14 CHAPTER 9

Sime Darby Biodiesel Sdn Bhd EIA

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CHAPTER 9:
ENVIRONMENTAL MANAGEMENT PLAN

9.1 INTRODUCTION

An Environmental Management Plan (EMP) is a document that is prepared to detail out the
mitigation measures that shall be undertaken by Project Proponent in order to pursue
compliance and minimizing the negative impacts to the environment. It is necessary to help
facilitate the effective environmental management of the Construction and Operational Phase
activities of the Project.

The primary objective is to ensure the proper implementation of all environmental
considerations recommended for the Proposed Project in the Environmental Impact
Assessment (EIA) report. The management plan covers both construction and operational
phases of the Project. The EMP comprises of these following topics:

• Pollution Prevention and Mitigation Measures to be Implemented;
• Establishment of Environmental Management Unit;
• Environmental Monitoring System;
• Environmental Training.

In this chapter, the outline of EMP that shall be implemented is presented. The full EMP is to
be submitted to DOE after EIA approval.

9.2 POLLUTION PREVENTION AND MITIGATION MEASURES TO BE IMPLEMENTED

The Project Proponent through the Environmental Officer (EO) shall prepare a Performance
Monitoring Document (PMD) that describes in detail how EIA approval conditions (COAs) are
going to be complied and how performance monitoring of the P2M2s will be conducted to
ensure the optimal functionality of the P2M2s is maintained.

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The project proponent is required to keep a current copy of the PMD and PM log book at the
Project Site or at an easily accessible location, so that it can be made available at the time of
an onsite inspection or upon request by the Department of Environment (DOE) inspector. This
log book shall be maintained or updated by weekly/event-based inspections.

The Project Proponent through the EO shall prepare a Performance Monitoring Report (PMR)
that discusses the results of the performance monitoring conducted as described in the PMD.
Wherever relevant, PMR shall include data interpretation and assessment of the effectiveness
of the P2M2s by making comparison of the performance monitoring parameters with their
recommended ranges (or standards). Statistical techniques and graphical presentation of the
performance monitoring parameters shall be used wherever appropriate. PMR shall also make
some definitive conclusions on the overall performance of the P2M2s.

Table 9.1 shows the template for the pollution prevention and mitigation measures (P2M2s)
to be implemented for the proposed Project Site. The contents of the table shall be derived
from recommended in the EIA report and additional requirements stipulated in the EIA
approval conditions (COAs). P2M2 shall be those which can be described as “state of the art
technologies” or “industry best practices”.

Table 9.1: Pollution Prevention and Mitigation Measures (P2M2) To Be Implemented

Project Activities and Impacts P2M2 Recommended P2M2 to be
Environmental Implemented

Issues Concerned

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9.3 MANAGEMENT TEAM AND ENVIRONMENTAL MANAGEMENT UNIT (EMU)

Collective effort towards systematic implementation of the environmental management
programmes is vital to secure an effective EMP. As such, the establishment of a team of
personnel with defined roles and responsibilities is required in the EMP.

• Environmental Officer (EO) and Certified Competent Person

Environmental Officers and Certified Competent Person shall be appointed before the
commencement of works at site (Note: Certified Competent Person needs to be a CePIETSO
qualified and CePSWaM qualified or any equivalent qualification).

Currently, the appointed competent person for the handling of Wastewater treatment plant is
En. Ahmad Faisal bin Abdullah (Certified Environmental Professional in the Operation of
Industrial Effluent Treatment System – Physical Chemical Processes CePIETSO-PCP/00407.

Duty and Job Scope of the competent person for the Operation of Industrial Effluent Treatment
System on site are:

• To operate the leachate treatment system for a sanitary landfill
• Conducting measurements, collecting samples and conducting analysis
• Preparing performance monitoring report and presenting it to the DOE
• Making decision on IETS/LTP matters
• Initiating efforts to introduce new/improved work or monitoring procedure in IETS/LTP
• operation

An appointed competent person for the handling of scheduled wastes is En. Mohd Hakim
Firdaus (Certified Environmental Professional In Scheduled Wastes CePSWaM/15946.

Duty and job scope of the competent person for the Scheduled Wastes Management on site
are:

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• Formulate an implementation plan for full compliance with the regulatory and
requirements of the Environmental Quality (Scheduled Wastes Regulations,
2005).

• Assist the operation department to monitor and control the special management in the
disposal site.

• Conduct training to company staff on scheduled waste management.
• Propose and review company procedures in scheduled waste management.
• Plan, propose and implement company’s waste disposal procedures of Scheduled

Wastes.

