT Landfill (hereafter refer to “SENTX”) (see Figure 1.2a). 

Under the latest design, the SENTX has a net void capacity of about 6.5 Mm3 and provides an additional lifespan of about 6 years, commencing operation upon exhaustion of the SENT Landfill.  The SENTX will receive construction waste only.

The design, construction, operation, restoration and aftercare of the SENTX shall comply with the requirement stipulated in the EP (EP-308/2008/B).

1.2.2  The Project

The SENTX is a piggyback landfill, occupying the southern part of the existing SENT Landfill (including its infrastructure area) and 13 ha of TKO Area 137.  A layout plan of the SENTX is shown in Figure 1.2a.  The key elements of the construction, operation/restoration and aftercare of the SENTX are described below.

Construction of SENTX

Construction works will commerce about two years prior to the operation of the SENTX.  The major construction works includes:

·      Site formation at the TKO Area 137 and the existing infrastructure area at SENT Landfill;

·      Construction of surface and groundwater drainage systems;

·      Construction of the leachate containment and collection systems;

·      Construction of new leachate and landfill gas treatment facilities, site offices, maintenance yards at the new infrastructure area;

·      Construction of new pipelines to transfer the leachate and landfill gas collected from the existing SENT Landfill to the treatment facilities at the new infrastructure area;

·      Construction of the site access and new waste reception facilities; and

·      Demolition of the facilities at the existing SENT Landfill infrastructure area.

Operation and Restoration of SENTX

The leachate and landfill treatment facilities will be commissioned and the first phase of the SENTX will start operation upon exhaustion of the SENT Landfill.  Construction of the leachate containment and collection system for the subsequent phases will continue while the first phase of the SENTX is in operation.  The areas that reach the finished profile will be progressively restored and landscaped.      

Aftercare of SENTX

Upon the completion of final filling and restoration, the aftercare of the SENTX will begin and last for 30 years.  Regular site maintenance, collection and treatment of landfill gas and leachate will be undertaken during the aftercare period to ensure that the landfill complies with the required environmental performance requirements and is safe.  The restored landfill may then be developed for various passive beneficial uses (eg open spaces, walking trails, etc).       

An EM&A programme will be implemented throughout the construction, operation/restoration and aftercare phases of the SENTX.  

Implementation Programme

The key implementation of milestone of the Project is indicatively summarised in Table 1.2a.

Table 1.2a      Estimated Key Dates of Implementation Programme

Key Stage of the Project

Indicative Date

Start construction

31 December 2018

Commissioning of new infrastructure facilities

2020

Demolition of existing infrastructure facilities

2021

 

 

Start waste intake at SENTX

2021 or upon exhaustion of SENT Landfill

Stop taking waste at SENTX

2027

End of aftercare for SENTX

2057

1.3                                                         Objectives of the EM&A Programme

The potential environmental impacts associated with the Project have been assessed and described in the approved EIA Report.  Mitigation measures are required to comply with the environmental criteria.  The updated mitigation measures associated with the latest design and their implementation requirements are presented in the Implementation Schedule (see Annex A[CL1]  ).  An EM&A programme will be implemented to assess the effectiveness of measures and to confirm that there will be no adverse environmental impacts during all phases of the Project.  Regular site audits will be undertaken during the construction and operation/restoration phases to check whether good site practices are properly implemented to prevent adverse environmental impacts.  Any activities that have a potential to cause adverse environmental impacts are identified before the adverse impacts occurred.  Ad hoc visits to the impacted sites should also be undertaken in response to any complaints or reported non-compliance with environmental standards in order to enable prompt actions are taken to address the impacts. 

This updated EM&A Manual provides details of the updated EM&A requirements associated with the latest design (SENTX only accept construction waste).  The main objectives of the EM&A programme are to:

·           verify the environmental impacts predicted in the EIA Report taking account of latest design;

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

·           determine Project compliance with regulatory requirements and standards;

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

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

·           provide a database against which any short or long term environmental impacts of the Project can be determined; and 

·           provide data against which environmental audits may be undertaken.

1.4                                                         Scope of The EM&A Programme

Table 1.4a summarises the requirements at various phases of the Project.

Table 1.4a      Summary of EM&A Requirements

Parameter

EM&A Phase

Construction

Operation/ Restoration

Aftercare

Dust

P

P

P (b)

Ambient Volatile Organic Compounds (VOC),  Ammonia and Hydrogen Sulphide (H2S)

P (a)

P

P

Stack emissions from Flares and Thermal Oxidizers

 

P

P (d)
(flares only)

Odour

 

P

P (b)

Surface Water

P

P

P

Groundwater

P (a)

P

P

Leachate

 

P

P

Landfill Gas

P (a)

P

P

Noise

P

P

P (b)

Waste Management (c)

P

P

 

Ecology (c)

P

P

P

Landscape and Visual (c)

P

P

P

Notes:

(a)                                                The monitoring of VOCs, ammonia, H2S, groundwater and landfill gas during construction would act as baseline monitoring for operation impact

(b)                                                The monitoring and audit of dust, odour and noise in aftercare phase will only be required when there are major maintenance / maintenance works requiring excavation of waste.

(c)                                                 EM&A scope include audit works only.

(d)                                                Since the leachate quantity will be significantly decreased during aftercare phase, therefore, SBR/MBR tanks should be sufficient to treat the leachate to meet the required standards without the need to operate the thermal oxidiser.  Hence, stack emission monitoring will only be conducted at flares only if the thermal oxidiser is no longer in use.

The scope of the EM&A programme is to:

·           implement regular monitoring and site audit requirements and undertake additional or ad hoc monitoring if non-compliance identified;

·           evaluate and interpret all environmental monitoring data on a regular basis to provide an early indication should any of the environmental control measures or practices fail to achieve the required performance standards, and to verify the environmental impacts predicted in the EIA Report taking account of the latest design;

·           liaise with, and provide environmental advice (as requested or when otherwise necessary) to construction/operation site staff on the comprehension and consequences of the environmental audit;

·           identify and resolve environmental issues that may arise from the Project;

·           investigate environmental complaints associated with the Project;

·           check and evaluate the Contractor's overall environmental performance, and the effectiveness of the remedial actions; and

·           prepare and submit EM&A reports which summarise project monitoring and auditing data, with full interpretation illustrating the acceptability or otherwise of any environmental impacts and identification or assessment of the implementation status of agreed mitigation measures.

