6.                   LAND CONTAMINATION

Introduction

6.1               Potentially contaminated areas have been identified at the existing Hong Kong School of Motoring (HKSM) and City Bus Depot (CBD). As recommended in the EIA report, site investigation shall be carried out to determine the presence and extent of contamination before the construction works take place at the concerned areas. The contamination assessment shall be carried out in accordance with EPD’s ProPECC PN3/94 “Contaminated Land Assessment and Remediation” and “Guidance Notes for Investigation and Remediation of Contaminated Sites of Petrol Filling Stations, Boatyards, and Car Repair / Dismantling Workshops”. 

6.2               The contaminated sites shall be remediated before commencement of any construction work at the concerned sites which may disturb the ground. The duration of remediation shall be taken into account by the Project Proponent or the Contractor as part of the construction programme. In all cases, contaminated soil remediation, treatment or disposal must be managed in an environmentally sound manner, including compliance with all relevant legislation and Government requirements.

Land Contamination Assessment

6.3               For CBD site, the SI has been undertaken from 31 March to 3 April 2006. The results indicated that heavy metals and Total Petroleum Hydrocarbon (TPH) exceedances were found in 7 sampling locations.

6.4               A Remediation Action Plan (RAP) has been prepared which essentially recommends removal of the underground tanks and any local soil contamination around them as well as replacing the removed material with clean in-fill.  Considering the estimated contaminated soil volume is ~150m3, such soil is recommended to be excavated and disposed of at EPD’s designated landfill site.

6.5               For the soil with elevated level of heavy metals, Toxicity Characteristic Leaching Procedure (TCLP) test will be conducted as a further study in order to determine the leachability (hence the toxic risk) of the soil at the CBD Site. For a conservative approach, the clean-up strategy (i.e. cement solidification/stabilisation treatment) has been proposed for the soil contaminated with arsenic/tin in the RAP.

6.6               For HKSM site, the Contamination Assessment Plan (CAP) which proposed 10 sampling locations for site investigation (SI) has been prepared under this EIA for an illustrative purpose. The party responsible for the SI at the HKSM site in the future would need to separately submit a CAP and Contamination Assessment Report (CAR) (and Remediation Action Plan (RAP), if necessary) to EPD for their approval. 

6.7               The CAR should be prepared to document the findings of the site investigation for the HKSM Site. Interpretation of laboratory testing results in accordance with the ProPECC Note No. 3/94 and comparison of the findings with relevant standards, such as the ‘Dutch B’ levels in the Dutch guidelines or other international practices as appropriate shall be also included in the CAR.

6.8               If land contamination is confirmed, a RAP should be prepared and drawn up to formulate necessary remedial measures. The subsequent CAR and RAP should be endorsed by EPD before implementation of any remediation works. Any necessary actions to be carried out at these sites would be the responsibility of the current site user or responsible parties.

6.9               In the event that the current users or responsible parties of the HKSM Site do not fulfil its obligations to undertake a CAP, CAR or RAP or the necessary remediation to the satisfaction EPD, and the site handed-over to OPC is not totally cleaned (for technical or other reasons), then the whole HKSM site will initially be fenced off and the suspected contaminated area will be fully demarcated and isolated. The purpose of fencing the site is to restrict access to ensure there would be no risk to the general public.  Following this, OPC undertakes to carry out, to the extent outstanding, the site investigation. Such an undertaking does not relieve the existing users of their obligations to clean the site, nor does it in any way restrict OPC’s rights to recover the costs of carrying out the SI works from the responsible parties.  

6.10            Once the SI results are available, the potential contaminated area could be identified and the fenced-off area could be adjusted to isolate only the area of contamination. OPC would ensure that no work would be undertaken within the fenced off area. OPC would modify the design of the new entry plaza and access road so as to accommodate this fenced off area in its layout and to limit access to, as well as circulation around it.

Mitigation Measures during Construction Stage

6.11            It is expected that any identified contaminated land would be remediated to the acceptable standards prior to site clearance/excavation works. Therefore, no significant impact in relation to land contamination would be expected. However, as a precaution, mitigation measures are recommended to minimise the potentially adverse effects on the health and safety of construction workers and the impacts arising from the disposal of potentially contaminated materials. These measures include, but are not limited to, the following:

l            Construction workers’ potential contact with contaminated materials should be minimised by using bulk earth-moving excavator equipment;

l            Exposure to any contaminated materials should be minimised by wearing appropriate clothing and personal protective equipment such as gloves and masks (when interacting directly with suspected contaminated material), providing adequate hygiene and washing facilities and preventing smoking and eating during such activities;

l            Stockpiling of contaminated excavated materials on site should be avoided as far as possible;

l            The use of contaminated soil for landscaping should be prohibited unless there is proper treatment of soil;

l            Vehicles containing any excavated materials should be suitably covered to limit potential dust emissions or contaminated wastewater run-off, and truck bodies and tailgates should be sealed to prevent any discharge during transport or during wet conditions;

l            Only licensed waste haulers should be used to collect and transport any contaminated material to an appropriate treatment/disposal site and procedures should be developed to ensure that illegal disposal of waste does not occur;

l            Speed control for the trucks carrying contaminated materials should be enforced;

l            The necessary waste disposal permits should be obtained, as required, from the appropriate authorities, in accordance with the Waste Disposal Ordinance (Cap 354), Waste Disposal (Chemical Waste) (General) Regulation (Cap 35), as required;

l            Records of the quantities of wastes generated and disposed of should be maintained; and

l            In accordance with good construction practice, silt traps should be used to reduce the impact to drainage caused by suspended solids arising from disturbed ground, or any construction materials such as cement and gravel. Wastewater, surface runoff or extracted groundwater should be disposed of in accordance with the WPCO.

Mitigation Measures for Remediation Process

6.12            The following mitigation measures are proposed for biopiling and cement solidification/stabilisation processes (applicable to both Tai Shue Wan and the open space near the rest garden) which are the possible remediation actions in the unlikely event of significant contamination found. 

 

Air Quality Impact

 

l            Biopile should be covered by tarpaulin or low permeable sheet to avoid dust emission;

l            Vented air from biopile should be connected to blower and carbon adsorption system for treatment before release to the atmosphere. Exhaust air from the blower and carbon adsorption system should be monitored regularly;

l            The materials which may generate airborne dust emissions e.g. untreated contaminated soil  should be adequately wetted prior to and during the loading, unloading and handling operations;

 

Noise Impact

 

l            Silencers should be installed at biopile blower to minimise noise impact;

l            Quiet plant shall be used for biopile treatment such as generator, blower, etc.

 

Water Quality Impact

 

l            Impermeable liners should be placed at the bottom of biopile and leachate collection sump should be constructed along the perimeter of biopile to minimise contaminated run-off.  The leachate should be recycled back to the biopile or trucked away to Chemical Wastes Treatment Centre for disposal;

l            Mixing of contaminated soils and cement/water/other additive(s) should be undertaken at a solidification plant to minimise the potential for leaching;

l            Run-off from the solidification/stabilisation area should be prevented by constructing a concrete bund along the perimeter;

 

Waste

 

l            The loading, unloading, handling, transfer and storage of cement should be carried out in an enclosed system;

l            The contaminated soils should be transported by roll-off trucks (containerisation).  This provides the most effective way to control the handling of contaminated soil and minimise the chance of spillage/ leakage during transportation.

l            Mixing process and other associated material handling activities should be properly scheduled to minimise potential noise impact.

 

Visual Impact

 

l            Temporary hoarding should be provided around the treatment area in order to minimize the visual impact.

6.13            The implementation for the recommended land contamination mitigation measures is presented in Appendix B.