1. 現時香港的廢物量比十五年前大幅增加，導致堆填區的填滿速度遠比預期快。在2003年，香港回收了41%的都市廢物，但其中只有4% 在本地循環再造。故此，當局需採取更多措施以改善本地循環再造的成效。其中一項可推動本港環保工業及廢物再造業的措施，是向業界提供可負擔並附有基礎建設的長期土地。
最可取的位置 – 屯門38區
8. 建議中的環保園位於屯門區市郊，與數座工業用處所為鄰(見圖一) 。 該址距離現有之住宅區超過2公里，故它與易受噪音影響的地方相距甚遠。
60. 總括而言，在屯門38區發展環保園可充分體現2005年施政報告的抱負 – 為本地回收再造及環保工業提供年期較長、經濟上又能負擔的用地，鼓勵回收業發展，從而改善環境。如此一來，不但廢物管理可朝著可持續的方向發展，本港經濟可亦因就業職位增加而受惠。
1. Hong Kong's landfills are filling up faster than expected and much more waste is being produced now than 15 years ago, when the landfills were being planned. By the end of 2003, although Hong Kong was recycling 41% of municipal waste, less than 4% was being recycled locally. Thus, further measures need to be taken to improve the level of local recycling. The long-term availability of affordable land provided with basic infrastructure has been identified as one such measure to promote the growth of the environmental and waste recycling industries in Hong Kong.
2. To this end, the Chief Executive announced in his 2005 Policy Address that the Government will formulate a policy to provide concessions to assist the development of the environmental industry. He has pledged to build an EcoPark for exclusive use by recycling industries and committed to the first phase of EcoPark being commissioned in late-2006.
3. The EcoPark is a Designated Project (DP) under G.4(b) of Part 1, Schedule 2 of the EIAO. As a DP under Schedule 2, an Environmental Permit (EP) is required.
4. The EIA for EcoPark is unique in that the future scope of operation of EcoPark cannot be determined at this stage. The initial mix of tenants (and corresponding processes) identified will not remain static but will change in response to the market demands of the recycling industry. Thus, the EIA will need to demonstrate that the environmental impacts of all future recycling processes have been fully considered. Furthermore, it is intended that the EP for EcoPark should encompass a large range of processes such that tenants will not normally need their own EP.
5. To achieve this, three key approaches have been incorporated into this EIA :
· The Umbrella Approach to include as wide a range of processes as possible, based on the best available information available at this time.
· The Design Audit Approach to allow for inclusion within EcoPark any future processes not covered by this EIA.
· Continuous Public Involvement to ensure that the community and stakeholders are fully consulted.
6. In recent years, the Environmental Protection Department (EPD) have carried out extensive site searches for the preferred location for an EcoPark and these focused on utilising the restored closed landfill sites in Hong Kong. The factors considered in the searches included location of each site, programme of the restoration works, any committed afteruse, progress in determining the afteruse and implementation programme, potential usable area for recycling activities and compatibility with neighbouring land uses.
7. The results of the site search indicated that Pillar Point Valley Landfill, Ma Yau Tong Central Landfill, Tseung Kwan O Stage lI/III Landfill and Siu Lang Shui Landfill all had potential for accommodating materials recycling activities. However, when a 20ha piece of land in Tuen Mun Area 38 became available (because the previously proposed Fourth Industrial Estate was relocated to Tseung Kwan O), this proved to be a better location for EcoPark and became the preferred location.
8. The proposed EcoPark is situated on the outskirts of Tuen Mun, adjacent to a number of industrial premises and existing industrial uses (see Figure 1). The site is more than 2km from existing residential developments, and therefore considered to be remote from sensitive receivers.
9. The site is currently zoned “Other Specified Uses” (“OU”) and annotated “Special Industries Area” (“SIA”) on the latest approved Tuen Mun OZP No. S/TM/20. As “EcoPark” is neither a Column 1 or Column 2 use on the OZP, an amendment to the zoning is required, and this is being addressed in a parallel EcoPark Zoning Amendment Report to be submitted to the Rural and New Town Planning Committee for consideration under the Town Planning Ordinance.
