7                    WASTE MANAGEMENT IMPLICATIONS

 

7.1.1          This Section identifies the wastes arising from the demolition of the Existing Crematorium as well as the construction and operation of the New Crematorium at Diamond Hill and assesses the potential environmental impacts associated with the handling and disposal of waste.  Where appropriate, procedures for waste reduction and management are considered and environmental control measures for avoiding and minimizing the potential impacts are recommended. 

 

7.2              Assessment Methodology

 

7.2.1          The potential environmental impacts associated with the handling and disposal of waste arising from this Project have been assessed in accordance with the criteria given in Annexes 7 and 15 of the EIAO TM, and are summarized as follows:

 

·             Estimation of the types and quantities of the waste generated and identification of the disposal options for each type of waste

·             Assessment of secondary environmental impacts due to the management of waste with respect to potential hazards, air and odour emissions, transportation and wastewater discharges

·             Assessment of the potential impacts on the capacity of waste collection, transfer and disposal facilities

 

7.3              Identification of Potential Environmental Impacts During Construction and Demolition Phase

 

7.3.1          Based on the tentative construction and demolition programme, the construction and demolition activities will be divided into two phases: Phase I – from September 2004 to February 2006 and Phase II –from October 2006 to November 2007.  To handle the cremation demand, operation of the Existing Crematorium will be maintained until full operation of the new cremators and other main facilities to be provided under Phase I of the Project.  Facilities to be constructed / demolished under each phase are given below:

 

Phase I

Ÿ               Demolition of facilities in Existing Crematorium in the southern side of the Project site, including

Ÿ                 Existing sitting out area

Ÿ                 Garden of remembrance

Ÿ                 Existing building structure, including CLP secondary substation, toilets, pavilion and retaining walls

 

·             Construction of the New Crematorium main facilities, including:

Ÿ                 One (1) cremator plant room housing six (6) cremators

Ÿ                 Three (3) fuel tanks (with total capacity of 34,000 L)

Ÿ                 Two (2) service halls

Ÿ                 One (1) pulverizing room

Ÿ                 One (1) mortuary

Ÿ                 One (1) office

Ÿ                 Toilets for public

Ÿ                 Ancillary service rooms including battery fork lift, transformer and switch room, emergency generator room and joss burners

Ÿ                 Two (2) automatic transportation systems for coffins and part of an underground service tunnel for coffin circulation

Ÿ                 Vehicular loading bay for coffin van and coach

Ÿ                 Landscape area

Ÿ                 Dangerous goods store

Ÿ                 Installation of temporary CLP electricity transformer at Phase II boundary

 

 

Phase II

·             Demolition of the Existing Crematorium main facilities, including:

Ÿ                 Two (2) service halls

Ÿ                 One (1) cremation room with six (6) cremators

Ÿ                 One (1) transformer room

Ÿ                 One (1) underground oil fuel storage tank (9,092 L)

Ÿ                 One (1) mortuary

Ÿ                 One (1) machine room

Ÿ                 One (1) general store plus water tank

Ÿ                 One (1) dangerous goods store

Ÿ                 One (1) chimney (approximately 10 m in height)

 

·             Construction of the rest of the New Crematorium, including:

Ÿ                 Two (2) service halls

Ÿ                 Two (2) automatic transportation systems for coffins and part of an underground service tunnel for coffin circulation

Ÿ                 Vehicular loading bay for coffin van and coach

Ÿ                 Landscape area

 

7.3.2          The columbarium next to the Project site will remain untouched.

 

7.3.3          Activities conducted during Phase I and Phase II will result in generation of the following types of waste:

 

·             Excavated materials

·             Construction and demolition (C&D) materials

·             Contaminated materials (including: ash waste, building structures and soil contaminated by asbestos, dioxin, heavy metals, hydrocarbons or polychlorinated biphenyls (PCB))

·             Chemical waste

·             General refuse

 

7.3.4          No additional environmental impact related to waste management is envisaged during transitional stage between the operation of Existing Crematorium and commissioning of New Crematorium. 

 

7.3.5          If not properly managed, the handling and disposal of these wastes may cause environmental impact and nuisance.  The nature of each type of waste is discussed in Section 7.5 together with an evaluation of the potential environmental impacts associated with these waste types.

 

7.4              Identification of Potential Environmental Impacts During Operation Phase

 

7.4.1          During operation phase of the New Crematorium, the following key types of waste are expected:

 

·             Ash and non-combustible residues generated from cremators during combustion

·             Chemical waste generated from the air pollution control system, machinery maintenance and servicing

·             General refuse generated by visitors and staff during daily operation

 

7.4.2          Since the tendering process for the air pollution control system in the New Crematorium is yet to commence, the exact type and design of the system to be employed can not be confirmed at this stage.  Nevertheless, based on experience of other similar projects, ‘dry’ type air pollution control system will be adopted.  There will, therefore, be no liquid effluent from the air pollution control system.

 

7.4.3          To estimate the likely types and quantities of wastes generated from the ‘dry’ air pollution control system, new cremators with air pollution control system using ‘dry’ process should therefore be referenced.  With this in mind, references have been made to the Fu Shan Crematorium for the purpose of assessing the chemical waste arising from the air pollution control system.

 

7.4.4          Based on the information provided in  the Replacement of Cremators at Fu Shan Crematorium EIA Report (EIA-063/2001), the major types of chemical wastes generated from the air pollution control system of the New Crematorium will include (i) activated carbon and un-reacted lime used for flue gas treatment; and (ii) particulate matter collected from dust removal facilities.  Environmental impacts and nuisance may arise if these wastes are not properly managed.  The relevant quantity estimation and evaluation of potential impacts of the wastes are discussed in Section 7.6.

 

7.5              Prediction and Evaluation of Environmental Impacts for Construction and Demolition Phase

 

Excavated Materials

 

7.5.1          Demolition of the Existing Crematorium and site formation for the New Crematorium will require slope excavation and fill material.  A small amount of excavated material will also be generated during construction of building foundations.  Therefore, the majority of the excavated materials are expected to be generated during the Phase I construction and demolition works (from September 2004 to February 2006).  According to the information provided by Architectural Services Department (Arch SD), approximately 12,300 m3 (10,300 m3 from geotechnical works and 2,000 m3 for foundation works) of excavated materials will be generated during the construction and demolition works. 

 

7.5.2          The fill requirement for site formation is approximately 10,200 m3, according to Arch SD, and provides a good opportunity to utilize the excavated materials generated on-site.  The design of the site formation of this Project should ensure a cut and fill balance as far as practical.  The excavated materials will consist of clean rock and soil, which could be reused on-site.  Approximately 2,100 m3 of surplus excavated materials will be generated from the construction and demolition works and they should be used for landscaping works in the New Crematorium, as far as practicable. in order to minimize the need for any off-site disposal of excavated materials.

 

7.5.3          Therefore, with careful planning for reusing excavated materials on-site, the secondary environmental impacts and potential impacts on waste handling capacity of excavated materials is expected to be minimal.

 

Construction and Demolition Materials

 

7.5.4          Construction and demolition (C&D) materials generated from the construction and demolition works will mainly comprise unwanted materials, including:

 

Ÿ             Existing Crematorium structures (e.g. concrete, steel, glass, bricks, wood, plastics, etc.)

