2                         Consideration of Alternatives

2.1                   Introduction

In response to clause 3.3 of the EIA Study Brief, the Project Proponent has explored different construction methods and operation arrangements for the Projects in a view to avoid or minimize adverse environmental impacts.  This section summarizes the alternatives that have been considered during the planning and design stages and the rational for choosing the preferred options. 

2.2                   Options for Construction

 

2.2.1             Jetty Construction

The proposed biodiesel plant will be located at the Chun Wang Street within the TKOIE (the Site) (see Figure 2.2a).   The Site is located adjacent to the existing rubble mount sloping seawall of the TKOIE.  Transportation of biodiesel, PFAD and methanol will be by marine-going vessels.  It is therefore necessary to develop a jetty for the reception of PFAD and methanol from the barges and loading of biodiesel to the barge.  A jetty of 50m long and 26m wide is proposed. 

 

During the project planning and design stage, two construction methods for the jetty were considered.  The first option (Option 1) (see Figure 2.2b) is to construct a vertical seawall with concrete blocks.   Standard concrete seawall blocks will be placed by crane on compacted rockfill foundation and the space between the concrete block seawall and the land will be filled with compacted granular fill.  The area reclaimed will be paved with concrete or bitumen macadam.  In this option, the reclamation will obstruct the water flow in the area and thus may affect the flow regimes during the operational phase.  The habitat and marine organisms on the existing seawall will be directly impacted as a result of the construction of the jetty. 

Another option considered is construction of a piled deck jetty (Option 2) (see Figure 2.2c).  The jetty will be in form of a reinforced concrete deck supported by marine piles (about 1m diameter each).  The piles will be installed using drilling rig and hence will have minimal impact on the existing seawalls.  No dredging works or reclamation will be required.  Although there may be localised effects due to physical resistance of the piles, the water flows through the piled structure and the bathymetry will generally be maintained.  It is not expected that the piles will cause adverse impacts to the water flow regime at the jetty during operation phase.  Unlike Option 1, this option will only affect the areas where the piles will be placed and hence the potential impacts to marine ecology will be very much reduced and minimal.  The piles will also serve as artificial habitat for the settlement and re-colonisation of marine assemblages.  Therefore, Option 2 (ie a piled deck jetty) is selected for detailed engineering design and adopted for EIA Study.

2.2.2             Construction of Tank Farm

A tank farm will be constructed within the biodiesel plant for storage of feedstock and products.  With respect to the nature of the materials to be stored, concrete tanks are more susceptible for cracks and hence have a higher change of leakage.   For storage of similar materials, steel tanks are commonly used.   Steel tank offers better mechanical, technical and safety standards.    In addition, the concrete tanks will have to be constructed on-site and will generate more construction waste and have a higher potential to cause dust and noise impacts.   The storage tanks will therefore be constructed with structural steel.    

The tanks will be prefabricated off-site and delivered to the site for installation.  To ensure the integrity of the tanks, the tanks will be installed on a reinforced concrete platform which will be supported by a thick layer of granular fill to allow for settlement during full load.  This will minimize the potential leakage from the tanks.  The tank farm area will be bunded (at least 110% of the volume of the largest tank) to contain ay spillage or leakage from the tanks.

 

2.2.3             Pipelines

Most of the pipelines for conveying raw materials, semi-products and end-products within the Site are overhead pipelines installed on the pipe bridges.   Overhead pipelines are preferred to underground pipelines as any leakage of the pipelines can be easily detected by visual inspection.  The potential for land contamination can be minimized if leakage occurred.  All pipelines on the pipe bridges are welded and the connections (such as flanges and values) will be placed within or above a bunded area to minimize the environmental impacts if leakage occurred at the joints.     

 

The minimum height of all pipe bridges is 4.5m above ground level to prevent them from collision by vehicles.  Height check and control will be implemented at the site entrance to ensure no vehicle taller than 4.5m will enter to the pipe bridges areas.  The columns of the pipe bridges will be protected by a concrete wall. 

