1. INTRODUCTION

1.1 The existing Fu Shan Crematorium was completed in 1984 and has been in operation since 1985. Complaints of dark smoke emission from the cremators have been received.

1.2 In 1996, the Electrical & Mechanical Services Department (EMSD) commissioned a study to explore the possibility of upgrading the existing cremators so as to protect the environment and to resolve the dark smoke problem. It was found that the cremators are near the end of their service life, and upgrading work of the existing cremators would be technically unable to satisfy the Air Pollution Control (Smoke) Regulation nor to achieve the latest requirements stipulated in BPM 12/2 - A Guidance Note on the Best Practicable Means for Incinerators (Crematoria) issued by Environmental Protection Department (EPD). Taking EMSD recommendation, the Food and Environmental Hygiene Department (FEHD), thus, proposed to replacee the existing two twin cremators of Fu Shan Crematorium (the Project). With the replacement of cremators, the latest stringent environmental emission requirements will be satisfied, and the dark smoke problem will be resolved. The Project was welcomed by local residents and supported by the Shatin District Council, when they were consulted in July 2000.

1.3 Under the Environmental Impact Assessment Ordinance (EIAO), replacement of cremators involving construction and operation of new crematorium, is a Schedule 2 Designated Project, which requires an Environmental Permit prior to the Project commencement. In April 2001, an application with a project profile for an Environmental Impact Assessment (EIA) study brief was lodged to EPD and the EIA study brief was issued in May 2001. The study brief requires an EIA study for the Project to assess the environmental impacts of the Project and propose mitigation measures if necessary. In addition, for the operation of the cremation plant, a specified process licence is required under the Air Pollution Control Ordinance (APCO).

1.4 Architectural Services Department (ArchSD), being the Project Proponent was responsible for the design and the construction of the cremators. After the construction work is completed, the operation of the cremators will be handed over to FEHD.

1.5 Maunsell Environmental Management Consultants Ltd. (MEMCL) was commissioned by ArchSD to assess the potential environmental impact of construction and operation the cremators. This EIA Report presents the assessment criteria, methodology, and results for the potential impact on air quality, land contamination, waste management, landscape, visual and water quality during construction and operation phases, with and without mitigation measures. The detailed environmental monitoring and audit (EM&A) requirements have also been presented in this EIA Report.

1.6 The purpose of this EIA Study is to provide information on the nature and extent of the environmental impacts likely to arise from the construction and operation of the Project and related activities taking place concurrently. The information provided by this EIA Study will contribute to the decisions on:

i) the overall acceptability of any adverse environmental consequences that are likely to arise as a result of the proposed project;

ii) the conditions and requirements for the detailed design, construction and operation of the proposed project to mitigate against adverse environmental consequences wherever practicable; and

iii) the acceptability of residual impacts after the proposed mitigation measures have been implemented.

1.7 This EIA Study has been carried out based on information available at the time. Relevant reports and drawings have been reviewed and findings have been incorporated where appropriate in this EIA Report. For example, findings of the Preliminary Environmental Review (PER) for the proposed “Replacement of the Existing Cremators in Fu Shan Crematorium at Shatin” carried out in 2000, have been reviewed and incorporated in this study.

1.8 In accordance with the requirements of the EIA Study Brief, the EIA covers the following aspects of impact assessment:

· Air quality impacts arising from the construction, decommissioning/ demolition, and operation of the Project;

· Landscape and visual impacts from the operation of the Project;

· Water quality impacts from the operation of the Project, if there is to be effluent discharge from the new cremators or associated air pollution control scrubbing systems;

· Hazard to life impact, if there is to be fuel gas or dangerous goods storage;

· Contamination prevention for the operation of the Project; and

· Waste management for the construction and operation of the Project.

1.9 The assessment will identify impacts arising from the proposed Project on both existing and planned sensitive developments, and locations where acceptable criteria are exceeded and appropriate mitigation measures are required.

1.10 Considering the nature and environment of the project, constructional/ operational noise impact, ecological impact and impact on sites of cultural heritage are considered to be minimal. These areas have not been included in the Study Brief and are outside the scope of this EIA.

1.11 The EIA Report has been prepared in accordance with the requirements stipulated in the Technical Memorandum on Environmental Impact Assessment Process (EIAO-TM). This covers relevant project information, relevant legislation, existing environmental conditions, assessment criteria and methods, assessment findings and proposed mitigation measures.

2. DESCRIPTION OF THE PROJECT

2.1 The Project proposes to replace the two existing twin cremators of the Fu Shan Crematorium. Replacement cremators will rectify the dark smoke emission problem and will comply with the latest environmental protection requirements. Key works of the Project comprise:

(a) Construction of a new cremation room with four flat-bed type single cremators designed to meet the latest EPD standards.

(b) Construction of a pulverising room with a bone cremulator for pulverisation of cremated remains.

(d) Construction of a public toilet as a replacement for the existing one.

(e) Provision of emergency generator room, main switch room, fire services pump room, sprinkler tank and storeroom, etc. necessary for the operation of the new cremators.

(f) Re-alignment of the existing vehicle access.

(g) Re-provision of car parking spaces and upgrading of the overall landscape area.

(h) Renovation of the two existing service halls to cater for the change in the location of the new cremation room.

(i) Demolition and removal of the existing cremators after the satisfactory commissioning of the new ones. Renovate the old cremation room into workshop for EMSD maintenance staff and storerooms.

(j) Installation of fire services provisions, including sprinkler system, hose reels, street hydrant etc. to the existing crematorium to meet current fire safety standards.

2.2 The project site lies within the site boundaries of the existing Fu Shan Crematorium, which is located in Area 18 of Shatin adjacent to Lower Shing Mun Road. The Fu Shan Crematorium site covers approximately 24,000 m² and is currently occupied by the existing crematorium, columbarium and staff quarters.

2.3 The new crematorium will be built as an extension to the southwestern side of the existing crematorium, which is currently occupied by a public toilet, car park and garden. A chimney structure of 19 metres high above the existing ground (and at least 3m higher than the physical structure of the new crematorium building and the immediate neighbor building of the existing crematorium) will merge at the base of the new crematorium. The new emergency generator room and main switch room will be located to the north-east of the existing crematorium and next to the existing transformer room respectively, providing upgrade of power supply for the new cremators. The proposed site layout plan is shown in Figure 2.1.

Description of the New Cremators

2.4 Four new flat-bed type single cremators will replace the existing two twin cremators. To cater for the varying sizes and weights of coffin to be handled, three cremators of design capacity 170kg and one cremator of 250kg maximum design capacity will be provided. Each cremation will last for 1-2 hours and the capacity of the crematorium is therefore 380 kg/hr to 760 kg/hr, i.e. maximum capacity of crematorium is 760 kg/hr. The maximum output of each cremator is 5 cremations per day. Since the total installed capacity of the 4 cremators is more than 500 kg/hr, the operation of the cremators will come under the control of a specified process licence.

2.5 Under the Air Pollution Control (Fuel Restriction) Regulation, the crematorium is in a “fuel restriction” area where the new cremator shall use town gas as fuel. There will be no gas storage on-site and gas supply will come directly from the gas company via pipelines. Also there will be no dangerous goods storage according to the Fire Protection Notice No.4-Dangerous Goods General issued by the Fire Services Department.

2.6 The replacement crematorium is designed in compliance with the latest edition of BPM 12/2 – A Guidance Note on the Best Practicable Means for Incinerators (Crematoria) issued by the EPD. The new cremator consists of two combustion chambers, namely primary and secondary chamber. The secondary chamber will have an operating temperature not less than 850°C and a residence time of more than 2 seconds. The concentration of oxygen at the outlet of the secondary combustion zone will be not less than 6% by volume (measured on wet basis) or an average of 6% by volume with a minimum of 3% by volume (measured on dry basis).

2.7 Dark smoke (primarily fine carbon particulate) as a result of incomplete combustion, and the entrainment of non-combustibles in the flue gas stream. To prevent the new cremator from emitting dark smoke, on the one hand the operating temperature and residence time in the secondary combustion chamber of the cremator will ensure complete combustion, on the other hand a flue gas filtering system consisting of bag filters will also be installed. When the particulate laden gas passes through the bags, particulates are retained on the upstream side of the fabric, thus cleaning the gas. Also, the emission smoke density from the cremator during normal operations (including start up and shut down) shall be continuously monitored and should not exceed Shade 1 on the Ringelmann Chart.

2.8 To further reduce the pollution emission, each cremator will be equipped with heat exchanger and a flue gas filtering plant of one-to-one arrangement at downstream side. The purpose of the heat exchanger is to cool down the flue gas in two stages from the cremator temperature of 850°C to a chimney exit temperature of 200°C. This temperature drop will discourage the generation of precursor radicals leading to the reformation of dioxins. In the first stage, the cool incoming air supplied for combustion will be pre-heated up to 300°C by the hot flue with the use of heat exchanger. The second stage will be a water-to-flue gas heat exchanger where cooling water is circulating in a closed circuit. The waste heat of cooling water will be conveyed to individual groups of remote radiator where the waste heat is disposed of to the atmosphere.

2.9 After passing through the heat exchanger, the flue gas enters the flue gas filtering plant that will clean up the specific pollutants in the gas stream. The flue gas filtering plant comprises a cyclone, an additive injection system, a conditioning rotor to recycle the additives and a flat bag filter, corresponding functions of key components are summarized in the table below. The mitigation measures stated in Sections 2.7 to 2.9 will be implemented under the control of the Specified Process Licence of the APCO.

Component	Key Features/ Functions
Cyclone	Separates the silt and sparks being carried over in the flue stream
Additive Injection System · Lime addition · 30% open hearth furnace coke or active carbon	· neutralizes acidic pollutants, e.g. HCl · removes precursor radicals of dioxin
Conditioning Rotor	Facilitates the taking place of the reaction between the additives and flue gas pollutants. Recycles the unused additives
Flat-Bag Filter	Filters the fine carbon particulates attributed to the dark smoke emission

2.10 The proposed flue gas filtering system involves only dry processes. There will be no wet scrubbing for flue gas from cremators and thus no wastewater will be discharged into the sewer.

2.11 The flue gas from each cremator after treatment will be separately ducted to a chimney structure of at least 19 metres above the formation level, which is higher than the physical structure of the new crematorium building, and the adjacent existing Fu Shan Crematorium by more than 3m. The exit flue gas will have an efflux velocity greater than 7 m/s at full load condition, and a temperature of 200°C that shall not be less than the acid dew point. Such requirements in compliance with the BPM 12/2 will come under control of a Specified Process licence of the APCO.

2.12 To maintain the uninterrupted crematorium services, the Project will be implemented under 2 stages as follows:

· Stage I: Construction of a new cremator plant room, new generator room, ancillary facilities, installation of four new single cremators, renovation of the existing service halls in the crematorium. A specified process licence will be obtained for the operation of the new cremators.

· Stage II: Demolition of the two existing twin cremators after the satisfactory commissioning of the new cremators and renovation of the old cremator rooms.

2.13 The programme of the Project will last from August 2002 to June 2004, taking 17 months for Stage I to construct the new cremators and 3 months for Stage II to demolish the old cremators. Table 2.1 shows the Project construction programme.

Table 2.1 Project Construction Programme

Project Construction Activity	From	To
Stage I construction	August 2002	December 2003
Commissioning of new cremators	January 2004	March 2004
Stage II construction	April 2004	June 2004
Operation of new cremators	April 2004	--

2.14 Upon completion of Stage I construction and obtaining the Specified Process licence, there will be a commissioning period of about 3 months to allow for testing of the new cremators that includes few trial cremations to verify design data. During the commissioning test period, there would be no more than 4 cremators in operation accounting for old and new cremators. Only upon satisfactory commissioning of the new cremators, the old cremators would cease operation and be demolished and removed. The new cremator is anticipated to be operational in April 2004.

Interactions with Other Projects

2.15 There are no other projects likely to interact with this proposed development.

Consideration of Alternative Sites

2.16 The FEHD propose to protect the environment by replacing the two old cremators with new ones. The new cremators will satisfy the latest stringent environmental emission requirements and the air quality of Shatin will be improved with the Project.There is an urgent need to replace the old cremators with new ones.

2.17 The Fu Shan Crematorium is well connected with different parts of Kowloon and New Territories. To replace the existing crematorium, the alternative site should be easily accessible by the public. In addition, the infrastructure requirements, including water and electricity supplies, drainage and sewerage system and road access, of the site need to be satisfied. The new crematorium should be environmentally compatible with the site, and should satisfy the statutory requirements on land.

2.18 FEHD has conducted a site search for the crematorium relocation but no readily available new sites were identified. This Project site has been selected in view of lesser environment impact and availability of land.

2.19 Building a new crematorium at an alternative site will have no improvement of the existing crematorium from an environmental point of view. Pursuing this option and at the same time meeting the increasing demand of cremation services, FEHD will have no choice to continue operating the old cremators for a certain long period. It takes more time to get the vacant and earmarked land for this type of facilities in relevant statutory plan. Also, a longer construction period is required for the new crematorium and the associated infrastructure. Dark smoke and pollutant would therefore continue to be emitted from the old cremators for a longer time.

2.20 Given that the existing crematorium facilities are readily available, replacing the old cremators at the existing crematorium will involve smaller number of construction activities and shorter construction period. The construction impact and disturbance would be reduced to a minimum. The old cremators could therefore be phased out in a short period of time.

2.21 Location of chimney is controlled by the operational constraints of the cremation process. It should be located close to the new crematorium building so as to minimise the amount of transfer of the coffin. Also, the chimney should be away from the sensitive receivers as far as practicable. A chimney is therefore proposed adjacent to the new crematorium building, which is close to the cremator and away from sensitive receivers including the existing staff quarters.

2.22 With the new cremators, satisfying the latest stringent environmental emission requirements, emission of pollutants from the facility would be reduced and the environment will be benefited. Replacement of old cremators at the existing site was welcomed by local residents and supported by the Shatin District Council, when they were consulted in July 2000.

3. ENVIRONMENTAL LEGISLATIONS, POLICIES, PLANS, STANDARDS AND CRITERIA

Environmental Impact Assessment

3.1 The Environmental Impact Assessment Ordinance (EIAO) requires all designated projects to be subject to the EIA process and applies to most of the major infrastructure projects. This Project involving the construction and operation of a crematorium is considered to be a designated project under Schedule 2, Part I (N.4) of the EIA Ordinance.

3.2 A Technical Memorandum on EIA Process issued under Section 16 of the EIA Ordinance (EIAO-TM) sets out the principles, procedures, guidelines requirements and criteria for preparing and reviewing an EIA report.

Air Quality

3.3 The criteria for evaluating air quality impacts and the guidelines for air quality assessment are laid out in Annex 4 and Annex 12 of the Technical Memorandum on Environmental Impact Assessment Process (EIAO-TM), respectively.

3.4 The Air Pollution Control Ordinance (APCO) provides the statutory authority for controlling air pollutants from a variety of sources. The Hong Kong Air Quality Objectives (AQOs) should be satisfied at the Hong Kong Special Administrative Region (HKSAR). The AQO stipulate the maximum allowable concentrations for typical pollutants, of which total suspended particulates (TSP), respirable suspended particulates (RSP), nitrogen dioxide (NO₂) and carbon monoxide are relevant to this EIA Study. The relevant AQOs are listed in Table 3.1.

Table 3.1 Hong Kong Air Quality Objectives

Pollutant	Maximum Average Concentration (µg m^-3) ⁽¹⁾
	1-Hour ⁽²⁾	8-Hour ⁽³⁾	24-Hour ⁽³⁾	Annual ⁽⁴⁾
TSP	^-	-	260	80
RSP ⁽⁵⁾	-	-	180	55
NO₂	300	-	150	80
CO	30,000	10,000	-----	-----

1. Measured at 298 K and 101.325 kPa.

2 Not to be exceeded more than three times per year.

3 Not to be exceeded more than once per year.

4. Arithmetic mean.

5 Suspended particulates in air with a nominal aerodynamic diameter of 10 mm or smaller.

3.5 The Technical Memorandum for Issuing Air Pollution Abatement Notices to Control Air Pollution From Stationary Polluting Process, stipulated that the Health Protection Concentration Level (HPCL) of chlorinated dioxins and dibenzofurans (expressed as 2,3,7,8 –TCDD) is 3.36 x 10^-5 mg/m³(hourly average).

