7                         WASTE MANAGEMENT IMPLICATION AND LAND CONTAMINATION

7.1                    Introduction

7.1.1.1        This section identifies potential waste that may arise from the construction and operation of the EMSD Hong Kong Workshop project and assesses potential environmental impacts associated with their handling and disposal.  Options of reuse, minimization, recycling, treatment, storage, collection, transport and disposal of such wastes have been examined.  Where appropriate, procedures for waste reduction and management have been considered, with environmental control measures to avoid or minimise impacts recommended. 

7.1.1.2        In addition, as the EMSD Hong Kong Workshop will be constructed on previously developed land, the potential for contaminated land which could cause impacts during construction of the facility has also been assessed. 

7.2                    Environmental Legislation and Standards

7.2.1              General Waste Management

7.2.1.1        The following legislation is relevant to the handling, treatment and disposal of waste in HKSAR, and will be considered in assessing potential impacts and their avoidance or mitigation:

·               Environmental Impact Assessment Ordinance (Cap 499);

·               Waste Disposal (Amendment) Ordinance (Cap 354);

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

·               Public Health and Municipal Service Ordinance (Cap 132) – Public Cleansing and Prevention of Nuisances By-laws.

7.2.1.2        Under the Waste Disposal (Amendment) Ordinance, some of the regulations are relevant to this EIA, including:

·               Waste Disposal (Charges for Disposal of Construction Waste) Regulation (Cap 354); and

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

7.2.2              Waste Disposal (Amendment) Ordinance and the Waste Disposal (Charges for Disposal of Construction Waste) Regulation

7.2.2.1        The Waste Disposal (Amendment) Ordinance (WDO) prohibits unauthorised disposal of wastes.  Schedule 5 of the Waste Disposal (Charges for Disposal of Construction Waste) Regulation (Charging Regulation) also defines that the inert construction waste includes rock, rubble, boulder, earth, soil, sand, concrete, brick, tile, masonry or used bentonite. 

7.2.2.2        Under the WDO and the charging regulation, wastes can only be disposed of at designated waste disposal facilities licensed by the EPD.  For construction work with a value of more than HK$1 million, the main contractor is required to establish a billing account at the EPD before transporting the construction waste to the designated waste disposal facilities (for example, landfill and public fill).  The vessels for delivering construction waste to the public fill reception facilities require prior approval from the Public Fill Committee (PFC).  Any breach of these regulations may lead to a fine and/or imprisonment.

7.2.3              Waste Disposal (Chemical Waste) (General) Regulation

7.2.3.1        Chemical waste includes any scrap materials or unwanted substances specified under Schedule 1 of this Regulation if such a substance or chemical occurs in such a form, quantity or concentration that causes pollution or constitutes a danger to health or risk of pollution to the environment. 

7.2.3.2        A person shall not produce, or cause to be produced, any chemical wastes unless he/she is registered with the EPD, otherwise, it will be an offence and is liable to a fine and/or imprisonment.  Chemical wastes must be treated using on-site plant as licensed by the EPD or with engaging a licensed collector to transport the wastes to a licensed facility.  For each consignment of wastes, the waste producer, collector and disposer of the wastes must sign all relevant parts of a computerised trip ticket so as to trace wastes from production to disposal.

7.2.3.3        This regulation also prescribes the storage facilities to be provided on-site including the labeling and warning signs.  In order to minimise the risks of pollution and danger to human health and life, waste producers are required to prepare and make available written emergency procedures for any spillage, leakage or accidents arising from storage of chemical wastes, and waste producers must also provide employees with training for such procedures. 

7.2.4              Public Cleansing and Prevention of Nuisances Regulation

7.2.4.1        This regulation provides further control on the illegal dumping of litter or waste in streets and public places (including water courses, streams, channels etc).  Any offence of this regulation would result in a fine and/or to imprisonment. 