1.5                                                         Organisation and Structure of the EM&A Programme

1.5.1  Project Organisation

The proposed organisation of the personnel involved in the EM&A process is illustrated in Figure 1.5a. 

Figure 1.5a     Organisation Chart

 

 

 

 

 

 

 

 

The roles and responsibilities of the various parties are summarised below:

·                     Project Proponent: Environmental Infrastructure Division, EPD

·                     Independent Consultants (IC):  The IC should be responsible for overseeing the Project undertaken by the Contractor and for ensuring that the Project is undertaken by the Contractor in accordance with the specification and contractual requirements.  The responsibilities for the IC include the following:

-             Verify and check the Contractor’s activities and ensure that the requirements in the Contract Specifications, including the implementation and operation of the environmental mitigation measures and other aspects of the EM&A programme are fully complied with ([1]).

·                     Contractor:  The landfill contractor should be responsible for carrying out design, construction, operation, restoration and aftercare of the SENTX.

The Contractor should:

-             implement environmental controls and mitigation as set out in this EM&A Manual as well as any additional measures necessary for compliance with the environmental control standards;

-             assist the Project Proponent to establish an ET to undertake the monitoring and reporting of the EM&A requirements outlined in this EM&A Manual;

-             submit proposals on mitigation measures in case of exceedances of Action and Limit levels in accordance with the Event and Action Plans;

-             implement measures to reduce impact where Action and Limit levels are exceeded;

-             implement the corrective actions instructed by Project Proponent and advised by the ET;

-             participate in the site inspections undertaken by the ET and undertake any corrective actions advised by the ET; and

-             adhere to the procedures for carrying out complaint investigation.

·          Environmental Team (ET):  The ET should be responsible for ensuring the implementation of the mitigation measures and EM&A requirements recommended in this EM&A Manual, and report to the Project Proponent and the EPD (EIAO Authority) on all environmental aspects of the Project.   The ET should be led and managed by the ET Leader (or sometimes called Environmental Manager).  The ET Leader should have relevant education, training, knowledge, experience and professional qualifications.  The ET Leader should possess at least 7 years of experience in EM&A and/or environmental management.  The ET shall not be in any way an associated body of the Contractor or the IEC for the Project.  The ET should:

-             Monitor of the various environmental parameters as required by this or subsequent revisions to the Manual;

-             assess the EM&A data and review the success of the EM&A programme determining the adequacy of the mitigation measures implemented and the validity of the predictions in the approved EIA Report taking account of the latest design;

-             conduct site inspections to investigate and inspect the work equipment and methodologies with respect to pollution control and environmental mitigation, monitor compliance with environmental protection specifications, and to anticipate environmental issues that may require mitigation before the problem arises;

-             compile the environmental monitoring data and report the status of the general site environmental conditions and the implementation of mitigation measures resulting from site inspections;

-             review working programme and methodology, and comment as necessary;

-             investigate and evaluate complaints, and identify corrective measures;

-             advice on environmental improvement, awareness, enhancement matters, etc, on site;

-             report on the environmental monitoring and audit results and the wider environmental issues and conditions to the Project Proponent and the EPD (EIAO Authority);

-             adhere to the agreed protocols in the event of exceedances or complaints; and

-             the ET Leader will keep a contemporaneous log-book and record each and every instance or circumstance or change of circumstances which may affect the findings of approved EIA Report (taking account of the latest design) and non-compliance with the EP.

·                     Independent Environmental Checker (IEC):  An IEC will be appointed, as part of the IC, who should verify the overall environmental performance of the Project.  The IEC should be responsible for verifying all environmental submissions required under the EM&A programme and EP to the EPD (EIAO Authority).  The IEC should possess at least 7 years of experience in EM&A and/or environmental management.  The IEC shall not be in any way an associated body of the Contractor or the ET for the Project.

The IEC should:

-             audit the EM&A works performed by the ET (at least at monthly intervals);

-             carry out random sample check and audit the monitoring activities and results (at least at monthly intervals);

-             conduct site inspections and report the audit/site inspection results and other environmental performance reviews to the Project Proponent;

-             review and verify the EM&A reports submitted by the ET;

-             review the effectiveness of environmental mitigation measures and project environmental performance;

-             check the mitigation measures recommended in this updated EM&A Manual, and ensure they are properly implemented in timely manner when required;

-             review the proposal on mitigation measures submitted by the Contractor in accordance with the EAP; and

-             adhere to the procedures for carrying out complaint investigation.

·             EPD:  The Authority under the EIAO, including the EPD Environmental Assessment Division and EPD Environmental Compliance Division.  The EPD will be the authority to approve all submissions under the EIAO.

1.6                                                         Structure of the EM&A Manual

The remainder of this updated EM&A Manual is set out as follows:

·           Section 2 sets out the EM&A general requirements;

·           Section 3 details the requirements for air quality monitoring;

·           Section 4 details the requirements for water quality and leachate monitoring;

·           Section 5 details the requirements for landfill gas monitoring;

·           Section 6 details the requirements for noise monitoring;

·           Section 7 details the requirements for waste management audit;

·           Section 8 details the requirements for ecological mitigation measures;

·           Section 9 details the requirements for landscape and visual impacts mitigation measures;

·           Section 10 describes the scope and frequency of site auditing;

·           Section 11 details the EM&A reporting requirements;

·           Annex A contains the implementation schedule summarising all applicable mitigation measures in the approved EIA Report taking account of the latest design; and

·           Annex B contains the monitoring and complaint log sheets.

This updated EM&A Manual is an evolving document that should be updated to maintain its relevance as the Project progresses.  The primary focus for these updates will be to ensure the impacts predicted and the recommended mitigation measures remain consistent and appropriate to the manner in which the works are to be carried out.  Any changes to the programme shall be justified by the ET Leader and verified by the IEC before submission to the EIAO Authority for approval.

