3. INDUSTRIAL / RESIDENTIAL INTERFACE

3.1 Non-consenting Marine Lots

3.1.1 As mentioned in previous sections, there are 3 Yau Tong Bay marine lot owners have not reached an agreement with the Joint Venture at this stage to become a partner of the Joint Venture. The lots owned by these dissenting owners (the Dissenting Lots) are as follows:

(a) YTMLs 73 and 74 - occupied by Wing Shan Industrial Building (formally known as Agincourt Industrial Building);

(b) YTML 25 - currently used for material storage (timber factory from 1973 to 1993);

(d) YTML 27 - Bonanza Sawmill Ltd., same owner as YTML 1;

(e) YTMLs 2-4 - Universal Dockyard Ltd (UDL) at 2-4 Ko Fai Road;

(f) YTMLs 1 - Bonanza Sawmill Ltd., same owner as YTML 27.

Location of these land lots is shown in Figure 3.1.

3.1.2 The scenario of I/R interface has been in existence since 1992 when the Yau Tong Bay was first zoned as CDA. Even in the latest gazetted OZP No. S/K/15/13, the problem still exists. If agreement between the Joint Venture and these dissenting owners for developing Yau Tong Bay could not be made finally and the current industrial operations at these Dissenting Lots continue their operation after the occupation of CDA, the operations of shipyard, sawmill and industrial building on these lots will cause environmental nuisance to the future nearby resident in the CDA.

3.2 Study Assumptions and Principles

3.2.1 According to the geographical position of these Dissenting Lots, they can be generally grouped into three individual zones for the assessment of their environmental impacts:

(a) YTML 1 (1,129m²) & YTML 2-4 (3,527m²)

(b) YTML 25 (2,006m²), YTML 26 (1,706m²) & YTML 27 (1,140m²)

The figures shown in the brackets are the land area of the Dissenting Lots.

(a) YTMLs 1 & 2-4 – Bonanza Sawmill Ltd. & Universal Dockyards Ltd.

3.2.2 YTML 1 is located along existing seafront adjacent to YTMLs 2-4 and is currently occupied by Bonanza Sawmill Ltd. After the reclamation of Yau Tong Bay, the marine access of this lot will be removed. This physical constraint limits the type of wood / timber to be handled at the sawmill because timber logs cannot be delivered to the sawmill by water. Moreover, it is not worth and not practicable to deliver timber logs to the sawmill on road. In fact, the existing site is operated as a timber storage yard instead of sawmill. Only well-formed or prepared wood is stored in the yard and the operation of the sawmill is inactive as observed in several site visits. Under Building Ordinance and lease condition, building works on YTML 1 which are within a CDA will not be approved and change of industrial use other than sawmill or timber storage will not be permitted.

3.2.3 Universal Dockyards Ltd. (or Tai Yuen Shipyards) is currently operated on YTMLs 2-4 respectively. Since the subjected marine lots have already been zoned as CDA in the latest gazetted OZP No. S/K/15/13, application of change in land use, other than sawmill or timberyard, or application for carrying out the construction of new building structure will not be permitted in accordance with Town Planning Ordinance and Building Ordinance (relevant clauses of the ordinances are attached in Appendix 3A). Moreover, the industries of shipbuilding, ship repairing and sawmill are declined nowadays in Hong Kong facing of the competition from Mainland China and other countries in South East Asia.

3.2.4 Therefore, should the owners of YTMLs 1 and 2-4 have not reach an agreement with the Joint Venture finally, it is reasonably to assume that the current industrial operation on YTMLs 2-4 will either remain unchanged or change to sawmill operation.

Shipbuilding and Ship Repairing Industry in Hong Kong

Site Visit to Local Shipyards

3.2.5 A site visit to two local shipyards – “Wang Tak Engineering & Shipbuilding Co. Ltd.” and “The Hong Kong Shipyard Limited” by the Project Proponent and the environmental consultants was conducted on 30 January 2001. The purposes of this visit are to investigate the actual operation of shipbuilding / repair and to understand the current situation of shipbuilding / repair industry in Hong Kong.

