Biodiesel Plant EIA Summary

PEIA FOR THE PROPOSED BIODIESEL PLANT IN EXECUTIVE SUMMARY MUKIM SG KARANG, KUANTAN, PAHANG DARUL MAKMUR

EXECUTIVE SUMMARY 1.0 INTRODUCTION

This Environmental Impact Assessment (EIA) is for the Proposed Biodiesel Plant on Tanah Tambakan Fasa 2B, Kawasan Industri Pelabuhan Kuantan, HS(D) 24266, Lot No. 10937, Mukim Sg Karang, Kuantan, Pahang. The Project involves the construction and commissioning of a biodiesel plant to produce biodiesel from crude palm oil (CPO) or refined, bleached deodorized palm oil (RBDPO) and methanol. The Project covers an area of 4.0 ha.

2.0 PROJECT INITIATOR AND CONSULTANTS

Global Bioenergy Resources Sdn Bhd (GBR) is the Project Initiator (PI) and Asia Pacific Environmental Consultants Sdn Bhd (ASPEC) carried out the EIA Study. The Civil and Structural Consultant for the Project is M.E.I. Project Engineers Sdn Bhd, while the Technology Provider is JJ Lurgi Engineering Sdn Bhd.

3.0 LOCATION

The Project site is located within the Kuantan Port Industrial Area (KPIA) in Mukim Sg Karang, District of Kuantan, at Latitude 3° 59’ 23.1” N and Longitude 103° 25’ 10.8” E to Longitude 103° 25’ 20.0” E along the reclaimed land on Tanah Tambakan Fasa 2B. The Project site is bordered by the South China Sea in the east while the west faces a stockpile area belonging to Bredero Shaw (M) Sdn Bhd. The Project site is located approximately 27 km northeast of Kuantan town and is accessible via Federal Route 3 (FR3) and Federal Route 2 (FR2), both of which are interconnected via the Kuantan Pelabuhan By-pass.

4.0 STATUTORY REQUIREMENTS

The Project to construct a biodiesel plant is a prescribed activity under the Environment Quality (Prescribed Activities) (Environmental Impact Assessment) Order 1987, Schedule 8 (a) Chemical industry with production capacity of each product or of combined products greater than 100 t/day, where an EIA is mandatory under Section 34A of Environment Quality Act 1974 to be submitted for approval by the Department of Environment (DOE), Ministry of Natural Resources and Environment Malaysia. This EIA is carried out in compliance to this Order.

ASPEC/GBR(EIA-Biodiesel)/2007 ES-1


5.0 STATEMENT OF NEED The need for the Project is predicated on the following: (a) Complementing the National Biofuel Policy (NBP): The Project will support the

5 main thrusts of the NBP through the use of alternative renewal energy sources. CPO and/or RBDPO will be processed into biodiesel and other derivatives at the biodiesel plant situated within the KPIA.

(b) Abundance of CPO as Raw Material: Malaysia is currently the largest producer

and exporter of palm oil in the world. The large amount of available raw materials in the form of CPO in the Country and especially from the State of Pahang, ensures the steady and secured supply of raw materials to produce biofuel for the biodiesel plant.

(c) High Demand for Biodiesel: The increase in demand for biofuels from foreign

markets provides an added incentive for the Project to be established to take advantage of the current demand for biofuel for the export markets. This will help the Country and State favourably in terms of foreign exchange and foreign reserve positions.

(d) Promotion of a Renewable Energy Source: Biodiesel is an alternative

renewable fuel through the use of vegetable oils and their derivatives as a fuel source or better known as biofuels. Malaysia with its vast production of palm oil, which has a comparative advantage over all other vegetative oils, is in a favourable position to develop this cost-effective and environment-friendly renewable fuel source.

(e) Savings in Fuel Costs: The Government has spent an estimated RM16 billion on

fuel subsidies in 2005. The Government is now trying to promote a blend of 5% processed palm oil and 95% diesel as diesel substitute at a national level. The Project serves this need by increasing the amount of biodiesel available for use.

(f) Economic Generator for the State: The Project will help contribute to the State's

aim of developing the KPIA and Gebeng Industrial Park (GIP) into a petrochemical hub with associated downstream industries. Industrial development will generate income through exports and increase taxation for the State. In addition the biodiesel plant will increase employment opportunities and boost the local economy.