 

2          EM&A General Requirements

2.1                                                         Introduction

The general requirements of the EM&A programme are described in this Section.  The scope of the programme is developed with reference to the findings and recommendations from the approved EIA Report taking account of the latest design.

2.2                                                         EM&A

The potential environmental impacts and the implementation of the recommended mitigation measures for the construction, operation, restoration and aftercare of the SENTX should be monitored through the EM&A programme specified in this EM&A Manual. 

The EM&A programme will include regular and ad hoc site inspections/ audits and environmental monitoring.  The programme also include the mechanisms to review and assess the Contractor’s environmental performance, ensuring that the recommended mitigation measures have been properly implemented, and that timely resolution of received complaints are managed and controlled in a manner consistent with the recommendations of the approved EIA Report.

2.2.1  Environmental Monitoring

Baseline monitoring and impact monitoring during the construction, operation, restoration and aftercare of the SENTX should be managed by the ET.  The monitoring should be focused on the following aspects:

·           dust and odour impacts on air sensitive receivers;

·           ambient VOCs, ammonia & H2S along the SENTX Site boundary;

·           stack emissions from the flares of landfill gas treatment facilities and the thermal oxidisers of Leachate Treatment Plant (LTP);

·           water quality impacts on groundwater and surface water;

·           landfill gas concentration at the SENTX Site boundary; and

·           effluent flow and quality from the LTP, and leachate level in the landfill;

These are discussed further in Sections 3 to 10 of this EM&A Manual.

2.2.2  Compliance with Action and Limit Levels

The action and limit levels should be defined for environmental monitoring at designated monitoring locations exceeding which a prescribed response should be required.  Individual action and limit levels should be quantitatively defined for the respective environmental monitoring parameters according to the following basic principles:

Action Level

Action levels indicate deteriorating ambient environmental quality potentially due to the Project implementation.  It acts as a sign to trigger stepped up monitoring and appropriate remedial actions in order to rectify any mal-practices or non-conformance of Project activities thereby preventing the deterioration of environmental quality and to resume the ambient environmental quality back to normal levels.

Limit Level

Limit levels are the statutory and/or contractual levels above which environmental conditions are considered unacceptable.  If limit levels were exceeded, the relevant part of the works should not be continued without implementation of immediate remedial action, including a critical review of plant and working methods.

2.2.3  Event and Action Plans

The purpose of the Event and Action Plans (EAPs) is to provide, in association with the EM&A activities, procedures for ensuring that if any significant environmental incident (either accidental or through inadequate implementation of mitigation measures) on the part of the Contractor does occur, the cause should be quickly identified and remediated, and the risk of a similar event recurring is reduced.

2.2.4  Site Inspections/Audits

In addition to monitoring works as the means of assessing the ongoing environmental performance of the Project, the ET and IEC should undertake site inspections and audits of on-site practices and procedures.  The primary objectives of the site inspection and audit programme are to ensure the good site practices and mitigation measures in this updated EM&A Manual are properly implemented and to assess the effectiveness of these measures. 

The findings of site inspections and audits should be made known to the Contractor and the IEC at the time of the inspection to enable the rapid resolution of identified non-compliances.  Non-compliances, and the corrective actions undertaken, should be reported in the monthly EM&A reports.

Section 10 of this updated EM&A Manual presents details of the scope and frequency of on-site inspections and defines the range of issues that the audit protocols should be designed to address.

2.2.5  Enquiries, Complaints and Requests for Information

Enquiries, complaints and requests for information can be expected from a wide range of individuals and organisations including members of the public, Government departments, the press and television media and community groups. 

All enquiries concerning the environmental impacts of the Project, irrespective of how they are received, should be reported to the Project Proponent and IEC and directed to the Contractor and ET who should set up procedures for handling, investigation and storage of such information.  The following steps should be followed:

(a)    The ET should notify the IEC of the nature of the enquiry.

(b)    An investigation should be initiated to determine the validity of the complaint and to identify the source(s) of the problem.

(c)    The ET and the Contractor should undertake the following steps, as necessary:

·           investigate and identify source(s) of the problem;

·           if considered necessary by the IEC, undertake additional monitoring to verify the existence and severity of the alleged complaint;

·           identify necessary remedial measures and implement as soon as possible;

·           repeat the monitoring to verify effectiveness of mitigation measures; and

·           repeat review procedures to identify further possible areas of improvement if the repeat monitoring results continue to substantiate the complaint.

(d)    The outcome of the investigation and the actions taken should be documented on a complaint proforma (see Annex B) and should be verified by the IEC.  A formal response to each complaint received should be prepared by the Contractor within a maximum of five working days and submitted to the IEC for review.  The ET should submit the formal response to the Project Proponent for approval.  The Project Proponent will notify the concerned person(s) of the findings of the complaint investigation and the actions taken, if required.

(e)    All enquiries/complaints that trigger this process should be reported in the monthly EM&A reports, which should include results of investigations undertaken by the ET and the Contractor, and details of the measures taken, and additional monitoring results (if deemed necessary).  It should be noted that the receipt of complaint or enquiry should not be, in itself, a sufficient reason to introduce additional mitigation measures. 

In all cases the complainant will be notified of the findings of the investigation.

2.2.6  Reporting

With respect to the identified potential impacts and the nature and frequency of the EM&A to be undertaken, it is considered that real-time reporting of the monitoring data through a dedicated website is not applicable.  However, the monitoring data should be uploaded to the Project website at regular interval to be agreed by the EPD (EIAO Authority), Contractor and the Project Proponent. 

Monthly EM&A reports prepared by the ET should be certified by the ET Leader and verified by the IEC prior to submission to the Project Proponent and EPD (EIAO Authority).  The monthly EM&A reports should be prepared and submitted within 10 working days of the end of each reporting month.  Additional details on reporting protocols are presented in Section 10.

2.2.7  Cessation of EM&A

The ET will continue to manage the environmental monitoring and site inspection/audit until completion of the Project (i.e. until the completion of the aftercare period).

