Environment Impact Assessment (EIA) Report Comment

Section 34A,Environment Quality Order, 1987 (prescribed activities)(EIA) (8) Industry a) Chemical where production capacity of each product or combined products is greater than 100 tones/day b) Petrochemicals all sizes c) Non-ferrous Primary smelting: Aluminium all sizes Copper all sizes Others producing 50 tonnes/day and above of product d) Non-metallicCement: for clinker throughput of 30 tonnes/hour and above Lime : 100 tones/day and above burnt lime rotary kiln or 50 and above vertical kiln tonnes/day

e) Iron and steel require iron ore as raw materials for production greater than 100 tonnes/day : or using scrap iron as raw material for production greater than 200 tonnes/ day f) Shipyards Dead weight tonnage > 5,000 tonnes g) Pulp and paper industry production capacity > 50 tonnes/day

INTRODUCTION The PROPOSED PROJECT is known as the Proposed Sulphuric Acid Production Plant on PLO 289, Jalan Perak, Pasir Gudang lndustrial Estate, Pasir Gudang, Johor. The project proponent, Taiko Acid works Sdn Bhd proposes to establish a sulphuric acid plant with capacity of 105 TPD (or 35,000 tonnes/year) within the existing bleaching earth plant on PLO 289, which is owned by Premier Bleaching Earth Sdn Bhd (a wholly owned subsidiary of Taiko Clay Chemicals Sdn Bhd). Comment: Actually this proposed project only wants to establish a sulphuric acid plant within the existing bleaching plant, so it means that the location is already determined and undergoes inspection of EIA. But because of the increase of capacity of production plant, so the project proponent need to conduct another EIA report to meet the requirement.

PROJECT DESCRIPTION The production of suphuric acid includes the following processes: Melting of sulfur; Burning of liquid sulfur to form sulphur dioxide (SO2) gas; Conversion of SO2 gas to SO3 gas at converter; and Absorption of SO3 to produce sulphuric acid (H2SO4) through absorbing process. A total of 15,000 tonnes/year of produced sulphuric acid will be used as raw material for the in house bleaching earth production -Reducing the need for raw material from other suppliers. The balance, 20,000 tonnes/year will be delivered to other customers.

Comment: A total of 35,000 tonnes/year of production capacity will be produced from the plant. If we divided 35,000 per 365 days we will get 95.89 tonnes per day. But EIA prescribed activity just has stated Chemical where production capacity of each product or combined products is greater than 100 tones/day. So supposedly, they no need to conduct EIA anymore. But actually this is a mistake to think this way, because normally production of the factory is not really consistent as we calculated. Maybe the production per day is less than 100tonnes/ day or maybe less than 100 tonnes/day. So whenever the chemical factory is produce more than 100 tonnes per day so they are require conducting EIA report.

EXISTING ENVIRONMENT Hydrology and Drainage System Surface runoff from the project site will be catered by the road side drain of Jalan Perak, flowing through Titans Petrochemical plant and will eventually discharge into Sg. Perembi before entering Straits of Johor. Land Use land use within 800m from the project site consists of industrial land. The nearest sensitive receptors are mainly located to the north of the project site, namely Taman Mawar, Taman Sg. Buloh and Sek. Keb. Pasir Gudang 4. They are located about 1.1 km from the project site. Water Quality Three water sampling stations are established at the downstream of the project site. The results show BOD and COD levels were exceeded the limit of NWQS Class Ill at all stations. Treated Effluent Quality Premier Bleaching Earth has carried out monthly treated effluent discharge monitoring at the existing effluent treatment system. The recent monitoring results (Jan to Jul 11) show that all tested parameters are complied with Standard B of Environmental Quality (Industrial Effluents) Regulations 2009. Air Quality Two air sampling stations were established at upwind and downwind of the project site. Three (3) parameters (TSP, SO2 and NO2) were monitored. Results show that all parameters were below the reference limit of the Malaysian Recommended Air Quality Guidelines. Noise Quality Two noise quality monitoring station was established at the project site boundaries. Noise levels (Leq) for both day-time and night-time range from 62.3 - 66.4 dB(A).

Ecological Environment The project site is located within an established industrial estate. Therefore, the existing ecological environment has no conservation values.

Comment: For the existing environment part, the most important consideration is providing readers with sufficient appropriate information in relation to the key environment issues. At this EIA report, the EIA consultant has successfully provide the equal coverage on all aspects of the existing environment which is necessary and the extent of coverage is commensurate with the importance of the subject matter. Here the report has stated the hydrology and drainage system, land use, water quality, treated effluent quality, air quality, noise quality, ecological environment. All those aspects are really related to chemical industry. In sulphuric acid production plant, most of the related important issues will be water that use in industry and the waste water that discard from the process. So they have major concentrate this and stated out the existing environment as hydrology and drainage system, water quality and treated effluent quality. The ecological environment is also one of the concern aspects which the project will affected the existing ecosystem or not, but luckily since the industry is located at established industrial estate, therefore they no need to conserve the ecological environment. Air quality also needs to check whether it has exceeded the limit which stated under Malaysian Recommended Air Quality Guidelines. Air quality also have to be defined since the machine that run the production process will be annoying and produce noise pollution and create uncomfortable feeling on the nearby residents. Land use is one of the issues which have to be noted and where the nearest sensitive receptors have to be stated out. Sensitive receptor is important whereby it is the individual, communities or ecosystem that could potentially bear the impacts from the proposed projects. So, the approving authority will consider the project can launch or not from the adverse impacts which affected to sensitive receptor.