Ÿ             Wood from formwork and falsework

Ÿ             Materials and equipment wrappings

Ÿ             Unusable/surplus concrete/grouting mixes

Ÿ             Damaged construction materials

 

7.5.5          The above C&D materials of the Project will be generated during both Phase I and Phase II periods. 

 

7.5.6          According to the architectural drawings and information provided by Arch SD, the gross floor area (GFA) of the Existing Crematorium and New Crematorium are approximately 1,300 m2 and 2,100 m2 respectively.  Based on the generation rate of 0.1 m3 per 1 m2 of GFA(1), the estimated quantity of C&D materials to be produced from the construction and demolition works will be approximately 340 m3, which may vary depending on the exact types of the buildings and the construction and demolition methods adopted.  A more detailed account of C&D material to be generated will be provided in the Waste Management Plan to be prepared by the contractor.

 

7.5.7          The C&D materials can be divided into two portions: (i) inert portion such as rock and concrete (i.e. public fill), which can be used as fill material for reclamation and earth filling projects; and (ii) non-inert portion such as timber, glass, plastics (i.e. C&D waste), which can be recycled before disposal at landfills.  It is estimated that around 80%(2) of the C&D material generated (i.e. 272 m3) will be categorized as public fill and the remaining 20% (i.e. 68 m3) will be categorized as C&D waste. 

 

7.5.8          The C&D materials can be minimized with careful planning during the detailed design stage as well as during construction and demolition works.  For example, the contractor should use reusable non-timber formwork and temporary works wherever practicable.  In addition, the contractor should, as far as possible, carry out on-site sorting of public fill from C&D materials and reuse public fill in this Project, before disposal at public filling areas.  The C&D waste generated in this Project should also be reused or recycled as much as possible before disposal at landfill. 

 

7.5.9          With reuse of the public fill on-site as well as reuse and recycling of the C&D waste, the surplus public fill and C&D waste requiring disposal is expected to be small and hence the extra loading on public filling areas and landfills will be minimal.  For similar reasons, the potential impacts from transportation of the surplus public fill and C&D waste by road, such as noise impact, possible congestion due to increased traffic flows, and dust and exhaust emissions from haul vehicles, will not be significant.  Provided that waste management practices as detailed in Section 7.7 are properly implemented, the secondary environmental impacts arising from on-site handling of the C&D materials would be minimal.

 

Contaminated Materials

 

7.5.10      Contaminated materials are expected to be mainly generated during demolition of the Existing Crematorium during Phases I and II.  The key types of such contaminated materials will include:

 

·             Asbestos containing materials (ACM) – likely from building structures

·             Dioxin containing materials (DCM) – likely from ash wastes and from contaminated soil

·             Heavy metal containing materials (HMCM) whose heavy metal content(s) exceed the ‘Dutch B’ level as quoted in the Practice Note for Professional Persons (ProPECC) Note PN 3/94, “Contaminated Land Assessment and Remediation” – likely from ash waste and from contaminated soil

·             Hydrocarbons containing materials – polyaromatic hydrocarbons (PAHs) likely from ash waste; PAHs and total petroleum hydrocarbon (diesel range) (TPH) likely from contaminated soil

·             Polychlorinated biphenyls containing materials (PCBCM) – likely from contaminated soil around CLP secondary substation

 

7.5.11      All of the above contaminated materials are classified as chemical waste under the Part A of Schedule 1 under the Waste Disposal (Chemical Waste)(General) Regulation.  Prior to disposal of these types of waste, EPD must be notified.

 

7.5.12      The contaminated materials are expected to be concentrated around cremators /flues /chimney.  The Consultants  have tried to conduct sampling around these areas, however, the cremators and the flange of the chimney could not be accessed because the Existing Crematorium is still in operation and the lowest temperature inside the cremators /flues /chimney is above 200oC, even at 7 am in the morning when the cremators have been shut down since 6 pm in the previous day.  The Consultants have explored several ways to conduct sampling and findings are listed as follows:

 

Ÿ             Sampling during routine maintenance: the Consultants contacted the Electrical and Mechanical Services Department (EMSD) to see if sampling during routine maintenance can be made.  However, information from EMSD indicates that the monthly routine maintenance of cremators does not require shutting down of cremators

Ÿ             Sampling during annual servicing: according to EMSD, the only time when cremators would be turned off is during annual servicing, and the next opportunity is due at the end of 2003

Ÿ             Sampling by shutting down the whole crematorium: according to FEHD, shutting down all the cremators at the Existing Crematorium would severely affect the cremation services in the district (please refer to Section 2.1 for cremation demand in the district).  It is also estimated that a period of at least seven days would be required to cool down the chimney to enable safe entry.  Therefore the interruption of cremation services due to sampling may last from 8 to 10 days

Ÿ             Sampling by shutting down one or two cremators: the Consultants also investigated the possibility of shutting down one or two cremators for sampling purpose.  The cremators have to shut down in pairs and have to cool down for at least three days before any person can enter for sampling (i.e. each pair of cremators have to crease operation for at least 4 days).  Therefore it may affect the cremation services in the district (please see Section 2.1 for cremation demand in the district).  In addition, sampling cannot be conducted for flues/ chimney because the other cremators would still in operation

 

7.5.13      A land contamination site investigation was carried out to assess disposal options for contaminated soil (see Section 6 for details).  However, no soil sample was taken around CLP secondary substation as it is still operational.

 

7.5.14      Based on the above findings, further site investigation after decommissioning of these facilities is recommended.

 

Asbestos Containing Materials (ACM)

 

7.5.15      An Asbestos investigation has been carried out at readily accessible areas by a registered asbestos consultant.  ACM has been found in the following facilities:

 

·             Cremator room (cloth insulation on chimney duct) (Type 2 asbestos materials, according to Code of Practice on the Handling, Transportation and Disposal of Asbestos Waste)

·             Machine room (gaskets on air burners and fan ducts) (Type 2 asbestos materials)

·             Offices of the Existing Crematorium (vinyl floor tile adhesive in offices and waiting rooms) (Type 1 asbestos materials)

 

7.5.16      The overall hazard is considered to be low due to good physical condition of the ACM.  Details of the asbestos assessment are given in the Asbestos Investigation Report attached in Appendix D.     

 

7.5.17      The quantity of ACM will be detailed in the Asbestos Management Plan (AMP), which should be prepared prior to the decommissioning work.    The AMP will also include the Asbestos Abatement Plan (AAP) prepared by a registered asbestos consultant and submitted to EPD for approval under the Air Pollution Control Ordinance (APCO).  The asbestos abatement work shall be carried out by a registered asbestos contractor according to the future AMP.

 

7.5.18      When the handling, storage, transportation and disposal of ACM are in line with the mitigation measures provided in Section 7.7, environmental impacts associated with ACM are expected to be minimal.

 

Dioxin Containing Materials (DCM) / Heavy Metal Containing Materials (HMCM) / Polyaromatic Hydrocarbon Containing Materials (PAHCM) from Demolition of the Existing Crematorium

 

7.5.19      According to the information provided by FEHD, the Existing Crematorium accepted amputated body parts from hospitals from 1994 (around 2,000 kg/year) to 2001 (around 120 kg/year) and this operation ceased in 2002.  DCM / HMCM / PAHCM may be found in ash waste and particulate matter within the cremators, chimney walls, flues and surrounding areas of the Existing Crematorium.  Hence building structures of cremators / flues/ chimney would also likely to be contaminated by DCM / HMCM / PAHCM.  However, it is currently impossible to conduct inspection and sampling within the cremators, chimney and flues to assess the levels of contamination due to the operational constraints mentioned above.  As such, it is recommended that the contractor should collect samples from the aforementioned potential areas of contamination for testing of dioxin, heavy metals (the “Dutch List”) and PAH after decommissioning but prior to the demolition of the Existing Crematorium.