 

3          aIR qUALITY

3.1                                                         Introduction

The general requirements, methodology, equipment, and mitigation measures for the monitoring and audit of potential air quality impacts associated with different phases of the Project are described in this Section.  The air quality monitoring parameters includes:

·         Dust;

·         Ambient volatile organic compounds (VOCs), ammonia and hydrogen sulphide (H2S);

·         Odour;

·         Emission from the thermal oxidiser of the LTP;

·         Emission from LFG flares; and

·         Emission from LFG generator.

The requirements of setting up a meteorological station are also described in this Section.  

The mitigation measures recommended to control air quality impacts are summarised in Annex A.

3.2                                                         Dust

3.2.1  Introduction

Monitoring of the Total Suspended Particulates (TSP) levels should be carried out to ensure that construction works and operation/ restoration of SENTX will not cause adverse dust impacts to the identified air sensitive receivers.  During the aftercare phase, monitoring of dust should also be conducted when there are major maintenance works.  Timely action should be taken to rectify the situation if an exceedance is detected.

All relevant data including temperature, pressure, weather conditions, elapsed-time meter reading for the start and stop of the sampler, identification and weight of the filter paper, any other special phenomena and work progress of the concerned site should be recorded.  A sample data log sheet is shown in Annex B.

3.2.2  Monitoring Equipment 

A high volume air sampler in compliance with the following specifications should be used for TSP monitoring:

·           capable of collecting TSP in the range of 10 to 750 µg m-3;

·           0.6 to 1.7 m3 min-1 (20-60 SCFM) adjustable flow range;

·           equipped with a timing/control device with +/- 5 minutes accuracy for 24 hours operation;

·           installed with elapsed-time meter with +/- 2 minutes accuracy for 24 hours operation;

·           capable of providing a minimum exposed area of 406 cm2 (63 in2);

·           flow control accuracy: +/- 2.5% deviation over 24-hr sampling period;

·           equipped with a shelter to protect the filter and sampler;

·           incorporated with an electronic mass flow rate controller or other equivalent devices calibrated against a traceable standard at regular intervals;

·           equipped with a flow recorder for continuous monitoring;

·           provided with a peaked roof inlet;

·           equipped with a manometer;

·           able to hold and seal the filter paper to the sampler housing in a horizontal position;

·           easy to change the filter; and

·           capable of operating continuously for 24-hr period.

The Contractor should be responsible for provision of the monitoring equipment, and should ensure that sufficient number of high volume air samplers and appropriate calibration kits are available for carrying out the baseline, impact and ad hoc monitoring.  All the equipment, calibration kit, filter papers, etc. should be clearly labelled.

The Contractor should calibrate the dust monitoring equipment upon installation and thereafter at bi-monthly intervals.  The transfer standard should be traceable to the internationally recognised primary standard and be calibrated annually.  The calibration data should be properly documented for future reference by concerned parties, such as the IEC.   All the data should be converted into standard temperature and pressure condition.

The flow-rate of the sampler before and after the sampling exercise with the filter in position should be verified to be constant and recorded in the data sheet as described in Section 3.2.1.

Meteorological data should be obtained from the on-site meteorological monitoring station as described in Section 3.9. 

3.2.3  Laboratory Measurement/ Analysis

A clean laboratory with constant temperature and humidity control and equipped with necessary measuring and conditioning instruments should be used for sample analysis and equipment calibration and maintenance.  The laboratory should be HOKLAS accredited.

If a site laboratory (HOKLAS accredited) is set up or a non-HOKLAS accredited laboratory is hired for carrying out the laboratory analysis, the laboratory equipment should be fully justified by ET Leader, verified by IEC and approved by EPD (EIAO Authority).  Measurement performed by the laboratory should be demonstrated to the satisfaction of the EPD (EIAO Authority) and the IEC.  The IEC should conduct regular audits of the measurements performed by the laboratory to ensure the accuracy of the results.  The ET should provide Contractor and the IEC with one copy each of the Title 40 of the Code of Federal Regulations, Chapter 1 (Part 50), Appendix B and Appendix J for reference.

Filter paper of size 8"x10" should be labelled before sampling.  It should be a clean filter paper with no pin hole and should be conditioned in a humidity controlled chamber for over 24-hr and be pre-weighed before use for the sampling.

After sampling, the filter paper loaded with dust should be kept in a clean and tightly sealed plastic bag.  The filter paper should then be returned to the laboratory for reconditioning in the humidity controlled chamber followed by accurate weighing by an electronic balance with a readout down to 0.1 mg.  The balance should be regularly calibrated against a traceable standard.

All the collected samples should be kept in a good condition for 6 months before disposal.

3.2.4  Monitoring Locations

Construction Phase

High volume air samplers (HVSs) should be installed at the two designated locations at ASRs (i.e. DM1 and DM2) as shown in Figure 3.2a. 

DM1 is located at TKO Fill Bank site boundary which is representative of the impact to the ASRs at the TKO industrial area including the nearest ASR TVB City.

DM2 is located at the existing TKO Fill Bank site office as TKO Fill Bank will continue to operate for the next 5 year during the construction phase of the SENTX; while the two planned ASRs which are the Construction & Demolition Material Handling Facility and the TKO Desalination Plant will not exist during construction phase of SENTX by 2021 according to the latest information available.

Operation/Restoration Phase

HVSs should be installed at the four designated locations along the site boundary (i.e. AM1, AM2, AM3 and AM4) as shown in Figure 3.2a.  Should change of location is required after issuing this EM&A Manual, the proposed alternative monitoring locations should be fully justified by ET Leader, verified by IEC and approved by EPD (EIAO Authority).

When alternative monitoring locations are proposed, the following criteria, as far as practicable, should be followed:

·           at the site boundary or such locations close to the major dust emission source(s);

·           close to the ASRs; and

·           taking into account the prevailing meteorological conditions.

The ET Leader should agree with the Contractor on the position of the HVSs for installation of the monitoring equipment.  When positioning the samplers, the following points should be noted:

·           a horizontal platform should be provided with appropriate support to secure the samplers against gusty wind;

·           the distance between the sampler and an obstacle, such as buildings, should be at least twice the height that the obstacle protrudes above the sampler;

·           a minimum of 2m separation from any supporting structure, measured horizontally is required;

·           no furnaces or incineration flues or building vents are nearby;

·           airflow around the sampler is unrestricted;

·           the sampler is more than 20m from the drip line;

·           any wire fence and gate, to protect the sampler, should not cause any obstruction during monitoring;

·           permission must be obtained to set up the samplers and to obtain access to the monitoring stations; and

·           a secured supply of electricity is needed to operate the samplers.