(g) Development of Kuantan Port as a Biofuel Hub: The Kuantan Port Authority

(KPA) is pushing for a RM40 million Biodiesel Park in the KPIA. The Project is in support of the KPA’s goals by planning to set up a biodiesel plant in the Biodiesel Park. This will enhance the economic viability of the Park and promote the production of biodiesel for the State and Country.

(h) Increasing Awareness of Environmental Protection: Increasing awareness of

environmental protection has led to efforts in the adoption of an environmental friendly alternative energy source. Biodiesel is a clean alternative fuel as it does not emit toxins, does not contain sulphur and emits less carbon monoxide (CO). Using biodiesel could reduce environmental pollution between 75% and 90% and provide better engine lubrication compared to petroleum diesel.



(i) Support Palm Oil Pricing and Alternative Uses: The adoption of palm oil for use in producing biodiesel will increase the demand for palm oil and cause a shift upwards in the demand and pricing of the commodity. Once there is a change in the demand profile, it is expected that the CPO pricing will ultimately stabilise at a level that will be beneficial to the oil palm growers. Stabilisation of palm oil prices could translate into higher export revenues for corporations and the Government; the latter, in the form of increased corporate taxes.

6.0 STUDY OBJECTIVES The specific objectives of the Study are: (a) To identify and describe the physical and marine environment, climate, air, noise

and water quality, flora and fauna, landuse, traffic, infrastructures and utilities as well as the socio-economic profile of the Project site and its surrounding areas;

(b) To identify and assess all impacts, both negative and beneficial, that the Project will have on the physical, biological and the social, cultural and economic life in the impact area;

(c) To recommend mitigation measures that will minimise or offsetting possible environmental impacts with recommendations of options to abate the impacts;

(d) To predict the potential significant residual impacts and plan for monitoring and surveillance for the changed environment; and

(e) To recommend the formulation of an Environmental Monitoring and Audit Requirements (EMAR) for the management of the identified adverse environmental impacts and concerns during the construction and operational phases of the Project.

7.0 PROJECT DESCRIPTION The biodiesel plant will be established to produce 200,000 MT of biodiesel per annum initially, with options to expand to 400,000 MT. The feedstock used will either be CPO or RBDPO or both. The biodiesel plant will produce methyl esters (FAME) as its main product and pharmaceutical grade glycerine as a secondary product to meet European EN 14214/ASTM D 6751 Standard as well as the European Pharmakopoe 99.5 Standard. The set of processes installed at the biodiesel plant includes the following: (a) Degumming, bleaching and deacidification of CPO; (b) Trans-esterification and methyl ester drying and recovery of methanol; (c) Glycerine water pre-treatment; (d) Glycerine water evaporation; and (e) Glycerine distillation and bleaching. Other raw materials that will be used in the various processes include bleaching earth, phosphoric acid, methanol, sodium methylate (30% methanol), hydrochloric acid, sodium hydroxide, nitrogen, activated carbon and fuel. The finished products from the biodiesel plant will yield methyl ester (FAME), glycerine I (Pharmaceutical grade), glycerine II (Industrial grade) and fatty acids with a total of 697.8 MT per day.



The biodiesel plant is designed to recycle and reuse the input materials as much as feasible to minimise waste generation. None of the wastes produced are classified as scheduled wastes according to the Environmental Quality Act 1974, Environmental Quality (Scheduled Wastes) Regulations 2005. The main waste generated will be wastewater which will be treated to Standard B of the Environmental Quality (Sewage and Industrial Effluents) Regulation 1979 before being safely discharged to the drainage networks in the KPIA. A total of 12.2 MT/day of waste will be generated excluding wastewater.

8.0 PROJECT IMPLEMENTATION SCHEDULE The timeframe of the Project is approximately 14 months and is expected to be completed and ready for operation by the end of September 2008.

9.0 PROJECT OPTION The choice to locate the Project in the State of Pahang is obvious as Pahang is currently the largest CPO producer in Peninsular Malaysia. Apart from the above considerations, the decision to locate the biodiesel plant in KPIA also takes into account of the land compatibility of the Project site, environmental consideration on the surrounding area, socio-economic benefits and viability of the process technology that will be used.

