Strategies and procedures

The HSSE Management System states that the environmental risks associated with a project’s operational life cycle should be appropriately managed.

The environmental aspects covered in the HSSE Management System include:

• Environmental impact assessments

• Environmental monitoring

• Environmental Management System (EMS) development

• Environmental due diligence

• Data management systems.

As part of CLP’s Pre-investment Environmental Risk Assessment, an Environmental Due Diligence (EDD) is conducted at the project planning stage, followed by a more detailed Environmental Impact Assessment (EIA) if needed. During the EIA, key environmental impacts such as air quality and biodiversity assessments are conducted where applicable.

CLP takes great care in conducting all EIAs and is committed to fulfilling the requirements and recommendations stipulated in EIA reports and local regulations. Processes are in place to ensure the EIA recommendations are implemented. Planning procedures extend beyond compliance in countries where regulations are not as stringent. For instance, CLP mandates an EIA for all major generation projects in India, even though it is not a statutory requirement for renewable energy projects in the country.

CLP is currently refreshing its HSSE Management System, including the EMS contained within it. This is used as a management tool to identify and manage significant environmental risks arising from operations. The refresh will deliver specific environmental operational controls designed to provide a systematic approach to continually improving the environmental performance of assets. During the transition to the refreshed HSSE Managment System, certain environmental standards and guidelines from the existing EMS will continue to support daily operations.

Under its HSSE Management System, CLP requires power generation assets, of which it has operational control, to achieve third-party certification to the international standard, ISO 14001 environmental management systems, within two years from commencement of operation or acquisition. In 2020, all assets in this category have successfully certified their environmental management system to the ISO 14001: 2015 standard.

Monitoring and follow-up

CLP recognises that the development of goals and targets can help monitor progress in using environmental resources efficiently. Since 2019, the Group started to develop environmental targets for key environmental performance indicators.

CLP has also developed an environmental monitoring process to be applied at project level. It specifies how environmental conditions should be assessed and assists with the design and implementation of suitable measures.

It is fundamental that CLP fully complies with applicable environmental laws and regulations in the jurisdictions in which it operates. Established processes are in place to review relevant environmental requirements for new investments.

If an incident occurs at an asset under CLP’s operational control, it is classified and recorded in a timely manner in accordance with the relevant internal process. Incidents managed through this process include notifications of any fines or prosecution from local authorities.

A table outlining the Company's environmental regulatory performance is featured below.

Environmental regulatory non-compliance and licence exceedances

In 2020, Jhajjar Power Station in India continued to implement enhanced control and monitoring processes to improve its emission performance, resulting in a reduction in the number of licence exceedances. There was one minor licence limit exceedance for nitrogen oxides (NO_x) at the plant in 2020 which did not result in any action by the local authorities. Jhajjar has successfully achieved 100% utilisation of the ash generated as well as the ash stored in the ash dyke up to December 31, 2020 and was compliant with the authority’s ash utilisation requirements on thermal power plants in this regard. 

At EnergyAustralia, a total of three environmental licence non-compliances were reported. There was a minor chemical spillage incident at Newport Power Station involving ferrous sulphate, and a minor brine waste leakage incident at Mount Piper. Environmental agencies were notified of the two incidents, and no fines or penalties were imposed. At Mount Piper, there was also an administrative breach with the water quality monitoring requirements under the new licence. Corrective action has been taken to prevent a repeat of these incidents.

Environmental regulatory requirements are becoming more stringent in many locations. CLP is monitoring these developments closely. A summary of the key upcoming environmental regulations that could affect business units are listed below. Emerging policy changes related to greenhouse gas (GHG) emissions can be found here.

For Mainland China, no key emerging environmental regulation updates that are considered relevant have been identified.

Key emerging environmental regulations

Strategies and procedures

CLP’s Power Plant Air Emissions Standard stipulates that any fossil fuel-based power plant developed after the effective date of the Standard is required to operate within CLP’s prescribed limits on sulphur dioxide (SO₂), nitrogen oxides (NO_X) and total particulate matter (total PM), or they must fully comply with local regulations, whichever is more stringent.

