1. INTRODUCTION

1.1 Purpose of the Manual

1.1.1 The purpose of this Environmental Monitoring & Audit (EM&A) Manual is to guide the EM&A programme prepared for the Demolition of the Kwai Chung Incineration Plant and to ensure compliance with the Environmental Impact Assessment (EIA) Report. This is subject to approval of the EIA Report under the statutory procedures of the EIAO and supporting Technical Memorandum. The EIA recommends procedures to:

· ensure that any environmental impacts resulting from the demolition of Kwai Chung Incineration Plant (KCIP) are kept to within acceptable levels;

· check that mitigation measures have been applied and are effective, and that the appropriate corrective actions are undertaken, if and when required; and

· provide a means of checking compliance with environmental objectives, recording anomalies and documenting corrective action.

1.1.2 This Manual contains the following:

· available information on the KCIP demolition project, the project organisation and demolition programme;

· general EM&A principles and the EM&A team organisation;

· monitoring parameters, schedules, Action/Limit Levels and action plans;

· complaints procedures; and

· reporting procedures.

1.1.3 The EM&A Manual has taken on a dual function since the introduction of the EIAO. These roles are:

· to provide a contract document between a Client and a Contractor defining the monitoring requirements and other duties in a form that is consistent with accepted contract practice.

· to provide additional controls that are implemented through the provisions of the Environmental Permit that are applicable to the project, but for which the responsibility does not rest with the Contractor (such as the role of the Environmental Team employed directly by the Proponent).

1.2 Requirement for EM&A Programme

1.2.1 The criteria for the requirement for undertaking EM&A are provided by EPD, these are summarised as follows:

(a) to protect sensitive receivers from environmental impacts if mitigation is not implemented;

(b) to protect the ecosystem;

(d) to monitor the effectiveness of mitigation measures which involves a long period to establish;

(e) to monitor any unproven technology;

(f) to validate the hypothesis in analysis and design;

(g) to audit the changing project scheduling; and

(h) others.

1.2.2 Whereas none of the above criteria are directly applicable to the project, Criterion a) can nevertheless be viewed as relevant with respect to the possible impacts excessive dust may have on the part time staff at the Kwai Chung Primary Treatment Works (KCPTW). There is automatic control equipment at the KCPTW next to the site and whereas such equipment is not defined as a sensitive receiver such equipment and it’s operation would also be sensitive to high dust levels and could therefore be impacted by construction activities.

1.2.3 Without mitigation for dust during the demolition phase, activities could cause nuisance to the workers or equipment at the Kwai Chung Primary Treatment Works although it is unlikely that such impacts would be prejudicial to the health or well being of people, and detrimental to the marine environment. Also as there are potential water quality impacts, this further justifies the requirements for monitoring and audit. The other criteria are not relevant to this project. On the basis of this interpretation of Criterion a) an EM&A programme is recommended.

1.3 Project Description

Background

1.3.1 The KCIP is located at Kwai Yue Road, Kwai Chung, facing the Rambler Channel and Tsing Yi South Bridge, with a site area of about 14,000 m² (Figure 1.1). The site is close to the Kwai Chung Park, the former Gin Drinkers Bay Landfill.

1.3.2 The KCIP site is adjacent to the KCPTW and part of the KCIP site overlaps the “Sewerage Tunnel Protection Area” of the Strategic Sewerage Disposal Scheme (SSDS), administered by Drainage Services Department (DSD).

1.3.3 There is no identified long term use of the area after demolition, however, the future land use is unlikely to be residential given the close proximity of the site to Gin Drinkers Bay Landfill and the Rambler Channel Bridge.

1.3.4 A Public Fill Barging Point (PFBP), located on reclaimed land (Area 30D) to the north of the KCIP, is planned to be operational in early 2005. The PFBP is also subject to a separate EIA study by others.

1.3.5 The site is opposite the Rambler Channel Typhoon Shelter and Public Cargo Working Area. These facilities accommodate a range of cargo related activities including permanently moored barges.

1.3.6 The structures that remain to be demolished at KCIP are summarised in Table 1.1. There is currently no definite programme for the demolition of KCIP however the demolition works are planed to commence in 2003. A twelve month demolition period has been assumed in the EIA. There are contaminated soils and the demolition will be followed by a soil remediation programme lasting up to eight months.

Table 1.1 Structures to be demolished at KCIP

Building	Brief Description
KCIP Chimney	Reinforced concrete construction of diameter 6m – 12m and 150m high. Internal metal flues and platforms
KCIP Buildings	High, single storey steel frame, with weather cladding, pre-cast concrete slab, reinforced concrete partitions, corrugated metal sheet external wall and roof. The overall size is approximately 83m x 92m on plan.
Weigh Bridge Office No2	Single Storey. Approximately 4m x 13m on plan.
Site Office/ Storage Buildings	Two storey high prefabricated building. Approximately 40m x 7.5m on plan.

1.4 Sensitive Receivers and Constraints to Demolition

Sensitive Receivers at KCIP

Residential

1.4.1 There are no residential SRs close enough to the works at KCIP which would be severely affected by demolition. However residential receivers within 700m have been assessed in the EIA. These include locations in the vicinity of Cheung Ching Estate and Greenfield Garden (about 600m away across the Rambler Channel, Figure 1.1).

Other Sensitivities near KCIP

1.4.2 There are several engineering and other locations, which would be very sensitive to demolition by blasting. These include:

· The Rambler Channel marine traffic and ferry services.

· Rambler Channel Typhoon Shelter and PCWA.

· The Public Fill Barging Point (PFBP) at Area 30D.

· The seawalls and drainage channels other infrastructure around the area.

· The 200m Sewerage Tunnel Protection Area.

· The Kwai Ching Primary Treatment Works.

· The Kwai Chung Park (Gin Drinkers Bay Landfill).

· The Rambler Channel Bridge.

· The Tsing Yi Bridge.

· Kwai Tai Road and heavy vehicle access.

· Container Terminal 5 (Kwai Tai Road).

1.4.3 Due to the short distances between the chimney and the surrounding structures, the high risk and lack of cost effectiveness meant that demolition of the single chimney by blasting was reaffirmed as not feasible in the early stages of this EIA study.

1.4.4 Demolition by blasting appears to be a very high-risk option and top down demolition by more conventional means has been endorsed. A soil remediation plan has also been developed to deal with contaminated soil under the site. Site safety measures will need to be implemented the demolition phase and soil remediation phase, in accordance with established standards and guidelines and the findings of the landfill gas hazard assessment.

1.5 General Approach to Demolition of Buildings and Structures at KCIP

General Approach

1.5.1 This section seeks to illustrate some of the more general procedures for demolition that apply to KCIP. The intention is not to prescribe a precise method or provide a work specification or a demolition plan but to indicate the approach that should be taken, in sufficient detail, to illustrate the agreed methodology which has been used to progress the Environmental Impact Assessment.

1.5.2 Whereas the eventual detailed demolition plan, which would be prepared by the selected demolition Contractor(s) may not necessarily adopt the precise methodology summarised here, the general characteristics of the methods, which do not involve blasting, are appropriate. The methods are sufficiently effective and applicable for the tasks (Appendix A). Where possible methods that will help reduce noise and dust nuisances have been chosen. The options selected are also broadly in line with the Draft Code of Practice for Demolition of Buildings (Buildings Department 1998). The Draft Code of Practice for Demolition of Buildings (Buildings Department 1998) shall be observed at the detailed design stage.

1.5.3 The overriding concerns for the demolition and soil remediation phases of the Project will be safety and minimisation of environmental impacts. This will include the safety of the demolition operatives, safety of other workers on the site and safety of the general public, as well as protection of adjacent facilities and minimisation of nuisances. The Contractor shall also, during the course of demolition, ensure and verify that all utilities and services have been rendered safe.

Hoarding and Site Access

1.5.4 Typical hoardings are shown in the indicative hoarding plan (Figure 1.2). Portable barricades should be used to cordon off different work zones within the site. The hoardings structures should be totally within the proposed Project site and access appropriately controlled. No members of the public or unauthorised persons should be allowed entry to the site. Only Contractors’ personnel and Government officials should be allowed within the Contractor’s working area.

General Demolition Principles

1.5.5 Demolition of building and structures are generally in the reverse order to that of construction, progressive, level by level and having regard to type of construction. Wherever possible, external non-load bearing cladding would be removed first. Asbestos containing materials must be removed prior to commencement of demolition works, wherever possible. Other ACM may need to be removed as access is gained to particular areas and as the demolition progresses. In this project, the materials around the ACM, in some cases, will be dismantled by the civil demolition contractor, leaving the ACM in-situ (undisturbed). The work actually involving the removal of ACM, that involves the handling of the ACM (except those exempted by the APCO) shall be carried out by an RAC. The multi-party nature of the project and the involvement of non-asbestos contractor increase the risk of accidental disturbance of ACM. CED will work out a detailed asbestos abatement programme for the sequence of the asbestos removal at the detailed design stage. In view of the multiparty nature of the works the owner will be the person liable for any accidental disturbance of ACM, and hence, should take steps to prevent such disturbance. The asbestos abatement programme shall be agreed by all parties including the supervising registered asbestos consultant (CSL), prior to the commencement of the demolition work. A dedicated Asbestos Abatement Plan has been prepared as required under the Air Pollution Control Ordinance.

General Safety Measures

1.5.6 The Contractor must carry out works in accordance with the Factories and Industrial Undertakings Ordinance (FIUO) as well as all other statutory requirements and guidelines covering health and safety issues. Relevant legislation has been reviewed as part of the Site Investigation Report and the Asbestos Study Report.

1.6 Principles of Chimney Demolition at KCIP

General Approach

1.6.1 The area beneath the chimney should be cordoned off and only authorised staff involved in the demolition of the chimneys should be allowed admission into the vicinity of the chimney structure.

1.6.2 The principle of the demolition procedure for the upper portion of the chimneys (10m from ground level or greater) is that the chimneys would be cut into small pieces by hand held tools on the spot by operatives who would work from working platforms inside the chimney. Hydraulic breakers would be used for the remaining lower portions of the chimneys.

1.6.3 The concrete supporting weather shield and the metal flues would be removed manually. The principle of the demolition procedure shall be that the chimney and flues would be cut up into pieces and these pieces lowered to the ground by derrick. This method would ensure that full control of the debris and that the pieces of reinforced concrete are not left to free fall.

1.7 Remedial Action Plan for Contaminated Soils

1.7.1 The areas requiring decontamination, identified based on the Contamination Assessment Report and Remediation Action Plan are shown in Figure 7.1.

1.8 EIA Requirements

1.8.1 The EIA Report recommends a range of mitigation measures to control the project’s potential environmental impacts with regard to marine water quality, dust, construction waste impacts during the demolition and the soil remediation phases. The schedule of mitigation measures as given in the EIA Report is repeated in Section 10 of this Manual.

1.9 Project Organisation

1.9.1 The proposed project organisation is presented in Figure 1.3 as the basis of information available at the time of report preparation.

1.9.2 The preferred approach is for the Independent Environmental Monitoring Team (ET) to be employed directly by the project proponent (CED). The monitoring is audited and checked by the Environmental Monitoring Team Leader (ETL) who reports to the Engineer’s Representative (ER).

1.9.3 Independent Monitoring Team Leader (ETL): This person should be professionally qualified with suitable experience in environmental management and planning. As a general recommendation, 7 years’ experience is desirable, although if the proposed ETL has less, agreement should be sought from the ER. Extensive knowledge of the study area is required. The ETL should have work experience in Hong Kong managing and providing specialist advice on environmental monitoring of infrastructure projects.

1.9.4 Site Inspection Team Leader: Requires experience working on environmental projects in Hong Kong. Extensive experience in dealing directly with Contractors is required.

1.9.5 Noise/Air Specialist: Requires experience in the air and noise pollution field. Skills in the use of computer models, database design and management of monitoring programmes are required.

1.9.6 Consultant: Experience as an environmental consultant with a broad range of expertise both in the technical and managerial aspects of environmental assessment. Proficient in: water quality sampling, analysis and assessment; air and noise monitoring, modelling and analysis; site assessment; and scoping exercises to identify key environmental issues.

1.9.7 Assistant Consultant: Experience in conducting on-site monitoring, data-gathering and subsequent computer-modelling data analyses.

1.9.8 The duties to be undertaken by the Environmental Team (ET) comprise the following:

· sampling, analysis and statistical evaluation of monitoring parameters with reference to the EIA Study recommendations and requirements.

· environmental site surveillance;

· audit of compliance with environmental protection and pollution prevention and control regulations;

· monitor the implementation of the environmental mitigation;

· monitor compliance with the environmental protection clauses/specifications in the Contract;

· review construction (demolition) programme and comment as necessary;

· review construction (demolition) methodology and comments as necessary;

· complaint investigation , evaluation and identification of corrective measures;

· liaison with IC(E) on environmental performance matters and submission of EM&A deliverables to IC(E) for approval; and

· advise on environmental improvement and enhancement.

1.9.9 Appropriate resources shall be allocated by the ET to fulfil the duties specified in this Manual.

1.9.10 Independent Checker (Environment). The role of the IC(E) shall be independent from the management of construction works; but the IC(E) shall be empowered to audit the environmental performance of construction (Appendix B). The IC(E) shall have a similar of level of experience as the ETL.

1.10 Demolition Programme

1.10.1 The details of the demolition works are not yet available but the estimated timing is towards the end of 2004. The buildings and chimney at KCIP can be demolished and removed by the conventional top down demolition using hand held tools and mechanical breaking methods within one year. The estimated time for the completion of these works based on professional experience and advice sought from local Contractors suggests 12 months would appear to be ample time for demolition based on the above methodology. The chimney demolition would follow demolition of the main building, and weighbridge. The EM&A programme will also cover the soil remediation work that will follow on from the demolition and may last another six to eight months.

1.10.2 This programme is for information for the ETL to get an initial idea of the sequencing of the works. It may be refined and amended by the Contractor(s). The ET Leader shall make reference to the actual works progress and programme during the construction stage to schedule the EM&A works. The project proponent shall require Contractor(s) to provide the relevant programme information to the ETL for formulating the EM&A schedule.

1.10.3 The EM&A programme will also cover the land remediation phase, which will be undertaken following the demolition of structures.

2. AIR QUALITY

2.1 Air Quality Parameters

2.1.1 The major air quality issue associated with the demolition at KCIP is the potential for dust generation to cause elevated Total Suspended Particulates (TSP) levels and a nuisance at the adjacent Kwai Chung PTW.

2.2 Total Suspended Particulates

2.2.1 Monitoring and audit of TSP levels shall be carried out by the ET to detect any deterioration in air quality. This will allow a pro-active approach to be taken in order to rectify the situation and avoid any breaches of the Hong Kong Air Quality Objectives (AQO). The proposed location is shown in Figure 2.1.

2.2.2 24-hour TSP levels shall be measured to indicate the impacts of construction dust on air quality. The TSP levels shall be measured by following the standard high volume sampling method as set out in the Title 40 of the Code of Federal Regulations, Chapter 1 (Part 50).

2.2.3 All relevant data including temperature, pressure, weather conditions, elapsed-time meter reading for the start and stop of the sampler, identification and weight of the filter paper, and other special phenomena and work progress on the site shall be recorded in detail.

2.3 Monitoring Equipment

2.3.1 High volume samplers (HVS) to be used for carrying out the 1-hour and 24-hour TSP monitoring shall comply with the following specifications:

· 0.6-1.7 m³/min (20-60 SCFM) adjustable flow range;

· equipped with a timing/control device with +/- 5 minutes accuracy for 24 hours operation;

· installed with elapsed-time meter with +/- 2 minutes accuracy for 24 hours operation;

· capable of providing a minimum exposed area of 406 cm² (63 in²);

· flow control accuracy: +/- 2.5% deviation over 24-hour sampling period;

· equipped with a shelter to protect the filter and sampler;

· incorporated with an electronic mass flow rate controller or other equivalent devices;

· equipped with a flow recorder for continuous monitoring;

· provided with a peaked roof inlet;

· incorporated with a manometer;

· able to hold and seal the filter paper to the sampler housing at horizontal position;

· easy to change the filter; and

· capable of operating continuously for 24-hour period.

2.3.2 The ET shall provide sufficient HVSs with the appropriate calibration kit to ensure that the baseline, impact and ad hoc monitoring commences on schedule and is not interrupted as a result of equipment failure, damage, loss or routine maintenance.

2.3.3 The HVSs shall be equipped with an electronic mass flow controller and be calibrated against a traceable standard at regular intervals. All the equipment, calibration kit, filter papers, etc. shall be clearly labelled.

2.3.4 Initial calibration of dust monitoring equipment shall be conducted upon installation and thereafter at bi-monthly intervals. The transfer standard shall be traceable to the internationally recognised primary standard and be calibrated annually. The calibration data shall be properly documented for future reference. All the data shall be converted into standard temperature and pressure conditions.

