4 Waste management

Introduction

4.1 Waste management issues associated with the Project will be related to the demolition of existing crematorium as well as the construction and operation of the new crematorium. This section identifies the possible waste arisings from the Project, evaluates the potential environmental impacts associated with the handling, collection, treatment, transportation and disposal of waste and recommends appropriate mitigation measures and good site practice to minimize the identified environmental impacts.

Environmental Legislation, Policies, Plans, Standards and Criteria

Environmental Legislation

4.2 Annexes 7 and 15 of the Technical Memorandum on Environmental Impact Assessment Process correspondingly sets out the Criteria and Guidelines for evaluating and assessing the Waste Management Implications arising from the Project.

4.3 The following legislations cover the handling, treatment and disposal of waste in the Hong Kong Special Administration Region (HKSAR), and have been considered in the assessment.

· Waste Disposal Ordinance (Cap. 354) and subsidiary Regulations;

· Land (Miscellaneous Provisions) Ordinance (Cap. 28); and

· Public Health and Municipal Services Ordinance (Cap.132)

Environmental Guideline

4.4 Other guideline documents that detail how the contractor should comply with the regulations are as follows:

· A Guide to the Registration of Chemical Waste Producers, Environmental Protection Department, Hong Kong;

· A Guide to the Chemical Waste Control Scheme, Environmental Protection Department, Hong Kong;

· Ch9 Environment (2007), Hong Kong Planning and Standards Guidelines, Hong Kong Government;

· Code of Practice on Packaging, Labelling and Storage of Chemical Wastes (1992), Environmental Protection Department;

· Code of Practice on the Handling, Transportation and Disposal of Asbestos Waste (1993) Environmental Protection Department;

· Code of Practice on Asbestos Control: Asbestos Work Using Full Containment or Mini Containment Method (1997) Environmental Protection Department;

· Code of Practice on Asbestos Control: Asbestos Work Using Glove Bag Method;

· Code of Practice on Asbestos Control: Safe Handling of Low Risk Asbestos Containing Materials (1997) Environmental Protection Department;

· Code of Practice on Asbestos Control: Preparation of Asbestos Investigation Report, Asbestos Management Plan and Asbestos Abatement Plan (1997) Environmental Protection Department;

· ProPECC PN2/97 Handling of Asbestos Containing Materials in Buildings;

· Guidance Note for Contaminated Land Assessment and Remediation (2007) Environmental Protection Department;

· Works Branch Technical Circular 32/92, The Use of Tropical Hard Wood on Construction Sites; Works Branch, Hong Kong Government;

· Works Branch Technical Circular No. 2/93, Public Dumps;

· Works Branch Technical Circular No. 2/93B, Public Filling Facilities

· Works Branch Technical Circular No.16/96, Wet Soil in Public Dumps;

· Works Bureau Technical Circular No.4/98 & 4/98A, Use of Public Fill in Reclamation and Earth Filling Projects;

· Works Branch Technical Circular No. 19/2001, Metallic Site Hoardings and Signboards;

· Works Bureau Technical Circular No.33/2002, Management of Construction / Demolition Materials including Rock;

· Works Bureau Technical Circular No.31/2004, Trip-ticket System for Disposal of Construction and Demolition Materials; and

· Works Bureau Technical Circular No.19/2005, Environmental Management on Construction Sites.

Project Description

4.5 The project site is the site of the existing Cape Collinson Crematorium which consists of twelve cremators with four service halls. According to current available information, it was first put to use in 1962 with several alterations and development hereafter.

4.6 Cape Collinson Crematorium is located at Cape Collinson Road, Chai Wan and surrounded by woodland area of Shek O Country Park and Tai Tam Country Park. This is a valley formed by Mount Collinson and Mount Parker.

4.7 The new crematorium will be constructed in two phases. Site formation work will be carried out at the beginning of Phase 1. After the site formation has been completed, a new crematorium with 4 cremators and 2 service halls will be constructed to the north of the existing crematorium. During this period, all the 12 cremators in the existing crematorium will remain in operation until the satisfactory commissioning of the new cremators under Phase 1 by 2012.

4.8 After the satisfactory commissioning of the new cremators under Phase 1, demolition of the existing crematorium as well as the construction of another 6 cremators and 1 service hall will then be carried out in Phase 2. The total installed capacity of 4 cremators in Phase 1 and 6 cremators in Phase 2 will be approximately 583 kg/hour and 943 kg/hour, respectively.

Assessment Methodology

4.9 The assessment of waste management impacts arising from this Project during construction phase and operation phase is made in accordance with the EIA Study Brief and criteria given in Annexes 7 and 15 of the EIA Technical Memorandum.

4.10 Waste generation reduction methods have been assessed based upon the following:

· Avoiding or minimizing waste generation through out the design stage;

· Segregation of waste materials would be promoted and consider as better management practices;

· Reuse and recycling; and

· Waste diversion to public fill or other construction site

4.11 Types and quantities of waste have been estimated and disposal options have been identified. Estimation of existing and future capacities of waste disposal facilities and the environmental implication on handling, collection and disposal of waste materials have also been taken into account.

4.12 The assessment includes:

· Construction and Demolition phase waste generation analysis

- Excavated materials and Construction & Demolition (C&D) materials from site formation

- Contaminated materials

- Chemical waste from plants and equipment maintenance

- General waste from daily activities

· Operation phase waste generation analysis

- Waste generation from cremation process

- Waste generation from maintenance of plant and equipment

- General waste from daily activities

· Proposals on waste management during construction and operation phases for respective sources of waste in terms of:

- Reduction, reuse and recycling

- Disposal options

- Impacts and mitigation measures

· Impacts caused by handling, collection and disposal of waste, in terms of

- Potential hazards

- Air and odour emissions

- Noise

- Wastewater discharge

- Public transport

Identification of Environmental Impacts

Activities and Waste Generation for Construction and Demolition Phase

4.13 Based on the tentative construction and demolition programme, construction site activities will be divided into two phases: Phase 1 – July 2010 to March 2012 and Phase 2 – March 2012 to December 2014. Due to high demand for cremation service, all the twelve cremators in the existing crematorium will remain in operation during the construction of Phase 1 until full operation of four new cremators with total capacity of 583 kg/hour and other main facilities to be provided under Phase 1 of the Project.