In addition to incorporating state-of-the-art air emissions mitigation measures into plant management processes, CLP also designs new gas-fired power stations with advanced generation technologies. These new technologies more efficiently produce electricity, and assist in further lowering emissions and greenhouse gases.

Monitoring and follow-up

The Company continuously monitors air emissions (SO₂/NO_x /total PM) from facilities under its operational control using a continuous emissions monitoring system and/or stack sampling and mass-balance calculation methodologies. CLP also regularly monitors mercury emission using stack sampling in accordance with local regulations.

CLP has implemented different types of emission control measures in its thermal plants which are now a part of normal operations. Since 1990 electricity demand in CLP Power's service area in Hong Kong has grown by over 80%, but the Company has achieved more than 90% emissions reduction in SO₂, NO_x and RSP during the same period. Air emissions have fallen as a result of various emission reduction efforts. In the Group's other assets, the emission control equipment for SO₂ and NO_x in Fangchenggang Power Station, and the installation of flue gas desulphurisation (FGD) units in Jhajjar Power Station, which were fully implemented in 2019, achieved a 90% reduction in SO₂ since 2017.

In the year, Hallett Power Station in Australia completed the installation of a new fast-start gas-fired generator of 30MW. It was commissioned in April 2020. The new gas generator uses less fuel as compared with other generators on site. This will improve the overall generation efficiency of the plant, and also improve its emission performance of NO_x and CO₂.

In Hong Kong, the new 550MW gas-fired generation unit at Black Point Power Station and another one of similar capacity planned for commissioning by 2023 will further reduce emissions. CLP Power is also aware of the high global warming potential of sulphur hexafluoride (SF₆), an insulating gas commonly used in switchgears and transmission lines, and is vigilant in the control of SF₆ leakage throughout the life cycle of electrical equipment. It has explored non-SF₆ gas equipment in the market and trialled 11kV non-SF₆ gas switchgears.

Strategies and procedures

CLP endeavours to reduce both the hazardous and non-hazardous waste it produces, and works with qualified parties and partners to reuse or recycle whenever possible. All wastes are managed according to the waste management hierarchy (i.e. prevent, reduce, reuse, recycle, replace, treat and dispose). CLP seeks to avoid the use of hazardous materials and replace them with alternatives wherever possible. All hazardous and non-hazardous wastes are managed in accordance with local regulations, collected by licensed collectors, or sold for recycling.

At CLP’s coal-fired power stations, coal ash from coal combustion and gypsum from the flue gas desulphurisation process constitutes the majority of generation by-products. The aim is to use them as a resource for construction and other applications in line with local regulations and practices rather than disposal.

Monitoring and follow-up

CLP monitors its waste generation monthly by tracking solid and liquid forms of hazardous and non-hazardous waste produced and recycled at its facilities.

Generation of hazardous solid waste increased while hazardous liquid waste decreased in 2020, resulting from different plant maintenance activities across the Group. CLP continued to sell its generation by-products such as ash and gypsum for use in other industries where feasible.

The Group’s power stations run different programmes to manage waste, and learnings are shared with both colleagues and contractors to raise awareness and build capacity. Key programmes in 2020 include:

• Jhajjar Power Station: Despite a country-wide lockdown, CLP India was able to achieve a 100% utilisation rate of ash generated in 2020. Apart from its enhanced ash handling systems, Jhajjar ensured that reuse and recycling contracts were in place with cement manufacturers, construction industries and various traders. CLP India also actively pursued opportunities such as using ash for brick manufacturing, as well as road and bridge construction projects.

• Jinchang Solar Power Station: CLP China continued to utilise the initiative from solar panel manufacturers to take back any damaged panels for recycling. The aluminium frames which account for a large part of the waste are reused, and other components such as silicon and silver embedded in the panels are recovered. Since 2017, over 2,000 solar panels have been returned for recycling.