3.6 In the absence of statutory guidelines in HKSAR for non-AQO pollutants, chronic and acute criteria from international organization, including the World Health Organization (WHO) and California Air Resources Board (CARB), are employed for this Study. The air quality criteria for non-AQO pollutants employed for this Study are shown in Table 3.2

Table 3.2 Air Quality Criteria for non-AQO Pollutants

Parameter	Unit	Criteria
Parameter	Unit	1 hour	Annual
Dioxins ⁽¹⁾	pgI-TEQ/m³	33.6⁽²⁾	3.5⁽³⁾
Hydrogen Chloride (HCl)	mg/m³	3,000 ⁽³⁾	7 ⁽³⁾
Mercury (Hg)	mg/m³	18 ⁽³⁾	1 ⁽⁴⁾

1. Expressed as TCDD-equivalent concentration of 2,3,7,8-tetrachlorobenzo dioxin (TCDD)

2. TM for Issuing Air Pollution Abatement Notices to Control Air Pollution From Stationary Polluting Processes

3. California Air Resources Board, California Environmental Protection Agency, 1999

4. Guidelines for Air Quality, World Health Organisation, 2000.

3.7 The EIAO-TM also stipulates that the hourly TSP level should not exceed 500 µgm^-3 (measured at 25°C and one atmosphere) for construction dust impact assessment. Mitigation measures from construction sites have been specified in the Air Pollution Control (Construction Dust) Regulations.

3.8 In accordance with the EIAO-TM, odour measured at a sensitive receiver should not exceed 5 odour units based on an averaging time of 5 seconds.

3.9 Under the Air Pollution Control (Specified Process) Regulation, incinerator (including cremator) with installed capacity exceeds 0.5 tonne per hour, is classified as a specified process, and a Specified Process licence is required for its operation.

3.10 The Air Pollution Control Ordinance provides legislative control on the removal of asbestos-containing materials. Under the APCO, The Environmental Protection Department (EPD) endorses the asbestos investigation report (AIR) and asbestos abatement plan (AAP) prepared in accordance with the relevant codes of practice by a registered asbestos consultant. The AAP specifies the proper asbestos abatement procedure that has incorporated mitigation measures to check the asbestos fibre release and hence to minimize the potential impact. Moreover, the APCO requires registered professionals to undertake, supervise, audit and air-monitor the asbestos abatement work.

3.11 Health risk from exposure to air toxics is not currently control by the HKSAR Risk guidelines for the assessment of health risk from exposures to air toxics are given by California Air Resources Board, California Environmental Protection Agency (CARB). Guidelines value on acceptability of increased cancer risk from a lifetime exposure to air toxics have been provided and are shown in Table 3.3.

Table 3.3 Health Risk Guidelines for Exposure to Air Toxics ⁽¹⁾

Acceptability of Cancer Risk	Estimated Individual Cancer Risk Level
Acceptability of Cancer Risk	Individual Lifetime Risk ⁽²⁾	Individual Risk Per Year
Significant	> 10 ^–4	> 1.4 x 10 ^–6
Risk should be reduced to As Low As Reasonably Practicable (ALARP)	> 10^-6 – 10^-4	> 1.4 x 10^-8 – 1.4 x 10 ^-6
Insignificant	10 ^–6	1.4 x 10 ^–8

(1) California Air Resources Board, California Environmental Protection Agency (CARB)

(2) Assumed as 70 years recommended by World Health Organization (WHO)

Land Contamination

3.12 Contaminated land assessment in Hong Kong is investigated under the EPD’s direction in accordance with their Practice Note for Professional Persons (ProPECC PN 3/94) Contaminated Land Assessment and Remediation, the EIAO TM, and EPD’s Guidance Notes for Investigation and Remediation of Contaminated Sites of Petrol Filling Stations, Boatyards and Car Repair / Dismantling Workshops (1999).

3.13 Under the EIAO TM, Annex 19: Guidelines for Assessment of Other Impacts, consideration shall be given to a number of potentially contaminating land uses, including petrol filling station, shipyards, car repair / dismantling workshops. Annex 19 provides guidance on developing a framework for a Contamination Assessment Plan (CAP), Contamination Assessment Report (CAR) and Remediation Action Plan (RAP) for land with a high contamination potential.

Waste Management

3.14 The following legislation relates to the handling, treatment and disposal of wastes in the Hong Kong SAR and will be used in assessing potential impacts:

· Waste Disposal Ordinance (Cap 354);

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

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

· Public Health and Municipal Services Ordinance (Cap 132) – Public Cleansing and Prevention of Nuisances Regulations

3.15 The following documents, circulars and guidelines which relate to waste management and disposal in Hong Kong SAR will also be referred to during the study:

· Waste Disposal Plan for Hong Kong (December 1989), Planning, Environment and Lands Branch, Hong Kong Government Secretariat;

· Environmental Guidelines for Planning in Hong Kong (1990), Hong Kong Planning Standards and Guidelines, Planning Department;

· New Disposal Arrangements For Construction Waste (1992), Environmental Protection Department and Civil Engineering Department;

· Code Of Practice On The Packaging, Labelling And Storage Of Chemical Wastes (1992), Environmental Protection Department;

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

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

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

· WBTC No. 16/96, Wet Soil in Public Dumps;

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

· WBTC No. 5/98, On Site Sorting Of Construction Waste On Demolition Sites;

· WBTC No. 5/99 & 5/99A, Trip-ticket System for Disposal of Construction and Demolition Material;

· WBTC No. 19/99, Metallic Site Hoardings and Signboards;

· WBTC No. 25/99, 25/99A & 25/99B, Incorporation of Information on Construction and Demolition Material Management in Public Works Subcommittee Papers;

· WBTC No. 12/2000, Fill Management;

· WBTC No. 29/2000, Waste Management Plan;

· Code of Practice on Asbestos Control (4 sets);

· Code of Practice – Safety and Health at Work with Asbestos; and

· Code of Practice on the Handling, Transportation and Disposal of Asbestos Waste.

Chemical Waste

3.16 Under the Waste Disposal (Chemical Waste) (General) Regulations all producers of chemical waste must register with the EPD and treat their wastes, either utilising on-site plant licensed by the EPD, or arranging for a licensed collector to transport the wastes to a licensed facility. The regulation also prescribes the storage facilities to be provided on site, including labelling and warning signs, and requires the preparation of written procedures and training to deal with emergencies such as spillages, leakages or accidents arising from the storage of chemical wastes.

Construction and Demolition (C&D) Materials

3.17 The current policy relating to the dumping of construction and demolition (C&D) material is documented in the Works Branch Technical Circular No.2/93, “Public Dumps”. Construction and demolition materials that are wholly inert, namely public fill should not be disposed of to landfill, but taken to public filling areas which usually form part of reclamation schemes. The Land (Miscellaneous Provision) Ordinance requires that dumping licenses are obtained by individuals or companies who deliver public fill to public filling areas. The licenses are issued by the Civil Engineering Department (CED) under delegated powers from the Director of Lands.

3.18 In addition to the Works Branch Technical Circular, EPD and CED have produced a leaflet entitled ‘New Disposal Arrangements for Construction Waste’ (1992) which states that C&D material with less than 30% by weight (or 20% inert material by volume) of inert material (i.e. public fill) will be accepted at landfill. If the material contains more than 30% inert material, the waste must be sorted and sent to a public filling area and the non-inert material (i.e. C&D waste) can be sent to landfill for final disposal.

Landscape and Visual

3.19 Environmental legislation in relation to landscape and visual aspects is guided by the EIAO. The criteria for evaluating Landscape and Visual Impacts are laid out in the EIAO-TM. The relevant criteria for Landscape and Visual Impacts are defined in the following sections of the EIAO-TM:

· Annex 10 : Criteria for Evaluating Visual and Landscape Impact, and Impact on Sites of Cultural Heritage

· Annex 18 : Guidelines for Landscape and Visual Impact Assessment

3.20 Government guidelines on the preservation and felling of trees in Hong Kong are detailed in Government General Regulation 740, Works Branch Technical Circular No. 24/94 and Planning, Environment and Lands Branch Technical Circular No. 3/94. Documents that are also relevant to landscape and visual aspects include WBTC 25/93 on Control of Visual Impact of Slopes, WBTC 18/94 on Management and Maintenance of both Vegetation and Landscape Works, WBTC 17/2000 on Improvement to the Appearance of Slopes and HyDTC No. 6/98 on Visibility of Directional signs.

Water Quality

3.21 The Water Pollution Control Ordinance (Cap.358) provides the major statutory framework for the protection and control of water quality in Hong Kong. According to the Ordinance and its subsidiary legislation, all Hong Kong waters are divided into Water Control Zones (WCZ).

3.22 All discharges during the construction phase are required to comply with the Technical Memorandum (TM) on Standards for Effluents Discharged into Drainage and Sewerage Systems, Inland and Coastal Waters issued under Section 21 of the WPCO which defines acceptable discharge limits to different types of receiving waters. Under the TM, effluents discharged into foul sewers, storm water drains, inland and coastal waters are subject to pollutant concentration standards for particular volumes of discharge. These are defined by EPD and specified in licence conditions for any new discharge within a WCZ.

Hazard to Life

3.23 Chapter 11 of the Hong Kong Planning Standards and Guidelines (HKPSG) requires risk assessment for the potentially hazardous installation (PHI). By definition, a PHI is an installation which stores hazardous materials in quantities equal to or greater than a substance-specified threshold quantity, Relevant to this study, the threshold quantity for Town Gas installation is 15 tonnes.

4. AIR QUALITY IMPACT ASSESSMENT

4.1 This Section presents an assessment of air quality impact from the construction and operation of the Project. Air Sensitive Receivers (ASRs) have been identified and their respective impacts have been assessed, on a worst-case scenario basis.

4.2 Construction dust from the dusty activities and chimney emissions from the operation of cremators are major areas of concern for this Project. The air quality impacts, from both the construction and operation of the crematorium, have been assessed quantitatively in this Section. Mitigation measures, where necessary, have been recommended to ensure that the environmental legislation, standards and criteria, stipulated in Section 3, are satisfied. Environmental Monitoring and Audit (EM&A) requirements of the Project have been proposed and described in Section 10, to ensure the specified criteria are satisfied.

Description of the Environment

Baseline Conditions

4.3 The study area is located in the Sha Tin airshed. Under the Air Pollution Control (Fuel Restriction) Regulation, only gaseous fuel is allowed in the Shatin area. Air quality of the study area is mainly affected by the traffic emissions from the existing road networks. Emissions from the existing crematorium also contribute to the pollutants of the area.

4.4 The EPD’s Sha Tin Air Quality Monitoring Station is located at the rooftop of Sha Tin Government Secondary School. Concentration of Total Suspended Particulates (TSP), Respirable Suspended Particulates (RSP) and nitrogen dioxide (NO₂) are monitored in the station. The long-term (annual) and short-term AQO (in terms of TSP, RSP and NO₂) were satisfied at the station in 2000. The annual average concentrations, measured at the Shatin Station have been selected as the background of the area, and their values are listed in Table 4.1. Both carbon monoxide (CO) and dioxins are not monitored in the station, and the annual average levels of the two parameters monitored at the Tsuen Wan Station have been employed as background for this Study.

Table 4.1 Annual Average Concentrations of Pollutants (2000)

Pollutants	Monitoring Station	Annual Average
TSP	Shatin	58 mgm^-3
RSP	Shatin	46 mgm^-3
NO₂	Shatin	46 mgm^-3
CO	Tsuen Wan	915mgm^-3
Dioxins ⁽¹⁾	Tsuen Wan	0.061 pg I-TEQ m^-3

1. Expressed as TCDD-equivalent concentration of 2,3,7,8-tetrachlorobenzo dioxin (TCDD).

Chimney Emissions

4.5 The existing Fu Shan Crematorium, comprising four cremators, is a pollutant source of the Shatin and dark smoke is emitted from the facility during some periods. Measurements of the pollutant concentrations from the stack have been conducted for the existing crematorium on 27 March 2001. During the measurement periods, only one cremator was operated. Other cremators were either inactive or under maintenance. Concentrations of particulate matters, hydrogen chloride (HCl), carbon monoxide (CO), total organic compounds (TOC), dioxins and furans have been measured and their results are summarised in Table 4.2.

Table 4.2 Results of Stack Emission Measurements

Pollutants	Measured Emission Concentration (mg/m³) ⁽¹⁾
Particulate matter	48 mg/m³
HCl	9 mg/m³
CO	276 mg/m^{3 (2)}
TOC	0.015 mg/m³
Dioxins and furans ⁽³⁾	0.53 ng I-TEQ /m³

(1) Expressed as reference conditions of dry, 0^oC, 101.325kPa, 11% O₂.

(2) Figure in italic exceeded the BPM requirement.

(3) Expressed as TCDD-equivalent concentration of 2,3,7,8-tetrachlorobenzo dioxin (TCDD)

4.6 Low levels of dioxins and furans were emitted from the existing crematorium. A number of dioxin and furan congeners have been shown to exert a number of toxic responses similar to those of 2,3,7,8-tetrachlorodibenzo-dioxin (TCDD), the most toxic dioxin. Levels of dioxins and furans are usually expressed as toxic equivalent (I-TEQ) concentration of 2,3,7,8-TCDD, based on the International Toxic Equivalent Factors (I-TEF) of the North Atlantic Treaty Organisation (NATO/CCMS), 1988. Appendix 4.1 shows the calculation of dioxin and furan toxic equivalents.

4.7 It is understood that pollutant emissions from the cremator are controlled by weight and composition of coffin (e.g. thickness of lacquer applied). The amount and type of mementos being incinerated would also contribute to the emission of the pollutants. The results of stack emission measurements, listed in Table 4.2 above, are typical emission concentration from the facility. Higher concentration of pollutants may be emitted from the crematorium, under worst case scenario. However, the measured emission data did indicate that the CO emission from the facility is high and exceeds the EPD’s current BPM requirement. CO is a product of incomplete combustion and its presence is related to insufficient oxygen, residence time, temperature and turbulence in the combustion zone. The new cremators will provide adequate oxygen, temperature, residence time and turbulence to control emissions from the facility, and satisfy the BPM concentration limits. It is expected that phasing out the old creators with new one will reduce emission from the facility and therefore improve the air quality of the area.

Air Sensitive Receivers

4.8 Ten representative Air Sensitive Receivers (ASRs), including a school, residential areas, and G/IC areas, have been identified for this assessment in accordance with the criteria set out in the EIAO-TM. Description of the ASRs and their horizontal distance from the crematorium are listed in Table 4.3. Locations of the ASRS are shown in Figure 4.1. It is understood that ASR A10 will not be developed until 2004, and the receiver is therefore identified as ASR during the operation phase only.

Table 4.3 Air Sensitive Receivers

ASRs	Description	Distance (m)⁽¹⁾	Elevation (mPD)	No. of floors	Land Uses
A1	Village in Lower Shing Mun Road	134	47	1	Residential
A2	Staff Quarter	96	67	2	Residential
A3	Lakeview Garden (House 1)	270	165	3	Residential
A4	Lakeview Garden (Block 5)	357	155	7	Residential
A5	Po Leung Kuk Y. C. Cheng Centre	425	87	3	G/IC
A6	Fu Shan Public Mortuary	282	93	4	G/IC
A7	Heung Fan Liu Village/ Proposed CDA site	235	21/ 17	1/ 19 – 21⁽²⁾	Residential
A8	Granville Garden	498	20	29 + 5 storeys of car parks	Residential
A9	Area 38A Development⁽³⁾	483	48	8	School
A10	Area 4C Development ⁽³⁾	255	14	40	Residential

(1) Distance measured from the chimney to the site boundary of ASRs.

(2) Source: Master Layout Plan of the Proposed CDA site

(3) Areas 4C & 38A Developments are to be developed for schools, Home Ownership Scheme (HOS) and Public Housing Estate, 8 and 40 numbers of floor were assumed for schools and residential blocks respectively.

Assessment Methodologies

Construction Phase

4.9 Potential impacts arising from the construction of cremators include dust nuisance and gaseous emissions from the construction plant and vehicles. It is expected that dust would be generated from foundation works, site clearance, excavation, material handling and wind erosion.