4.14 The following types of waste will be generated from the construction and / or demolition works during Phase 1 and Phase 2:

· Phase 1

- Excavated materials;

- Construction and demolition (C&D) waste materials;

- Chemical waste; and

- General refuse

· Phase 2

- Excavated materials;

- Construction and demolition (C&D) waste materials;

- Contaminated materials including ash waste, building structure and contaminated soil;

- Chemical waste; and

- General refuse

4.15 Waste from construction and demolition phase may cause environmental impact and nuisance if handling and disposal methods are not properly managed. The potential impacts and the mitigation measures have been discussed and proposed in Sections 4.18 to 4.47 and Sections 4.58 to 4.85, respectively.

Activities and Waste Generation for Operation Phase

4.16 During the operation phase of the new crematorium, major types of waste to be generated are as follows

· Bone Ash and non-combustible residues generated by cremators during the combustion process of the cremators;

· Chemical waste generated from plant, equipment and machinery maintenance and servicing;

· Fly ash generated from the air pollution system; and

· General refuse generated by the visitors and staff during daily operation.

4.17 Potential impacts and mitigation measures have been discussed and proposed in Sections 4.48 to 4.57 and Sections 4.86 to 4.103, respectively.

Prediction and Evaluation of Environmental Impacts for Construction and Demolition Phase

Excavated Materials from Phases 1 and 2

4.18 For construction works during two phases, excavated materials will be generated from site formation and foundation works for new crematorium. As advised by ArchSD, approximately 14,300m³ and 27,000m³ of excavated materials will be generated from Phase 1 and Phase 2, respectively. The excavated materials to be reused on site are estimated to be 720m³ and 1,350m³ for Phase 1 and Phase 2 respectively.

4.19 With careful planning for reusing excavated materials on site, secondary environmental impacts and potential impacts on waste handling is expected to be minimal.

Construction and Demolition (C&D) Materials from Phases 1 and 2

4.20 C&D materials can be divided into two portions, namely inert materials portion such as rock, concrete which can be used as fill materials and also non-inert materials portion including timber, glass, steel and plastic is termed C&D waste. Some C&D waste can be reused or recycled prior to disposal at landfill site.

4.21 During Phases 1 and 2, the following C&D materials will be generated:

· Timber from formwork and falsework;

· Existing crematorium structure from Phase 2 such as concrete, rock, steel, bricks, glass, wood and plastic;

· Materials and equipment wrappings;

· Unusable / surplus concrete or grouting mixes

4.22 According to the information provided by ArchSD, approximately 15,830m³and 42,440m³ of C&D materials will be generated from Phase 1 and Phase 2, respectively. A more detailed account of C&D material generation will be provided in the Waste Management Plan to be prepared by the Contractor.

4.23 As advised by ArchSD, the quantities of C&D materials to be reused, delivered to public fill and disposed of at landfill have been estimated as shown in Table 4.1.

Table 4.1 Estimated Quantity of C&D materials to be Generated, Reused and Disposed Of

	Estimated Quantity of C&D Materials (m³)
	Phase 1	Phase 2
C&D Materials Generated	1,530	15,440
Reuse on Site	0	580
Deliver to Public Fill	720	12,850
Dispose of at Landfill	810	2,010

4.24 The project proponent would obtain an advance agreement from the Public Fill Committee to ensure the availability and capacity of public fill facility for disposal of the anticipated amount of C&D materials.

4.25 Provided that waste management practices as detailed in Sections 4.58 to 4.66 are properly implemented, the secondary environmental impacts arising from on-site handling of the C&D materials would be minimal.

Contaminated Materials from Phase 2

4.26 According to the construction schedule, all twelve cremators in the existing crematorium would remain in operation and no demolition works will be carried out during Phase 1.

4.27 Also, based on the findings from Asbestos Investigation Report (April 2008) and Contaminated Assessment Plan (March 2008), all identified asbestos containing materials are located in the existing crematorium building and no heavy metals and dioxin containing surface soil was found in Phase 1 works area. Under this consideration, no contaminated materials is anticipated during the Phase 1 construction.

4.28 Contaminated materials are expected to be generated during Phase 2 construction and demolition works. The key types of contaminated materials will include:

· Asbestos containing materials (ACM) – likely from existing building structure;

· Dioxin containing materials (DCM) – likely from ash waste and contaminated subsurface soil;

· Potential Contaminated Soil.[1]

4.29 All the above contaminated materials are classified as chemical waste under the Waste Disposal (Chemical Waste)(General) Regulation. Asbestos is classified as a special waste.

4.30 The contaminated materials are expected to be accumulated around cremators, flues and chimneys. Since the existing crematorium is in operation and these areas are not accessible, thus no sampling is carried out at this stage.

Asbestos Containing Materials (ACM) from Phase 2

4.31 According to the Asbestos Investigation Report (see Appendix 3.3), asbestos investigation has been carried out at assessable areas of the existing crematorium by a registered asbestos consultant. The asbestos survey revealed the presence of ACM. Asbestos gasket (woven) and insulation sheet were identified during the survey. ACM has not been found in the six columbarium blocks and car park area.

4.32 External structure of the crematorium main building and cremator at Hindu Service Hall were inspected by the survey team. However, all the pipelines concealed inside the wall were not available for this inspection. Moreover, flange connection was covered by a metal cover, which was also inaccessible for inspection.

4.33 Re-inspection of the inaccessible area will be undertaken prior to demolition works. Due to low friability nature and good condition of ACM, potential hazard is relatively low which subsequently will not impose health hazard to occupier.

4.34 Environmental impacts associated with ACM are anticipated to be minimal, provided that the mitigation measures are implemented.

Dioxin Containing Materials (DCM) from Demolition of Existing Crematorium during Phase 2

4.35 Since the cremators are still in operation, it is not possible to carry out site investigation inside the cremation rooms at this stage. Further site inspection is recommended to be carried out after decommissioning and prior to the demolition of the existing crematorium. A DCM Assessment Plan shall be prepared for EPD endorsement to present detailed sampling and testing plan. Findings of site investigation and appropriate remediation methods will be presented in DCM Assessment Report for EPD endorsement prior to the commencement of any earthworks.

