3. Air Quality

3.1. Introduction

3.1.1. This section presents the assessment of potential air quality impacts on air sensitive receivers (ASRs) arising from the construction and operation of the Project. Assessment has been conducted in accordance with criteria and guidelines as stipulated in Annex 4 and Annex 12 of the EIAO-TM as well as the requirements given in Clause 3.4.4 and Appendix B of the EIA Study Brief (No. ESB-362/2023).

3.1.2. The potential dust impact arising from dusty construction activities of the Project have been assessed and appropriate mitigation measures are proposed to alleviate any adverse air quality impact.

3.1.3. The potential operation air quality impact due to the proposed crematorium are associated with dust and gaseous emission from cremators. Cumulative impacts associated with other emission sources including chimney sources and vehicular emissions within the Assessment Area during the operation phase of the proposed crematorium are assessed.

3.2. Environmental Legislations, Standards and Guidelines

3.2.1. The relevant legislations, standards and guidelines applicable to the present study for the assessment of air quality impacts include:

· Technical Memorandum on Environmental Impact Assessment Process (EIAO-TM);

· Air Pollution Control Ordinance (APCO) CAP 311;

· A Guidance Note on the Best Practice Means for Specified Process (SP) – Incinerators (Crematoria) (BPM 12/2 (2020));

· Air Pollution Control (Construction Dust) Regulation;

· Air Pollution Control (Non-road Mobile Machinery) (Emission) Regulation;

· Air Pollution Control (Fuel Restriction) Regulations;

· Recommended Pollution Control Clauses for Construction Contracts;

· DEVB's TC No.13/2020, Timely Application of Temporary Electricity and Water Supply for Public Works Contracts and Wider Use of Electric Vehicles in Public Works Contracts; and

· DEVB's TC No.1/2015, Emissions Control of NRMM in Capital Works Contracts of Public Works.

3.2.2. The APCO provides a statutory framework for establishing the Air Quality Objectives (AQOs) and stipulating the anti-pollution requirements for air pollution sources. The AQOs stipulate concentration for a range of pollutants, amongst which carbon monoxide (CO), fine suspended particulates (FSP), respirable suspended particulates (RSP), nitrogen dioxide (NO₂) and sulphur dioxide (SO₂) are relevant to this study. The current AQOs in Hong Kong are summarized below in Table 3.1.

3.2.3. In addition, to attain the ultimate targets set under the World Health Organisation (WHO) Air Quality Guidelines (AQGs), the Government will review the Air Quality Objectives (AQOs) every five years in accordance with the law and assess the progress in improving air quality to aid deciding the AQOs for the next five-year period. The prevailing AQOs was updated and gazetted on 1 January 2022. In 2022, the Government has set up an AQOs Review Working Group to undertake a series of assessments and discussions to evaluate the air quality improvement and set the AQOs to be attained in 2030. The proposed new set of AQOs has undergone public consultation between Aug 2023 to Oct 2023 and is shown in Table 3.1 for reference. For conservative assessment purpose, both the prevailing and proposed AQOs would be assessed in this impact study.

Table 3.1 Prevailing and Proposed Hong Kong Air Quality Objectives

Pollutant	Averaging Time	Prevailing AQOs		Proposed New AQOs
Pollutant	Averaging Time	Concentration Limit (μg/m³)^[ⁱ^]	Number of Exceedances Allowed per Year	Concentration Limit (μg/m³)^[ⁱ^]	Number of Exceedances Allowed per Year
Sulphur Dioxide (SO₂)	10-minute	500	3	500	3
Sulphur Dioxide (SO₂)	24-hour	50	3	40	3
Respirable Suspended Particulates (RSP) ^[ii]	24-hour	100	9	75	9
Respirable Suspended Particulates (RSP) ^[ii]	Annual	50	N/A	30	N/A
Fine Suspended Particulates (FSP) ^[iii]	24-hour	50	18 [iv]	37.5	18
Fine Suspended Particulates (FSP) ^[iii]	Annual	25	N/A	15	N/A
Nitrogen Dioxide (NO₂)	1-hour	200	18	200	18
	24-hour	-	-	120	9
	Annual	40	N/A	40	N/A
Ozone (O₃)	8-hour	160	9	160	9
Ozone (O₃)	Peak Season	-	-	100	N/A
Carbon Monoxide (CO)	1-hour	30,000	0	30,000	0
	8-hour	10,000	0	10,000	0
	24-hour	-	-	4,000	0
Lead (Pb)	Annual	0.5	N/A	0.5	N/A
Notes: [i]. All measurements of the concentration of gaseous air pollutants, i.e. sulphur dioxide, nitrogen dioxide, ozone and carbon monoxide, are to be adjusted to a reference temperature of 293 Kelvin and a reference pressure of 101.325 kilopascal. [ii]. Respirable suspended particulates mean suspended particles in air with a nominal aerodynamic diameter of 10 μm or less. [iii]. Fine suspended particulates mean suspended particles in air with a nominal aerodynamic diameter of 2.5 μm or less. [iv]. The number of allowable exceedances is 18 for government projects, and 35 for non-government projects.

3.2.4. According to EPD’s BPM 12/2 (2020)), which specifies specific design standards for cremators as well as stipulates emission limits of a number of pollutants associated with the cremation process, the key air pollutants emitted from the cremator include particulates, nitrogen dioxide (NO₂), ammonia (NH₃), total organic carbon (TOC), hydrogen chloride (HCl), carbon monoxide (CO), mercury (Hg) and dioxin.

3.2.5. Ammonia, which has an emission limit prescribed in BPM 12/2 (2020) in the case where urea or ammonia is used as a reagent in the De-NOx system of the cremators, has potential concern for causing odour impact. Therefore, in accordance with Annex 4 of EIAO-TM, odour impact assessment shall be conducted for ammonia emission, with the assessment criteria based on the limit of 5 odour units per an averaging time of 5 seconds at any air sensitive receivers. According to the Ammonia Fact Sheet, AERISA and previous EIA reports, ammonia has a detectable odour threshold of 0.037ppm (or 0.0259 mg/m³ at 25 degree Celsius). Hence one odour unit of ammonia of 0.0259 mg/m³ shall be adopted for the odour impact assessment.

3.2.6. For pollutants that are not covered by AQOs (i.e. NH3, TOC, HCl, Hg, dioxin), references have been made to the relevant international standards/guidelines and previous EIA reports for crematoria in Hong Kong approved under the EIAO as appropriate for establishing the relevant assessment criteria, which include inhalation exposure thresholds and inhalation unit risk for cancer. The relevant documents include:

· Air Quality Guidelines for Europe, 2000, by the World Health Organization (WHO);

· Air Toxics Hot Spots, by the California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA);

· Integrated Risk Information System (IRIS), 1995, by the United State Environmental Protection Agency (USEPA);

· Reference Exposure Levels, 2019, by the OEHHA.

· Approved EIA Report for Wo Hop Shek Crematorium, i.e. the existing one (AEIAR-119/2008); and

· Approved EIA Report for Cape Collinson Crematorium (AEIAR-137/2009).

3.2.7. According to OEHHA, the Inhalation Unit Risk (IUR) is an estimate of the increased cancer risk resulting from continuous inhalation exposure to a concentration of 1 µg/m³ of the carcinogen for a lifetime of 70 years. The cancer risk is then determined by multiplying the IUR with the long-term incremental inhalation exposure concentration of the carcinogen. It is considered acceptable if the incremental cancer risk is less than 1 chance in a million (i.e. 1 x 10^-6). For the air pollutants emitted due to this Project, dioxin is considered carcinogenic with an IUR of 38 (ug/m³)^-1 as indicated by OEHHA. To assess its incremental lifetime cancer risk, the dioxin IUR will be multiplied by the annual dioxin concentrations predicted in this study in order to determine its incremental lifetime cancer risk.

3.2.8. The list of proposed assessment criteria for both AQO and other pollutants in this Study is listed in Table 3.2 below.

Table 3.2 Assessment Criteria for Air Quality Impact Study

Pollutant	Averaging Time	Concentration Limit (μg/m³) ^[1]	No. of Annual Exceedances Allowed	Reference
Hong Kong AQOs
Sulphur dioxide (SO₂)	10-minute	500	3	Hong Kong AQO
Sulphur dioxide (SO₂)	24-hour	50 (40)	3
Respirable suspended particulates (RSP) ^[2]	24-hour	100 (75)	9
Respirable suspended particulates (RSP) ^[2]	Annual	50 (30)	N/A
Fine suspended particulates (FSP) ^[3]	24-hour	50 (37.5)	18 ^[4]
Fine suspended particulates (FSP) ^[3]	Annual	25 (15)	N/A
Nitrogen dioxide (NO₂)	1-hour	200	18
	24-hour	(120)	9
	Annual	40	N/A
Carbon monoxide (CO)	1-hour	30,000	N/A
	8-hour	10,000	N/A
	24-hour	4,000	N/A
Noncancer Inhalation Exposure Levels
Hydrogen chloride (HCl)	1-hour	2100	N/A	OEHHA ^[5]
	Annual	20	N/A	USEPA IRIS ^[6]
	Annual	9	N/A	OEHHA ^[7]
Mercury (Hg)	1-hour	0.6	N/A	OEHHA ^[5]
	Annual	1	N/A	WHO ^[8]
		0.3	N/A	USEPA IRIS ^[6]
		0.03	N/A	OEHHA ^[7]
Ammonia (NH₃)	1-hour	3,200	N/A	OEHHA ^[5]
	Annual	500	N/A	USEPA IRIS ^[6]
	Annual	200	N/A	OEHHA ^[7]
Dioxin ^[9]	Annual	40 pg I-TEQ/m³	N/A	OEHHA ^[7]
Total organic carbon (TOC) ^[10]	1-hour	N/A	N/A	N/A
Total organic carbon (TOC) ^[10]	Annual	N/A	N/A	N/A
Odour Impact
Ammonia (NH₃)	5-seconds	5 Odour Units	N/A	AERISA ^[12]
Incremental Inhalation Cancer Risk
Dioxin	Lifetime	Inhalation Unit Risk of 38 (μg/m³)^-1	N/A	OEHHA ^[11]
Notes: [1]. Values in ug/m³ unless specified. For values under “Hong Kong AQOs” heading, those in bracket denote proposed AQOs limits. [2]. Respirable suspended particulates mean suspended particles in air with a nominal aerodynamic diameter of 10 μm or less. [3]. Fine suspended particulates mean suspended particles in air with a nominal aerodynamic diameter of 2.5 μm or less. [4]. The number of allowable exceedances is 18 for government projects, and 35 for non-government projects. [5]. Acute Reference Exposure Level, California OEHHA [6]. Reference Concentration for Inhalation Exposure, IRIS, USEPA [7]. Chronic Reference Exposure Level, California OEHHA [8]. Air Quality Guidelines for Europe, Second Edition, 2000, WHO [9]. Expressed as chlorinated dibenzo-p dioxins and dibenzofurans. [10]. No relevant criteria are available for TOC. Hence the assessment results will be presented for reference purpose only. [11]. Refer to Section 3.2.7. [12]. Refer to Section 3.2.5.

