| 2. |
GIC proposed
to build a co-combustion pilot plant at No. 7, Lung
Yiu Street, Tap Shek Kok, Tuen
Mun, N.T. The pilot plant aims to collect data on
co-combustion technology for an academic research project
jointly undertaken by GIC and the Hong Kong University
of Science and Technology (HKUST). |
| 3. |
GIC applied
for a specified process licence on 30
October 2002 and the particulars of the application
were published in local newspapers on 27
May 2003. Under the Air
Pollution Control Ordinance(APCO), the public had
the opportunity to object, within 30 days after the notice
was published, to GIC's application on air quality or
health grounds. At the close of the 30-day public
notification period, 195 objections were received. |
| The
Application |
| 4. |
According to
GIC's application, the pilot plant will burn no more than
40 tonnes of municipal waste per day. Municipal
waste will be received and processed within 24 hours in
an enclosed building under negative pressure in order
to control odour. The waste will be fed to the combustion
chamber where it will be burnt for about 30 minutes. The
ash generated will be sampled and analysed. It will
either be stored in totally enclosed systems or solidified
before disposal at landfills. The exhaust gas will be
directed to the secondary combustion chamber inside which
the gas will be kept at or above 1200 oC for
at least 4 seconds to ensure complete destruction of all
organic compounds. Lime (calcium oxide) in excessive quantity
will be used to remove hydrogen chloride and other acidic
gases thus controlling the formation of dioxins. The exhaust
gas will be further treated to reduce nitrogen oxides
and particulates before discharging into the atmosphere
through a 114 metres tall chimney to ensure effective
dispersion. Thermodynamic data will be collected to evaluate
the feasibility of recovering heat energy from the exhaust
gas for power generation. The pilot plant will be
operated for a cumulative period of 16 weeks at the maximum. |
| Objections |
| 5. |
Under Section
14(4)(b) of the APCO, any person may object to the
granting of a licence to GIC on the following grounds
- |
| |
(a)
|
air quality
ground: that the project would tend to inhibit the attainment
or maintenance of any relevant air quality objective;
or |
| (b) |
health ground: that the
emission of noxious or offensive emissions would be, or
likely to be, prejudicial to health. |
| 6. |
During the 30-day
public notification period, a total of 195 objections
were received from 189 individuals and 6 organisations. |
| 7. |
Of the 195 objections
received, 128 objectors did not provide any ground for
objection. It was therefore not possible to consider
their objections further in accordance with the provisions
of the APCO.
|
| 8. |
The
grounds for objection of the remaining 67 objectors
were related to air quality and health. Their concerns
are summarised in Appendix 1. As four
of them had provided very comprehensive comments to
GIC's air pollution control plan, we decided to convene
hearings with them and thereafter with GIC. We met the
four objectors on 14
August 2003 to discuss their concerns and
seek supplementary information from them to substantiate
their demands. We also met GIC on 15
August 2003 to relay to them the objectors'
main concerns and clarify certain technical aspects.
While the objectors were most concerned about the impacts
on air quality and health, they made several suggestions
to better monitor the operation of the pilot plant.
Having considered the objectors' suggestions, GIC agreed
to set up a local environmental monitoring committee,
comprising 2 nominations from GIC, 2 from HKUST and
4 from Tuen Mun District Council. GIC found the suggestions
on heavy metal and dioxins monitoring not viable because
the technologies proposed were either still being developed
or had no local technical support. Instead, they would
adopt methods comparable with the international practices
for heavy metal and dioxin monitoring such as those
in the United States
and Europe. |
| 9. |
Having carefully
reviewed the objectors' concerns and GIC's responses,
we consider that the operation of the pilot plant will
not have any significant impact on air quality objectives
or public health. Our response to the objections raised
is summarised in Appendix 2. |
| 10. |
We have also
received other comments objecting to GIC's proposed project
on grounds other than those specified under the APCO.
