11.1.1
This section outlines the
recommendations for the environmental monitoring and audit (EM&A) programme
for the demolition of the Existing Crematorium as well as construction and
operation of the New Crematorium, based on the findings of this Study. This EM&A programme is formulated
based on the recommendations of the “Environmental Monitoring and Audit
Guidelines for Development Projects in Hong Kong” published by EPD in
1998. A separate EM&A Manual Report
has been prepared in accordance with Annex 21 of the EIAO-TM.
11.1.2
The objectives of carrying out
EM&A programme for the Project are as follows:
Ÿ
To
establish a database of any short or long term environmental impacts of the
Project
Ÿ
To
provide an early indication if there is any of the environmental control
measures or practices fail to achieve the acceptable standards
Ÿ
To
monitor the performance of the environmental mitigation measures of the Project
and the effectiveness of mitigation measures
Ÿ
To
verify the environmental impacts predicted in this EIA
Ÿ
To
determine project compliance with regulatory requirements, standards and
government policies
Ÿ
To
take remedial action if unexpected problems or unacceptable impacts arise
Ÿ
To
provide data to enable an environmental audit
11.1.3
According to assessment results, no
adverse environmental impacts are anticipated during construction and
demolition phases of Existing Crematorium as well as operational phase of the
New Crematorium. Certain environmental
monitoring measures are recommended to closely monitor the environmental
performance of the Project. The
suggested EM&A requirements during the construction and operation phases
are summarized as follows.
11.2.1
According to the environmental
assessment results, there would be no adverse environmental impact of the air
quality, waste and water quality on the surrounding sensitive receivers. However, fugitive dust emission and
construction noise would be major concerns to the nearby sensitive receivers
during construction phases, EM&A of air quality and construction noise is
recommended. Details of the
EM&A programme are described in Sections
3 and 4 in the EM&A
Manual.
Air Quality
11.2.2
Total suspended particulates (TSP)
monitoring should be carried out at two representative locations at the ASRs A8
and A17. . 1-hour and 24-hour monitoring should be
carried out at 2 measurement locations at the frequency of every 6 days to
monitor the impact of fugitive dust to the nearby environment. The limit levels of 1-hour and 24-hour
TSP levels are summarized in Table 11.1 while the proposed TSP measurement
locations are listed in Table 11.2.
Table 11.1Limit Levels of TSP Monitoring
|
Monitoring Period
|
Limit Level (mg/m3)
|
|
1-hour
|
500
|
|
24-hour
|
260
|
Table 11.2Location of TSP Monitoring
|
Air Sensitive Receivers
|
Location
|
|
A8
|
Po Leung Kok Grandmont Primary School
|
|
A17
|
Staff Quarter for Diamond Hill Crematorium
|
A
baseline monitoring should be carried out for 14 consecutive days prior to the
commencement of the construction works.
11.2.3
The demolition of the existing
cremator facilities and the crematorium building may involve removal of
ACM. When the demolition material
is confirmed to have ACM, the method of removal and details of asbestos
abatement works would be provided in the Asbestos Study Report, AIR and AAP to
be submitted under the APCO.
Whereas it is not expected that asbestos fibre would be liberated from
the demolition of the Existing Crematorium building, the EM&A for asbestos
fibre would be carried out at the boundary of the construction site for
reassurance purposes as per the requirement of future license for asbestos
abatement.
Noise
11.2.4
Monitoring of noise should be carried
out during the construction and demolition works. The noise monitoring locations are summarized in Table 11.3
Table 11.3Location of Noise Monitoring
|
Noise Sensitive Receivers
|
Location
|
|
SR
3
|
(New school under construction)
Po Kong Village Road School Village
|
|
SR
4
|
Po Leung Kuk
Grandmont Primary School
|
|
SR
6
|
Staff Quarter for Diamond Hill Crematorium
|
11.2.5
Noise monitoring should be carried out
weekly during the working hours of the construction site. The noise limit of construction or
demolition activities for the time period other than the restricted hours is
shown in Table 11.4
Table 11.4Limit Levels of Noise Monitoring
|
Monitoring Period
|
Limit Level (dB(A))
(Domestic Premises/ Schools)
|
|
0700
– 1900
on
normal working days
|
75/
70 (1)
|
Note: (1)
Reduced to 65 dB(A) during school examination periods
Land Contamination
Supplementary Site
Investigations
11.2.6
The CAR and RAP have recommended
supplementary site investigations at the CLP secondary substation that is currently
in use and cannot readily be accessed.
In addition, the ash waste in cremator/chimney/flues should also be
collected for the testing of DCM/HMCM/PAHCM during Phase II of the works. These investigations will be carried
out once the existing facility has been decommissioned but prior to
demolition.