 

7.5.20      There is no criterion in Hong Kong regarding the dioxin level in DCM requiring special disposal.  However, it is proposed to use the USEPA criterion of 1 ppb TEQ (1 ng/g, Toxicity Equivalent Unit) as the assessment criterion, above which special disposal option would be required.  This criterion has been used as the land contamination remediation target for residential sites in the USA.  The criteria used for HMCM / PAHCM are the Dutch “B” levels as quoted in the ProPECC PN3/94.  If the dioxin level of DCM exceeds the 1 ppb TEQ criterion or the levels of  HMCM / PAHCM exceed the Dutch “B” levels, the relevant measures as recommended in Section 7.7 should be implemented.

 

7.5.21    Although it is not possible to analyze the levels of the DCM / HMCM / PAHCM at this stage, reference to demolition projects of similar nature (i.e. ash waste requiring disposal) was made to provide an estimation of the potential level of contamination.  Two documents identified are the Demolition of Kwai Chung Incineration Plant EIA Report and the Project Profile for Decommissioning and Disposal of a Clinical Waste Incinerator at Tang Siu Kin Hospital.

 

7.5.22      The dioxin level in ash waste and quantity requiring remediation in the Kwai Chung Incineration Plant (KCIP) and the Tang Siu Kin Hospital (TSKH) clinical waste incinerator were different, as shown in Table 7.1.

 

Table 7.1   Level and Volume of Contaminated Ash Waste in KCIP and TSKH Clinical Waste Incinerator

 

Project

Parameter Measured and Concentration

Volume Required Special Disposal

Location where Contaminated Ash was Found

KCIP

DCM: 3-22 ppb TEQ

HMCM: not measured

PAHCM: not measured

Approximately 20m3

Near main hall ash bunker wall and main hall floors

TSKH Clinical Waste Incinerator

DCM: <0.1 ppb TEQ

HMCM: Copper exceeded the Dutch “B” List

PAHCM: Naphthalene exceeded the Dutch “B” List

Approximately 0.15m3

Bottom of the furnace

DCM: 7-13 ppb TEQ (samples usually found in the order of 10 ppb TEQ)

HMCM: not measured

PAHCM: not measured

Approximately 0.12 m3

In flues

 

7.5.23      Considering the nature of materials for incineration, the KCIP was used to incinerate municipal solid waste, whereas the TSKH clinical waste incinerator was used to treat waste from laboratories, tissues or organs or other wastes from the operating theatre, dressings with blood and unused drug waste.  As such, it is expected that the dioxin level in the ash waste in the Existing Crematorium would be similar to that in the TSKH clinical waste incinerator (i.e. in the order of 10 ppb TEQ).  In terms of the scale of operation, the Existing Crematorium (with 10 m chimney) is much smaller than the KCIP (with 150 m chimney).  Therefore, it is expected that the amount of ash with DCM / HMCM / PAHCM in the Existing Crematorium, if any, would be much less than that in the KCIP, i.e., much less than 20 m3.

 

7.5.24      It should, however, be noted that the quantity and dioxin level of the ash waste in the Existing Crematorium as mentioned above are only indicative estimates.  The exact volume of contaminated ash waste (if any) and its levels of contamination will only be determined upon completion of  further sampling and testing of the ash waste in the cremator/flue/chimney of the Existing Crematorium. 

 

7.5.25      Based on the experience in KCIP and TSKH, the level of DCM would be the main factor in determining ash waste remediation requirements and disposal options.  Details of the contamination classification, demolition, handling, treatment and disposal methodologies for the Existing Crematorium are given in Section 7.7.

 

7.5.26      Building structures where ash waste with DCM / HMCM / PAHCM is located are also likely to be contaminated with dioxin / heavy metals / PAHs, e.g. cremators, chimney, flues and surrounding areas.  For building structures where ash waste is classified as moderately/severely contaminated, ash waste would be required to be carefully removed from these building structures before disposal at landfill.  In particular, building structures where severe DCM contaminated ash is found should be sealed before disposal at landfill.  More importantly, these same building structures would also likely contain asbestos.  Subject to further asbestos investigations, these multiple contaminated building structures would require combined treatment and disposal methods for ACM/DCM/HMCM/PAHCM mentioned in Section 7.7.

 

7.5.27      With appropriate handling, treatment and disposal of contaminated ash waste and building structures, the associated environmental impact is expected to be minimal.

 

Dioxin Containing Materials (DCM) / Heavy Metal Containing Materials (HMCM) / Polyaromatic Hydrocarbon Containing Materials (PAHCM) / Total Petroleum Hydrocarbon Containing Materials (TPHCM) / Polychlorinated Biphenyls Containing Materials (PCBCM) from Soil Remediation at the Project Site

 

7.5.28      As detailed in Section 6 and the CAR in Appendix C2, soil samples were collected from within the site boundary for testing of dioxin, heavy metals, TPH and PAH.  According to the test results, no exceedance of the assessment criteria was found in any of the soil samples, except the two samples collected at sampling locations S3 and S5 that were found to be contaminated with lead and tin.  Toxicity Characteristic Leaching Procedure (TCLP) testing was also carried out for the two samples and the testing results have confirmed that the contaminated soil can be disposed of at landfill without any pretreatment.  It is estimated that the amount of HMCM to be removed from the vicinity of these two locations would be small (less than 100 m3).   Details of the arrangement for disposal of this HMCM are given in the RAP (Appendix C2).

 

7.5.29      Nevertheless, since the vicinity of the CLP secondary substation could not be readily accessed at the moment, further investigations of TPH and PCB should be carried out when decommissioned during Phase I of the work.  Such recommendations have been included in the CAP and CAR/RAP (see Appendix C). For this, a sampling and analysis plan will need to be prepared for approval by EPD.  Subject to the results of additional investigations, the need for any further remedial works, in addition to those described in the current RAP (Appendix C2), will be determined.  In addition, confirmatory testing on dioxin levels in locations S1 to S6 should be carried out to determine further remediation if required.

 

Potential Hazards of ACM, DCM, HMCM, Hydrocarbon Containing Materials and PCBCM

 

7.5.30      Mishandling of the ACM, DCM,  HMCM, PAHCM, TPHCM and PCBCM may pose toxic effects as well as health hazards to workers.  It is considered that the possibilities for contact with these contaminated materials would be relatively low, provided appropriate precautionary measures are implemented.  Nevertheless, the ash waste must be cleaned up under modified controlled/containment method prior to demolition, depending on its level of contamination in cremators /flues /chimney.  Possibilities for workers to contact contaminated soil can be controlled by implementation of appropriate safety precautions recommended in Section 7.7.

 

7.5.31      When the handling, storage, transportation and disposal of materials contaminated with asbestos, dioxin, heavy metals, hydrocarbon and PCB containing materials are in accordance with the mitigation measures provided in Section 7.7, environmental impacts associated with these waste types are expected to be minimal.