2.3.5 The flow-rate of the sampler, before and after the sampling exercise with the filter in position, shall be verified to be constant and be recorded in the data sheet.

2.3.6 The ET shall provide sufficient equipment to ensure that the monitoring commences on schedule and is not interrupted as a result equipment failure, damage, loss or routine maintenance.

2.4 Laboratory Measurement/ Analysis

2.4.1 A clean laboratory with constant temperature and humidity control, and equipped with necessary measuring and conditioning instruments, to handle the dust samples collected, shall be available for sample analysis, equipment calibration and maintenance.

2.4.2 If a site laboratory is set up or a non-HOKLAS accredited laboratory is hired for carrying out the laboratory analysis, the laboratory equipment shall be approved by the ER and the measurement procedures shall be witnessed by the ER. The ETL shall provide the ER with one copy of the Title 40 of the Code of Federal Regulations, Chapter 1 (Part 50).

2.4.3 Filter paper of size 8”x10” shall be labelled before sampling. It shall be a clean filter paper with no folds or pin holes, and shall be conditioned in a humidity controlled chamber for over 24-hour and be pre-weighed before sampling.

2.4.4 After sampling, the filter paper loaded with dust shall be kept in a clean and tightly sealed plastic bag. The filter paper shall be returned to the laboratory for reconditioning in the humidity controlled chamber followed by accurate weighing by an electronic balance with a readout down to 0.1 mg. The balance shall be regularly calibrated against a traceable standard.

2.4.5 All the collected samples shall be kept in a good condition for 6 months before disposal.

2.5 Monitoring Locations

2.5.1 Monitoring shall be conducted at one representative position at the boundary of the site adjacent to the Kwai Chung PTW. The equipment shall therefore be as adjacent to the potentially worst affected ASR as is practical. It is possible that the equipment could also be located within the boundary Kwai Chung PTW. Given the reason for the choice of location there should be few practical constraints such as lack of access, power or refusal for permission to locate equipment.

2.5.2 The proposed location is shown in Figure 2.1.

2.5.3 The status and location of dust sensitive receivers shall be reviewed after issue of this Manual. The ETL shall identify the ASR location to be adopted based on the updated construction (demolition) programme and seek approval from the ER and relevant Government Departments.

2.5.4 The monitoring location should be chosen based on the following criteria:

· a horizontal platform with appropriate support to secure the samplers against gusty wind should be provided;

· the distance between the sampler and an obstacle, such as buildings, must be at least twice the height that the obstacle protrudes above the sampler;

· a minimum of 2 metres of separation from walls, parapets and penthouses is required for rooftop samplers;

· a minimum of 2 metre separation from any supporting structure, measured horizontally is required;

· no active furnace or active incinerator flues should be nearby;

· airflow around the sampler should be unrestricted;

· the sampler should be more than 20 metres from any dripline;

· any wire fence and gate, to protect the sampler, should not cause any obstruction during monitoring;

· permission must be obtained to set up the samplers and to obtain access to the monitoring stations; and

· a secured supply of electricity is needed to operate the samplers.

2.6 Baseline Monitoring

Total Suspended Particulates

2.6.1 The ETL shall carry out baseline monitoring as close to the Kwai Chung PTW as is practical at a location agreed with EPD.

2.6.2 The exact locations should be agreed with the ER and relevant Government Departments prior to commencement of the monitoring programme and subject to practical considerations. If practical, this should match with the proposed permanent location for the monitoring equipment.

2.6.3 Monitoring shall be for 14 consecutive days prior to the commissioning of the demolition works to obtain daily 24-hour average TSP samples (total of 14 24-hour average measurements).

2.6.4 Construction or dust generation activities from the project with potential to affect the results shall not have commenced in the vicinity of the monitoring stations.

2.6.5 In exceptional cases, where insufficient baseline monitoring data or questionable results are obtained, the ETL shall liaise with the ER to agree on an appropriate set of data to be used as a baseline reference and submit to ER for approval and relevant Government Departments.

2.6.6 Ambient conditions may vary seasonally and shall be reviewed at three monthly intervals. The ETL may consider that the ambient conditions have changed and a repeat of the baseline monitoring is required in order to obtain the updated baseline levels. If so the new monitoring, to confirm ambient conditions, should be at times when the Contractor’s activities are not generating dust, at least in the proximity of the monitoring stations. Should changes in ambient conditions be determined, the baseline levels and, in turn, the air quality criteria, should be revised. The revised baseline levels and air quality criteria should be agreed with ER and relevant Government Departments.

2.7 Impact Monitoring

Total Suspended Particulates

2.7.1 The ET shall carry out regular impact monitoring during the course of the works. Monitoring shall be undertaken at 1 location for 24-hour TSP monitoring. A sampling frequency of one 24 hour measurement every six-days shall be adopted.

2.7.2 In case of non-compliance with the air quality criteria, more frequent monitoring shall be conducted within 24 hours of the non-compliance. This is specified in the Action Plan. Further monitoring shall be continued until the excessive dust emission or the deterioration in air quality is rectified.

2.8 Event and Action Plan for Air Quality

2.8.1 The baseline monitoring results form the basis for determining the air quality criteria for the impact monitoring. Table 2.1 shows the air quality criteria, namely Action and Limit levels, to be used. Should non-compliance of the air quality criteria occur, the ET, the ER and the Contractor(s) shall undertake the relevant action in accordance with the Action Plan in Table 2.2. Reference should be made to Appendix B for the IC(E)'s role (not included in the main body of the report as this does not form part of the contractual requirements of the EM&A Manual).

Table 2.1 Action and Limit Levels for Air Quality

Parameters	Action	Limit*
24 Hour TSP Level in mg/m³	For baseline level < 200 mg/mAction level = (Baseline level * 1.3 + Limit level)/2; For baseline level > 200 mg/m Action level = Limit level	260
1 Hour TSP Level in mg/m³	For baseline level < 384 mg/m Action level = (Baseline level * 1.3 + Limit level)/2; For baseline level > 384 mg/m Action level = Limit level	500

Parameters

Action

Limit*

24 Hour TSP Level in mg/m³

For baseline level < 200 mg/mAction level = (Baseline level * 1.3 + Limit level)/2;

For baseline level > 200 mg/m Action level = Limit level

260

1 Hour TSP Level in mg/m³

For baseline level < 384 mg/m Action level = (Baseline level * 1.3 + Limit level)/2;

For baseline level > 384 mg/m Action level = Limit level

500

Table 2.2 Event/Action Plan for Air Quality

			ACTION
1. Exceedance for one sample	1. Identify source 2. Inform (C(E) and ER 3. Repeat measurement to confirm finding 4. Increase monitoring frequency to daily	1. Check monitoring data submitted by ET 2. Check Contractor’s working method	1. Notify Contractor 2. Check monitoring data and Contractor's working methods	1. Rectify any unacceptable practice 2. Amend working methods if appropriate
2. Exceedance for two or more consecutive samples	1. Identify source 2. Inform IC(E) and ER 3. Repeat measurements to confirm findings 4. Increase monitoring frequency to daily 5. Discuss with Contractor , IC(E) and ER for remedial actions required 6. If exceedance continues, arrange meeting with IC(E) and ER 7. If exceedance stops, cease additional monitoring	1. Checking monitoring data submitted by ET 2. Check Contractor’s working method 3. Discuss with ET and Contractor on possible remedial measures 4. Advise the ER on the effectiveness of the proposed remedial measures 5. Supervise implementation of remedial measures	1. Confirm receipt of notification of failure in writing 2. Notify Contractor 3. Check monitoring data and Contractor's working methods 4. Discuss with IC(E) and Contractor on potential remedial actions 5. Ensure remedial actions properly implemented	1. Submit proposals for remedial actions to ER within 3 working days of notification 2. Implement the agreed proposals 3. Amend proposal if appropriate
LIMIT LEVEL
1. Exceedance for one sample	1. Identify source 2. Inform ER and EPD 3. Repeat measurement to confirm finding 4. Increase monitoring frequency to daily 5. Assess effectiveness of Contractor's remedial actions and keep IC(E), EPD and ER informed of the results	1. Checking monitoring data submitted by ET 2. Check Contractor’s working method 3. Discuss with ET and Contractor on possible remedial measures 4. Advise the ER on the effectiveness of the proposed remedial measures 5. Supervisor implementation of remedial measures	1. Confirm receipt of notification of failure in writing 2. Notify Contractor 3. Check monitoring data and Contractor's working methods 4. Discuss with ET Leader and Contractor potential remedial actions 5. Ensure remedial actions properly implemented	1. Take immediate action to avoid further exceedance 2. Submit proposals for remedial actions to ER within 3 working days of notification 3. Implement the agreed proposals 4. Amend proposal if appropriate
2. Exceedance for two or more consecutive samples	1. Identify source 2. Inform IC(E), ER and EPD the causes & actions taken for the exceedances 3. Repeat measurement to confirm findings 4. Increase monitoring frequency to daily 5. Investigate the causes of exceedance, Contractor’s working procedures to identify possible mitigation 6. Arrange meeting with IC(E) and ER to discuss the remedial actions to be taken 7. Assess effectiveness of Contractor's remedial actions and keep IC(E), EPD and ER informed of the results 8. If exceedance stops, cease additional monitoring	1. Discuss amongst ER, ET and Contractor as the potential remedial actions 2. Review Contractor’s remedial actions whenever necessary to ensure their effectiveness and advise the ER accordingly 3 Supervise the implementation of remedial measures	1. Confirm receipt of notification of failure in writing 2. Notify Contractor 3. Carry out analysis of Contractor's working procedures with IC(E) to determine possible mitigation to be implemented 4. Discuss amongst Environmental Team Leader and the Contractor potential remedial actions 5. Review Contractor's remedial actions whenever necessary to assure their effectiveness 6. If exceedance continues, consider what portion of the work is responsible and instruct the Contractor to stop that portion of work until the exceedance is abated	1. Take immediate action to avoid further exceedance 2. Submit proposals for remedial actions to ER within 3 working days of notification 3. Implement the agreed proposals 4. Resubmit proposals if problem still not under control 5. Stop the relevant portion of works as determined by the ER until the exceedance is abated

ACTION

EVENT

IC(E)

CONTRACTOR

ACTION LEVEL

1. Exceedance for one sample

1. Identify source

2. Inform (C(E) and ER

3. Repeat measurement to confirm finding

4. Increase monitoring frequency to daily

1. Check monitoring data submitted by ET

2. Check Contractor’s working method

1. Notify Contractor

2. Check monitoring data and Contractor's working methods

1. Rectify any unacceptable practice

2. Amend working methods if appropriate

2. Exceedance for two or more consecutive samples

1. Identify source

2. Inform IC(E) and ER

3. Repeat measurements to confirm findings

4. Increase monitoring frequency to daily

5. Discuss with Contractor , IC(E) and ER for remedial actions required

6. If exceedance continues, arrange meeting with IC(E) and ER

7. If exceedance stops, cease additional monitoring

1. Checking monitoring data submitted by ET

2. Check Contractor’s working method

3. Discuss with ET and Contractor on possible remedial measures

4. Advise the ER on the effectiveness of the proposed remedial measures

5. Supervise implementation of remedial measures

1. Confirm receipt of notification of failure in writing

2. Notify Contractor

3. Check monitoring data and Contractor's working methods

4. Discuss with IC(E) and Contractor on potential remedial actions

5. Ensure remedial actions properly implemented

1. Submit proposals for remedial actions to ER within 3 working days of notification

2. Implement the agreed proposals

3. Amend proposal if appropriate

LIMIT LEVEL

1. Exceedance for one sample

1. Identify source

2. Inform ER and EPD

3. Repeat measurement to confirm finding

4. Increase monitoring frequency to daily

5. Assess effectiveness of Contractor's remedial actions and keep IC(E), EPD and ER informed of the results

1. Checking monitoring data submitted by ET

2. Check Contractor’s working method

3. Discuss with ET and Contractor on possible remedial measures

4. Advise the ER on the effectiveness of the proposed remedial measures

5. Supervisor implementation of remedial measures

1. Confirm receipt of notification of failure in writing

2. Notify Contractor

3. Check monitoring data and Contractor's working methods

4. Discuss with ET Leader and Contractor potential remedial actions

5. Ensure remedial actions properly implemented

1. Take immediate action to avoid further exceedance

2. Submit proposals for remedial actions to ER within 3 working days of notification

3. Implement the agreed proposals

4. Amend proposal if appropriate

2. Exceedance for two or more consecutive samples

1. Identify source

2. Inform IC(E), ER and EPD the causes & actions taken for the exceedances

3. Repeat measurement to confirm findings

4. Increase monitoring frequency to daily

5. Investigate the causes of exceedance, Contractor’s working procedures to identify possible mitigation

6. Arrange meeting with IC(E) and ER to discuss the remedial actions to be taken

7. Assess effectiveness of Contractor's remedial actions and keep IC(E), EPD and ER informed of the results

8. If exceedance stops, cease additional monitoring

1. Discuss amongst ER, ET and Contractor as the potential remedial actions

2. Review Contractor’s remedial actions whenever necessary to ensure their effectiveness and advise the ER accordingly

3 Supervise the implementation of remedial measures

1. Confirm receipt of notification of failure in writing

2. Notify Contractor

3. Carry out analysis of Contractor's working procedures with IC(E) to determine possible mitigation to be implemented

4. Discuss amongst Environmental Team Leader and the Contractor potential remedial actions

5. Review Contractor's remedial actions whenever necessary to assure their effectiveness

6. If exceedance continues, consider what portion of the work is responsible and instruct the Contractor to stop that portion of work until the exceedance is abated

1. Take immediate action to avoid further exceedance

2. Submit proposals for remedial actions to ER within 3 working days of notification

3. Implement the agreed proposals

4. Resubmit proposals if problem still not under control

5. Stop the relevant portion of works as determined by the ER until the exceedance is abated

Parameter	Measurement	Required Action
O₂	< 19 %	Increase ventilation to restore O₂ to >19%
< 18 %	Stop work
Evacuate Personnel
Increase ventilation to restore O₂ to >19%
CH₄	> 10 % LEL	Prohibit hot works
Increase ventilation to restore CH₄to < 10 % LEL
> 20 % LEL	Stop work
Evacuate Personnel
Increase ventilation to restore CH₄to < 10 % LEL
CO₂	> 0.5 %	Increase ventilation to restore CO₂ to < 0.5 %
> 1.5 %	Stop work
Evacuate Personnel
Increase ventilation to restore CO₂ to < 0.5 %

Methane	0 - 100 % LEL and 0 - 100 % v/v
Carbon Dioxide	0 - 20 % v/v
Oxygen	0 - 21 % v/v

5. Water Quality

5.1 Sources of Water Quality Impacts

5.1.1 Surplus water may arise on site from three main sources. During the demolition works when it rains site run-off and surface water drainage have the potential to contain elevated levels of suspended solids. During the soil remediation phase site run-off and surface water drainage will remain as a potential impact but it may also be the case that soil decontamination procedures (including dewatering) result in the generation of surplus water for disposal. Sewage effluents generated from the workforce may also occur in both phases.

5.1.2 Site run-off and drainage should be prevented or minimised in accordance with the guidelines stipulated in the EPD Practice Note for Professional Persons, Construction Site Drainage (ProPECC PN 1/94). Reuse of water on site is to be encouraged wherever possible. Good housekeeping and storm-water best management practices, detailed below, shall be implemented to ensure that WPCO standards are met and that no unacceptable impacts on the WSR arise due to the demolition of KCIP. All discharges from the site shall be controlled in order to comply with the standards for effluents discharged into the Victoria Harbour WCZ under the TM.

5.2 Sewage Effluents

5.2.1 Sewage discharges from the demolition workforce on site shall be connected to the existing sewer and diverted to sewage treatment facilities. If it emerges that that no sewer connection is available during certain stages of the demolition works the installation of adequate portable chemical toilets will need to be provided by a licensed contractor who will be responsible for the proper maintenance of these facilities. Assuming that either the foul sewer or portable toilets are utilised throughout the demolition works no adverse water quality impacts should arise from the demolition workforce sewage.

5.3 Site Run-off and Surface Water Drainage during Demolition

5.3.1 Whereas the majority of the site has a hard concrete covering the area of potentially exposed soil will be minimal. Such areas and the accumulation of dust and fine waste material shall be kept to a minimum to reduce the potential for siltation, contamination of run-off, and erosion.

Mitigation Measures

5.3.2 Run-off related impacts associated with demolition work and other general activities can all be readily controlled through the use of appropriate mitigation measures which include:

· The use of sediment traps, where appropriate; and

· The adequate maintenance of drainage systems to prevent flooding and overflow.