3.3. Baseline Conditions

Existing Ambient Air Quality

3.3.1. The nearest air quality monitoring station (AQMS) is the North AQMS. Since the North AQMS was commissioned in 2020, only data between 2020-2023 is available at the AQMS. The next closest AQMS is the Tai Po AQMS, which is also considered representative of the conditions at the Project Site. For completeness, Table 3.3 summarises the air quality monitoring data between 2019 and 2023 at the North AQMS and Tai Po AQMS.

Table 3.3 Air Quality Monitoring Data at Tai Po and North Station (2019-2023)

Pollutants		Parameter	Concentrations (μg/m³)					Prevailing AQO (μg/m³) ^[3]
Pollutants		Parameter	2019	2020	2021	2022	2023	Prevailing AQO (μg/m³) ^[3]
SO₂	Tai Po AQMS	4^th highest 10-minute	20	19	15	12	27	500 (3)
	North AQMS	4^th highest 10-minute	-	19	18	27	27	500 (3)
	Tai Po AQMS	4^th highest 24-hour	10	7	8	5	4	50 (3)
	North AQMS	4^th highest 24-hour	-	8	7	-	7	50 (3)
RSP (PM₁₀)	Tai Po AQMS	10^th highest 24-hour	65	58	60	48	23	100 (9)
	North AQMS	10^th highest 24-hour	-	55	62	50	57	100 (9)
	Tai Po AQMS	Annual	31	24	26	21	25	50
	North AQMS	Annual	-	-	25	23	27	50
FSP (PM_2.5)	Tai Po AQMS	19^th highest 24-hour	41	33	32	30	30	50 (18) ^[3]
	North AQMS	19^th highest 24-hour	-	29	29	28	28	50 (18) ^[3]
	Tai Po AQMS	Annual	20	15	16	-	15	25
	North AQMS	Annual	-	-	15	-	15	25
NO₂	Tai Po AQMS	19^th highest 1-hour	142	106	115	93	95	200 (18)
	North AQMS	19^th highest 1-hour	-	112	135	115	116	200 (18)
	Tai Po AQMS	Annual	36	30	32	27	27	40
	North AQMS	Annual	-	-	36	31	30	40
O₃	Tai Po AQMS	10^th highest 8-hour	197	165	168	188	163	160 (9)
O₃	North AQMS	10^th highest 8-hour	-	166	187	197	164	160 (9)
CO	Tai Po AQMS	Max. 1-hour	-	-	-	-	-	30,000
	North AQMS	Max. 1-hour	-	1,830	2,150	1,710	2,390	30,000
	Tai Po AQMS	Max. 8-hour	-	-	-	-	-	10,000
	North AQMS	Max. 8-hour	-	1,238	1,550	1,304	1,231	10,000

Notes:

1. Data Source: EPD - Air Quality Reports - Annual Air Quality Monitoring Results (http://www.aqhi.gov.hk/en/download/air-quality reportse469.html)

2. Numbers in bracket showing allowable number of exceedance.

3. 18 exceedances of 24-hour FSP allowed for new government projects.

4. Monitoring results exceeding the prevailing AQOs during the monitoring period are in bold and underlined.

3.3.2. Except for exceedances in ozone from 2019-2023, which is more a regional issue of the Pearl River Delta area, all other air pollutants fall below the AQOs which were effective during the monitoring period.

3.3.3. For the non AQO-criteria pollutants of ammonia, dioxin, mercury, total organic carbon and hydrogen chloride, the highest annual and short-term monitoring concentrations for the past 5 available years from 2018-2022 at the nearest station (i.e. Yuen Long Station for HCl, Hg, NH₃, TOC, Tsuen Wan Station for dioxin) were adopted as the background. There is no direct measurement for HCl, Hg, NH₃, TOC and thus the values of chloride ion, mercury, ammonium ion and total carbon were adopted as the background concentrations. The monitoring results are summarized in Table 3.4 below.

Table 3.4 Background Concentrations of Other Pollutants (2018 – 2022)

Pollutant	Annual Average Concentration					Maximum Annual Concentration ^[1]
Pollutant	2018	2019	2020	2021	2022	Maximum Annual Concentration ^[1]
Dioxin (pg I-TEQ/m³)	0.03	0.018	0.014	0.018	0.011	0.03 pg I-TEQ/m³
Mercury (ng/m³)	0.18	0.17	0.14	0.15	0.16	0.18 ng/m³
Total Carbon (ng/m³)	6,799	6,441	5,602	6,584	5,574	6,799 ng/m³
Chloride Ion (ng/m³)	408	508	518	374	498	518 ng/m³
Ammonium Ion (ng/m³)	1,891	1,814	1,286	1,463	1,210	1,891 ng/m³
Pollutant	Maximum Daily Concentration					Maximum Short-term Concentration ^[2]
Pollutant	2018	2019	2020	2021	2022	Maximum Short-term Concentration ^[2]
Dioxin (pg I-TEQ/m³)	N/A	N/A	N/A	N/A	N/A	N/A ^[3]
Mercury (ng/m³)	0.205	0.195	0.175	0.18	0.18	0.205 ng/m³
Total Carbon (ng/m³)	16,100	22,000	16,350	18,700	13,500	22,000 ng/m³
Chloride Ion (ng/m³)	2,400	2,900	3,000	2,000	3,700	3,700 ng/m³
Ammonium Ion (ng/m³)	6,300	5,914	5,014	7,843	6,043	7,843 ng/m³

Notes:

[1]. Airbone species concentrations are measured from RSP samples, according to data taken from Yuen Long monitoring station at EPD website “Summary of Annual Concentration of Airborne Species Derived from RSP” (https://www.aqhi.gov.hk/en/download/air-quality-reports0c72.html). The dioxins concentrations are measured at the Tsuen Wan monitoring station at EPD website (https://www.aqhi.gov.hk/en/download/air-quality-reportsf0e5.html).

[2]. Airbone species concentrations are measured from RSP samples, according to data taken from Yuen Long monitoring station at EPD website “Summary of Daily Concentration of Airborne Species Derived from RSP in the past five years” (https://www.aqhi.gov.hk/en/download/air-quality-reports0c72.html).

[3]. No short-term dioxin concentration is applicable for this Project since short-term impact of dioxin is not assessed.

Predicted Future Background Air Quality

3.3.4. Apart from the EPD AQMS monitored data, EPD also provide a set of background concentrations for key pollutants in the “Pollutants in the Atmosphere and their Transport over Hong Kong”, PATH model (PATH v3.0). Given that the proposed Project would begin construction in Year 2026 and are planned for completion by Year 2030, the background air quality predicted by PATH v3.0 for Year 2030 will be adopted for the quantitative assessment as it is considered conservative and closest to the opening year.

3.3.5. The air quality impact within 500 m from the Project Boundary would be assessed. As shown in Figure 3.1, the 500m assessment area for this Project is covered by the PATH grids (37,50), (37,51), (38,50), (38,51). The predicted Year 2030 background concentrations at these grids are summarized in Table 3.5 and compared against the prevailing and proposed AQOs.

Table 3.5 Background Air Pollutant Concentrations Predicted by the PATH v3.0 Model in Year 2030

Pollutant	Averaging Time	Concentrations (μg/m³)^[^2]				Prevailing AQOs (μg/m³)	Proposed AQOs (μg/m³)
Pollutant	Averaging Time	(37,50)	(37,51)	(38,50)	(38,51)	Prevailing AQOs (μg/m³)	Proposed AQOs (μg/m³)
SO₂	10-minute (4^th highest)	26	28	25	28	500	-
SO₂	24-hour (4^th highest)	7	7	7	6	50	40
RSP (PM₁₀)	24-hour (10^th highest)	53	51	54	52	100	75
RSP (PM₁₀)	Annual	20	20	21	20	50	30
FSP (PM_2.5)	24-hour (19^th highest) ^[1]	31	30	34	32	50	37.5
FSP (PM_2.5)	Annual	13	12	13	13	25	15
NO₂	1-hour (19^th highest)	47	51	56	57	200	-
	24-hour (10^th highest)	18	19	21	22	-	120
	Annual	12	12	13	12	40	-
O₃	8-hour (10^th highest)	170	174	169	167	160	-
CO	1-hour	530	534	545	537	30,000	-
	8-hour	487	494	505	503	10,000	-
	24-hour	453	458	463	457	-	4,000

Notes:

[1] 18 exceedances of 24-hour FSP allowed for new government projects.

[2] Results exceeding the prevailing and the proposed AQOs are in bold and underlined.

3.4. Identification of Air Sensitive Receivers

3.4.1. In accordance with Annex 12 of the EIAO-TM, Air Sensitive Receivers (ASRs) include any domestic premises, hotel, hostel, hospital, clinic, nursery, temporary housing accommodation, school, educational institution, office, factory, shop, shopping centre, place of public worship, library, court of law, sports stadium or performing arts centre shall be considered to be air sensitive receiver. Places/premises in which exposure is transient in nature (for example, cycle track, pedestrian walkway, bus stop, mini-bus stop, and taxi stand) are not considered to be air sensitive receivers. Any other premises or place with which, in terms of duration or number of people affected, has a similar sensitivity to the air pollutants as the aforelisted premises and places shall also be considered to be a sensitive receive.