7.2.5              Other Relevant Guidelines

7.2.5.1        The following guidelines also relate to waste management and disposal:

·               Technical Memorandum on Environmental Impact Assessment Process (TM-EIAO), Annex 15 – Guidelines for Assessment of Waste Management Implications, and Annex 7 – Criteria for Evaluating Waste Management Implications;

·               Waste Reduction Framework Plan, 1998-2007, Planning Environment and Lands Branch, Government Secretariat (1998);

·               Waste Disposal Plan for Hong Kong (1989);

·               Hong Kong Planning Standards and Guidelines (HKPSG), Chapter 9 – Environment;

·               Code of Practice on the Packaging, Labeling and Storage of Chemical Wastes, EPD (1992);

·               New Disposal Arrangement for Construction Waste (1992), Environmental Protection Department & Civil Engineering Department;

·               Works Branch Technical Circular (WBTC) No. 32/92, The Use of Tropical Hard Wood on Construction Site;

·               WBTC No. 2/93, Public Dumps;

·               WBTC No. 2/93B, Public Filling Facilities;

·               WBTC Nos.25/99, 25/99A and 25/99C, Incorporation of Information on Construction and Demolition Material Management in Public Works Sub-committee Papers;

·               WBTC No. 12/2000, Fill Management, Hong Kong SAR Government;

·               WBTC Nos. 6/2002 and 6/2002A, Enhanced Specification for Site Cleanliness and Tidiness. Works Bureau, Hong Kong SAR Government;

·               WBTC No. 12/2002, Specification Facilitating the Use of Recycled Aggregates. Works Bureau, Hong Kong SAR Government;

·               ETWB TC(W) No. 33/2002 Management of Construction and Demolition Material Including Rock;

·               DevB TC(W) No. 6/2010, Trip Ticket System for Disposal of Construction & Demolition Materials, Development Bureau, Hong Kong SAR Government; and

·               ETWB TC(W) No. 19/2005 Environmental Management on Construction Sites. 

7.2.5.2        The ETWB TC(W) No. 19/2005 also sets out the policy and procedures requiring contractors to prepare and implement an environmental management plan to encourage on-site sorting of C&D materials and to reduce C&D waste generation during construction. 

7.2.6              Contaminated Land

7.2.6.1        The following legislation relevant to the land contamination issues as a result of handling, treatment and disposal of contaminated materials:

·               Environmental Impact Assessment Ordinance (Cap 499);

·               Waste Disposal Ordinance (Cap 354);

·               Waste Disposal (Chemical Waste) (General) Regulation (Cap 354C); and

·               Dangerous Goods Ordinance (Cap 295).

7.2.6.2        The following EPD publications provide guidance on the land contamination assessment in this Assignment:

·               Code of Practice of the Packaging, Labelling and Storage of Chemical Waste, EPD (1992).

·               Practice Guide for Investigation and Remediation of Contaminated Land

·               Guidance Note for Contaminated Land Assessment and Remediation; and

·               Guidance Manual for Use of Risk-Based Remediation Goals (RBRGs) for Contaminated Land Management.

7.3                    Waste Management

7.3.1              Assessment Methodology

7.3.1.1        The assessment of the environmental impacts from the handling, storage, collection, transportation and disposal of waste material generated by the project has been undertaken in accordance with Annex 7 and Annex 15 of the TM-EIAO. 

7.3.1.2        The waste management hierarchy has been applied in the assessment and development of mitigation measures for waste.  The waste management hierarchy is a concept which shows the desirability of various waste management methods and comprises the following in order of preference:

·               avoidance;

·               minimisation;

·               recycling/reuse;

·               treatment; and

·               disposal.

7.3.1.3        All opportunities for reducing waste generation have been assessed based upon the following factors:

·               avoiding or minimising waste generation through changes in the design;

·               adopting better management practices to promote segregation of waste materials;

·               reuse and recycling; and

·               diverting waste to public dumps or other construction sites.

7.3.1.4        The types and quantities of waste have been estimated and disposal options for each category of waste identified, taking into account the existing or future spare capacities of the waste disposal facilities and the environmental implications of the handling, collection and disposal of waste material. The potential environmental impacts associated with the handling, transportation and disposal of waste arising from the construction works will be assessed with reference to the following approach:

·               estimation of the types, timing and quantities of the wastes to be generated and fill to be imported; and

·               assessment of the potential environmental impacts on the capacity of waste collection, transfer and disposal facilities.

7.3.1.5        The impact caused by handling (including stockpiling, labelling, packaging and storage), collection, transportation and re-use/disposal of wastes has been addressed in detail and appropriate mitigation measures have been proposed.  This assessment covers the following areas: potential hazard, air and odour emissions, noise, wastewater discharge and public transport.  

7.3.2              Construction Phase Waste Management Assessment

Waste Types

7.3.2.1        The construction of the EMSD Hong Kong Workshop will involve a number of activities which will generate wastes which can broadly be classified into distinct categories based on their nature and the options for their disposal.  These include:

·               Excavated construction and demolition (C&D) materials suitable for public fill (no excavation of marine sediment would occur in this Project);

·               Construction and demolition waste, including some cleared vegetation, which is not suitable for public fill;

·               Chemical waste; and

·               General refuse.