 

Chemical Wastes

 

7.5.32      Throughout the whole construction and demolition works, construction plant and equipment will require regular maintenance and servicing, which will generate chemical waste such as cleaning fluids, solvents, lubrication oil and fuel.  Maintenance for on-site equipment will also involve the use of a variety of chemicals and lubricants, including heavy-duty cleaners, organic solvents, degreasers, brake fluids, battery acid and soldering fluids.

 

 

7.5.33      Chemical waste may pose serious environmental, health and safety hazards if not stored and disposed of in an appropriate manner as outlined in the Waste Disposal (Chemical Waste) (General) Regulation and the Code of Practice on Packing, Labelling and Storage of Chemical Wastes.  These hazards may include:

 

·             Toxic effects to workers

·             Adverse effects on air, water and land from spills

·             Fire hazards

 

7.5.34      The amount of chemical waste that will arise from the construction activities will vary depending on the contractor’s on-site maintenance requirements and the amount of plant utilized.  It is anticipated that the quantity of chemical waste, such as lubricating oil and solvent, produced from plant maintenance will be relatively small.  If chemical waste generation is expected, the contractor must register with the EPD as chemical waste producer.  These types of waste will be readily accepted for disposal at the Chemical Waste Treatment Centre (CWTC) at Tsing Yi.  A detailed account of chemical waste generation should be provided by the contractor during preparation of the site Waste Management Plan.

 

7.5.35      Whenever possible, the contractor should reuse or recycle chemical waste.  When chemical waste is properly managed in accordance with the relevant mitigation and control measures in Section 7.7, the potential environmental impacts arising from the storage, handling and disposal of a small amount of chemical waste generated from the construction and demolition activities will be minimal.

 

General Refuse

 

7.5.36      Staff working at the construction site will generate general refuse requiring disposal during Phases I and II works.  General refuse will mainly consist of food wastes, aluminium cans, plastic bottles and waste paper.  The storage of general refuse may give rise to adverse environmental impacts.  These could include water quality (if waste enters nearby water bodies); odour, (if waste is not collected frequently) and visual impact; and in the form of windblown litter.  The Project site may also attract pests and vermin if the storage areas are not well maintained and cleaned regularly.  In addition, disposal of waste at sites other than approved waste transfer or disposal facilities can also have environmental impacts.

 

7.5.37      Based on the Consultants’ experience, the amount of general refuse generated by the site workers during construction and demolition activities will not be significant.  If the refuse is stored and transported in accordance with relevant good practices as specified in Section 7.7 and disposed of at licensed landfills, the potential environmental impacts will be minimal.

 

Cumulative Impacts

 

7.5.38      According to the information provided by Planning Department and Water Services Department and the KCRC Shatin to Central Link Project Profile submitted under EIA Study Brief ESB-106/2002, two other projects will be implemented during the construction and demolition phase of this Project.  They are (i) The Diamond Hill No. 2 Freshwater Service Reservoir, which is scheduled from 4 July 2002 to end of 2005, and (ii) the KCRC Shatin to Central Link, which is undergoing preliminary feasibility study and the construction is scheduled from 2004 to 2008.

 

7.5.39      Given the amounts of wastes requiring disposal to be generated from this Project as reviewed above and with the proper implementation of the mitigation measures as specified in Section 7.7, it is expected that the contribution to cumulative impacts from this Project would not be significant compared to other projects in the area.

 

7.6              Prediction and Evaluation of Environmental Impacts for Operation Phase

 

Ash and Non-combustible Residues

 

7.6.1          After cremation, bone ash and non-combustible residues remain.  According to FEHD, the weights of bone ash and non-combustible residues after each cremation are about 2.2 kg and 1.8 kg respectively.  Under current practice, bone ash is stored in covered containers to be collected by the deceased’s relatives within 2 months.  Based on the analytical results of non-combustible residues (i.e. furnace bottom ash) in TSKH, which contain less than 0.1 ppb TEQ of dioxin, the non-combustible residues in the New Crematorium should be collected in polyethene bags and disposed of to landfill.  This practice is expected to continue for the New Crematorium.  Under full load operation, each of the 6 cremators can handle 6 cremations per day, therefore the maximum generation of bone ash and non-combustible residues per day are 79.2 kg (2.2 x 6 x 6) and 64.8 kg (1.8 x 6 x 6) respectively.  Given the small quantity of waste requiring disposal and with the appropriate waste management practices as detailed in Section 7.8, the associated environmental impacts are expected to be minimal.

 

Chemical Waste

 

7.6.2          As discussed in Section 7.8, chemical wastes, including used activated carbon, un-reacted lime and collected particulate matter would likely be generated by the dry air pollution control system expected to be used at the New Crematorium.  The following chemical waste generation rates as contained in the Replacement of Cremators at Fu Shan Crematorium EIA Report are used for estimating the amounts of chemical wastes that would be produced by the air pollution control system of the New Crematorium:

 

Ÿ             Used activated carbon and un-reacted lime – 0.6 kg/hr

Ÿ             Collected particulate matter – 0.95 kg/hr

7.6.3          Taking the cremation time of 100 minutes and 6 cremations per cremator per day for the 6 new cremators, it can be calculated that the daily chemical waste arisings associated with operation of the air pollution control system of the New Crematorium would be 36 kg (0.6 x 100/60 x 6 x 6) of used activated carbon and un-reacted lime and 57 kg (0.95 x 100/60 x 6 x 6) of collected particulate matter.  Therefore, the estimated total generation of such chemical wastes would be about 93 kg/day.

 

7.6.4          In addition, a small amount of chemical waste in form of cleaning fluids, solvents, lubrication oil and fuel will be generated during regular maintenance and servicing of battery fork lift, transformer and switch room, emergency generator room and hydraulic lifts.

 

7.6.5          The chemical wastes generated from the air pollution control system would be in form of ash and those generated during maintenance and servicing would mainly be in form of liquid.  Chemical waste may pose serious environmental, health and safety hazards if not stored and disposed of in an appropriate manner as outlined in the Waste Disposal (Chemical Waste) (General) Regulation and the Code of Practice on Packing, Labelling and Storage of Chemical Wastes.  These hazards may include:

 

·             Toxic effects to operators

·             Adverse effects on air, water and land from spills

·             Fire hazards

 

7.6.6          As chemical waste generation is expected, the operator must register with the EPD as chemical waste producer. 

 

7.6.7          Chemical wastes generated from the New Crematorium can be readily accepted for disposal at the CWTC at Tsing Yi.  These chemical wastes should be collected in  drum-type containers and will be removed by licensed chemical waste contractor periodically.  With proper storage, handling and disposal of small amount of chemical wastes, as detailed in Section 7.8, adverse environmental impacts are not anticipated.

 

General Refuse

 

7.6.8          According to the experience from operation of the Existing Crematorium, it is anticipated that the quantity of general refuse generated by visitors and staff during daily operation at the New Crematorium will not be substantial.  Therefore, with the proper waste management facilities as detailed in Section 7.8 in place, it is expected that the potential environmental impacts arising from the handling and disposal of the general refuse will be negligible, and thus will not cause any major environmental concerns.