10.0 EXISTNG ENVIRONMENT

Parameters Description

Physical and Land Resources

Topography The terrain is flat as the Project site is sited on reclaimed land. The South China sea forms the eastern border. On the western side is the KPIA and further away are two small hillocks that have been partially quarried. These are Bukit Pengorak and Bukit Tg Gelang.

Geology As the Project is on reclaimed land, the lithology has been altered by the fill materials.

Soils Borehole test results showed the ground composing of layers of sand, clay and silt. The surrounding areas of the Project site are of Rudua-Rusila, Tanah Bandar and Tanah Gambut soil series.

Coastal Morphology

The original coastline has been changed into an artificial coastal landform as the Kuantan Port expanded. The present coastline is now embanked with a rock armour revetment. South of the Project site there is a small deep sea fishing wharf and the Kuantan Port Lagoon.

Tides Based on Tides Table (2006) Tg Gelang Standard Port:

Highest Astronomical Tide (HAT) 3.83 m

Mean Higher High Water (MHHW) 3.35 m

Mean Sea Level 1.94 m

Coastal Current Current directions have been observed to follow closely with the monsoons:

November – March Northeast Monsoon, southerly monsoon current.

May – September Southwest Monsoon, northerly monsoon current.




Waves Wave height at the Project site was observed to be 0.1 – 0.3 m, with a wave period of 5 seconds. Wave height reached 4.0 m or more during the Northeast Monsoon.

Climate Warm and humid tropical with heavy seasonal monsoonal rains.

Climate Data (2001 – 2005):

Highest rainfall (2003) 3,793.7 mm

Lowest rainfall (2002) 2,500.6 mm

Annual 24 hr mean temperature: 26.5°C – 27.2°C

Monthly 24 hr mean temperature: 25.4°C – 28.0°C

Annual 24 hr mean relative humidity: 82% – 85%

Monthly 24 hr mean relative humidity: 81% – 89%

Hydrology The Project site is located at the northeast section of the Sg Pengorak basin. Sg Pengorak and other small rivers from Bukit Pengorak have been joined through a system of drainage channels along the Kuantan Pelabuhan By-pass to form 2 outer drainage channels of the Kuantan Port area. A system of internal drains in KPIA then joins the 2 main channels. The Project site and KPIA are not subject to flooding due to proper drainage.

Water Quality The results of the marine water sampling (SW1 to SW3) complied with the parameters of IMWQS except for Oil & Grease at SW2 which was 4.6 mg/L. The seawater samples were observed to be clear of any floating debris. Levels of TSS and E. Coli exceeded the IMWQS limit at WQ2 which was 74 mg/L and 5,000 MPN/100 mL, respectively, whilst E. Coli levels at WQ1 was 9,000 MPN/100 mL.

Air Quality Results from both AQM1 and AQM2 showed that the air quality complied with the Recommended Malaysian Air Quality Guidelines.

Noise Levels Noise levels recorded at all four measurement points were between 42.9 – 54.2 dB(A), which complied with the Planning Guidelines for Environmental Noise Limits and Control.

Biological Resources

Terrestrial Flora The Project site is cleared of vegetation. The eastern boundary of the Project site consists of a vegetated earth bund with grass cover and casuarinas. The Project site is populated by primary colonisers and natural regrowth.

Terrestrial Fauna The existing fauna is low because the original habitat has been disturbed. The population consists of small mammals, reptiles and bird species.

Aquatic and Marine Phytoplankton and zooplankton were moderately abundant. A moderate abundance of macrobenthos was found. 10 types of fish were caught along the coast of KPIA (South China Sea), during the study period.

Landuse

Existing Landuse The existing KPIA (Lot 1863) is categorised as an industrial area where the predominant landuses are manufacturing and storage facilities. Phase 2A (Lot 9916) and Phase 2B (Lot 10937) on reclaimed land in KPIA formed the Biofuel Park. A deep sea fishing jetty (Lot 4676), owned by PKNP is located southeast of the Project site separating Phase 2A and Phase 2B.

Socio-economic Survey

Residents Kg Selamat is the only village within a 1-km radius of the Project site. Approximately 300 people reside in this village.




Workers Approximately 2,000 people work in the KPIA with 400 people working for the KPA and KPC. These workers mainly live in Kg Selamat, Kg Sg Ular and Baluk.