10. Current uses of Tuen Mun Area 38 include Shiu Wing Steel Mill, River Trade Terminal and Construction and Demolition (C&D) Material facilities operated by the Civil Engineering and Development Department. Planned uses include the Permanent Aviation Fuel Facility (PAFF), adjacent to the northwest boundary of EcoPark, and additional C&D Material facilities. A “holiday camp” on the hillside to the north of EcoPark is also planned. All existing and planned uses are also shown on Figure 1.
11. An EcoPark is an area of land set aside for use by the environmental industry within which individual tenants can acquire a lot of land suitable for their particular recycling and environmental operation at an affordable price. The length of tenure would be sufficient to fully justify their investment in the buildings, plant and machinery necessary for their operations to be carried out in an efficient and sustainable manner.
12. A follow-on Design-and-Construct (D&C) consultancy will develop the detailed design of EcoPark and its infrastructure and this will be constructed as a Public Works project (by the Works Contractor). A Management Contractor (the Operator) will then take possession of EcoPark and manage the facility for EPD. Thus, each individual tenant will need capital investment only for the provision of his own particular requirements, although each will need to pay for use of common facilities.
approach will ensure that costs are kept to a minimum and should make EcoPark
more financially attractive to the local environmental industry.
14. Construction of EcoPark (by the Works Contractor) will likely involve the following:
· Construction of basic infrastructure, including roads, drainage, sewers, utilities, etc.
· Provision of empty, serviced lots (initially grassed, open ground) to be developed by qualifying tenants for their own use.
· Construction of an Administration Building containing management offices, a visitor centre, etc., and facilities for management of the marine frontage.
· On-site Wastewater Treatment Facility (WTF) and a waste collection facility.
· Berthing facilities (e.g. bollards, fenders) for loading/unloading at the 460m of marine frontage within the EcoPark site.
15. Operation of EcoPark (by the Operator) will likely include the following activities :
· Preparation of contractual/leasing arrangements with individual tenants and allocation of lots to tenants for their construction of recycling and environmental facilities.
· Preparation and implementation of management procedures/emergency procedures.
· Management of the marine frontage allocated to EcoPark.
· Maintenance of common infrastructure, plant, Administration Building, etc.
16. Environmental Monitoring and Audit (EM&A) and implementation of necessary mitigation measures to meet any EP conditions will be carried out by both the Works Contractor and the Operator.
17. There are a number of constraints (from existing and planned users in Area 38) to developing EcoPark and so it is intended that EcoPark will be developed in two phases. As such, Phase I must be able to operate as a self-contained facility, including all necessary components, from late-2006. It must also allow expansion into Phase II after 2009. A conceptual layout for EcoPark has been developed and is shown in Figure 2.
18. The rationale behind the conceptual design of EcoPark can be summarised in one word – “flexibility”. It is considered that flexibility in providing for a wide range of tenants, ranging from sole-proprietor operations to large companies and a wide range of processes will be paramount to the success of EcoPark and the local recycling industry.
19. The following material types were initially suggested for recycling within EcoPark :
· Organic Food Waste
· Ferrous Metals
· Non-ferrous Metals
· Rubber Tyres
· Spent Copper Etchant
20. Other material types and/or processes not initially considered in the EIA can nevertheless be considered for inclusion in EcoPark through the Design Audit process.
21. The EIA study followed the requirements of the Study Brief, which specified assessments of :
· Air Quality.
· Water Quality.
· Waste Management.
· Prevention of Land Contamination.
· Landfill Gas Hazard Assessment
· Hazard to Life.
22. Assessments were carried out under the umbrella approach, in that a wide range of recycling processes for each material type were assumed at maximum throughputs to be the “worst case”. Furthermore, under the EM&A programme, a review of each proposed process will be carried out to confirm environmental acceptability prior to the process being operated within EcoPark.
23. Quantitative air quality assessments were carried out for the construction phase, and cumulative dust impacts were identified as a key issue. Through mandatory implementation of dust control measures as required under the Air Pollution Control (Construction Dust) Regulation, it was concluded that construction dust can be controlled to within acceptable limits, and no significant impacts were anticipated.
24. Quantitative air quality assessments were also carried out for the operation phase during which emissions from recycling activities were of concern.
25. Those processes that would result in significant levels of air pollution, even when using the best available air pollution control equipment not entailing excessive cost, were identified during an initial screening of the suggested processes.