4.36 With reference to the approved EIA Study for Provision of Cremators at Wo Hop Shek Crematorium, it is not anticipated that large amount of contaminated materials will be present, as these materials will only be found with the residual ash waste inside the cremators, flue and chimneys. Through appropriate handling, treatment and disposal of contaminated ash waste, the associated environmental impact is expected to be minimal.

Dioxin Containing Materials (DCM) / Total Petroleum Hydrocarbon Containing Materials (TPHCM) from Subsurface Soil at Phase 2 Project Site

4.37 The Contamination Assessment Plan and Contamination Assessment Report / Remediation Action Plan have been presented in Appendix 5.1 and Appendix 5.2, respectively.

4.38 Ten soil samples were collected from four boreholes for contamination assessment around the underground fuel tank system, while five surface soil samples were collected for laboratory analysis for surface deposition contamination assessment. The results indicated that no detectable VOCs or TPHs was reported and only 1 soil sample (BH-1, 1.5 – 1.95m bcl) was found exceeding the relevant RBRG for lead. The amount of contaminated soil required for remediation is estimated to be ~38m³. Appropriate remediation methods have been identified in Remediation Action Plan (see Appendix 5.2). There was no groundwater encountered at all boreholes, therefore, no groundwater sample was collected.

4.39 Further site investigation underneath the pipeline (TP-1) will be carried out before the Phase 2 demolition works of the exiting cremators. A supplementary Contamination Assessment Report will be prepared to present the findings of further site investigation for EPD’s approval. If contamination is found, supplementary Remediation Action Plan will be submitted to EPD and all contaminated soils will be treated prior to the commencement of any construction works.

4.40 With appropriate handling, treatment and disposal of contaminated subsurface soil around existing building structure, the associated environmental impact is expected to be minimal.

Chemical Waste from Phases 1 and 2

4.41 During the construction and demolition works, construction plant and equipment will require regular maintenance and servicing, which will generate chemical waste such as cleaning fluids, solvents and lubrication oil.

4.42 Chemical waste is likely to pose serious environmental, health and safety hazards if it is not properly managed in accordance with the Waste Disposal (Chemical Waste) (General) Regulation and the Code of Practice on Packaging, Labelling and Storage of Chemical Waste. These hazards may include:

· Toxic effects to workers;

· Adverse effects on water quality from spill; and

· Fire hazards

4.43 The majority of chemical waste generated from the construction and demolition works of the Project is anticipated during Phases 1 and 2. Should any chemical waste be generated, the Contractor must register with EPD as a chemical waste producer. These types of waste will be readily accepted for disposal at the Chemical Waste Treatment Centre (CWTC) at Tsing Yi. A detailed account of chemical waste generation should be provided by the Contractor during preparation of the site Waste Management Plan.

4.44 The potential environmental impacts associated with the storage, handling and disposal of the chemical waste will be minimal provided that the relevant mitigation measures in Sections 4.81 to 4.83 are implemented.

General Refuse from Phases 1 and 2

4.45 Generation of general refuse is anticipated by resident site staff during construction and demolition phases. General refuse include food waste, plastic bottles, aluminium cans and waste paper. Storage of general refuse on site will generate adverse environmental impacts. These include water quality (if waste enters nearby water bodies) contamination; odour nuisance and visual impact if waste is stored on site without frequent collection for disposal. The site may also attract pests and vermin if waste storage areas are not well maintained and cleaned up regularly. The amount of general refuse generated by the site staffs during construction and demolition activities is expected to be insignificant.

4.46 The potential environmental impacts will be insignificant provided that the mitigation measures and good site practices in Sections 4.84 to 4.85 are implemented.

4.47 Table 4.2 provides a summary of the various waste types likely to be generated from construction and demolition works during Phase 1 and Phase 2 for the Project, together with the recommended disposal methods.

Table 4.2 ⁽¹⁾ Summary of Recommended Disposal Routes from C&D Works During Phase 1 and Phase 2

	Waste Material Type	Generated from works item	Total Quantity Generated	Quantity to be disposed of	Recommended Disposal Outlets
Phase 1	Excavated materials	Formation and foundation works	14,300m³	720m³	Reuse on site as far as practicable
				13,580m³	Public fill reception facility
	C&D materials		1,530m³	720m³	Reuse and recycle as much as possible before disposal at public fill reception facility
	C&D materials		1,530m³	810m³	Reuse and recycle as much as possible before disposal at landfill
	Chemical waste	Cleaning fluids, solvents and lubrication oil	Small	Small	Recycle by licensed facility or disposal at CWTC
	General refuse	Resident site staff (food waste, plastic bottles, aluminium cans and waste paper)	Insignificant	Insignificant	Reuse or recycle as much as possible before disposal at landfill
Phase 2	Excavated materials	Formation and foundation works	27,000m³	1,350m³	Reuse on site as far as practicable
				25,650m³	Public fill reception facility
	C&D materials		15,440m³	12,850m³	Reuse and recycle as much as possible before disposal at public fill reception facility
				2,010m³	Reuse and recycle as much as possible before disposal at landfill
				580m³	Reuse on site as far as practicable
	ACM²	Demolition	-	-	Follow the code of Practice on the Handling, Transportation and Disposal of Asbestos to dispose of at landfill
	DCM ⁽²⁾ (Low contaminated)	Demolition	-	-	Disposal at landfill
	DCM ⁽²⁾ (Moderately contaminated)	Demolition	-	-	Disposal at landfill with CWTC as fallback option
	DCM ⁽²⁾ (Severely contaminated)	Demolition	-	-	Disposal at CWTC where it will be incinerated and the residue will be disposed of at landfill
	DCM/TPHCM containing subsurface soil ⁽²⁾	Demolition	-	-	Disposal at landfill with CWTC as fallback option
	Chemical waste	Cleaning fluids, solvents and lubrication oil	Small	Small	Recycle by licensed facility or disposal at CWTC
	General refuse	Resident site staff (food waste, plastic bottles, aluminium cans and waste paper)	Insignificant	Insignificant	Reuse or recycle as much as possible before disposal at landfill

Note 1: Prior to the wastes (shown in Table 4.2) can be properly disposed of in future, Project Proponent or their representatives are still required to demonstrate all their proposed disposal outlets can fulfill the specific requirements to be given by the relevant reception authorities e.g CWTC or Landfill Authority, etc.