3.4.2. Both existing and planned representative ASRs within a distance of 500m from the Project Boundary have been identified. Existing ASRs are identified by means of reviewing topographic maps, aerial photos, supplemented by site inspections.

3.4.3. Air Sensitive Receivers (ASRs) within the Assessment Area have been identified in accordance with Annex 12 of the Technical Memorandum on Environmental Impact Assessment Process (EIAO-TM). Representative ASRs and their assessment heights up to the building height (if applicable) are summarized in Table 3.6 below. Locations of the representative ASRs are shown in Figure 3.1.

Table 3.6 Representative ASRs within 500m Assessment Area

ASR ID	ASR Description	Type of Use^[1]	Assessment Heights to Top of Building(mAG) ^[2]	Approximate Separation Distance from Project Site Boundary (m)
A01	Cheung Kee Stoneworks	O/R^[^3]	1.5, 5, 10	450
A02	Kin Fuk Stone Factory	F	1.5	412
A03	Temporary Structure	O	1.5	451
A04	Village House No. 168, Nam Wa Po	R	1.5, 5, 10	421
A05	Village House No. 50A, Nam Wa Po	R	1.5, 5, 10	365

Notes:

[1] F = Factory, O = Office, R = Residential. All ASRs are existing ASRs.

[2] mAG = metres above local ground

[3] Mixed-use 3-storey building

3.5. Construction Phase Impact Assessment

3.5.1. The construction of the proposed crematorium would involve the following main activities:

· Site clearance, site formation works and slope upgrading works;

· Foundation works;

· Superstructure works; and

· Landscaping works and other associated works.

3.5.2. The potential air quality impact would be fugitive dust emissions associated with site clearance and construction activities such as open cut, material handling and transportation and wind erosion of open area. Operation of diesel-powered construction equipment and machineries may also emit gaseous and particulate pollutants such as nitrogen dioxide (NO₂), sulphur dioxide (SO₂) and smoke.

3.5.3. The works area for demolition of existing coffin burial terraces is 7,190 m² and for demolition of existing access road is approximately 862 m². The site formation area and Excavation and Lateral Support (ELS) area are 15,110 m² and 12,420 m², respectively. Given the project area is relatively small and no deep excavation is needed, the excavated material from site clearance and site formation works would be relatively small. About 254,000 tonnes of inert construction and demolition (C&D) materials and 7,950 m³ of non-inert C&D materials will be excavated.

3.5.4. Dump trucks would be required for transportation of excavated material from site formation works, with a maximum of 21 dump trucks required per day. Before leaving the Project Site, dump truck loaded with excavated material would be covered entirely to ensure that dusty material would not leak from the dump truck according to the APCO requirement. In case temporary stockpiling of small amount of dusty material is required, the stockpile will be covered by tarpaulin sheets or placed in an area sheltered on the top and the 3 sides. The mitigation measures described in Section 3.5.12 would also be implemented during the construction phase to minimise impacts on air quality on nearby ASRs.

3.5.5. Furthermore, due to the small site area and limited space for construction works, it is anticipated that less than 20 number of construction plant would be in operation during each construction activity. Therefore, the potential gaseous emissions from these plant and equipment are expected to be minimal and unlikely to cause adverse air quality impacts.

3.5.6. With the implementation of the hourly watering on site and dust suppression measures stipulated in the Air Pollution Control (Construction Dust) Regulation, Air Pollution Control (Non-road Mobile Machinery) (Emission) Regulation and Air Pollution Control (Fuel Restrictions) Regulations, good site practices proposed in Section 3.5.12, no adverse fugitive dust impacts during the construction phase are anticipated. The Contractor will be required to properly maintain the construction plant in a good condition to prevent exhaust emissions. Wherever possible, connection to the main power supply should be considered to minimize the need for use of diesel fuel generator.

3.5.7. Fuel combustion from the use of Powered Mechanical Equipment (PME) during construction works is also a source of particulates, NOx, SO₂ and CO. However, the number of such equipment required on-site will be limited under normal operation. Limited smoke and gaseous emissions would be generated from equipment with proper maintenance. In addition, according to DEVB’s TC No. 1/2015 Emissions Control of NRMM in Capital Works Contracts of Public Works and the Air Pollution Control (Non-road Mobile Machinery (NRMM)) (Emission) Regulation, starting from 1 December 2015, only approved or exempted NRMMs with a proper label are allowed to be used in specified activities and locations including construction sites. The Contractor is required to ensure the adopted machines or non-road vehicle under the Project could meet the prescribed emission standards and requirement. In addition, legal control is imposed on the types of fuels allowed for use and their sulphur contents in commercial and industrial processes under the Air Pollution Control (Fuel Restriction) Regulations. To control the exhaust emissions from construction plant and equipment, the sulphur content of liquid fuel shall not exceed 0.005%. Hence, with the implementation of the said Regulation, the emissions from PMEs are considered relatively low, no adverse air quality impact and odour impact to the surrounding ASRs is expected.

3.5.8. According to DEVB’s TC No. 13/2020 Timely Application of Temporary Electricity and Water Supply for Public Works Contract and Wider Use of Electric Vehicles in Public Works Contracts, timely provision of electricity could help reduce carbon emission arising from operation of diesel generators at the construction sites. At the detailed design stage, project team should timely apply for the temporary electricity with a target that the necessary cables laying works could be completed before the commencement of the works contract. In addition, timely provision of electricity to construction sites can facilitate the use of Electric Vehicles (EVs) in public works contracts. The Project team should specify the use of EV(s) as well as the installation of designated medium-speed charger for each EV as a standard provision at the site accommodation in public works contracts.

3.5.9. Furthermore, the Contractor should also adhere to the general requirements under EPD’s Recommended Pollution Control Clauses for Construction Contracts to further minimize emission of air pollutants from construction plant and fugitive dust emissions from construction activities.

3.5.10. As such, the air quality impacts due to generation of fugitive dust and exhaust emissions from the proposed construction activities are anticipated to be minor.

3.5.11. Based on EPD’s latest PATH model results (Year 2030) as shown in Table 3.5, the background maximum annual average RSP and FSP concentration is predicted to be 21 µg/m³ and 13 µg/m³, which is well below the respective AQO of 50 µg/m³ and 25 µg/m³ by about 58% margins and 48% margins respectively. The maximum daily average RSP and FSP concentration is predicted to be 54 µg/m³ and 34 µg/m³, which is well below the respective AQO of 100 µg/m³ and 50 µg/m³ by about 46% margins and 32% margins, respectively. In view of the lower background pollutant levels and the implementation of the dust control measures under APCO, dust emissions from the proposed construction works would be well controlled.

Mitigation Measures

3.5.12. Dust suppression measures, including watering once per hour, will be incorporated in accordance with the requirements of the Air Pollution Control (Construction Dust) Regulation. The contractor should also implement sufficient dust suppression measures as stipulated under the Air Pollution Control (Construction Dust) Regulation and good site practices wherever applicable, to limit the dust emissions generated. The following mitigation measures would be implemented during the construction phase to minimise impacts on air quality on nearby ASRs.

· In the process of material handling, any material which has the potential to create dust will be treated with water or sprayed with a wetting agent where practicable;

· Any vehicles with an open load compartment used for transferring dusty materials off-site will be properly fitted with side and tail boards and cover;

· Stockpiles of sand and aggregate will be enclosed on three sides and water sprays will be used to dampen stored materials and when receiving raw material;

· The construction site will be frequently cleaned and watered once per hour to minimise fugitive dust emissions;

· Motorised vehicles on the construction site will be restricted to a maximum speed of 15 km/hr and shall be confined to designated haul routes which will be paved;

· Provide electric power supply for on-site machinery as far as practicable and diesel generators and machinery shall be avoided to minimize the gaseous and particulate emissions;

· Locate all the dusty activities away from any nearby ASRs as far as practicable;

· Erect higher hoarding at the locations with ASRs in immediate proximity to the project boundary;

· Consider using cleaner dump trucks (compliant with more stringent emission standards such as Euro VI) during the construction; and

· Use of appropriate dust suppression measures.

Concurrent Projects

3.5.13. As discussed in Section 2.10, the concurrent projects have been identified, with their locations shown in Figure 2.6. The projects include:

- Provision of Columbarium at Wo Hop Shek – Phase 2,

- Provision of Columbarium at Wo Hop Shek – Phase 3,

- Provision of Columbarium at Wo Hop Shek – Phase 4,

- Road Improvement Works at Wo Hop Shek Cemetery for Phases 2 and 3 Columbarium Development, and

- Utilities Improvement Works connecting to Kiu Tau Road

3.5.14. Among the above projects, Provision of Columbarium at WHS Phase 3 is located more than 600m away from the proposed WHS Crematorium, and significant cumulative construction dust impact with the latter is therefore not anticipated.

3.5.15. Due to the short distances, Provision of Columbarium at the WHS - Phases 2 and Road Improvement Works at WHS Cemetery for Phases 2 and 3 Columbarium Development together with the Utilities Improvement Works connecting to Kiu Tau Road have the potential to cause cumulative construction dust impact, as their planned construction periods overlap with that of this Project.

3.5.16. For each of the concerned concurrent projects, proper mitigation measures including watering frequently and good site practice will be implemented to ensure that their construction activities would not cause adverse construction dust impacts. Therefore, adverse cumulative construction dust impact arising from construction activities of the concurrent projects of concern are not anticipated.

3.5.17. The traffic forecast for operation phase impact has also taken into account the induced traffic from the concerned concurrent projects (see Section 3.6 for details).

3.6. Operation Phase Impact Assessment

3.6.1. Identification of Emission Sources

3.6.1.1. The sources of air pollution within the Assessment Area during the operation phase of the Project are listed below and shown in Figure 3.2.