2.3                   Options for Operation 

2.3.1             Materials for Biodiesel Processes

The biodiesel manufacturing process adopted for the plant has taken accounted of the best available technology (BAT) for the multiple feedstock processes.  Material recycling and waste minimization have been carefully considered in the design of the production processes which allow better material utilization and minimize the generation of solid waste and wastewater.  The adopted technology has the following characteristics:

·            Generate saleable by-product:  All by-products are saleable.  The main by-products are glycerine and potassium sulphate which can be sold for chemical, pharmaceutical and other industrial applications.  This will avoid the need to dispose the by-products generated from the processes.

·            Offer a high material-to-product conversion:  During the processes, sub-standard products will be recycled back into the system at various stages.  This will minimise the generation of chemical waste and wastewater from the plant. 

·            Minimize energy use:  The main biodiesel production line is a semi-continuous process which is operated at atmospheric pressure and room temperature.  This minimizes the energy consumption of the plant.  In addition, the bioheating oil (which is a lower grade biodiesel) and biogas generated from the biodiesel production process and wastewater treatment plant, respectively will be reused on-site as a fuel for the boilers.  This minimizes the use of petroleum based fuel (eg diesel or Town Gas).

·            Choose the most suitable raw materials:  The raw materials used for the manufacturing processes are chosen to minimize the potential environmental, health and safety impacts.  Table 2.3a summarizes the rationales for choosing raw materials to be used for the biodiesel production processes. 

Table 2.3a      Raw Materials to be used for the Biodiesel Production Processes

Function in the Production Line

Raw Materials Chosen

Other Potential Materials

Rationale

Strong acid  to be added to carboxylic acids in the fat to minimize reaction time

 

Sulphuric Acid

Other strong acids

A saleable by-product potassium sulphate (a raw material for agricultural fertilisers) will be produced and thus minimized waste generation

 

Simple alcohol to replace glycerol in the feedstock during the transesterification process

Methanol

Other simple alcohol (eg ethanol)

To produce a saleable product, fatty acid methyl ester.  Methanol has been attributed a harmfulness ranking of “low” and has a lower photochemical ozone creation potential (POCP) of 21 comparing with that of ethanol (45)

 

Acid to be used in the washing steps

Phosphoric Acid

Other acids (eg sulphuric acid)

To reduce the input of sulphur-based materials and hence minimise the risk of sulphur being added to the biodiesel.  Phosphoric acid is more effective than other acids in removal of impurities.

 

Alkaline catalyst for various stages of process

Potassium Hydroxide

Other alkaline catalyst (eg sodium hydroxide) 

To produce a saleable product, potassium sulphate (a solid which is easy to handle).  The use of sodium hydroxide will produce sodium sulphate which is highly soluble.  It will be discharged into liquid waste stream and cannot be reused

2.3.2             Air Abatement Technology

Volatile Organic Carbons (VOC)

 

Various VOC recovery and abatement technologies listed in the European Commission’s Integrated Pollution Prevention and Control (IPPC) have been reviewed.  Wherever possible, the VOCs recovered will be re-used within process.  The VOC recovery technologies considered during the design stage are listed in Table 2.3b.

Table 2.3b      VOC Recovery Technologies

Technique

 

Recycling Potential

Condensation

To condense the VOCs by increasing the pressure or reduce temperature

 

Condensate can be reused in the system

Absorption

Remove VOCs from a gas stream by mass transfer into a scrubbing liquor

 

Resulting a mixture which can recycled

Adsorption

Remove VOCs from a gas stream by passing the gas through a solid medium

 

Typically for final polishing of the exhaust gas.  The VOCs cannot be recovered for recycling

 

Thermal Oxidation

Complete thermal breakdown of VOCs will lead to the formation of carbon and water. This can be combined with existing combustion units such as boilers or biogas flares

Do not enable recycling

 

Condensation is chosen to recycle the majority of the spent methanol.  Methanol from the process exhaust emissions will be recovered for reuse using condensers and a wet scrubber which will use water as the scrubbing medium.  The spent scrubber water will be recycled and the methanol will be separated in the demethanolisation/ dewatering column.  The methanol will be reused in the production processes.  Although the VOCs arising from feedstock pre-treatment and storage tanks are expected to be low ([1]), the exhaust air or vent gas from the pre-treatment and storage tanks which will be removed by a two-bed carbon filter adsorption system.   The potential VOC emission from the plant will therefore be negligible.   During the loading of the methanol tank, the vent gas will be recovered/ recycled back to the tanker so that the vent gas will not be discharge to the atmosphere.