11.2.7
Details of the supplementary site
investigation are described in Section 6
of the EM&A Manual. The scope
of the supplementary site investigations is to recover soil samples from around
the CLP secondary substation during Phase I of the works and determine the
relevant handling/treatment/disposal method.
Confirmatory Site
Investigations
11.2.8
In addition to these supplementary
site investigations, confirmatory testing is required of the soil around the
crematorium chimney, to ensure that no additional contamination has occurred
due to aerial deposition between the current time (2003) and closure of the
facility in 2006. The confirmatory
testing will consist of surface sampling (i.e. 0.1m depth) at points S1 to S6,
and analysis for dioxins, metals and PAH.
11.2.9
The underground fuel storage tank and
associated pipework will be removed as part of the site formation works. The base of the excavations will be
inspected by a suitably experienced environmental specialist in order to
determine whether there is any visual or olfactory evidence of fuel
contamination. If such
contamination is suspected, then confirmatory soil sampling will be carried
out, and the samples analyzed for TPH.
11.2.10 Once access to these areas is available, a sampling and analysis
plan should be prepared for approval by EPD, additional investigations will
take place, and the need for remedial works will be determined. Any remedial works required will be in
addition to those described in the CAR and RAP. The analysis should include, as a minimum, the parameters
detailed in Table 11.5 below;
Table 11.5Supplementary and Confirmatory Site Investigations
Locations, Timing and Parameters
|
Timing
|
Location
|
Parameters
|
|
Phase I
|
CLP Secondary Substation:
(soil samples)
|
Polychlorinated biphenyls
(PCBs)
Total petroleum hydrocarbons
(TPH) (diesel range)
|
|
Phase II
|
Locations S1 – S6 described
in CAR/RAP:
(soil samples)
|
Polyaromatic hydrocarbons
(PAH)
Dioxins
Metals (“Dutch List”: Cr,
Co, Ni, Cu, Zn, As, Mo, Cd, Sn, Ba, Hg, Pb)
|
|
Phase II
|
Underneath underground fuel
tank (if visual or olfactory evidence of fuel contamination is identified):
(soil samples)
|
Total petroleum hydrocarbons
(TPH) (diesel range)
|
11.2.11 These supplementary and confirmatory site investigations should be
conducted by consultants experienced in abatement of the corresponding chemical
waste.
Remedial Works
11.2.12 The scope of remedial works is described in the CAR/RAP, and
consists of excavation and landfill disposal of small “hotspots” of
contaminated material.
11.2.13 As tin and lead was found in locations S3 and S5, confirmatory
testing will be carried out following excavation at each location, in order to
confirm that all contaminated material has been removed. The confirmatory testing will consist
of five samples in each location, situated immediately to the north, south,
east and west of each location, and at the base of the excavation, to be
analyzed for lead and tin. If the
results of analysis are less than the Dutch B Levels, no further excavation
will be required. If the
concentrations exceed the Dutch B Level, then the area of excavation should be
extended, and further confirmatory testing should be carried out following this
excavation. In this event, the
area of excavation should be extended by a further 5m radius in the quadrant
where the contaminated sample is encountered, or by a further 0.5m depth if the
contaminated sample is from the base of the excavation. This procedure should be followed until
no further contamination is encountered.
11.2.14 If contamination is found in supplementary / confirmatory site
investigations, appropriate remediation measures approved by EPD should be
implemented.
11.2.15 A Remediation Report should be prepared once remedial works have
been completed, to demonstrate compliance with the CAR/RAP.
Waste Management
Supplementary Site
Investigation
11.2.16 Due to the accessibility issues of the cremator room, supplementary
site investigation is recommended in Section
7 of this Report and details are provided in Section 7 of the EM&A Manual. A list of supplementary site investigation locations, timing
and parameters is given in the table below:
Table 11.6Supplementary Site Investigations Locations, Timing
and Parameters
|
Timing
|
Location
|
Parameters
|
|
Phase II
|
Around cremators, chimney
and flues inside cremator room:
(building structures)
|
Asbestos
|
|
Phase II
|
Around cremators, chimneys
and flues inside cremator room:
(Ash/particulate matter
samples)
|
Dioxins
Metals (“Dutch List”: Cr,
Co, Ni, Cu, Zn, As, Mo, Cd, Sn, Ba, Hg, Pb)
Polyaromatic hydrocarbons
(PAH)
|
11.2.17 The supplementary site investigation plan, devised by consultants experienced
in abatement of corresponding chemical waste, should be submitted to EPD for
approval prior to the sampling works.
11.2.18 If contamination is found, relevant mitigation suggested in Section 7 should be implemented. During the Phases I and II, a waste
management audit should be carried out to check compliance with all appropriate
environmental protection and pollution control measures. Details of the waste management audit
are provided in Section 7 of EM&A
Manual.