Note 2: Since the existing crematorium is still under operation, the respective estimated volumes for ACM,,DCM and DCM/TPHCM containing subsurface soil will be determined once the plant is decommissioned.

Prediction and Evaluation of Environmental Impacts for Operation Phase

Bone Ash and Non-combustible Residues from Operation Phase

4.48 Remains after cremation include bone ash and non-combustible residues. According to the information provided by FEHD, the average weights of bone ash and non-combustible residues after each cremation are about 1.6kg and 2.0kg, respectively. Estimated quantities are provided in Table 4.3 and the maximum generation of bone ash and non-combustible residues per day are 233.6kg and 292kg, respectively.

Table 4.3 Maximum Quantity of Bone Ash and Non-combustible Residues

Number of Cremators	No. of Cremations per day	Bone Ash, 1.6kg per Cremation (kg/day)	Non-combustible 2kg per Cremation (kg/day)
10	14.6	233.6	292.0

4.49 Bone ash is stored in covered container to be collected by the deceased’s relatives within 2 months and non-combustible residues is collected in polyethylene bags and disposed of at landfill. Therefore, only small quantity of waste will require disposal.

4.50 The associated environmental impacts will be minimal provided that the mitigation measures in Sections 4.86 to 4.87 are implemented.

Chemical Waste from Operation Phase

4.51 A small amount of chemical waste in the form of cleaning fluids, solvents, lubrication oil and fuel would be generated during regular maintenance and servicing of transformer, switch room and hydraulic lifts.

4.52 Chemical waste is likely to pose a serious environmental, health and safety hazard if it is not properly managed in accordance with the Waste Disposal (Chemical Waste)(General) Regulation and the Code of Practice on Packaging, Labelling and Storage of Chemical Wastes.

4.53 Should any chemical waste be generated, the Operator must register with EPD as a chemical waste producer. The chemical wastes will be readily accepted for disposal at the Chemical Waste Treatment Centre (CWTC) at Tsing Yi. These chemical wastes should be collected in drum-type containers by licensed chemical waste collector periodically. With proper storage, handling and disposal of small amount chemical waste, adverse environmental impacts are not anticipated.

Fly Ash from Operation Phase

4.54 Fly ash consists of used activated carbon, un-reacted lime and collected particulate matter, it solidifies while suspended in the exhaust gases and is collected by electrostatic precipitators or filter bags, which form part of the Air Pollution Control (APC) equipment.

4.55 According to the information provided by FEHD, the estimated volume of particulate matter is 76 kg per day and activated carbon / un-reacted lime is 18 kg per day.

General Refuse from Operation Phase

4.56 Quantity of general refuse generated by visitors and staff during daily operation of the new crematorium will not be substantial with the proper waste management facilities. It is expected that the potential environmental impacts arising from the handling and disposal of the general refuse will be negligible and will not cause any major environmental concerns.

4.57 Table 4.4 provides a summary of the various waste types likely to be generated during Operation Phase for the Project, together with the recommended disposal methods.

Table 4.4 Summary of Recommended Disposal Routes During Operation Phase

Waste Material Type	Generated from works item	Total Quantity Generated	Quantity to be disposed of	Recommended Disposal Outlets
Bone Ash	During combustion process of cremation	233.6 kg/day		Stored in covered container to be collected by the deceased’s relatives
Non-combustible residues	During combustion process of cremation	292.0 kg/day	Small	Collected in polyethylene bags and disposal of at landfill
Chemical waste	From plant, equipment and machinery maintenance and servicing	Small	Small	Recycle at licensed facility or disposal at CWTC
Fly ash	During combustion process of cremation	76kg/day (Particulate matter); 18kg/day (Activated carbon/un-reacted lime)		Store the fly ash in sealed drums which are taken to CWTC for further treatment and the residue will be disposed of at landfill
General refuse	Visitors and staff	Small	Small	Reuse and recycle as much as possible before disposal at landfill

Note: Prior to the waste (shown in Table 4.4) can be properly disposed of in future, Project Proponent or their representatives are still required to demonstrate all their proposed disposal outlets can fulfill the specific requirements to be given by the relevant reception authorities e.g CWTC or Landfill Authority, etc.

Mitigation of Adverse Environmental Impacts for Construction and Demolition Phase

General – Good Site Practice and Waste Reduction Measures

4.58 Adverse environmental impacts due to waste generation are not expected. The following recommendations should be implemented during the construction activities:

· Obtain relevant waste disposal permits from the appropriate authorities, in accordance with the Waste Disposal Ordinance (Cap. 354), Waste Disposal (Chemical Waste)(General) Regulation (Cap. 354), Waste Disposal (Charges for Disposal of Construction Waste) Regulation (Cap 345) and the Land (Miscellaneous Provision) Ordinance (Cap.28)

· Prepare a Waste Management Plan approved by the Engineer / Supervising Officer of the Project based on current best practice on Construction Sites

· Waste licensed collector to collect waste

· Implementation of trip ticket system with reference to ETWB(W) No.31/2004 Trip Ticket System for Disposal of Construction & Demolition Materials.

· Provide staff training for proper waste management and chemical waste handling procedures

· Separation of chemical waste for special handling and dispose to licensed facility for treatment

· Sufficient waste disposal points and regular collection programme setup

· Recording system for waste generation, recycle and disposal

4.59 The ETWB TCW No.19/2005 “Environmental Management on Construction” includes procedures on waste management requiring contractors to reduce the C&D material to be disposed of during the course of construction. Under this ETWB TCW No.19/2005, the Contractor is required to prepare and implement an Environmental Management Plan (EMP) and the Waste Management Plan (WMP) becomes part of the EMP.