Details of Work Activities

7.3.2.2        As described in Section 3 of this EIA report, the EMSD Hong Kong Workshop project comprises mainly the construction of a land-based steel shed structure on a raft foundation.  Upon site clearance, site formation works will be carried out which involves the excavation of soil for the subsequent construction of concrete slab and footing, erection of formwork and cover shed, plant rooms, utilities and finally installation of building services. 

Construction and Demolition Materials

7.3.2.3        Construction and demolition (C&D) materials generated during construction will comprise materials that are suitable for reuse on site or as public fill and a portion of waste material that will require disposal to a licensed landfill facility.  For the purposes of this assessment, these two fractions are denoted C&D material and C&D waste and are discussed below.

C&D Materials

7.3.2.4        The Construction and Demolition (C&D) materials generated from the EMSD Hong Kong Workshop project will comprise excavated materials mainly from the construction of raft foundation, concrete footing and slab, utilities trenches.

7.3.2.5        In accordance with the waste hierarchy presented in Section 7.3.1, it is necessary to consider all ways to avoid the generation of material and also reuse within the project.  The following methods have been adopted:

·               Minimising Generation of C&D Materials: Section 2 of this EIA report presented that the design of this workshop has taken into account the environmental benefits arising from an optimized design of the workshop, in particular the adoption of a simple open steel shed design instead of a typical building design of the workshop so as to reduce the C&D materials and wastes to be generated.

·               Maximising Use of C&D Materials: Inert C&D materials from the site formation works will be reused both on-site and off-site as far as practicable, e.g. scrapped steel bars to be recycled; earth materials, concrete debris and aggregates for backfilling, etc.

7.3.2.6        A summary of the C&D materials anticipated to arise from the project is provided in Table 7.1 below.

Table 7.1         Summary of C&D Materials Arising from the Project

Material Type

Quantity (tonne)

Remarks

Excavated soil

150

Generated from the excavation works for the construction of raft foundation and concrete footing.

Concrete debris and aggregate

70

Generated from the construction of raft foundation and concrete footing. 

Scrap steel

0.15

Generated from the construction of raft foundation, concrete footing, steel formwork of shed structure. 

TOTAL

220.15

 

 

7.3.2.7        Some of the C&D material generated by the project has been explored for reuse either on-site or off-site.  All scrap steel will be collected for recycling.  It is estimated that approximately 20 tonne of sand and aggregate would also be reused on-site.  The possibility of maximizing the reuse of excavated soil would be explored during the detailed design phase of the Project.  Approximately 75 tonnes of the excavated soil can be reused as backfill upon the completion of the raft foundation works.  As some of the materials would be reused on-site, impacts from transportation would be minimised. 

7.3.2.8        The balance of approximately 75 tonnes of excavated soil and 50 tonne of construction debris is proposed to be delivered to the Tseung Kwan O Area 137 Fill Bank via the adjacent Chai Wan Public Fill Barging Point at Kai Yip Street.  The transportation of the material would be undertaken over 14 months, between August 2012 and October 2013 (refer to the overall construction programme in Section 3 of this EIA report).  Given the relatively small quantities involved and an average truck capacity of 7.5 m3, a total of approximately 25 trucks would be needed over this 14 month period.  Based upon the material being exported on a regular basis for the majority of the 15-month construction period, this would equate to around only a maximum of 4 trips per day, assuming a 6 day working week.  The material would be transported via Sheung On street to Ka Yip Street and as minimal amount of additional traffic to be generated is not predicted to cause any additional impacts to sensitive receivers along this route.

7.3.2.9        However, the material will need to be carefully stockpiled if it cannot be reused or removed directly to avoid dust and other nuisance impacts.  No construction work is allowed to proceed until all issues on management of C&D materials have been resolved and all relevant arrangements have been agreed between the responsible Government department and party. 

C&D Waste

7.3.2.10    In addition to the C&D materials that will be generated by the project and will be suitable for reuse as public fill, some C&D waste will be generated during the construction phase.  These materials will include:

·               Cleared vegetation;

·               Wood from formwork;

·               Unusable cement mixes; and

·               Damaged or contaminated construction materials.

7.3.2.11    The volume of C&D waste generated by the project will be dependant on specific operating procedures and site practices and, is expected to be small at about 10 tonnes.  In addition, as the EMSD Hong Kong Workshop is a relatively minor facility covering a small area which has mostly been cleared, the amount of C&D waste generated from site clearance comprising a mixture of topsoil and vegetative matter is expected to be small.