• Fangchenggang Power Station: CLP continued its trial of using white mud, a by-product generated by a paper mill factory, to partially replace the use of limestone in the plant’s flue gas desulphurisation process. In 2020, around 1,150 tonnes of white mud were used, reducing the use of limestone and recycling solid waste produced from the local paper mill.

• CLP Power Hong Kong: CLP actively encouraged employees to reduce their use of single-use plastics for take-away meals and home deliveries during the outbreak of COVID-19. Furthermore, an electronic meal ticket system was rolled out in the canteens of Castle Peak Power Station and Black Point Power Station. The electronic system replaces the issue of 260,000 paper tickets a year.

Strategies and procedures

The quantity of water withdrawal and discharge in CLP’s operations is dominated by thermal plants using once-through seawater cooling. In this process, large quantities of seawater are used for cooling and returned to the sea with only a slight increase in water temperature. The total volume of water withdrawal and discharge is dependent on the total electricity generated.

Where freshwater is withdrawn for operations, CLP strives to reduce water use and reduce the freshwater intensity of the electricity generated. CLP’s power stations carry out a range of water conservation initiatives depending on site conditions, operational situations and age. The amount of water which can be recycled depends on factors such as location, power station design, and regulatory requirements.

Monitoring and follow-up

The Company assesses water availability in the planning stage of projects including the likelihood of water scarcity in the future and during plant operations. It is important to ensure water availability in power stations to ensure operations will not be disrupted. However, engaging with and understanding the needs of local stakeholders is also prioritised to ensure the licence to operate is maintained. As a result of the water treatment processes put in place, none of CLP’s operations significantly impact their respective water receiving bodies.

Water quality impact assessments are also carried out at the planning stage of development projects, in accordance with local requirements. This is to ensure that any impacts associated with project construction and plant operation are managed and mitigated to an acceptable level.

In-depth assessments on water risk in the generation portfolio are conducted regularly by using globally recognised tools such as the World Resources Institute (WRI) Aqueduct. The assessment covers parameters such as water availability, water sensitivity, water stress mapping, potential competing use with other stakeholders, and the management strategies in place in each of the regions. The results of the most recent assessment confirmed that CLP has a sufficiently robust regime in place for managing water risks.

CLP also participates in the CDP Water Survey to disclose and benchmark its practices with industry peers in relation to water resource management. The Company is committed to continuing its monitoring of water use and to manage this precious resource carefully.

CLP encourages its power stations to track their total water recycling and report this for indicative purposes. Considerable emphasis is placed on sharing initiatives across the Group to maximise the benefit of an individual power station’s efforts.

Three of the Group’s thermal power stations, Mount Piper, Jhajjar and Fangchenggang operate on a zero liquid discharge basis. The water is treated internally and recycled or reused in other parts of the power generation process, or for dust control or horticulture.

• In 2020, Mount Piper Power Station in Australia completed a water conservation project which reuses treated wastewater from the nearby Springvale Mine to provide the power station with water for cooling. This has resulted in significant reduction in water use compared to previous years.

• The Jhajjar Power Station in India is designed with a water re-circulation process and although it uses river water, it has zero liquid discharge, and requires smaller quanitity of water to be topped up, only to make up for evaporation loss.

• In Mainland China, the Fangchenggang Power Station continued to implement further water-saving initiatives through reusing its treated wastewater (up to 76% of total wastewater volume) for flue gas desulphurisation, dust suppression and irrigation for greening within the power station. Each day, about 1,300 m³ freshwater is being saved.

Different water reduction or conservation initiatives continue to be put in place. Implementation of robotic cleaning of solar panels expanded in Sihong Solar Farm and to Huai’an Solar Farm, both in Mainland China. The Jiangbian Hydro Power Station completed modification of its wastewater treatment facilities which reuse treated domestic wastewater for irrigation at the site, making it another zero liquid discharge site. This initiative will save 20,000 m³ of freshwater annually.