Review of Shipbuilding / Repair Industry in Local Market

3.2.6 A paper named “Port Development Strategy Review (PDSR) Study on the Supply and Demand of Ship Repair Yards in Hong Kong” (PLVAC Paper No. 3/2001) prepared by Provisional Local Vessel Advisory Committee was issued by Planning and Development Branch of Marine Department recently. In the paper, it is concluded that the business of local ship repair yards had been declining over the past few years. In 1999, the local ship repair industry had a 46% excess in capacity and that the excess would gradually increase to 53% by 2016. These figures indicate that competition of ship repair industry has been keen. The competition is not only among local shipyards but also against the shipyards in the mainland. PLVAC Paper No. 3/2001 is attached in Appendix 3B.

3.2.7 Apart from the above information, the project proponent – Main Wealth Development Ltd. has appointed BMT Asia Pacific Ltd. in November 2000 to conduct a study on the review of Yau Tong Bay shipyards. The purpose of this study is to identify the impacts and ability of these remaining lots to function as shipyards following their isolation from the shoreline. The study report is attached in Appendix 3C. The report concluded that facing to the situation of losing marine access, competition with shipyards in Mainland China and decline in ship repair / building industry in local market, the shipyards at YTMLs 2-4 will not be viable.

Limitations and Assumptions for Shipyard Operation at YTMLs 2-4

Transportation of Marine Vessels on Public Road

3.2.8 In general, whilst the reclamation of Yau Tong Bay is complete, the marine access of YTML 2-4s will be removed. It is to everyone’s understanding that marine access is crucial to ship building, ship repairing or sawmill industry. Without marine access, the affected shipyards would be very difficult to continue their operations. Marine vessels cannot be transported by means of water to the existing shipyards at the reclaimed Yau Tong Bay for routine maintenance or repairing. Similarly, new marine vessels manufactured at the affected shipyards cannot be delivered by water too. Normally, suffering from this physical constraint, the owner of the affected shipyards would cease their shipbuilding or ship repairing business and change into another more profitable business.

3.2.9 Nevertheless, a worst scenario is assumed that the shipyards on YTMLs 2-4 can survive even without marine access. In principle, marine vessels can be lifted by crane on land or by other means and then transported on public road from or to the shipyards for repairing. As such, transportation of marine vessels on public road will be a routine operation of shipyard without marine access. In order to transport marine vessels on public road, the requirements and limitations as stipulated in the Road Traffic Ordinance must be fulfilled.

3.2.10 All road users shall follow the regulations stipulated in Road Traffic Ordinance (Cap 374), in particular, the Road Traffic (Traffic Control) Regulations (Cap 374G) and Road Traffic (Construction and Maintenance of Vehicles) Regulations (Cap 374A) for the sake of other road users. From Regulations 6 to 8 of the Construction and Maintenance of Vehicles Regulations, the maximum dimensions, weight and overhanging of vehicles are limited. In addition, according to Regulations 54 to 58 of the Traffic Control Regulations, a goods vehicle or special purpose vehicle to be driven on a road shall not exceed the permitted gross vehicle weight, permitted dimensions of loads and overhanging loads assigned unless permission from the Commissioner of Transport Department is obtained. The regulations are shown in Appendix 3A.

3.2.11 In order that marine vessel can be transported on public road, it should be towed by means of motor vehicle, such as articulated heavy goods vehicle or by trailer. Pursuant to the two above-mentioned regulations, the maximum overall dimensions of articulated heavy goods vehicle and trailer are as shown in Table 3.1.

Table 3‑1 Maximum Overall Dimensions of Vehicles

Vehicle	Overall Length (m)	Overall Width (m)	Overall Height (m)
Articulated Heavy Goods Vehicle	16	2.5	4.6
Trailer	13.5	2.5	4.6

3.2.12 Table 3.1 is extracted from Schedule 1 of Regulations Cap 374A. From the table, there are limitations on the overall length, width and height of motor vehicles to be driven on road. Furthermore, as stipulated in Schedule 2 of Cap 374A, the maximum permitted gross vehicle weight of articulated heavy goods vehicle and trailer is 38 tonnes. It can be increased to 44 tonnes for 3 or more axled motor vehicle with 3 or more axled trailer. Only those motor vehicles with marine vessel on tow fulfilling these limitations are allowed to be transported on public road. As a result, the possible type and size of the marine vessels that can be repaired or built at the shipyards on YTMLs 2-4 will be limited.