 

7.7              Mitigation of Adverse Environmental Impacts for Construction and Demolition Phase

 

General - Good Site Practice and Waste Reduction Measures

 

7.7.1          If good site practices are strictly followed, it is expected that adverse environmental impacts due to waste generation would not arise.  The following recommendations for good site practice should be included in the Contract Specifications for the Project during the construction activities:

 

·             Obtain relevant waste disposal permits from the appropriate authorities, in accordance with the Waste Disposal Ordinance (Cap. 354), Waste Disposal (Chemical Waste) (General) Regulation (Cap. 354) and the Land (Miscellaneous Provision) Ordinance (Cap. 28)

·             Prepare a Waste Management Plan approved by the Engineers/Supervising Officer of the Project  in accordance with Environment, Transport and Works Bureau Technical Circular (Works) (ETWBTC(W)) 15/2003, Waste Management On Construction Sites

·             Nominate an approved person, such as site manager, to be responsible for good site practice, arrangements for collection and effective disposal of all types of wastes generated on-site to appropriate facility

·             Use waste haulier authorized or licensed to collect specific category of waste

·             Establish trip ticket system as contractual requirement (with reference to Works Branch Technical Circular (WBTC) No. 21/2002) for monitoring of public fill and C&D waste at public filling facilities and landfills.  Such activities should be monitored by the Environmental Team

·             Provide training to site staff in terms of proper waste management and chemical waste handling procedures

·             Separate chemical wastes for special handling and dispose them at licensed facility for treatment

·             Establish routine cleaning and maintenance programme for drainage systems, sumps and oil interceptors

·             Provide sufficient waste disposal points and regular collection for disposal

·             Adopt measures to minimize windblown litter and dust during transportation of waste, such as covering trucks or transporting wastes in enclosed containers

·             Establish recording system for the amount of wastes generated, recycled and disposed of (including the disposal sites)

 

7.7.2          The contractor should submit the Waste Management Plan to Engineer/Supervising Officer of the Project for approval.  The Waste Management Plan should describe the arrangements for avoidance, reuse, recovery and recycling, storage, collection, treatment and disposal of different categories of waste to be generated from the activities of the Project and indicate the disposal location(s) of all waste.   A trip ticket system shall be included in the Waste Management Plan. 

 

7.7.3          Waste reduction is the most effective when considered during planning and design stage, provided those suggested measures are implemented.  Good management and control can prevent the generation of significant amount of waste.  It is therefore recommended to include the following practice in the Contract Specifications to ensure waste reduction: 

 

·             Minimize the damage or contamination of construction material by proper storage and site practices

·             Plan and stock construction materials carefully to minimize amount of waste generated and avoid unnecessary generation of waste

·             Prior to disposal of C&D waste, wood, steel and other metals should be separated for reuse and / or recycling to minimize the quantity of waste to be disposed of to landfill

·             Minimize use of wood and reuse non-timber formwork to reduce the amount of C&D waste

·             Recycle any unused chemicals or those with remaining functional capacity as far as practicable

·             As far as practicable, segregate and store different types of waste in different containers, skips or stockpiles to enhance reuse or recycling of materials and their proper disposal

·             Encourage collection of aluminium cans, plastic bottles and packaging material (e.g. carton boxes) and office paper by individual collectors, separate labeled bins should be provided to help segregate this waste from other general refuse generated by the work force

 

7.7.4          In addition to the above, specific mitigation measures are recommended below for the identified waste to minimize environmental impacts during handling, transportation and disposal of these wastes.

 

Excavated Material

 

7.7.5          Rock and soil generated from excavation should be reused for site formation as far as possible.  In addition, excavated material from foundation work can be reused for landscaping as far as practicable to avoid disposal off-site.

 

Construction and Demolition Material

 

7.7.6          Careful design, planning and good site management can minimize over-ordering and generation of waste materials such as concrete, mortar and cement grouts.  Standard formwork should be used as far as practicable, wooden formwork should be replaced by metal ones whenever possible.  Alternatives such as plastic fencing and reusable site office structures can also minimize C&D waste generation.

 

7.7.7          The contractor should recycle as much as possible of the C&D material on-site.  Public fill and C&D waste should be segregated and stored in different containers or skips to enhance reuse or recycling of materials and their proper disposal.  Materials such as concrete and masonry can be crushed and used as fill and steel reinforcing bar can be used by scrap steel mills.  Different areas of sites should be designated for such segregation and storage. 

 

7.7.8          To maximize landfill life, government policy discourages the disposal of C&D materials with more than 20% inert material by volume (or 30% inert material by weight) at landfill.  Inert C&D material (public fill) should be directed to an approved public filling area, where it has the added benefit of offsetting the need for removal of materials from borrow areas for reclamation purposes.

 

Contaminated Materials

 

Further Contamination Investigation

 

7.7.9          After decommissioning but prior to demolition of the Existing Crematorium, further contamination  investigation should be carried out to confirm the quality and quantity ash waste, building structures and contaminated soil requiring treatment and disposal (see Table 7.2 for details).    Further contamination investigation shall provide information on the extent of contamination (DCM / HMCM / PAHCM) at cremators /flues / chimney as well as the quantity of contaminated materials requiring treatment and disposal.  Regarding ACM, future AIR, AMP/AAP should be submitted to EPD for approval under the APCO.

 

Table 7.2   Further Contamination Investigation Requirements

 

Location

Investigation Parameter

Investigation Period

Responsible Party

Investigation Procedure

Cremators / flue / chimney and surrounding areas

Asbestos

(building structures)

Phase II

The contractor

See S.7.7.16

CLP secondary substation

PCB, TPH

(soil samples)

Phase I

The contractor

See Section 6.8 and Appendix C2

Cremators / flue / chimney and surrounding areas

Dioxins, heavy metals, PAH

(ash waste)

Phase II

The contractor

See S.7.7.9

S.7.7.12

Surface soil around Existing Crematorium

Dioxins, heavy metal, PAH

(soil sample)

Phase II

The contractor

See S.7.7.9

S.7.7.12

 

7.7.10      For DCM / HMCM / PAHCM in ash waste, as discussed in Section 7.5, samples of ash/particulate matters should be collected from within the cremators (including the bottom ash), chimney walls, flues and surrounding area of the Existing Crematorium for analysis of dioxin, heavy metals and PAHs by a HOKLAS accredited laboratory.  It is recommended that a consultant experienced in the abatement of chemical wastes particularly the handling of DCM, should be appointed in order to assist with the evaluation of the information and prepare an abatement plan for the ash waste.  Such a plan shall be submitted to EPD and the Labour Department (LD) to establish an acceptable and safe method for these potentially hazardous wastes.  The abatement plan for ash waste should identify the method of abatement, the performance criteria for the protection of workers and the environment and any emergency procedures and contingency measures required.  The plan should also quantify the amount of material that will require removal. The abatement plan should be agreed with EPD and LD.

 

7.7.11      It must be ensured that the treatment of ash wastes will comply with all routine construction site safety procedures as well as statutory requirements under the Occupational Safety and Health Ordinance and Factories and Industrial Undertakings Ordinance.  Due to the difficulties in establishing permanent and effective engineering controls, the protection of workers is likely to be at the worker level.  A safe system of work must be provided, and training and suitable personal protective equipment as well as hygienic decontamination facilities should be provided.  It is recommended that the methods to be adopted by the contractor for disposal of the ash waste should be agreed with LD and EPD. 

 

7.7.12      Sufficient time should be allocated to abate all ash waste with DCM / HMCM / PAHCM.  The contractor should ensure the implications of dust containing DCM / HMCM / PAHCM on air quality and workers health during the clean up work are mitigated.