These comments and our views are summarised respectively
in Appendix 3 and Appendix
4. |
| The
decision |
| 11. |
Having considered
all the relevant information, we are satisfied that: |
| |
(a) |
GIC is capable of providing
and maintaining the best
practicable means as required by the APCO (including
proper monitoring of its emissions) for the prevention
of the emission of air pollutants from the pilot plant; |
| (b) |
the emissions from the pilot
plant will not have any unacceptable impact on the attainment
and maintenance of any relevant air quality objective;
and |
| (c) |
the emissions from the pilot
plant will not have any unacceptable impact on public
health. |
| 12. |
A specified
process (an Incinerator) licence was granted to GIC on
25 November
2003. |
Environmental
Protection Department
November
2003 |
| Appendix
1 - The objectors' concerns |
| 1. |
The pilot plant will cause
air pollution and pollute the environment. (click
here to see EPD's response)
|
| 2. |
The release of heavy metals
and dioxins from the proposed pilot plant will have adverse
impact on health. (click here to see
EPD's response) |
| 3. |
The release of heavy metals
and dioxins from the pilot plant will have adverse impact
on the ecology. (click here to see EPD's
response) |
| 4. |
Emissions from the pilot
plant will damage the ozone layer. (click
here to see EPD's response) |
| 5. |
The pilot plant is too close
to Tuen Mun. It should be away from Tuen Mun. (click
here to see EPD's response) |
| 6. |
Incineration violates the
principle of environmental protection and the concept
of developing Hong Kong as a green
city. The Government should give up the incineration policy
and promote recovery of waste. (click here
to see EPD's response) |
| 7. |
The pilot plant operation
will be lengthened from about 16 weeks to years if a licence
is granted to GIC. (click here to see
EPD's response) |
| 8. |
The pilot plant will incinerate
more than 40 tonnes of municipal waste if a licence is
granted to GIC. (click here to see EPD's
response) |
| 9. |
The accuracy and credibility
of the air quality assessment done by GIC are questionable.
(click here to see EPD's response) |
| 10. |
There could be health risk
other than those caused by air pollution, for example,
contamination of food by dioxins. (click
here to see EPD's response) |
| 11. |
There are concerns about
the impact of the pilot plant on the environment as no
environmental impact assessment has been conducted. (click
here to see EPD's response) |
| 12. |
The heavy metals, including
beryllium, arsenic, chromium and cobalt emitted from the
stack should be individually monitored. The sampling and
analytical methods used for monitoring heavy metals should
be specified. Continuous emission monitoring of heavy
metal emissions from the stack is recommended. (click
here to see EPD's response) |
| 13. |
The emission of particulates
from the stacks should be monitored continuously. (click
here to see EPD's response) |
| 14. |
Continuous monitoring of
dioxins such as the AMESA system developed in Belgium
would give the most accurate and reliable measurement
of the emission of dioxins from the pilot plant. (click
here to see EPD's response) |
| 15. |
The exhaust gas may leak
from the main stack to the stack for lime cooling. Stack
monitoring of the latter should be the same as the former.
(click here to see EPD's response) |
Appendix
2 - EPD's response |
| 1.
Will the pilot plant cause air pollution and pollute
the environment? |
| 1.1 |
The by-products produced
from the pilot plant are mainly ash and air pollutants.
|
| 1.2 |
As the ash will either be
stored in totally enclosed systems or solidified followed
by proper landfill disposal, air pollution is the only
major residual environmental concern that needs to be
tackled. |
| 1.3 |
To evaluate the impact of
the pilot plant on air quality, computer model developed
by the United States Environmental Protection Agency has
been used and EPD's published guidelines
on the selection of computer models and model parameters
have been followed to predict the air quality under the
worst possible scenario. The modelling results show that
the emissions from the pilot plant will not have any unacceptable
impact on the attainment and maintenance of any relevant
air quality objective. |
| 2.
Will the release of heavy metals and dioxins from the
proposed pilot plant have adverse impact on health? |
| 2.1 |
The pilot plant is required
to comply with emission limits for heavy metals and dioxins
that are in line with the most stringent international
standards. |
| 2.2 |
A risk assessment has been
conducted to evaluate the health risk associated with
the potential carcinogenic air pollutants emitted from
the pilot plant including dioxins and heavy metals. The
total health risk is found to be 2 x 10-9 per
year which is lower than the acceptable risk level under
the Technical
Memorandum (TM) of the Environmental
Impact Assessment Ordinance (EIAO). The risk
assessment shows that emissions from the pilot plant should
not have any unacceptable impact on public health. |
| 3.