Project induced contributions (Tier 1)

· Stack emissions from the Project, including the proposed cremators and joss paper burners;

Pollutant-emitting activities within Assessment Area (Tier 2)

· Stack emissions from the existing WHS Crematorium, including cremators and joss paper burners;

· Joss paper burner emissions from the existing WHS Columbarium Phase II, IV, V and VI Block A;

· Joss paper burner emissions from the planned concurrent project for Provision of Columbarium at WHS Phase 2;

· Industrial emissions from existing plastics recycling plant at Ming Yin Road;

· Vehicular emissions from existing and planned roads including running and start emissions (e.g. Kiu Tau Road, Ming Yin Road, Wo Hop Shek Road);

Other emission sources not accounted for in Tier 1 and Tier 2 (Tier 3)

· The background concentrations shall be predicted using the regional scale model “Pollutants in the Atmosphere and their Transport over Hong Kong” (PATH v3.0); and

· There are no other far-field major point sources identified within 4km of the Project Site. Note that the existing WHS Crematorium is itself considered a 4km major point source by EPD, but is included as Tier 2 emission source since it is also within the 500m Assessment Area.

3.6.1.2. According to A Guidance Note on the Best Practicable Means for Specified Process - Incinerators (Crematoria) (BPM 12/2 (2020)) published by EPD, the key air pollutants from the cremation process include particulates, nitrogen dioxide (NO₂), total organic carbon (TOC), hydrogen chloride (HCl), carbon monoxide (CO), ammonia (NH₃), mercury (Hg) and dioxin.

3.6.1.3. The main air pollutant from joss paper burners (JPB) would be particulate matters in the form of ash flakes. For the proposed joss paper burners for the Project, as well as the JPBs in the planned concurrent projects and existing WHS Columbarium Phase V and VI Block A mentioned in Section 3.6.1.1 above, they are designed in accordance with EPD’s “Guidelines on Air Pollution Control for Joss Paper Burning at Chinese Temples, Crematoria and Similar Places”. With the adoption of proper flue gas treatment technology including water scrubbers and electrostatic precipitators and other administrative measures, the air quality impact due to operation of these JPBs is anticipated to be insignificant. For the JPBs in the existing WHS Columbarium Phase II and IV, they are not installed with flue gas treatment equipment. Nevertheless, as the nearest ASRs are located about 400m away, the air quality impact from these JPBs on the nearest ASRs is also considered to be insignificant.

3.6.1.4. The main air pollutants coming from the waste plastics recycling plant would be particulate matters and volatile organic compounds (VOCs) that are emitted via the plastic moulding, extrusion and cutting processes.

3.6.1.5. The key pollutants due to vehicular emissions include nitrogen dioxide (NO₂), respirable suspended particulates (RSP) and fine suspended particulates (FSP).

3.6.2. Assessment Methodology

3.6.2.1. The operation phase air quality impact of the Project has been conducted with reference to EPD’s Guidelines on Assessing the 'TOTAL' Air Quality Impacts. Refer to the following sections for the detailed methodology.

Stack Emissions from the Project (Tier 1)

3.6.2.2. The emissions from the proposed cremators from the Project shall be assessed quantitively. For emissions from the proposed cremators at the Project, a literature review of overseas emission rates has been made as indicated in Table 3.7. Note that the standards for Australia are considered much more lenient compared to the emission limits from all other regions/ countries, whilst the emission limits prescribed by the United States Environmental Protection Agency (USEPA) and the European Union (EU) are in terms of emissions per body cremated and cannot be directly compared to other concentration-based standards (e.g. mg/m³). Hence the above standards are only shown as reference only.

3.6.2.3. For SO2, which is an AQO pollutant, no limit is given in the EPD BPM 12/2 (2020). Upon review of available international regulations on cremator emission (i.e. Australia, China, EU, UK, US), it is noted that only the Ministry of Ecology and Environment of the People’s Republic of China (中華人民共和國生態環境部) has prescribed emission limit for SO2 in the publication “火葬場大氣污染物排放標準” (GB13801-2015), whilst the EU and US have SO2 limits in terms of emission per body cremated, which is not directly comparable with the concentration units in BPM 12/2 (2020). Therefore, the SO2 limit stipulated in GB13801-2015 shall be used as the emission concentration for the proposed cremators for this Project.

Air Pollutants ⁽¹⁾	Averaging Period ⁽²⁾	Emission Limits in BPM 12/2(2020)	Emission Limits from existing crematoria in HK	Overseas Emission Limits	Proposed Emission Limits for this Study
Particulates (as PM₁₀)	1-hour	20	20/40	20	RSP: 7.34	20	250	30	80	20
FSP: 3.67
Organic compounds (as total organic carbon)	1-hour	20	20	20	20	20	226	-	-	20
Hydrogen chloride	1-hour	30	30	30	23.6	30	200	30	50	30
Carbon monoxide	1-hour	100	100	100	100	100	150	150	200	100
Ammonia ⁽⁹⁾	1-hour	7	-	-	-	-	-	-	-	7
Mercury	Process-specific	0.05	0.05	0.05	0.03	0.05	3	0.1	-	0.05
Dioxins (as ng I-TEQ/m₃) ⁽¹⁰⁾	0.1	0.1	0.1	0.1	0.1	-	0.5	1.0	0.1
Nitrogen oxide (as nitrogen dioxide)	1-hour	200	N/A⁽¹⁴⁾	380 ⁽¹¹⁾	282	-	500 (as NO_x)	200	300	200
Sulphur dioxide	1-hour	-	180 ⁽¹²⁾	180 ⁽¹²⁾	180 ⁽¹²⁾	-	-	30 ⁽¹³⁾	100 ⁽¹³⁾	100
Reference Conditions	273K, 101.325 kPa, 11% oxygen, Dry.	273.1K, 101.3 kPa, 11% oxygen, Dry.	273.1K, 101.3 kPa, 7% oxygen, Dry, 12% CO₂ (for PM)	273.15K, 101.325 kPa, 11% oxygen, Dry.	273.1K, 101.325 kPa, 11% oxygen, Dry.

3.6.2.4. As shown in Table 3.7, the emission concentration limits stipulated in EPD’s BPM 12/2 (2020) are found to be the most stringent compared to overseas limits and shall be adopted as the emission limits of the proposed cremators due to technical concern and market availability of the cremators. Nonetheless, the feasibility of adopting lower emission limits would be explored at a later stage of the project when more design details are available (e.g. during application for a SP licence).

3.6.2.5. The emission rates for the 10 no. proposed cremators at the Project site are based on the flue gas properties and stack parameters provided by Project Proponent. They are shown in Table 3.8 below. Detailed calculations as well as location plan for the cremator stacks are shown in Appendix 3.7. The normal operating hours are from 08:30 to 23:00 and have been adopted as such in the air model. Nevertheless, FEHD advised that there have been cases where 24-hour continuous cremation operation at the existing WHS Crematorium is required during emergency such as the shutdown of other crematorium due to extreme weather. Emergency situations only happen under extreme circumstances (e.g. black rainstorm), such as when there was flooding in Chai Wan Road which took about 1-2 days to clear up and affected the operation of Cape Collision Crematorium. Therefore, these occasional operational changes have a minimal impact to long term pollutant concentrations (e.g. annual average values) as these events are rare over an annual period. On the other hand, the emergency situations would have significant impacts to short term pollutant concentrations (e.g. hourly and daily average values) because the impact of increasing operation hours would be reflected in the short-term pollutant concentration. To cater for these worst-case scenarios, the short-term air quality impact (10-minute, 1-hour, 24-hour averages) has also been assessed for the emergency scenario, during which the proposed cremators will operate continuously for 24 hours whilst the cremators in the existing WHS Crematorium will operate within the normal operating hours of 08:30 to 23:00. Note that the cremation capacity of the standard cremator is 170kg per cycle, and that of the large cremator is 250kg per cycle.

Table 3.8 Emission Rates for Proposed Cremators

	Discharge Parameters for Proposed Cremators
	Large Cremator (250kg/cycle)	Standard Cremator (170kg/cycle)
	Flue Gas and Stack Parameters
Number of furnaces	1 no.	9 no.
Exhaust type	Individual vertical exhaust	Individual vertical exhaust
Stack height above ground	30 m above ground	30 m above ground
Flue gas temperature ⁽¹⁾	379K	403K
Flue gas oxygen % ⁽¹⁾	15.2	15.1
Flue gas moisture % ⁽¹⁾	8.4%	9.4%
Flue gas flow rate ⁽¹⁾ (actual condition)	3474 m³/hour	2807 m³/hour
Stack exit diameter ⁽²⁾	0.33 m	0.29 m
Flue gas exit velocity⁽³⁾	11.3 m/s	11.8 m/s
Air Pollutants	Derived Emission Rate (g/s)
NOx as NO₂	7.33E-02	5.61E-02
RSP ⁽⁴⁾	7.30E-03	5.60E-03
FSP ⁽⁴⁾	7.30E-03	5.60E-03
TOC	7.30E-03	5.60E-03
HCl	1.10E-02	8.40E-03
CO	3.67E-02	2.80E-02
Hg	1.80E-05	1.40E-05
Dioxin	3.67E-11	2.80E-11
SO₂	3.66E-02	2.80E-02
NH₃	2.60E-03	2.00E-03
Notes: 1. Flue gas properties are based on stack monitoring results for Cape Collinson Crematorium. 2. Internal diameter of cremator chimney stack is provided by Project Proponent based on Cape Collinson Crematorium design. 3. Exit velocity is derived from actual flow rate divided by stack inner exit area. Minimum velocity is 10m/s as per BPM 12/2(2020). 4. BPM 12/2(2020) Limit is for TSP, and here it is assumed to be both RSP and FSP for conservative assessment purpose.