 

7.7.13    Since DCM is chemically related to PCB wastes, the requirements of the Code of Practice on the Handling, Transportation and Disposal of (PCB) Wastes should be referenced when developing the abatement plan.  Reference should also be made to the safety procedure mentioned in Appendix C2.

 

7.7.14      A land contamination site investigation was carried out under this EIA to determine disposal requirements for contaminated soil (see Section 6 for detail).   Further site investigation on soil around CLP secondary substation is needed when decommissioned, which will be during Phase I of the works.  In addition, confirmatory testing on DCM level in locations S1 to S6 will be required to identify the appropriate remediation and disposal requirements during Phase II of the works.

 

7.7.15      The key measures for handling, transportation, treatment and disposal of the ACM/DCM/HMCM/PCBCM/PAHCM and TPHCM are described below:

 

Asbestos Containing Materials (ACM)

 

7.7.16      Further asbestos assessment should be carried out when access to the cremators /flue /chimney is accessible after decommissioning and before demolition.  An AMP should be prepared.  The AAP should be prepared and submitted to EPD for approval prior to commencement of demolition works in accordance to the APCO.  It is preferable to remove all ACM before actual demolition.  A registered asbestos removal contractor should be employed to remove all ACM in accordance with the approved AAP which will be prepared in due course in accordance with the Code of Practice (COP) on Asbestos Control for Safe Handling of Low Risk ACM and Asbestos Work Using Full Containment or Mini Containment Method published by EPD.  A registered asbestos consultant should also be employed to supervise abatement works.  For the disposal of ACM, the contractor should observe the COP on Handling, Transportation and Disposal of Asbestos Waste under the Waste Disposal (Chemical Waste) (General) Regulation.

 

Dioxin Containing Materials (DCM) / Heavy Metal Containing Materials (HMCM) / Polyaromatic Hydrocarbon Containing Materials (PAHCM) from Demolition of the Existing Crematorium

 

7.7.17      According to the experience in KCIP and TSKH, the level of dioxin was the prime factor affecting the ash waste treatment and disposal options.  With reference to the remediation and disposal methods in KCIP and TSKH clinical waste incinerator, different contamination classifications based on the levels of DCM / HMCM / PAHCM in ash waste are proposed in Table 7.3, and their corresponding handling, transportation, treatment and disposal methodologies are described in the subsequent paragraphs.

 

Table 7.3   Proposed Contamination Classification for Ash Waste with DCM/HMCM

 

Classification of Contamination

Dioxin Level in Ash Waste

Heavy Metal Level / Polyaromatic Hydrocarbon in Ash Waste

Low/Non Contaminated  DCM / HMCM / PAHCM

< 1 ppb TEQ

< Dutch “B” List

Moderately/Severely Contaminated HMCM / PAHCM

< 1 ppb TEQ

≥ Dutch “B” List

Moderately Contaminated DCM

≥ 1 and <10 ppb TEQ

Any level

Severely Contaminated DCM

≥ 10 ppb TEQ

Any level

 

Demolition, Handling, Treatment and Disposal of Low/Non Contaminated DCM / HMCM / PAHCM from Demolition of Existing Crematorium

 

7.7.18      Where the ash waste contains low/non contaminated DCM/HMCM/PAHCM, the contractor should avoid ash waste becoming airborne during demolition.  General dust suppression measures mentioned in Section 4 should be followed.  All such ash waste can be directly disposal of at landfill.

 

7.7.19      Subject to the findings of the further asbestos investigation, building structures where such ash waste is found but contaminated with asbestos should be dealt in accordance to S.7.7.16.

 

Demolition, Handling, Treatment and Disposal of Moderately Contaminated DCM and Moderately/Severely Contaminated HMCM / PAHCM from Demolition of the Existing Crematorium

 

7.7.20      The demolition, handling, treatment and disposal of moderately contaminated DCM and moderately/severely contaminated HMCM / PAHCM with reference to the Demolition of Kwai Chung Incineration Plant EIA Report and the Project Profile for the Decommissioning and Disposal of a Clinical Waste Incinerator at Tang Siu King Hospital is given in Table 7.4. 

 

Table 7.4   Demolition, Handling, Treatment and Disposal of Moderately Contaminated DCM and Moderately/Severely Contaminated HMCM / PAHCM

 

Item

Procedure

Site Preparation

The contractor should ensure the impacts of dust containing dioxin and/or heavy metals on air quality and workers health during the handling and transportation of the contaminated materials are mitigated.  Except the cremators/flue/chimney, all removable items where moderately contaminated DCM or moderately/severely contaminated HMCM / PAHCM is identified should be removed as far as practicable to avoid obstructing the decontamination activities.  Preliminary site decontamination of all debris shall be carried out using (High Efficiency Particulate Air) HEPA vacuum cleaner.  The top portion of the chimney above the roof shall be enclosed by a chamber with three layers of polyethene sheets.  At the entrance to the cremators /flues /chimney, a 3-chamber decontamination unit shall be constructed for entry and exit from the work area. The 3-chamber decontamination unit shall comprise a dirty room, a shower room and a clean room of at least 1m x 1m base each with 3 layers of fire retardant polyethene sheet where all workers shall carry out decontamination procedures before leaving the work area.  Warning signs in both Chinese and English should be put up in conspicuous areas.

 

All workers shall wear full protective equipment, disposable protective coverall (such as Tyvek) (with hood and shoe covers), nitrile gloves, rubber boots (or boot covers), and full-face positive pressure respirators equipped with a combination cartridge that filters particulate and removes organic vapour. The organic vapour protection is an added protection against the unlikely exposure to any vapour.

 

If ACM is identified in building structures where moderately contaminated DCM or moderately/severely contaminated HMCM / PAHCM is found, relevant abatement measures for building structures described in the AAP (see S.7.7.16) should be implemented prior to the above site preparation.

Demolition and handling

The cremators/flue/chimney shall be removed from top down starting from the chimney.  Any ash or residues attached to the cremators/flue/chimney or any other building structures shall be removed by scrubbing and HEPA vacuuming.

Wastes generated from the containment or decontamination unit including the protection clothing of the workers such as the coverall, nitrile glove, rubber boots and materials used for wet wiping shall be disposed of at landfill site.

 

After completion of removal, decontaminate all surfaces by HEPA vacuum.

 

If ACM is identified in building structures where moderately contaminated DCM or moderately/severely contaminated HMCM / PAHCM is found, relevant abatement measures for building structures described in the AAP (see S.7.7.16) should be implemented prior to the above decontamination, demolition and handling measures.

 

 

Treatment

The ash waste contains dioxin/heavy metals and in its untreated state would be classified as a chemical waste under the Waste Disposal (Chemical Waste) (General) Regulation.  While the quantity of DCM/HMCM is not expected to be significant, the levels of dioxin and heavy metals would affect the treatment option.  With reference to the Demolition of Kwai Chung Incineration Plant EIA Report, immobilization of the contaminated materials by mixing with cement followed by disposal at landfill (if landfill disposal criteria can be met) would be the most preferable option.