7.3.2.12    The other types of C&D waste are, also, expected to be limited, with only small quantities of maintenance and packaging waste being generated.  Given that the material will be generated will be of in small quantities, significant impacts associated with its handling and disposal would not be expected.

7.3.2.13    Measures to minimise the generation of waste shall be implemented and demolition waste shall be sorted to avoid contamination of the materials suitable for public fill but significant impacts would not be anticipated from the handling, storage or disposal of this material.   

Chemical Waste

7.3.2.14    Chemical wastes likely to arise from the construction activities for the EMSD Hong Kong Workshop would include:

·               Scrap batteries or acid/alkali from maintenance activities;

·               Used paints, engine oils, hydraulic fluids and waste fuel;

·               Spent mineral oils/cleansing fluids from machineries; and

·               Spent solvents/solutions, some of which may be halogenated, from equipment cleansing activities.

7.3.2.15    Chemical wastes may pose environmental, health and safety hazards if not stored and disposed of appropriately as outlined in the Waste Disposal (Chemical Waste) (General) Regulation and the Code of Practice on the Packing, Labeling and Storage of Chemical Waste.  These hazards may include:

·               Toxic effects to workers;

·               Adverse effects on air quality, water quality and land contamination due to spillage;

·               Hazards of fire; and

·               Disruption of sewage treatment works should the chemical waste enter the sewerage system. 

7.3.2.16    The amount of chemical waste would be estimated to be approximately 100L for the whole project, depending on the Contractor’s on-site maintenance practices and the number of mechanical plant and vehicles utilised on-site.  However, it is anticipated that the quantity of chemical waste arising during the construction of this project would be very small given the small scale of the project and if handled, stored, transported and disposed of in an appropriate manner, impacts would not be anticipated. 

7.3.2.17    Notwithstanding, the Contractor should register to the EPD as a Chemical Waste Producer pursuant to the Regulation and the chemical waste should be collected by licensed collectors for subsequent disposal at licensed waste disposal facilities, for example the Chemical Waste Treatment Centre in Tsing Yi. 

General Refuse

7.3.2.18    The presence of the construction site with workers and the site office would generate a variety of general refuse which will need disposal, consisting mainly of food waste, aluminum cans, waste paper, etc.

7.3.2.19    The storage of general refuse has the potential to cause adverse environmental impacts, e.g. odour nuisance if the waste is not collected frequently, windblown litter, water quality impacts if the waste enters water bodies, visual impacts, etc.  Construction sites may also attract pests, vermin and other disease vectors if the waste storage areas were not well maintained.  Disposal of waste at areas other than approved refuse transfer stations and landfills can also lead to similar adverse impacts. 

7.3.2.20    The number of workforce (clerical and workers) to be employed for the EMSD Hong Kong Workshop project is expected to be approximately 12 people per day over the 14 month construction period.  Based on a generation rate of 0.65 kg per worker per day, the maximum daily arising of general refuse during the construction period would be approximately 8kg only (or approximately 3 tonnes for the entire construction period).  Provided that mitigation measures are adopted, potential environmental impacts caused by the storage, handling, transport and disposal of general refuse would be expected to be insignificant.  It is recommended that the general refuse should be collected on a daily basis and transferred to the adjacent Island East Refuse Transfer Station at Sun Yip Street in Chai Wan.  Given the relatively small quantities of general refuse expected, adverse impacts to the operation of the refuse transfer stations and landfills would not be expected.

7.3.3              Operational Phase Waste Management Assessment

7.3.3.1        The operational phase of the EMSD Hong Kong Workshop project is not be expected to generate any significant quantities of waste. 

7.3.3.2        The quantities of general refuse arising from the project at this stage will be low and mainly arise from office activities and the vehicle maintenance activities.  Quantities of waste and chemical waste e.g. lubrication oil, used batteries, etc are likely to be generated but the quantities will be small and insignificant.  Standard good operating practice requirements should be followed in the storing, handling and transporting of any chemical wastes.

7.3.3.3        The chemical waste likely to be generated in the operation of the EMSD Hong Kong Workshop would mainly arise from the repairing and maintenance of vehicles, including scrap batteries or spent acid/alkali, used engine oils, lubricating and hydraulic fluids and waste fuel, and spent mineral oils/ cleaning fluids from mechanical machinery.  However, the quantity of chemical waste arising will be limited and proper management procedures should be followed according to the EPD’s Code of Practice of the Packaging, Labelling and Storage of Chemical Waste.