Infrastructures and Utilities

Water Supply Water supply is tapped from the JBA pipeline at the main road leading to Kuantan Port. An estimated 15 m3 per day of potable water is required. A total of 104,255 m3 of recycled water is required per day for biodiesel plant operations.

Electricity The electricity supply to Kuantan District is obtained from 7 main intake stations. The Project will obtain electricity from the Tg Gelang station. The Project requires 550 kW/hr.

Sewerage System There is no centralised sewage treatment system in KPIA. The Project will use a septic tank built for 30 P.E.

Solid Waste Management

Municipal solid waste will be send to the landfill at KM-1 Jalan Jabor-Jerangau.

Telecommunication There are 17 telephone stations with 105,936 lines in Kuantan District.

Road Network The Project site is connected to the East Coast Expressway (ECE), Federal Routes 2 and 3 (FR2 and FR3) and the Kuantan Pelabuhan By-pass.

Port Facilities Facilities available at Kuantan Port include berth facilities, common pipe-rack network, shore equipment, storage areas, tank farms, and tug boat services.

Traffic 12 traffic volume counting stations were established at the two entrance points of KPIA. The traffic composition, in descending order, are cars, motorcycles, lorries/ tankers, private van/ small lories and buses.

11.0 ENVIRONMENTAL IMPACT ASESSMENT

This EIA has carried out an assessment of all the major potential adverse and beneficial impacts and examined against the environmental baseline (Chapter 7), with the results discussed in Chapter 8. The parameters include hydrology, drainage, water quality, physical environment, physical marine environment, socio-economics, landuse, noise, traffic, air quality, and biological resources. The main potential adverse impacts during the construction phase are silt and turbidity due to soil erosion, increased traffic, and increased air and noise pollution. During the operational phase, the main potential impacts could be from air and noise pollution, and risk to occupational safety and health.

In terms of beneficial impacts, the local communities within the area and in Kuantan town will benefit from the Project through improved employment opportunities both during the construction and operational phases.

12.0 RESIDUAL IMPACT

The main residual impacts are permanent landuse change, noise, and an increase of traffic in the area.


PEIA FOMUKIM SG

R THE PROPOSED BIODIESEL PLANT IN EXECUTIVE SUMMARY KARANG, KUANTAN, PAHANG DARUL MAKMUR


13.0 ENVIRONMENTAL MONITORING AND AUDIT REQUIREMENTS

Under the Environmental Management Plan, an environmental monitoring and audit programme has been proposed for the Project as shown in Table ES 13.1.

Table ES 13.1: Proposed Audit Programme

Environmental Impacts

Method of Monitoring

Frequency of Test Inspection

Period of Sampling Action/Report

Water quality Composite samples

From monthly samples

Construction and operational phases

Samples to be analysed by an accredited laboratory.

Air quality measuring meter

From quarterly samples


Indication of exceedance. Number of complaints. Air quality

Visual inspections Quarterly Construction and

operational phases

Number of complaints from the public.

Noise Noise level measuring meter

From quarterly samples


Indication of exceedance.

Solid waste disposal

Mode of handling and disposal Monthly Construction and

operational phases Any indication of violations.

14.0 EMERGENCY RESPONSE PLAN (ERP)

An Emergency Response Plan (ERP) is provided in Chapter 12 and should be used as a guide to formalise a system, identify responsibilities and provide the necessary training to persons in cases of emergencies.

15.0 PROJECT ABANDONMENT AND CLOSURE PLAN Chapter 13 provides the Project Abandonment and Closure Plan, which has procedures and actions that can be taken if the Project is abandoned partially completed due to unforeseen circumstances or after completion of the Project, when the DOE needs to be informed of its closure of its construction works.

16.0 CONCLUSION

In conclusion, there are both positive and negative impacts associated with this Project but the gains achieved through the implementation of this development would outweigh the losses. Table ES 16.1 provides a summary of the potential impacts, mitigation measures and residual impacts according to Project activities.