5.3.3 Critical areas within the Site shall be clearly marked and provided with protective measures to control site run-off. Temporary channels shall be provided to facilitate run-off discharge into the appropriate watercourses, via a silt retention pond. Permanent drainage channels shall incorporate sediment basins or traps and baffles to enhance deposition rates.

5.3.4 Temporary and permanent drainage pipes and culverts which are provided to facilitate run-off discharge shall be adequately designed for the controlled release of storm flows. All sediment traps shall be regularly cleaned and maintained. Temporarily diverted drainage shall be reinstated to its original condition when the demolition work has finished or the temporary diversion is no longer required.

5.3.5 Wheel washing facilities will be installed to ensure no earth, mud and debris is deposited on roads. Sand and silt in the wash water from such facilities shall be settled out and removed before (in line with effluent discharge standards, Appendix C) discharging the used water into storm drains. A section of the road between the wheel washing bay and the public road shall be paved with backfall to prevent wash water or other site run-off from entering public road drains.

5.3.6 Oil interception facilities should be provided in appropriate areas in the drainage system, where oil spills may occur, and regularly emptied to prevent the release of oil and grease into the storm water drainage system after accidental spillage.

5.3.7 Provided the surface run-off and drainage are effectively managed and controlled over the site, adverse water quality impacts can be avoided.

5.3.8 All demolition works will be land based and the EIA concludes that no insurmountable water quality impacts will result from the demolition work of KCIP provided that:

· All the recommended mitigation measures including appropriate drainage and silty run-off collection facilities are incorporated in accordance with the recommendations of ProPEC PN 1/94;

· All demolition workforce sewage is discharged either to foul sewer or to temporary portable toilets, as appropriate according to the demolition programme and methodology;

· All temporary drainage diversions will be reinstated to the original condition after the demolition works are completed and implemented properly, in accordance with the recommendations of ProPECC PN 1/94; and

· All demolition works area discharges must comply with the TM standards of the WPCO in respect of all applicable WQ parameters. Any practical options for the diversion and re-alignment of drainage should comply with both engineering and environmental requirements. General Demolition Activities

5.3.9 Debris and rubbish on site should be collected, handled and disposed of properly to prevent such material from entering the water column and causing water quality impacts. The solid waste management requirements are presented later in this report.

5.3.10 If required, fuel storage areas should be provided with locks and be sited on sealed areas, within bunds of a capacity equal to 110% of the storage capacity of the largest container (to provide a safety margin) and control spilt fuel oils.

5.3.11 The effects on water quality from these demolition activities are likely to be minimal provided that site boundaries are well maintained and good site practice is observed to ensure that litter and fuels are managed, stored and handled properly

5.3.12 It is considered that controls on discharges from land based demolition activities and proper site management procedures, as referenced above, will minimise residual water quality impacts to the acceptable levels stipulated in the WPCO criteria.

5.4 Site Run-off and Surface Water Drainage during Soil Remediation

Site Run - off

5.4.1 The above mitigation shall also apply generally to all excavated and/or stockpiled materials during the soil remediation process. In practice the consultants experience suggests that runoff from the site can be controlled even though the hard concrete covering is removed in places and the area of potentially exposed soil in greater than during the demolition. Surplus water arising from dewatering is to be collected on site for re-use where possible (see below).

5.4.2 The exposed areas and the accumulation of dust and fine waste material shall be kept to a minimum to reduce the potential for siltation, contamination of run-off, and erosion. It is recommended that the mixing of concrete with contaminated soil be carried out on a concrete covered area with bunding to control run-off, especially if heavy rain were to occur during the period while the cement sets. Bunding or sand-bagging around the excavated pits is also recommended to minimise ingress of water. However, impacts associated with this work and other general activities can be all readily controlled through the use of appropriate mitigation measures mentioned above.

Dewatering

5.4.3 In addition, the Contractor is strongly advised to operate any necessary ground remediation works such that discharge of groundwater should be kept to minimum. This could be achieved by:

· minimising the ingress of surface water, which would mix with groundwater extracted during ground excavation if any; and

· reusing water on-site in ground remediation processes (mixing with cement).

5.4.4 In a case where any surplus groundwater is generated the Contractor must ensure that any effluent that requires to be discharged from the site satisfies the TM Requirements under the WPCO (Appendix C).

5.4.5 Surplus water arising from dewatering is to be collected on site for re-use where possible. Groundwater and leachate shall be reused and mixed with cement in the immobilisation process for contaminated soils. Surplus groundwater shall be collected and tested for metals and other pollutants for compliance with standards for effluents discharged into the Victoria Harbour WCZ under the TM. If the concentrations of contaminants exceed the standards the surplus water shall be treated.

Treatment of Surplus Groundwater Prior to Discharge

5.4.6 Treatment methods for any surplus contaminated groundwater, such as the addition of chemicals have been covered in the EIA. These industry standard methods will precipitate out contaminants and floating free products can be removed using an interceptor tank by flotation. The contractor shall therefore make provisions to include for treatment of surplus groundwater to reduce chemical concentrations in order to comply with the standards for effluents discharged into the inshore waters of Victoria Harbour WCZ under the TM.

5.4.7 The EIA has indicated that it is not possible to rule out the requirement to discharge leachate. If the volumes are low it is possible that limited quantities could be discharged to the foul sewer. In this case the necessary permissions and discharge licences would need to be obtained from the authorities under the relevant legislation. However the contractor shall not discharge directly or indirectly into any public sewer stormwater drain any effluent or contaminated water without the prior written consent of the site engineer in consultation with the Director of Environmental Protection (DEP). In granting this permission the DEP may require the contractor to maintain suitable works for the treatment and disposal of such effluent or contaminated water (surplus groundwater or leachate). The contractor shall therefore make provisions to include for treatment of surplus groundwater or leachate to reduce chemical concentrations in order to comply with the standards for effluents discharged into the inshore waters of Victoria Harbour WCZ. These facilities should be in place before the need arises to make any discharge of such effluent.

5.5 Conclusions

5.5.1 The EIA report has recommended water quality control and mitigation measures. The Contractor shall be responsible for the design and implementation of these measures. Monitoring of effluents for compliance with the Marine Water Quality will not be necessary and no insurmountable water quality impacts will result from the demolition work of KCIP provided that the above mitigation measures are implemented.

.

6. Waste Management

6.1 Waste Management

6.1.1 The Contractor shall be responsible for waste control within the construction site, removal of the waste material produced from the site and implementation of any mitigation measures to minimise waste or redress problems arising from the waste from the site.

6.1.2 The variety of wastes generated from demolition activities can be divided into certain categories based on the constituent elements and include:

· Construction and Demolition (C&D) materials;;

· Chemical waste; and

· General refuse.

6.1.3 The environmental impacts from the various waste types are summarised in Table 6.1.

Table 6.1 Summary of Waste Management Impacts

Waste Type	General Evaluation
C&D material	The total quantities of C&D materials which will be generated will be about 200te day^-1, in comparison with the disposal capacity available at public filling areas, it is small. Due to the inert nature of most C&D material and the availability of public filling areas, disposal is not likely to raise long term environmental concerns.
Chemical Waste	A small volume of chemical waste, as well as asbestos containing roofing materials and louvres (preliminary estimate, up to 2,000m³) will be produced. Temporary storage on site, handling, transport and disposal must be in accordance with the Code of Practice on the Handling, Transportation and disposal of Asbestos Waste. Provided that this occurs, and chemical wastes are disposed of at a licensed facility, and there will be little environmental impact.
General Refuse	If good practice is adhered to and all feasible avoidance, reuse and recycling opportunities are taken, including minimising over ordering, there should be minimal impact.

6.2 Mitigation Measures

Introduction

6.2.1 This section sets out recycling, storage, transportation and disposal measures which are recommended to avoid or minimise potential adverse impacts associated with waste arisings from the demolition of the KCIP, under the headings of each waste type. The Contractor should incorporate these recommendations into a comprehensive on-site waste management plan. Such a waste management plan should incorporate site specific factors, such as the designation of areas for the segregation and temporary storage of reusable and recyclable materials ad be in compliance with the Works Bureau Technical Circular No. 29/2000 – Waste Management Plan.

Waste Management Hierarchy

6.2.2 The various waste management options can be categorised in terms of preference from an environmental viewpoint. The options considered to be more preferable have the least impacts and are more sustainable in a long term context. Hence, the hierarchy is as follows:

· Avoidance and minimisation by not generating waste through changing or improving practices and design;

· Reusing materials and therefore avoiding disposal (generally with only limited reprocessing);

· Recovery and recycling, avoiding disposal (although reprocessing may be required); and

· Treatment and disposal, according to relevant laws, guidelines and good practice.

6.2.3 The Waste Disposal Authority should be consulted by the Contractor on the final disposal of wastes.

6.2.4 This hierarchy should be used to evaluate waste management options, thus allowing maximum waste reduction and often reducing costs. For example, by reducing or eliminating over-ordering of materials required to undertake the demolition, waste is avoided and costs are reduced both in terms of purchasing and in disposing of wastes.

C&D material

6.2.5 At this stage a broad estimate up to 1500m³ of C&D materials will arise at the KCIP demolition site each month. Generation of C&D waste requiring disposal at landfill(s) is estimated to be a relatively low proportion of this total. In order to minimise waste and maintain environmental impacts within acceptable levels, the mitigation measures described below should be adopted. It can also be expected that some small quantities of oil stained concrete will be generated and these will need to be treated as chemical waste for disposal purposes and appropriate measures are described.

6.2.6 In accordance with the New Disposal Arrangement for Construction Waste, Environmental Protection Department, 1992, disposal of C&D material can either be at a specified landfill, or at a public filling facility with the latter being the preferred option. However C&D materials currently comprise a high proportion of C&D waste inputs to landfills and in order to maximise landfill life, Government policy prohibits the disposal of C&D material to landfill if it contains more than 20% inert material by volume. Such inert wastes are directed to reclamation areas, where they have the added benefit of offsetting the need for removal of materials from terrestrial borrow areas for reclamation purposes. In the same way that materials which may be recycled should be segregated from other wastes, clean inert waste, suitable for disposal at public filling areas, should be segregated from any ‘contaminated’ wastes which will require landfill disposal.

6.2.7 The Contractor should recycle C&D material on-site as far as possible. Planning, careful design and good site management of the demolition process can minimise over ordering and avoidable waste. Areas within the Site areas can be segregated for the separation and storage. Proper segregation of wastes on site will increase the feasibility of utilising recycling contractors to recycle certain components of the waste stream. Concrete and masonry can be crushed and used as fill to level the site after demolition. However there will be little or no excavation of any underground structures therefore the majority of inert waste will need to be delivered to public filling areas. Steel reinforcing bars can be re-used by scrap steel mills.

6.2.8 If landfill disposal has to be used, the C&D wastes will most likely be delivered to the WENT Landfill or SENT Landfill. Government is currently studying the possibilities of introducing a pilot C&D waste recycling facility that would offer another alternative if it were in operation by the time demolition for KCIP takes place.

6.2.9 The provisions of WBTC No. 5/98 (On Site Sorting of Construction Waste on Demolition Sites) shall be followed. At present, Government is developing a charging policy for the disposal of C&D waste to landfill. When it is implemented, this will provided additional incentive to reduce the volume of waste generated and hence encourage the appropriate sorting and segregation of different types of C&D material.

Chemical Waste

6.2.10 For those processes that generate chemical waste, it may be possible to find alternatives that generate reduced quantities or even no chemical waste, or less dangerous types of chemical waste.

6.2.11 Chemical waste that is produced, as defined under section 3 of the Waste Disposal (Chemical Waste) (General) Regulation, should be handled in accordance with the Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes as follows.

6.2.12 Containers used for the storage of chemical wastes should:

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

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

· Display a label in English and Chinese in accordance with instructions prescribed in Schedule 2 of the Regulations.

6.2.13 The storage area for chemical wastes should:

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

· Be enclosed on at least 3 sides;

· Have an impermeable floor and bunding, of capacity to accommodate 100% of the volume of the largest container or 20% by volume of the chemical waste stored in that area, whichever is the greatest;

· Have adequate ventilation;

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

· Be arranged so that incompatible materials are adequately separated.

6.2.14 Disposal of chemical waste should:

· Be via a licensed waste collector; and

· Be to a facility licensed to receive chemical waste, such as the Chemical Waste Treatment Facility which also offers a chemical waste collection service and can supply the necessary storage containers; or

· Be to a recycling or reprocessing facility , licensed by EPD.

6.2.15 The Centre for Environmental Technology operates a Waste Exchange Scheme which can assist in finding receivers or buyers.

6.2.16 Asbestos waste that is produced should be handled in accordance with the Code of Practice on the Handling, Transportation and Disposal of Asbestos Wastes. The detailed requirements will be presented in the Asbestos Study Report.

Disposal of Residual Ash Waste (Ash Bunker Wall)

6.2.17 EPD indicated that the PCDD/PCDF contaminated ash waste (20m³approx.) could be disposed of at CWTC. Remedial action has been recommended and action will be required to clean up these materials prior to the demolition. Treatment on-site prior to disposal at a landfill is the preferred method. This material must be immobilised on site, tested to ensure compliance with TCLP testing requirements (Appendix D) and removed by an appropriately qualified specialist contractor and must be collected, deposited at landfill in accordance with criteria and conditions as specified in agreement with EPD.

6.2.18 The proposed method of disposal is for the ash waste to be collected up and stabilised to meet landfill disposal criteria of EPD. In this case it is envisaged that the process would involve collection and mixing the ash material with cement. Pilot mixing and TCLP tests should establish the ratio of cement to ash to the satisfaction of EPD in line with the Guidance Notes for Investigation and Remediation of Contaminated Site. The materials for disposal would then be treated and the extracted material placed into polythene lined steel drums. Transparent plastic sheeting of 0.15mm thickness low-density polythene or PVC should be employed. The drums should be 16 gauge steel or thicker and fitted with double bung fixed ends adequately sealed and well labelled in new or good condition. Prior agreement of the disposal criteria from EPD and agreement to disposal from the landfill operator must be obtained.

6.2.19 The SENT Landfill has been identified as the appropriate location for disposal. However, disposal at the CWTC should be considered as a fall back option (as a last resort) if the landfill disposal criteria cannot be met.

Protection of Site Workers

6.2.20 The release of contaminants from disturbed ash should be minimised prior to gathering up the ash materials and amended water containing a wetting agent should be sprayed on the ash. The wetting agent will assist in water penetration to thoroughly soak the ash and ensure dust levels are reduced without use of excessive water. (Spray shall comprise 50% polyoxyethylene ester and 50% polyoxyethylene ether, or equivalent, diluted to specific concentration in accordance with the manufacturer’s instructions). The use of amended water for dust suppression will minimise the use of excessive water that would result in surface runoff in the removal process. Dust suppression can therefore be carried out in a controlled manner and no insurmountable environmental problem would result.

6.2.21 Given the nature of the work and the contaminants involved consideration should be given to the use of decontamination facilities (showers) that should be provided for the work force to remove contamination after work.

6.2.22 Preliminary provisions for the protection of workers during the management of the ash removal are presented in Appendix E.

6.2.23 Handling, transportation and disposal of the ash waste shall be carried out according to the relevant regulations.

6.2.24 As a fall back option the materials can be transported to the CWTC for disposal if the landfill criteria cannot be met. No PCDD/PCDF were detected above the USEPA criterion at any other locations in soil samples. Remedial action will be required to clean up these materials prior to the demolition. The material that is contaminated is deposited on the walls. As such, there is no opportunity for in-situ containment or treatment of this material in the context of the ultimate redevelopment of the site. Therefore, there is no alternative but to dispose of this material offsite. This should be undertaken prior to the demolition of any structures.

General Refuse

6.2.25 General refuse should be stored in enclosed bins or compaction units separate from demolition and chemical wastes. A reputable waste collector should be employed by the Contractor to remove general refuse, separately from C&D material and chemical wastes, daily to minimise odour, pest and litter impacts. The burning of refuse on construction sites is prohibited by law.

6.2.26 General refuse is generated largely by food service activities on site, so reusable rather than disposable dishware should be used if feasible. Aluminium cans are often recovered from the waste stream by individual collectors if they are segregated or easily accessible, so separate, labelled bins for their deposit should be provided if feasible.

6.2.27 Office wastes can be reduced through recycling of paper if volumes are large enough to warrant collection. Participation in a local collection scheme should be considered if one is available.

Storage areas for different waste types

6.2.28 Different types of waste should be segregated and stored in different containers, skips or stockpiles to enhance reuse or recycling of materials and their proper disposal.