9.4 ENVIRONMENTAL MONITORING PROGRAMME

Environmental Monitoring Programme is an essential element of the Environmental
Management Plan as it serves to provide feedback information on the effectiveness of the
Environmental Management Programme, and the need for introducing additional mitigation
measures for minimizing adverse impacts or residual impact.

The parameters that are being monitored must comply to established standards by DOE or
other recognised Malaysian or international standard. Table 9.2 and Table 9.3 shows the
standards to be complied during construction and operation, respectively.

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Table 9.2: Standards to be Complied During Construction

Aspects Standards and Regulations
Noise
River quality The Planning Guidelines for ANNEX A S
Environm ental Schedule 1
Noise Limits and Control of Construc
Work by Re

Landuse C

National Water Quality Standard Class III Ri

Ambient Air Quality Malaysian Ambient Air Quality Interim targ
Guideline

Discharge from Silt Trap N/A N/A

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Specifications Parameters & Limit values

Schedule of Permissible Sound Levels Day time
1- Maximum Permissible Sound Levels • LAeq: 70 dBA
ction, Maintenance and Demolition
eceiving Land Use Night time
• LAeq: 60 dBA
CategoryDesignated Industrial Zone

iver -
get 1 (IT-1) in 2015
• PM10 (24-hour): 150 μg/m3
• PM2.5 (24-hour): 35 μg/m3

• Turbidity: < 250 NTU
• TSS: <50 mg/l

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Table 9.3: Environmental Standards to be Complied During Operati

Aspects Standards and Regulations

River quality National Water Quality Standard ANNEX A
Noise Levels
The Planning Guidelines for Schedule
Environm ental Levels of
Noise Limits and Control Dem olitio

Landuse

Industrial effluent Environmental Quality (Industrial Standard
Effluent) Regulations 2009

Stack Discharges Environmental Quality (Clean Air) Third Sch
Ambient Air Quality Regulations 2014

Malaysian Ambient Air Quality Interim ta
Guideline

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ion

Specifications Parameters
Class III River -

A Schedule of Permissible Sound Day time
• LAeq: 70 dBA
e 1- Maximum Permissible Sound
f Construction, Maintenance and Night time
on Work by Receiving Land Use • LAeq: 60 dBA

e CategoryDesignated Industrial Zone

d B as per Fifth Schedule • Temperature: 40 °C
• pH: 5.5-9.0
• BOD: 50 mg/L
• Suspended Solids: 100 mg/L
• Oil & Grease: 10 mg/L
• Ammoniacal Nitrogen: 20 mg/L

hedule- Boilers • Total Particulate Matter: 50 mg/m 3
arget 1 (IT-1) in 2015 • NO2: 500 mg/m 3
• SO2: 500 mg/m 3

• PM10 (24-hour): 150 μg/m3
• PM2.5 (24-hour): 75 μg/m3
• SO2 (24-hour): 105 μg/m3
• NO2 (24-hour): 75 μg/m3
• O3 (8-hour):120 μg/m3
• CO (24-hour):10 μg/m3

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9.4.1 Performance Monitoring

Performance Monitoring (PM) during constructions phase is the monitoring to ensure that the
pollution control systems are in place before the earthworks and other mitigation measures
are in good condition to reduce the adverse impacts from the proposed Project at a minimum
level. Environmental Officer (EO) or Certified Competent Person shall carry out on-site
performance monitoring. Weekly or after a rainfall event of more than 12.5mm., monitoring of
the following will be performed, recorded and corrective action, if required, be taken

• Erosion Control (Turfing/ hydroseeding of areas completed and exposed)
• Drainage Inlet and Outlet Protection
• Detention Pond
• Silt Trap
• Temporary Earth Drain
• Hoarding
• Stabilized Construction Access
• Wash trough

Performance monitoring during operations phase is done in order to ensure that the pollution
control system in an industry is functioning optimally. Additionally, it is a kind of preventive
maintenance which helps detect early onset of deteriorating performance of the control system
hence avoids unnecessary plant shutdowns and costly enforcement penalties. The
performance of the Wastewater Treatment Plant is directly monitored while the air emissions
indirectly monitored by looking at the performance of the Boilers.

• Waste Water Treatment Plant

The performance monitoring for the Waste Water Treatment Plant shall involve monitoring of
the key sections of the Plant for the parameters such as BOD, COD, pH, O&G and TSS. This
is to ensure the proper functioning of all the WWTP components. For performance monitoring
purposes only grab sampling is required. Section 5.7.4 (page 5-30) of this EIA report presents
the information on the upgraded WWTP at Plant. Currently, the Plant is being monitored daily
by the onsite lab. It is recommended that this performance monitoring, as shown in Table 9.4
is continued. The sampling method for performance monitoring is grab sampling.