Table ES 16.1: Summary of Potential Significant Impacts by Activities and Proposed Mitigation Measures

Activities Consequences to Environment

Adverse Environmental Impacts Mitigations Measures Residual Impacts

CONSTRUCTION PHASE

• Site preparation • Earthworks and filling • Stockpiling and

compaction

• Denuded landscape • Altered soil profile

• Soil erosion • Water quality degradation • Increased runoff

• Maintain the earth bund and construct temporary earth drains

• Exposed areas to be covered as soon as possible through compacting, turfing or artificial covers

• Limit the working area • Maintain buffer strips • Fence up appropriate locations

susceptible to safety hazards • Frequent site inspections • Landscape and revegetate exposed areas

• Job opportunities • Reduced water quality • Permanent landuse

change

• Drainage alteration and realignment

• Altered landscape • Altered surface

hydrology affecting aquatic organisms

• Soil erosion • Water quality degradation

• Design drainage system with silt traps

• Reduced water quality

• Transportation of equipment and construction materials

• Noise • Fugitive dust • Increase of heavy

vehicles in the vicinity of the site

• Air quality deterioration • Noise pollution

• Maintain the existing haulage road • Vehicles transporting earth should be

covered with tarpaulin to reduce wind blown dust

• Wheel wash trough for vehicles exiting the site

• Clean and sweep away mud and dirt that are carried onto the public roads

• Regular service of vehicles to reduce exhaust emission

• Reduce dust by regularly spraying water to wet the dusty surfaces

• Increased risk of traffic accidents





• Vehicles must comply with Environmental Quality (Motor Vehicle Noise) Regulations 1987

• Storage of materials • Dust and particulate emission

• Poorly designed and managed storage area and equipment may result in accidental spillages and leakages

• Water pollution from oil, grease or chemical spills

• Fuel storage to be installed with physical barrier e.g. bunding, capable of containing any potential spills

• A spill kit should be kept within the Project site to contain and absorb any accidental spills

• Minor

• Setting up of base camp

• Construction of temporary site office, storage facilities and working areas

• Dust and particulate emission

• Municipal waste and sewage generated

• Oil, grease and hydraulic fluid produced

• Air pollution • Noise pollution • Reduced water quality

due to oil, grease and hydraulic fluid spills

• Proper collection of garbage at the base camp

• Prohibit open burning • Regular checks on temporary sanitary

toilets in the area • Standard safety measures and regulations

to be enforced to safeguard public health and safety

• Include training course and medical check-up for workers

• Maintenance of all equipment to ensure reliability

• Minor

• Construction of building structures

• Construction of utilities and amenities

• Oil, grease and hydraulic fluid used

• Minor erosion • Dust and particulate

emission • Increased vehicular

movement through the Project site

• Reduced water quality due to oil, grease and hydraulic fluid spills

• Air pollution • Noise pollution

• Construction of silt traps if necessary • Regularly spraying water to wet the dusty

road surface • Landscaping • Avoid executing construction work during

rainy seasons and monsoon periods • A spill kit should be kept within the Project

site to contain and absorb any accidental spills

• Minor air pollution





• Solid waste disposal • Sewage treatment

and disposal

• Public health problems • Water pollution

• Disease vector proliferation, sanitary problem

• Public health and sanitary problem from improper disposal

• Contamination of receiving waters if not properly treated

• Provide adequate and regular solid waste collection and disposal

• Dispose appropriately and regularly to municipal waste facility

• Adequate sanitary facilities away from drainage streams

• Install drainage, sediment silt traps and oil interceptors

• Dispose lubricating/fuel oils to secure landfill site

None

• Transport of large structure and plant equipment

• Noise • Fugitive dust • Increase of heavy

vehicles in the vicinity of the site

• Dust, exhaust emissions • Increased traffic in the

vicinity of the Project site • Accident risks

• Control speed of vehicles • Regular service of vehicles to reduce

exhaust emission • Alternative traffic routes, transport large

structures by night


• Plant construction, installation and commissioning

• Oil, grease and hydraulic fluid produced

• Oil and hydraulic spills • Control preparation and installation areas None

• Recruitment of labour

• Immigrant workers • Sewage • Temporary base camp

• Cultural abrasion between immigrant workers and the local community

• Increased traffic in the vicinity of the Project site

• Proper collection of garbage should be instituted at the base camp

• Prohibit open burning • Checks on any temporary sanitary toilets

in the area • Standard safety measures and regulations

to be enforced to safeguard public health and safety

• Include training courses and medical check-up for workers

• Job opportunities for the local community





• Final furnishing • Landscaping and

revegetation

• Dust and particulate emission

• Altered landscape

• Minimal adverse environmental impacts

• Reduce dust by regularly spraying water to wet the dusty surfaces

None

OPERATIONAL PHASE

Transport of raw and processed materials to/from Project site

• Chemicals, oil, grease and hydraulic fluid produced

• Increase in risk

• Leakage and spills from transport vehicles

• Risks of fire explosion, toxic gas clouds

• Traffic risks

• Vehicle and tank design and labelling • Use of Material Safety Data Sheets

(MSDS) • Emergency response plan/ equipment and

facilities • Training of drivers and emergency

response personnel • Avoidance of densely populated areas • Impose traffic control measures