In Australia, a joint initiative between the Yallourn Power Station and Mine allowed 540,000 m³ of mine wastewater to be recycled through the power station’s cooling tower system in 2020. This directly reduces the volume of clean river water required for cooling tower operation.

Goals and targets

The Group’s goal is "no net loss of biodiversity". Targets are site-specific depending on the different levels of regulatory controls on biodiversity, from assessment requirements to ecological compensation. For example, in Australia, Yallourn Mine strives for a net gain in biodiversity by offsetting disturbed areas and improving the habitat quality outside the mine perimeter in accordance with the relevant local regulatory requirements.

Strategies and procedures

In addition to implementing an internal Environmental Impact Assessment (EIA) standard that mandates an environmental assessment for all new projects, CLP's Biodiversity Impact Assessment Guideline provides a framework for a more systemic assessment of biodiversity impacts. The guideline, under the HSSE Management System, applies to power generation, transmission and distribution, mines and other power-related projects.

During the EIA stage, CLP partners with qualified personnel to conduct a biodiversity impact assessment in accordance with the CLP Biodiversity Impact Assessment Guideline. The guideline provides guidance on managing biodiversity risks where appropriate, and considers the IUCN Red List of Threatened Species and national conservation lists of threatened species. Any new operations that could affect the IUCN Red List of Threatened Species and national conservation list species are flagged well ahead of any investment decision. The assessment also describes the baseline conditions, evaluates the magnitude and significance of project impacts, and investigates options for mitigation. If necessary, the assessment contemplates offsets after considering options relating to avoidance, minimisation, and restoration or rehabilitation. The assessment also observes local legislative requirements and references the International Finance Corporation Sustainability Framework.

Biodiversity

Much of the biodiversity work across the Group is continuous. It includes activities such as vegetation management along transmission lines in Hong Kong, the fish management regime in place at the Jiangbian Hydro Power Station in Mainland China, and the tree management work undertaken by the Jhajjar Power Station in India.

In Hong Kong, CLP is developing an IT system, namely the Predictive Vegetation Management System, for its transmission and distribution network. The system supports the monitoring of the growth and condition of trees and vegetation that may affect overhead line operations. A research project is being carried out with the Education University of Hong Kong to develop an algorithm of vegetation growth prediction which will be integrated into the system to further enhance its predictive ability. CLP continues to support the Government’s Strategy of "Right Tree in the Right Place". Any trees identified to be hazardous are replaced by native species to support local biodiversity.

In Mainland China, the Xicun Solar Power Station has successfully integrated the farming of honeysuckle plants, a crop for traditional Chinese medicinal use, in its operation. This initiative transforms the previously deserted sandy area into cultivated farmlands and brings benefits to local farmers. The Huaiji and Dali Yang_er Hydro Power Stations were awarded the “Green Small Hydro” label by the Government. The award recognises their performance in meeting the required evaluation criteria on the protection of the river course and ecological habitats, operation management, improvement of local economy and livelihood.

The Xicun Solar Power Station integrates the farming of honeysuckle plants into its operations.

In India, Jhajjar Power Station continues its annual effort to augment the green belt area on site. In 2020, around 10,000 saplings of native species were planted.

In Australia, the Yallourn Mine continues to implement its Progressive Rehabilitation Plan and a Conservation Management Plan to oversee final rehabilitation. In 2020, the rehabilitation coverage exceeded the mine disturbance footprint by providing a total of 39 hectares of grass and native vegetation habitats.

Land remediation

In Australia, EnergyAustralia's sale negotiations for the Wallerawang Power Station were completed in 2020. As part of those negotiations, the new owners will undertake the safe closure of legacy ash dams and remediation for permanent closure of the power station. Part of the site will be redeveloped into an eco-industrial park. At Jeeralang Power Station and Newport Power Station, detailed site investigations of per- and polyfluoroalkyl substances (PFAS) in soil and groundwater have been completed, and a remediation action plan has been developed to guide the clean-up strategy to be deployed in 2021. PFAS are man-made chemicals found in many consumer products including firefighting equipment.