4.10 The Fugitive Dust Model (FDM) was used to assess the potential dust impacts from dusty construction activities. Prediction of dust emissions was based on emission factors from USEPA Compilation of Air Pollution Emission Factors (AP-42), 5^th Edition. General construction activities (comprising foundation, site clearance and excavation) and wind erosion of open sites were considered to be the major dust emission sources from the construction work in this study. Demolition works will be conducted inside the existing crematorium, involving no structural demolition. Dust emissions from the demolition works will be low.

4.11 The dust emission factors adopted in this assessment are given in Table 4.4. Detailed calculations of the emission factors are provided in Appendix 4.2.

Table 4.4 Dust Emission Factors

Activities	Dust Emission Factor
General construction activities	2.69 Mg/hectare/month (Section 13.2.3) ⁽¹⁾
Wind erosion of open site	0.85 Mg/hectare/year (Table 11.9.4) ⁽¹⁾

(1) Reference to AP-42, 5^th Edition

4.12 The Air Pollution Control (Construction Dust) Regulation specified that reduction measures such as watering should be applied for the construction site. The control measures could reduce dust emission from the site by 50% and was assumed in the FDM model.

4.13 Hourly average and 24-hour average TSP concentrations were predicted at the ASRs. A ten hour working day was assumed in the assessment.

4.14 The dispersion model was undertaken for 288 predetermined meteorological conditions. The following meteorological conditions have been assumed in the model. Highest dust impact at each ASRs, under their respective worst meteorological conditions, was predicted by the FDM model.

· Wind speed : 1 and 2 m/s

· Wind direction : 0- 360^o with resolution of 5^o

· Stability class : B & D for daytime; D & F for night time

· Surface roughness : 1 m

· Mixing height : 500 m

4.15 Background TSP concentration of 58 mg m^-3 has been included in the modelling results to account for the cumulative impact.

4.16 A sample output file of the FDM model run, which includes all the input information and model parameters for this assessment, is presented in Appendix 4.3.

Asbestos Fibre

4.17 Given the legislative control on asbestos in place, the impact of asbestos fibre was assessed by reviewing the mitigation measures as stipulated by the current ordinance and regulation. Adequacy of mitigation measure has been reviewed and the significance of impact was predicted.

Operation Phase

Design of Crematorium

4.18 A total of four cremators (three 170 kg cremators and one 250 kg cremator) will be provided. The exhaust flue gases will be discharged via a multi-flue chimney (at 19m above ground), with exit temperature of 200 °C and exit velocity of 7 m s^-1. The emission rates of the cremators are:

· 2500 m³/ hr (at 6.3% O₂ and 15.5 % H₂O) for the 170 kg cremator1; and

· 4600 m³/ hr (at 11% O₂ and 12.7% H₂O) for the 250 kg cremator1.

4.19 The emission rates, corrected to reference condition of 273 K, 101.3 kPa, 11% O₂ and dry condition, are calculated to be 1654 m³/hr for the 170 kg cremator and 1926 m³/hr for the 250 kg cremator.

4.20 The new cremators are equipped with air pollution control devices to reduce emission of air pollutants to acceptable levels. The latest BPM 12/2 emission concentration limits will be satisfied for the new cremators. Adoption of the BPM 12/2 emission concentration limits will ensure adequate protection of human health and the environment.

4.21 Both the ArchSD and FEHD are committed to minimize pollutant emissions, and state-of-art cremators will be installed. The final selection of cremators will be subject to competitive tendering with the successful supplier selected on the basis of various factors, including the ability to meet the pre-determined performance specification with respect to emissions. In the commercial market, cremators satisfying the German Emission Standards are available. The German Emission standards are more stringent than the BPM 12/2 emission concentration limits and a comparison of the two standards is shown Table 4.5.

4.22 Mercury (Hg) emission is not currently controlled by the BPM 12/2. There are public concerns on mercury exposure, mainly attributed to dental fillings, on cremation of human remains. Mercury, due to its high vapour pressure, could not be controlled by particle enrichment (usually employed for metal emissions) and is emitted largely in the vapour form. It is proposed by some Federal States in Germany that the mercury emission from cremator should be limited to 0.2 mg/m³.

4.23 The design of the new cremators will satisfy the German Emission Standards, including the proposed mercury emission limit.

4.24 The FEHD targets to satisfy the German Emission Standards listed in Table 4.5, in the long run. Training and instructions in relation to the control of the process and emissions of air pollutants will be provided to crematory staff at all levels, to ensure that the cremators are operated according to the manufacturer’s instructions. Effective regular maintenance will be employed on the cremators and associated equipment. Other control measures will also be exploited to ensure that the target emission limits are satisfied.

4.25 With the new cremators, the current pollutant emissions will be reduced and the latest BPM 12/2 emission concentration limits will be satisfied at all times. With the target emission limits achieved in the long run, it is likely that cremator emissions could be further reduced.

4.26 This air quality assessment was conducted based on the worst case scenario of the new cremators, i.e. BPM 12/2 concentration limits. Air quality impact of the mercury emission was also assessed against the international criteria in this EIA Study.

Table 4.5 Emission Concentrations of Pollutants

Pollutant	Emission Concentration ⁽¹⁾
	BPM 12/2 Limit	Target Emission Limit ⁽²⁾
Particulate Matter	100 mg/m³	10 mg/m³
HCl	100 mg/m³	10 mg/m³
CO	100 mg/m³	50 mg/m³
TOC	20 mg/m³	20 mg/m³
Hg	-	0.2 mg/m³
Dioxins ⁽³⁾	1 ng/m³	0.1 ng/m³

(1) Expressed at reference conditions of 0^oC, 101.325 kPa, 11% O₂ and dry conditions.

(2) Germany Emission Standards for Cremator.

(3) Expressed as TCDD-equivalent concentration of 2,3,7,8-tetrachlorobenzo dioxin (TCDD)

Pollutant Emission Rates

4.27 The concentration limits stipulated in the BPM 12/2, were assumed in this assessment, as a conservative approach. Mercury emission limit of 0.2 mg/m³ was also assumed for the cremators. The emission rates of cremators employed in the Study are summarised in Table 4.6. It is assumed that the size of particulate matter emitted from the chimney is less than 10 mm (i.e. within the RSP category), and emission limit of particulate matter, 100 mg/m³, is assumed for RSP.

Table 4.6 Concentration Limits of Crematorium

Parameter	Concentration Limit (mg/m³) ⁽¹⁾	Emission Rates (g/s)
Parameter	Concentration Limit (mg/m³) ⁽¹⁾	170 kg cremator ⁽²⁾	250 kg cremator ⁽³⁾
RSP	100 mg/m³	4.59 x 10^-2	5.35 x 10^-2
HCl	100 mg/m³	4.59 x 10^-2	5.35 x 10^-2
CO	100 mg/m³	4.59 x 10^-2	5.35 x 10^-2
TOC	20 mg/m³	9.19 x 10^-3	1.07 x 10^-2
Hg	0.2 mg/m³	9.19 x 10^-5	1.07 x 10^-4
Dioxins ⁽⁴⁾	1 ng/m³	4.59 x 10 ^–10	5.35 x10^-10

(1) Expressed as reference condition of 0^oC, 101.325 kPa, 11% O₂ and dry condition.

(2) Flow rate of 1654 m³/hr at reference conditions.

(3) Flow rate of 1926 m³/hr at reference conditions.

(4) Expressed as TCDD-equivalent concentration of 2,3,7,8-tetrachlorobenzo dioxin (TCDD)

Air Dispersion Model

4.28 Air quality impacts of the chimney emissions were modelled with the US EPA approved air dispersion model, Industrial Source Complex Short-Term (ISCST3). Concentrations of RSP, CO, HCl, TOC, Hg, and dioxins have been modelled. Hourly meteorological data for the year 2000 (including wind speed, wind direction, air temperature, Pasquill stability class and mixing height) of the Shatin Weather Station were provided by the Hong Kong Observatory and have been employed for the model run. The ISCST3 model simulated the pollutant concentrations at the ASRs for each hourly meteorological data in year 2000, and the worst case scenario have been predicted by the model.

4.29 The crematorium operates between 09:30 hours and 18:00 hours, and a maximum of 5 cremations will be conducted for each cremator. It was assumed in the air dispersion model that the cremators would be operated in full capacity with maximum load during the operation hour, as a worst case scenario.

4.30 Sample output files of the ISCST3 model are given in Appendix 4.4.

Health Risk Analysis

4.31 Health risk assessment has been calculated based on the risk imposed by toxic air pollutants (TAP). The increase cancer risk due to exposure of TAP is determined by multiplying the increase in predicted annual average of the TAP concentration with its unit risk factor. The California Environmental Protection Agency, 1999 has identified that the unit factor of dioxins (expressed as 2.3.7.8 – TCDD) associated to lifetime exposure of 70 years to be 38 (mg m^-3)^-1, and the value is considered up-to-date (during preparation of this report, the addendum of 9^th report on Carcinogens from US National Toxicology Program made in early 2001 was reviewed and no amendment was noted on the year 1999 figure of unit risk factor) and employed for this assessment. The predicted value is compared with the health risk guideline indicated in Table 3.3.

Odour

4.32 The coffin is delivered by mortuary vehicle outside the ceremony hall. It is brought to the hall immediately, and exposure of human remains in air is not expected. The coffin stays at the ceremony hall during the farewell ceremony, and is delivered to the cremation hall afterwards. All the processes are conducted in an enclosed environment, and odour emission from the crematorium building is not expected.

4.33 The new cremators are designed to ensure complete combustion and are fitted with a secondary combustion zone at high temperature. All cremators are operated at negative pressure and are designed with adequate secondary air in the primary combustion zone to ensure good turbulence and combustion. The gases are held at 850^oC for minimum of 2 seconds in the secondary combustion zone. Odorous gases exist in organic forms; the gases will be broken down into simple substances, under such high temperature with sufficient residence time. With the negative pressure along the cremator, leakage of odorous gas is also not expected. The subsequent flue gas filtering system would also remove any trace amount of odorous gas that escapes from the combustion chamber. Odour emission from the cremators is therefore unlikely.

Environmental Impact Identification, Prediction and Evaluation

Construction phase

4.34 Construction dust impacts at the ASRs have been predicted for this assessment. Both the 1-hour and 24-hour average TSP concentrations have been assessed. The worst impacted height (i.e. same elevation as the source) has been predicted and the results are shown in Table 4.7. As discussed in Section 4.8, ASR A10 will not be operated until year 2004, and its impact is therefore not assessed for the construction phase.

Table 4.7 Predicted Maximum TSP Concentrations

ASR	Elevation (mPD)	Maximum TSP Level (mg/m³) ⁽¹⁾
ASR	Elevation (mPD)	1-hr	24-hr
A1	47	152	100
A2	67	191	117
A3	165	77	67
A4	155	70	64
A5	87	67	62
A6	93	77	67
A7	21	89	72
A8	20	65	61
A9	48	66	61

(1) Background TSP level of 58 mg/m³ included in the figure.

4.35 It has been predicted that TSP levels at the ASRs are low, and comply with the hourly criteria of 500 mg/m³ and daily criteria of 260 mg/m³. Maximum hourly TSP level of 191 mg/m³and daily TSP level of 117 mg/m³have been predicted at ASR A2. Contours of hourly and daily average TSP concentrations are presented in Figures 4.2 and 4.3. They confirmed that the construction TSP impacts are low in the study area. No further mitigation is therefore required.

Asbestos Fibre

4.36 Under the APCO, the asbestos-containing material (ACM) should be removed in accordance with the AAP. The AAP has specified all necessary precautionary and mitigation measures to control the asbestos fibre release during the removal work. The precautionary and mitigation measures include:

· Work area segregation,

· Containment for the removal of friable ACM,

· Provision of personal decontamination facility,

· Use of personal respiratory/ protection equipment,

· Adequate but not excessive water-spraying on the ACM being removed,

· Use of vacuum cleaner equipped with high-efficiency air particulate (HEPA) filter for the area cleanup, and

· Air monitoring during the asbestos abatement work.

4.37 With the legal regulation in force, the impact due to the asbestos fibre is considered insignificant. The APCO requires the appointment of :

· a registered asbestos contractor to carry out,

· a registered asbestos supervisor to supervise,

· a registered asbestos laboratory to air-monitor, and

· a registered asbestos consultant supervise the carrying out of and to certify the asbestos abatement work.

Operation Phase

4.38 Air quality impacts of RSP, CO, HCl, TOC, Hg, and dioxins have been predicted at the ASRs. A10 and A4 have been identified as the worst impacted ASRs, and their pollutant concentrations are shown in Table 4.8.

Table 4.8 Maximum Pollutant Concentration at the Worst Impacted ASRs

Pollutant	Worst Impacted ASR/ height above ground (m)	Averaging Time	Concentration (mg/m³) ⁽¹⁾	Criteria (mg/m³)
RSP	A4/ 1.5m	24 hour 1 year	60 48	180 55
CO	A10/ 90 m	1 hour 8 hour	1110 947	30000 10000
HCl	A10/ 90 m A4/1.5m	1 hour 1 year	195 2.2	3000 7
TOC	A10/ 90 m	1 hour	39	-
Hg	A10/ 90 m A4/1.5m	1 hour 1 year	0.39 0.004	18 1
Dioxins ⁽²⁾	A10/ 90 m A4/ 1.5 m	1 hour 1 year	2.0 x 10^-6 8.3 x 10^–8	3.36 x 10^-5 3.5 x 10^-6

Pollutant

Worst Impacted ASR/ height above ground (m)

Averaging Time

Concentration (mg/m³) ⁽¹⁾

Criteria

(mg/m³)

RSP

A4/ 1.5m

24 hour

1 year

180

A10/ 90 m

1 hour

8 hour

1110

947

30000

10000

HCl

A10/ 90 m

A4/1.5m

1 hour

1 year

195

2.2

3000

TOC

A10/ 90 m

1 hour

A10/ 90 m

A4/1.5m

1 hour

1 year

0.39

0.004

Dioxins ⁽²⁾

A10/ 90 m

A4/ 1.5 m

1 hour

1 year

2.0 x 10^-6

8.3 x 10^–8

3.36 x 10^-5

3.5 x 10^-6

(1) Background included for RSP, CO and dioxins in the figure.

(2) Expressed as TCDD-equivalent concentration of 2,3,7,8-tetrachlorobenzo dioxin (TCDD)

4.39 It has been assessed that the air quality impacts at the worst impacted ASRs will be low. Under the worst case scenario, the air quality criteria would be satisfied at the worst impacted ASRs. This assessment assumed that the cremators are operated in full, and that the highest allowable concentrations of pollutants are emitted.

4.40 Table 4.9 – Table 4.19 presents the predicted air quality impacts at the ASRs. Modelling results indicated that the air quality criteria would be satisfied at all ASRs, during the operation of the Fu Shan Crematorium.

4.41 Contours of the hourly average of gaseous pollutants (CO, HCl, TOC Hg and dioxins) and daily average of RSP at the worst affected heights, 90 m above local ground of A10 (i.e. 103.5 mPD) have been plotted and are shown in Figures 4.4-4.9. They confirm that the air pollutants emitted from the crematorium will not cause exceedance of air quality criteria near the site.

Table 4.9 Daily RSP Concentration at ASR

ASR	Concentration (mg m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	46	--	--	--	--	--	--	--	--	--	--	--	--
A2	48	50	--	--	--	--	--	--	--	--	--	--	--
A3	53	53	--	--	--	--	--	--	--	--	--	--	--
A4	60	59	54	--	--	--	--	--	--	--	--	--	--
A5	48	50	--	--	--	--	--	--	--	--	--	--	--
A6	49	53	--	--	--	--	--	--	--	--	--	--	--
A7	46	46	46	46	47	47	48	51	54	--	--	--	--
A8	46	46	46	47	47	48	49	50	54	53	50	--	--
A9	46	46	46	--	--	--	--	--	--	--	--	--	--
A10	46	46	46	46	46	47	47	48	50	59	57	48	47

* Background PM concentration of 46 mgm^-3 is included.

-- No air sensitive receiver is located at this elevation.