6.2.29 An on-site temporary storage area should also be provided.

Trip-ticket system

6.2.30 In order to monitor the disposal of C&D and solid wastes at public filling facilities and landfills, and control fly-tipping, a trip-ticket system (Works Bureau Technical Circular No. 5/99, Trip-ticket System for Disposal of Construction and Demolition Material) should be included as one of the contractual requirements and implemented under the supervision of the Environmental Team. The system should be subject to independent auditing by the IC(E).

Training and Records of wastes

6.2.31 A waste management plan will be requited under Works Bureau Technical Circular No. 29/2000. This should include a description of the training proposed to educate the workforce on the requirements of the Waste Disposal Ordinance, subsidiary legislation and guidelines listed above. The training should include as a minimum arrangements for waste management, On Site Sorting of Construction Waste on Demolition Sites (WBTC No. 5/98), Trip-ticket System for Disposal of Construction and Demolition Material (WBTC No. 5/99).

6.2.32 A recording system for the amount of wastes generated, recycled and disposed (including the disposal sites) should be proposed.

Waste Management Requirements

6.2.33 This section describes waste management requirements and provides practical actions which can be taken to minimise the impacts arising as a result of the generation, storage, handling, transport and disposal of wastes. A Waste Management Plan will be required for all stages of the demolition and soil remediation works in line with Works Bureau Technical Circular No. 29/2000.

6.2.34 Waste reduction is best achieved at the planning and design stage, as well as by ensuring that processes are run in the most efficient way. Good management and control can prevent the generation of significant amounts of waste. For unavoidable wastes, reuse, recycling and optimal disposal are most practical when segregation occurs on the demolition site, as follows:

· Public fill (inert) for disposal at public filling areas;

· C&D waste (non-inert) for landfill;

· Chemical waste for treatment at licensed facilities; and

· General refuse for disposal at landfill.

6.2.35 The criteria for sorting solid waste is described in New Disposal Arrangements for Construction Waste, Environmental Protection Department and Civil Engineering Department, 1992 and Works Bureau Technical Circular No. 5/98, On Site Sorting of Construction Waste on Demolition Sites. C&D material containing in excess of 20% by volume of inert materials should be segregated from C&D waste with a larger proportion of putrescible material. In preference the inert materials shall be directed to the proposed Pilot C&D Waste Recycling Facility at Kai Tak and after early 2005 excess materials could be directed to the adjacent proposed public filling barging point on Area 30D.

6.2.36 Proper storage and site practices will minimise the damage to, or contamination of, demolition C&D materials that may reduce their recyclability and suitability for disposal in public filling areas. On site measures may be implemented which promote the proper disposal of wastes once off-site. For example having separate skips for inert (rubble, sand, stone, etc) and non-inert (wood, organics, etc) materials would help to ensure that the former are taken to public filling areas, while the latter are properly disposed of at controlled landfills. Since public fill brought to public filling areas will not attract a charge, while C&D waste taken to landfill may attract some charge in the future, separating C&D material may also help to reduce waste disposal costs, should landfill charging be introduced.

6.2.37 Specifically, it is recommended that:

· Wastes should be handled and stored in a manner which ensures that they are held securely without loss or leakage thereby minimising the potential for pollution;

· Only reputable waste collectors authorised to collect the specific category of waste concerned should be employed;

· Appropriate measures should be employed to minimise windblown litter and dust during transportation by either covering trucks or transporting wastes in enclosed containers;

· The necessary waste disposal permits should be obtained from the appropriate authorities, if they are required, in accordance with the Waste Disposal Ordinance (Cap 354), Waste Disposal (Chemical Waste) (General) Regulation and the Government Land Ordinance (Cap 28);

· Collection of general refuse should be carried out frequently, preferably daily;

· Waste should only be disposed of at licensed sites and site staff and the civil engineering Contractor should develop procedures to ensure that illegal disposal of wastes does not occur;

· Waste storage areas should be well maintained and cleaned regularly; and

· Records should be maintained of the quantities of wastes generated, recycled and disposed, determined by weighing each load.

EM&A Requirements

6.2.38 It is recommended that auditing of each waste stream, including any waste arising from the decontamination of soils and the remediation procedures should be carried out periodically by the EM&A Team to determine if wastes are being managed in accordance with approved procedures. The audits should look at all aspects of waste management including waste generation, storage, recycling, treatment, transport, and disposal. An appropriate audit programme would be to undertake a first audit at the commencement of the demolition works, and then to audit quarterly thereafter.

6.2.39 It is likely that relatively small quantities of C&D materials will require disposal at landfill. The bulk of the C&D materials will be disposed at public filling areas and some, in particular reinforcement bar, will be recycled. Limited quantities of chemical wastes (mainly asbestos) and general wastes will be generated. Mitigation measures relating to good practice have been recommended to ensure that adverse environmental impacts are prevented and that opportunities for waste minimisation and recycling are followed.

6.2.40 Provided that the recommendations are thoroughly implemented the storage, handling, collection, transport, and disposal of wastes arising from the demolition of KCIP will be in full compliance with the regulatory requirements.

7. Contaminated Land

7.1 Remediation Action Plan

7.1.1 During the demolition phase, the monitoring and audit requirements recommended include a proactive approach to air quality monitoring. The demolition will only be for above ground structures but this approach should continue in the soil remediation phase.

7.1.2 During the subsequent soil remediation, requirements for clean-up and procedures are in line with the Guidance Notes for Investigation and Remediation of Contaminated Site documented in the EIA Report. Actions required post demolition are presented in Table 7.1, which indicates where remedial action will be required, where reassurance/confirmatory sampling is warranted and summarises the locations requiring clean up based on the available information. In order to make sure that all contaminated material is excavated a margin of about 0.5metre is allowed above and below the shallowest and deepest contamination detected. In addition reassurance / confirmatory sampling is required at the boudaries of the excavations to make sure that all contaminated material is excavated. If residual contamination is still detected by the reassurance sampling at the periphery of the excavation, the pit shall be extended one metre in the direction of the residual contamination. The extracted soil shall be treated as with the materials already extracted in that location and reassurance / confirmatory sampling carried out again (Figure 7.2).

7.1.3 The ETL will be required to audit the working methods to ensure that the remediation is carried out according to the specification and the recommendations of the EIA. The above recommendations for air, waste and water quality monitoring will apply. Reassurance sampling will be required to ascertain that the remedial action plan has been carried out effectively and a summary report shall be issued to EPD at the completion of the remedial works programme. Interim reports should also be submitted to allow EPD to monitor the progress of the remedial works.

7.2 Mitigation Measures

Management of Contaminated Soil Material

7.2.1 Although ground conditions on the site are contaminated with metals and some organic compounds, at this stage the only opportunity for human exposure to any of the contamination on site will be if the materials are excavated. Contaminated ash waste (20m³approx.) will be cleaned up prior to the demolition and treatment on-site prior to disposal at a landfill is the preferred method. This material must be treated on site (see section 6) and removed by an appropriately qualified specialist contractor and must be collected, deposited at landfill in accordance with criteria and conditions as specified in agreement with EPD.

7.2.2 For this site and any potential redevelopment, the preferred approach with least environmental impact, is to cause minimal disturbance to the ground conditions, immobilise the contaminated soils where necessary and make provisions for the protection of workers. Where this is not appropriate the disposal of some small amount of material to landfill may be a more suitable remedial option.

Volume of Soil for Immobilisation

7.2.3 The volume of soil to be treated on site has been estimated by making a broad brush estimate based on depths to which materials >Dutch B are identified by sampling. The estimated total of about 1750m³ is preliminary and assumes that all material within 5m (10m x 10m square hole) at the contaminated depths would be treated (Figure 7.1). This excludes the 450m³for disposal at landfill. The material is not disposed of off site and therefore off site effects are minimised. However it is possible that reassurance sampling at the periphery and base of the excavations will identify further contaminated materials at a later stage, however it is not possible to predict the extent of this contamination based on current information.

Volume of Soil to Landfill

7.2.4 A volume of about 450m³ contaminated with hydrocarbons would be directed to landfill. Again this estimate is preliminary and assumes that all material within 5m (10m x 10m square hole) at the contaminated depths would be treated. In this case the material is disposed off-site, however the quantities are small perhaps resulting in a few tens of lorry loads and therefore off-site effects are not expected to cause any in-surmountable environmental problems. The precise volume of hydrocarbon contaminated waste is also difficult to determine. However, the hydrocarbon contaminated soil appears to be confined to the lower depths at one end of the site. Whereas it is possible that reassurance sampling at the periphery and base of the excavations will identify further contaminated materials at a later stage, it is not possible to predict the extent of any additional contamination based on current information.

7.3 Protection of Site Workers during excavation and treatment of soils

7.3.1 General site safety provisions incorporate some basic practices such as the provision of safety boots, hard hat, overalls, gloves and eye protection. In addition, dust masks shall be made available and sufficient first aid facilities and procedures and appropriate washing amenities. It is important to avoid skin contact, ingestion and inhalation of contaminated materials, however this would not normally be a significant risk provided basic personal protective equipment is provided. In addition to statutory occupational safety requirements site staff shall be given adequate training and instruction specific to the potential hazards in the work place, their health and safety responsibilities and safe working practice including basic personal hygiene, which is important on contaminated sites.

7.3.2 Given the potential for hydrocarbons (TPH) in the soil and groundwater, skin contact shall be avoided. Prolonged exposure (i.e. skin contact) can potentially result in dry skin, irritation and allergic dermatitis although these effects would not normally cause acute reactions at the concentrations encountered so far encountered at this site. Exposure to dusty material shall be avoided. Dust shall be controlled at source by damping techniques and operatives shall be protected by the use of dust masks.

7.3.3 To ensure that the health and safety measures outlined above are actually implemented on-site, specific clauses can be incorporated into the contract documents, and the proponent shall provide and EM&A team with experienced staff on similar sites in Hong Kong to supervise/audit the demolition. This supervision will ensure that the specific contractual clauses are followed and that health and safety on the site is given a high priority.

Table 7.1 Actions Required Post Demolition

Borehole	Action Required	Remove concrete surface and clear uncontaminated surface material and stockpile	Proposed depth of Material for Removal or Treatment	Remedial Action *	Estimate quantity of contaminated material for Treatment (m³ , #)	Reassurance / Confirmatory Sampling	Sampling Strategy
B1	Yes	Down to 1m depth	1m to 2m	Immobilisation *	100	Yes, determine extent of HM (Pb) contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B2	Yes	Down to 2m depth	2m to 3m	Immobilisation *	100	Yes, determine extent of HM (Pb, Cu) contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B3	Yes	Down to 2m depth	2m to 3.5m	Immobilisation *	150	Yes, determine extent of HM (Pb) contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B4	Yes	Concrete down to 1.5m depth	Below concrete down to 2m	Immobilisation *	50	Yes, determine extent of HM (Pb) contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B5	Yes	Down to 1.5m depth	1.5m to 3.5m	Immobilisation *	200	Yes, determine extent of HM (Pb) contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B6	Yes	Concrete down to 0.4m depth	Below concrete down to 1.4m	Immobilisation *	100	Yes, determine extent of HM (Pb) contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B7	Yes	Concrete down to 0.9m depth	Below concrete to 1.9m	Immobilisation *	100	Yes, determine extent of HM (Pb) contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B8	No Clean Up	N/A	N/A	N/A	N/A	N/A	N/A
B9	No Clean Up	N/A	N/A	N/A	N/A	N/A	N/A
B10	No Clean Up	N/A	N/A	N/A	N/A	N/A	N/A
B11	Yes	Down to 1.5m depth	1.5m to 3.5m	Immobilisation *	200	Yes, determine extent of HM (Pb) contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B12	No Clean Up	N/A	N/A	N/A	N/A	N/A	N/A
B13	No Clean Up	N/A	N/A	N/A	N/A	N/A	N/A
B14	No Clean Up	N/A	N/A	N/A	N/A	N/A	N/A
B15	Yes $$	Excavate concrete down to 0.9m. (TPH contamination as bolus of tarry bitumen at 0.9m (only).	0.9m to 2.0m	TCLP test followed by removal of 1m to 2m landfill. Immobilisation if necessary **. @	110	Yes, determine extent of HM (Cu and TPH) contamination. * $$	5 samples 5m N, S, E, W and base of borehole,
B16	No Clean Up	N/A	N/A	N/A	N/A	N/A	N/A
B17	No Clean Up	N/A	N/A	N/A	N/A	N/A	N/A
B18	Yes	Excavate concrete down to 0.6m depth	Below concrete (0.6m) down to 1.6m	TCLP test followed by removal of 0.6m to 1.6m to landfill, @.	100	Yes, determine extent of TPH contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B19 (surface)	No Clean Up	Concrete down to 1.6m depth	N/A	N/A	N/A	N/A	N/A
B19 (middle)	Yes	N/A	1.6m down to 2.6m	Immobilisation.	100	Yes, determine extent of HM (Cu, Zn and Pb) contamination at edge and base of hole.*	5 samples 5m N, S, E ,W of borehole,
B19 (bottom)	Yes	N/A	2.6m down to rockhead (say 3.2m)	TCLP test followed by removal of 2.6m to 3.6m landfill. Immobilisation if necessary **, @.	<100	Yes, determine extent of HM (Pb, Zn and Cu) PCB, PAH and TPH) contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B20	No clean Up	Down to 2.5m depth	N/A	N/A	N/A	N/A	N/A
B20	Yes	N/A	2.5m to 4.0m (or rockhead)	TCLP test followed by removal of 2.5m to 4m to landfill. Immobilisation if necessary**, @	150	Yes, determine extent of HM (Cu, Pb, Zn) PAH and TPH contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
B21 (top)	No Clean Up	Concrete down to 2.5m Remove soil to 4.0m depth	Assume surface to 4.0m not contaminated.	N/A	N/A	N/A	N/A
B21 (bottom)	Yes	N/A	4.0m to 6.0m contaminated	Immobilisation *	200	Yes, determine extent of HM (Pb) contamination at edge and base of hole.*	5 samples 5m N & S, 2m E & W and base of borehole.
B22	Yes	Concrete down to 1.5m depth	Immediately below concrete at 1.5m down to 4.0m (or rockhead)	Immobilisation*	250	Yes, determine extent of HM (Pb, Cu and Zn) contamination at edge and base of excavated hole.*	5 samples 5m N, S, E ,W and base of borehole
B23	Yes	Down to 1.5m depth	Immediately below concrete at 1.5m to 3.5m contaminated.	Immobilisation*	200	Yes, determine extent of HM (Pb) contamination at edge and base of hole.*	5 samples 5m N, S, E, W and base of borehole,
Refuse and Ash Bunkers	Yes	N/A	N/A	Landfill disposal	To be determined after inspection of bunkers	Examine bunker refuse prior to demolition	Consider analysis depending on bunker contents
Main Hall Ash Bunker Wall	Yes	N/A		Remove ash under controlled conditions up to 5m up wall. Landfill disposal to meet EPD criteria.	Assume materials within 5m of ground contaminated	Visual inspection of walls to ensure all visible dust and debris removed.	-
Main Hall Floors	Yes	N/A	-	Remove ash under controlled conditions up to 5m from wall. Landfill disposal to meet EPD criteria.	Assume materials within 5m of wall contaminated.	Visual inspection of floor within 5m of wall to ensure all visible dust and debris removed.	-
Chimney	Reassurance sampling only	N/A				Review requirements after demolition and confirmatory sampling.	-

* If contamination confirmed by reassurance sampling extract a further 1.0m into the soil, immobilise and resample.

** TCLP test for all metals identified in Table E1 in EPD Contaminated Sites Investigation and Remediation Guidance Notes

$$ TPH Contamination isolated to bolus of tarry bitumen found only at one depth. Isolated contaminant.

# According to the quantity of contaminated material estimated for each borehole location, the total quantity of contaminated soil should be about 2200m^3..

About 1750m^3.of the total volume is estimated to require treatment on site by immobilisation (Broad brush estimate based on depths to which materials >Dutch B are identified by current round of sampling and all material within 5m (10m x 10m square hole) to that depth (rounded up to nearest 10m³.)

@ Broad brush estimate of materials to be transferred to landfill (rounded up to nearest 10m³. (Total about 450m³, broad brush estimate as # , requiring confirmation).

8. Site Environmental Audit

8.1 Site Inspections

8.1.1 Site Inspections provide a direct means to trigger and enforce the specified environmental protection and pollution control measures. Pollution control measures shall be undertaken routinely and results catalogued in a site diary to facilitate inspection of the construction activities in order to ensure that appropriate environmental protection and pollution control mitigation measures are properly implemented. With well defined pollution control and mitigation specifications and a well established site inspection, deficiency and action reporting system, the site inspection is one of the most effective tools to enforce the environmental protection requirements on the construction site.

8.1.2 The ETL is responsible for formulation of the environmental site inspection, deficiency and action reporting system, and for carrying out the site inspection works. He shall submit a proposal on the site inspection, deficiency and action reporting procedures within 21 days of the construction contract commencement to the Contractor for agreement and to the ER for approval.