3.2.13 Although one can apply for an abnormal load movement permit (a long load or wide load permit) for transporting marine vessel with overall dimensions larger than those allowed in accordance with Regulation 55 of Cap 374G, the application process would be quite time-consuming and approvals from various government departments, such as Hong Kong Police, Highways Department and Transport Department must be obtained. As mentioned above, transportation of marine vessels is a routine operation of the shipyards without marine access, frequent application of abnormal load movement permit for marine vessel transportation is not feasible, therefore, the possibility of building or repairing marine vessels of overall dimensions larger than those allowed in the Road Traffic Ordinance is eliminated. In addition, with the limitation on the overall dimensions, the possibility of metal ship repair or building at the subjected shipyards is also eliminated.

3.2.14 Based on the above arguments, ships of size compatible to the shipyards at YTMLs 2-4 can only be pleasure yacht or speedboat, etc. As advised by experienced local ship repair and local fleet operators, these pleasure yachts and speedboats are usually made of wood, fibreglass or aluminium.

Assumptions on Operation of Shipbuilding and Ship Repair

3.2.15 In view of the limitations faced by the subjected shipyards, operation of shipbuilding or ship repair will be focused mainly on wooden, fibreglass and aluminium types of ship.

· Fibreglass Boats

- Because of stringent quality requirements for fibreglass shipbuilding, the operations shall be carried out in a fully enclosed environment.

- Due to limited space of the shipyards at YTMLs 2-4, shipbuilding / repair cannot be a continuous process and mass production of boat is not feasible.

- To build a fibreglass boat, the first step is to form a wooden frame for hull and then layering of fibreglass follows to form a boat. Limited sawing of wood is required.

- Before applying paint to a fibreglass boat, a small scale grinding by hand tools is required to roughen up the surface. This process is called “sand down”.

- Painting of a fibreglass boat is typically in four layers: Primer, Antifouling, Second coating and Final coating. Most paint used is epoxy based and can be apllied directly without thinning with solvent.

- Usually, building of a small fibreglass boat requires 3 weeks’ time and the cost is around fifty thousand dollars depending on boat size. Normally, a fibreglass boat has a life span of about 10 years.

- Due to environmental consideration and quality requirements, fibreglass shipbuilding requires a total enclosure for control of humidity, VOC emission and waste control.

- When fibreglass boat subjects to collision, cracks are likely to be extensive rather than localised, cost for repairing (including transportation cost) is comparable with building cost. It is, therefore, not worth for repairing extensive cracks in small fibreglass boat. For minor damage which only requires localised repair, fibreglass boat can be repaired at the nearest shipyards with marine access.

· Wooden Boats

- Nowadays, either manufacturing or repairing of wooden boats is being phased out in local market.

- Wooden boats are not environmentally friendly

- Elevated cost for good quality workmanship and material.

- Difficulty in achieving the same smoothness of the hull as for other materials.

- Longer time required for manufacturing (usually double the time required for fibreglass boat)

- Aging / lack of skilled workers in local market

- Therefore, building or repair of wooden boat is ruled out

· Aluminium Boats

- Because of good performance in corrosion resistance and relative light in weight, aluminium is one of the most frequently used materials for shipbuilding.

- As advised by the shipyard operators, aluminium is only used for large and up-market ships in local market. However, this aluminium made ship cannot be transported in public road due to its size.

- The required technique for aluminium shipbuilding is higher than those for wooden or fibreglass. Indoor operation is essential for good control of cleanliness for welding and good quality control of painting on aluminium

- As high technique is required for aluminium shipbuilding, upgrading of plant and equipment is necessary

- Based on the above reasons, aluminium shipbuilding / repair at the shipyard of YTMLs 2-4 is also ruled out.

3.2.16 As mentioned above, due to aging / lack of skilled workers, wooden shipbuilding or repair has been phased out already. The possibility of aluminium shipbuilding or ship repair at the shipyards on YTMLs 2-4 can also be eliminated because of the size and high quality requirement of aluminium ship. The only possible type of ship that can be built or repaired at the shipyards on YTMLs 2-4 is fibreglass.

3.2.17 The quality control for fibreglass shipbuilding is quite stringent such that indoor manufacturing is almost a must. The shipyards at YTMLs 2-4 were built in several decades ago and the capacity of the existing shipyards in terms of equipment and plant is expected not sufficient to achieve the required market standards for fibreglass ship building. In order that the existing no-marine-access shipyards may have the chance to compete with other well-developed local shipyards in the future, it is required to upgrade the current equipment and plant and to build new structures to facilitate indoor ship building requirements.