26. This initial screening identified that the use of Ultra-low Sulphur Fuel would significantly reduce sulphur dioxide emissions from fuel usage. It was also identified that inedible rendering of organic food waste (such as lard boiling) would generate very high levels of odour that could not be mitigated to acceptable levels.
27. It was further identified that the thermal processing of ferrous metals would require significantly more fuel than an equivalent quantity of non-ferrous metals, or that for the same quantity of thermal processing, ferrous metals would generate significantly more pollutants from fossil fuel burning. High fuel usage requirements for non-ferrous metal processing and paper pulping were also noted.
28. As a result of the initial screening, it was decided to mandate that Ultra-low Sulphur Fuel should be used in EcoPark and that lard boiling should be excluded from assessment.
29. It was further decided that to minimise air pollution from fossil fuel usage, thermal processing of ferrous metals should be excluded from assessment, although non-thermal processes would remain. Also, thermal processes using non-fossil fuels could be considered.
30. Three scenarios were then developed to allow modelling of the air quality impacts. These three scenario provided for a range of material throughputs to be examined.
31. The results of the modelling showed that where a wide range of materials and throughputs were allowed, there were concerns regarding air quality impacts. With a more restricted range of materials and throughputs, the air quality impacts would be reduced to acceptable levels.
32. It was concluded that the scenario that allowed the greatest range of materials and throughputs to be processed, while not causing unacceptable air quality impacts was preferred as the “base case” for future comparisons (under the Design Audit) and formed the basis for the remaining environmental assessments.
33. The construction phase water quality assessment concluded that no unacceptable impacts would arise provided that recommendations for good site practice were implemented. This included preventing uncontrolled discharges into adjacent marine waters and provision of portable toilet facilities for workers.
34. The operation phase assessment focused on the provision of the WTF to treat all industrial wastewater generated by tenants to the standard required for discharge into a sewer leading to a treatment works – in this case, Pillar Point Sewage Treatment Works (STW). It was proposed that “domestic” wastewater should be collected in a separate sewerage system and sent to Pillar Point STW directly for treatment.
35. The design capacity of the WTF was estimated with a variable quality of influent (depending on recycling processes being carried out) and with high chemical oxygen demand and heavy metals. It was further noted that some tenants may need to install their own pre-treatment plants if their process wastewater could not meet the influent limits of the WTF.
36. Other key water quality design features are the provision of stop-logs/interceptors in the surface water drainage system to prevent any spilled materials from entering the surface water system. These features were also recommended for the marine frontage area to minimise contamination of the sea during loading and unloading of materials.
37. Overall, it was concluded that the provision of the WTF would be a key factor in reducing water pollution to an acceptable level, and that regular monitoring would ensure compliance with conditions of the WTF Discharge Licence issued under the Water Pollution Control Ordinance.
38. The construction phase waste assessment concluded that the EcoPark design could achieve, as a minimum, a balanced “cut and fill”, i.e., there would be no surplus C&D Materials requiring off-site disposal. Furthermore, EcoPark could be designed to be a net importer of C&D materials through the construction of landscape features, thereby reducing the stockpiles of C&D Materials, e.g. at the adjacent Fill Bank.
39. The operation phase waste assessment focused on the four main sources of waste that would arise, namely, waste from recycling activities, chemical waste arising from maintenance of plant and equipment, sewage sludge (from the WTF) and general daily waste from EcoPark operations.
40. It was concluded that while recycling activities would generate some solid waste requiring off-site treatment, much more waste would be diverted from landfill to EcoPark for processing. As such, the operation of EcoPark can help to extend the operational life of the existing landfills. Furthermore, this net reduction in waste disposal translates into a significant cost saving to Government through reduced disposal costs. Overall, therefore, EcoPark provides a very positive environmental benefit in waste management terms and is also a more sustainable approach.
41. To ensure that land does not become contaminated during the operation of EcoPark, a number of design features were proposed, such as the use of concrete hardstanding in those areas where activities considered to be potentially contaminating (in the event of an accident) would be carried out.
42. Furthermore, a series of good practice recommendations were made, particularly for chemical wastes, to prevent land contamination during operations.