8.1.3 Regular site inspections shall be carried out at least once per week. The areas of inspection shall not be limited to the environmental situation, pollution control and mitigation measures within the site. They should also review the environmental situations outside the Site that are likely to be affected, directly or indirectly, by the site activities. The ETL shall make reference to the following information in conducting the inspections:

· the EIA Report recommendations on environmental protection and pollution control mitigation measures;

· works progress and programme;

· individual works methodology proposals (which shall include proposals on associated pollution control measures);

· the contract specifications on environmental protection;

· the relevant environmental protection and pollution control laws; and

· previous site inspection results.

8.1.4 The ETL shall request all information regarding the construction contract from the Contractor required for him to carry out the site inspections. The inspection results and their associated recommendations on improvements to the environmental protection and pollution control works shall be submitted to the ER and the Contractor within 24 hours, for reference and for taking immediate action. The Contractor shall follow the procedures and time-frame as stipulated in the environmental site inspection, deficiency and action reporting system formulated by the ETL to report on any remedial measures subsequent to the site inspections.

8.1.5 Ad hoc site inspections shall also be carried out if significant environmental problems are identified. Inspections may also be required subsequent to receipt of an environmental complaint, or as part of the investigation work, as specified in the Action Plan for environmental monitoring and audit.

8.2 Compliance with Legal and Contractual Requirements

8.2.1 The demolition activities shall comply with all contractual environmental protection and pollution control requirements as well as environmental protection and pollution control laws in Hong Kong.

8.2.2 In order that the works are in compliance with the contractual requirements, all the works method statements submitted by the Contractor to the ER for approval shall be sent to the ETL for vetting to see whether sufficient environmental protection and pollution control measures have been included.

8.2.3 The ETL shall also review the progress and programme of the works to check that relevant environmental laws have not been violated, and that any foreseeable potential for violating the laws can be prevented.

8.2.4 The ETL shall regularly request copies of relevant documents from the Contractor so that the checking work can be carried out. The documents shall at least include the updated Work Progress Reports, the updated Works Programme, the application letters for different licenses/permits under the environmental protection laws, and all the valid licenses/permits. The site diary shall also be available for the ETL’s inspection upon his request.

8.2.5 After reviewing the document, the ETL shall advise the ER and the Contractor of any non-compliance with the contractual and legislative requirements on environmental protection and pollution control for them to take follow-up actions. If the ETL’s review concludes that the current status on license/permit applications and any environmental protection and pollution control preparation works may not cope with the works programme he shall also advise the Contractor and the ER accordingly. If the ETL’s review concludes that the current status may result in potential violation of environmental protection and pollution control requirements by the works in due course, he shall also advise the Contractor and the ER accordingly.

8.2.6 Upon receipt of the advice, the ER shall follow up to ensure that appropriate action has been taken by the Contractor in order to ensure that the environmental protection and pollution control requirements are fulfilled.

8.3 Environmental Complaints

8.3.1 Complaints shall be referred to the ETL for carrying out complaint investigation procedures. The ETL shall undertake the following procedures upon receipt of any complaints:

· log complaint and date of receipt onto the complaint database;

· investigate the complaint to determine its validity, and to assess whether the source of the problem is due to works activities;

· if a complaint is valid and due to works, identify mitigation measures;

· if mitigation measures are required, advise the Contractor accordingly;

· review the Contractor’s response on the identified mitigation measures, and the updated situation;

· if the complaint is submitted by EPD, submit interim report to EPD on status of the complaint investigation and follow-up action within the time frame agreed between the ER and relevant Government Departments;

· undertake additional monitoring and audit to verify the situation if necessary, and review that any valid reason for complaint does not recur;

· report the investigation results and the subsequent actions to the source of the complaint for responding to the complainant (if the source of complaint is EPD, the results should be reported within the time frame agreed with the ER and relevant Government Departments); and;

· record the complaint, investigation, the subsequent actions and the results in the monthly EM&A reports.

8.3.2 During the complaint investigation work, the Contractor shall provide all the necessary information and assistance for completion of the investigation. If mitigation measures are identified in the investigation, the ER shall advise the Contractor to promptly carry out the mitigation (the ER will have the authority to require that the measures are carried out). The ET shall inspect measures that have been carried out by the Contractor and advise ER of their acceptability.

Table 8.1 Event Contingency Plan for Environmental Complaints

Step	Day	Action	Contractor	ER	ET	IC(E)
1	1	Party receiving complaint shall create a new complaint record. If the Contractor receives a complaint, he shall pass the information to the ER.	¨	¨	¨
2	1	ER to ensure details of complaint provided to Contractor (if complaint not originally received by the Contractor), ET and IC(E)		¨
3	2	Within 1 working day after the receipt of the Notification of Complaint, provide ER relevant works site information, e.g. types and locations of construction works.	¨			à
4	2	Investigate the complaint to determine its validity, and to assess whether the source of the problem is due to the works activities. Report the validity of the complaint to ER.				¨à
5	2	If complaint is valid and due to works, ER shall notify the Contractor. If complaint is invalid or not due to works, Go to Step 12.		¨
6	2	Propose mitigation measures to ER within 1 working day of the receipt of the Notification.	¨			à
7	2	Review and agree with the proposed mitigation measures and make recommendations where necessary.		¨à		¨à
8	2	Implement the mitigation measures once they have been agreed.	¨
9	4	Audit the implementation of the proposed mitigation measures on site within 2 working days after measures have been agreed.		¨à		¨à
10	-	Undertake additional monitoring to verify the situation where necessary.			¨
11	4	Report the investigation results and subsequent actions taken to ER within 2 working days after the implementation of mitigation measures.	¨		¨
12	5	Respond to the complainant within 1 working day after receiving the investigation report.		¨
13	25	If no further comments or complaints are received from the complainant within 20 working days after responding to the complainant, close the complaint record. If the complainant has further comments or complaints on the same issue, notify other parties on the same day and go to step 2.		¨		¨à

¨ action party

à enter comments/proposals into appropriate complaint record where applicable

9. REPORTING

9.1 General

9.1.1 The following reporting requirements are based upon a paper documented approach. However, the same information can be provided in an electronic medium upon agreeing the format with the ER and relevant Government Departments. This would enable a transition from a paper/historic and reactive approach to an electronic/real time proactive approach.

9.2 Baseline Monitoring Report

9.2.1 The ETL shall prepare and submit a Baseline Environmental Monitoring Report within 10 working days of completion of the baseline monitoring. Copies of the Baseline Environmental Monitoring Report shall be submitted to the project proponent, the Contractor, the ER and the EPD. The ETL shall liaise with the relevant parties on the exact number of copies required.

9.2.2 The baseline monitoring report shall include at least the following:

· a 1-2 page executive summary;

· brief project background information;

· drawings showing locations of the baseline monitoring station;

· monitoring results (in both hard and diskette copies) together with the following information:

- monitoring methodology;

- equipment used and calibration details;

- parameters monitored;

- monitoring locations; and

- monitoring date, time, frequency and duration.

· details on influencing factors, including:

- major activities, if any, being carried out on the site during the period;

- weather conditions during the period; and

- other factors which might affect the results.

· determination of the Action and Limit Levels for each monitoring parameter and statistical analysis of the baseline data;

· revisions for inclusion in the EM&A Manual; and

· comments and conclusions.

9.3 Monthly EM&A Reports

9.3.1 The ETL shall undertake all reporting which shall be reviewed by the ER to determine that the reporting has been carried out in accordance with the requirements of the Manual.

9.3.2 The results and findings of all EM&A work required in the Manual shall be recorded in the monthly EM&A Reports. The EM&A Report shall be prepared and submitted within 10 working days of the end of each reporting month, with the first report due in the month after construction commences. A copy of each monthly EM&A Report shall be submitted to the project proponent, the Contractor, the ER and the EPD. Before submission of the first EM&A Report, the report producer shall liaise with the parties on the exact number of copies and format of the monthly reports in both hard copy and electronic medium requirement. The monthly EM&A reports shall continue through to the end of the soil remediation works phase

9.3.3 The first monthly report shall include at least the following :

· 1-2 pages executive summary;

· basic project information including a synopsis of the project organisation, programme and management structure, and the work undertaken during the month;

· a brief summary of EM&A requirement including :

- all monitoring parameters;

- environmental quality performance limits (Action and Limit levels);

- Event-Action Plans;

- environmental mitigation measures, as recommended in the project EIA study final report;

- environmental requirements in contract documents;

· advice on the implementation status of environmental protection and pollution control/mitigation measures, as recommended in the project EIA study report, summarised in the updated implementation schedule;

· drawings showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations;

· monitoring results (in both hard and diskette copies) together with the following information:

· monitoring methodology;

· equipment used and calibration details

· parameters monitored

· monitoring locations

· monitoring date, time, frequency, and duration;

· major activities being carried out on site during the period;

· weather conditions during the period; and

· any other factors which might affect the monitoring results;

· advice on the solid and liquid waste management status;

· a summary of non-compliance (exceedances) of the environmental quality performance limits (Action and Limit levels);

· a review of the reasons for and the implications of non-compliance and deficiency reporting and any follow-up procedures;

· a description of the actions taken in the event of non-compliance and deficiency reporting and any follow-up procedures related to earlier non-compliance;

· a summary record of all complaints received (written or verbal) for each media, including locations and nature of complaints, liaison and consultation undertaken, actions and follow-up procedures taken and summary of complaints; and

· an account of the future key issues as reviewed form the works programme and work method statements.

9.3.4 The subsequent monthly EM&A reports shall include the following :

· title page;

· Executive Summary (1-2 pages);

- breaches of AL levels ;

- complaint Log;

- reporting Changes; and

- future key issues.

· contents page;

· environmental status;

- drawing showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations;

- summary of non-compliance with the environmental quality performance limits; and

- summary of complaints.

· environmental issues and actions;

- review issues carried forward and any follow-up procedures related to earlier non-compliance (complaints and deficiencies);

- description of the actions taken in the event of non-compliance and deficiency reporting;

- recommendations (should be specific and target the appropriate party for action); and

- implementation status of the mitigation measures and the corresponding effectiveness of the measures.

· future key issues;

· appendices;

- AL levels

- graphical plots of trends of monitored parameters at key stations over the past four reporting periods for representative monitoring stations annotated against the following:

i. major activities being carried out site during the period;

ii. weather conditions during the period; and

iii. any other factors which might affect the monitoring results.

- monitoring schedule for the present and next reporting periods;

- cumulative complaints statistics; and

- details of complaints, outstanding issues and deficiencies.

9.4 Contamination Remediation Report

9.4.1 Following the remediation stage, a Final Remediation Report is required for submission to EPD. The Purpose of this Report is to confirm that ground remediation works have been satisfactorily completed. The scope, content and format of this Report shall follow those requirements set out in the Contract for the remediation works in question which shall themselves comply with the provisions of any pertinent environmental permit.

9.5 Data Keeping

9.5.1 Site documents such as the monitoring field records, laboratory analysis records, site inspection forms, etc. are not required to be included in the Monthly EM&A Report for submission. However, the documents shall be kept by the ETL and be ready for inspection upon request. All relevant information shall be clearly and systematically recorded in the document. The monitoring data shall also be recorded in magnetic media form, such that the electronic copy can be made available upon request. The documents and data which shall be kept for at least one year after completion of the construction contract will include the following:

· all reports issued;

· site inspection forms and reports;

· monitoring field and laboratory records;

· complaints and related follow-up action information; and

· revised mitigation measures proposals adopted during the course of the works programme.

9.6 Interim Notifications of Environmental Quality Limit Exceedances

9.6.1 With reference to Event/Action Plans, when the environmental quality limits are exceeded, the ETL shall immediately notify the ER and relevant Government Departments, as appropriate. The notification shall be followed up with advice to EPD on the results of the investigation, proposed action and success of the action taken, with any necessary follow-up proposals. A sample template for the interim notifications is shown in Table 9.1.

Table 9.1 Sample Template for Interim Notifications of Environmental Quality Limits Exceedances

Project
Date
Time
Monitoring Location
Parameter
Action & Limit Levels
Measured Level
Possible reason for Action or Limit Level Non-compliance
Actions taken / to be taken
Remarks

				Location Plan
Prepared by :
Designation :
Signature :
Date :

10. Schedule of Mitigation from the EIA

Table 10.1 Schedule of Impacts and Mitigation Measures

No.	Activity	Mitigation/EIA Recommendations	Responsibility for Implementation	Location Duration completion of measures	Implemen-tation Stage	Relevant Guidelines Legislation
1	Ash Disposal
I	Treatment	Reconfirm extent of contaminated ash deposits by sampling for dioxins and furans. Handling, transportation and disposal of the ash waste in line with relevant regulations. Collection, immobilisation and testing of waste for disposal to landfill shall be carried out according to the relevant regulations and recommendations of the EIA including immobilisation by collection and mixing the ash material with cement. Pilot mixing and TCLP tests should establish the ratio of cement to ash to the satisfaction of EPD. Ash waste to be treated and placed into steel drums lined with plastic sheeting. The drums should be adequately sealed and in new or good condition. Prior agreement of the disposal criteria from EPD and agreement to disposal from the landfill operator must be obtained.	CED’s Contractor	KCIP work areas. Duration of the ash removal	A@	1, 10, EIA
II	Disposal	To monitor the disposal of waste at landfills, a “trip-ticket” system (WBTC No. 5/99) for all solid waste transfer/disposal operations should be implemented. The system should be included as a contractual requirement, and monitored by the Environmental Team and audited by the Independent Checker (Environment).	CED’s Contractor	As above	A	1, 5, 9
III	Asbestos Removal	An asbestos abatement programme should be submitted to EPD for approval prior to the commencement of the asbestos abatement work.	CED and Contractor	As above	A	4
2	Demolition
A1	Non-blasting Methodology	Demolition by Non-Blasting Methodology Only. All structures and buildings should be demolished and removed prior to demolition of chimneys	CED	KCIP work areas. Duration of the demolition	C#	8
A2	Waste Management Plan.	A Waste Management Plan shall be submitted to EPD for approval. The Waste Management Plan shall include, but not be limited to, the findings of the Waste Management Paper of the EIA, the types, quantities, disposal methods, timing, locations of final disposition, responsibilities for implementation and the possible recycling and reuse of wastes generated.	CED and Contractor	Prior to commencement of the demolition works	Prior to C#	1
B	Material Storage	Covers for dusty stockpiles and control of dust emissions from construction (demolition) works requires appropriate dust control measures to be implemented in accordance with the requirements in the Air Pollution Control (Construction Dust) Regulation.	CED’s Contractor	KCIP work areas. Duration of the demolition	C	4
C	Vehicle movement	Haul road watering, vehicle wheel wash prior to exit. Where practical, access roads should be protected with crushed gravel.	CED’s Contractor	As above	C	4
D	Plant maintenance	All plant shall be maintained to prevent any undue air emissions.	CED’s Contractor	As above	Prior to start of works	4
E	Demolition Techniques	Selection of non-blasting demolition techniques to minimise noise and vibration.	CED’s Contractor	As above	C	8
F	Plant maintenance	All plant shall be maintained to prevent any undue noise nuisance.	CED’s Contractor	As above	C	2, 3
G	Wheel wash	All wheel wash water shall be diverted to a sediment pit.	CED’s Contractor	As above	C	5
H	Sediment control	Sediment removal facilities shall provided and be maintained and excavated as necessary to prevent sedimentation of channels. Perimeter channels should be provided. Works should be programmed for the dry season where feasible. Environmental guidelines for the handling and disposal of discharges from construction sites, as stipulated in the Practice Note for Professional Persons, Construction Site Drainage (ProPECC PN 1/94) to be followed.	CED’s Contractor	As above	C	5, 12
I	Surface water diversion	All clean surface water shall be diverted around the site.	CED’s Contractor	As above	C	5, 12
J	Fuel can storage	All fuel cans shall be placed within a bunded area. Any fuel spills shall be mopped up as necessary.	CED’s Contractor	As above	C	5,6
K	Material, plant move-ment & fuel can filling.	Any fuel or oil spills shall be excavated and disposed of.	CED’s Contractor	As above	C	6,7
L	Generators	All generators shall be placed within a bunded area. Any fuel spills shall be mopped up as necessary.	CED’s Contractor	As above	C	5,6,7
M	Material containers	All empty bags and containers shall be collected for disposal.	CED’s Contractor	As above	C	6,7
N	Worker generated litter and Waste	Litter receptacles shall be placed around the site. Litter shall be taken regularly to the refuse collection points. Chemical toilets (or suitable equivalent) should be provided for workers. Any canteens should have grease traps.	CED’s Contractor	As above	C	6
O	Neighbourhood nuisance	All complaints regarding construction works shall be relayed to the environmental team.	CED’s Contractor	As above	C	1, 6
P	Legal requirements	Different types of waste should be segregated, stored, transported and disposed of in accordance with the relevant legislative requirements and guidelines	CED’s Contractor	As above	C	1,6
Q	On-site separation	On-site separation of municipal solid waste and construction/demolition wastes shall be conducted in order to minimise the amount of solid waste to be disposed to landfill.	CED’s Contractor	As above	C	1, 11
R	Temporary storage area	Separated wastes should be stored in different containers, skips, or stockpiles to enhance reuse or recycling of materials and encourage their proper disposal.	CED’s Contractor	As above	C	1, 11
S	Record of wastes	Records of quantities of wastes generated, recycled and disposed (with locations) shall be kept.	CED’s Contractor	As above	C	1, 9
T	Trip-ticket system	To monitor the disposal of waste at landfills and control fly-tipping, a “trip-ticket” system under WBTC N0.5/99 for all solid waste transfer/disposal operations should be implemented. The system should be included as a contractual requirement, and monitored by the Environmental Team and audited by the Independent Checker (Environment).	CED’s Contractor	As above	C	1, 9
3	Soil Remediation Phase
U	B, C, D, F, G, I, J, K, L, M, N, O, P, Q, R, S and T as above	As above (see W for soil remediation).	As above	As above	R	As above
V	De-watering	Collect and recycle extracted groundwater and leachate by mixing with cement for soil remediation. Environmental guidelines for the handling and disposal of discharges from construction sites, as stipulated in the Practice Note for Professional Persons, Construction Site Drainage (ProPECC PN 1/94) to be followed. Any surplus groundwate and leachate requiring disposal to be disposed of under the relevant legislation or treated to meet the standards given in Table 9a of the WPCO TM.	CED’s Contractor	KCIP work areas. Duration of the soil remediation	R	5
W	Immobilisation	Immobilisation and testing of waste soil shall be carried out according to the relevant regulations and recommendations of the EIA including immobilisation by collection and mixing the contaminated soil material with cement. Pilot mixing and TCLP tests should verify the effectiveness and establish the ratio of cement to soil to the satisfaction of EPD. Reassurance confirmatory sampling shall be carried out to confirm the extent of contamination. Soil waste to be cast in blocks and replaced in the ground. Extracted soils and materials and stabilisation/solidification to be conducted in bunded area to prevent surface run-off. See also item 2(H) above. Final soil decontamination report to be submitted to EPD.	CED’s Contractor	As above	R	1, 10
4	Monitoring and Audit	To be carried out in accordance with the Schedule in the EM&A Manual.	CED*/ Contractor/ RSS	KCIP works areas During demolition and at end of demolition throughout execution of Remediation Action Plan	C	1