Table 4.10 Annual RSP Concentration at ASR

ASR	Concentration (mg m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	46	--	--	--	--	--	--	--	--	--	--	--	--
A2	46	46	--	--	--	--	--	--	--	--	--	--	--
A3	47	47	--	--	--	--	--	--	--	--	--	--	--
A4	48	48	47	--	--	--	--	--	--	--	--	--	--
A5	46	46	--	--	--	--	--	--	--	--	--	--	--
A6	46	46	--	--	--	--	--	--	--	--	--	--	--
A7	46	46	46	46	46	46	46	46	47	--	--	--	--
A8	46	46	46	46	46	46	46	46	47	47	46	--	--
A9	46	46	46	--	--	--	--	--	--	--	--	--	--
A10	46	46	46	46	46	46	46	46	46	46	46	46	46

* Background PM concentration of 46 mgm^-3 is included.

--No air sensitive receiver is located at this elevation.

Table 4.11 Hourly CO Concentration at ASR

ASR	Concentration (mg m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	917	--	--	--	--	--	--	--	--	--	--	--	--
A2	925	932	--	--	--	--	--	--	--	--	--	--	--
A3	964	968	--	--	--	--	--	--	--	--	--	--	--
A4	955	954	948	--	--	--	--	--	--	--	--	--	--
A5	970	978	--	--	--	--	--	--	--	--	--	--	--
A6	988	993	--	--	--	--	--	--	--	--	--	--	--
A7	916	916	917	918	919	922	931	968	1022	--	--	--	--
A8	918	918	919	919	920	923	932	943	996	1018	969	--	--
A9	921	921	922	--	--	--	--	--	--	--	--	--	--
A10	917	917	917	918	920	921	925	948	977	1110	1083	951	924

* Background CO concentration of 915 mg m^-3 is included.

-- No air sensitive receiver is located at this elevation.

Table 4.12 8-hour Average CO Concentration at ASR

ASR	Concentration (mg m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	915	--	--	--	--	--	--	--	--	--	--	--	--
A2	919	928	--	--	--	--	--	--	--	--	--	--	--
A3	933	936	--	--	--	--	--	--	--	--	--	--	--
A4	936	935	932	--	--	--	--	--	--	--	--	--	--
A5	922	926	--	--	--	--	--	--	--	--	--	--	--
A6	924	931	--	--	--	--	--	--	--	--	--	--	--
A7	915	915	915	916	916	917	919	924	939	--	--	--	--
A8	916	916	916	916	917	918	919	922	931	930	922	--	--
A9	916	916	916	--	--	--	--	--	--	--	--	--	--
A10	915	915	916	916	916	916	917	921	926	947	943	921	917

* BackgroundCO concentration of 915 mg m^-3 is included.

-- No air sensitive receiver is located at this elevation.

Table 4.13 Hourly HCl Concentrations at ASR

ASR	Concentration (mg m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	1.8	--	--	--	--	--	--	--	--	--	--	--	--
A2	9.7	16.8	--	--	--	--	--	--	--	--	--	--	--
A3	49.1	52.9	--	--	--	--	--	--	--	--	--	--	--
A4	40.1	39.3	33.5	--	--	--	--	--	--	--	--	--	--
A5	55.1	63.1	--	--	--	--	--	--	--	--	--	--	--
A6	73.2	78.4	--	--	--	--	--	--	--	--	--	--	--
A7	1.2	1.4	2.1	3.1	4.5	7.3	16.2	53.4	106.6	--	--	--	--
A8	3.3	3.5	3.8	4.3	4.9	8.2	16.6	28.2	81.5	103.1	53.9	--	--
A9	6.1	6.2	6.9	--	--	--	--	--	--	--	--	--	--
A10	1.6	1.8	2.5	3.4	4.7	6.3	9.5	33.4	62.4	194.8	168.0	36.2	8.5

* Background not included in the figure.

-- No air sensitive receiver is located at this elevation.

Table 4.14 Annual HCl Concentration at ASR

ASR	Concentration (mg m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	0.0	--	--	--	--	--	--	--	--	--	--	--	--
A2	0.1	0.4	--	--	--	--	--	--	--	--	--	--	--
A3	0.9	0.9	--	--	--	--	--	--	--	--	--	--	--
A4	2.2	2.1	1.4	--	--	--	--	--	--	--	--	--	--
A5	0.1	0.2	--	--	--	--	--	--	--	--	--	--	--
A6	0.2	0.4	--	--	--	--	--	--	--	--	--	--	--
A7	0.0	0.0	0.0	0.0	0.0	0.0	0.1	0.2	0.6	--	--	--	--
A8	0.0	0.0	0.0	0.1	0.1	0.2	0.3	0.4	0.6	0.5	0.3	--	--
A9	0.0	0.0	0.0	--	--	--	--	--	--	--	--	--	--
A10	0.0	0.0	0.0	0.0	0.0	0.0	0.1	0.1	0.2	0.4	0.3	0.1	0.0

* Background not included in the figure.

-- No air sensitive receiver is located at this elevation.

Table 4.15 Hourly TOC Concentration at ASR

ASR	Concentration (mg m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	0.4	--	--	--	--	--	--	--	--	--	--	--	--
A2	1.9	3.4	--	--	--	--	--	--	--	--	--	--	--
A3	9.8	10.6	--	--	--	--	--	--	--	--	--	--	--
A4	8.0	7.9	6.7	--	--	--	--	--	--	--	--	--	--
A5	11.0	12.6	--	--	--	--	--	--	--	--	--	--	--
A6	14.6	15.7	--	--	--	--	--	--	--	--	--	--	--
A7	0.2	0.3	0.4	0.6	0.9	1.5	3.2	10.7	21.3	--	--	--	--
A8	0.7	0.7	0.8	0.9	1.0	1.6	3.3	5.6	16.3	20.6	10.8	--	--
A9	1.2	1.2	1.4	--	--	--	--	--	--	--	--	--	--
A10	0.3	0.4	0.5	0.7	0.9	1.3	1.9	6.7	12.5	39.0	33.6	7.2	1.7

*Background not included in the figure.

-- No air sensitive receiver is located at this elevation.

Table 4.16 Hourly Hg Concentration at ASR

ASR	Concentration (mg m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	0.00	--	--	--	--	--	--	--	--	--	--	--	--
A2	0.02	0.03	--	--	--	--	--	--	--	--	--	--	--
A3	0.1007	0.1108	--	--	--	--	--	--	--	--	--	--	--
A4	0.086	0.086	0.075	--	--	--	--	--	--	--	--	--	--
A5	0.1109	0.131	--	--	--	--	--	--	--	--	--	--	--
A6	0.152	0.163	--	--	--	--	--	--	--	--	--	--	--
A7	0.00	0.00	0.00	0.01	0.01	0.01	0.03	0.11	0.21	--	--	--	--
A8	0.01	0.01	0.01	0.01	0.01	0.02	0.03	0.06	0.16	0.21	0.11	--	--
A9	0.01	0.01	0.01	--	--	--	--	--	--	--	--	--	--
A10	0.00	0.00	0.00	0.01	0.01	0.01	0.02	0.07	0.12	0.39	0.34	0.07	0.02

* Background not included in the figure.

--No air sensitive receiver is located at this elevation.

Table 4.17 Annual Hg Concentration at ASR

ASR	Concentration (mg m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	0.000	--	--	--	--	--	--	--	--	--	--	--	--
A2	0.000	0.001	--	--	--	--	--	--	--	--	--	--	--
A3	0.002	0.002	--	--	--	--	--	--	--	--	--	--	--
A4	0.004	0.004	0.003	--	--	--	--	--	--	--	--	--	--
A5	0.000	0.000	--	--	--	--	--	--	--	--	--	--	--
A6	0.000	0.001	--	--	--	--	--	--	--	--	--	--	--
A7	0.000	0.000	0.000	0.000	0.000	0.000	0.000	0.000	0.001	--	--	--	--
A8	0.000	0.000	0.000	0.000	0.000	0.000	0.001	0.001	0.001	0.001	0.001	--	--
A9	0.000	0.000	0.000	--	--	--	--	--	--	--	--	--	--
A10	0.000	0.000	0.000	0.000	0.000	0.000	0.000	0.000	0.000	0.001	0.001	0.000	0.000

* Background not included in the figure.

--No air sensitive receiver is located at this elevation.

Table 4.18 Hourly Dioxin Concentration at ASR

ASR	Concentration (pg m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	0.08	--	--	--	--	--	--	--	--	--	--	--	--
A2	0.16	0.23	--	--	--	--	--	--	--	--	--	--	--
A3	0.55	0.59	--	--	--	--	--	--	--	--	--	--	--
A4	0.46	0.45	0.40	--	--	--	--	--	--	--	--	--	--
A5	0.61	0.69	--	--	--	--	--	--	--	--	--	--	--
A6	0.79	0.84	--	--	--	--	--	--	--	--	--	--	--
A7	0.07	0.08	0.08	0.09	0.11	0.13	0.22	0.59	1.13	--	--	--	--
A8	0.09	0.10	0.10	0.10	0.11	0.14	0.23	0.34	0.88	1.09	0.60	--	--
A9	0.12	0.12	0.13	--	--	--	--	--	--	--	--	--	--
A10	0.08	0.08	0.09	0.10	0.11	0.12	0.16	0.40	0.68	2.01	1.74	0.42	0.15

* Background dioxin concentration of 0.061 pgm^-3 is included.

--No air sensitive receiver is located at this elevation.

Table 4.19 Annual Dioxin Concentration at ASR

ASR	Concentration (pg I-TEQ m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	0.06	--	--	--	--	--	--	--	--	--	--	--	--
A2	0.06	0.07	--	--	--	--	--	--	--	--	--	--	--
A3	0.07	0.07	--	--	--	--	--	--	--	--	--	--	--
A4	0.08	0.08	0.07	--	--	--	--	--	--	--	--	--	--
A5	0.06	0.06	--	--	--	--	--	--	--	--	--	--	--
A6	0.06	0.07	--	--	--	--	--	--	--	--	--	--	--
A7	0.06	0.06	0.06	0.06	0.06	0.06	0.06	0.06	0.07	--	--	--	--
A8	0.06	0.06	0.06	0.06	0.06	0.06	0.06	0.07	0.07	0.07	0.06	--	--
A9	0.06	0.06	0.06	--	--	--	--	--	--	--	--	--	--
A10	0.06	0.06	0.06	0.06	0.06	0.06	0.06	0.06	0.06	0.06	0.06	0.06	0.06

* Background Dioxin concentration of 0.061 pg I-TEQ m^-3 is included.

-- No air sensitive receiver is located at this elevation.

Health Risk Analysis

4.42 This section assesses the increase health risk from exposure of air toxics. Dioxins have been identified as TAP in this Study, and the incremental risk of TAP, in term of dioxin, has been assessed against the health risk guideline shown in Table 3.3.

4.43 has been assessed. It has been predicted thatThethe increase in annual dioxin concentrations at the ASRs has been calculated and their values are shown in Table 4.20. A4 is the worst affected receiver and this receiver shows dioxin level increase by 0.02174 pg/m³. The unit risk factor of dioxins associated to lifetime exposure of 70 years is 38 (ugm^-3)^-1 and the increase lifetime risk due to the exposure of dioxin is therefore calculated to be 8.26 x 10^–7, which is lower than the guideline value of 1 x 10 ^-6. The risk level associated with the operation of the new cremators is therefore insignificant.

Table 4.20 Increase in Annual Dioxin Concentration at ASR

ASR	Increase in concentration (pg I-TEQ m^-3)*
	Height above ground (m)
	1.5	10	20	30	40	50	60	70	80	90	100	110	120
A1	0.00007	--	--	--	--	--	--	--	--	--	--	--	--
A2	0.00092	0.00412	--	--	--	--	--	--	--	--	--	--	--
A3	0.00863	0.00930	--	--	--	--	--	--	--	--	--	--	--
A4	0.02174	0.02109	0.01372	--	--	--	--	--	--	--	--	--	--
A5	0.00073	0.00162	--	--	--	--	--	--	--	--	--	--	--
A6	0.00212	0.00404	--	--	--	--	--	--	--	--	--	--	--
A7	0.00002	0.00002	0.00004	0.00009	0.00017	0.00032	0.00070	0.00181	0.00563	--	--	--	--
A8	0.00030	0.00032	0.00040	0.00057	0.00094	0.00158	0.00255	0.00405	0.00561	0.00514	0.00287	--	--
A9	0.00004	0.00005	0.00009	--	--	--	--	--	--	--	--	--	--
A10	0.00002	0.00003	0.00004	0.00008	0.00015	0.00030	0.00064	0.00130	0.00238	0.00377	0.00270	0.00080	0.00021

* Background Dioxin concentration of 0.061 pg I-TEQ m^-3 not included.

-- No air sensitive receiver is located at this elevation.

4.44 The TAP emissions during the operation of the new cremators will not pose health risk to the community. The FEHD will, however, adopt the best available technology on the cremators to reduce the emission of dioxins. A target emission concentration of 0.1 ng/m³ (c.f. BPM requirement of 1 ng/m³) will be achieved in the long run. Comparison of dioxin emission between the existing and future conditions is shown in Table 4.21.

Table 4.21 Comparison of Dioxin Emission

	Unit	Existing	Future
Emission rate ⁽¹⁾	ng I-TEQ/m³	1 ⁽²⁾	0.1 ⁽³⁾
Maximum flow rate ⁽¹⁾	m³/hr	6888	6888
Annual Emission ⁽⁴⁾	mg I-TEQ	21.4	2.14

(1) Expressed at reference conditions of dry, 0^oC, 101.325 kPa and 11% O₂.

(2) Data not available and BPM emission concentration limit was assumed.

(3) Target emission limit, based on German Emission Criteria.

(4) Assumed crematorium operates 365 days with 8.5 hours per days.

4.45 With the operation of the new cremators, amount of dioxins emitted from the facility will be reduced by 90%. The associated risk to the community will also be reduced.

Odour

4.46 As discussed in Sections 4.32 & 4.33, the transfer of human remains is conducted in enclosed environment and odour nuisance is not expected. Cremation of human remains is the only source of odour nuisance, if not properly mitigated. The new cremators are designed with adequate secondary air in the primary combustion zone to ensure good turbulence and combustion. Odour nuisance from the cremators is sufficiently mitigated and the odour criteria would be satisfied with the implementation of the control measures.

Mitigation of Adverse Environmental Impacts

Construction Phase

4.47 As mentioned in Sections 4.34 and 4.35, with the incorporation of mitigation measures stipulated in the Air Pollution Control (Construction Dust) Regulation, exceedance of either TSP criteria or AQO is not expected at any of the ASRs. Further mitigation measures are therefore not required.

4.48 The noted mitigation measures will be enforced by normal site management practices as stated in Section 10.

4.49 There is no significant asbestos fibre impact provided that the requirement under the APCO should be strictly complied with. It is therefore recommended that an asbestos investigation should be conducted and an AIR and AAP prepared by a registered asbestos consultant. Also the APCO requires all asbestos-containing materials to be removed prior to the general demolition work.

Operation Phase

4.50 The cremators are designed to ensure complete combustion and are fitted with a secondary combustion zone at high temperature satisfying the latest BPM 12/2 requirements and pollutant concentration emissions limits. All cremators are designed with adequate secondary air in the primary combustion zone to ensure good turbulence and combustion. The gases are held at 850^oC for minimum 2 seconds in the secondary combustion zone. A flue gas filtering plant will be installed to bring down the pollutant emission prior to its discharge. Dioxin emission is controlled by rapid quenching of the flue gas and activated carbon along the filtering system. The mitigation measures should be stated in the licence of the Specified Process under the APCO. Modelling results indicated that the air quality criteria would be satisfied at all ASRs. Further mitigation measures are therefore not required.

4.51 Some in-house management measures are however necessary to prevent abnormal operation of the cremator from resulting in excessive pollutant emissions. Recommended management measures include training of the operators and regular preventive maintenance of the cremator so as to secure that the manufacturer’s instruction of cremators are strictly followed. The FEHD will also educate the public to choose coffins of simple construction or recycled materials for cremation uses. The use of plastic, paints/ lacquer finishes and adhesives in coffin construction will also be discouraged. Personal mementos containing plastic materials should be avoided as far as possible.

4.52 The Environmental Monitoring and Audit (EM&A) requirement during the operation of the crematorium are also stated in Section 10.

Evaluation of Residual Impacts

Construction Phase

4.53 With the incorporation of Air Pollution Control (Construction Dust) Regulation and EM&A programme, adverse residual impact is not expected.

Operation Phase

4.54 The design and emission concentration limits of the new cremators comply with the BPM 12/2 requirements. Air quality at the ASRs has been predicted to satisfy all the relevant limits and guidelines, and adverse residual impact is not expected.