43. The EcoPark site lies within 250m of Siu Lang Shui Landfill and so a LFG Hazard assessment is required. A qualitative source-target-pathway approach was used and concluded that the risk to EcoPark from LFG was low. As such, a number of precautionary measures were suggested for the design, construction and operation.
44. Based on the range of processes to be carried out, a number of substances were identified that may pose a potential risk during storage or transportation.
45. The hazards posed by each of these substances, and also by liquid fuels, were examined and an assessment of the likely off-site risks was made. Given the safety and mitigation measures suggested, the off-site risk for each substance was determined to be negligible.
46. It was noted that there was the potential for risk from a fire at the adjacent PAFF to any multi-storey EcoPark buildings close to the PAFF boundary. To address this issue, it was proposed to limit building heights (and thereby risks to workers) within EcoPark along the boundary with the PAFF.
47. An EM&A programme has been proposed that relies heavily on auditing of activities within EcoPark.
48. The EM&A programme also requires an Environmental Management Plan to be implemented by the Works Contractor and Operator and for an Emergency Response Plan to be developed by the Operator.
49. During construction, regular site inspections and reporting provide the means to ensure that the Works Contractor is meeting the environmental conditions specified in the Implementation Schedule and any conditions specified in the EP.
50. During operation, and in addition to regular reporting, the Process Review approach (including the Design Audit where required) has been adopted to ensure that all recycling processes within EcoPark have been individually confirmed to be acceptable, with environmental impacts/risks no greater than those assessed in this EIA.
51. The purpose of the Design Audit is to confirm that all new processes to be operated within EcoPark comply with the conditions of the EP and to ensure that the recommendations of the EIA are met in full.
52. This is achieved by comparison of impacts from the proposed process with those assessed in the EIA. Where environmental impacts/risks from proposed processes are not greater than those assessed in the EIA, the process is approved for operation within EcoPark. If impacts/risks are greater than those assessed under the EIA, then the Operator’s ET shall :
· Propose modifications to the intended process such that the impacts/risks are avoided, e.g. through adoption of cleaner technology, not using chemicals, etc.
· Propose mitigation to reduce impacts/ risks to a level no greater than that assessed in the EIA. Such mitigation may include better air pollution control equipment, wastewater pre-treatment, provision of hardstanding and/or shelters, improved material safety/handling, etc.
53. If none of the above options can satisfy the IEC or EPD that the impacts/risks from the process are acceptable, then that process will not be allowed in EcoPark.
54. Furthermore, by considering environmental impacts/risks of each process in this holistic manner, through the design audit, the Operator shall develop EcoPark as a single, integrated facility, rather than simply as a collection of disparate recycling operations, and in so doing will assess the cumulative impact of operations.
55. In seeking to develop environmentally friendly designs for EcoPark, and thereby minimising the environmental impacts of EcoPark itself, the EIA has demonstrated the benefits of applying the EIA process under the EIAO. This is shown in the modifications to the design resulting from the environmental assessment and from the consultations held throughout the EIA preparation with key stakeholders.
56. The environmental benefits of EcoPark are fourfold. Firstly, where operators have relocated to EcoPark there will be an immediate benefit experienced by the local population and the immediate environment at former sites of informal waste recycling.
57. Secondly, within EcoPark, processes that would result in the generation of unacceptable levels of air pollutants have been excluded on environmental grounds. The provision of key infrastructure, such as the stop-logs within perimeter lot drainage and the WTF, will also ensure no unacceptable levels of water pollution from wastewater generated within EcoPark.
58. Thirdly, within the controlled environment of EcoPark, all processes will comply with air quality and water quality objectives, thereby resulting in an overall net reduction in environmental pollution, compared to that generated by the existing uncontrolled recycling activities carried out elsewhere in Hong Kong. This will be further demonstrated and confirmed in the Design Audit to be carried out for new processes.
59. Finally, the synergy between the operations of the various tenants will result in waste reduction and the enhanced recovery of materials for on-site/off-site re-manufacture.
60. In conclusion, the development of the EcoPark in Area 38 will fulfill the vision made in the 2005 Policy Address in that long-term land at an affordable price will be provided to encourage the recycling and environmental industry in Hong Kong. The waste will be managed in a more sustainable way and, as a result, not only will the environment be protected, but the local economy will also be stimulated through job creation.