Will the release of heavy metals and dioxins from the
pilot plant have adverse impact on the ecology? |
| 3.1 |
As mentioned in section
1 above, air pollution is the only major residual
environmental concern. Any significant impact on the ecology
would only be caused by the air emissions from the pilot
plant. The computer air model has demonstrated that the
pilot plant will not have any unacceptable impact on the
attainment and maintenance of any relevant air quality
objective nor any unacceptable impact on public health
even under the worst case scenario. It is therefore unlikely
that the pilot plant will cause any unacceptable adverse
impact on the ecology due to its emissions. |
| 4.
Will the emissions from the pilot plant damage the
ozone layer? |
| 4.1 |
The air pollutants emitted
from the pilot plant do not contain any ozone depleting
substances specified under the Montreal
Protocol on Substances that Deplete the Ozone Layer.
It is unlikely that the emissions from the pilot plant
will cause damage to the ozone layer. |
5.
Is the plant too close to Tuen Mun? |
| 5.1 |
In assessing the impacts
of the pilot plant on air quality, the computer model
demonstrates that the relevant air quality objectives
in Tuen Mun area will not be violated and the calculated
total health risk is lower than the acceptable level under
the TM
of the EIAO.
It is therefore concluded that although the pilot plant
is located in Tuen Mun, it will not have any unacceptable
adverse environmental impacts on the local residents of
Tuen Mun. |
| 6.
What is the government's waste management policy and
its relationship with the pilot plant? |
| 6.1 |
The pilot plant is a research
project jointly undertaken by GIC and the HKUST. It does
not represent the direction towards which the Government's
policies on waste management and sustainable development
are proceeding. |
| 6.2 |
While the Government has
been promoting waste minimization, reuse and recycling,
there is still a large amount of waste which cannot be
recycled. In mid-2002, we invited international
waste management industry to express interest to provide
large-scale waste treatment technologies in Hong
Kong. An advisory committee comprising
mainly non-official members has been established to evaluate
the proposals received and advise Government on the type
of large-scale waste management facilities most suitable
for Hong Kong. The Government
will consult the public before making a final decision. |
| 7.
Will the pilot plant operation period be extended? |
| 7.1 |
The licence has been granted
with the condition that the total cumulative operation
period shall not be longer than 16 weeks. It will
be an offence if this licence condition is violated.
GIC have advised that it will not be economical to operate
a pilot plant of research scale for a long period of time
and they have no plan to extend the operation period. |
| 8.
Will the pilot plant incinerate more than 40 tonnes
of municipal waste? |
| 8.1 |
The licence has been granted
with the condition that the average daily amount of municipal
waste incinerated over any 3 consecutive days shall not
be more than 40 tonnes. It will be an offence if this
licence condition is violated. |
| 9.
What measures are in place to ensure that the air quality
assessment done by GIC is accurate and credible? |
| 9.1 |
GIC is required to comply
with EPD's guidelines
on the selection of computer models and model parameters
for air quality assessment. We have checked the assessment
submitted by GIC and are satisfied that the assessment
results are accurate and credible. Moreover, GIC's
air pollution control plan including the air quality assessment
had been made available for public inspection during the
public notification period. |
| 10.
What health impact will be caused by means other than
air pollution emitted from the pilot plant? |
| 10.1 |
As mentioned in section
1 above, air pollution is the only major residual
environmental concern. As the most stringent emission
standards have been imposed upon GIC and the assessment
has shown that the relevant air quality objectives will
not be violated, it is unlikely that food, which is mainly
imported, will be contaminated by the air pollutants emitted
from the pilot plant. |
| 11.
What are the impacts of the pilot plant on the environment? |
| 11.1 |
Under
the EIAO,
projects that could have adverse impact on the environment
are classified as designated projects and they are required
to conduct environmental impact assessments. |
| 11.2 |
The pilot plant is not a
designated project because of its small processing capacity,
which is less than 40 tonnes of municipal waste per day.
Moreover, it will only be in operation for a maximum of
16 weeks. Thus, the plant is unlikely to cause any
unacceptable environmental impact. |
| 11.3 |
As mentioned in section
1 above, air pollution is the only major residual
environmental concern that needs to be addressed in GIC's
licence application. The air quality assessment shows
that the pilot plant will not have any unacceptable impact
on the attainment and maintenance of any relevant air
quality objective or any impact on public health even
under the worst case scenario. |
| 12.