5. WASTE MANAGEMENT IMPLICATIONS

5.1 The proposed project is to replace the existing cremators of the Fu Shan Crematorium for rectifying the existing dark smoke emission problem and compliance with the latest environmental protection requirements. Waste to be generated during the construction of the project is expected to comprise excavated material, construction and demolition (C&D) materials, asbestos, chemical wastes and general refuse.

5.2 During the operation of the crematorium, the major issues that relate to waste management are ash and non-combustible residues that will be produced during the combustion process. General refuse will also be generated from visitors and staff at crematorium during the operation phase, but the amount is expected to be minimal. The potential environmental impacts arising from handling and disposal of this small amount of wastes is anticipated to be negligible. Therefore, it is not expected to cause any environmental concerns and has not been evaluated further in this report.

5.3 This section identifies the potential wastes arising from the construction and operation of the project and assesses the potential environmental impacts of their handling and disposal. The assessment methodology and criteria are also outlined.

Assessment Methodology

5.4 The criteria for evaluating the potential construction waste management implications are set out in Annexes 7 of the EIAO-TM. The method for assessing potential waste management impacts arising from the project follows those presented in Annex 15 of EIAO-TM and include the following:

· Estimation of the types and quantities of the waste generated;

· Assessment of potential impacts from the management of solid waste with respect to potential hazards, air and odour emissions, noise, wastewater discharges and transport; and

· Impacts on the capacity of waste collection, transfer and disposal facilities.

Identification of Impacts

Construction and Decommission Phases

5.5 The construction of the project consists of two stages as follows

Stage 1: Construction of a new cremator plant room, a new generator room, ancillary facilities, installation of four new single cremators, renovation of existing service halls in the crematorium.

Stage 2: Decommission and demolition of the two existing twin cremators after the satisfactory commissioning of the new cremators and renovation of the old cremator rooms.

5.6 During Stage 1 and 2, the construction and demolition activities to be carried out may result in the generation of the following wastes

· C&D wastes;

· Asbestos;

· Chemical wastes; and

· General refuse.

5.7 If not properly managed, the handling and disposal of these waste arisings may cause environmental impact and nuisance. The nature of each type of waste is discussed below together with an evaluation of the potential environmental impacts associated with these waste types.

Operation Phase

5.8 During the operation of the crematorium, the ash and non-combustible residues will be produced during the combustion process of the proposed cremator. Chemical wastes will also be generated during the operation of the Flue Gas Filtering System. The handling and disposal of these wastes would likely cause environmental impact and nuisance if not properly managed. The nature of each type of waste is discussed below together with an evaluation of the potential environmental impacts associated with these waste types.

5.9 Since the amount of general refuse generated from visitors and staff at the crematorium is expected to be minimal, the potential environmental impacts arising from handling and disposal of this small amount of wastes is anticipated to be negligible and, therefore, it is not expected to cause any environmental concerns.

Prediction and Evaluation of Environmental Impacts

Construction and Decommission

Construction and Demolition Materials

5.10 Construction and demolition (C&D) material will comprise unwanted materials generated during construction and may include:

· Wood from formwork and falsework;

· Materials and equipment wrappings;

· Unusable/surplus concrete/grouting mixes; and

· Damaged contaminated surplus construction materials.

5.11 The inert portion of C&D material (e.g. rock, concrete, etc.) which can be used as fill material for reclamation and earth filling projects is termed public fill. The non-inert portion (e.g. timber, glass, plastic etc.) which should be disposed of at landfills is termed C&D waste. The amount of C&D material expected to be generated will be quantified in the site Waste Management Plan to be prepared by the Contractor.

5.12 C&D material arising from the Stage 1 construction works of the project will be generated during the periods from August 2002 to December 2003 and is estimated to be approximately 7000m³.

5.13 Demolition materials will be generated from the removal of the existing cremators during Stage 2 of the project. Based on the preliminary construction programme, the demolition of the existing cremators is scheduled to take place from April 2004 to June 2004. The estimated quantity of C&D material from the demolition of the cremators is approximately 160m³.

5.14 The C&D materials arising from the construction of project must be sorted on-site into “public fill” which should be re-used on-site as far as possible before disposal at public filling areas, and “C&D waste” which should be reused and recycled before disposal at landfill. According to the Project programme, the demolition work commences after the construction work. Therefore, there will be limited amount of demolition material reused on-site. It is estimated that some 700 m³ (i.e. 10%) and 32 m³ (i.e. 20%) C&D materials generated during Stage 1 construction work and Stage 2 demolition work respectively will be categorized as “public fill” where complementarily 6300 m³ (i.e. 90%)and 128 m³ (i.e. 80%) will be disposal of at landfills. Since the quantity of surplus C&D material generated during construction works of the project is expected to be small, the potential for environmental impacts from the transportation of material by road such as noise impact, possible congestion due to increased traffic flows, and dust and exhaust emissions from haul vehicles will not be significant.

Asbestos

5.15 Given their age of construction, the existing cremators and associated structures might have been made up of asbestos-containing material (ACM). During the demolition phase of Stage 2 construction, the old cremators will be demolished and some crematorium areas will be renovated. It is expected that some quantity of ACM will be removed and disposed of. Subject to the findings of asbestos investigation report and asbestos abatement plan prepared in accordance with the Air Pollution Control Ordinance, the ACM quantity generated is estimated to be less than 5m³ for the purpose of this study.

Other Chemical Wastes

5.16 Construction plant and equipment will require regular maintenance and servicing which will generate chemical waste such as cleaning fluids, solvents, lubrication oil and fuel. Vehicle maintenance will also involve the use of a variety of chemicals and lubricants, including heavy duty cleaners, organic solvents, degreasers, brake fluids, battery acid and soldering fluids.

5.17 Chemical waste may pose serious environmental, health and safety hazards if it is not properly managed. These hazards may include:

· Toxic effects to workers;

· Adverse effects on water quality from spills; and

· Fire hazards.

5.18 The amount of chemical waste that will arise from the construction activities will be highly dependent on the Contractor’s on-site maintenance requirements and the amount of plant utilized. If chemical waste is produced, the Contractor should register with the EPD as chemical waste producer. It is anticipated that the quantity of chemical waste, such as lubricating oil and solvent, produced from plant maintenance will be relatively small. These types of waste will be readily accepted at the Chemical Waste Treatment Facility at Tsing Yi. The amount of chemical waste expected to be generated will be quantified in the site Waste Management Plan to be prepared by the Contractor.

5.19 Storage, handling, transport and disposal of chemical waste should be arranged in accordance with the Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes published by the EPD. Wherever possible opportunities should be taken to reuse and recycle materials. Mitigation and control requirements for chemical wastes are detailed in Sections 5.24 - 5.39. Provided that this occurs, and the chemical waste is disposed of at a licensed chemical waste treatment and disposal facility, the potential environmental impacts arising from the storage, handling and disposal of a small amount of chemical waste generated from the construction activities will be minimal.

General Refuse

5.20 The workforce will generate general refuse, including paper and food waste, throughout construction. The storage of general refuse has the potential to give rise to environmental impacts. These include water quality, if waste enters nearby water bodies, odour and visual impact. The worksites may also attract pests and vermin if the storage areas are not well maintained and cleaned regularly. In addition, disposal of waste at sites other than approved waste transfer or disposal facilities can also lead to environmental impacts.

5.21 If the refuse is stored and transported in accordance with good practices and disposed of at licensed landfills, the potential environmental impacts will be minimal.

Operation Phase

5.22 Remains of cremation include bone ashes and non-combustible residues. Among the 6 kg remain per cremation on average, 2.5 kg of bone ash will be collected and the remainder 3.5 kg will be the non-combustible residues. Under current practice, bone ash will be stored in covered containers to be collected by the deceased’s relatives within 2 months upon appointment while the non-combustible residues will be collected and buried at landfill. This practice is expected unchanged for the new replacement cremators. For the new 4 cremators each capable to handle 5 cremations a day, about 60 kg of bone ash and 84 kg of non-combustible residues as general refuse will be generated each day under a maximum cremators output condition. Minimal quantity of waste that needs to be disposed of will be expected.

5.23 Chemicals such as active carbon and lime will be used in the flue gas filtering system. It is estimated that the consumption rate for chemical dosing is about 0.6 kg/hr. Waste collection rate of heavy particulate matter after cyclone separator and other particulate matter after the bag filter are about 0.15 kg/hr and 0.8 kg/hr, respectively. Taking cremation time of 100 minutes and 5 cremations per cremator per day for the 4 new cremators, daily waste arisings associated with operation of the flue gas filtering system are 16.8 kg, 4.2 kg and 22.4 kg for dosed chemicals, particulate matter from cyclone separator and particulate matter from bag filter respectively. All these wastes will be collected by a drum type container and will be removed by the licensed chemical waste contractor periodically. With proper storage, handling and disposal of these chemical wastes, adverse environmental impacts are not anticipated.

Mitigation of Adverse Environmental Impacts

Construction and Decommission Phases

Good Site Practice and Waste Reduction Measures

5.24 It is not expected that adverse waste management related impacts would arise, provided that good site practice is strictly followed. It is recommended that the following good site practice should be included Recommendations for good site practice in the Contract Specifications for the Projectduring the construction activities include:

· Use waste haulier authorized or licensed to collect specific category of waste;

· Obtain the necessary waste disposal permits from the appropriate authorities, if they are required, in accordance with the Waste Disposal Ordinance (Cap 354, Waste Disposal (Chemical Waste) (General) Regulation (Cap 354), the Land (Miscellaneous Provision) Ordinance (Cap 28);

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

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

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

· Appropriate measures to minimise windblown litter and dust during transportation of waste by either covering trucks or by transporting wastes in enclosed containers;

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

· Regular cleaning and maintenance programme for drainage systems, sumps and oil interceptors;

· A recording system for the amount of wastes generated, recycled and disposed of (including the disposal sites);

· In order to monitor the disposal of C&D and solid wastes at public filling facilities and landfills, and control fly-tipping, a trip-ticket system should be included as one of the contractual requirements and implemented by the Environmental Team. One may make reference to WBTC No. 5/99 for details; and

· A Waste Management Plan (WMP) shall be prepared and this WMP shall be submitted to the Engineer for approval. One may make reference to WBTC No. 29/2000 for details.

5.25 Good management and control can prevent the generation of significant amount of waste. Waste reduction is best achieved at the planning and design stage, as well as by ensuring the implementation of good site practice. Recommendations to include the following practice in the Contract Specifications to ensure achieve waste reduction include of the Project:

· 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;

· to encourage collection of aluminium cans by individual collectors, separate labelled bins shall be provided to segregate this waste from other general refuse generated by the work force;

· any unused chemicals or those with remaining functional capacity shall be recycled;

· use of reusable non-timber formwork to reduce the amount of C&D material;

· prior to disposal of C&D waste, it is recommended that wood, steel and other metals shall be separated for re-use and / or recycling to minimise the quantity of waste to be disposed of to landfill;

· proper storage and site practices to minimise the potential for damage or contamination of construction materials; and

· plan and stock construction materials carefully to minimize amount of waste generated and avoid unnecessary generation of waste.

5.26 In addition to the above good site practice and waste reduction measures, specific mitigation measures are recommended below for the identified waste arisings to minimize environmental impacts during handling, transportation and disposal of these wastes.

Construction and Demolition Waste

5.27 Careful design, planning and good site management can minimize over-ordering and generation of waste materials such as concrete, mortar and cement grouts. The design of formwork should maximize the use of standard wooden or metal panels so that high reuse levels can be achieved. Alternatives such as steel formwork or plastic facing should be considered to increase the potential for reuse.

5.28 The contractor should use as much of the C&D material as possible on-site. Proper segregation of waste types on site will increase the feasibility of certain components of the waste stream by recycling contractors.

5.29 To maximize landfill life, Government policy discourages the disposal of C&D wastes with more than 20% inert material by volume (or 30% inert material by weight) at landfill. Inert C&D material (public fill) is directed to reclamation areas or to an approved public filling area (PFA), where it has the added benefit of offsetting the need for removal of materials from borrow areas for reclamation purposes. Due to limited space at landfills, disposal at reclamation sites or a PFA would be the preferred method.

Asbestos

5.30 While the APCO requires registered professionals to undertake the abatement work, the Waste Disposal Ordinance provides control on the packaging, labelling, storage, collection and disposal of asbestos waste. Asbestos wastes shall 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.

5.31 Asbestos waste, by definition under the Waste Disposal (Chemical Waste) Regulation, is categorized as chemical waste of which the arrangement of production, collection and disposal will follow the ‘trip-ticket’ system as with other chemical wastes. The registered asbestos contractor who is the waste producer shall appoint a licensed asbestos waste collector to collect the packaged asbestos waste and deliver to the designated landfill for disposal. Under the Waste Disposal (Chemical Waste) Regulation, directions of asbestos disposal shall be obtained from the EPD and prior arrangement with the landfill operator shall be made prior to the actual disposal.

Other Chemical Wastes

5.32 After use, chemical wastes should be handled according to the Code of Practice on the Packaging, Labeling and Storage of Chemical Wastes. Spent chemicals should be stored and collected by an approved operator for disposal at a licensed facility in accordance with the Chemical Waste (General) Regulation.

5.33 Containers used for the storage of chemical waste should:

· Be suitable for the substance they are holding, resistant to corrosion, maintained in good condition, and securely closed;

· Have a capacity of less than 450 litres 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 Regulations.

5.34 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 entering (water collected within the bund must be tested and disposal as chemical waste if necessary); and

· Be arranged so that incompatible materials are adequately separated.

5.35 Disposal of chemical waste should:

· Be via a licensed waste collector; and

· Be a facility licensed to receive chemical waste, such as the Chemical Waste Treatment Facility which offers a chemical waste collection service and can supply the necessary storage containers; or

· Be a reuser of the waste, under approval from the EPD.

General Refuse

5.36 General refuse should be stored in enclosed bins or compaction units separate from C&D and chemical wastes. A reputable waste collector should be employed by the contractor to remove general refuse from the site, separately from C&D and chemical wastes, on a daily or every second day basis to minimize odour, pest and litter impacts.

5.37 Aluminum cans are often recovered from the waste stream by individual collectors if they are segregated or easily accessible, so separate labeled bins for their deposit should be provided if feasible. Site office waste can be reduced through recycling of paper if volumes are large enough to warrant collection. Participation in a local collection scheme should be considered if one is available.

Operation Phase

5.38 The bone ash and non-combustible residues should be properly handled and disposed of to prevent dust emissions. The cremation remains should be moved and transported in a covered container or other sealed heavy-duty polyethene bags. Should these good practices be employed, the potential secondary environmental impacts will be kept at minimum.

5.39 All the chemical wastes arising from the flue gas filtering system should be collected by drum type container and removed by the licensed chemical waste contractor under the provisions of the Waste Disposal (Chemical Waste) Regulations.

6. LAND CONTAMINATION IMPACT

Identification of Possible Contamination Sources During Operation Phase

6.1 There will be no contamination sources in association with the operation of cremators because;

· Only town gas but no liquid fuel will be used in the cremator; and

· All cremations will be carried out in a contained manner. Also most of the ash portion in terms of bone ash will be collected by the deceased’s relatives, only small quantity of ash will be generated each day and will not impose a significant contamination impact with regard of its handling and disposal.

6.2 There is only one contamination source associated with the new emergency generator. In operation, 1.5 tons of diesel fuel will be stored on-site to fuel up the generator during emergency. Accidental spillage and rupture of the storage tank could lead to land contamination impact.

Prevention of Contamination Impact

6.3 In order to prevent the fuel storage facility from contaminating the land, the following precautionary measures should be taken.

· Store the liquid fuel in a durable, rustless and sealed tank;

· Situate the storage tank above ground to facilitate inspection of fuel leaks/ seepage;

· Finish the floor of the storage room with impervious concrete paving to stop any fuel spillage from penetrating to the ground;

· Provide adequate bund volume for holding the fuel inventory inside the storage room to contain accidental spillage;

· Never overfill the storage tank;

· Inspect regularly the fittings, valves and flanges of storage tanks; and

· Monitor regularly the fuel inventory to spot early leaks/ seepage.