3.2.18 To build new structures for the shipyards, the shipyard owner should undergo the process of BD submission for obtaining the approval from Building Department. However, pursuant to Clause 16(1)(da) of Building Ordinance (CAP. 123), the Building Authority can refuse to give the approval of the building works which are within a comprehensive development area (CDA) of an approved or draft plan prepared under the Town Planning Ordinance. Nevertheless, the TPB will allow the carrying out of minor alteration works including maintenance works to the existing building, provided that such works do not constitute a change of use or give rise to any planning implication. Additionally, a wastewater treatment system, for example, an oil/water separation grease tank should be installed to satisfy the requirement of EPD and to obtain a license for discharge under Water Pollution Control Ordinance (CAP. 358). Therefore, the possibility of upgrading the facilities and building new structures in the shipyards for carrying out of fibreglass shipbuilding business can be eliminated.

3.2.19 Manufacturing of vessel engine is assumed not to be carried out in the shipyards as it is contravene the lease condition.

3.2.20 Existing building structures are close to the lot boundary of the shipyards, with the provision of tall podium / installation of noise barriers at the lot boundary, the shipyards can be assumed fully enclosed.

Conclusion

3.2.21 It is noted that the owners of YTMLs 2-4 are involved in a legal dispute recently which cannot be resolved in the near future. It is also understood that the owners of YTMLs 2-4 may not continue the ship repair business and may likely consider joining up with the Joint Venture to redevelop Yau Tong Bay or developing their lots individually.

3.2.22 Since there is no final decision on the arrangement of YTMLs 2-4, it is necessary to assume the shipyards still exist after the occupation of Yau Tong Bay development. Based on the above arguments, only small scale of ship repairing and shipbuilding operation for fibreglass boat can be carried out in the existing shipyards at YTMLs 2-4. This scenario will be assessed in the following sections.

(b) YTMLs 25, 26 and 27

3.2.23 Under the lease, YTML 25 and 27 can be operated as shipyard, sawmill and timber yard while YTML 26 can only be used for timber yard / sawmill. Bonanza Sawmill Ltd. is currently occupied at YTML 27 as well as YTML 1. YTMLs 25 and 26 are temporarily used for construction material storage, timber storage and car repairing activities under short-term waivers issued by Lands Department. All short-term waivers of those polluting uses currently on Yau Tong Bay Marine Lots could be terminated by Lands Department before the occupation of Yau Tong Bay CDA.

3.2.24 Facing to the keen competition from the sawmills in countries of South East Asia, high labour and operation cost, sawmill is now a sunset industry and declining in Hong Kong. Most of the existing sawmills in Hong Kong are currently used for well-formed timber storage. Timber logs are delivered to the timber yards at Yam O of Lantau Island nowadays.

3.2.25 Because of the removal of marine access to the marine lots at Yau Tong Bay, it is reasonable to assume that timber logs cannot be delivered to the existing sawmills by means of water. In fact, the sawmill at YTML 27 is used mainly for storage of well-formed timber and wood.

3.2.26 As these Dissenting Lots have already been zoned as CDA, no change of land use or building of new structure will be allowed under the provisions of Planning Ordinance and Building Ordinance. Therefore, it is unlikely for the owners of Dissenting Lots to alter their lots for shipbuilding / repair operations.

3.2.27 Although the environmental impacts generated by construction material storage at YTMLs 25 and 26 are minor, the scenario of sawmills to be operated on all three Dissenting Lots is assumed as the worst case scenario for the purpose of EIA study. The operating conditions of the assumed sawmills are exactly the same as the current sawmill at YTMLs 1 and 27. The sawmills are fully enclosed with openings in the front and rear sides. Only two numbers of hand-held saw or electric saw table would be used occasionally on-site.

3.2.28 According to the above assumptions and factual reasons, the environmental impacts generated by the assumed sawmills at YTMLs 25 –27 to the residents of future CDA and environment will be assessed in the following sections in the EIA report.

(c) YTMLs 73 & 74

3.2.29 Under the lease, YTMLs 73 and 74 are only allowed for general industrial uses and godown. The request for rezoning for extending the boundary of the CDA zoned at Yau Tong has been approved by MPC in principle on 11 December 1998. Under this rezoning, the current industrial uses at these dissenting lots will be changed to CDA. As no objection was received from the owners of YTMLs 73 and 74 during the process of the request for rezoning, therefore, it is reasonable to conclude that the owners of these lots have intention to redevelop Yau Tong Bay either individually or jointly with the Joint Venture.