3.6.2.6. During the operation of the Project, odour nuisance generated from the cremation process will be properly controlled, given that the bodies will be delivered to the crematorium and immediately stored in the refrigerated mortuary, and that any odorous organic compounds generated during the cremation process would be destroyed under high heat (850^oC for 2 seconds) in the combustion chamber of the cremator. Furthermore, no odour complaints related to the operation of the existing WHS Crematorium have been received for the past three years between 2021 and 2023. Since the operation of the Project would be similar to the existing WHS Crematorium, odour nuisance from cremation process is not anticipated

3.6.2.7. As discussed in Section 3.2.5, the emission of ammonia from the De-NOx system of the cremator would cause potential odour concern at nearby ASRs, and the odour impact of ammonia at the ASRs would be assessed for an averaging time of 5 seconds in accordance with EIAO-TM Annex 4. According to Ammonia Fact Sheet, AERISA and previous EIA reports, ammonia has a detectable odour threshold of 0.037ppm (or 0.0259 mg/m³ at 25 degrees Celsius), thus one Odour Unit of a 5-second concentration value of 0.0259 mg/m³ will be equated with one odour unit for the odour impact assessment.

Existing WHS Crematorium (Tier 2)

3.6.2.8. For the operating cremators within the existing WHS Crematorium, the emission rates and discharge parameters indicated in past monitoring data and the prevailing Specified Process licence issued by EPD shall be adopted for quantitative assessment. Refer to Appendix 3.7 for the location and emission rate calculations for the cremator discharge stacks.

Industrial Emissions from Plastics Recycling Plant (Tier 2)

3.6.2.9. There is an existing plastics recycling plant located on Ming Yin Road as shown in Figure 3.2. Based on site survey and desktop review, the recycling plant would undergo various treatment processes (sorting, moulding, extrusion, cutting) before turning the collected waste plastics into recycled plastic pellets/materials. The plant is installed with bag filter and activated carbon filter to collect/remove dust particles and VOCs before discharging the treated air via a single stack on the roof. The factory has a handling capacity of 100 tonnes of plastics per month and operates on Monday to Friday from 9am – 6pm.

3.6.2.10. The emission factors for particulate matters (assumed to be the same for both RSP and FSP) and VOC (assumed to be total organic carbon) are taken from the approved EIA report for Development of an EcoPark in Tuen Mun Area 38 (AEIAR-086/2005). Refer to Appendix 3.7 for details.

Vehicular Emissions from Open Roads (Tier 2)

3.6.2.11. The road networks within the Assessment Area have been identified in Appendix 3.1. The open roads within the 500m assessment area include the two local distributor roads of Kiu Tau Road and Ming Yin Road. The existing Wo Hop Shek Road is an internal access road, whilst a slip road parallel to Wo Hop Shek Road is proposed to be completed in 2029 under the new road widening work project for WHS Cemetery for Phase 2 and Phase 3 Columbarium Development. Furthermore, as discussed in Section 2, with the phased concurrent operation of other proposed columbarium development expected (Phase 2 by 2029, Phase 3 by 2030/2031 and Phase 4 by 2035), there would be additional traffic load on Wo Hop Shek Road and the proposed slip road. Therefore, vehicular emissions impact from all roads within the 500m assessment area, including the open roads (Kiu Tau Road, Ming Yin Road), existing Wo Hop Shek Road, proposed slip road and a few other minor roads, have been included in the assessment.

3.6.2.12. The predicted 24-hour traffic flow and vehicle compositions at the identified roads shall be used for the assessment. The modelled fleet will be broken down into the 18 vehicle classes based on Appendix 1 of EPD’s Guideline on Modelling Vehicle Emissions. During the festival dates of Ching Ming and Chung Yeung Festivals, as well as during the two weekends before and after the two festival dates, there will be special traffic arrangements by the Transport Department (e.g. partial road closure for private cars, additional public transport services). In order to capture the traffic flow patterns for both festival and non-festival periods, the traffic flow would be predicted for two scenarios, namely Normal Operating Scenario (Weekday) and Normal Operating Scenario (Festival). The traffic flow forecast for both scenarios as well as endorsement of the traffic data by Transport Department are provided in Appendix 3.1.

3.6.2.13. The traffic of passenger coaches carrying the ceremony attendees to and from the Project Site and the existing WHS Crematorium has also been considered in the traffic forecast for both scenarios. It is assumed that the passenger coach will arrive and park at the crematorium 5-10 minutes before each ceremony session, and then depart 30 minutes after the session starts, taking into account the preparation time and the average ceremony duration. For the existing WHS Crematorium, there is a maximum of 54 ceremony sessions held per day across seven timeslots, with 8 sessions held over the each of timeslots no.1-6 and 6 sessions held during timeslots no. 7. Hence 8 coaches are anticipated to arrive/depart during timeslots no.1-6 and 6 coaches during timeslot no. 7. For the Project Site, a maximum of 68 daily sessions are assumed to be held over the same seven timeslots, with 10 sessions held over timeslots no. 1-5 and 9 sessions held over timeslots no. 6-7. Hence there will be a traffic of 10 coaches and 9 coaches during timeslots no. 1-5 and timeslot no. 6-7 respectively. Furthermore, the normal operating scenario traffic flows account for the traffic of hearses accessing the existing WHS crematorium and the Project Site. Hearses have been assumed as Light Goods Vehicle (vehicle class LGV6), and the LGV6 traffic flow pattern at the roads accessing the existing WHS crematorium and Project Site adopts the same pattern as that of the passenger coach (NFB8) for those road links during the cremation session hours. This assumes that for each ceremony session, there will be 1 hearse carrying the coffin and 1 passenger coach carrying the family members. Refer to Appendix 3.2 for the coach traffic details on the specific ingress and egress roads to the two crematoria.

3.6.2.14. For the emergency 24-hour operation case mentioned in Section 3.6.2.5, a different set of traffic data is used. The basis of the emergency scenario traffic data is based on the Year 2030 Normal Operating Scenario (Festival) traffic data, which has the highest emission burden amongst the festival and weekday scenarios for the three assessment years 2030, 2038, 2045. To account for the potential additional traffic of hearses and passenger coaches accessing the Project, for conservative assessment purpose, an additional 15 NFB8 coaches and 15 LGV6 hearses are added to every hour of the 24-hour traffic flow for the roads accessing the Project Site (i.e. Road IDs 7, 8, 9, 10, 11, 13, 24, 25, 27, 40, 45). Refer to Appendix 3.1 for details.

3.6.3. Dispersion Modelling Approach

3.6.3.1. The USEPA approved model, AERMOD version 22112, has been employed to model the emission from the cremators and start/running emissions from the open roads within the 500m Assessment Area including the two local distributor roads of Kiu Tau Road and Ming Yin Road. There is also the existing Wo Hop Shek Road which is an internal access road and a slip road parallel to Wo Hop Shek Road which is proposed to be completed in 2029 under the new road widening work project for Wo Hop Shek Cemetery for Phase 2 and Phase 3 Columbarium Development.

Stack Emissions from the Project, existing WHS Crematorium and Plastic Recycling Plant

3.6.3.2. The proposed cremator chimney stacks within the Project, existing cremator chimney stacks at the WHS Crematorium and plastics recycling plant would be modelled as “POINT” sources in AERMOD. The emission rates of the cremator chimney shall refer to the values listed in Table 3.8. For the emission parameters of the cremators at the WHS Crematorium and the plastics recycling plant, refer to Appendix 3.7 for details.

3.6.3.3. Under the current EPD guideline “Guidelines on Choice of Models and Model Parameters”, hourly meteorological data including wind speed, wind direction, temperature, relative humidity, atmospheric pressure, cloud cover and mixing height of Year 2019 from the WRF Meteorological model under PATH v3.0 will be adopted for the meteorological input to AERMET (the meteorological pre-processor of AERMOD). The minimum wind speed will be capped at 0.5 metre per second, whilst the mixing height will be capped by the minimum and maximum values recoded at Hong Kong Observatory (HKO) at the reference year 2019. The input file to AERMET has been obtained from EPD’s Smart Air Modelling Platform (SAMP) version 2.0.

3.6.3.4. The surface parameters such as albedo, Bowen ratio and surface roughness are also required in the AERMET. Those surface parameters would be determined by AERMET according to its land use characteristics within 10km for albedo and Bowen ratio, and 1 km for surface roughness. Refer to Appendix 3.5 for the albedo and Bowen ratios and surface roughness calculations obtained from EPD’s SAMP. The urban option was selected as the Project site is located in an urban area. The population of 309,631 taken from the latest 2021 census for the North District, was used for the urban option setting.

Vehicular Emissions from Open Roads

3.6.3.5. The roads within the Assessment Area were modelled as “LINE” sources. See Appendix 3.3 for the road links map. The Emfac mode under the latest EMFAC-HK model (version 4.3) has been used by EPD’s SAMP tool to derive the hourly composite vehicular running emission rates of NO₂, NO, RSP and FSP, based on the predicted 24-hour traffic forecast data for 18 vehicle classes endorsed by Transport Department (TD) (refer to Appendix 3.1 for traffic data and TD endorsement). Default values of speed fraction, trips and VKT in the Emfac mode has been used by SAMP to calculate emission factors. For conservative purpose, no zero-emission vehicles were included in the composite emission factors output by SAMP v2.0.

3.6.3.6. Apart from running vehicular emissions, the start emissions for all vehicle types at all assessed roads, including start activities of passenger coaches accessing the Project Site and WHS Crematorium crematoria as discussed in Section 3.6.2.13, have also been considered using the broad-brush approach. The broad-brush approach is based on the trip-to-vehicle kilometres travelled (VKT) ratio for each vehicle type, and the highest NO₂, NO, RSP and FSP start emission factors for each vehicle class among different soak times are adopted. Considering the average soak time of 35-40 minutes for passenger coach during each ceremony session, the adoption of the highest start emission factor with a soak time of 720 minutes is considered a conservative approach. The total number of trips and VKT within Hong Kong has been extracted from the default values from the EMFAC-HK model for the respective modelling year, whilst the proportion of local and rural roads to all roads within Hong Kong has been adjusted from the latest Annual Traffic Census (2022) and applied to this Project. The broad-brush start emissions are also generated from EPD SAMP tool. Refer to Appendix 3.2 for the EMFAC-HK assumptions.