* Normally undertaken by a specialist monitoring team employed directly by the proponent and audited by the Independent Checker (Environment)

@ A = during ash removal (before demolition)

# C = during construction (i.e. demolition phase).

* R = during soil remediation phase (after demolition)

1. Environmental Impact Assessment Ordinance Technical Memorandum (EIAO)

2. Noise Control Ordinance

3. The ProPECC Note PN2/93 (Construction Noise daytime limits)

4. Air Pollution Control Ordinance (APCO)

5. Water Pollution Control Ordinance (WPCO)(Cap. 358)

6. Waste Disposal Ordinance (Cap 354)

7. Waste Disposal (Chemical Waste)(General) Regulation (Cap 354)

8. Draft Code of Practice on Demolition of Buildings (BD, 1998)

9. Works Bureau Technical Circular No. 5/99, Trip-ticket System for Disposal of Construction and Demolition Material

10. Guidance Notes for Investigation and Remediation of Contaminated Sites

11. Works Bureau Technical Circular No. 5/98, On Site Sorting of Construction Waste on Demolition Sites

12. ProPECC Note PN 1/94Construction Site Drainage

List of Abbreviations

AAP	Asbestos Abatement Plan
ACE	Advisory Committee on Environment
ACM	Asbestos Containing Material
AIR	Asbestos Investigation Report
AP	Authorised Person
APCO	Air Pollution Control Ordinance
BOO	Building Ordinance Office
CAP	Contamination Assessment Plan
CAR	Contamination Assessment Report
CED	Civil Engineering Department
CPLD	Committee on Planning & Land Development
DCDB	Draft Code of Practice on Demolition of Buildings
DSD	Drainage Services Department
EIA	Environmental Impact Assessment
EIAO	Environmental Impact Assessment Ordinance
EM&A	Environmental Monitoring & Audit
EMSD	Electrical & Mechanical Services Department
EPD	Environmental Protection Department
G I/C	Government, Institutional/Community
GDBL	Gin Drinker’s Bay Landfill
KCIP	Kwai Chung Incineration Plant
KCPTW	Kwai Chung Preliminary Treatment Works
LEHAGN	Landfill Gas Hazard Assessment Guidance Note
NWFB	New World First Bus Depot
PCWA	Public Cargo Working Area
PFBP	Public Fill Barging Point
PQA	Preliminary Quanlitative Assessment
PTW	Preliminary Treatment Works
RAC	Registered Asbestos Consultant
RSE	Resident Site Engineer
SR	Sensitive Receiver
TIA	Traffic Impact Assessment
TM	Technical Memorandum

SUMMARY

I. The Study Brief requires that the alternative methods of demolition of the Kwai Chung Incineration Plant and the Kennedy Town Comprehensive Development Area (the Project) to be investigated as a basis for defining the activities to be addressed within the environmental assessment. This Working Paper sets out the analysis of the alternative demolition options for both facilities and the major conclusions regarding demolition methods. The Working Paper also presents the major constraints associated with the Project.

II. The PPFS for Kwai Chung Incineration Plant concluded that it was not feasible to demolish the chimney by implosion (blasting) due to the short distances between the chimney and the surrounding structures and other local facilities, the high risk and the lack of cost effectiveness. Preliminary investigations for this Study have confirmed the severe concerns raised by various Government departments at the PPFS stage and confirmed the conclusion that blasting techniques should not be used for the felling of the chimney or the main building structures.

III. In addition to the original concerns it is now confirmed that parts of the chimney and the cladding of the buildings include asbestos containing materials (ACM). The presence of these materials alone is sufficient grounds to require that a non-blasting approach is adopted as all ACM must be removed in line with statutory requirements. A conceptual demolition method has been developed which avoids the any form of blasting to fell the chimneys or the associated buildings. Details of the engineering requirements for such an approach are presented in this report.

IV. The details of the constraints to demolition are presented in the main report. A conceptual demolition method has been developed which avoids most of the complications associated with blasting and provides flexibility for the implementation stages of the works.

V. The conclusion of this Working Paper is that non-explosive demolition methods should be used for the demolition of the Kwai Chung Incineration Plant.

A1. Introduction

A1.1 Background

A1.1.1 The Civil Engineering Department (CED) has appointed Atkins China Ltd. (ACL) to undertake the Environmental Impact Assessment (EIA) for the Demolition of the Kwai Chung Incineration Plant and the Kennedy Town Comprehensive Development Area (Agreement No. CE 15/99). The Kwai Chung Incineration Plant (KCIP) ceased to operate in May 1997 and has been decommissioned and the facilities require demolition. The main plant items have already been removed. The demolition of the remaining facilities on the site constitutes the Project as defined under the requirements of the Environmental Impact Assessment Ordinance (EIAO).

A1.1.2 The primary aim of this paper is to establish a conceptual demolition method and to define the major constraints, which must be considered in the final demolition process. The paper presents information to facilitate decisions on acceptable conceptual demolition methods for the Project as a basis for the remainder of the Study.

A1.1.3 To satisfy the requirements of the EIA it is necessary to define clearly the nature of the works involved in the demolition process. The development of a conceptual scheme for the demolition process in turn requires detailed analysis of the facilities and those surrounding uses and activities which might influence decisions on demolition. This paper presents this analysis. The conceptual scheme for demolition of the facilities has been developed based on practical experience and current demolition practice in Hong Kong as well as internationally.

A1.1.4 A description of the elements of the community and environment, likely to be affected by the proposed demolition activities is provided to ensure that any potential constraints on demolition works due to the need to protect sensitive receivers, surrounding infrastructure or facilities are considered. Such requirements may constrain the way the proposed Project is executed and affect the methods that can be used so as to influence the choice of demolition methods.

A1.2 Structure of the Report

A1.2.1 In addition to this introduction Working Paper 1 Report includes sections covering the following:

· Section 2 Project and Study Area

· Section 3 Appreciation and Understanding of Constraints to Demolition.

· Section 4 General Approach to Demolition of Buildings and Structures.

· Section 5 Conceptual Demolition Method for Chimney at KCIP.

· Section 6 Conclusions.

A2 proJecT and STUDY AREA

A2.1 Kwai Chung Incineration Plant (KCIP) Study Area

A2.1.1 The Kwai Chung Incineration Plant (KCIP) is located at Kwai Yue Road, Kwai Chung, facing the Rambler Channel and Tsing Yi South Bridge, with a site area of about 14,000 m² (Figure 2.1). The site is close to the Kwai Chung Park, the former Gin Drinkers Bay Landfill, and therefore may be impacted by contaminants and landfill gas generated from the landfill site.

A2.1.2 The KCIP site is adjacent to the Kwai Chung Preliminary Treatment Works (KCPTW) and part of the KCIP site overlaps the “Sewerage Tunnel Protection Area” of the Strategic Sewerage Disposal Scheme (SSDS), administered by Drainage Services Department (DSD).

A2.1.3 The KCIP site is currently zoned as “G/IC”, with no identified long term use of the area after demolition. However, the future land use is unlikely to be residential given the close proximity of the site to Gin Drinkers Bay Landfill and the Rambler Channel Bridge.

A2.1.4 A Public Fill Barging Point (PFBP), located on reclaimed land (Area 30D) to the north of the KCIP, is planned to be operational in early 2002. Construction of the PFBP is scheduled to commence in early 2001 for completion by the end of 2001. The PFBP is also subject to EIA under a separate study.

A2.1.5 The site is opposite the Rambler Channel Typhoon Shelter and Public Cargo Working Area. These facilities accommodate a range of cargo related activities including permanently moored barges. The structures which remain to be demolished are summarised in Table 2.1.

Table 2.1 Structures to be demolished at KCIP

Building	Brief Description
KCIP Chimney	Reinforced concrete construction of diameter 6m – 12m and 150m high. Internal metal flues and platforms
KCIP Buildings	Single storey with steel frame, precast concrete slab, reinforced concrete partition, corrugated steel sheet external wall and roof. The overall size is approximately 83m x 92m on plan.
Weigh Bridge Office No2	Approximately 4m x 13m on plan.
Site Office/ Storage Buildings	2 storey height prefabricated building overall size is approximately 40m x 7.5m on plan.

A3 Appreciation and Understanding of Constraints to Demolition

A3.1 Background

A3.1.1 This section identifies the sensitive receives (SRs) affected by the Project as defined in the EIAO and discusses the implications of these and other nearby sensitive engineering projects and infrastructure with respect to the constraints they will place on demolition methods. Where relevant we have also noted the implications such sensitive locations may have on the potential for explosive demolition. Sensitive receivers and other constraints are shown in Figures 2.1 for KCIP.

A3.1.2 It has been assumed that the demolition for KTCDA will take place as soon as possible in order to allow future developments on and near the site. The earliest start date will be in 2001 with demolition works lasting about one year. There is currently no planned programme for the demolition of KCIP although a 16 month demolition phase was assumed in the PPFS.

A3.2 Sensitive Receivers at KCIP

Residential

A3.2.1 There are few SRs such as residential premises which are so close to the works at KCIP as to be severely affected by either explosive or conventional top down demolition. However residential receivers within 700m will be included in the EIA. This includes Cheung Ching Estate, Greenfield Garden and Grand Horizon (respectively more than 600m and 700m away across the Rambler Channel).

A3.3 Other Sensitivities near KCIP

A3.3.1 There are several engineering and other locations, which would be very sensitive to controlled demolition by implosion. These include:

· The Rambler Channel marine traffic and ferry services.

· Rambler Channel Typhoon Shelter and PCWA.

· The Public Fill Barging Point (PFBP) at Area 300.

· Container Terminal 5 (Kwai Tai Road).

· The seawalls and drainage channels other infrastructure around the area.

· The 200m Sewerage Tunnel Protection Area.

· The Kwai Ching Preliminary Treatment Works.

· The Kwai Chung Park (Gin Drinkers Bay Landfill).

· The Rambler Channel Bridge.

· The Tsing Yi Bridge.

· Kwai Tai Road and heavy vehicle access.

A3.4 Implications of Demolition by Implosion at KCIP

A3.4.1 The PPFS concluded that due to the short distances between the chimney and the surrounding structures, the high risk and lack of cost effectiveness meant that demolition of the single chimney by implosion was not feasible.

A3.4.2 The chimney at KCIP is 150m high. The exclusion zone under the “Draft Code of Practice for Demolition of Buildings (Buildings Department) would therefore require evacuation of an area up to 375m from the chimney during blasting. In the event that a Risk Assessment Report were conducted for this site, the result could require such a zone to be greater in order to minimise risks from ejecta. The possible limits of exclusion with respect to the chimney at KCIP are shown on Figure 2.1.

A3.4.3 The distance of residential SRs at Cheung Ching Estate, Greenfield Garden and Grand Horizon is 600m or greater. Whereas the results of a Risk Assessment cannot be predicted, experience suggests that such distances would be likely to place these SRs well beyond any likely exclusion zone. Therefore it is unlikely that these SRs would need to be evacuated.

A3.4.4 The distance to industrial buildings over the Rambler Channel would fall within a three chimney height radius and these buildings may require evacuation in then event that demolition by implosion was chosen

A3.4.5 Engineering and other locations are much nearer and would be very sensitive to controlled explosive demolition. The proximity of some facilities places them at physical risk of damage from vibration or flying debris. Others would be impacted by the need to suspend services and the costs of co-ordinating the closure of many services in the area could be unacceptable. Either individually or together the impact on these facilities/works could be sufficient to dictate against the use of demolition by blasting.

A3.4.6 A large section of the Rambler Channel, the Rambler Channel Typhoon Shelter, the PCWA and part of Container Terminal 5 would be likely to fall within an exclusion zone for explosive demolition. The suspension of services and marine traffic in the Rambler Channel, necessary for an demolition by blasting, presents a major potential impact. Marine Department have indicated that prima facie the closing the Rambler Channel to marine traffic is unacceptable and that they have an in principle objection to this line of action. The implications of demolition by blasting for evacuation of Rambler Channel, Typhoon Shelter and suspension of activities in the PCWA and Container Terminal 5 are therefore considered to be unacceptable.

A3.4.7 The Public Fill Barging Point (PFBP) at Area 30D is scheduled to be under construction some time in 2001 which is before the target date for the completion of the demolition indicated in the PPFS. If the chimney were to be felled using a blasting technique, the target area for the fall could just fit within the KCIP site towards the east. Otherwise the target area would be Area 30D. In the latter case there is a potential conflict for demolition by explosive methods which would be impossible prior to the subsequent cessation of activities at Area 30D as and when the barging point closes.

A3.4.8 The Kwai Chung Preliminary Treatment Works (KCPTW) is located immediately adjacent to the KCIP and the base of the chimney is only about 20m from the main KCPTW control building. The control centre is manned during the daytime and runs with automatic control from late afternoon, overnight, until early morning. The Drainage Services Department has indicated that the control equipment is very sensitive to vibration and they are especially concerned that vibration caused by blasting of the chimney could damage the equipment and possibly even the building fabric. Regardless of the method of demolition, vibration control techniques for the site may be required because of the proximity of the Kwai Chung PTW.

A3.4.9 The demolition works and the chimney are within 100m of the vertical shaft tunnel of the SSDS and require special scrutiny by Government. Part of the site is within the 200m outer limit of the Sewerage Tunnel Protection Area. The Technical Notes for Guidance in Assessing Effects of Civil Engineering Works/Building Development on Sewage Tunnel Works (PNAP 165) require that peak particle velocities (PPV) at any sewerage tunnel structure resulting from blasting or other operations which can induce prolonged vibration, shall not exceed 25mm/sec. The maximum peak particle velocities for other operations shall not exceed 15mm/sec. Drainage Services Department have also expressed concerns that such maximum PPV could be exceeded at the sewage tunnels with blasting techniques. Given the sensitivity of the SSDS project, the use of implosion techniques is considered to be unacceptable.

A3.4.10 The approach viaduct of the Rambler Channel Bridge is within 40m of the chimney. Highways Department have expressed concerns that blasting techniques could cause vibration or release ejecta which could damage the structure. The Bridge would also have to be closed temporarily, which is unacceptable for this main route to the Airport.