3.2.30 Wing Shan Industrial Building, formerly called Agincourt Industrial Building, is now situated at YTMLs 73 and 74. It is a multi-storey concrete building structure with windows on only two opposite faces (facing to Cha Kwo Ling Road and the bay).

3.2.31 Due to the decline in industry in Hong Kong, number of tenants at Wing Shan Industrial Building reduces and vacancy increases from year to year. Vacancy of the industrial building is about 70% at present.

3.2.32 Offices and godown uses are in operation on most of the leased floor. A canteen currently occupies on the top floor of the building. There is no chimney or exhaust ventilation pipe installed on the building.

3.2.33 It is a possible that the current industrial uses at these lots may be terminated and converted to commercial uses in future, for example, offices. However, the environmental impact of commercial uses to the nearby residents in the CDA is less significant comparing with the current industrial uses. In addition, based on the factual reason stated above, it is logically to assume that industry in Hong Kong would not grow up again and the amount of industrial operation in the building would not be increased in future. According to these assumptions and facts, the assessment for the environmental impacts due to I/R interface at YTMLs 73 and 74 will be based on the current industrial uses.

3.3 Development and Phasing Layout due to I/R Interface

3.3.1 Proper arrangement of development layout and construction phasing of future Yau Tong Bay CDA are the effective mitigation measures to alleviate the environmental impacts due to I/R interface problem.

3.3.2 In Section 2, it is mentioned that there are two development options for the layout plan of Yau Tong CDA (Figure 2.2a and 2.2c) if agreement between the dissenting owners and the Joint Venture can be reached well before the construction works start. The whole Yau Tong Bay can be developed in one goal. These development options can be considered as an ideal situation. The environmental impacts of Yau Tong Bay Development based on these development options have been assessed in the following sections of the EIA report and are found to be acceptable with the implementation of suitable mitigation measures.

3.3.3 However, should the agreement could not be reached before the commencement of the construction works of Yau Tong CDA, the existing industrial operations and premises will remain on the current Dissenting Lots. The scenario of coexistence of residential and industrial area will occur. Two development options for the development layout plan – “Minimized Reclamation with I/R Interface Stage A (Figure 2.2b)” and “Full Reclamation with I/R Interface Stage A (Figure 2.2d)” are introduced to alleviate the environmental impacts by careful arrangement of building layout.

3.3.4 In these two development layouts for I/R interface problems, the characteristics of arrangement on building layout are summarized in the follows:

· three numbers of school (S3, P4 and P5) are proposed along the waterfront

· one commercial tower with 15m high podium is located adjoining to the shipyards on YTMLs 2-4

· shopping arcades and office towers with 15m high podium will be built to surround YTMLs 25-27

· noise tolerant building design (single aspect building) is proposed for residential tower nos 1, 7, 12, 13 and 34 which are located in the vicinity of the Dissenting Lots

· areas for school no. S2 and residential tower no. 31 adjacent to YTMLs 73-74 and YTMLs 2-4 respectively are reserved as open space. These building structures will be built upon the removal of industrial operations.

3.3.5 If the problem of I/R interface can be resolved during the construction stage or in final stage, then development on the Dissenting Lots and the reserved open space can proceed. The final stage of development layout plans for I/R interface are shown in Figure 3.2 – “Minimised Reclamation with I/R Interface Stage B” and Figure 3.3 – “Full Reclamation with I/R Interface Stage B”. The environmental impacts, mainly noise and air quality impacts, based on these final development layout plans will be assessed in the following parts of Section 3 and Section 4.

3.3.6 Phasing of the development for the Development Options with I/R interface are expressed in Figure 3.4 and 3.5. Basically, same development programme as shown in Figure 2.3 can be applied for Development Options 1B and 2B such that number of residential towers and schools to be built in each phase remain the same. The programme may be adjusted slightly in case of I/R interface if necessary.

3.4 I/R Interface Noise Problem from Remaining Lots

3.4.1 The anticipated noise impacts and assessment results of I/R interface problem from the remaining lots are summarized in Section 5 – Noise Impact.

3.5 I/R Interface Air Quality Problem from Remaining Lots

Industrial/Residential (I/R) Interface Issue

3.5.1 The I/R interface problems caused by the dissenting lots and the assumptions for the continuing operations of these lots have been described in the previous sections, Based on these assumptions, the air quality impacts have been assessed and reported.