Odour Emissions

In order to minimize potential odour nuisance, all the GTW and WCO will be unloaded at the designated stations via flexible hoses or pipelines in a closed system arrangement.   The GTW screening room and screenings storage room will be provided with ventilation at all time (except during maintenance period) to maintain a slight negative pressure to prevent odour emissions to the atmosphere.  The exhaust air will be scrubbed.  Instead of discharging to the atmosphere, the scrubbed air will be used as part of the ventilation air for the enclosed wastewater treatment tanks and air supply for the aeration tanks.  This will further minimise the discharge of odorous air to the atmosphere (please refer to Section 3.2.2 for further details). 

All processing vessels and tanks in the biodiesel plant, including wastewater treatment tanks, will be enclosed to prevent odour emissions ([2]).  The vent gas will be scrubbed prior to discharge to the atmosphere (please refer to Section 3.2.2 for further details).

The surplus sludge from the sludge thickener will be dewatered to at least 30% dry solids (about 1.3 tpd) using a belt press in the Sludge Dewatering Room.  The dewatered sludge will be stored in container inside the Sludge Room.  The roller door of the Sludge Room will be closed except for removal of the sludge container for disposal.  The Sludge Dewatering Room and Sludge Room will be provided with a ventilation system and the exhaust air will be scrubbed (by the final scrubber, see Figure 4.4a) prior to discharge to the atmosphere.   A slight negative pressure will be maintained at all times when the sludge dewatering process is carrying out and sludge is being stored in the Sludge Room.  The sludge container will be properly covered with metal flip doors or tarpaulin before the roller door of the Sludge Room is opened.  

 

2.3.3             Wastewater Management

Source reduction and segregation are adopted in the design of the wastewater management system to minimize the needs for treatment.  Source reduction measures include recycling of the biodiesel wash water through the process and careful control of the process and utilities.  In addition, containment bund will be provided for the material storage tanks and good housekeeping will avoid/ minimize the potential for land contamination and surface water contamination.

Drainage System

The Site will be provided with separate surface water and foul water drainage systems to prevent untreated sewage/ potentially contaminated stormwater runoff from discharge into the sea (see Figure 3.2h).   The proposed drainage system consists of three separate sub-systems:

·            Wastewater  from the process, utilities and high-risk yard areas (ie tank farm and GTW reception area);

·            Surface water runoff from low risk areas (ie non process area); and

·            Surface water runoff from roofs.

The wastewater collected from the process and high-risk yard areas will be collected and treated at the on-site wastewater treatment plant to meet the statutory requirements for discharge to foul sewer.   In order to prevent contaminated surface runoff from discharge off-site, surface runoff of the bunded area will pass through an oil interceptor before discharge to the stormwater drainage system of the TKOIE.   

Wastewater Treatment Plant

Wastewater generated from feedstock pre-treatment and glycerine dewatering processes will contain trace amount of oils and fats and have a high COD concentration.  The wastewater will be treated at the on-site wastewater treatment plant prior to discharge to the foul sewer leading to the TKO Sewage Treatment Plant.  Different treatment methods have been considered in the planning and design stages and they are described below.

Pre-treatment options including grit separation, sedimentation (including coagulation and flocculation), air flotation, filtration and membrane filtration have been considered.   Three pre-treatment techniques, including the dissolved air flotation (DAF), settlement after chemical treatment and membrane filtration, can achieve more than 80% fat/oil removal efficiency and therefore they are further studied.  Table 2.3c compares these technologies.   Oil-water separator and DAF with prior equalisation and pH adjustment are selected for the design of the on-site wastewater treatment plant.