 

Rather than treating the already incinerated ash waste by incineration, the ash waste with moderately contaminated DCM or moderately/severely contaminated HMCM / PAHCM should be collected and stabilized to meet landfill disposal criteria of the Facilities Management Group (FMG) of EPD.  In this case it is envisaged that the process would involve collection and mixing of the ash waste with cement.  Pilot mixing and TCLP tests should be carried out done to establish the appropriate ratio of cement to ash waste to the satisfaction of EPD.  It is envisaged that the pilot tests would involve the mixing of say 5%, 10% and 15% ratios of cement to ash waste and three replicate of 300 mm cube blocks for each ratio.  TCLP tests should then be used to establish the correct ratio of cement to ash waste to the satisfaction of EPD.

Disposal

After immobilization of the ash waste by mixing with cement in the correct ratio as determined by the pilot mixing and TCLP test, the waste materials should be placed inside polyethene lined steel drums for disposal at landfill.  Transparent plastic sheeting of 0.15 mm thickness low-density polyethene or PVC should be employed.  The drums should be 16 gauge steel or thicker and fitted with double bung fixed ends adequately sealed and well labelled in new or good condition.  The drums should be clearly marked “DANGEROUS CHEMICAL WASTE” in English and Chinese.  Prior agreement of the disposal criteria from the FMG of EPD and agreement to disposal from the landfill operator must be obtained.

 

As a fall back option, if the landfill disposal criteria cannot be met after immobilization of the ash waste, disposal at the CWTC should be considered.

 

The building structures will be disposal of at landfill.

 

If ACM is identified in building structures where moderately contaminated DCM or moderately/severely contaminated HMCM / PAHCM is found, relevant disposal measures for building structures described in the AAP (see S.7.7.16) should be implemented instead.

 

Demolition, Handling, Treatment and Disposal of Severely Contaminated DCM from Demolition of the Existing Crematorium

 

7.7.21      The areas with severely contaminated DCM shall be removed under containment as a prudent approach to avoid the release of any ash waste to the environment, which could be generated during the demolition of cremators/flue/chimney of the Existing Crematorium.  The demolition, handling, treatment and disposal of severely contaminated DCM with reference to the Project Profile for the Decommissioning and Disposal of a Clinical Waste Incinerator at Tang Siu King Hospital is given in Table 7.5. 

 

Table 7.5   Demolition, Handling, Treatment and Disposal of Severely Contaminated DCM

 

Item

Procedure

Site Preparation

Except the cremators/flue/chimney, all removable items where severely contaminated DCM is identified should be removed from the cremator room as far as practicable to avoid obstructing the decontamination activities.  Preliminary site decontamination of all debris shall be carried out using HEPA vacuum cleaner.  The walls, floor and ceiling of the cremator room where severely contaminated DCM located shall be lined with 3 layers of fire retardant polyethene sheets.  The top portion of the chimney above the roof shall be enclosed by a chamber with three layers of polyethene sheets.  At the entrance to the cremators/flues/chimney, a 3-chamber decontamination unit shall be constructed for entry and exit from the work area. The 3-chamber decontamination unit shall comprise a dirty room, a shower room and a clean room of at least 1m x 1m base each with 3 layers of fire retardant polyethene sheet where all workers shall carry out decontamination procedures before leaving the work area.  Warning signs in both Chinese and English should be put up in conspicuous areas.

 

Air movers should be installed at the cremator room, and at the bottom of the chimney to exhaust air from the work area.  A stand-by air mover shall also be installed with each of the air movers. Sufficient air movement shall be maintained to give a minimum of 6 air changes per hour to the work area, and maintain a negative pressure of 0.05-0.15 inches of water within the work area throughout the entire course of the decommissioning works.  A pressure monitor with printout records and audible alarm shall be installed at an easily accessible location to demonstrate that negative pressure is maintained.  New pre-filters and HEPA filters shall be used on the air movers.

 

A copy of the maintenance records of the air movers should be kept on site for inspection upon request. The appointed contractor shall also check the differential pressure of the air mover to make sure the filter is not blocked. A differential pressure above 0.2 inches of water indicates that the filters would need to be changed.

 

Smoke Test: before commencement of the decommissioning work, a smoke test with non-toxic smoke shall be carried out to ensure the air-tightness of the containment.  Also check whether there are stagnant air pockets indicated by an aggregate of smoke that cannot effectively be extracted.  After a successful test, switch on the air mover to exhaust smoke from the containment and to give a minimum of 6 air changes per hour, and check visually to see that the filters screen out the smoke effectively and if the pressure gauges read normal.  If not, the air mover shall be sealed up and returned to the supplier workshop for necessary servicing, and replaced by a tested air mover.  The normal reading pressure range for maintaining 6 air changes per hour shall be 1.5-4 mm/0.05-0.15 inches of water or equivalent (negative pressure). The audible alarm’s integrity should also be checked and the trigger shall be at <1.5 mm/0.05 inches of water (negative pressure).  Otherwise securely seal up all openings before switching off the air mover.

 

Treatment of Waste/Workers Safety Protection: the contractor shall be required to register as a Chemical Waste Producer.  All workers shall wear full protective equipment, disposable protective coverall (such as Tyvek) (with hood and shoe covers), nitrile gloves, rubber boots (or boot covers), and full-face positive pressure respirators equipped with a combination cartridge that filters particulate and removes organic vapour. The organic vapour protection is an added protection against the unlikely exposure to any vapour as a necessary measure.

 

If ACM is identified in building structures where severely contaminated DCM is found, relevant abatement measures for building structures described in the AAP (see S.7.7.16) should be implemented prior to the above site preparation.

Decontamination, demolition and handling

The cremators/flue/chimney shall be removed from top down starting from the chimney.  Any ash or residues attaching to the cremators/flue/chimney or any other building structures shall be removed by scrubbing and HEPA vacuuming.

The detached sections of the building structures where severely contaminated DCM is located shall be wrapped with 2 layers of fire retardant polyethene sheets.  A third layer shall then be wrapped and secured with duct tape.  Decontaminate the outer layer of the wrapped flue sections by wet wiping.

 

Wastes generated from the containment or decontamination unit including the fire retardant polyethene sheets, protection clothing of the workers such as the coverall, nitrile glove, rubber boots and materials used for wet wiping shall be disposed of at landfill site.

 

The quantity of wastewater generated from the decontaminated process will be very small but the contractor should take precautionary measures as to minimize the quantity of contaminated water arising. Nevertheless, if any contaminated wastewater needs to be discharged out of the site, it has to be properly treated to WPCO requirements with prior agreement from EPD on discharge standards.

 

After completion of removal, decontaminate the surface where severely contaminated DCM was located, including the wrapped incinerator furnace and flue sections left within the containment, by wet wiping and HEPA vacuum. Then spray the innermost layer of the fire retardant polyethene sheet covering the wall, ceiling and floor with PVA. Upon drying, peel off this innermost layer of the polyethene sheet covering the containment and dispose of at landfill site.

 

Repeat the above decontamination procedure for the second innermost layer of fire retardant polyethene sheet by wet wiping and HEPA vacuuming. After spraying with PVA, peel off this second innermost layer of the polyethene sheet covering the wall, ceiling and floor and dispose of at landfill site. Finally, the last layer of polyethene sheet shall then be taken down after spaying with PVA and be disposed as contaminated wastes.

 

If ACM is identified in building structures where severely contaminated DCM is found, relevant abatement measures for building structures described in the AAP (see S.7.7.16) should be implemented prior to the above decontamination, demolition and handling measures.