Timberyards/Sawmills

3.5.2 The sites identified to have any likelihood to operate as a sawmill are YTML 1, YTML 2-4, YTML 25-26 and YTML 27.

3.5.3 The assessment criteria for dust control are based on Air Quality Objectives (AQOs) as required by Annex 4 of the Technical Memorandum on Environmental Impact Assessment Process (TM). The standards for TSP were adopted and given in Table 3.2.

Table 3‑2 Hong Kong Air Quality Objectives for Pollutants

Pollutant	Pollutants concentration in µg/m³
	Averaging Time
	1 hour (i)	8 hours (ii)	24 hours (ii)	1 year (iii)
TSP	N.A.	N.A.	260	80

Meteorological Data

3.5.4 Meteorological data of Junk Bay Weather Station of the year 1998 obtained from the Hong Kong Observatory have been used in the ISCST computer model. Parameters used include:

· Hourly wind direction;

· Hourly wind speed with minimum assumed as 1m/s;

· Hourly Pasquill stability class (A to F);

· Hourly ambient air temperature (°K);

· Morning and afternoon mixing heights (m); and

· Total sky cover, and sky cover and ceiling height of the 1st - 4th layer.

Source Description and Emissions Inventory

3.5.5 There is only one non-consenting site currently operating as sawmill/timber storage at the proposed Yau Tong Bay development site: YTML 27. Based on the assumptions mentioned in the previous sections, the air quality impacts from the limited sawing activities has been assessed based on the assumptions listed in the following.

3.5.6 If land owners of the above mentioned lots choose to be excluded from the proposed redevelopment project and continue to operate as timber yard, saw dust could potentially be generated from these operations and could impose an impact upon the proposed development. This report has quantitatively assessed the air quality impact from the timber yard during the operational phase of the development.

Technical Assumptions

3.5.7 Area coverage of YTML27 is approximately 1,140m² (15m x 76m).

3.5.8 Timber storage:

· Based on site observations, timbers are stacked to average of approximately 3m high occupying about 70% of the lot

· Volume of timber = 1,140 x 70% x 3 = 2,394 m³ of timber

3.5.9 It was assumed that sawing would comprise at most 10% of the timber; i.e., ~240m³ on a monthly basis. This volume was considered in line with the observations from repeated site visits that there were minimal sawing activities.

3.5.10 In order to calculate the dust emission rate from the sawmill, the following assumptions were used:

· Density of timber: 700kg/m³ (average of soft wood 450 kg/m3 and hard wood 950 kg/m3)

· Total mass of timber for sawing =167,580 kg per month; i.e.: 0.19 kg/s

3.5.11 According to AP-42, Fifth Edition, Volume I: Stationary Point and Area Sources published by USEPA, the particulate emission factor for log sawing process is 0.175 kg/MT (Metric Tonne) of timber.

3.5.12 As timberyard sites shall be taken as fully enclosed as established in the general assumptions, emission of the dust could only be through openings of the enclosure. The emission factor was taken as an area source at 2.92x10^-5 g/s-m² as calculated from the assumptions made for YTML 27 (0.19kg/s x 0.175kg/MT/1,140m³), which shall be a conservative estimation as compare to an enclosed emission source. The dimensions of the openings were immaterial as the calculation has not taken into account neither the enclosure nor the openings of an enclosure.

3.5.13 Site areas for other timberyard sites are:

Marine Lot Number	Site Area (m²)
YTML 1	1129
YTML 2-4	3527
YTML 25	2006
TYML 26	1706
YTML 27	1140

Assessment Methodology

3.5.14 The assessment of dust emission from the timberyards was carried out using the software "Industrial Source Complex Short Term Version 3 (ISCST3)" developed by Trinity Consultants Incorporated. This model is based on the principle of Gaussian dispersion and is widely acceptable by authorities world-wide including the Hong Kong Environmental Protection Department (EPD) and the United States Environmental Protection Agency (USEPA). Selected section of a typical ISCST.LST result file for TSP emission assessment is included in Appendix 3D for reference.

Air Sensitive Receivers

3.5.15 Air sensitive receivers (ASRs) were selected in accordance with a 30m by 30m grid covering the entire proposed development for assessing all pollutants of concern.