A3.4.11 There are potential landfill gas hazards associated with the Kwai Chung Park (Gin Drinkers Bay Landfill). The landfill gas hazard assessment, undertaken to identify the nature and extent of landfill gas release, is included in the EIA Report. At this stage explosure demolition would appear to be a very high risk option. Site safety measures implemented in the site investigation stage will need to be implemented in the demolition phase, in accordance with established standards and guidelines and the findings of the hazard assessment.

A3.4.12 The local road network is currently busy with much heavy traffic serving not only the PCWA but also other industrial facilities nearby. Transport Department expressed general concerns about the potential impact of the need to close roads to allow blasting techniques. Generally road closures would be unacceptable unless proved acceptable. A TIA would be required to assess impacts on all roads in the exclusion zone and the public transport system and a feasible traffic diversion scheme would need to be developed. Emergency plans would also need to be developed. Given the plethora of other non-traffic constraints, these measures have not been detailed at this stage.

A3.5 Implications of the Presence of Asbestos Containing Materials

A3.5.1 Asbestos Investigation Reports and Asbestos Abatement Plans for both sites are required under the Air Pollution Control Ordinance (APCO) prior to the commencement of any asbestos abatement work. Reports and plans prepared by Registered Asbestos Consultants (EPD register RACs 1014 and 1019) indicate asbestos containing materials (ACM) are present at the Site.

A3.5.2 The Brief assumes that any asbestos containing materials (ACM) present in the chimneys and superstructures within the two sites will be removed before commencement of the demolition works. However, experience suggests that in practice the asbestos abatement processes will run more smoothly if both asbestos contractors and civil demolition contractors work in tandem, as has been the case with the civil demolition of the remaining buildings and structures at other large industrial locations in Hong Kong. This is generally due to the convenience of the main civil demolition contractors providing access (scaffolding etc.) to the ACM, for the asbestos contractor. In other cases it may be necessary for the civil demolition contractor to remove large sections of materials for the asbestos contractor to gain access to the ACM. Further details are presented in the dedicated Asbestos Study Report.

A3.5.3 Bulk asbestos removal of ACM from the incineration plant was undertaken by Government, prior to the removal of plant and machinery. Inspection of the plans and recent site surveys show that low risk asbestos containing materials are present in the chimney of the KCIP. The cladding to the superstructures of the KCIP incinerator building is also similar to other typical corrugated metal weather cladding with asbestos paint (ACM).

A3.5.4 There is also low risk asbestos containing material (ACM) present in the ventilation louvres to the chimney. The louvres are also made from metal with an asbestos type mastic protective paint coating. This is identical to ACM typically found on louvres at other industrial sites in Hong Kong.

A3.5.5 Drawings indicate that an asbestos cement plate was used as a thermal insulation to the chimneys internal flue guide sections. Physical inspection of this material shows it to be a low risk ACM in good condition. However the location means that a controlled removal may only be possible as the chimney is progressively dismantled and as the chimney and flue sections are removed. Therefore blasting will not be an option.

A3.5.6 Other areas have been investigated but no potential ACM has been identified. Details are presented in the dedicated Asbestos Study Report (Asbestos Investigation Report and Asbestos Abatement Plan).

A3.6 Conclusion

A3.6.1 Based on the information presented in Section 3 the consultants believe that sufficient information has been gathered to recommend that the preferred method of demolition should adopt a top-down, non-explosive, non-blasting approach for the demolition of the Kwai Chung Incineration Plant.

A4 General Approach to Demolition of Buildings and Structures at KCIP

A4.1 General Approach

A4.1.1 This section seeks to illustrate some of the more general procedures for demolition that apply at KCIP. The intention in this and sections 5 is not to prescribe a precise method or provide a work specification or a demolition plan but to indicate the approach which should be taken, in sufficient detail to facilitate broad agreement on the methodology and progress EIA.

A4.1.2 Whereas the eventual detailed demolition plan of the selected demolition contractor(s) may not necessarily adopt the methodology proposed in this working paper, the consultants believe that general characteristics of the methods are appropriate. The methods are sufficiently effective and applicable for the tasks and where possible methods that will help reduce noise and dust nuisances have been chosen. The options selected are also broadly in line with the Draft Code of Practice for Demolition of Buildings (DCDB, Buildings Department 1998) which will also need to be observed at the detailed design stage.

A4.1.3 The overriding concerns for the demolition Project will be safety and minimisation of environmental impacts. This will include the safety of the operatives, safety of the other workers on the site and safety of the general public as well as protection of adjacent facilities and minimisation of nuisances.

A4.1.4 The Contractor should during the course of demolition, ensure and verify that all utilities and services have been rendered safe.

A4.2 Hoarding and Site Access

A4.2.1 Typical hoardings would to be provided along the site boundaries. Portable barricades will be used to cordon off different work zones where demolition is in progress. Where conditions warrant the Contractor should seek opinion and advice from the Site Engineer/AP/RSE in order to modify such plans accordingly.

A4.2.2 The buildings and chimneys are totally within the proposed Project sites and access would be controlled by security guards. No members of the public or unauthorised person would be allowed to enter the sites.

A4.2.3 Only contractors’ personnel and Government officials concerned with the demolition would be allowed within the contractors working area.

A4.3 Demolition Principles

A4.3.1 Building and other structures should generally be demolished in the reverse order to that of their construction. The order of demolition for building would be progressive, storey by storey, having regard to the type of construction.

A4.3.2 As a general rule, wherever possible, external non-loading bearing cladding or any non-structural work should be removed first. All asbestos containing materials (ACM, particularly any ACM panels, would be removed prior to commencement of demolition works where ever possible. Other ACM may need to be removed as access is gained to particular areas and as the demolition progresses (see also section 3).

A4.3.3 Overloading of any parts of the remaining structure with debris or other materials should be avoided. Where materials and debris and are lowered from higher levels, care should be taken to prevent the material from swinging in such a manner that it creates a danger to the workers on site or the surrounding structures. Larger pieces of debris should be broken down into manageable sizes, subject to a maximum of 1.0m x 1.0m. The weight of loaded buckets for unloading debris would be limited to say, 200 kg.

A4.3.4 All debris would be removed at frequent intervals and stockpiles should not be allowed to build up excessively. In general it is anticipated that demolition waste would be removed on a daily basis with several tens of lorries leaving the site each day at the peak of demolition activities.

A4.3.5 Reinforced concrete structural members should be cut into lengths appropriate to the weight and size of member before being lowered to the ground. Where possible, crane and lifting gear should be used to support beams and columns whilst they are being cut and lowered to the ground.

A4.3.6 Removal of bricks walls should be from top to bottom in horizontal runs of not more that 300mm wide.

A4.3.7 Before and during demolition, the Contractor should pay attention to the nature and condition of the concrete, the condition and position of reinforcement, and the possibility of lack of continuity of reinforcement should be ascertained. Attention should also be paid to the principles of the structural design to identify parts of the structure, which cannot be removed in isolation. If uncertainties exist then advice of the Site Engineer/AP/RSE’s advice should be sought.

A4.3.8 During demolition works, if anomalies or irregularities are discovered in structural elements, regarding reinforcement bar details, alteration and addition works, unauthorized building works, etc, demolition works should stop immediately. AP/RSE should be informed and works will commence only after AP/RSE approval is obtained.

A4.3.9 If the Contractor discovers that the removal of certain parts of the buildings or structure during demolition would result in other parts becoming unsafe, it would be necessary to determine where temporary support will be needed and the advice of the Site Engineer/AP/RSE should be sought.

A4.4 General Safety Measures

A4.4.1 The Contractor will need to carry out works in accordance with the Factories and Industrial Undertakings Ordinance, particularly the Construction Site (Safety) Regulations and the Code of Practice for Scaffold Safety, as well as all other statutory requirements and guidelines covering health and safety issues.

A4.4.2 All contractor and sub-contractors should be competent and qualified in demolition works. Site Engineer/AP/RSE(s) will need to ensure that all levels of Contractor(s) and his subordinates are fully conversant with the demolition plans, method statements and procedures.

A4.4.3 Where scaffolding is used, the Contractor should arrange for a competent scaffolder to visit site and inspect the scaffolding work, and to make any adjustments required to the scaffolding as the work proceeds, to ensure its stability.

A4.4.4 The Contractor shall also appoint a competent person, experienced or trained in the type of operation being performed at that particular time, to supervise and control the work on site.

A4.4.5 The Contractor should ensure that every work place, approach and opening, which may pose a danger to persons employed and others should be properly illuminated and protected.

A4.4.6 The use of all mobile cranes must be strictly controlled to ensure that cranes of adequate capacity will be used for lifting under different loading conditions.

A5 Principles of Chimney Demolition at KCIP

A5.1 Access

A5.1.1 The main site would be protected by security personnel and a high hoarding such that the public would be totally excluded from the Project.

A5.1.2 The area beneath the chimneys would be cordoned off and only authorized staff involved in the demolition of the chimneys would be allowed admission into the vicinity of the chimney structures.

A5.2 General Approach

A5.2.1 The principle of the demolition procedure for the upper portion of the chimneys (10m from ground level or greater) is that the chimneys will be cut into small pieces by hand held tools on the spot by operatives who would work from working platforms inside the chimney. Hydraulic breakers would be used for the remaining lower portions of the chimneys.

A5.2.2 The concrete liner and the metal flues will be removed manually. The principle of the demolition procedure is that the chimney and flues would be cut up into pieces and these pieces lowered to the ground by derrick. This method would ensure that full control of the debris and that the pieces of reinforced concrete are not left to free fall (Figure 5.1).

A5.3 Preparation

A5.3.1 The area surrounding the chimney would be made secure and all necessary barricades erected. Only Authorized personnel would be allowed into the area.

A5.3.2 Two crane shafts each size 1.5m x 1.5m would be erected inside the chimney up to 100m high. The two crane shafts would be reduced to 1m x 1m above 100m high.

A5.3.3 A derrick would be mounted on the top of each crane shaft for hoisting & lowering of tools and debris.

A5.3.4 A working platform would be constructed at a level 2m below the top of the chimney.

A5.3.5 Panel of mesh flooring of the existing steel platform at each level would be removed to facilitate creation of the crane shaft and the lowering of debris.

A5.4 Sequence of Operations

A5.4.1 Using hand held tools, the insulation of the flue (non-ACM) would be removed down to 2m below top level.

A5.4.2 On the platform the concrete liner and metal flues are removed by hand and loaded into skips for lowering down to adjacent ground.

A5.4.3 The metal flues would be flame cut into 2m maximum length for lowering down to ground level.

A5.4.4 Using light weight chain saws, the chimney would be cut up into pieces of maximum size 1m x 1m, each piece being secured by a cable to a derrick to ensure that when the cutting is completed the concrete is fully supported.

A5.4.5 The individual pieces can then be lowered to the ground in a safe and controlled manner, thus ensuring there will be no free falling of material.

A5.4.6 The crane shafts and derricks can then be lowered by 2m. A new platform will be erected 2m below the new top level of the remaining chimney portion. The platform size would be progressively enlarged, as demolition progresses downward to accommodate the increasing diameter of the Chimney.

A5.4.7 This process would be repeated until only the lower 10m of the chimney remained. These remaining lower levels would be within the reach of normal, mobile hydraulic breakers. Such breakers would be on the ground and the lower portion of the chimney would be removed by these means.

A5.5 Duration of Demolition

A5.5.1 The buildings and chimney at KCIP can be demolished and removed by the conventional top down demolition using hand held tools and mechanical breaking methods. In order to avoid hazards caused to the adjacent areas, all the structures and other buildings near to the chimneys would be demolished and removed prior to the demolition of the chimneys. The estimated time for the completion of these works included in the PPFS was 16months which would appear to be ample time for demolition base on the above methodology.

A.6 Conclusion

A6.1.1 This working paper has presented information concerning the difficulties associated with the demolition of the Kwai Chung Incineration Plant and the demolition of Kennedy Town Comprehensive Development Area (the Project). In order to facilitate the progress of the Initial Assessment Report and the EIA process as a whole it is necessary to define the Project in sufficient detail in line with the objectives of the Study.

A6.1.2 The primary aim of this working paper is to establish a conceptual demolition method for both Project in order to facilitate progress the EIAs. During the preliminary investigations the consultants have taken note of the work conducted previously and also initiated discussions with relevant Government departments, many of whom have expressed severe concerns with the proposals to include any form of blasting techniques for the felling of the chimneys or the main building structures at either site.

A6.1.3 In the selection of an appropriate demolition method the physical effects on local sensitive receivers and adjacent structures are very important. There are also hidden costs arising from the need to carefully co-ordinate a demolition by implosion. The effect on marine and road transport systems and the complexity of implementing controls is also an important factor. The cumulative impacts of the surrounding interfaces on the project methods have been assessed and make demolition by implosion at either site a potentially costly and a very high risk proposal.

A6.1.4 In order to facilitate the progress of the Initial Assessment Report the consultants therefore seek endorsement of the content of this working paper. Whereas the eventual detailed demolition plan of the selected demolition contractor(s) may not necessarily adopt the precise methodology proposed in this working paper, the methods used should adopt top-down, non-explosive methods for the demolition of the Kwai Chung Incineration Plant and the demolition of Kennedy Town Comprehensive Development Area.

1. Hazards and Safety Precautions

1.1 Introduction

1.1.1 Hazards which may arise at KCIP generally be classified under the following headings:

· General Hazards

· Gas hazards

· Landfill leachate

1.2 General Safety

Operators

1.2.1 Operators should be experienced and licensed drivers. Where possible, all operators should be required to demonstrate their driving ability in the equipment they will be operating and under actual job conditions before recruitment.

1.2.2 Only personnel with valid driving licences are permitted to drive any site cars or vehicles. In the case of vehicles which are not intended for road use, the driver should hold a licence for the nearest comparable class of road vehicle.

1.2.3 For operators employed, a photocopy of their driving licence should be obtained. Their validity and the class of vehicle licences to drive should be checked.

1.2.4 The site office should keep an up to date list of names and copies of driving licences of drivers of motor vehicles and plant.

Equipment

1.2.5 Drivers should make a daily inspection of their vehicles. The check should include steering, brakes, mirrors, lights, horn, tires and windshield wipers. Reverse alarms which must be installed on all trucks and lorries should also be checked to ensure safe operation. Drivers are required to report all defects to the plant mechanic foreman, and repairs should be made promptly.

Roads

1.2.6 Site roads should be maintained in safe operating condition at all times. Roads should be built to provide adequate drainage and width and should avoid sharp curves, abrupt changes in gradient and excessive gradients. The use of one-way traffic roads is recommended wherever possible. Site roads must have clearly visible signs in both Chinese and English.

Transporting Personnel

1.2.7 Personnel should only ride in vehicles designed for the purposes. It is forbidden for personnel to take rides with operations where no specific sear has been provided for passengers.

Loading Lorries

1.2.8 Materials loaded onto lorries should be within the permitted safe weight limit and should not project beyond the lorry body or be placed in an unsafe pile in such a manner as to present a hazard to other vehicles, pedestrians or structures.

General Requirements

1.2.9 Drivers leaving the driver leaves the driving seat of a vehicle shall ensure the engine shall is switched off, the gear engaged and parking brakes applied. The wheels shall be chocked on slopes.

1.2.10 Lorries should only be backed under the direction of a marshal or spotter. In dumping areas, the marshal and spotters should be identified by a reflective vests.

1.2.11 All operators and drivers are required to observe speed limits at all times.

1.2.12 All pedestrians requiring to pass close to an operating machine shall ensure that the machine operator has been them and has stopped operation prior to proceeding.

1.2.13 All personnel working on site roads or directing traffic shall wear reflective vests.

Plant Noise

1.2.14 The foreman shall ensure that noise assessments are carried out on all noisy plant used on site. Any plant that creates noise exceeding the first action level stated in the Factories and Industrial Undertakings (Noise at Work) Regulations should be identified, with notices fixed to the plant and appropriate action should be taken as described in the Regulations to avoid exposure to the noise. Attention shall also be paid to the recommended Environmental Monitoring and Audit plan for the site.

1.3 Gas Hazards

1.3.1 Waste in the landfill emits a mixture of gases. The composition of gases at KCIP is not known however leachate gases of the following composition would not be untypical for such a site approximately as follow:

· 45-55% methane – Explosive.

· 44-54% Carbon Dioxide – Asphyxiant.

· 1% Other gases – mainly organic vapours.

1.3.2 The main danger from landfill gas is due to explosion of methane, however, if large concentrations of gas displace air there can be a danger of asphyxiation or poisoning. Gas concentrations are likely to be higher near the tops of gas wells and near exposed areas of leachate collection stone.

1.3.3 All personnel are advised to observe the following guidelines to avoid gas accidents:

· No smoking on the site.