4.60 Waste reduction should be considered in planning and design stage, the following practice should be implemented.

· Prior to disposal of C&D waste, wood, steel and other materials should be separated for reuse, recycling to minimize the quality of waste to be disposed of at landfill.

· Minimize use of wood and reuse non-timber formwork to reduce C&D waste

· As far as practicable, segregate and store different types of waste in different containers, skips or stockpiles to enhance reuse or recycling of materials and their proper disposal.

· Encourage collection of aluminum cans, plastic bottles and packaging material and office paper.

Excavated Materials

4.61 Rock and soil generated from excavation should be reused during site formation and landscaping as far as practicable to reduce total amount to be disposed of off-site.

4.62 Trip-ticket system should be implemented for surplus excavated materials disposal in accordance with ETWB TC(W) No.31/2004 and the Construction Waste Disposal Charging Scheme. Waste should be delivered to a public fill reception facility. Copies or counterfoils of trip tickets will be kept for record purpose.

Construction and Demolition Materials

4.63 Well-planned design and good site management can minimize over-loading and generation of waste materials such as concrete and cement grouts. Wooden frame should be replaced by metals. Plastic fencing and reusable site office structure can reduce C&D waste generation.

4.64 The Contractor should recycle as much C&D materials as possible. Proper segregation of waste types on site to enhance reuse and recycling of materials. Designated areas for different materials storage should be assigned for segregation.

4.65 Under the Construction Waste Disposal Charging Scheme, construction waste producers such as construction and renovation contractors and premises owners, prior using government waste disposal facilities, need to prepare a billing account with EPD and pay for construction waste disposal.

4.66 It is expected that trip-ticket system will be implemented for surplus C&D materials disposal in accordance with ETWB TC(W) No.31/2004 and the Construction Waste Disposal Charging Scheme. Waste should be delivered to a public fill reception facility. Copies or counterfoils of trip tickets will be kept for record purpose.

Contaminated Materials

4.67 Since all twelve cremators in the existing crematorium will remain in operation during Phase 1 and demolition works will be carried out during Phase 2, contaminated material will only be generated during the Phase 2 construction and demolition works.

Specific Plan for Contaminated Materials arising from Demolition Works

4.68 Building structure of cremators, flues and chimneys would likely to be contaminated by DCM ash due to long term servicing. As the cremators are still in operation, it is not possible to carry out site investigation in the areas of cremators, flues and chimneys at this stage. To maintain uninterrupted cremation services, further site investigation in cremation rooms and associated equipments are proposed to undertake after decommissioning and prior to demolition of the existing crematorium.

4.69 According to the asbestos investigation report, asbestos gasket (woven) and insulation sheet were identified with ACM. It is also not possible to inspect all potential asbestos containing material locations due to on-going operation of cremators, concealed pipeline inside wall and metal cover of flange connection. Further inspection of the inaccessible locations will be undertaken after decommissioning and prior to demolition of the existing crematorium.

4.70 Under this consideration, contaminated ash and ACM potential contamination locations will be further identified. In view of close distance between the contaminated ash and ACM, there is a concern on contaminated ash wastes being embedded in ACM. Therefore, it is advisable to remove contaminated ash waste prior to any asbestos containing material on building structures. This is considered as the worst case scenario in this assessment.

4.71 Should contaminated ash is identified on the ACM, the contaminated ash will be removed first prior to removal of ACM. If the procedures and precautionary measures described in Section 4.75 to 4.78 are followed properly, cross contamination could be minimized under normal circumstances. These procedures and measures are considered as reasonable approach to handle the cross contaminated wastes.

4.72 Asbestos waste will be handled in accordance with the Code of practice on the Handling, Transportation and Disposal of Asbestos Waste issued by the Environment Bureau.

4.73 Production, collection and disposal of asbestos waste will follow the “trip-ticket” system. The registered asbestos contractor will appoint a licensed asbestos waste collector to collect the packaged asbestos waste and deliver to the designated landfill for disposal. Notification has to be given to EPD for its disposal. EPD will normally require ten working days notice of the intention to dispose of any quantity of asbestos waste. After processing the notification, EPD will issue specific instructions and directions for disposal of the waste. The waste producer or his agent must strictly follow these directions.

4.74 Different contamination classifications based on the dioxin level in ash waste are proposed in Table 4.5 and corresponding mitigation measures are also described:

Table 4.5 Proposed Contamination Classifications for Ash Waste

Classification of Contamination	Dioxin Level in Ash Waste
Low Contaminated DCM	<1ppb TEQ
Moderately Contaminated DCM	>1 and <10 ppb TEQ
Severely Contaminated DCM	>10ppb TEQ

4.75 Where the ash waste contains low contamination levels of DCM, the Contractor should avoid ash waste becoming airborne during demolition. General dust suppression measures will be followed and ash waste will be directly disposed of at landfill.

4.76 Where the ash waste contains moderately contaminated DCM, the following steps should be followed:

· Site Preparation

- Except the cremators / flue / chimney, all removable items should be removed as far as practicable to avoid obstructing the decontamination activities;

- Preliminary site decontamination of all debris should be carried out using High Efficiency Particulate Air (HEPA) vacuum cleaner;

- Top portion of the chimney should be enclosed by a 3-layer chamber of polyethene sheets;

- At the entrance to the cremators / flues / chimney, a 3-chamber decontamination unit should be constructed for entry and exit from the work area. The 3-chamber decontamination unit should comprise a dirty room, a shower room and a clean room of at least 1m x 1m base with 3-layer of fire retardant polyethylene sheet;

- Workers should carry out decontamination procedure before leaving the work area;

- Workers should wear full protective equipment, nitrile gloves, robber boots and full-face positive pressure respirator; and

- Warning signs in both Chinese and English should be displayed in conspicuous areas.

· Demolition and Handling

- The cremators / flue / chimney should be removed from top down. Any ash or residues attached to the cremators / flue / chimney or any other building structure should be removed by scrubbing and HEPA vacuuming;

- Waste generated from the containment or decontamination unit including the protection clothing of the workers should be disposed to landfill;

- After removal, all surfaces should be decontaminated by HEPA vacuum cleaner; and

- The storage area for ash waste should be properly enclosed throughout the demolition works. The location of storage area for ash waste will be identified in the Waste Management Plan to be prepared by the Contractor.