3.2.5  Baseline Monitoring

Construction Phase

24-hour TSP levels should be monitored at the two designated locations (i.e. DM1 and DM2), where there are two existing TSP monitoring stations operating by the Civil Engineering and Development Department (CEDD).  The recent 1 year historical data at a 6-day interval monitored by the two existing CEDD’s monitoring stations prior to the commissioning of the construction works will be used to establish the baseline levels for construction phase.  It is more representative to use the recent 1 year historical data, taking into account of the seasonal variation, to establish the baseline levels.

Operation/ Restoration & Aftercare Phases

24-hour TSP levels should be monitored at the four designated locations along the site boundary (i.e. AM1, AM2, AM3 and AM4) for at least 14 consecutive days prior to the commissioning of the operation phase to establish the baseline levels for operation phase.  Prior to the commencement of the operation phase, earthworks and laying of liner should have been completed and the condition would be representative of the baseline condition prior to the operation phase.  Prior to the commencement of the construction phase, AM3 and AM4 are located within the TKO Fill Bank area and the baseline monitoring results would be affected by the dusty activities in TKO Fill Bank which will not represent the baseline condition prior to the operation phase of the SENTX.  In addition, in terms of technical feasibility, it is not practical to set up the HVSs at the four monitoring locations since there is no suitable horizontal platform or secured supply of electricity prior to the construction phase.  Before commencing the baseline monitoring, the ET leader should inform the IEC and EIAO Authority of the monitoring programme such that the IEC can conduct on-site audit of the monitoring.

In exceptional case, when insufficient baseline monitoring data or questionable results are obtained, the ET Leader should liaise with IEC to agree on an appropriate set of data to be used as a baseline reference and submit to EPD (EIAO Authority) for approval.

Ambient conditions may vary seasonally and should be reviewed at quarterly intervals.  If the ET Leader considers that the ambient conditions have been changed and repeat of the baseline monitoring is required to be carried out for obtaining the updated baseline levels, the monitoring should be conducted at times when the Contractor’s activities are not generating dust, at least in the proximity of the monitoring stations.  Should changes in ambient conditions be determined, the baseline levels and, in turn, the air quality criteria, should be revised.  The revised baseline levels and air quality criteria should be fully justified by ET Leader, verified by IEC and approved by EPD (EIAO Authority).

3.2.6  Impact Monitoring

Impact monitoring should be undertaken during the construction and operation/restoration of the SENTX, and during aftercare phase if there are major maintenance works. 

Construction Phase

24-hour TSP levels should be measured at the two designated locations (i.e. DM1 and DM2) at least once every six days during the construction phase to monitor the dust impacts of construction works.   

Operation/ Restoration & Aftercare Phases

During operation/restoration phase and aftercare period when there are major maintenance works, 24-hour TSP levels should be monitored at least once every six days at four designated locations along the site boundary (i.e. AM1, AM2, AM3 and AM4).  

The specific time to start and stop the 24 hours monitoring should be clearly defined for each location and be strictly followed by the operator. 

The parameters, locations and frequency of dust monitoring are summarized in Table 3.2a.

Table 3.2a      Parameters, Locations and Frequency of Dust Monitoring

Phase

Location

Frequency

Parameter

Baseline monitoring

At two designated locations (i.e. DM1 and DM2)

Once every 6 days of the recent 1 year

·     24-hr TSP

 

 

At four designated locations along the SENTX site boundary (i.e. AM1, AM2, AM3 and AM4)

At least 14 consecutive days prior to the commencement of the operation phase

·     24-hr TSP

Construction

At two designated locations (i.e. DM1 and DM2)

Once every 6 days

·     24-hr TSP

Operation/ Restoration

At four designated locations along the SENTX site boundary (i.e. AM1, AM2, AM3 and AM4)

Once every 6 days

·     24-hr TSP

 

Aftercare

At four designated locations along the SENTX site boundary (i.e. AM1, AM2, AM3 and AM4)

Once every 6 days when there are major maintenance works

·     24-hr TSP

 

3.2.7  Event and Action Limits for Dust

The baseline dust monitoring results and the Air Quality Objectives (AQOs) form the basis for determining the dust criteria for impact monitoring.  The ET should compare the impact monitoring results with dust criteria.  In case of non-compliance with the dust criteria, more frequent monitoring, as specified in the EAP (see Section 3.6), should be conducted.  This additional monitoring should be continued until the non-compliance is rectified.  Actions in accordance with the EAP (see Section 3.7) should be carried out in case non-compliance occurred.

Table 3.2b      Action and Limit Levels for Dust

Parameter

Action Level

Limit Level

Construction Phase

 

 

·        24-hr TSP Level

 

For baseline level ≤ 200 µg m-³, Action level = (Baseline level *1.3 + Limit level)/2

For baseline level > 200 µg m-³, Action level = Limit level

260 µg m-³

Operation/Restoration Phase

 

 

·        24-hr TSP Level

Action level = Limit level

260 µg m-³

Aftercare Phase when there are major maintenance work

 

 

·        24-hr TSP Level

Action level = Limit level

260 µg m-³

3.3                                                         Ambient VOCs, Ammonia and H2S

3.3.1  Introduction

The general requirements, methodology, equipment, and mitigation measures for the monitoring and audit of ambient methane, VOCs, ammonia and H2S associated with the operation, restoration and aftercare phases of the Project are described below.  The sampling and analysis method should be prepared by the ET, in consultation with the IEC.

3.3.2  Sampling Equipment

The Contractor should be responsible for providing and maintaining a sufficient number of the following instruments for taking ambient air samples of VOCs, ammonia and H2S.

Methane

The instruments should be able to capture ambient air into inert sample containers (e.g. low flow-rate pump and tedlar bags) for direct analysis using gas chromatography.  If low flow-rate pump is used, it should be capable of maintaining a steady flow of air to collect the sample volume specified, and a rotameter of suitable range to measure flow rate during the sampling process.   