Air Quality
11.3.1
During the operation of the new
crematorium, it is anticipated that the major environmental concern would be
the chimney emission. RSP, CO,
HCl, Hg, organic compounds and dioxins would be generated from the cremators
during the operation. Referring to
the air quality impact assessment as discussed in Section 4, the air quality at the nearby air sensitive receivers is
predicted to comply with the relevant air quality guidelines with the
implementation of the recommended mitigation measures. There would be no odour nuisance from
the new Crematorium. Furthermore,
with proper operation of the cremators and air pollution control system,
minimum dark smoke emission is expected.
11.3.2
In order to ensure compliance of the
legislation requirements, the conditions and the continuous monitoring
stipulated in BPM 12/2 - A Guidance Note on the Best Practicable Means for
Incinerators (Crematoria), published by EPD, shall be conducted. Real time data acquisition facilities
shall be provided at each stack or inside each cremator for continuous
monitoring on the following pollutants and processes:
Ÿ
Temperature
inside the primary combustion zone;
Ÿ
Temperature
at the outlet from the secondary combustion zone;
Ÿ
Oxygen
concentration at the outlet from the secondary combustion zone;
Ÿ
Carbon
Monoxide concentration at the outlet from the secondary combustion zone;
Ÿ
Smoke
density at the chimney of the cremator; and
Ÿ
Other
essential operating parameter(s) which may affect the performance of air
pollution control measures.
11.3.3
The continuous monitoring equipment to
be provided should meet the specifications specified by EPD. They should be maintained and
calibrated according to the manufacturer’s recommendations. Unless otherwise agreed by EPD, zero
and span checks should be carried out every 24 hours.
11.3.4
The monitoring of the above air
pollutants shall comply with the Specified Process License of the new
Crematorium, to be issued by EPD under the APCO. All continuous monitor readings shall be continuously recorded
and the readings shall be on immediate display to the operating staff for the
monitoring of cremation process.
11.3.5
As required in BPM 12/2, all real time
data as required in BPM 12/2 shall be transmitted to a remote display unit
installed at the corresponding EPD Local Control Office by means of telemetry
transmission when requested by EPD.
11.3.6
All the real time monitoring equipment
shall be properly maintained and calibrated. All the real time monitoring data shall be recorded and
stored up in accordance with the requirement of the future Specified Process
License.
11.3.7
There may be possible odour impact
during the operational phase due to chimney emissions, and therefore routine
odour patrol at the site boundary shall be carried out to detect any offensive
odour. Corrective actions shall be
taken if offensive odour is noted during odour patrols.
11.3.8
Results of all monitoring and
inspections should be recorded in a manner specified by EPD. These records should be retained at the
premises for a minimum of two years, or other period specified by EPD, after
the date of last entry and be made available for examination as and when
required by the Authority.
11.3.9
A commissioning test shall be arranged
prior to the normal operation of the crematorium, in order to evaluate the
performance and the emission of air pollutants meet the requirements under the
Specified Process License.
11.3.10 Other stack emissions listed in the BPM 12/2 but not covered in the
continuous monitoring shall be subject to routine monitoring during the
operation phase for every 12 months interval but the stack emission monitoring
frequency shall be based on the Specified Process License for the new
Crematorium. Permanent provisions
in the stacks or cremators, which are necessary in terms of accessibility,
gaseous sampling facilities, shall be provided. Table 11.7 presents the summary of the requirements for
different kinds of pollutants and process monitoring.
Table 11.7Summary of the Requirements for Monitoring of
Air Pollution Emissions and Cremation Process
|
Type of monitoring
|
Monitoring Parameter
|
Methodology of Continuous
Monitoring
|
Data Logging
|
Regular Compliance Monitoring
|
|
In-Stack Monitoring
|
Particulate matters
|
-
|
-
|
Isokinetic stack sampling USEPA
method 5
|
|
Hydrogen chloride
|
-
|
-
|
Isokinetic sampling USEPA method
26A
|
|
Carbon monoxide
|
Infra-red spectrophotometry
|
Yes
|
Electrochemical CO analyzer,
modified USEPA method 10
|
|
Mercury
|
-
|
-
|
Isokinetic stack sampling USEPA
method 29
|
|
Organic compounds
|
|
-
|
Sampling of stack gas and analyzed
with FID, USEPA method 25
|
|
Dioxins
|
-
|
-
|
Isokintic stack sampling USEPA
method 23
|
|
Smoke density
|
Stack gas opacity meter
|
Yes
|
Visual assessment by Ringelmann
chart
|
|
Process Monitoring
|
Temperature of primary chamber
|
Thermocouple
|
Yes
|
Provision of continuous monitoring
|
|
Temperature of secondary chamber
|
Thermocouple
|
Yes
|
Provision of continuous monitoring
|
|
Oxygen concentration at secondary
chamber
|
Paramagnetic analysis USEPA method
3A
|
Yes
|
Provision of continuous monitoring
|
11.3.11 The instruments for smoke density monitoring should be fitted with
audible or visual alarms, which should activate at a reference level agreed by
EPD. Emission events that lead to
the alarms being activated should be properly recorded in a manner and format
agreed with EPD. These instruments
should be checked to ensure that they are functioning correctly in accordance
with the manufacturer’s instructions.