Treatment and disposal

Waste to be disposed to CWTC: all contaminated ash waste with severely contaminated DCM removed and the used HEPA filters shall be sent to CWTC in Tsing Yi.  The total volume should be confirmed by further site investigation.

 

Waste to be Disposed of at Landfill: other wastes including the building structures and its associated panels as well as wastes generated from this decommissioning works are also considered as contaminated waste and shall be disposed of at a designated landfill. Wastes generated from this decommissioning works refer to the polyethene wrapping sheets for the building structures, waste generated from the dismantlement of the containment and decontamination units, and cloth used in wet wrapping, etc. as previously described in this section. They shall be placed into appropriate containers such as drums, jerricans, or heavy duty and leak-proof plastic as a prudent approach.  A disposal permit has to be obtained from the Authority. The disposal trip ticket is required to be made available as record after disposal.

 

If ACM is identified in building structures where severely contaminated DCM is found, relevant disposal measures for building structures described in the AAP (see S.7.7.16) should be implemented in prior to the above disposal measures.

 

Dioxin Containing Materials (DCM) / Heavy Metal Containing Materials (HMCM) / Polyaromatic Hydrocarbon Containing Materials (PAHCM) / Total Petroleum Hydrocarbon Containing Materials (TPHCM) / Polychlorinated Biphenyls Containing Materials (PCBCM) from Soil Remediation at the Project Site

 

7.7.22      According to the CAR and RAP provided in Appendix C2, less than 100 m3 of soil would require disposal at landfill.  Relevant health and safety procedure, waste disposal requirements and compliance report are as detailed in Appendix C2.  Mitigation measures to avoid fugitive dust emission mentioned in Section 4 should also be observed.

 

7.7.23      In addition, after decommissioning but before demolition of the Existing Crematorium, further investigations during Phase I of the works at the vicinity of CLP secondary substation should also be carried out to determine if additional remediation (in addition to the current RAP) is required.  Confirmatory test on levels of DCM, HMCM and PAHCM in locations S1 to S6 during Phase II of the works is also required to determine any further remediation /treatment/disposal.  In addition, the ash waste in cremator/chimney/flues should also be collected for the testing of DCM/HMCM/PAHCM during Phase II of the works.  The sampling and analysis plan should be prepared and submitted to EPD for approval.

 

7.7.24      All the aforementioned ACM/DCM/HMCM/PAHCM/TPHCM/PCBCM are classified as chemical waste.  In addition to the measures mentioned above, the packaging, labelling and storage practices of chemical waste as stipulated in the following paragraphs should also be applied to these contaminated materials.

 

Chemical Waste

 

7.7.25      All the chemical waste should be handled according to the Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes.  The chemical waste should be stored and collected by an approved contractor for disposal at a licensed facility in accordance with the Waste Disposal (Chemical Waste) (General) Regulation.  Containers used for the storage of chemical waste should:

 

·             Be suitable for the substance they are holding, resistant to corrosion, maintained in good condition, and securely closed;

·             Have a capacity of less than 450 L unless the specifications have been approved by the EPD; and

·             Display a label in English and Chinese in accordance with instructions prescribed in Schedule 2 of the Waste Disposal (Chemical Waste) (General) Regulation.

 

7.7.26      The storage area for chemical waste should:

 

·             Be clearly labeled and used solely for the storage of chemical waste;

·             Be enclosed on at least 3 sides;

·             Have an impermeable floor and bunding, of capacity to accommodate 110% of the volume of the largest container or 20% by volume of the chemical waste stored in that area, whichever is the greatest;

·             Have adequate ventilation;

·             Be covered to prevent rainfall from entering (water collected within the bund must be tested and disposal as chemical waste if necessary); and

·             Be properly arranged so that incompatible materials are adequately separated.

 

7.7.27      The chemical waste should be disposed of by:

 

·             A licensed waste collector;

·             A facility licensed to receive chemical waste, such as the CWTC at Tsing Yi, which offers chemical waste collection service and can supply the necessary storage containers; and/or

·             A waste recycling plant as approved by EPD.

 

General Refuse

 

7.7.28      General refuse should be stored in enclosed bins or compaction units separated from C&D and chemical wastes.  A reliable waste collector should be employed by the contractor to remove general refuse from the site, separately from C&D and chemical wastes, on a daily or every second day basis to minimize odour, pest and litter impacts.  The burning of refuse on construction sites is prohibited by law.

 

7.7.29      Aluminum cans are often recovered from the waste stream by individual collectors if they are segregated or easily accessible.  Therefore, separately labeled bins for deposit of these cans should be provided if feasible. Similarly, plastic bottles and carton package material generated on-site should be separated for recycling as far as practicable.  Site office waste should be reduced through recycling of paper if volumes are large enough to warrant collection.  Participation in a local collection scheme should be considered if one is available.

 

7.8              Mitigation of Adverse Environmental Impacts for Operation Phase

 

Ash and Non-combustible Residues

 

7.8.1          The disposal of bone ash and non-combustible residues should be properly collected and handled to avoid dust emissions.  In line with the current practices, the bone ash will be stored in covered containers for collection by the deceased’s relatives within 2 months upon appointment while the non-combustible residues will be collected in sealed heavy-duty polyethene bags for disposal at landfill.  Provided that these good practices continue, the potential secondary environmental impacts will be kept to a minimum.

 

Chemical Waste

 

7.8.2          The chemical wastes generated from the air pollution control system would mainly include used activated carbon, un-reacted lime and collected particulate matter.  To prevent health hazards to operators, all such chemical wastes should be carefully collected and handled to avoid dust emissions.

 

7.8.3          All the chemical wastes generated from the air pollution control system as well as from machinery maintenance and servicing should be dealt with according to the Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes under the provisions of the Waste Disposal (Chemical Waste)(General) Regulation.  The chemical wastes should be collected by drum-type containers and removed by a licensed chemical waste contractor.  In addition, the relevant measures as provided in Section 7.7 should be followed.

 

General Refuse

 

7.8.4          Waste generated in offices should be reduced through segregation and collection of recyclable waste materials (such as paper and carton packages) if the volumes are large enough to warrant collection.  Participation in a local collection scheme should be considered if one is available.

 

7.8.5          To promote recycling of waste paper, aluminum cans and plastic bottles by the visitors, it is recommended to place clearly labeled recycling bins (such as those available from EPD) at convenient locations within the New Crematorium area.  The recyclable waste materials should then be collected by reliable waste recycling agents on a regular basis.

 

7.8.6          The general refuse (other than those segregated recyclable wastes) should be separated from any chemical wastes and stored in covered waste skips.  Food and Environmental Hygiene Department (FEHD) should remove general refuse from the site, separately from chemical wastes, on daily basis to minimize odour, pest and litter impacts.  Burning of refuse must be strictly prohibited.

 

7.9              Conclusions

 

7.9.1          This assessment has considered the waste management implications on the demolition of Existing Crematorium as well as the construction and operation of New Crematorium.  The potential environmental impacts arising from the handling and disposal of various types of waste materials have been identified.  With effective implementation of the recommended mitigation measures, it is anticipated that the associated secondary impacts on the environment and the potential impacts on the capacity of waste collection, transfer and disposal facilities will not be significant.

 




(1) Reduction of Construction Waste Final Report (March 1993), Hong Kong Polytechnic.

(2) Monitoring of Solid Waste in Hong Kong 2001, Environmental Protection Department.