· Do not enter trial pits unless the air quality has been tested (see 1.6)

· If any personnel has any of the following health symptoms while working at, in or near a trial pit on the Site he should move away from the area of the trial pit immediately:

- Headache,

- Dizziness / lightheadedness,

- Tingling or numbness,

- Nausea,

- Blue lips or bright red skin.

1.3.4 Once the affected person has moved to a position remote from the trail pit he should inform his supervisor who will evaluate the situation, decide whether other persons should be evacuated from the immediate area whether medical aid is required.

1.4 Landfill Leachate

1.4.1 Solid waste in the reclamation under the site or leachate originating from GDBL may be toxic, the following rules should therefore be observed:

· If leachate has to be handled, or groundwater samples lotion ensure that the operatives wear protective clothing and gloves. If any operatives come into contact with leachate, should be immediately wash the affected area with clean fresh water.

· Ensure that any broken skin, cuts, graze and the like do not come into contact with waste or leachate. All cuts etc should be covered prior to working on the site.

· Safety boots should be worn on the site.

· All operatives should keep a lookout for sharp objects on the site such as broken glass, syringe needles, nails in pieces of wood and the such like.

· If any operative receives any cuts or grazes whilst he is on he landfill, he should report this immediately to his supervisor who will arrange for medical attention.

1.5 Site Safety Precautions

1.5.1 All operational and supervisory staff’s attention shall be drawn to the hazards of landfill gas generated by decaying refuse in the landfill which may have migrated to the KCIP Site. This gas can endanger the safety of workers, as the flammable gas it contains explosive potential once it is mixed with air. Attention shall also be given to other components of the gas which have the potential to cause asphyxiation or toxic effects under appropriate conditions.

1.5.2 Smoking and the use of naked lights and welding shall be prohibited in areas of the site where landfill gas likely to be present and can migrate. Warning signs designating “no smoking areas” shall be put up to remind workers of these restrictions.

1.5.3 Plant and mobile plant shall carry fire extinguishers, and shall be equipped with properly functioning spark arrestors and automatic air intake shut down valves. Wherever possible diesel operated plant shall be used.

1.5.4 No fires shall be permitted on the site. Operational and supervisory staff shall immediately extinguish any fires within the site.

1.5.5 Confined spaces and excavation where entry is required shall be treated as described under Section 1.6.

1.5.6 Temporary offices, huts and storage containers shall not be located where infiltration of gas could occur, and in any event shall be provided with simple gas protection measures and detection systems where appropriate.

1.5.7 Fire fighting facilities shall be maintained on the site, and shall be property housed and kept readily available for instant use.

1.5.8 The site designated emergency co-ordinator shall liaise with the Fire Services Department to ensure that they are in a position to respond quickly to any fire or explosion which may occur. The emergency co-ordinator shall notify the Fire Services Department immediately in the event of any such emergency.

1.5.9 The site agent shall carry out the following:

· Prepare detailed working procedures and safety precautions for the work being carried out.

· Instruct the workmen and other staff in the working procedures and safety precautions to be followed.

· Record in writing that the workmen and other staff have been so instructed.

· Provided sufficient equipment so the working procedures and safety precautions can be followed.

· Ensure the working procedures and safety precautions are adhered to.

1.6 Working in Confined Spaces

1.6.1 The Site contractor shall ensure that any work in a confined space, as defined in the Factories and Industrial Undertakings (Confined Spaces) Regulations, complies with the requirements of the Regulations and is in accordance with the Guide to the Regulations published by the Labour Department.

1.6.2 All entries into confined spaces will be subject to a written detailed safe working procedure and a permit to work procedure. The written safe working procedure will include, but may not be limited to, details of the following: -

· arrangements for detecting toxic or explosive gas or oxygen deficiency, and the detection equipment to be used.

· supervision arrangements

· safety and emergency rescue equipment to be used, including breathing apparatus, safety harness and safety ropes

· permit to work procedures

1.6.3 All persons entering a confined space shall have received appropriate training from authorised bodies.

1.6.4 All written safe working procedures and completed “Permit-To-Work Certificate” shall be kept in the site office.

DOCUMENT TITLE PAGE
*Client :* Civil Engineering Department				*Contract No.* (if any) : - CE 15/99
*Project Title :* Environmental Impact Assessment for Demolition of Kwai Chung Incinerator Plant and Kennedy Town CDA				*Project No. :* 2996
*Document No. :* 2996-OR027-03				*Controlled Copy No. :*
*Document Title :* Kwai Chung Incineration Plant EM&A Manual
*Covering Letter / Transmittal Ref. No. :* 2996/15.99/ELT /DG/jw/OG				*Date of Issue :* September 2001
Revision, Review and Approval/Authorisation Records
		/	/		/
		/	/		/
03	4^th Issue	Various/	JWS/		DG/
02	3^rd Issue	Various/	JWS/		DG/
01	2^nd Issue	Various/	JWS/		DG/
00	1^st Issue	Various/	JWS/		DG/
Revision	Description	Prepared by / date	Reviewed by / date		App. or Auth. By / date

Controlled Copy No.	Issued to
1 - 45	Civil Engineering Department
46 - 47	ACL – ELAN
48 - 65	ACE

AL	Action/limit
APCO	Air Pollution control Ordinance
AQO	Air Quality Objective
CNP	Construction Noise Permit
EIA	Environmental Impact Assessment
EIAO	Environmental Impact Assessment Ordinance
EM & A	Environmental Monitoring and Audit
EPD	Environmental Protection Department
ER	Engineer’s Representative
ET	Environmental Monitoring Team
ETL	Environmental Monitoring Team Leader
FIUO	Factories and Industrial Undertakings Ordinance
IC(E)	Independent Checker (Environment)
HKPSG	Hong Kong Planning Standards and Guidelines
HVS	High Volume Sampler
HyD	Highways Department
KCPTW	Kwai Chung Primary Treatment Works
NCO	Noise Control Ordinance
NSR	Noise Sensitive Receiver
SR	Sensitive Receiver
TM	Technical Memorandum
TSP	Total Suspended Particulates
USAEPA	United States of America Environmental Protection Agency
WDO	Waste Disposal Ordinance
WPCO	Water Pollution Control Ordinance

Parameter	TCLP Limit (ppm)
Cadmium	10
Chromium	50
Copper	250
Nickel	250
Lead	50
Zinc	250
Mercury	1
Tin	250
Silver	50
Antimony	150
Arsenic	50
Beryllium	10
Thallium	50
Vanadium	250
Selenium	1
Barium	1000

1.1.2 This Manual contains the following:

1.1.3 The EM&A Manual has taken on a dual function since the introduction of the EIAO. These roles are:

1.2.1 The criteria for the requirement for undertaking EM&A are provided by EPD, these are summarised as follows:

1.3.1 The KCIP is located at Kwai Yue Road, Kwai Chung, facing the Rambler Channel and Tsing Yi South Bridge, with a site area of about 14,000 m2 (Figure 1.1). The site is close to the Kwai Chung Park, the former Gin Drinkers Bay Landfill.

1.3.2 The KCIP site is adjacent to the KCPTW and part of the KCIP site overlaps the “Sewerage Tunnel Protection Area” of the Strategic Sewerage Disposal Scheme (SSDS), administered by Drainage Services Department (DSD).

1.3.3 There is no identified long term use of the area after demolition, however, the future land use is unlikely to be residential given the close proximity of the site to Gin Drinkers Bay Landfill and the Rambler Channel Bridge.

1.3.4 A Public Fill Barging Point (PFBP), located on reclaimed land (Area 30D) to the north of the KCIP, is planned to be operational in early 2005. The PFBP is also subject to a separate EIA study by others.

1.3.5 The site is opposite the Rambler Channel Typhoon Shelter and Public Cargo Working Area. These facilities accommodate a range of cargo related activities including permanently moored barges.

1.4.2 There are several engineering and other locations, which would be very sensitive to demolition by blasting. These include:

1.4.3 Due to the short distances between the chimney and the surrounding structures, the high risk and lack of cost effectiveness meant that demolition of the single chimney by blasting was reaffirmed as not feasible in the early stages of this EIA study.

1.5 General Approach to Demolition of Buildings and Structures at KCIP

1.6.1 The area beneath the chimney should be cordoned off and only authorised staff involved in the demolition of the chimneys should be allowed admission into the vicinity of the chimney structure.

1.7.1 The areas requiring decontamination, identified based on the Contamination Assessment Report and Remediation Action Plan are shown in Figure 7.1.

1.9.1 The proposed project organisation is presented in Figure 1.3 as the basis of information available at the time of report preparation.

1.9.2 The preferred approach is for the Independent Environmental Monitoring Team (ET) to be employed directly by the project proponent (CED). The monitoring is audited and checked by the Environmental Monitoring Team Leader (ETL) who reports to the Engineer’s Representative (ER).

1.9.4 Site Inspection Team Leader: Requires experience working on environmental projects in Hong Kong. Extensive experience in dealing directly with Contractors is required.

1.9.5 Noise/Air Specialist: Requires experience in the air and noise pollution field. Skills in the use of computer models, database design and management of monitoring programmes are required.

1.9.7 Assistant Consultant: Experience in conducting on-site monitoring, data-gathering and subsequent computer-modelling data analyses.

1.9.8 The duties to be undertaken by the Environmental Team (ET) comprise the following:

1.9.9 Appropriate resources shall be allocated by the ET to fulfil the duties specified in this Manual.

1.9.10 Independent Checker (Environment). The role of the IC(E) shall be independent from the management of construction works; but the IC(E) shall be empowered to audit the environmental performance of construction (Appendix B). The IC(E) shall have a similar of level of experience as the ETL.

1.10.3 The EM&A programme will also cover the land remediation phase, which will be undertaken following the demolition of structures.

2.1.1 The major air quality issue associated with the demolition at KCIP is the potential for dust generation to cause elevated Total Suspended Particulates (TSP) levels and a nuisance at the adjacent Kwai Chung PTW.

2.2.2 24-hour TSP levels shall be measured to indicate the impacts of construction dust on air quality. The TSP levels shall be measured by following the standard high volume sampling method as set out in the Title 40 of the Code of Federal Regulations, Chapter 1 (Part 50).

2.2.3 All relevant data including temperature, pressure, weather conditions, elapsed-time meter reading for the start and stop of the sampler, identification and weight of the filter paper, and other special phenomena and work progress on the site shall be recorded in detail.

2.3.1 High volume samplers (HVS) to be used for carrying out the 1-hour and 24-hour TSP monitoring shall comply with the following specifications:

2.3.2 The ET shall provide sufficient HVSs with the appropriate calibration kit to ensure that the baseline, impact and ad hoc monitoring commences on schedule and is not interrupted as a result of equipment failure, damage, loss or routine maintenance.

2.3.3 The HVSs shall be equipped with an electronic mass flow controller and be calibrated against a traceable standard at regular intervals. All the equipment, calibration kit, filter papers, etc. shall be clearly labelled.

2.3.5 The flow-rate of the sampler, before and after the sampling exercise with the filter in position, shall be verified to be constant and be recorded in the data sheet.

2.3.6 The ET shall provide sufficient equipment to ensure that the monitoring commences on schedule and is not interrupted as a result equipment failure, damage, loss or routine maintenance.

2.4.1 A clean laboratory with constant temperature and humidity control, and equipped with necessary measuring and conditioning instruments, to handle the dust samples collected, shall be available for sample analysis, equipment calibration and maintenance.

2.4.3 Filter paper of size 8”x10” shall be labelled before sampling. It shall be a clean filter paper with no folds or pin holes, and shall be conditioned in a humidity controlled chamber for over 24-hour and be pre-weighed before sampling.

2.4.5 All the collected samples shall be kept in a good condition for 6 months before disposal.

2.5.2 The proposed location is shown in Figure 2.1.

2.5.3 The status and location of dust sensitive receivers shall be reviewed after issue of this Manual. The ETL shall identify the ASR location to be adopted based on the updated construction (demolition) programme and seek approval from the ER and relevant Government Departments.

2.5.4 The monitoring location should be chosen based on the following criteria:

2.6.1 The ETL shall carry out baseline monitoring as close to the Kwai Chung PTW as is practical at a location agreed with EPD.

2.6.2 The exact locations should be agreed with the ER and relevant Government Departments prior to commencement of the monitoring programme and subject to practical considerations. If practical, this should match with the proposed permanent location for the monitoring equipment.

2.6.3 Monitoring shall be for 14 consecutive days prior to the commissioning of the demolition works to obtain daily 24-hour average TSP samples (total of 14 24-hour average measurements).

2.6.4 Construction or dust generation activities from the project with potential to affect the results shall not have commenced in the vicinity of the monitoring stations.

2.6.5 In exceptional cases, where insufficient baseline monitoring data or questionable results are obtained, the ETL shall liaise with the ER to agree on an appropriate set of data to be used as a baseline reference and submit to ER for approval and relevant Government Departments.

2.7.1 The ET shall carry out regular impact monitoring during the course of the works. Monitoring shall be undertaken at 1 location for 24-hour TSP monitoring. A sampling frequency of one 24 hour measurement every six-days shall be adopted.

2.9.1 The EIA report has discussed in general terms the appropriate dust control and mitigation measures, these are provided in more detail below.

2.9.2 The Air Pollution Control (Construction Dust) Regulation came into operation in June 1997 that requires notification before carrying out of certain types of construction works and to adopt dust reduction measures while carrying out construction activities.

2.9.6 The Contractor shall implement dust suppression measures as identified in the Schedule given in Section 10.

3.1 Conclusions from the EIA

.

4.2.3 Monitoring equipment should have, as a minimum, the indication ranges set out below.

4.2.4 As a minimum:

· monitoring frequency should be on an hourly basis and should always be undertaken by suitably qualified personnel; and

· all measurements should be taken such that they include the highest and lowest points within the works below ground level.

4.2.5 All measurements should be recorded and included in the site diary. This should be reflected in the Safety Plan. Some basic site safety precautions recommended in the EIA are included at Appendix E.

5.3.1 Whereas the majority of the site has a hard concrete covering the area of potentially exposed soil will be minimal. Such areas and the accumulation of dust and fine waste material shall be kept to a minimum to reduce the potential for siltation, contamination of run-off, and erosion.

Mitigation Measures

5.3.2 Run-off related impacts associated with demolition work and other general activities can all be readily controlled through the use of appropriate mitigation measures which include:

5.3.6 Oil interception facilities should be provided in appropriate areas in the drainage system, where oil spills may occur, and regularly emptied to prevent the release of oil and grease into the storm water drainage system after accidental spillage.

5.3.7 Provided the surface run-off and drainage are effectively managed and controlled over the site, adverse water quality impacts can be avoided.

5.3.8 All demolition works will be land based and the EIA concludes that no insurmountable water quality impacts will result from the demolition work of KCIP provided that:

· All the recommended mitigation measures including appropriate drainage and silty run-off collection facilities are incorporated in accordance with the recommendations of ProPEC PN 1/94;

· All demolition workforce sewage is discharged either to foul sewer or to temporary portable toilets, as appropriate according to the demolition programme and methodology;

· All temporary drainage diversions will be reinstated to the original condition after the demolition works are completed and implemented properly, in accordance with the recommendations of ProPECC PN 1/94; and

· All demolition works area discharges must comply with the TM standards of the WPCO in respect of all applicable WQ parameters. Any practical options for the diversion and re-alignment of drainage should comply with both engineering and environmental requirements. General Demolition Activities

5.3.9 Debris and rubbish on site should be collected, handled and disposed of properly to prevent such material from entering the water column and causing water quality impacts. The solid waste management requirements are presented later in this report.

5.3.10 If required, fuel storage areas should be provided with locks and be sited on sealed areas, within bunds of a capacity equal to 110% of the storage capacity of the largest container (to provide a safety margin) and control spilt fuel oils.

5.3.11 The effects on water quality from these demolition activities are likely to be minimal provided that site boundaries are well maintained and good site practice is observed to ensure that litter and fuels are managed, stored and handled properly

5.3.12 It is considered that controls on discharges from land based demolition activities and proper site management procedures, as referenced above, will minimise residual water quality impacts to the acceptable levels stipulated in the WPCO criteria.

Site Run - off

Dewatering

5.4.3 In addition, the Contractor is strongly advised to operate any necessary ground remediation works such that discharge of groundwater should be kept to minimum. This could be achieved by:

.

6.1 Waste Management

6.1.1 The Contractor shall be responsible for waste control within the construction site, removal of the waste material produced from the site and implementation of any mitigation measures to minimise waste or redress problems arising from the waste from the site.

1.3.1 The KCIP is located at Kwai Yue Road, Kwai Chung, facing the Rambler Channel and Tsing Yi South Bridge, with a site area of about 14,000 m² (Figure 1.1). The site is close to the Kwai Chung Park, the former Gin Drinkers Bay Landfill.