VOCs

Samples for VOCs analysis should be collected using adsorption tubes containing a solid tenax/charcoal trapping medium or pressurised canisters fixed with a flow controller, which should be able to capture the suite of VOCs as shown in Table 3.3b for laboratory analysis. 

Ammonia

The sampling instruments (e.g. low flow-rate pump and silica gel sampling tubes) should be able to collect samples for the laboratory analysis for measuring ammonia concentrations in between the range of 0.02 to 2 mg m-3.

H2S

Cadmium hydroxide solution was used as the absorbing solution to collect H2S in air with mid-get impringer.  The air sampling flow rate was set at 1.5 L/min. 

3.3.3  Laboratory Measurement/Analysis

Air samples collected for laboratory analysis of should be transported to HOKLAS registered laboratories within 24 hours and analysed within 48 hours.  The following analytical methods should be used:

·      Methane – gas chromatography with thermal conductivity detection or non dispersion infrared spectroscopy or equivalent method approved by the IEC;

·      VOCs – gas chromatography with mass selective detection or mass spectrophotometry or equivalent method approved by the IEC;

·      Ammonia – NIOSH method S347 or equivalent method approved by the IEC; and

·      H2S –US NIOSH P&CAM Method 126 or equivalent method approved by the IEC.

The required detection limits for the methane, VOCs, ammonia and H2S are detailed in Table 3.3a.

Table 3.3a      Analytical Detection Limits for VOCs and Ammonia (a)

Analytical Parameters (b)

Detection Limit (c)

Ammonia

0.02 mg m-3

Methane

0.0025%

Methanethiol

27 ppb

Ethanethiol

1,400 ppb

Butanethiol

1,400 ppb

Trichloroethylene

0.6 ppb

Vinyl Chloride

2.0 ppb

Benzene

2.0 ppb

Methylene Chloride

1.0 ppb

Chloroform

0.8 ppb

1,2-dichloroethane

0.2 ppb

Carbon tetrachloride

0.2 ppb

Tetrachloroethylene

0.2 ppb

1,1,1- trichloroethane

0.5 ppb

1,2-dibromoethane

0.5 ppb

All other VOCs

0.25 µg m-3

H2S

1 ppb

Notes:

(a)   Reference to the detection limit adopted in the existing SENT Landfill.

(b)   Please refer to the footnote (b) of Table 3.3b for a full list of 40 VOCs to be monitored.

(c)    For parameters not specified in this table, the detection limit should be 0.25 µg m-3 or better with the exception of methane which shall be 0.0025% or better.

3.3.4  Monitoring Parameter, Location and Frequency

Quarterly monitoring for a period of 12 months prior to waste filling should be conducted to establish the baseline ambient methane, VOCs, ammonia and H2S concentrations prior to landfilling operation.  Impact monitoring should be undertaken throughout the operation/restoration and aftercare phases of the SENTX and should not be conducted on rainy day.  The monitoring frequency, locations, and parameters are summarised in Table 3.3b.

 

Table 3.3b      Monitoring Parameters, Locations and Frequency of Ambient VOCs, Ammonia and H2S Monitoring

Phase

Monitoring Locations

Monitoring Frequency

Parameters

Baseline Monitoring

 

4 locations along the SENTX Site Boundary (a)

Quarterly, for a period of 12 months prior to waste filling

 

·     Methane

·     Ammonia

·     A suite of VOCs (b)

·     H2S

Operation/ Restoration/Aftercare

4 locations along the SENTX Site Boundary (a)

Quarterly, throughout operation/restoration and aftercare phases

 

·     Methane

·     Ammonia

·     A suite of VOCs (b)

·     H2S

Notes:

(a)                See Figure 3.2a for the proposed locations.

(b)                A suite of VOCs includes:

·        Trichloroethylene

·        Vinyl chloride

·        Methylene chloride

·        Chloroform

·        1,2-dichloroethane

·        1,1,1-trichloroethane

·        Carbon tetrachloride

·        Tetrachloroethylene

·        1,2-dibromoethane

·        Benzene

·        Toluene

·        Carbon disulphide

·        Propyl benzene

·        Ethyl benzene

·       Butyl benzene

·       Xylenes

·       Decanes

·       Undecane

·       Limonene

·       Terpenes

·       Ethanol

·       Butan-2-ol

·       Dimethylsulphide

·       Methyl propionate

·       Ethyl propionate

·       Propyl propionate

·       Butyl acetate

·       Ethyl butanoate

·       Dichlorobenzene

·       Methyl butanoate

·       Dipropyl ether

·       Methanethiol

·       Ethanethiol

·       Butanethiol

·       Methanol

·       Heptanes

·       Octanes

·       Nonanes

·       Dichlorodifluoro-methane

·       Methane

3.3.5  Limit Levels for Methane, Ambient VOCs, Ammonia and H2S Monitoring

Ambient methane, VOCs, ammonia and H2S monitoring results will be evaluated against the limit levels.  The limit levels at the SENTX boundary are defined as WHO/USEPA/CARB’s ambient criteria if available or the odour thresholds or 1% of Workplace Exposure Limit (WEL) as stipulated in the “UK Health and Safety Executive (HSE) EH 40/2005 Workplace Exposure Limits”, whichever is lower. 

In case of exceedance of the limit levels, more frequent monitoring, as specified in the EAP (see Section 3.8) should be conducted.  This additional monitoring should be continued until the non-compliance is rectified.

3.4                                                         Emissions of the Thermal Oxidiser

3.4.1  Introduction

The performance of the thermal oxidiser should be monitored when the LTP is in operation.  The purpose of the monitoring is to ensure the thermal oxidizer is operated under its design condition and emission limits.

3.4.2  Monitoring Parameter, Location and Frequency

Gas samples should be collected from the stack of the thermal oxidiser for laboratory analysis of the parameters at a frequency as described in Table 3.4a.  In addition, the operating conditions of the thermal oxidiser should also be monitored continuously. 