Table 2.3c      A Comparison of Potential Wastewater Pre-Treatment Technologies

Technique

Advantages / Disadvantages

Dissolved Air Flotation (DAF)

·     Ideally suited to treat wastewaters containing high concentrations of fats and oils

·     Can reduce COD/BOD concentrations by more than 80%

 

Settlement / Sedimentation

·     Much larger footprint than DAF or membrane filtration

·     The process is not induced / controlled by a physical separation process

·     Settlement tank requires a large open area and also have a higher potential for odour emissions

 

Membrane Filtration

·     Fats have a high potential to block the membrane which will lead to a rapid tail off of removal efficiency

 

After pre-treatment (ie DAF process), the wastewater will be conveyed to the biological treatment processes to further reduce the organic loading.  An anaerobic treatment process, Internal Circulation (IC) reactor (utilising the upflow anaerobic sludge blanket (UASB) technology), will be used to further reduce the organic loading of the wastewater.   The wastewater will then be treated by an activated sludge treatment process to reduce the remaining COD from the anaerobic digestion.  These treatment technologies were chosen because of their high removal efficiency for organic matters in the wastewater.  A combination of the IC reactor and an activated sludge treatment process has been widely used to treat wastewater with high COD/BOD (such as fermentation, paper and pulp, brewery and food etc). 

2.3.4             Materials Transfer

PFAD and methanol will be received from barges via the on-site jetty.  Biodiesel will be pumped from the storage tanks to the barge.  Different transfer methods, such as drums and ISO tankers, hose pipe, etc were considered for the transfer of materials from the jetty to the tank farm to minimize the risk of spillage and hence water pollution and land contamination.   Dry coupling will be used to connect the loading/unloading pipes to prevent leakage of the material at the joints.  This technology has been used in a number of existing biodiesel plants in Europe and proved to be very effective and reliable in preventing spillage. 

Barge with well insulated compartments will be used to minimise energy required to heat up the PFAD and maintains the material in liquid during transfer.  The PFAD will be pumped to the storage tank through a coiled heat pipeline.  ISO Tanker barge can also be used as the heating coils can be put into the tanker if heating is required.  ISO tanker barge has been used for transfer of oil at the Shell Oil Terminal in Tsing Yi.    The bulk transfer of feedstock (PFAD and methanol) by barge will also minimise the traffic associated with delivery of the materials by road.

Other precautionary measures such as loading/unloading of materials at a bunded area and on-site drainage system will also minimise the risk of water pollution (see Section 6). 

2.3.5             On-site Storage of Raw Materials and Products

The tank farm is the main area for on-site storage of raw materials and products.   All tanks and pumps are designed to fulfil both local and international standards for mechanical, technical and safety requirements.  

The layout of the tanks has been designed to comply with local fire protection requirements.   The methanol storage tank will be placed in a separate bunded area.  It will be located more than 15m from other dangerous goods tanks (such as the biodiesel storage tanks) and away from the site boundary in order to minimise the potential risk to off-site population.   The other storage tanks for the dangerous goods are located at least 10m from site boundary so that there will be sufficient buffer zone to minimize potential risk to off-site population. 

2.4                   Choosing the Best Available Options

The Project Proponent has explored various construction methods and operation arrangements for the Project in a view to avoid or minimise adverse environmental impacts.  Practicable means to prevent marine pollution and hazardous incidents arising from transfer of PFAD and methanol from the jetty to storage tanks and biodiesel from the storage tank to the jetty have been considered in the design.   The design and operation of the biodiesel plant have taken account of the best available technology to minimise potential environmental pollution and risk to the public. 

 



([1])      The oil and grease will be recovered from the GTW in the feedstock pre-treatment tanks.  As GTW containing diluted oily water from food establishments, it is anticipated that the vent gas will contain low level of VOCs.  Other raw materials include PFAD, WCO, animal fat, sulphuric acid and phosphoric acid will generate minimal VOCs or are inorganic compounds.

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