11.3.12 Smoke emission from the cremators during normal operations
(including start up and shut down) shall not exceed Shade 1 on the Ringelmann
Chart.
11.3.13 In addition to the automatic feedback system, manual override of the
operation should be allowed for the new cremators. In case of emergency or failure of the automatic feedback
system, the operation of the individual cremators should be manually suspended
until the problem has been fixed and faulty equipment repaired. Also EPD should
be informed of the event as soon as possible. The implementation of such
contingency and arrangements should be controlled under the Specified Process
License of the APCO.
Landscape and Visual
11.3.14 The project landscape architect would be responsible for inspection
of the following:
Ÿ
Tree felling and transplanting
operations to ensure the correct trees are felled, prepared and transplanted in
accordance with the landscape specification and agreed transplant locations.
Ÿ
Existing planting to be retained is
properly protected by hoarding, or
other means specified, at the commencement of the works and such protection
measures are properly maintained throughout the construction period.
Ÿ
Any topsoil excavated during
construction is carefully saved and stored to one side of the works area for
reuse upon completion.
Ÿ
New planting is provided in accordance
with the specification and detailed planting plan.
Ÿ
Growth of plants in accordance with
the landscape plan to make sure mitigation method is effective and the
landscape enhanced after the first, the sixth and the twelfth month of the
completion of all recommended planting works
11.4.1
A summary for all parameters to be
monitored and audited during construction phase and operational phases are
summarized in Table 11.8.
Table 11.8Summary for All Monitoring Parameters
|
Monitoring Area
|
Construction and Demolition Phases I & II
|
Operation Phase
|
|
Air Quality
|
Monitoring of 24-hour and 1-hour TSP every 6 days at 2 selected
sampling locations at nearby ASRs
|
Continuous monitoring
-
Temperature
of primary chamber
-
Temperature
of secondary chamber
-
Smoke
density
-
Carbon
monoxide and oxygen
Commissioning stage & routine
compliance checking
-
Particulate
matters
-
Hydrogen
chloride
-
Carbon
monoxide
-
Organic
compounds
-
Mercury
-
Dioxins
-
Smoke
density
|
|
Noise
|
Weekly monitoring of noise level at 3 selected sampling locations at
the sensitive receiver
|
Not required
|
|
Land Contamination
|
Supplementary site investigation
Soil: At the CLP secondary substation during Phase I (TPH and PCB)
Confirmatory site investigation
Soil: Locations S1 to S6 during Phase II (dioxin, heavy metals, PAH)
Soil: Underneath underground fuel tank during Phase II (if visual or
olfactory evidence of fuel contamination by experienced environmental
specialist) (TPH)
Remedial work
Soil: Around locations S3 and S5 during Phase II (tin and lead)
|
Not required
|
|
Waste Management
|
Supplementary site
investigation
Ash: At cremators/chimney/flues during Phase II (dioxin, heavy metals,
PAH)
Building Structures: cremators/chimney/flues during Phase II
(asbestos)
|
Not required
|
|
Landscape & Visual Impact
|
Weekly inspections of tree protection measures as well as monitoring
of tree transplant operations during both phases
|
The 1st, 6th and 12th months
inspection of maintenance after the completion of all the recommended
planting work
|
11.5.1
While the environmental impacts
arising from the New Crematorium are assessed based on certain assumptions e.g.
cremator will be able to achieve the emission standard set out in the BPM 12/2,
the maximum allowable sound power level recommended can be met, it is essential
to ensure these targets are continuously met by the selection of a proper
design and the proper operation / maintenance of the equipment. In view of the above, it is desirable
for FEHD to adopt environmental management plan for the operation of New
Crematorium as a means to ensure satisfactory environmental performance of the facilities
at all times. A framework for
environmental management plan is provided in Appendix F. In particular, the following items
would be considered to be implemented in the New Crematorium operations:
Ÿ
Clear
allocation of roles and responsibilities for environmental management issues
Ÿ
Provision
of definitive procedures for proper operation and maintenance of various
facilities, e.g. the cremators and air pollution control systems
Ÿ
Planning
and provision of adequate training to equip the staff about the relevant
competence for carrying the operation and maintenance
Ÿ
Planning
and carrying out regular compliance monitoring and audits to ensure
satisfactory environmental performance and to identify any area for
rectification or further inspection
Ÿ
Establishment of public enquiry
/complaint handling mechanism