Table 3.4a      Monitoring Parameters and Frequency of Stack of Thermal Oxidiser

Phase

Monitoring Frequency

Parameters

Operation/ Restoration

·     Monthly for the first 12 months of operation and thereafter at quarterly intervals

 

Laboratory analysis for

·     NO2

·     CO

·     SO2

·     Benzene

·     Vinyl chloride

In-situ analysis for

·       Exhaust gas velocity

 

·     Quarterly for the 1st year of operation (a)

Laboratory analysis for

·     Non-methane organic compounds

 

·     During commissioning and thereafter at quarterly intervals if any ammonia is detected during commissioning stage

Laboratory analysis for

·       ammonia

 

·     Continuously

 

·     Gas combustion temperature

·     Exhaust temperature

·     Exhaust gas velocity (b)

Notes:

(a)                                           The monitoring results will be reviewed towards the end of the first year of operation to determine if monitoring of this parameter can be terminated upon agreement by the EIAO Authority, IEC and Project Proponent.

(b)                                           The exhaust gas velocity will be calculated based on the cross-section area of the stack and continuous monitored gas flow and combustion temperature data.

Under the combustion temperature of the thermal oxidiser, all ammonia will be destroyed.  To confirm this design assumption, it is recommended that the ammonia concentration in the flue gas of the thermal oxidiser be monitored during the commissioning stage of the thermal oxidiser.  If required, an emission standard will be set for ammonia for the thermal oxidiser based on the monitoring results and to be fully justified by ET Leader, verified by IEC and approved by EPD (EIAO Authority).  If no ammonia is detected in the flue gas during the decommissioning stage, the monitoring of ammonia in the flue gas of the thermal oxidiser could be discontinued.

3.4.3  Monitoring Equipment

The Contractor should be responsible for providing and maintaining a sufficient number of the following monitoring equipment. 

Air Sampling Equipment

The sampling equipment should be able to capture emission from the stack into inert sample containers for direct analysis on a gas chromatography in the laboratory.  The method for the monitoring should be proposed by the ET and agreed with the Project Proponent in consultation with the IEC.

Gas Combustion Temperature, Exhaust Gas Temperature

A built-in monitoring system should be installed in the thermal oxidiser, which should be capable of continuous monitoring of gas combustion temperature and the exhaust gas temperature.  

3.4.4  Laboratory Analysis

Gas samples should be transferred to the analytical laboratory within 24 hours of collection and analysed within 48 hours after collection. 

Bulk gas samples should be analysed by gas chromatography for the parameters listed in Table 3.4a to detection limit of 0.0025% or lower unless other specified.  The carrier gas to be used for the analysis should be helium, hydrogen or nitrogen with a minimum purity of 99.995%. 

3.4.5  Impact Monitoring

The ET should carry out impact monitoring when the thermal oxidiser is in operation.

3.4.6  Performance Compliance 

The limit levels for NO2, CO, SO2, benzene and vinyl chloride from the stack emission and gas combustion temperature presented in Table 3.4b should be met.  The gas combustion temperature should also comply with the design parameters of the thermal oxidiser.  These parameters have been updated as per the latest design and the air quality still complies with the prevailing AQOs.  In case of non-compliance with the limit levels, more frequent monitoring and actions in accordance with the EAP (see Table 3.8b) should be carried out.

If ammonia is detected during the commissioning stage, an emission standard will be set for ammonia for the thermal oxidiser based on the monitoring results and to be fully justified by ET Leader, verified by IEC and approved by EPD (EIAO Authority). 

Table 3.4b      Limit Levels for Stack Emission of the Thermal Oxidiser

Parameter

Limit Level

NO2

1.58 gs-1

CO

0.53 gs-1

SO2

0.07 gs-1

Benzene

3.01 x 10-2 gs-1

Vinyl chloride

2.23 x 10-3 gs-1

Gas combustion temperature

850oC (minimum)

Exhaust gas exit temperature

443K (minimum) (a)

Exhaust gas velocity

7.5 ms-1 (minimum) (a)

Note:

(a)   Level under full load condition.

3.5                                                         Emissions of Landfill Gas Flare

3.5.1  Introduction

The performance of the landfill gas flares should be monitored when they are in operation.  The purpose of the monitoring is to ensure the flares are operated in compliance with their design conditions and emissions standards.

3.5.2  Monitoring Parameter and Frequency

The operating conditions (i.e. gas combustion temperature and exhaust gas velocity) of the flare should be monitored continuously.  Exhaust gas samples should be collected for laboratory analysis of NO2, CO, SO2, benzene and vinyl chloride.  Table 3.5a summarised the monitoring parameters, locations and frequency of the emissions from the flares. 

Table 3.5a      Monitoring Parameters, Location and Frequency of Stack of the Flares

Phase

Monitoring Frequency

Parameters

Operation/ Restoration and aftercare

·     Monthly for the first 12 months of operation and thereafter at quarterly intervals (a)

 

Laboratory analysis for

·     NO2

·     CO

·     SO2

·     Benzene

·     Vinyl chloride

In-situ analysis for

·     Exhaust gas velocity

 

·     Quarterly for the 1st year of operation (b)

Laboratory analysis for

·     Non-methane organic compounds

 

·     Continuously

·     Gas combustion temperature

·     Exhaust temperature

·     Exhaust gas velocity (c)

Notes:

(a)   Reduction of monitoring frequency will be subject to the monitoring results to demonstrate environmentally acceptable performance.

(b)   The monitoring results will be reviewed towards the end of the first year of operation to determine if monitoring of this parameter can be terminated upon agreement by the EIAO Authority, IEC and Project Proponent.

(c)    Exhaust gas velocity will be calculated based on the cross-section area of the stack and continuous monitored gas flow and combustion temperature data.

3.5.3  Monitoring Equipment and Laboratory Analysis

The monitoring equipment and laboratory analysis requirements are the same as those for thermal oxidiser (see Sections 3.4.3 and 3.4.4)

3.5.4  Impact Monitoring

The Contractor should carry out impact monitoring when the flares are in operation.