· Treatment and Disposal

- Immobilise ash waste by proper mixing with cement as determined by the pilot mixing and Toxicity Characteristic Leaching Procedure (TCLP);

- Waste material should be placed in polyethylene lined steel drums for disposal at landfill, the drums should be 16 gauge steel or thicker and fitted with double bung fixed ends adequately sealed and well labeled in new or good condition.

- Drums should be clearly marked “DANGEROUS CHEMICAL WASTE” in English and Chinese. Prior agreement of the disposal criteria must be obtained from EPD and the landfill operator.

- As a fall back option, if landfill disposal criteria cannot be met after immobilization of the ash waste, disposal at the Chemical Waste Treatment Center (CWTC) should be considered.

4.77 The areas with severely contaminated DCM should be removed under containment as a prudent approach to avoid the release of ash waste to the environment during the demolition works of the existing building and the following should be addressed.

· Site Preparation

- Except the cremators / flue / chimney, all identified removable items with severely contaminated DCM should be removed as far as practicable to avoid obstructing the decontamination activities;

- Preliminary site decontamination of all debris should be carried out using High Efficiency Particulate Air (HEPA) vacuum cleaner;

- The walls, floor and ceiling of the cremator room where severely contaminated DCM should be lined with 3-layer chamber of fire retardant polyethene sheets. Top portion of the chimney above the roof should be enclosed by a 3-layer chamber of polyethene sheets;

- Air movers should be installed at the cremator room, and at the bottom of the chimney to exhaust air from work area. A stand-by air mover should be installed with each of air movers. Sufficient air movement should be maintained to give a minimum of 6 air changes per hour to the work area;

- New pre-filters and HEPA filters should be used on the air movers.

- Before commencement of the decommissioning work, a smoke test with non-toxic smoke should be carried out to confirm the air tightness of the containment;

- Workers should wear full protective equipment, disposable protective coverall (such as Tyvek with shoe covers and hood), nitrile gloves, rubber boots and full-face positive pressure respirator equipped with a combination cartridge that filters particulate and removes organic vapour; and

- Warning signs in both Chinese and English should be displayed in conspicuous areas.

· Decontamination, Demolition and Handling

- The contaminated detached sections of the building structure with severely contaminated DCM should be wrapped with 2 layers of fire retardant polyethene sheets. The third layer should be wrapped and secured with duct tape. Decontaminate the outer layer of the wrapped flue sections by wet wiping;

- After completion of removal and decontamination, spray the innermost layer of the fire retardant polyethene sheet with PVA. Upon drying, peel off and dispose of at landfill site; and

· Treatment and Disposal

- All contaminated ash waste with severely contaminated DCM removed and the used HEPA filters should be sent to Chemical Waste Treatment Center (CWTC) at Tsing Yi accordingly to Chapters 2 & 3 Code of Practice on the Packaging, Labelling & Storage of Chemical Wastes published under the Waste Disposal Ordinance (Cap 354), Section 35; and

- Other waste including the building structures and its associated panels as well as waste generated from this decommissioning works are also considered as contaminated waste and should be disposed of at designated landfill. Waste generated from this decommissioning works refer to the polyethene wrapping sheets should be placed into appropriate containers for disposal. Waste Disposal Permit has to be obtained from EPD. Disposal trip ticket is required to be made available as record after disposal.

4.78 Further investigation and confirmatory test for ash waste in cremator, chimney and flues should be carried out on DCM prior to the demolition works of the existing building. The sampling and analysis plan should be prepared and submitted to EPD for approval.

4.79 The principles as stated in Section 4.75 to 4.78 aim to address the detailed measures of avoiding cross contamination of DCM and ACM and should form part of the DCM Assessment Report which will be submitted to EPD for approval before the commencement of the demolition of the existing crematorium.

4.80 Contaminated Soil:

· According to the Contamination Assessment Report (CAR) and Remediation Action Plan (RAP) provide in Appendix 5.2, among five 0.1m samples analyzed, no surface soil samples were found to have testing parameters exceeding the relevant Risk-Based Remediation Goals (RBRGs).

· In additional, further investigations and confirmatory test should be carried out to determine if additional remediation (in addition to the current RAP) is required.

Chemical Waste

4.81 All the chemical waste should be handled according to the Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes. The chemical waste should be stored and collected by a licensed contractor for disposal at licensed facility in accordance with the Waste Disposal (Chemical Waste) (General) Regulation. Containers used for the storage of chemical waste should be:

· Suitable for substance holding, resistant to corrosion, maintained in good condition and securely closed;

· Capacity of less than 450 liters 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 Waste Disposal (Chemical Waste) (General) Regulation.

4.82 The storage area for chemical waste should:

· Be clearly labeled 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 110% 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 from entering (water collection within the bund must be tested and disposal as chemical waste if necessary); and

· Be properly arranged so that incompatible materials are adequately separated.

4.83 The chemical waste should be disposed of by:

· A licensed waste collector;

· A facility licensed to receive chemical waste, such as CWTC at Tsing Yi, which offers chemical waste collection service and can supply the necessary storage containers; and

· A waste recycling plant as approved by EPD.

General Refuse

4.84 General refuse should be stored in enclosed bins or compaction units separated from C&D and chemical wastes. Waste collector should be employed by the Contractor to minimize odour, pest and litter impacts. Open burning of refuse on construction site is prohibited by law.

4.85 The Contractor should carry out an education programme for workers in avoiding, reducing, reusing and recycling. This should include provision of three-colour recycling bins and on site and posters and leaflets advising on the use of recycling bins.

Mitigation of Adverse Environmental Impacts for Operation Phase

Ash and Non-Combustible Residues

4.86 The disposal of bone and non-combustible residues should be properly collected and handled to avoid dust emissions. In line with the current practices, the bone ash will be stored in covered containers for collection by the deceased’s relatives within 2 months upon appointment while the non-combustible residues will be collected in sealed heavy-duty polyethene bags for disposal at landfill. Potential secondary environmental impacts will be kept to a minimum.