• Dust generation

• Generation of noise during processing

• Generation of fugitive dust during transport

• Increase of heavy vehicles in the vicinity of the Project site

• Noise pollution • Increased traffic in the

vicinity of the Project site • Pedestrian hazards

aggravated by heavy trucks transporting raw materials and products to/from facility

• Restrict delivery times to outside peak hours

• Use alternative routes

None

Storage and handling of raw materials and products

• In case of leakages, there could be spills of raw materials and chemicals at the Project site

• Contamination of Project site and storage area in case of leakages

• Leaks from containing vessels and soil/groundwater contamination

• Fire and explosion hazards/ toxic hazards

• Construct interceptors and hold-up tanks • Methanol, acids and alkalis to be stored

separately from oxidisers • Absorbent pads, booms and saw dust

should be easily accessible on-site • Immediate clean-up operations to be

activated based on the Emergency Response Plan

• Spillage and reduced water quality





Manufacturing processes where the wastewater is discharged and treated in the wastewater treatment Plant located within the Project site (See Figure 4.2.1)

• Discharge to the wastewater treatment Plant will be treated on-site.

• The effluent consists of cooling water blow-down and flushing and cleaning waters, which are high in suspended solids, oil and grease

• Accidental release of potentially hazardous solvents, acidic and alkaline materials

• Heated liquid discharges can have an impact on marine and aquatic life

• The wastewater treatment plant will provide adequate and appropriate treatment facilities for different types of wastewater received to meet the Standard B of Environmental Quality (Sewage and Industrial Effluents) Regulations 1979

• A comprehensive system of wastewater and ambient water monitoring has been proposed in the Monitoring and Audit Programme

• Reduced water quality

Final disposal of process liquid wastes

• Risk from leaks and spills during transportation to final disposal site

• Leaks and spills causing water pollution and health implications

• Vehicle and tank design and labelling • Use of Material Safety Data Sheets

(MSDS) • Detailed emergency response plan/

equipment and facilities • Training of drivers and emergency

response personnel • Avoidance of densely populated areas

• Spillage and reduces water quality

• Possible particulate matter generated during plant operations

• Gaseous compounds (SOx, NOx, CO, etc.) from boilers, process furnaces

Gaseous emission

• Generation of gaseous pollutants

• Fugitive vapours • Health implications for

workers and nearby residents

• Provide adequate and appropriate air pollution control systems

• Implement air quality monitoring programme

Minor





Solid waste management and waste from the WWTP

• Generation of solid wastes

• After wastewater treatment, there is a small quantity of sludge, which will be collected by the licensed contractor for recycling and treatment

• Garbage from the Project site will be collected by the municipal authorities and dumped at the landfill site

• Provide adequate solid waste storage area

• Provide containment for leaks and spills such as double walled tanks, diking or concrete walls, and tank leak detection systems

• Unusable solid residue to be stored securely on-site prior to final disposal

• Spillage and reduced water quality

Solid waste generated from the process system that contains fatty matter, filter cake and spent activated carbon

• These are not hazardous and can be recycled easily

• These are not hazardous and can be recycled easily

• However, the storage of these end products at the Project site may generate some odours

• Fatty matter and spent activated carbon can be sold to the recycling traders and/or approved waste handlers

• The filter cakes will be sold to the animal feed manufacturers

• Incorporate on-going training in plant health and safety and good housekeeping practices

• Emergency procedures, regular drills and action plan in case of a major spills or fire

• Odour

Noise generation from biodiesel plant equipment

• Noise generation from plant facilities/ equipment

• Typical noise levels range from 60 to 110 dB(A) at a distance of 1 m from the source

• Occupational health implications

• Incorporate noise attenuation measures in the design of equipment and plant

• Provide adequate noise attenuation facilities for workers such as ear mufflers

None


Biodiesel Plant EIA Summary

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