7. LANDSCAPE AND VISUAL IMPACT

Introduction

7.1 This section evaluates the degree of landscape and visual impact created by the proposed replacement on the identified sensitive receivers. The methodology of the assessment is based on the Technical Memorandum as required under the Environmental Impact Assessment (EIA) Ordinance.

7.2 The assessment judges the significance that the proposal will have on the landscape character and visual amenity. The landscape impact assessment predicts the effects upon the physical characteristics or components that together form a landscape. The visual impact assessment predicts the changes arising from development to the views of the landscape from the sensitive receivers. Subsequently, the appropriate landscape design measures, which mitigate the assessed impacts as far as possible will be outlined and the permanent residual impacts will be defined, based on the effectiveness of the mitigation proposals.

7.3 The proposed development is confined to the construction of new cremation rooms that will be built on the existing car park area and on part of the existing garden (~120m²). The building works will include: site formation, foundation works and building of a structure to house the new cremators and accessories. A new paved road will be constructed to replace the existing access. The entire work area will be closed-off by hoardings.

Baseline Study

Project Site

7.4 The project Site is situated on a terraced spur adjacent to the existing Fu Shan Crematorium, Sha Tin. The Site is partly within an existing parking lot and a garden (to serve the users and staff of the Crematorium). It is heavily surrounded by vegetation. No rare species were visually identified at time of the site inspection. The Site is almost at the edge of the steep slope to the northeast and northwest.

7.5 The project site is located adjacent to the existing Crematorium and towards the northeast at a distance of ~100m are a block of staff quarters. Towards the north west of the site is the Columbarium building. A gateway demarcates the main entrance to the Crematorium at ~250m from the Site.

Surrounding Land Uses

7.6 To the north, there is an access road that provides a link to the Lower Shun Mun Road and the Tai Po Road, Tai Wai. Beyond, the slope falls steeply to the Shing Mun River Channel, a ~35m wide channel at ~+15mPD. Parallel to the south of the River Channel is Heung Fan Liu Street and a bicycle track and Pik Tin Street runs along the north of the channel.

7.7 Directly towards the north of Pik Tin Street, along the lower foothills of Shing Mun Country Park is the small village of Heung Fan Liu, a small old village of single storey structures with a modern planned extension area of three-storey “villa style” units. There is a CDA site which is proposed for the construction of four 18-storey blocks above a 3 storey podium in close proximity to Heung Fan Liu Village towards the west. The development will be constructed in a southwest-northeast direction within the southern portion of the site.

7.8 To the northeast beyond Pik Tin Street is a single row of high rise private residential towers built on podiums. Granville Garden consists of three 28-storey blocks above a 5-storey podium (excluding the lower ground floor and the podium landscape deck) and Parkview Garden comprises two 27-storey blocks above a three storey podium (excluding the ground floor and the podium landscape garden).

7.9 Beyond the village and CDA is the prominent China Light and Power Electricity Sub-Station, a prominent ~29m high utility structure. At various distances across the hills are located a small number of structures. The Granville Garden and Parkview Garden blocks are backed by low steep retaining walls and a significant section of the low foothills in close proximity to the private housing blocks has been zoned as a permitted burial area.

7.10 Towards the north of the residential land uses the elevation rises through the foothills of Cham Shan (Needle Hill) to the Shing Mun Tunnel Road (~+80mPD) which runs from east to west across the hill slope at a distance of ~100m from the site boundary. A large part of the slope to the north is natural and covered in dense vegetation.

7.11 To the east of the site separated by a dense area of vegetated hillside are Sha Tin Areas 4C and 38A. Site formation works for a proposed housing development are in progress. The view of the Site will expect to be screened partially by the existing staff quarters for the crematorium and a formed slope.

7.12 To the south is Lakeview Garden situated on the top of a ridge at ~+200mPD with sufficient setback from a platform. It is part of the exclusive Sha Tin Heights luxury residential area and is characterized by ~30 low rise units.

7.13 To the southwest is the extended Lower Shun Mun Road that traverses the dam of the Lower Shun Mun Reservoir. A Water Works storage yard is located in close proximity. The retaining dam for the Lower Shing Mun Reservoir is a prominent feature in the landscape.

Review of Outline Zoning Plan

7.14 As shown in Figure 7.1, the project site and its adjacent area is zoned “Other Specified Uses” (“OU”) annotated “Crematorium, Columbarium, Mortuary and Funeral parlour” on the approved Sha Tin Outline Zoning Plan (OZP) No. S/ST/15. To the northeast and southwest are areas zoned as “Green Belt” (“GB”) on the Sha Tin OZP.

7.15 To the north of the Site across the Shing Mun River Channel is Heung Fan Liu Village that falls within an area zoned “Village Type Development”(“V”) on the approved Sha Tin OZP No. S/ST/15. Adjacent to the west of Heung Fan Liu Village is a “Comprehensive Development Area”(CDA”). To the east of Heung Fan Liu Village are the high-rise residential developments of Granville Garden and Park View Garden, both of which are zoned as “Residential (Group B)” on the Sha Tin OZP.

7.16 Further east of the Site separated by a “Green Belt” (“GB”) zone is Sha Tin Areas 4C and 38A which are zoned “Residential Group A” (“R(A)”) on the Sha Tin OZP . The area concerned is undergoing site formation works for the development of public housing by the Housing Authority.

7.17 The project Site is an extension of the existing Crematorium; therefore conflicts with the statutory town plans are not envisaged.

Landscape Impact Assessment Study

Identification of Landscape Units

7.18 A landscape unit is a spatial area within the visual envelope, which maintains positions that are sensitive to the landscape changes caused by the proposal. Based on the proposed works three landscape units have been identified within the affected area.

Unit 1

7.19 Unit 1 encompasses the small existing car parking area that is characterized by flat tarmac coverage.

Unit 2

7.20 Unit 2 includes an ornamental garden area that includes a small number of existing trees and shrub planting.

Unit 3

7.21 Unit 3 includes the existing vegetation surrounding the works area and at the edge of the slope area.

7.22 Initially the landscape units are ranked according to the value of their existing quality by a five-point scale as follows:

Highest Quality Landscape (HQL)

Very Attractive Landscape (VAL)

Good Landscape (GL)

Ordinary Landscape (OL)

Poor Landscape (PL)

7.23 The ranking classification of the landscape units is listed in Table 7.1.

Table 7.1 Value of Landscape Units of Concern

Landscape Unit	Value Classification
Unit 1	OL
Unit 2	VAL
Unit 3	GL

Prediction and Evaluation of Landscape Impact

7.24 Landscape impacts relate to changes in views arising from the proposed works to individual landscape units. The analysis shall identify and predict the type and extent of landscape impact, on each landscape unit relating to:

· direct quantification of impacts upon specific landscape elements; and

· more subtle effects upon the overall pattern of landscape elements that give rise to landscape character, and local and regional distinctiveness.

7.25 Landscape impacts on the individual receiver groups are assessed as follows.

Unit 1

7.26 The construction of the crematorium will create a substantial impact through the loss of the car parking area, although as the type of landscape is “ordinary” there will not be a significant loss. Overall there will only be a minimal degree of change to the key component features within the existing landscape. The ability of the landscape to accommodate change is high and there will be an insignificant impact on the landscape. Within the local and wider regional context the proposed works within Unit 1 will not be significant. In respect to the landscape unit the works, incorporating extensive landscape mitigation measures, will not have any direct impact upon specific landscape elements or upon acknowledged special interests. Instead, it will have a more subtle effect upon the overall pattern of landscape elements.

Unit 2

7.27 The construction of the crematorium will create an impact through the loss of ~120m² of ornamental garden. There will be a loss of mature trees and shrub planting. As the landscape type is “very attractive” there will be a significant loss. Overall there will be a high degree of change to the key component features within the existing landscape. The ability of the landscape to accommodate change is low and there will be a significant impact on the landscape. Within the local and wider regional context the proposed works within Unit 2 will not be significant. In respect to the landscape unit the works, incorporating extensive landscape mitigation measures, will not have any direct impact upon specific landscape elements or upon acknowledged special interests. Instead, it will have a more subtle effect upon the overall pattern of landscape elements.

Unit 3

7.28 The construction of the crematorium may have an impact through the loss of vegetation cover around the top of the slopes during construction work. As the landscape is “good” there may be a residual loss. Overall there will only be a minimal degree of change to the key component features within the existing landscape. The ability of the landscape to accommodate change is high and there will be an insignificant impact on the landscape. Within the local and wider regional context the proposed works within Unit 3 will not be significant. In respect to the landscape unit the works, incorporating extensive landscape mitigation measures, will not have any direct impact upon specific landscape elements or upon acknowledged special interests. Instead, it will have a more subtle effect upon the overall pattern of landscape elements.

7.29 The landscape units are ranked according to their perceived landscape quality and the expected impact. They are evaluated according to a seven-point scale as below. The ranking placed on a landscape unit relates to their potential sensitivity to impact based on their nature and quality.

· Substantial adverse impact (SAI), whereby the proposal would cause a significant landscape deterioration.

· Moderate adverse impact (MAI), whereby the proposal would cause a perceptible but medium landscape deterioration.

· Slight adverse impact (SLAI), whereby the proposal would cause a barely perceptible landscape deterioration.

· No change (NC), whereby the proposal would cause no landscape deterioration or benefit.

· Slight beneficial impact (SLBI), whereby the proposal would cause a barely perceptible landscape benefit.

· Moderate beneficial impact (MBI), whereby the proposal would cause a perceptible but medium landscape benefit.

· Substantial beneficial impact (SBI), whereby the proposal would cause a significant landscape benefit.

7.30 The impacts on landscape character are predicted by identifying changes such as value of existing landscape quality; degree of change to landscape elements; and the sensitivity of the landscape to change. The ranking classification of the landscape units in respect to the landscape impact created by the proposed development is listed in Table 7.2.

Table 7.2 Landscape Impact Classification

Landscape Unit	Impact Classification
Unit 1	MAI
Unit 2	SAI
Unit 3	SLAI

Overall Landscape Impact

7.31 The construction of new crematorium encompasses part of the garden area where small amounts of existing trees would be removed and some landscape areas be lost. The works are however expected to have relatively small impact on the existing vegetation surrounding the works area and at the edge of slope. Initial inspection did not identify any rare tree species in the vicinity. Upon approval of the proposed development, it is expected that a more extensive tree survey will be conducted to identify the existing trees to be affected.

Visual Impact Assessment Study

Identification of Visually Sensitive Receivers

7.32 The visual envelope defines the study area. Namely, the extent of the landscape or townscape (all residential buildings, including work places, recreational buildings and outdoor locations) across which the road is visible defined either by the ridgeline/watershed or inter-visibility. Inter-visibility being where view lines are blocked by localized topography, building mass or vegetation.

7.33 A visually sensitive receiver is a spatial area or built mass that has facades or viewing positions, which are visually affected by the proposed development.

7.34 For the purpose of the assessment, the potential visual sensitive receivers have been grouped into the following categories. The immediate viewer and its location relative to the source of visual impact influence the sensitivity of each group.

Category A. People who view the scheme from their homes - considered being the most sensitive to any visual intrusion, because the attractiveness of the view would have a notable affect on a homeowner’s general quality of life and acceptability of their environment.

Category B. People who view the scheme from their workplace - considered relatively less sensitive to visual intrusion, because they are employed in activities where visual outlook plays a less important role in the perception of the quality of the working environment.

Category C. People who view the scheme from public thoroughfares - degree of visual intrusion experienced, depending on the speed of travel and whether views are continuous or only occasional. Generally, the slower the speed of travel and the more continuous the viewing experience, then the greater the degree of sensitivity.

Category D. People who view the scheme from recreational areas / countryside - considered to be reasonably sensitive to any visual intrusion (depending on the recreational type) as the attractiveness of the view would have a direct effect on the pleasure / quality of their leisure experience and use of the area.

7.35 The identified sensitive receivers, according to category, define the visual envelope as listed in Table 7.3 and illustrated in Figure 7.2 – Visually Sensitive Receivers Plan.

Table 7.3 Identification and Category of Visual Sensitive Receivers

Key	Visual Sensitive Receiver	Existing View from the Receiver	Category
R1	Lakeview Garden	Plate 1 of Figure 7.3	A
R5	Heung Fan Liu Village and CDA Residential Site	Plate 2 of Figure 7.3
R6	Granville Gardens and Parkview Gardens	Plate 3 of Figure 7.3
R7	Crematorium Staff Quarters	Plate 4 of Figure 7.4
R8	Sha Tin Areas 4C and 38A (proposed Housing Authority development)	Plate 5 of Figure 7.4
R4	Water Works – works & storage yard	Plate 6 of Figure 7.4	B
R9	CLP Electricity Sub-station	Plate 7 of Figure 7.4	B
R2	Reservoir dam at Lower Shing Mun River Road	Plate 8 of Figure 7.5	C
R3	Lower Shing Mun River Road connecting the reservoir dam and villages	Plate 9 of Figure 7.5	C
R10	Footpaths across Lower Shing Mun Country Park	Plate 10 of Figure 7.5	D

Prediction and Evaluation of Visual Impact

7.36 The visual impact imposed on each sensitive receiver was assessed taking into account of the magnitude of change brought about and sensitivity of the receiver group.

7.37 The visual impact arising from the construction phase of the Project is on short-term basis and therefore negligible. During operation phase, some visual impacts are expected and the levels of impact are classified and illustrated in the Table 7.4.

Table 7.4 Classification of Level of Visual Impacts

Magnitude of Change	Sensitivity of Receiver Group
Magnitude of Change	High	Medium	Low
High	H	HtoM	MtoL
Medium	HtoM	MtoL	LtoN
Low	MtoL	LtoN	N
No Change	NC	NC	NC

Key : H - High

HtoM - High to Moderate

MtoL - Moderate to Low

LtoN - Low to Negligible

N - Negligible

NC - No Change

7.38 Visual impacts on the individual receiver groups are assessed as follows.

Category A – Place to Live

Lakeview Gardens (R1)

7.39 The unsightly view will be only experienced from certain angles on the top floors and roof of Lakeview Garden. Given that there are some horizontal distances of 450m away from the Crematorium, the magnitude of change perceived at Lakeview Gardens is considered medium (the photomontage in Figure 7.6). While the sensitivity for residential areas is high, the level of visual impact is assessed to be “high to moderate”.

Heung Fan Liu Village & CDA Residential Site (R5)

7.40 As the Project site is at level 68mPD the proposed facilities would not be visible from Heung Fan Liu Village to the north and the adjacent CDA development to the northwest upon completion. From the CDA lot boundary there is a direct distance of approximately 250m that would significantly reduce the dimension of the subject chimney even if visible. At the time of conducting this assessment, Rural and New Town Planning Committee of the Town Planning Board has agreed with the CDA lot owners that four 18-storey residential blocks above a 3-storey podium arranged in a southwest-northeast direction be proposed in the southern portion of the CDA site. Assuming that the proposed development is built from ground level at the existing level of 19.10mPD, the highest podium level is at 30.00mPD and the top floor of the 18-storey building is approximately at 84.00mPD. With the top floor of the existing Columbarium standing at level 84.00mPD, the sight of the proposed chimney reaching up to about 86.00mPD will be mostly screened with only 2m chimney tip visible. Though the sensitivity of the CDA development is high, the magnitude of change of view is however low, the level of visual impact is assessed to be “moderate to low”.

Granville Gardens & Parkview Gardens (R6)

7.41 The two high-rise developments are located at a considerable distance from the project site. The columbarium building would sufficiently block the view of the new cremators from the majority of high-level viewing positions. In many respects the visual target area is substantial and includes direct views to Sha Tin Aresa 4C and 38A and the hills of Shing Mun Country Park, whereas the proposed development will form only one element within Fu Shan Crematorium. The magnitude of change perceived at both Granville Gardens and Parkview Gardens are considered low. While the sensitivity for residential areas is high, the level of visual impact is assessed to be “moderate to low”.

Crematorium Staff Quarters (R7)

7.42 During the construction stage, some temporary visual impacts attributed by the hoarding and road works will impose on the staff quarters. During operation phase, the existing crematorium block will sufficiently screen out the sight of the new crematorium from the staff quarters except for the upper section of the 19m tall chimney. Considering that the staff who works everyday in the crematorium is less visually sensitive (i.e. medium sensitivity) and the magnitude of change is only medium, the level of visual impact is assessed to be “moderate to low”.