4.87 Combustion gas temperature, residence time, air supply and gas turbulence of the new cremators will be properly and adequately controlled to optimize the effectiveness of combustion during cremation process, therefore generation of Bone Ash will be expected in low amount.

Chemical Waste

4.88 Chemical waste generated from the air pollution system as well as from machinery maintenance and servicing should be managed in accordance with the Code of Practice on the Packaging, Labelling and storage of Chemical Wastes under the provisions of the Waste Disposal (Chemical Waste)(General) Regulation. The chemical waste should be collected by drum-type containers and removed by licensed chemical waste contractor.

4.89 Plant / equipment maintenance schedules should be planned in order to minimize the generation of chemical waste.

4.90 Non-recyclable chemical wastes and lubricants should be disposed at an appropriate facility, such as EPD Chemical Waste Treatment Centre at Tsing Yi. Copies or counterfoils from collection receipts issued by the licensed waste collector should be kept for record purpose.

4.91 Recyclable chemical waste that is collected will be transported off-site for treatment by a licensed collector. The Contractor will need to register with EPD as a chemical waste producer. Where possible, chemical wastes (e.g. waste lubricants) would be recycled at an appropriate facility, e.g. at Dunwell’s oil re-refinery.

Fly Ash

4.92 During the operation phase of the Project, combustion gas temperature, residence time, air supply and gas turbulence of the new cremators will be properly and adequately controlled to optimize the effectiveness of combustion during cremation process, thereby minimizing the generation of fly ash.

4.93 Fly ash is collected by the APC equipment. This is designed to maximize the collection of fly ash.

4.94 Disposal method of fly ash from the cremators should be stored in sealed drums and placed in a designated area for collection by CWTC. Fully incinerated residues should be disposed to landfill.

4.95 The following methods have been considered and assessed for applicability in treating the fly ash from cremators:

· Bioremediation: Using white-rot fungus (Ceriporia sp.) to degrade dioxins in a trial study. Concerns relate to potential problem of introducing a biohazard (the fungus) into the surrounding natural ecosystem. No proven commercial application.

· Detoxification: Contacting the contaminated incineration ash with an aqueous solution of an alkaline earth metal hydroxide at 100^°C. A patented process but no proven commercial application.

· Thermal Desorption: Considered feasible as the first stage in separating and concentration the dioxin from the contaminated soil. However, the residue from thermal desorption requires treatment. Thermal desorption was used in Hong Kong to initially treat dioxin-contaminated soil from Penny’s Bay, but the residue from the process still had to be treated at the CWTC.

· Base Catalytic Dechlorination and Gas Phase Chemical Reduction: Have been previously examined for use in Hong Kong but rejected due to concerns that BCD will generate a more toxic from of dioxin in the event of incomplete dechlorination. Besides, the need to import and test the feasibility of BCD technology, which is not readily available in Hong Kong,

· Ultraviolet Photolysis: This process volatilizes organic compounds from the soil matrix; collects the desorbed organics in a solvent; and, destroys the contaminants with high-intensity ultraviolet light. So far only a research project with no proven commercial application.

· Solidification: Generally implies the physical encapsulation of APC residues with cement or pozzolanic (cement-like) materials to reduce the leaching of constituents.

· Stabilisation: Generally defined as the addition of reagents to chemically transform soluble contaminants into a less soluble form, making use of both the precipitation of materials in new minerals as well as the binding of materials to minerals by sorption.

· Vitrification: Involves the mixing of residues with glass precursor materials such as high temperatures (1300 to 1500^OC) to form a single-phase amorphous glassy materials. This results in chemical bonding of inorganic species in the residues with glass-forming materials and encapsulation of residue constituents in a layer of glassy materials.

4.96 Of the above methods, only solidification, stabilization and vitrification are considered as potentially applicable for operation stage of this Project. The other methods are either only at the pilot plant / demonstration stage or else have no proven commercial application. The treatment method previously accepted for use in Hong Kong during operation stage – thermal desorption – still required residues to be treated at the CWTC.

4.97 To treat fly ash using solidification, stabilization or vitrification processes will require the construction and operation of substantial infrastructure, which would not only require the use of reagents and other chemicals (that themselves can pose an environmental hazard in their use and storage) but which would also occupy additional space with the Site. Furthermore, the on-site treatment of fly ash would likely be considered as Designated Project itself, under Item G.6 of Schedule 2 to the EIAO, and would thus require a separate Environmental Permit.

4.98 In conclusion, the use of alternative on-site treatment is not considered to be feasible, either environmentally, economically and practically; and the cremation and APC technologies adopted are considered optimal. Instead, it is proposed that handling of fly ash from the cremators at Cape Collinson Crematorium follows the established practice at other crematoria in Hong Kong, i.e.:

· Fly ash is collected and stored in sealed drums provided by the CWTC.

· Sealed drums are stored in a designated area and are periodically collected by CWTC (normally two to three weeks interval).

· Drums are taken to CWTC where they are incinerated and rendered harmless – this includes the complete destruction of dioxins.

· Residues are then disposed of at landfill.

4.99 This approach is considered to be environmentally sound, follows established practice, uses appropriate existing Government waste treatment facilities and minimizes the environmental impacts at the crematorium site during operational stage. This approach allows for the safe treatment and disposal of fly ash, irrespective of the concentration of dioxins or other contaminants in the fly ash.

General Refuse

4.100 Waste generated in offices should be reduced through segregation and collection of recyclable waste materials (such as paper). To promote recycling of waste paper, aluminum cans and plastic bottles, it is recommended to place clearly labeled recycling bins at designated locations. The recyclable waste materials should be collected by licensed collectors.

4.101 General refuse, other than segregated recyclable wastes, should be separated from any chemical waste and stored in covered skips. FEHD should remove general refuse from the site on daily basis to minimize odour, pest and litter impacts. Also, open burning of refuse must be strictly prohibited.