3.6.3.7. According to EPD guideline “Use of Temperature and Relative Humidity Data for Vehicular Emission Factor Prediction”, in order to estimate the short-term air quality impact, the daily profile of lowest temperature and relative humidity data in each hour for each month (i.e. 24hours data in each month and for 12 months) was used. For estimating annual air quality impact of NO₂, the daily profile of averaged temperature and relative humidity data in each hour for each month (i.e. 24 hours data in each month and for 12 months) was used. The temperature and relative humidity data under PATH v3.0 has been adopted and the emission factors for each road segment have been determined using EPD’s SAMP tool. Refer to Appendix 3.4 for the AERMOD emission input files for the line sources produced by SAMP.

3.6.3.8. For selection of the assessment year, the total vehicular emission burdens of NOx, RSP and FSP from the Project commencement year, 8 and 15 years after (i.e. Year 2030, 2038 and 2045) has been estimated by EMFAC-HK v4.3 within the EPD SAMP tool for both Normal Operating Scenario (Weekday) and Normal Operating Scenario (Festival). The traffic data described in Section 3.6.2.12, which includes passenger coach traffic, was used for the burden assessment. For each assessment year, the annual emission burden would be calculated based on the combination of specific festival days with special traffic arrangements (Normal Operating Scenario (Festival)) and non-festival days (Normal Operating Scenario (Weekday)) in that calendar year, and the year with the highest annual emission burden would be adopted as the assessment year. There is a total of 20, 19 and 20 festival days with special traffic arrangements for the year 2030, 2038 and 2045 respectively, as presented in Table 3.9 below. Given that the annual NOx, RSP and FSP emission burden in year 2030 is the highest, the year 2030 would be used for the quantitative assessment. Refer to Tabel 3.10 below and Appendix 3.2 for the emission burden calculation details.

Table 3.9 List of Ritual Festival Days in 2030, 2038 and 2045

Ritual Festival Days [1]	Year 2030	Year 2038	Year 2045
2^nd last weekend before CM	23-24 Mar	27-28 Mar	25-26 Mar
Last weekend before CM	30-31 Mar	3-4 Apr	1-2 Apr
CM	5 Apr	5 Apr	5 Apr
1^st weekend after CM	6-7 Apr	10-11 Apr	7-10 Apr
2^nd weekend after CM	13-14 Apr	17-18 Apr	15-16 Apr
2^nd last weekend before CY	21-22 Sep	25-26 Sep	7-8 Oct
Last weekend before CY	28-29 Sep, 1 Oct	1-3 Oct	14-15 Oct
CY	5 Oct, 6 Oct [2]	7 Oct	18 Oct
1^st weekend after CY	12-13 Oct	9-10 Oct	21-22 Oct
2^nd weekend after CY	19-20 Oct	16-17 Oct	28-29 Oct
Total No. of Festival Days	20	19	20
Notes: [1] CM = Ching Ming Festival, CY = Chung Yeung Festival [2] Chung Yeung Festival in 2030 occurs on Saturday 5 Oct, hence Sunday 6 Oct will also have special traffic arrangements.

Table 3.10 Annual Emission Burden for Year 2030, 2038 and 2045

Emission Burden (kg/year)	Year 2030	Year 2038	Year 2045
Annual NOx ^[1]	2,459	1,572	2,418
Annual RSP ^[2]	48	21	27
Annual FSP ^[2]	44	20	25
Notes: [1] Based on SAMP-generated emission factors derived from Monthly Hourly Average Temperature and RH output. [2] Based on SAMP-generated emission factors derived from Monthly Hourly Minimum Temperature and RH output. Note that RSP and FSP emission factors are independent of temperature and RH.

3.6.3.9. Similar to Section 3.6.3.3, the same surface and profile input files to AERMET obtained from EPD’s SAMP has been used for modelling open road emissions. Refer to Appendix 3.5 for calculations.

3.6.3.10. AERMOD was run for both sets of Normal Operating Scenario (Weekday) and Normal Operating Scenario (Festival) to generate two sets of hourly output files (.pst files) for each pollutant. The final hourly output data for data processing was then derived based on the calendar of ritual festival days and non-festival days for year 2030 as shown in Table 3.9 above, with the hourly output data during ritual festival days obtained from the output file for Normal Operating Scenario (Festival), and those during non-festival days obtained from the Normal Operating Scenario (Weekday) output file.

3.6.4. Post-Modelling Data Processing

Ozone Limiting Method for Short-term Cumulative NO₂ Assessment

3.6.4.1. For NOx emissions from the cremators, the initial NO₂/NO_x ratio of 10% is applied according to the Heathrow Airport EIA report ^[^{^[1]}^], with 90% of the emitted NO_x assumed to be NO. For vehicular emission, emission factors for NO₂ and NO (which is assumed by subtracting the NO₂ emission factor from the NO_x emission factor in EMFAC v4.3) has been obtained from EMFAC v4.3 and then predicted separately in AERMOD. The total predicted vehicular NO₂ will then be estimated according to the Ozone Limiting Method (OLM) as described in the EPD Guideline. The total predicted NO₂ will be calculated as follows:

[NO₂]_predicted= 0.1 x [NO_x]_chimney + [NO₂]_vehicle + MIN{ 0.9 x [NO_x]_chimney+[NO]_vehicleor (46/48) x [O₃]_PATH}

where

[NO₂]_predicted = the predicted NO₂ concentration at the ASR

[NO₂]_vehicle = the predicted NO₂ concentration from vehicular emissions at the ASR

[NO]_vehicle = the predicted NO concentration from vehicular emissions at the ASR

[NO_x]_chimney = the predicted NO_x concentration from cremator emissions at the ASR

MIN = the minimum of the two values within the bracket

[O₃] _PATH = hourly ozone concentrations as extracted from the relevant grid of the PATH-v3.0

(46/48) = the molecular weight of NO₂ divided by the molecular weight of O₃

Jenkin Method for Long-term Cumulative NO2 Assessment

3.6.4.2. For the assessment of annual average NO₂ concentration, the Jenkin method referenced in the EPD Guideline “Guidelines on Choice of Models and Model Parameters” has been used to estimate the annual NO₂ based on a functional form curve fitted for the NO₂ and NO_x concentrations measured at representative Air Quality Monitoring Stations (AQMS). Data for the past five years (2019-2023) from the two general AQMS stations at Tap Mun, Tai Po and one roadside AQMS station at Mongkok were used by SAMP to produce the Jenkin functional form curve. Refer to Appendix 3.6 for the detailed calculation obtained from SAMP.

Human Health Risk Assessment for Dioxins

3.6.4.3. The incremental cancer risk, in terms of the number of attributable cancer cases per million population, due to the inhalation of dioxins generated from the cremation process would be assessed in terms of the risk of developing cancer if a person is continuously exposed to a unit concentration for 70 years. References from OEHHA and USEPA have been taken to quantitatively assess the incremental human health risk against the individual lifetime risk level of 1 in 1 million (i.e. risk level of less than 1 x 10^-6).

3.6.4.4. To assess the incremental lifetime cancer risk due to dioxin exposure, the dioxin IUR of 38 (ug/m³)^-1 will be multiplied by the annual dioxin concentrations predicted in this study in order to determine its incremental lifetime cancer risk.

Adjustment of Pollutant Concentrations

3.6.4.5. In order to convert the hourly SO₂ concentration into 10-minute average concentration, a set of conversion factors shall be used according to EPD’s Guidelines on the Estimation of 10-minute Average SO₂ Concentration for Air Quality Assessment in Hong Kong. The conversion factor is based on the stability class for the hour corresponding to the maximum predicted cumulative 1-hour SO₂ concentration.

3.6.4.6. In order to convert the 1-hour odour concentration into 5-second value for odour impact assessment of NH₃, a set of conversion factors shall be used according to EPD’s Guidelines on Choice of Models and Model Parameters. The conversion factor is based on the stability class for the hour corresponding to the maximum predicted cumulative 1-hour NH₃ concentration.

Assessment of Predicted Concentrations

3.6.4.7. Year 2030 background concentrations from the PATH v3.0 model will be added to the AERMOD model results sequentially on an hour-to-hour basis to derive the short-term and long-term cumulative impacts at the ASRs. The pollutant concentration predicted at an ASR amongst the 8760 hours (i.e., number of hours in a year) will be ranked/ averaged to assess the cumulative impact.

3.7. Prediction and Evaluation of Environmental Impacts

3.7.1. The operation phase air quality impact assessment has considered the emission from the proposed cremators of the Project, cremators of the existing WHS crematorium, existing and future open road vehicular emissions, as well as the background concentration. The predicted cumulative concentrations for AQO pollutants and other pollutants under both normal operating hours (i.e. 08:30-23:00) and emergency scenario (i.e. 24-hour continuous operation) are presented in Table 3.11 to Table 3.14 respectively, whilst the human health risk and odour impact assessment results for both operating scenarios are shown in Table 3.15 to Table 3.17. Detailed results and breakdowns in terms of contributions from the Project and other sources are presented in Appendix 3.8.

AQO-pollutants

3.7.2. As shown in both Table 3.11 and Table 3.12, the predicted cumulative concentrations for all AQO pollutants comply with the respective prevailing AQO criteria and proposed AQO criteria under both normal operating and emergency scenarios.

3.7.3. Based on the assessment results, the worst hit level is generally found at 10mAG. The contour plots for the AQO pollutants at 10mAG are also shown in Figure 3.3a to Figure 3.14b for both normal operating and emergency scenarios. Based on the contour plots for both normal operating and emergency scenarios, there is no AQO exceedance zone within the Assessment Area and hence none of the identified ASRs falls within the AQO exceedance zone.

Other Pollutants

3.7.4. As shown in both Table 3.13 and Table 3.14, the predicted cumulative concentrations for all other pollutants comply with the respective assessment criteria under both normal and emergency scenarios. The contour plots for the other pollutants at the worst hit level of 10mAG are also shown in Figure 3.15a to Figure 3.24b for both normal operating and emergency scenarios. Based on the contour plots for both normal operating and emergency scenarios, there is no exceedance zone for other pollutants within the Assessment Area and hence none of the identified ASRs falls within the exceedance zone for other pollutants.