3.5.16 The variation of TSP concentration with respect to building height was predicted at breathing zone (1.5m above floor) of podium level (where ASRs of the closest horizontal distance from the dust source are located), 1/F, 4/F and 7/F. As the dust concentration will decrease with height, further assessment of ASR on floors higher than 7/F was not considered necessary. As the school sites are segregated from the timber yards by the 15m high podium, dust impact from the timber yards on the school sites is not anticipated.

3.5.17 The predicted pollutants concentrations were then used to generate two-dimensional concentration contour maps, which were then superimposed onto the master layout plan of the proposed development. The sensitive receivers at the I/R interface are the same for both Minimised and Full Reclamation options. Hence, the results are only presented on the Full Reclamation option.

Assessment Results

3.5.18 Assessment results were generated from a cumulative impact of all five sites simultaneously including background. The results are presented in concentration contours, which are given in Figure 3.6 to Figure 3.9. Background concentrations were taken from EPD’s publication: Air Quality 2000, at Kwun Tong, which was 79mg/m³. With reference to Para. 3.5.17 above, I/R interface dust impact is insignificant for both Minimised and Full Reclamation options.

Conclusion

3.5.19 Air quality impacts due to sawmill operations at the dissenting lots have been assessed and the results indicate that the air quality impacts upon the proposed development, in terms of dust, are likely to be within the relevant standards.

VOC Impact form Shipyard Operations

3.5.20 The sites identified to have any likelihood to operate as a shipyard is YTML 2-4.

3.5.21 There are two air quality concerns that could potentially be generated from shipyard operations, namely VOC and odour. The two issues are related as VOC is the predominant source of odour from a ship building operation.

VOC Emission factors:

3.5.22 Odour is caused by VOCs emitting from paint products. The emission factors depend on the type and quantity of VOC in the paint. In order to determine such factors, samples of typical boat paints have been obtained from an existing, operating shipyard in Hong Kong and analysed for VOCs and their concentrations using GC-MS-SCAN. The paint sample analysis reports of the paint products are given in Appendix 3E.

3.5.23 Results showed that the main components are:

Parameter	JVA003	CPA099	BRA142	BFA274
Units:	% (w/w)	% (w/w)	% (w/w)	% (w/w)
Ethyl Benzene	1.1	3.2	5.3	5.0
Methyl Isobutyl Ketone	21	<0.010	<0.010	<0.010
Toluene	0.11	0.016	0.026	0.011
Xylenes	26	3.9	16	24

Note: JVA003, CPA099, BQA347 and BFA137 are proprietary codes for anticorrosive coating, primer, first coating, and final coating respectively.

3.5.24 The emission factor of VOCs from paint application on boats was derived from AP-42, Section 4.2.2.1 General Industrial Surface Coating, Table 4.2.2.1-1 (April 1981), which has provided a method of estimating emission factors for VOCs for uncontrolled surface coating.

3.5.25 The emission rates of VOCs from paint application were estimated from the above sampling results and the AP-42 reference method together with further assumptions listed below:

· Under the Road Traffic Ordinance the ship on tow (including vehicle itself) cannot exceed the maximum allowable dimensions of vehicle: 16m(L) x 2.5m(W) x 4.6m(H).

· Painted surface of the ship include the exterior ship body has been estimated taking the shipbody to be triangular at the rear ends with the slanting length taken to be the hypotenuse of a triangle in a 2.5m x 4.6m rectangle, i.e. 4.8m. The shipbody was taken to be extending to the full length possible for inland towing (i.e., 16m). The ship exterior surface was estimated to be 159.4m² {16x4.8x2 + [(2.5x4.6)/2]}.

· Typical thickness of a painted film is 172 microns when the paint is wet (reference from specification of paints obtained from an existing shipyard). This is an average taken from:

1) primer: 183 microns;

2) anti-fouling: 179 microns;

3) second coating: 75 microns; and

4) final coating: 250 microns

· The volume of paint required to paint one boat is then 159.4m² x 172 microns = 0.028m³.

· Density of paint is taken to be: 870 kg/m³

· Therefore the weight of paint required to paint one boat is 24.4kg.

3.5.26 From interview with existing shipyard operators, it takes roughly 6 days for the paint work to dry thoroughly in order for the next layer of paint to be applied. It was then assumed that entire content of the VOC from the paint will evaporate throughout the 6 days period.