3.5.5  Performance Compliance 

The limit levels for NO2, CO, SO2, benzene and vinyl chloride from the stack emissions and gas combustion temperature presented in Table 3.5b should be met.  The gas combustion temperature should also comply with the design parameters of the flares.  These parameters have been updated as per the latest design and the air quality still comply with the prevailing AQOs.  In case of non-compliance with the action levels, more frequent monitoring and actions in accordance with the EAP (see Table 3.8b) should be carried out.

Table 3.5b      Limit Levels for Gas Flare Stack Emission

Parameter

Limit Level

NO2

0.97 gs-1

CO

2.43 gs-1

SO2

0.22 gs-1

Benzene

4.14 x 10-4 gs-1

Vinyl Chloride

2.60 x 10-4 gs-1

Gas combustion temperature

815oC (minimum)

Exhaust gas exit temperature

923 K (minimum) (a)

Exhaust gas velocity

9.0 m s-1 (minimum) (a)

Note:

(a)   Level under full load condition

 

3.6                                                         Emissions of LFG Generator

3.6.1  Introduction

The performance of the LFG generator should be monitored.  The purpose of the monitoring is to ensure that the generators are operated in compliance with their design conditions and emissions standards.

3.6.2  Monitoring Parameter and Frequency

The operating conditions (ie gas combustion temperature and exhaust gas velocity) of the generator stack should be monitored continuously.  Exhaust gas samples should be collected for laboratory analysis of NO2, CO, SO2, benzene and vinyl chloride.  Table 3.6a summarised the monitoring parameters, locations and frequency of the emissions from the generator stack.

Table 3.6a      Parameter, Location and Frequency of Stack of the LFG Generator

 

Phase

Monitoring Frequency

Parameters

Operation/ Restoration and aftercare

·     Monthly for the first 12 months of operation and thereafter at quarterly intervals (a)

 

Laboratory analysis for

·     NO2

·     CO

·     SO2

·     Benzene

·     Vinyl chloride

In-situ analysis for

·        Exhaust gas velocity

 

·     Quarterly for the 1st year of operation (b)

Laboratory analysis for

·        Non-methane organic compounds

 

·     Continuously

·     Exhaust temperature

·     Exhaust gas velocity (c)

 

Notes:

(a)   Reduction of monitoring frequency will be subject to the monitoring results to demonstrate environmentally acceptable performance.

(b)   The monitoring results will be reviewed towards the end of the first year of operation to determine if monitoring of this parameter can be terminated upon agreement by the EPD (EIAO Authority), IEC and Project Proponent.

(c)    Continuous monitoring of exhaust gas velocity will be calculated based on the cross-section area of the stack and continuous monitored gas flow and combustion temperature data.

3.6.3  Monitoring Equipment and Laboratory Analysis

The monitoring equipment and laboratory analysis requirements are the same as those for thermal oxidiser (see Sections 3.4.3 and 3.4.4)

3.6.4  Impact Monitoring

The Contractor should carry out impact monitoring when the generator is in operation.

3.6.5  Performance Compliance

The limit levels for NO2, CO, SO2, benzene and vinyl chloride from the stack emissions as presented in Table 3.6b should be met.  The gas combustion temperature should comply with the design parameters of the generator.  These parameters have been updated as per the latest design and the air quality still complies with the prevailing AQOs.  In case of non-compliance with the action levels, more frequent monitoring and actions in accordance with the EAP (see Table 3.8b) should be carried out.

Table 3.6b      Limit Levels for LFG Generator Stack Emission

Parameter

Limit Level

NO2

1.91 g s-1

CO

2.48 g s-1

SO2

0.528 g s-1

Benzene

2.47 x 10-4 g s-1

Vinyl chloride

1.88 x 10-5 g s-1

Gas combustion temperature

450oC (minimum)

 

Exhaust gas exit temperature

723K (minimum) (a)

 

Exhaust gas velocity

30.0 ms-1 (minimum) (a)

 

Note:

(a)   Level under full load condition.

 

3.7                                                         ODOUR

3.7.1  Introduction

The effectiveness of the odour mitigation measures should be monitored to ensure that the operation of the SENTX will not cause unacceptable odour impact on the ASRs.  This Section describes the EM&A requirements with respect to odour control.

3.7.2  Odour Patrol

Odour patrol should be carried out during the operation/restoration phase.  Odour patrol should commence once the SENTX starts receiving waste.  During aftercare phase, when there are maintenance works that require excavation of waste, odour patrol should also be undertaken.

Daily odour patrol should be conducted jointly by the ET and the IEC 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 odour intensity detected should be based on that determined by the IEC.  The patrol frequency shall be 3 times per day and conducted daily during the first month of operation and reduce to weekly for another three months should odour not being detected in the first month and no valid odour complaint cases are received.  The patrol frequency shall be reviewed after the 4-month patrol and reduce to monthly interval thereafter subject to the patrol findings and odour complaint record.  Since 6 January 2016, the SENT Landfill has been receiving construction waste only, which is significantly less odorous and no substantiated odour complaint against SENT Landfill were received in 2016 and 2017.  It is therefore considered appropriate to relax the monitoring frequency to monthly, which are made reference to the odour patrol requirement in other waste treatment facilities, including Sludge Treatment Facility, Organic Waste Treatment Facility Phase 1 and Integrated Waste Management Facilities Phase 1. 

Each proposed change of odour frequency shall be justified by the ET Leader and verified by the IEC and will be subject to agreement with Project Proponent and EPD (EIAO Authority).

In addition, an independent party (who should be a trained personnel/ competent person as described in Section 3.7.3) should be appointed to undertake odour patrol together with the ET and the qualified panellist from the IEC at monthly interval.  During these patrols, the odour intensity detected should be based on that determined by the independent third party.

The parameter, location and frequency of odour patrol are summarised in Table 3.7a.

Table 3.7a      Parameter, Location and Frequency for Odour Patrol

Phase

Patrol Locations

Patrol Frequency (a)

Parameters

Operation/ Restoration

Patrol along the SENTX Site Boundary

Period 1 - First month of operation

Daily, three times a day in the morning, afternoon and evening/night (between 18:00 and 22:00 hrs) conducted by the ET and the IEC

 

Three times per week on different days conducted by an independent thir