3.7.5. The incremental carcinogenic human health risk, due to the emission of dioxins from the proposed crematorium, under the normal operating scenario has been also evaluated and presented in Table 3.15. The calculations indicated that the incremental cancer health risk is predicted to be well below the USEPA’s target acceptable level of 10^-6 (1 in a million) at all ASRs. Note that for the emergency scenario, long-term (annual) assessment is not applicable. Therefore, the incremental carcinogenic human health risk under emergency scenario has not been assessed.

3.7.6. The odour impact predicted at the identified ASRs has also been found to comply with the assessment criteria of 5 odour units for both normal operating and emergency scenarios , as shown in Table 3.16 and Table 3.17.

Table 3.11 Cumulative Air Pollutant Concentrations of AQO-Pollutants at Representative ASRs under Normal Operating Scenario (10-minute, 1-hour, 24-hour and annual averages)

ASR ID	Description	Height above Ground (mAG)	Predicted Cumulative Pollutant Concentrations (µg/m³)
			AQO Pollutants
			SO₂		RSP		FSP		NO₂			CO
			10min (4^th highest)	24h (4^th highest)	24h (10^th highest)	Annual	24h (19^th highest)	Annual	1hr (19^th highest)	24h (10^th highest)	Annual	1hr	8hr	24hr
Prevailing AQO Criteria (μg/m³)			500	50	100	50	50	25	200	-	40	30,000	10,000	-
Proposed AQO Criteria (μg/m³)			500	40	75	30	37.5	15	200	120	40	30,000	10,000	4,000
A01	Cheung Kee Stoneworks	1.5	28.34	7.01	51.88	20.30	30.69	12.70	74.00	28.00	16.14	534.29	494.52	457.75
		5	28.34	7.01	52.00	20.30	31.00	12.70	74.00	28.00	16.22	534.29	494.52	457.75
		10	28.35	7.01	52.00	20.31	31.00	12.71	75.00	28.00	16.34	534.31	494.52	457.76
A02	Kin Fuk Stone Factory	1.5	28.37	7.03	52.00	20.34	31.00	12.74	78.00	31.00	17.03	534.28	494.54	457.76
A03	Temporary Structure	1.5	25.91	6.59	53.00	20.45	31.00	12.80	49.00	18.00	11.22	533.83	486.86	453.74
A04	Village House No. 168, Nam Wa Po	1.5	25.10	6.55	54.00	21.13	34.00	13.38	59.00	22.00	12.39	548.49	505.28	463.47
		5	25.10	6.55	54.00	21.13	34.00	13.38	59.00	22.00	12.39	548.59	505.28	463.48
		10	25.11	6.56	54.00	21.13	34.00	13.38	59.00	22.00	12.40	548.75	505.28	463.48
A05	Village House No. 50A, Nam Wa Po	1.5	25.13	6.56	54.00	21.13	34.00	13.38	61.00	23.00	12.47	548.22	505.28	463.28
		5	25.13	6.56	54.00	21.13	34.00	13.38	62.00	23.00	12.48	548.33	505.28	463.28
		10	25.13	6.56	54.22	21.13	34.04	13.38	62.00	23.00	12.49	548.54	505.28	463.29

Note: There is no exceedance of the AQO for the predicted cumulative pollutant concentrations.

Table 3.12 Cumulative Air Pollutant Concentrations of AQO-Pollutants at Representative ASRs under Emergency Scenario (10-minute, 1-hour and 24-hour averages)

ASR ID	Description	Height above Ground (mAG)	Predicted Cumulative Pollutant Concentrations (µg/m³)
			AQO Pollutants
			SO₂		RSP		FSP			NO₂			CO
			10min (4^th highest)	24h (4^th highest)	24h (10^th highest)	Annual	24h (19^th highest)	Annual	1hr (19^th highest)		24h (10^th highest)	Annual	1hr	8hr	24hr
Prevailing AQO Criteria (μg/m³)			500	50	100	50	50	25	200		-	40	30,000	10,000	-
Proposed AQO Criteria (μg/m³)			500	40	75	30	37.5	15	200		120	40	30,000	10,000	4,000
A01	Cheung Kee Stoneworks	1.5	28.51	7.37	52.18	-	30.92	-	93.90		38.04	-	534.29	494.57	457.76
		5	28.51	7.37	52.19	-	30.92	-	93.29		38.14	-	534.29	494.57	457.77
		10	28.51	7.37	52.20	-	30.91	-	94.06		38.22	-	534.31	494.57	457.77
A02	Kin Fuk Stone Factory	1.5	28.57	7.46	52.38	-	31.04	-	105.69		45.16	-	534.28	494.60	457.78
A03	Temporary Structure	1.5	25.91	6.60	53.35	-	31.42	-	52.58		18.81	-	533.83	487.67	454.18
A04	Village House No. 168, Nam Wa Po	1.5	25.10	6.62	54.30	-	34.03	-	61.96		23.98	-	548.49	505.94	463.80
		5	25.10	6.62	54.30	-	34.03	-	62.35		24.01	-	548.59	505.94	463.81
		10	25.11	6.63	54.30	-	34.03	-	62.68		24.08	-	548.75	505.95	463.81
A05	Village House No. 50A, Nam Wa Po	1.5	25.13	6.87	54.24	-	34.04	-	63.70		24.12	-	548.22	506.22	463.34
		5	25.13	6.88	54.24	-	34.04	-	63.72		24.14	-	548.33	506.25	463.34
		10	25.13	6.89	54.24	-	34.04	-	63.76		24.16	-	548.54	506.32	463.35

Note: There is no exceedance of the AQO for the predicted cumulative pollutant concentrations.

Table 3.13 Cumulative Air Pollutant Concentrations for Other Pollutants at Representative ASRs under Normal Operating Scenario (1-hour and annual averages)

ASR ID	Description	Height above Ground (mAG)	Predicted Cumulative Pollutant Concentrations (µg/m³)
			Other Pollutants
			HCl		Hg		Dioxin	TOC		Ammonia
			1hr	Annual	1hr	Annual	Annual	1hr	Annual	1hr	Annual
Assessment Criteria ⁽¹⁾ (μg/m³)			2100	9, 20	0.6	0.03, 0.3, 1	40 pg/m³	N/A	N/A	3200		200, 500
A01	Cheung Kee Stoneworks	1.5	6.37	0.85	0.0046	0.00073	0.0311	23.73	7.01	8.16	1.90
		5	6.42	0.85	0.0047	0.00074	0.0311	23.76	7.02	8.16	1.90
		10	6.57	0.86	0.0049	0.00075	0.0311	23.86	7.03	8.16	1.91
A02	Kin Fuk Stone Factory	1.5	6.44	0.88	0.0047	0.00079	0.0312	23.77	7.04	8.17	1.91
A03	Temporary Structure	1.5	5.89	0.55	0.0038	0.00023	0.0301	23.44	6.82	8.14	1.89
A04	Village House No. 168, Nam Wa Po	1.5	5.98	0.55	0.0040	0.00023	0.0301	23.50	6.82	8.19	1.89
		5	6.00	0.55	0.0040	0.00023	0.0301	23.52	6.82	8.19	1.89
		10	6.05	0.55	0.0041	0.00023	0.0301	23.55	6.82	8.20	1.89
A05	Village House No. 50A, Nam Wa Po	1.5	5.63	0.55	0.0034	0.00024	0.0301	23.28	6.82	8.17	1.89
		5	5.67	0.55	0.0035	0.00024	0.0301	23.30	6.82	8.18	1.89
		10	5.77	0.56	0.0036	0.00024	0.0301	23.37	6.82	8.19	1.89

Note: (1) Refer to Table 3.2 for description and references of various assessment criteria.

Table 3.14 Cumulative Air Pollutant Concentrations for Other Pollutants at Representative ASRs under Emergency Scenario (1-hour averages)

ASR ID	Description	Height above ground (mAG)	Predicted Cumulative Pollutant Concentrations (µg/m³)
			Other Pollutants
			HCl		Hg		Dioxin	TOC		Ammonia
			1hr	Annual	1hr	Annual	Annual	1hr	Annual	1hr	Annual
Assessment Criteria ⁽¹⁾ (μg/m³)			2100	9, 20	0.6	0.03, 0.3, 1	40 pg/m³	N/A	N/A	3200		200, 500
A01	Cheung Kee Stoneworks	1.5	6.37	-	0.0046	-	-	23.73	-	8.17	-
		5	6.42	-	0.0047	-	-	23.76	-	8.17	-
		10	6.57	-	0.0049	-	-	23.86	-	8.18	-
A02	Kin Fuk Stone Factory	1.5	6.44	-	0.0047	-	-	23.77	-	8.18	-
A03	Temporary Structure	1.5	5.89	-	0.0038	-	-	23.44	-	8.14	-
A04	Village House No. 168, Nam Wa Po	1.5	5.98	-	0.0040	-	-	23.50	-	8.33	-
		5	6.00	-	0.0040	-	-	23.52	-	8.33	-
		10	6.05	-	0.0041	-	-	23.55	-	8.33	-
A05	Village House No. 50A, Nam Wa Po	1.5	5.63	-	0.0034	-	-	23.28	-	8.18	-
		5	5.67	-	0.0035	-	-	23.30	-	8.19	-
		10	5.77	-	0.0036	-	-	23.37	-	8.19	-

Note: (1) Refer to Table 3.2 for description and references of various assessment criteria.