7.3.3.4        Based upon the above, significant waste implications during the operational phase would not be anticipated.  

7.3.4              Mitigation Measures

7.3.4.1        Mitigation measures are required to ensure the proper handling, storage, transportation and disposal of waste being carried out during both construction and operation phases of this project.  Also, measures to ensure that the generation of waste is avoided and minimised and that waste materials are recycled and treated as far as practicable.  The recommended mitigation measures for all categories of waste are as follows.  With proper implementation of these measures, the handling (including stockpiling, labelling, packaging & storage), collection, transportation and re-use/disposal of wastes will not casue adverse impacts on potential hazard, air and odour emissions, noise, wastewater discharge, ecology and public transport. 

(i)                  The requirements as stipulated in the ETWB TC(W) No.19/2005 Environmental Management on Construction Sites and the other relevant guidelines should be included in the Particular Specification for the Contractor as appropriate. 

(ii)                The EMSD Hong Kong Workshop Contractor should be requested to submit a Waste Management Plan (WMP) prior to the commencement of construction work, in accordance with the ETWB TC(W) No.19/2005 so as to provide an overall framework of waste management and reduction.  The WMP should include:

-                Waste management policy;

-                Record of generated waste;

-                Waste reduction target;

-                Waste reduction programme;

-                Role and responsibility of waste management team;

-                Benefit of waste management;

-                Analysis of waste materials;

-                Reuse, recycling and disposal plans;

-                Transportation process of waste products; and

-                Monitoring and action plan.

(iii)               The waste management hierarchy below should be strictly followed.  This hierarchy should be adopted to evaluate the waste management options in order to maximise the extent of waste reduction and cost reduction.  The records of quantities of waste generated, recycled and disposed (locations) should be properly documented. 

(iv)              A trip-ticket system should be established in accordance with DevB TC(W) No. 6/2010 and Waste Disposal (Charges for Disposal of Construction Waste) Regulation to monitor the disposal of public fill and solid wastes at public filling facilities and landfills, and to control fly-tipping.  A trip-ticket system would be included as one of the contractual requirements for the Contractor to strictly implement.  The Engineer would also regularly audit the effectiveness of the system. 

(v)                A recording system for the amount of waste generated, recycled and disposed (locations) should be established.  The future Contractor should also provide proper training to workers regarding the appropriate concepts of site cleanliness and waste management procedures, e.g. waste reduction, reuse and recycling all the time. 

(vi)              The CEDD should be timely notified of the estimated volumes of excavated materials to be generated and the Public Fill Committee should be notified and agreement sort on the disposal of surplus inert C&D materials.  Wherever practicable, C&D materials should be segregated from other wastes to avoid contamination and to ensure acceptability at public filling areas or reclamation sites. 

(vii)             The site and surroundings shall be kept tidy and litter free.

(viii)           No waste shall be burnt on-site.

(ix)              Make provisions in contract documents to allow and promote the use of recycled aggregates where appropriate.

(x)                Prohibit the Contractor to dispose of C&D materials at any sensitive locations e.g. natural habitat, etc.  The Contractor should propose the final disposal sites in the EMP and WMP for approval before implementation.

(xi)              Stockpiled material shall be covered by tarpaulin and /or watered as appropriate to prevent windblown dust and surface run off.

(xii)             Excavated material in trucks shall be covered by tarpaulins to reduce the potential for spillage and dust generation.

(xiii)           Wheel washing facilities shall be used by all trucks leaving the site to prevent transfer of mud onto public roads.

(xiv)           Standard formwork or pre-fabrication should be used as far as practicable so as to minimise the C&D materials arising.  The use of more durable formwork or plastic facing for construction works should also be considered.  The use of wooden hoardings should be avoided and metal hoarding should be used to facilitate recycling.  Purchasing of construction materials should be carefully planned in order to avoid over-ordering and wastage. 

(xv)            The Contractor should recycle as many C&D materials as possible on-site.  The public fill and C&D waste should be segregated and stored in separate containers or skips to facilitate the reuse or recycling of materials and proper disposal.  Where practicable, the concrete and masonry should be crushed and used as fill materials.  Steel reinforcement bar should be collected for use by scrap steel mills.  Different areas of the sites should be considered for segregation and storage activities. 