How will heavy metals be monitored? |
| 12.1 |
GIC will individually monitor
beryllium and all the heavy metals (including arsenic,
chromium and cobalt) listed in the best
practicable means for incineration. |
| 12.2 |
GIC
will use USEPA Method IO-3.1, 3.4 and 3.5 for sample
collection and to use inductively coupled plasma spectroscopy
or inductively coupled plasma mass spectroscopy for
sample analysis. At least one sample will be collected
per month.
|
| 12.3 |
GIC's proposal is comparable
with the international practices adopted for heavy metal
monitoring such as those in the United
States and Europe. |
| 12.4 |
Regarding continuous emission
monitoring of heavy metals, the emerging technologies
are still under laboratory research and trial development.
It is noted that with the exception of some prototype
systems, commercial grade products are still not available
in the market. |
| 13.
How will particulates be monitored? |
| 13.1 |
GIC will monitor continuously
the opacity which is widely regarded as an acceptable
surrogate for particulates monitoring. |
| 14.
How will dioxins be monitored and should AMESA system
be adopted? |
| 14.1 |
It is inappropriate to require
GIC to adopt a specific brand or product name in dioxins
monitoring. It is considered more appropriate to specify
the sampling and testing methods that are accepted internationally.
There are proven commercial products available in the
market. |
| 14.2 |
GIC will use USEPA Method
23 or CARB Method 428 to collect samples and gas chromatography-mass
spectroscopy to analyse the samples. At least one sample
will be collected per month. |
| 14.3 |
GIC's proposal is comparable
with the international practices adopted for dioxin monitoring
such as those in the United
States and Europe. |
| 15.
What measures will be adopted to prevent exhaust gas
leaking from the main stack to the stack for lime cooling?
|
| 15.1 |
The two stacks will be isolated by a tipping valve.
The pressure inside the stack for lime cooling is higher
than that of the main stack. The differential pressure
will draw air from the former to the latter and hence
close the tipping valve.
As such, leakage of exhaust gas during normal operation
is unlikely. |
| 15.2 |
The pressure at the two
sides of the tipping valve will be continuously monitored.
If the pressure inside the stack for lime cooling is lower
than that of the main stack, the operator will be required
to shut down the plant immediately. |
| Appendix
4 - EPD's response to other comments received |
| 1.
Will the pilot plant have adverse impact on the environmental
hygiene of Tuen Mun area? |
| 1.1 |
GIC will use enclosed refuse
collection vehicles to transport municipal waste to the
pilot plant. All the refuse collection vehicles will be
washed externally by disinfectant before leaving the pilot
plant. The waste will be processed inside an enclosed
compound. In addition, the licence will require
GIC to maintain in the pilot plant good housekeeping,
with which the plant should not cause any local environmental
hygiene problems. |
2.
Will the pilot plant have adverse impact on the employment
rate of the grass roots in Hong Kong? |
| 2.1 |
The
pilot plant will only handle 40 tonnes of waste per
day and the whole project will last for a cumulative
period of 16 weeks at the maximum. It is therefore unlikely
that the pilot plant will have any significant impact
on the employment market or affecting the employment
rate of the grass roots. |
| 3.
Will the pilot plant have adverse impact on the traffic
of Tuen Mun area? |
| 3.1 |
There will unlikely be any
adverse impact on the traffic of Tuen Mun area because
no more than 10 round trips of refuse collection vehicle
are required per day for transportation of waste to the
pilot plant. |
| 4.
How will EPD monitor the operation of the pilot plant
and stop the experiment when adverse effects become apparent? |
| 4.1 |
Before putting the pilot
plant into operation, GIC is required to verify to the
satisfaction of EPD its ability to use the best
practicable means for controlling emission of air
pollutants and to comply with all the terms and conditions
of the specified process licence. |
| 4.2 |
When the pilot plant is
in operation, GIC will be required to continuously monitor
the representative process parameters and the exhaust
gases to ensure that the emissions of air pollutants are
within the specified limits. All the continuous monitoring
data will be relayed continuously and instantaneously
to EPD's offices allowing EPD to keep the plant operation
under close surveillance. |
| 4.3 |
GIC has agreed to set up
a local environmental monitoring committee with 4 members
to be nominated by Tuen Mun District Council and 4 members
by GIC and HKUST. The plant operation will be subject
to public scrutiny. |
| 4.4 |
GIC is also required to
submit on a monthly basis to EPD a report of its environmental
monitoring results. |
| 4.5 |
EPD will take enforcement
actions, including stopping the plant operation, against
GIC if non-compliance with the licence terms and conditions
is confirmed. |
|