Good Site Practices and Waste Reduction Measures for Operation Phase

4.102 It is recommended that the following good operational practices should be adopted to minimise waste management impacts:

§ Obtain the necessary waste disposal permits from the appropriate authorities, in accordance with the Waste Disposal Ordinance (Cap. 354), Waste Disposal (Chemical Waste) (General) Regulation and the Land (Miscellaneous Provision) Ordinance (Cap. 28);

§ Nomination of an approved person to be responsible for good site practice, arrangements for collection and effective disposal to an appropriate facility of all wastes generated at the site;

§ Use of a waste haulier licensed to collect specific category of waste;

§ A trip-ticket system should be included as one of the contractual requirements and implemented by the Environmental Team to monitor the disposal of C&D and solid wastes at public filling facilities and landfills, and to control fly tipping. Reference should be made to ETWB TCW No. 31/2004.

§ Training of site personnel in proper waste management and chemical waste handling procedures;

§ Separation of chemical wastes for special handling and appropriate treatment at a licensed facility;

§ Routine cleaning and maintenance programme for drainage systems, sumps and oil interceptors;

§ Provision of sufficient waste disposal points and regular collection for disposal;

§ Adoption of appropriate measures to minimize windblown litter and dust during transportation of waste, such as covering trucks or transporting wastes in enclosed containers;

§ Implementation of a recording system for the amount of wastes generated, recycled and disposed of (including the disposal sites).

4.103 Good management and control can prevent the generation of significant amounts of waste. It is recommended that the following good operational practices should be adopted to ensure waste reduction:

§ Segregation and storage of different types of waste in different containers, skips or stockpiles to enhance reuse or recycling of materials and their proper disposal;

§ Encourage collection of aluminium cans, plastic bottles and packaging material (e.g. carton boxes) and office paper by individual collectors. Separate labelled bins should be provided to help segregate this waste from other general refuse generated by the work force;

§ Any unused chemicals or those with remaining functional capacity should be reused as far as practicable.

Impacts Caused by Handling, Collection and Disposal of Waste

Potential Hazard – Chemical Waste

4.104 Should any chemical waste be generated, the Contractor must register with EPD as chemical waste producer. All chemical waste will be handled according to the Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes. Chemical waste will be stored and collected by an approved contractor for disposal at a licensed facility in accordance with the Waste Disposal (Chemical Waste) (General) Regulation.

4.105 For containers used for storage, requirements for storage area and disposal method should refer to Sections 4.81 to 4.83 accordingly.

Potential Hazard – Asbestos

4.106 Air Pollution Control Ordinance requires registered professionals to carry out the abatement works, while the Waste Disposal Ordinance provides control on the packaging, labeling, storage, collection and disposal of asbestos waste. Asbestos waste should be handled in accordance with the Code of Practice on the Handling, Transportation and Disposal of Asbestos Waste issued by the Environment and Food Bureau.

4.107 Asbestos waste is categorized as chemical waste under the Waste Disposal (Chemical Waste) Regulation. The arrangement of production, collection and disposal will follow the ‘trip-ticket’ system. The registered asbestos contractor will appoint a licensed asbestos waste collector to collect the packaged asbestos waste and deliver it to the designated landfill for disposal.

Potential Hazard – DCM

4.108 Contamination classifications, site preparation procedures, demolition and handling procedures, treatment and disposal procedures for different contamination levels of DCM from building structure and soils have been presented in Sections 4.74 to 4.79.

Air and Odour Emissions

4.109 An air quality assessment for the Project has been presented in Section 3. Air and odour emissions from the handling, collection and disposal of waste during construction and demolition phase and operation phase were discussed. A number of mitigation measures have been recommended. There would be minimal impact from the handling, collection and disposal of waste in terms of air and odour.

Noise

4.110 A noise assessment for the Project has been presented in Section 7. During the construction, demolition and operation phases, no significant noise impact would be expected from handling, collection and disposal of waste.

Wastewater Discharge

4.111 Water quality assessment for the Project has been presented in Section 8. Discharge of wastewater from the Project during the construction and demolition phase was discussed and a number of mitigation measures have been recommended. There will be minimal impact from the handling, collection and disposal of waste.

4.112 During the operation phase of the Project, there will be no significant wastewater impacts from the handling, collection and disposal of waste as the proposed APC utilizes a “dry” process and all wastewater meets WPCO standards for discharge to foul sewer.

Public Transport

4.113 The transportation of all waste material will, in the immediate vicinity of the site, follow Cape Collinson Road, Lin Shing Road, Chai Wan Road and Island Eastern Corridor. Subsequent to these roads, the route will depend on the final destination of the waste.

4.114 According to information provided by ArchSD, the number of vehicle trips for waste disposal at landfill is estimated to be about 5 trips per day.

4.115 For chemical wastes to be either recycled or disposal of, the number of trips will depend on the quantity of chemical waste, but is unlikely to exceed one vehicle trip per week, on average.

4.116 No significant impact on public transport would be expected from the handling, collection and disposal of waste.

Evaluation of Residual Impacts

4.117 With the implementation of the recommended mitigation measures for the handling, transportation and disposal of the identified waste arisings, no residual impact is expected to arise during the construction and operation stages of the proposed Project.

Cumulative Impacts due to Concurrent Projects

4.118 According to the currently available information, no concurrent projects would be constructed and operated in the vicinity of the Study Area of the Project.

Conclusion

4.119 Waste management implications of the demolition of existing crematorium, construction and operation of the new crematorium have been assessed.

4.120 With effective implementation of the mitigation measures, it is anticipated that the impacts on the environment and the potential impacts on the capacity of waste collection, transfer and disposal facilities will be insignificant.

4.121 Prior to the demolition phase of the existing crematorium, further contamination investigation should be carried out to confirm quality and quantity of asbestos and DCM. Asbestos Investigation Report (AIR) should be prepared by registered asbestos consultant. Samples testing should be carried out by HOKLAS-accredited laboratory. Asbestos Abatement Plan (AAP) should be prepared for asbestos contaminated premises. Supplementary CAP/CAR/RAP should be carried out to confirm quality and quantity of contaminated soil.

4.122 Ash sampling should be carried out at potential areas of cremators, chimney and flues. Since the cremators are still in operation, it is not possible to carry out site investigation at these areas at this stage. The contaminated ash waste is recommended to be removed prior to any asbestos containing material in building structures.

[1] Land contamination issues would be addressed in Chapter 5 – Land Contamination Assessment where appropriate