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Table 9.4: The Existing Performance Monitoring Programme at Sime Darby Biodiesel

Sections Parameters Recommended Limits Frequency
TCOD (mg/l) 30,000
Inlet WWTP Glycerine (%) 1.0 Daily
pH 3.0-5.0
Conditioning Oil & Grease (mg/l) 1,000 Mondays & Thursdays
Sump Methanol (%) 0.30
Turbidity Daily
Anaerobic Total Suspended Solid (TSS) 500
Bioreactor (mg/l) 20,000 Mondays & Thursdays
TCOD 6.5-7.5 Daily
Aeration Sump pH Mondays & Thursdays
Oil & Grease 10 Wednesdays
Treated Water Methanol 0.01 Daily
at Discharge Turbidity 100 Tuesdays and Fridays
Point Total Suspended Solid Mondays & Thursdays
(TSS) (mg/l) 3,000
TCOD 6.9-7.2 Daily
pH
Total Nitrate Ratio N:P (5<1) Wednesdays
Total Phosphate
Ratio Nitrate- Phosphate 5.5-9.0
VFA 12,000
Alkalinity 11,000
TCOD
pH Ration N:P
MLSS (5<1)
MLVSS
Total Nitrate 200
Total Phosphate 5.5-9.0
Ratio Nitrate-Phosphate
TCOD 10
pH 100
Oil & Grease 100
Total Suspended Solids (TSS) 100
Turbidity 20
BOD
Ammoniacal Nitrogen

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• Boiler System

The Proposed Project has currently two boiler stacks and two more would be installed for the
proposed Plants, as described in Section 5.7.6 of this EIA Report.

The performance monitoring is indirectly monitored by measuring the input and output of the
plant and therefore its efficiency of the boilers. The amount of fuel consumed and the steam
generated everyday will be monitored. In the event, the amount of fuel consumption increases,
the boiler is deemed running at a lower efficiency and needing attention. The parameters to
be monitored daily are dust, fuel consumption and steam generated.

Sime Darby will also be installing a continuous emission monitoring system (CEMS) within the
two years or by 2019.

9.4.2 Compliance Monitoring

Compliance Monitoring (CM) is the monitoring activities to be carried out to ensure that the
EIA condition of approval (COAs) are complied with. An environmental audit may also be
carried out to assess the overall project compliance. A SAMM accredited laboratory shall carry
out on-site sampling and laboratory analysis. The Compliance Monitoring (CM) programme,
monitoring parameters, monitoring stations, recommended limits and frequencies are
summarised in Table 9.5 and 9.6. Project Proponent has been carrying out compliance
monitoring on monthly basis for the existing Plant.

9.4.3 Impact Monitoring (IM)

Impact Monitoring (IM) is the monitoring activities will be conducted once the proposed Project
is approved for implementation to verify that the findings of the EIA study of the potential
impacts identified during EIA preparation stage are correct, appropriate mitigation and
prevention measures are properly implemented and the measures are effective in mitigation
the adverse impacts to the environment. An appointed SAMM accredited laboratory shall carry
out on-site sampling and laboratory analysis. The Impact Monitoring (IM) programme,
monitoring parameters, stations and frequencies are summarised in Table 9.5 and 9.6.

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Table 9.5: Proposed Compliance Monitoring Programme during Co

Aspects Parameters Recommended Limits

Ambient Air PM10, PM2.5, SO2, NO2, As stated in Table 9.1
O3, CO

Noise LAeq As stated in Table 9.1

Discharge from Silt Turbidity & Total As stated in Table 9.1
Trap Suspended Solids (TSS)

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onstruction

s Location Frequency
Monthly
A1 Production Area
2°52'56.59"N,101°25'58. 36"E Monthly
Monthly
A2 Plant Boundary
2°52'53.15"N, 101°26'0.63"E

N1 Production Area
2°52'56.59"N,101°25'58. 36"E

N2 Plant Boundary
2°52'53.15"N, 101°26'0.63"E

Outlet of drain system

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Table 9.6: Proposed Compliance Monitoring Programme during Op

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peration

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Aspects Parameters Recommend
Limits

River Temperature, pH, BOD, COD, TSS, Oil As stated in
& Grease Table 9.2

Ambient Air PM10, PM2.5, SO2, NO2, O3, CO As stated in
Table 9.2
Noise LAeq
As stated in
Table 9.2

Industrial Temperature, pH, BOD, COD, TSS, DO, As stated in
Effluent Oil & Grease, Ammoniacal Nitrogen Table 9.2
Temperature, pH, BOD, COD, TSS,
Stack Mercury, Cadmium, Chromium As stated in
Discharges Hexavalent, Chromium Trivalent, Table 9.2
Arsenic, Cyanide, Lead, Copper,
Manganese, Nickel, Tin, Zinc, Boron,
Iron (Fe), Silver, Aluminium, Selenium,
Barium, Fluoride, Formaldehyde,
Phenol, Free Chlorine, Sulphide, Oil &
Grease, Ammoniacal Nitrogen, Colour,
E.coli