(xvi)           Chemical waste producers should register with the EPD.  Chemical waste should be handled in accordance with the Code of Practice on the Packaging, Handling and Storage of Chemical Wastes as follows:

-                suitable for the substance to be held, resistant to corrosion, maintained in good conditions and securely closed;

-                Having a capacity of <450L unless the specifications have been approved by the EPD; and

-                Displaying a label in English and Chinese according to the instructions prescribed in Schedule 2 of the Regulations. 

-                Clearly labelled and used solely for the storage of chemical wastes;

-                Enclosed with at least 3 sides;

-                Impermeable floor and bund with capacity to accommodate 110% of the volume of the largest container or 20% by volume of the chemical waste stored in the area, whichever is greatest;

-                Adequate ventilation;

-                Sufficiently covered to prevent rainfall entering (water collected within the bund must be tested and disposed of as chemical waste, if necessary); and

-                Incompatible materials are adequately separated. 

(xvii)         Waste oils, chemicals or solvents shall not be disposed of to drain.

(xviii)        Adequate numbers of portable toilets should be provided for on-site workers.  Portable toilets should be maintained in reasonable states, which will not deter the workers from utilising them.  Night soil should be regularly collected by licensed collectors.

(xix)           General refuse arising on-site should be stored in enclosed bins or compaction units separately from C&D and chemical wastes.  Sufficient dustbins shall be provided for storage of waste as required under the Public Cleansing and Prevention of Nuisances By-laws.  In addition, general refuse shall be cleared daily and shall be disposed of to the nearest licensed landfill or refuse transfer station.  Burning of refuse on construction sites is prohibited. 

(xx)            All waste containers shall be in a secure area on hardstanding;

(xxi)           Aluminium cans are usually collected and recovered from the waste stream by individual collectors if they are segregated and easily accessible.  Separately labelled bins for their deposition should be provided as far as practicable. 

(xxii)         Office wastes can be reduced by recycling of paper if such volume is sufficiently large to warrant collection.  Participation in a local collection scheme by the Contractor should be advocated.  Waste separation facilities for paper, aluminium cans, plastic bottles, etc should be provided on-site.

(xxiii)        Training shall be provided to workers about the concepts of site cleanliness and appropriate waste management procedure, including waste reduction, reuse and recycling.

7.3.5              Waste Disposal Recommendations

7.3.5.1        Based upon the estimated quantities and types of waste to be generated by the project, disposal options have been proposed, as detailed in Table 7.2 below.  In terms of the disposal of small quantities of general refuse, WENT Landfill via the nearby Island East Refuse Transfer Station is recommended.  In terms of the delivery of excavated C&D materials, the TKO Area 137 Fill Bank via the Chai Wan Public Fill Barging Point is recommended.  Chemical wastes will be disposed of at the Chemical Waste Treatment Centre in Tsing Yi or other licensed facilities via licensed collectors. 

Table 7.2      Recommended Waste Disposal Sites

Type of Waste

Disposal Site

Quantity

C&D materials

TKO Area 137 Fill Bank

Excavated soil: ~75 tonnes

Construction debris: ~50 tonnes

C&D waste (plastics, glass, wood, including cleared vegetation etc.)

SENT Landfill

~10 tonnes

Chemical waste (as defined under Schedule 1 of the Waste Disposal (Chemical Waste) Regulation)

Chemical Waste Treatment Centre in Tsing Yi or other licensed facilities via licensed collectors

~100 L

General refuse

WENT Landfill via Island East Refuse Transfer Station

~3 tonnes

        

7.4                    Land Contamination

7.4.1              Assessment Methodology

7.4.1.1        The assessment for land contamination of the Project site was carried out with reference to the EPD’s Practice Guide for Investigation and Remediation of Contaminated Land.  The normal sequence of steps involved in the assessment process is summarized below:

1.      Carrying out the site appraisal (information collection);

2.      Designing site investigation and preparing the Contamination Assessment Plan (CAP) for EPD’s approval;

3.      Conducting the site investigation;

4.      Interpreting results and preparing the Contamination Assessment Report (CAR) for EPD’s approval;

5.      Planning and designing the remediation works and preparing the Remediation Assessment Plan (RAP) for EPD’s approval;

6.      Carrying out the remediation works; and

7.      Preparing the Remediation Report (RR) for EPD’s endorsement. 

7.4.2              Assessment Findings from Site Appraisal

7.4.2.1        The site appraisal was conducted to identify whether there were any potential contamination sources that may have impacted the site.  The usual sequence of the site appraisal process is summarized below:

1.            Identification of the site’s future land use and applicable Risk-Based Remediation Goals (RBRGs) for the land use scenarios;

2.            Review of historical information;

3.            Health and safety risk assessment and planning for site walkover;

4.            Site walkover;

5.            Identification of sources of contamination / chemical of concern;

6.            Design and plan site investigation programme;

7.            Health and safety risk assessment and planning; and

8.            Prepare CAP for EPD’s approval.  

Identification of the Site’s Future Land Use

7.4.2.2        According to the EPD’s RBRGs Guidance Manual, the Project site’s future land use was determined as “Industrial” for the subsequent identification of the corresponding RBRGs.  The conceptual site model (industrial) was therefore selected based on Annex B of EPD’s Practice Guide for Investigation and Remediation of Contaminated Land, which served as a reference during this site appraisal exercise to identify contamination sources, exposure pathways and receptors for the site to ensure that no additional pathways or receptors exist for the site and that the selected RBRGs can be applied. 

Review of Historical Information

7.4.2.3        Information including the history and other available information regarding the Project site was reviewed in order to identify the potential current and historical, on-site and off-site activities that could result in contamination of the Project site, including

·               Potentially contaminating activities that have occurred at the site such as storage and handling of chemicals, oil and/or hazardous waste, on-site waste disposal, burn pits, etc.  There may have been different activities over time which may have caused contamination, all of which should be noted. 

·               Storage facilities, pipelines, collection sumps for chemicals, oil and/or hazardous wastewater/waste that are or were present on the site.

·               Accidents, fires, explosions, spillages and any pollution incidents attributed to the site and any remediation that has occurred at the site or neighbouring areas.

·               Other site information should include geological and hydrogeological characteristics of the site.

7.4.2.4        With reference to Annexes C1 and C2 of EPD’s Practice Guide for Investigation and Remediation of Contaminated Land, the information on the present activities and past land use history in relation to any possible land contamination were collated and included in Appendix 7.1 of this EIA report.  The key details are summarised below:

Historic Land Use

·               Before 1984:   Marine environment

·               1984-1985:      Reclamation

·               1987-1996:      Wing Tai Temporary Housing Area

·               1996-2003:      Vacant

·               2003-2004:      Temporary general storage area of Drainage Services Department

·               2005-2008:      Temporary general storage area of Drainage Services Department and Food and Environmental Hygiene Department

·               Since 2008:     Vacant

·               The Fire Services Department (FSD) also informed that there was no record of storage of dangerous goods (DGs) at the Project site and no incident of chemical leakage and spillage of DGs.  

Existing Land Use

·               The project site is currently vacant.

Site Walkover

7.4.2.5        Two site walkover events were conducted on 8 and 16 September 2011 at the Project site and the details of the site walkover events are also included in Appendix 7.1 of this EIA report.  The findings indicated that there were no potential sources and signs of contamination, e.g. chemicals, oils and hazardous waste handling and storage locations, bulk storage tanks, sumps, pipelines, staining, decolouration, distressed vegetation, etc. 

Conclusion from Site Appraisal

7.4.2.6        Based on the recorded nature of past and present land use activities, it is anticipated that there were no potentially contaminating activities occurred, such as storage and handling of chemicals, oils and/or hazardous waste, on-site waste disposal, burn pits, storage facilities, pipelines, collection sumps for chemicals, oils and/or hazardous wastewater/waste, accidents, fires, explosions, spillages and any pollution incidents, etc.  As such, it was considered not necessary to continue Steps (5), (6), (7) and (8) for the Site Appraisal.  As no potential land contamination sources and issues were identified, the CAP was considered not required for the contamination assessment for the construction phase of this Project in this EIA study. 

7.4.3              Preventive Measures during Operation Phase

Potential Land Contamination Sources

7.4.3.1        According to Section 3 of this EIA report, the following potential sources of land contamination during the operation of this proposed workshop were identified which are relevant to the storage and use of chemicals:

·               Repairing and maintenance areas inside the workshop;

·               DGs and chemical storage areas; and

·               Chemical waste storage area.

Preventive and Precautionary Plan

Storage of Chemicals and Chemical Wastes

7.4.3.2        Chemicals and chemical wastes should be stored in purpose-built storage areas.  For chemicals classified as DGs under the Dangerous Goods Ordinance, all segregation, storage and handling should comply with the requirements of EPD’s Code of Practice on the Packaging, Labeling and Storage of Chemical Waste.  The same preventative approach should apply to the storage of any raw solid and liquid chemicals and chemical wastes.