Shatin Areas 4C and 38A (R8)

7.43 The proposed chimney will not be clearly and directly visible from the proposed housing development site now being formed. As it is beyond 350m from the site, even after the housing blocks are built, view of the chimney from the closest tower of the development will be screened from the lower floors and only visible from the top floors, say from about the 14-storey at 76mPD to the top floor at about 158.30mPD. Direct views will only be available within the residential block at the farthest west of the development, pending the building’s designed layout and orientation. The level of visual impact is assessed to be “moderate to low” given the low magnitude of change and high sensitivity rating.

Category B – Place to Work

Water Works – works yard (R4)

7.44 As screened by the existing columbarium, the new crematorium will not be in sight and no visual impact on the area is expected.

CLP Electricity Sub-Station (R9)

7.45 There will be no change to the visual impact from the CLP Electricity Sub-station due to the presence of heavy vegetation and future CDA development at Heung Fan Liu that screen off the sight on the new crematorium and associated chimney. No visual impact on the area is expected.

Category C – Public Thoroughfares

Reservoir dam at Lower Shing Mun River Road (R2)

7.46 The reservoir dam is basically for people to enjoy their leisure walk, outing etc. It is about 350m to the southwest of the Project site at a much higher level, therefore the view of chimney is expected to merge with the background. The level of visual impact is assessed to be “moderate to low” given the medium magnitude of change and medium sensitivity rating. With mitigation measures, e.g. planting of screening trees as , i.e. tree planting, the view would be significantly improved and view of the chimney could be entirely screened.

Lower Shing Mun River Road connecting the reservoir dam and villages (R3)

7.47 At both sides of the gateway there are heavily planted tree species that screen off views of the buildings within the Crematorium compound. The Crematorium, therefore, is hardly visible from Lower Shun Mun Road. The level of visual impact is assessed to be “moderate to low” given the medium magnitude of change and medium sensitivity rating.

Category D – Recreational Areas

Footpaths across Lower Shing Mun Country Park (R10)

7.48 For the users of the footpaths across the Country Park the impact of the proposed development will be minimized due to the distance factor and associated local weather and atmospheric conditions. The undulating profile across the hills will further limit the area of the view envelope from where the extension to the Crematorium will be visible. The level of visual impact is assessed to be “moderate to low” given the medium magnitude of change and medium sensitivity rating

7.49 The ranking classification of the visual sensitive receivers in respect to the visual impact created by the proposed development is summarized in Table 7.5.

Table 7.5 Predicted Level of Visual Impact

Key	Visual Sensitive Receiver	Predicted Level of Visual Impact
R1	Lakeview Garden	H
R5	Heung Fan Liu Village and CDA Residential Site	MtoL
R6	Granville Gardens and Parkview Gardens	MtoL
R7	Crematorium Staff Quarters	MtoL
R8	Sha Tin Areas 4C and 38A (proposed Housing Authority development)	MtoL
R4	Water Works – works & storage yard	NC
R9	CLP Electricity Sub-station	NC
R2	Reservoir dam at Lower Shing Mun River Road	MtoL
R3	Lower Shing Mun River Road connecting the reservoir dam and villages	MtoL
R10	Footpaths across Lower Shing Mun Country Park	MtoL

Key : H - High

HtoM - High to Moderate

MtoL - Moderate to Low

LtoN - Low to Negligible

N - Negligible

NC - No Change

Overall Visual Impact

7.50 Generally, the project site is well enclosed by its topography and heavy vegetations around it. The proposed work is only an extension to the existing crematorium. Although it will create visual impact during construction, after construction the overall impact is minimum.

Mitigation Measures

7.51 Appropriate landscape design measures will be developed to mitigate the assessed impacts as far as possible and to increase visual quality and help blend the IRS into the surrounding landscape.

7.52 The Project site covers less than 200 square meters in area and the visual impact during and at post construction will be low to minimal. The only noticeable element is the proposed chimney to be stood at 19m from finished ground level – only 2m higher than the existing Columbarium.

7.53 60 nos. of tall trees will be planted at critical locations to act, as visual buffers for the chimney and compensate for the trees lost in the garden area. 30 nos. will be extra heavy standard and 30 nos. heavy standard in size. The visual impact of the chimney structure could further be reduced by considering chromatic treatment to the chimney, i.e. by the application of particular surface texture and colour paints. Both landscaping and chromatic treatment will require extensive experiment at detail design stage.

7.54 Taking into account the landscape impact, a detailed tree survey as normally required for landscaping works on government projects will be conducted to assess the vegetation composition and species that will be affected by the site formation and construction works. In accordance with the tree survey findings, appropriate plans of tree preservation and transplantation shall be devised and implemented. As a general practice, topsoils should be conserved as far as possible throughout the construction works. For the loss of garden area, some compensatory planting shall be recommended. Provision of planters, landscaping improvement to the interior garden at the main entrance of the existing Crematorium, resurfacing of the access road, additional roadside tree planting will further upgrade the visual environment of the entire area.

7.55 Furthermore additional buffer planting of extra heavy standard trees will be provided for the critical areas along the boundary line to be identified at time of detail design stage. Overall, the landscape plan as shown in Figure 7.7 illustrates the key proposed landscape mitigation work for both visual and landscape impacts.

Conclusion

7.56 Based on the landscape and visual impact assessment, it can be concluded that the impact for the proposed development is acceptable with mitigation measures for the identified adverse effects, but these can be eliminated, reduced or offset to a large extent by specific measures.

7.57 Some 120m² landscape areas, including the existing garden and sections of slope will be disturbed. The landscape areas will need to be reinstated with trees to be compensated subject to a detailed tree survey. With implementation of the landscape plan and mitigation measures the landscape of the project site could be significantly improved.

7.58 Minor visual impacts will expect to be experienced by a limited number of residents at various locations. The visual impact will be reduced through mitigation, i.e. the planting tall trees at critical areas around the Crematorium.

7.59 The following Tables 7.6 and 7.7 provide detailed summaries of the landscape and visual impact to conclude the Assessment.

Table 7.6 Summary of Landscape Impacts with and without Mitigation

Landscape Unit	Sources of Impact	Level of Impact	Mitigation Measures	Level of Impact after Mitigation
Unit 1	R,S	MAI	-	MAI
Unit 2	V,S	SAI	R, C	SLAI
Unit 3	V,S	SLAI	R, C	NC

Key :

Sources of Landscape Impact

V: Loss of Vegetation

R: Reduction in land use

S: Significant impact during Construction

Level of Landscape Impact

SAI: Substantial adverse impact

MAI: Moderate adverse impact

SLAI: Slight adverse impact

NC: No change

SLBI: Slight beneficial impact

MBI: Moderate beneficial impact

SBI: Substantial beneficial impact

Mitigation Measures

R: protection of retained trees, replanting of transplanted trees.

C: compensatory planting.

Table 7.7 Summary of Visual Impacts with and without Mitigation

Sensitive Receiver	Sources of Impact	Level of Impact	Mitigation Measures	Level of Impact after Mitigation
R1	C, L	HtoM	P, H	MtoL
R5	C, L	MtoL	P, H	LtoN
R6	C, L	MtoL	P, H	LtoN
R7	B, C, L, S	MtoL	P, H	LtoN
R8	C, L	MtoL	P, H	LtoN
R4	--	NC	P, H	NC
R9	--	NC	P, H	NC
R2	L	MtoL	P, H	LtoN
R3	L	MtoL	P, H	LtoN
R10	L	MtoL	P, H	LtoN

Key :

Sources of Visual Impact

S: Significant impact during Construction

C: Visual Impact caused by Chimney

B: Visual Impact caused by New Building

L: Loss of views

Level of Visual Impact

H - High

HtoM - High to Moderate

MtoL - Moderate to Low

LtoN - Low to Negligible

N - Negligible

NC - No Change

Mitigation Measures

P: planting of new tress to act as visual screens.

H: hard landscape treatment, including the development of chromatic themes in the architectural treatment of chimney.

8. WATER QUALITY IMPACT ASSESSMENT

8.1 The proposed flue gas filtering system involves only dry processes. There will be no effluent discharge from the new cremators nor the associated air pollution control scrubbing system, so adverse water quality impact is not expected.

9. HAZARD TO LIFE

9.1 The proposed cremators will be fuelled by commercial town gas supplied provided by the local Town Gas company via direct pipelines and there will be no storage of town gas on-site. Therefore, there will be no life hazard associated with fuel gas storage.

10. ENVIRONMENTAL MONITORING AND AUDIT REQUIREMENTS

10.1 This section elaborates the requirements of EM&A for the construction and operation of the Project, based on the assessment results of various environmental issues.

10.2 The objectives of carrying out EM&A for the Project include the following:

· to provide a database against which any short or long term environmental impacts of the Project can be determined;

· to provide an early indication should any of the environmental control measures or practices fail to achieve the acceptable standards;

· to monitor the performance of the Project and the effectiveness of mitigation measures;

· to verify the environmental impacts predicted in this EIA;

· to determine project compliance with regulatory requirements, standards and government policies;

· to take remedial action if unexpected problems or unacceptable impacts arise; and

· to provide data to enable an environmental audit.

10.3 According to assessment results, no adverse environmental impacts are anticipated during construction phase and air quality and landscape monitoring are recommended during operational phase. The following sections summarise the recommended EM&A requirements during construction and operation phase.

Construction Phase

10.4 No adverse air quality, waste and water quality impacts on the surrounding sensitive receivers are expected during construction phase as a small-scale construction works of this Project. Only standard pollution control measures would be adequate and shall by enforced by the normal site management practices.

Operation Phase

Air Quality

10.5 The potential impact arising from the Project will be air quality impact. RSP, CO, HCl, Hg, organic compounds and dioxins would be generated from the cremator during the operation. The air quality at the nearby air sensitive receivers is predicted to comply with the relevant limits and guidelines with the implementation of the recommended mitigation measures. No odour nuisance from the proposed cremators will be expected as the cremators are designed to ensure complete combustion. With the operating conditions (i.e. secondary combustion chamber of operating temperature of no less than 850°C and more than 2 second residence time) maintained to ensure complete combustion and the provision of bag filter, minimum dark smoke emission is expected.

10.6 In order to ensure the compliance of the legislation requirements, the conditions and the continuous monitoring stipulated in BPM 12/2 - A Guidance Note on the Best Practicable Means for Incinerators (Crematoria), published by EPD shall be conducted. Complete real time data acquisition facilities shall be provided at each stack or inside each cremator for continuous monitoring on the following pollutants and processes:

· Temperature inside the primary combustion zone;

· Temperature at the outlet from the secondary combustion zone;

· Oxygen concentration at the outlet from the secondary combustion zone;

· Carbon Monoxide concentration at the outlet from the secondary combustion zone;

· Smoke density at the chimney of the cremator; and

· Particulate matter at the chimney.

The above monitoring conditions should be controlled under the licence of Specified Process, under the APCO.

10.7 The complete real time data acquisition facilities shall be provided at each stack or inside each cremator for continuous monitoring on those parameters as required by BPM 12/2. All continuous monitor readings shall be continuously recorded and the readings shall be on immediate display to the operating staff.

10.8 In order to satisfy the requirement of EPD local control office, all real time data as required in BPM 12/2 shall be transmitted to a remote display unit by means of telemetry transmission.

10.9 Other stack emissions listed in the BPM 12/2 but not covered in the continuous monitoring shall be subject to routine monitoring during the operation phase for every six months interval. Permanent provisions in the stacks or cremators, which are necessary in terms of accessibility, gaseous sampling etc, shall be provided. Table 10.1 presents the summary of the requirements for different kinds of pollutants and process monitoring.

10.10 At the outlet from the secondary combustion zone, the cremator shall be provided with a short section of hot gas duct which accommodates the field sensors for continuous in-stack monitoring & process monitoring and provides sampling probes/tubes for the regular routine compliance checks in future.

10.11 All the real time data shall be linked to a multi-channel data logging system, individual to each cremator. The average of at least 10 readings taken per minute shall be held within the data logger and stored. The information from individual data loggers shall then be passed on to a central computer equipped with monitor and printer which shall be able to display all the real time data and historical information in numerical and graphical format.

10.12 Results of all monitoring and inspections should be recorded in a manner specified by EPD. These records should be retained at the premises for a minimum of two years, or other period specified by EPD, after the date of last entry and be made available for examination as and when required by the Authority.

10.13 The continuous monitoring equipment to be provided should meet the specifications specified by EPD. They should be maintained and calibrated according to the manufacturer’s recommendations. Unless otherwise agreed by EPD, zero and span checks should be carried out every 24 hours.

Table 10.1 Summary of the Requirements for Different Kinds of Pollutants and Process Monitoring

Continuous Monitoring			Data Logging	Routine Compliance Monitoring (Sampling Period = 6 months)
In-Stack Monitoring	Particulate Matter	1.Single Path Modulation Meter	Yes	Glass filters to EPA Method 5
	Hydrogen Chloride	-	-	Extractive manual wet chemical techniques to EPA Method 26
	Carbon Monoxide	2. Extractive Infrared Spectrophotometer	Yes	Using the fixed installation of Infrared Spectrophotometer (i.e. 2) plus verification through extractive manual wet chemical techniques based on EPA Method 10
	Organic Compounds	3.Flame ionization detector (FID) (Provisions for re-charging the fuel gas should be provided if local support for non-standard cylinder is not available)	-	Flame ionization detector (FID) to EPA Method 25a (i.e. 3)
	Dioxins	-	-	Required
	Smoke Density	Provisions for particulate matter measurement (i.e. 1) is utilized with auxiliary output display in %	-	Visual Assessment by Ringelmann Chart
Process Monitoring	Temperature of Primary Chamber	4. Thermocouples	Yes	By the provisions for continuous monitoring (i.e. 4)
	Temperature of Secondary Chamber	5. Thermocouples	Yes	By the provisions for continuous monitoring (i.e. 5)
	Oxygen Concentration at Secondary Chamber	6. Extractive Paramagnetic Analysis to EPA Method 3A	Yes	By the provisions for continuous monitoring (i.e.6)

Remarks: 1,2,3,4,5 and 6 represent 6 groups (i.e. 24 sets) of measuring instruments for 6 parameters of the four cremators. Any configuration with one analyzer sequentially monitoring for more than one cremator is acceptable provided that the time interval between two consecutive data of a particular parameter & cremator does not exceed 15 seconds.

10.14 The instruments for smoke density monitoring should be fitted with audible or visual alarms, which should activate at a reference level agreed by EPD. Emission events that lead to the alarms being activated should be properly recorded in a manner and format agreed with EPD. These instruments should be checked to ensure that they are functioning correctly in accordance with the manufacturer’s instructions.

10.15 The operating temperature and other working conditions of the cremators are controlled by automatic feedback system. When the operating temperature is low or smoke density is high, automatic feedback system will trigger to switch on burners and flows of fuel injection and air intake will be adjusted accordingly to increase the firing rates and eliminate the smoke emission. When oxygen level is low, air intake flow will be increase to ensure complete combustion in the combustion chamber.

10.16 The operator of the cremator shall compare the impact monitoring results with the following criteriacompare the impact monitoring result with the following criteria.

(a) ~~Conform to~~ BPM 12/2 (issued in August 1998), VDI 3891 and PG5/2(95);

(b) Smoke emission from the cremator during normal operations (including start up and shut down) shall not exceed Shade 1 on the Ringelmann Chart.

10.17 In addition to the automatic feedback system, manual override of the operation should be allowed for the new cremator. In case of emergency or failure of the automatic feedback system, the operation of the individual cremators should be manually suspended until the problem has been fixed and faulty equipment been repaired. Also EPD should be informed of the event as soon as possible. The implementation of such contingency and arrangements should be controlled under the Specified Process Licence of the APCO.

10.18 As described in the EIA Report, the air quality at the nearby air sensitive receivers is predicted to comply with the relevant limits and guidelines. No adverse residual impact is expected. However, the design of the cremators and the recommended measures stipulated in EPD BPM 12/2 should be complied.

1.1If the above measures are not sufficient to restore the air quality to acceptable levels, the Client shall recommend some other mitigation measures to EPD approval, and implement the mitigation measures.

10.19 The implementation schedule for the mitigation measures is presented in Section 13.

Landscape and Visual

10.20 Project landscape architect would be responsible for inspection of the growth of plants in accordance with the landscape plan to make sure mitigation method is effective and the landscape enhanced after the first, the sixth and the twelfth month of the completion of all recommended planting works.