Total Particulate Matter, NO2, SO2

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ded Frequency
Location Quarterly

Sungai Langat, upstream of confluence Quarterly
Quarterly
n W1 with effluent-receiving drain Monthly
2°52’28.39”N 101°25’30.29”E

W2 Downstream of Confluence
2°54’9.00”N 101°25’29.26”E

n A1 Plant Boundary
2°52'52.3”N,101°26'01.1"E

A2 Within the Plant
2°52'57.5"N, 101°25'57.6"E

n N1 About 50 m from Point A1
2°52'53.7”N,101°26'00.8"E

N2 About 50m from Point A2
2°52'58.1"N, 101°25'58.5"E

n

Final discharge point

Quarterly

n Stacks 1, 4,5,6,7 (Either 1 or 4 depending on the Quarterly
boiler operating)

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Figure 9.1: Proposed River Monitoring Points

W2

Confluence
of River and

Drain

Project
Site

W1

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Figure 9.2: Proposed Air and Noise Monitoring Points

N2
A2

N1
A1

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9.5 ENVIRONMENTAL AUDITING

Section 33A of the Environmental Quality Act 1974 is states the requirement for
environmental audit. According to the Section,

1) The Director General may require the owner or occupier of any vehicle, ship or
premises, irrespective of whether the vehicle, ship or premises are prescribed under
section 18 or otherwise, to carry out an environmental audit and to submit an audit
report in the manner as may be prescribed by the Minister by regulations made under
this Act.

2) For the purpose of carrying out an environmental audit and to submit a report thereof-

a) The Director General may appoint a qualified person or
b) The Director General may request the owner or occupier to appoint a qualifies

person from the amongst the qualified person listed under subsection (3)

3) For the purpose of this Section, the Director General shall maintain a list of qualified
person who may carry any environmental audit and submit a report thereof.

An environmental audit must be carried out every four months upon the commencement of
Earthworks. The Audit must be conducted by a third-party auditor who is registered with DOE.

9.6 ENVIRONMENTAL TRAINING

There is a serious need for environmental training in terms of environmental awareness for
contractors and their sub-contractors who will be involved in the construction phase of the
Project. Ideally, the environmental measures proposed in this report should be implemented
by the contractors. Provision of environmental training and awareness building by the EMU
with the help of consultants can greatly help resolve this problem. Such measures are further
enhanced when the DOE is involved during the implementation of the EMP whereby presence
of the DOE officers generally receives the attention of contractors. While environmental

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training will not instantly solve all environmental problems on site, this can be an initial effort
by the Project Proponent to improve the environmental management within the Project site.

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9.7 EMERGENCY RESPONSE PLAN

Sime Darby is aware of its responsibility for implementing an Emergency Response Plan
(ERP) for various possible emergencies, which shall include:

• Fire and Explosion
• Oil or chemical spillage
• Industrial accidents
• Failure of pollution control equipment
• Transport vehicle accidents
• Structural collapse of building structures

The company has prepared an emergency response plan (ERP) which it proposes to upgrade
from time to time to incorporate the current upgrading of the Plant. The existing ERP presents
the step by step procedure to be taken in case of emergencies, with focus on fire, oil and
waste spillage.

The operation of the plant’s ERP will be the responsibility of the safety and health officer and
supporting staffs with the knowledge of plant operations and training in emergency
procedures.

Two or more copies of the ERP shall be placed in prominent locations of the plant. This shall
include the main reception desk of the office, the guardhouse and/or at the main entrance of
Project Site.

Personal protective equipment (PPE) required for use during an emergency will be placed in
strategic locations of the factory.

Safety equipment and materials that may be needed in the handling of emergencies shall be
made available. In particular, the following equipment shall be provided for in sufficient
quantities:

• Fireproof protective clothing;

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• Gloves, boots, gas masks, and self-breathing apparatus;
• Hazardous waste labels, barricade tape;
• Storm drain covers;
• Tool kits;
• Maps; and
• Brooms, shovels and duct tape

The Project is classified as Non-Major Hazard Installation. As part of the requirement,
Demonstration on Safe Operation of Hazardous Material and Chemicals submission for
Department of Occupational Safety and Health is required.

Appendix Q is the Demonstration of Safe Operation of Hazardous Materials and Chemicals
(DOSO) for Methanol and Sodium Methylate which includes the key elements of ERP.

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