Emergency Procedures

7.4.3.3        Any spillage should be reported to the Workshop Manager who should attend to the spillage and initiate any immediate actions required to protect workers and to confine and clean up the spillage.

Spillage/Leakage of Liquid Chemical/Waste at Storage Area

7.4.3.4        Where the spillage/leakage is contained in the enclosed storage area, the material should be transferred to suitable containers by appropriate equipment, e.g. hand-operated pumps, scoops or shovels. If the spillage/leakage quantity is small, it should be covered and mixed with suitable absorbing materials. The resultant slurry should be treated as chemical waste and transferred to suitable containers for disposal.

Spillage/Leakage at Repairing and Maintenance Areas

7.4.3.5        For spillage/leakage in other areas, immediate action should be taken to contain the spillage/leakage.  Suitable absorbing materials should be used as appropriate to cover the spill. The slurry should be treated as chemical wastes and transferred to containers for proper disposal.  Areas that were contaminated by chemical waste spillage/leakage should be decontaminated.  For aqueous chemicals or wastes and water soluble organic wastes, water should be used to clean the contaminated area.  For organic chemical wastes that are not soluble in water, kerosene or turpentine should be used. Wastes from the cleanup operation should be treated and disposal of as chemical wastes. 

Record of Incidents

7.4.3.6        A detailed incident report should be compiled by Workshop Manager as soon as possible after any incident.  The report should contain the details of the incident, including an estimate of any amounts spilled, and any actions taken. The incident report should be used to evaluate any environmental impacts due to the spillage and to assess the effectiveness of the measures taken, so that improvements can be made to the response procedures for future incidents.

Procedures for Disposal of Wastes

7.4.3.7        Used or expired chemicals, deteriorated synthetic lube oil, expired or non-usable paint and similar materials should be managed according to EPD’s  Code of Practice of the Packaging, Labelling and Storage of Chemical Waste, and collected by a licensed collector and disposed of at a licensed chemical treatment facility. To avoid prolonged storage of chemical waste on site which may increase the potential for land contamination, waste should be removed from the Workshop on a regular basis.

7.5                    Residual Impacts

7.5.1.1        Assuming all the mitigation measures are implemented, adverse residual impacts would not be anticipated from the handling, storage, transportation or disposal of the waste generated by the project are predicted, even though the operation would be extended beyond July 2017 as planned.

7.5.1.2        In addition, no significant contaminated land impacts are predicted during the construction and operation phases and as such, adverse residual impacts would not be anticipated, even though the operation would be extended beyond July 2017 as planned.

7.6                    Environmental Monitoring and Audit

7.6.1.1        The assessment has concluded that the handling, transportation and disposal of waste materials during construction will not give rise to significant impacts if appropriate mitigation measures are implemented.  However, it is recommended that during construction phase, regular site inspections and supervision of the waste management procedures shall be undertaken as part of the EM&A procedures, to ensure proper control, that all waste is removed from the site area as appropriate and illegal disposal of waste is not being undertaken.  Waste EM&A during the operation phase is not required and, also, as contaminated land impacts are not predicted, no EM&A for contaminated land is recommended.  Further details of the specific construction phase EM&A requirements are detailed in Section 10 of this report and in the EM&A Manual. 

7.7                    Conclusion

7.7.1.1        The quantity and timing for the generation of waste during the construction phase have been estimated.  Measures, including the opportunity for on-site sorting, reusing excavated fill materials (on-site and off-site) etc., have been devised in the construction methodology to minimise the surplus materials to be disposed off-site.  The annual disposal quantities for C&D materials and their disposal methods have also been assessed.  Recommendations have been made for the Contractor for implementation of measures during the construction period to minimise the waste generation and any off-site disposal.  The types and quantities of waste that would be generated during the operation phase have been assessed.  Recommendations have been made to ensure proper treatment and disposal of these wastes.  No construction work is allowed to proceed until all issues on management of C&D materials have been resolved and all relevant arrangements have been agreed between the responsible Government department and party.  Adverse residual impact would not be anticipated during both the construction and operation phases of this Project, even though the operation would be extended beyond July 2017 as planned. 

7.7.1.2        There were no sources of historic land contamination issues associated with the Project site.  For the future operation of this workshop, with the implementation of the preventive and precautionary plan as recommended in this EIA study, land contamination impact would not be anticipated, even though the operation would be extended beyond July 2017 as planned.