Table 3.15 Incremental Cancer Risk due to Project-induced Dioxin Exposure under Normal Operating Scenario

ASR ID	Description	Meters above Ground (mAG)	Project-induced Annual Dioxin Concentration, pg I-TEQ/m³ (i.e. Tier 1 contribution)	Incremental Cancer Risk ^[1]	USEPA Acceptable Risk Level ^[2]
A01	Cheung Kee Stoneworks	1.5	1.95 x 10^-4	7.41 x 10^-9	1 x 10^-6
		5	1.96 x 10^-4	7.45 x 10^-9
		10	1.97 x 10^-4	7.49 x 10^-9
A02	Kin Fuk Stone Factory	1.5	2.07 x 10^-4	7.87 x 10^-9
A03	Temporary Structure	1.5	4.30 x 10^-5	1.63 x 10^-9
A04	Village House No. 168, Nam Wa Po	1.5	4.30 x 10^-5	1.63 x 10^-9
		5	4.30 x 10^-5	1.63 x 10^-9
		10	4.40 x 10^-5	1.67 x 10^-9
A05	Village House No. 50A, Nam Wa Po	1.5	4.80 x 10^-5	1.82 x 10^-9
		5	4.80 x 10^-5	1.82 x 10^-9
		10	4.90 x 10^-5	1.86 x 10^-9
Notes: [1] Incremental Cancer Risk (in unit of (ug m-3)^-1) = Tier 1 contribution (i.e. Annual Dioxin concentration) x Inhalation Unit Risk of 38 (OEHHA). [2] USEPA insignificant cancer risk level (target level) = 10^-6(i.e. 1 in a million).

Table 3.16 Odour Impact due to Ammonia Exposure under Normal Operating Scenario

ASR ID	Description	Meters above ground (mAG)	1-hr Ammonia Concentration ug/m3^[1]	1-hour Odour Impact (Odour Unit)^[^2]	5-second Odour Impact (Odour Unit)^[^3]	Odour Criteria (5-second Odour Unit)^[^4]
A01	Cheung Kee Stoneworks	1.5	8.158	0.315	1.890	5
		5	8.160	0.315	1.890
		10	8.165	0.315	1.891
A02	Kin Fuk Stone Factory	1.5	8.171	0.315	1.893
A03	Temporary Structure	1.5	8.143	0.314	1.886
A04	Village House No. 168, Nam Wa Po	1.5	8.192	0.316	1.898
		5	8.193	0.316	1.898
		10	8.197	0.316	1.899
A05	Village House No. 50A, Nam Wa Po	1.5	8.174	0.316	1.894
		5	8.179	0.316	1.895
		10	8.194	0.316	1.898
Notes: [1]. Refer to results for Cumulative 1-hour average ammonia concentrations. There are no Tier-2 values (existing WHS Crematorium) available for ammonia. [2]. 1 Odour Unit (OU) = Ammonia Odour Threshold of 0.037ppm, where 0.037 ppm = 0.0259 mg/m³, reference from Ammonia Fact Sheet, AERISA. Hence 1 OU = 25.9 ug/m³. The 1-hour Odour Impact therefore equals 1-hour Tier-1 concentrations divided by 25.9 ug/m³. [3]. For conservative assessment purpose, the highest 1-hour to 5-second conversion factor of 6 for a tall wake-free point source and far-field ASRs, taken from EPD’s Guidelines on Choice of Models and Model Parameters, has been applied. [4]. The odour criteria is 5 odour units based on averaging time of 5 seconds, according to Annex 4 of EIAO-TM.

Table 3.17 Odour Impact due to Ammonia Exposure under Emergency Scenario

ASR ID	Description	Meters above ground (mAG)	1-hr Ammonia Concentration ug/m3^[1]	1-hour Odour Impact (Odour Unit)^[^2]	5-second Odour Impact (Odour Unit)^[^3]	Odour Criteria (5-second Odour Unit)^[^4]
A01	Cheung Kee Stoneworks	1.5	8.171	0.315	1.893	5
		5	8.173	0.316	1.893
		10	8.179	0.316	1.895
A02	Kin Fuk Stone Factory	1.5	8.182	0.316	1.895
A03	Temporary Structure	1.5	8.143	0.314	1.886
A04	Village House No. 168, Nam Wa Po	1.5	8.332	0.322	1.930
		5	8.332	0.322	1.930
		10	8.332	0.322	1.930
A05	Village House No. 50A, Nam Wa Po	1.5	8.185	0.316	1.896
		5	8.186	0.316	1.896
		10	8.194	0.316	1.898
Notes: [1]. Refer to results for Cumulative 1-hour average ammonia concentrations. There are no Tier-2 values (existing WHS Crematorium) available for ammonia. [2]. 1 Odour Unit (OU) = Ammonia Odour Threshold of 0.037ppm, where 0.037 ppm = 0.0259 mg/m3, reference from Ammonia Fact Sheet, AERISA. Hence 1 OU = 25.9 ug/m3. The 1-hour Odour Impact therefore equals 1-hour Tier-1 concentrations divided by 25.9 ug/m3. [3]. For conservative assessment purpose, the highest 1-hour to 5-second conversion factor of 6 for a tall wake-free point source and far-field ASRs, taken from EPD’s Guidelines on Choice of Models and Model Parameters, has been applied. [4]. The odour criteria is 5 odour units based on averaging time of 5 seconds, according to Annex 4 of EIAO-TM.

3.8. Mitigation of Adverse Environmental Impacts

Construction Phase

3.8.1. Based on the assessment results, adverse air quality impact would not be anticipated during construction phase of the Project. Nonetheless, dust suppression measures stipulated in Air Pollution Control (Construction Dust) Regulation and good site practices listed in Section 3.5.12 should be carried out to further minimize construction dust impact.

3.8.2. According to DEVB’s TC No. 1/2015 Emissions Control of NRMM in Capital Works Contracts of Public Works and the Air Pollution Control (Non-road Mobile Machinery (NRMM)) (Emission) Regulation, starting from 1 December 2015, only approved or exempted NRMMs with a proper label are allowed to be used in specified activities and locations including construction sites. The Contractor is required to ensure the adopted machines or non-road vehicle under the Project could meet the prescribed emission standards and requirement. In addition, legal control is imposed on the types of fuels allowed for use and their sulphur contents in commercial and industrial processes under the Air Pollution Control (Fuel Restriction) Regulations.

3.8.3. According to DEVB’s TC No. 13/2020 Timely Application of Temporary Electricity and Water Supply for Public Works Contract and Wider Use of Electric Vehicles in Public Works Contracts, timely provision of electricity could help reduce carbon emission arising from operation of diesel generators at the construction sites.

3.8.4. The Contractor should also adhere to the general requirements under EPD’s Recommended Pollution Control Clauses for Construction Contracts to further minimize emission of air pollutants from construction plant and fugitive dust emissions from construction activities.

Operation Phase

3.8.5. Based on the predicted pollutant levels in Table 3.11 to Table 3.17, no adverse air quality impact is anticipated during the operation phase of the Project, thus mitigation measure is deemed not necessary with the development parameters as mentioned in Chapter 2 of this EIA report.

3.8.6. The design, the operation and the commissioning of the proposed cremators would comply with the BPM 12/2(2020). Prior to operation phase, commissioning trials (to be witnessed by the Authority whenever appropriate) shall be conducted to demonstrate performance capability of the air pollution control measures. Unless otherwise agreed by the Authority, a report of commissioning trial shall be submitted to the Authority within one month after completion of the trial.

3.8.7. In case of failure of any part of the cremator system, the operation should be suspended, and the failure rectified as soon as possible. Furthermore, a stringent management system will be implemented to ensure proper operation of the facility, the areas of staff training, emission monitoring, inspection and maintenance arrangements will be strengthened.

3.9. Evaluation of Residual Impacts

3.9.1. With the implementation of the recommended mitigation measures for construction dust, residual impacts would not be anticipated for the construction phase. Based on the assessment results, no residual air quality impacts for operation phase are anticipated.

3.10. Environmental Monitoring and Audit

3.10.1. The assessment has concluded that no adverse impacts during the construction and operation phases. Details of the Environmental Monitoring and Audit (EM&A) requirements and mitigation measures are provided in the stand-alone Project EM&A Manual. RSP and FSP monitoring and audit will be conducted during construction phase and odour patrol will be conducted during operation phase to ensure that no nearby ASRs will be subject to adverse air quality impact.

3.10.2. Before commencement of construction and dust monitoring, a construction dust monitoring plan shall be prepared by the Environmental Team (ET) and agreed by the Independent Environmental Checker (IEC). The plan should align with the EM&A Manual and verified by IEC. Referring to Section 3.1.25 of the EM&A Manual, the plan should include but not be limited to the followings:

· Details on the pollutants and environmental parameters to be monitored;

· Describe the equipment and measurement method to be used;

· Address the criteria for placing air sensors;

· Discuss the monitoring locations selected and rationale;

· Describe the criteria for selecting air sensors and test to determine if they are working properly;

· Determine the collocation location and establish the calibration and/or collocation and data correction methods;

· Identify types of data that may be used in the data analysis, including nearby reference monitor data, weather data, etc;

· List the procedures to maintain and operate air sensors, including site visits, routine maintenance, emergency maintenance, daily data review, periodic collocations, etc.;

· Describe the QC procedures to be performed;

· Describe how the data are processed, stored and adjusted;

· Describe the ownership of the data and who is granted access to it;

· Describe how the air monitoring data to be managed, tracing the path of data generation in the field to the final data use and end storage;

· Describe the procedures to verify and validate data during collection period;

· Describe the methods to produce meaningful figures and visualization; and

· Describe how the monitoring results will be used.

3.11. Conclusion

3.11.1. Potential air quality impacts from the construction works for the Project would mainly be related to fugitive dust and emissions from construction equipment. With the implementation of sufficient dust suppression measures as stipulated under Air Pollution Control (Construction Dust) Regulation and Air Pollution Control (Non-road Mobile Machinery) (Emission) Regulation, adverse air quality impacts would not be anticipated.

3.11.2. In respect of the operation phase of the Project, based on cumulative impacts of the proposed crematorium, vehicular emissions and existing WHS crematorium, no exceedances of the AQO pollutant and other relevant pollutants are predicted and no adverse operation phase impacts are expected to occur. The feasibility of adopting lower emission limits would be explored at a later stage of the project when more design details are available (e.g. during application for a Specified Process licence).

Figures

[[1]] Department for Transport. 2007. Air Quality Studies for Heathrow: Base Case, Segregated Mode, Mixed Mode and Third Runway Scenarios modelled using ADMS-Airport. Prepared by Cambridge Environmental Research Consultants.