6.                  Land Contamination

6.1              Introduction

6.1.1        Potential contaminative workshops have been identified close to the proposed site boundary of Pak Kong River based on the findings of the desktop study and site appraisal. As recommended in the EIA report, further investigation shall be required to determine the presence and extent of contamination before the construction works taken place at the concerned areas. The contamination assessment shall be carried out in accordance with EPD’s ProPECC PN3/94 “Contaminated Land Assessment and Remediation” and “Guidance Notes for Investigation and Remediation of Contaminated Sites of Petrol Filling Stations, Boatyards, and Car Repair / Dismantling Workshops”. 

6.1.2        The contaminated sites shall be remediated before commencement of any construction work at the concerned sites which may disturb the ground. The duration of remediation shall be taken into account by the Project Proponent or the Contractor as part of the construction programme. In all cases, contaminated soil remediation, treatment or disposal must be managed in an environmentally sound manner, including compliance with all relevant legislation and Government requirements.

 

6.2              Potential Areas Recommended for Further Investigation

6.2.1        A preliminary Contamination Assessment Plan (CAP) has been prepared and included in the EIA report. The CAP recommended that site investigation shall be conducted for the potential contaminated areas encroaching upon the proposed drainage works area of Pak Kong River. As shown in Figure 6.1, two potential zones (SI-1 and SI-2) have been confined for further investigation due to the presence of two potential contaminative workshops partially located within the proposed works area, including Workshop A - Wah Shing Motor Repairing Factory and Workshop B - Wing Chong Car Repair. The details of further investigation are presented in Table 6.1.

 

6.3              Preparation of Contamination Assessment Plan

6.3.1        Due to the possibility of land-use changes and variable future site conditions caused by different factors such as weather and business operation, a full site inspection is required by the future Environmental Team (ET) to review the validity of the preliminary CAP.  The ET shall have suitably qualified personnel with at least 7 years in land contamination investigation.  The CV of the relevant personnel shall be submitted to IC(E) and ER for approval before commencement of land contamination study.  The ET shall base on the findings of the EIA and further detailed site appraisal to prepare an updated CAP immediately after the site was resumed for this project. Such updated CAP should be submitted to EPD for approval.

6.3.2        Table 6.1 lists the parameters that shall be analysed and the number of samples proposed to be taken at each concerned area, according to EPD's Guidance Notes for Investigation and Remediation of Contaminated Sites, for reference. All the information given in Table 6.1 (including the number and location of sampling points and testing parameters) shall be reviewed during the preparation of CAP.

6.3.3        Upon receipt of EPD’s approval on the updated CAP, the actual site investigation for land contamination impact assessment shall be conducted accordingly before any construction work started at the identified contaminated sites. Soil and groundwater samples shall be collected and tested as described in the approved CAP to provide site-specific information for the assessment.  The soil and groundwater sampling and testing work may be carried out by the Contractor or other drilling contractors under suitable contractual arrangement by the Project Proponent or ER.   The field sampling work shall be supervised by the ET and audited by the IC(E).

6.3.4        A Contamination Assessment Report (CAR) shall be prepared by the ET to document the findings of the site investigation. Interpretation of laboratory testing results in accordance with the ProPECC Note No. 3/94 and comparison of the findings with relevant standards, such as the Dutch guidelines or other international practices as appropriate shall be also included in the CAR.

6.3.5        If land contamination is confirmed, a Remediation Action Plan (RAP) shall be prepared by the ET and drawn up to formulate necessary remedial measures, and potential water quality impact to the river shall be also addressed if necessary in the remediation measures. The subsequent CAR and RAP shall be endorsed by EPD before implementation of any remedial technology. The contaminated sites should be remediated before commencement of any construction work at the concerned sites which may disturb the ground. The duration of remediation should be taken into account by the Project Proponent or the Contractor as part of the construction programme.

6.4              Mitigation Measures during Construction Stage

6.4.1        In the execution of the construction works, it is expected that any identified contaminated land would be remediated to the acceptable standards prior to site clearance/excavation works. Therefore, no significant impact in relation to land contamination would be anticipated. However, as a precaution, mitigation measures are recommended to minimise the potentially adverse effects on the health and safety of construction workers and the impacts arising from the disposal of potentially contaminated materials. These measures include, but not limited to, the following:

·         Construction workers' potential contact with contaminated materials should be minimised by using bulk earth-moving excavator equipment;

 

·         Exposure to any contaminated materials should be minimised by wearing appropriate clothing and personal protective equipment such as gloves and masks (when interacting directly with suspected contaminated material), providing adequate hygiene and washing facilities and preventing smoking and eating during such activities;

 

·         Stockpiling of contaminated excavated materials on site should be avoided as far as possible;

 

·         The use of contaminated soil for landscaping should be prohibited unless there is proper treatment of soil;

 

·         Vehicles containing any excavated materials should be suitably covered to limit potential dust emissions or contaminated wastewater run-off, and truck bodies and tailgates should be sealed to prevent any discharge during transport or during wet conditions;

 

·         Only licensed waste haulers should be used to collect and transport any contaminated material to an appropriate disposal site and procedures should be developed to ensure that illegal disposal of waste does not occur;

 

·         The necessary waste disposal permits should be obtained, as required, from the appropriate authorities, in accordance with the Waste Disposal Ordinance (Cap 354), Waste Disposal (Chemical Waste) (General) Regulation (Cap 35), as required;

 

·         Records of the quantities of wastes generated and disposed of should be maintained; and

 

·         In accordance with good construction practice, silt traps should be used to reduce the impact to drainage caused by suspended solids arising from disturbed ground, or any construction materials such as cement and gravel. Wastewater, surface runoff or extracted groundwater should be disposed of in accordance with the WPCO.

 

 

 


Table 6.1         Preliminary Contamination Assessment Plan for Further Investigation of Identified Potential Sites 

 

Potential Site

Potential Contaminating Area for SI

Workshops within the Potential Contaminating Areas for SI

Current Activities/Uses

Potential Contaminants

Size/Area of Concern to this Project

Proposed no. of Sampling Points*

Parameters to be Analysed*

Remarks

Site A

(Pak Kong River)

SI – 1

Workshop -A

Wah Shing Motor Car Repairing Factory

Long vehicle parking and maintenance

Lubricants, petroleum products, fuels, battery acid and cleansing solvents.

200 m2

2

BTEX, TPH,

organic solvents, lead, copper, chromium, zinc & PAHs.

To be reconfirmed by the environmental team at the construction stage.

.

Site B

(Pak Kong River)

SI – 2

Workshop -B

Wing Cheong Car Repair

Repairing of private vehicles and mini-vans in majority

Lubricants, petroleum products, fuels, battery acid and cleansing solvents.

177 m2

2

BTEX, TPH,

organic solvents, lead, copper, chromium, zinc & PAHs.

Notes: *     Subject to further confirmation/review when preparing the CAP, and to be endorsed by EPD before the sampling work. 

                     TPH: Total petroleum hydrocarbons: C6 to C36.

                     BTEX: Benzene, toluene, ethlybenzene and xylenes.

                     PAHs: Polycyclic aromatic hydrocarbons