Summary

10.21 A summary for all parameters to be monitored and audited during construction phase and operational phases are summarised in Table 10.2.

Table 10.2 Summary for All Monitoring Parameters

Parameter	Construction Phase	Operation Phase
Parameter	Monitoring / Audit	Monitoring / Audit
Air Quality	Not required. Standard pollution control measures to be enforced by normal site management practices	(a) Continuous Monitoring · Temperature inside the primary combustion zone; · Temperature at the outlet from the secondary combustion zone; · Oxygen concentration at the outlet from the secondary combustion zone; · Carbon Monoxide concentration at the outlet from the secondary combustion zone; · Smoke density at the chimney of the cremator; and · Particulate matter. (b) Commissioning Stage and Routine Compliance Monitoring on every 6 months · Particulate matter · Hydrogen chloride · Carbon monoxide · Organic compounds · Dioxins · Smoke density
Landscape & Visual Impact~~Noise~~	Not required.~~Monthly audit~~	The first, the sixth and the twelfth month after the completion of all recommended planting works. -

11. SUMMARY OF ENVIRONMENTAL OUTCOMES

11.1 The nature and extent of environmental impacts arising from the Project have been assessed and is summarised in Table 11.1.

Table 11.1 Summary of Environmental Impacts

Environmental Impacts	Construction Phase		Operation Phase
Environmental Impacts	Stage 1 (Construction of the new crematorium)	Stage 2 (Demolition of the existing cremators)	Operation Phase
Air quality	TSP : no predicted exceedance of EIAO-TM hourly guideline	TSP: No significant impact arising from the intended demolition carried out indoors.	RSP : no predicted exceedance of 24-hr & 1 year HKAQO CO : no predicted exceedance of 1-hr and 8-hr HKAQO HCl: no predicted exceedance of CARB guideline. Hg: no predicted exceedance of 1-hr & 1 year guideline value. TOC: No exceedance of BPM emission limit at the chimney. Dioxins: no predicted exceedance of 1-hr and 1 year guideline value. Health Risk: insignificant Odour: No significant odour impact predicted as the cremator design complies with the BPM 12/2
Waste management (Estimated Arisings)	C&D: 7000 m³	C&D: 160 m³ Asbestos : <5 m³	Cremation remains : 84 kg per day of non-combustibles as general refuse Flue gas cleaning : 16.8 kg for dosed chemicals, 4.2 kg from cyclone separator and 22.4 kg from bag filter
Land contamination	Nil	Nil	No adverse impact expected when taking necessary preventive measures
Landscape and visual	Landscape : Loss of ~120m² garden area and a dozen of trees Visual : Temporal and insignificant		Landscape : Nil Visual : With mitigation measures, impact of the project is considered acceptable
Water quality	Nil	Nil	No adverse impact expected as there is no scrubbing system for flue gas cleaning
Hazard to life	Nil	Nil	No existence of life hazard associated with fuel gas storage

12. CONCLUSION

12.1 It has been assessed that the environmental impacts arising from the Project are either considered minimal or can be mitigated to an extent where the impacts on the sensitive receivers are acceptable. An environmental monitoring & audit programme is therefore recommended to ensure that the mitigation measures have been properly implemented and environmental quality has not been seriously affected throughout the Project.

EIA Ref ^#	Environmental Protection Measures / Mitigation Measures	Location / Timing	Implementation Agent	Implementation Stages*	Relevant Legislations and Guidelines
Construction Phase
S2.11	A chimney structure with emission point of ofat least 19 m above formation level ground to ensure good dispersion of pollutants	During design stage	ArchSD	ü			APCO
S4.47	Established standards and guidelines with EPD’s recommended pollution control clauses should be incorporated in the contract documents. Dust reduction measures while carrying out construction works in accordance with the Air Pollution Control (Construction Dust) Regulation	During construction phase within the site area	All contractors		ü	ü	APCO, Air Pollution Control (Construction Dust) Regulation
S4.36-S4.37	All asbestos-containing materials associated with the old cremators shall be removed by a registered asbestos contractor prior to decommissioning/ demolishing the old cremator. The asbestos removal work should be in accordance with the provision of the Air Pollution Control Ordinance on Asbestos Control.	During Stage II Construction phase	Registered asbestos contractor			ü	APCO

~~EIA Ref~~^#	~~Environmental Protection Measures / Mitigation Measures~~	~~Location / Timing~~	~~Implementation Agent~~	Implementation Stages*	~~Relevant Legislations and Guidelines~~
	·~~Temporary ditches shall be provided to facilitate runoff discharge into the appropriate watercourses, via sedimentation traps / silt retention ponds.~~ ·~~Permanent drainage channels shall also incorporate sediment basins or traps, and baffles to enhance deposition rates.~~ ·Sand / silt removal facilities such as sand traps, silt traps and sediment basins shall be provided to remove sand / silt particles from run-off. These facilities shall be regularly cleaned and maintained by the contractor. ·~~Collection of spent bentonite / other grouts in a separate slurry collection system for either cleaning and reuse / disposal to landfill shall be implemented.~~ ·~~Maintenance and plant areas shall be bunded and constructed on a hard standing with the provision of sediment traps and petrol interceptors.~~ ·~~All drainage facilities must be adequate for the controlled release of storm flows.~~ ·~~Careful programming of the works to minimize surface excavation works during the rainy season.~~ ·~~Exposed soil areas shall be minimized to reduce the potential for increased siltation and contamination of runoff.~~ ·~~All fuel tanks and storage areas shall be contained (bunded) such that spills are not allowed to gain access to water bodies.~~ ·~~Open drainage channels and culverts adjacent to the site shall be kept safe and free from any debris and excavated materials arising from the works.~~ ·~~Open stockpiles of construction materials (for examples, aggregates, sand and fill material) of more than 50 m~~³ ~~shall be covered with tarpaulin or similar fabric during rainstorms.~~ ·~~Any effluent discharged from the site shall be diverted away from any areas of embayed water.~~	~~Work site / During the construction period~~	~~All contractors~~		ü	ü		~~ProPECC PN 1/94, Water Pollution Control Ordinance~~
	·~~All fuel tanks and store areas shall be provided with locks and be sited on sealed areas, within bunds of a capacity equal to 110% of the storage capacity.~~ ·Temporary sanitary facilities, such as portable chemical toilets, shall be provided on-site by a licensed contractor. A licensed contractor would be responsible for appropriate disposal and maintenance of these facilities. ·Contractors shall be required, under conditions of contract, to ensure that site management is optimised and that disposal of any solid materials, litter or wastes to nearby water bodies does not occur.	~~Work site / During the construction period~~	~~All contractors~~		ü	ü		~~ProPECC PN 1/94, Water Pollution Control Ordinance~~

EIA Ref	Environmental Protection Measures / Mitigation Measures	Location / Timing	Implementation Agent	Implementation Stages	Relevant Legislations and Guidelines
~~S7.15 – 7.16~~S7.24	~~On mitigating landscape impact~~ ·~~Undertaking of Tree Survey~~ ~~Formulating and implementing a comprehensive landscape compensatory plan that consider the compensatory planting schedule, landscape improvement measures, etc.~~Planting tall trees at critical location as visual buffers as indicated in the Landscape Plan	~~Detailed Design Stage & Construction Stage~~Detailed Design & Construction Stage	ArchSD~~ArchSD~~	33	33			-

1 Information provided by the suppliers of cremators.

1.1 The existing Fu Shan Crematorium was completed in 1984 and has been in operation since 1985. Complaints of dark smoke emission from the cremators have been received.

1.4 Architectural Services Department (ArchSD), being the Project Proponent was responsible for the design and the construction of the cremators. After the construction work is completed, the operation of the cremators will be handed over to FEHD.

1.8 In accordance with the requirements of the EIA Study Brief, the EIA covers the following aspects of impact assessment:

1.9 The assessment will identify impacts arising from the proposed Project on both existing and planned sensitive developments, and locations where acceptable criteria are exceeded and appropriate mitigation measures are required.

1.10 Considering the nature and environment of the project, constructional/ operational noise impact, ecological impact and impact on sites of cultural heritage are considered to be minimal. These areas have not been included in the Study Brief and are outside the scope of this EIA.

2.1 The Project proposes to replace the two existing twin cremators of the Fu Shan Crematorium. Replacement cremators will rectify the dark smoke emission problem and will comply with the latest environmental protection requirements. Key works of the Project comprise:

2.10 The proposed flue gas filtering system involves only dry processes. There will be no wet scrubbing for flue gas from cremators and thus no wastewater will be discharged into the sewer.

2.12 To maintain the uninterrupted crematorium services, the Project will be implemented under 2 stages as follows:

2.13 The programme of the Project will last from August 2002 to June 2004, taking 17 months for Stage I to construct the new cremators and 3 months for Stage II to demolish the old cremators. Table 2.1 shows the Project construction programme.

2.15 There are no other projects likely to interact with this proposed development.

2.18 FEHD has conducted a site search for the crematorium relocation but no readily available new sites were identified. This Project site has been selected in view of lesser environment impact and availability of land.

3.2 A Technical Memorandum on EIA Process issued under Section 16 of the EIA Ordinance (EIAO-TM) sets out the principles, procedures, guidelines requirements and criteria for preparing and reviewing an EIA report.

3.3 The criteria for evaluating air quality impacts and the guidelines for air quality assessment are laid out in Annex 4 and Annex 12 of the Technical Memorandum on Environmental Impact Assessment Process (EIAO-TM), respectively.

3.7 The EIAO-TM also stipulates that the hourly TSP level should not exceed 500 µgm-3 (measured at 25°C and one atmosphere) for construction dust impact assessment. Mitigation measures from construction sites have been specified in the Air Pollution Control (Construction Dust) Regulations.

3.8 In accordance with the EIAO-TM, odour measured at a sensitive receiver should not exceed 5 odour units based on an averaging time of 5 seconds.

3.9 Under the Air Pollution Control (Specified Process) Regulation, incinerator (including cremator) with installed capacity exceeds 0.5 tonne per hour, is classified as a specified process, and a Specified Process licence is required for its operation.

3.14 The following legislation relates to the handling, treatment and disposal of wastes in the Hong Kong SAR and will be used in assessing potential impacts:

3.15 The following documents, circulars and guidelines which relate to waste management and disposal in Hong Kong SAR will also be referred to during the study:

Chemical Waste

Construction and Demolition (C&D) Materials

3.19 Environmental legislation in relation to landscape and visual aspects is guided by the EIAO. The criteria for evaluating Landscape and Visual Impacts are laid out in the EIAO-TM. The relevant criteria for Landscape and Visual Impacts are defined in the following sections of the EIAO-TM:

3.21 The Water Pollution Control Ordinance (Cap.358) provides the major statutory framework for the protection and control of water quality in Hong Kong. According to the Ordinance and its subsidiary legislation, all Hong Kong waters are divided into Water Control Zones (WCZ).

4.1 This Section presents an assessment of air quality impact from the construction and operation of the Project. Air Sensitive Receivers (ASRs) have been identified and their respective impacts have been assessed, on a worst-case scenario basis.

Baseline Conditions

Construction Phase

4.9 Potential impacts arising from the construction of cremators include dust nuisance and gaseous emissions from the construction plant and vehicles. It is expected that dust would be generated from foundation works, site clearance, excavation, material handling and wind erosion.

4.11 The dust emission factors adopted in this assessment are given in Table 4.4. Detailed calculations of the emission factors are provided in Appendix 4.2.

4.12 The Air Pollution Control (Construction Dust) Regulation specified that reduction measures such as watering should be applied for the construction site. The control measures could reduce dust emission from the site by 50% and was assumed in the FDM model.

4.13 Hourly average and 24-hour average TSP concentrations were predicted at the ASRs. A ten hour working day was assumed in the assessment.

4.14 The dispersion model was undertaken for 288 predetermined meteorological conditions. The following meteorological conditions have been assumed in the model. Highest dust impact at each ASRs, under their respective worst meteorological conditions, was predicted by the FDM model.

4.15 Background TSP concentration of 58 mg m-3 has been included in the modelling results to account for the cumulative impact.

4.16 A sample output file of the FDM model run, which includes all the input information and model parameters for this assessment, is presented in Appendix 4.3.

Asbestos Fibre

4.17 Given the legislative control on asbestos in place, the impact of asbestos fibre was assessed by reviewing the mitigation measures as stipulated by the current ordinance and regulation. Adequacy of mitigation measure has been reviewed and the significance of impact was predicted.

Operation Phase

4.18 A total of four cremators (three 170 kg cremators and one 250 kg cremator) will be provided. The exhaust flue gases will be discharged via a multi-flue chimney (at 19m above ground), with exit temperature of 200 °C and exit velocity of 7 m s-1. The emission rates of the cremators are:

4.19 The emission rates, corrected to reference condition of 273 K, 101.3 kPa, 11% O2 and dry condition, are calculated to be 1654 m3/hr for the 170 kg cremator and 1926 m3/hr for the 250 kg cremator.

4.23 The design of the new cremators will satisfy the German Emission Standards, including the proposed mercury emission limit.

4.25 With the new cremators, the current pollutant emissions will be reduced and the latest BPM 12/2 emission concentration limits will be satisfied at all times. With the target emission limits achieved in the long run, it is likely that cremator emissions could be further reduced.

4.26 This air quality assessment was conducted based on the worst case scenario of the new cremators, i.e. BPM 12/2 concentration limits. Air quality impact of the mercury emission was also assessed against the international criteria in this EIA Study.

4.30 Sample output files of the ISCST3 model are given in Appendix 4.4.

Construction phase

Asbestos Fibre

4.36 Under the APCO, the asbestos-containing material (ACM) should be removed in accordance with the AAP. The AAP has specified all necessary precautionary and mitigation measures to control the asbestos fibre release during the removal work. The precautionary and mitigation measures include:

4.37 With the legal regulation in force, the impact due to the asbestos fibre is considered insignificant. The APCO requires the appointment of :

Operation Phase

4.38 Air quality impacts of RSP, CO, HCl, TOC, Hg, and dioxins have been predicted at the ASRs. A10 and A4 have been identified as the worst impacted ASRs, and their pollutant concentrations are shown in Table 4.8.

4.40 Table 4.9 – Table 4.19 presents the predicted air quality impacts at the ASRs. Modelling results indicated that the air quality criteria would be satisfied at all ASRs, during the operation of the Fu Shan Crematorium.

Health Risk Analysis

4.42 This section assesses the increase health risk from exposure of air toxics. Dioxins have been identified as TAP in this Study, and the incremental risk of TAP, in term of dioxin, has been assessed against the health risk guideline shown in Table 3.3.

4.45 With the operation of the new cremators, amount of dioxins emitted from the facility will be reduced by 90%. The associated risk to the community will also be reduced.

Odour

Construction Phase

4.47 As mentioned in Sections 4.34 and 4.35, with the incorporation of mitigation measures stipulated in the Air Pollution Control (Construction Dust) Regulation, exceedance of either TSP criteria or AQO is not expected at any of the ASRs. Further mitigation measures are therefore not required.

4.48 The noted mitigation measures will be enforced by normal site management practices as stated in Section 10.

Operation Phase

4.52 The Environmental Monitoring and Audit (EM&A) requirement during the operation of the crematorium are also stated in Section 10.

Construction Phase

4.53 With the incorporation of Air Pollution Control (Construction Dust) Regulation and EM&A programme, adverse residual impact is not expected.

3.7 The EIAO-TM also stipulates that the hourly TSP level should not exceed 500 µgm^-3 (measured at 25°C and one atmosphere) for construction dust impact assessment. Mitigation measures from construction sites have been specified in the Air Pollution Control (Construction Dust) Regulations.

4.15 Background TSP concentration of 58 mg m^-3 has been included in the modelling results to account for the cumulative impact.

4.18 A total of four cremators (three 170 kg cremators and one 250 kg cremator) will be provided. The exhaust flue gases will be discharged via a multi-flue chimney (at 19m above ground), with exit temperature of 200 °C and exit velocity of 7 m s^-1. The emission rates of the cremators are:

4.19 The emission rates, corrected to reference condition of 273 K, 101.3 kPa, 11% O₂ and dry condition, are calculated to be 1654 m³/hr for the 170 kg cremator and 1926 m³/hr for the 250 kg cremator.