3.5.27 The estimated emission rates (g/s) of the concerned VOCs were tabulated below:

Parameter	JVA003	CPA099	BRA142	BFA274
Ethyl Benzene	0.0005*	0.0015	0.0025	0.0024
Methyl Isobutyl Ketone	0.0096	insignificant	insignificant	insignificant
Toluene	0.0001	insignificant	insignificant	insignificant
Xylenes	0.0122	0.0018	0.0075	0.0113

* sample calculation: (Wt x w/w%)/t = (24.4kg x 1.1%)/(6x24x3600) = 0.0005g/s

Assessment Methodology

3.5.28 The assessment of the dispersion of VOC from the ship-building was carried out using the software "Industrial Source Complex Short Term Version 3 (ISCST3)" developed by Trinity Consultants Incorporated. This model is based on the principle of Gaussian dispersion and is widely acceptable by authorities world-wide including the United States Environmental Protection Agency (USEPA) and the Hong Kong Environmental Protection Department (EPD). Selected section of a typical ISCST.LST result file for VOC emission assessment has been enclosed in Appendix 3F for reference.

Assessment Parameter

3.5.29 Xylene was found to be the major component in the paint samples and hence it has been used as the indicator of VOC emission impact assessment. The calculated maximum emission rate of 0.0122g/s was used in the impact assessment.

Assessment Criteria

3.5.30 In accordance to Annex 4 of the Technical Memorandum (EIAO), WHO standards for air quality were used.

3.5.31 24 hour guideline value for xylenes is 4,800mg/m³ as published in “Guidelines for Air Quality, WHO”.

Air Sensitive Receivers

3.5.32 Air sensitive receivers (ASRs) were selected in accordance with a 30m by 30m grid covering the entire proposed development for assessing all pollutants of concern.

3.5.33 The variation of VOC concentration with respect to building height were predicted at breathing zone (1.5m above floor) of the podium level, 1/F, 4/F and 7/F. The predicted concentration of VOC began to drop at 7/F and hence the worst affected floors are those between podium and 7/F.

3.5.34 The predicted pollutants concentrations were then transferred to a separate computer software to create two-dimensional concentration contour maps, which were then superimposed onto the master layout plan of the proposed development.

Meteorological Data

3.5.35 Meteorological data of Junk Bay Weather Station of the year 1998 obtained from the Hong Kong Observatory have been used in the modelling with ISCST programme. Parameters used include:

· Hourly wind direction;

· Hourly wind speed with minimum assumed as 1m/s;

· Hourly Pasquill stability class (A to F);

· Hourly ambient air temperature (°K);

· Morning and afternoon mixing heights (m); and

· Total sky cover, and sky cover and ceiling height of the 1st - 4th layer.

Assumptions Used in the ISCST Model

3.5.36 It has been established and agreed that scenario of fibre-glass ship building is to be carried out under enclosed condition. Assuming that the entire content of VOC was emitted from the painted surface and that the air within the enclosed structure is well mixed and a 5 ACPH ventilation rate is provided, the total flow from the exhaust is:

· Volume of enclosure: ~55m(L) x 25m(W) x 8m(H) = 11,000m³

· 5 ACPH yield 55,000m³/hr = 15.3m³/s

· Exit velocity = 9m/s, which is typical of an industrial exhaust.

· The discharge height was taken to be at 8m above ground level.

Results

3.5.37 Xylene impact from existing shipyard operation upon the proposed development have been quantitatively assessed. The predicted highest 24-hour average xylene concentration at different assessed levels are presented graphically in Figure 3.10 to Figure 3.13.

3.5.38 Predicted xylene concentration at the proposed development lies well below the WHO Guidelines Values and future residents of the proposed development would not be exposed to unacceptable VOCs emission impact from the existing shipyard operations.

Odour Impact from Shipyard Operations

3.5.39 Odour will result from VOC emission from paint products. According to the results of VOC analysis on the typical paint samples, the predominant source of odour is from Methyl Isobutyl Ketone, which has a low odour threshold. Using the same methodology outlined above, the impact of Methyl Isobutyl Ketone has been assessed.

3.5.40 The operation of fiberglass shipbuilding process is unlikely to be a source of VOC/odour emission. A sample of each of a typical Resin and Accelerator (an agent used to speed up the curing process of the Resin) was taken from an operating shipyard for GC-Scan and has revealed no VOC content. The sample analysis report is given in Appendix 3G.

3.5.41 The odour threshold of Methyl Isobutyl Ketone was reported to be 0.410 mg/m³ while the odour threshold for Xylene was 4.5 mg/m³.

Assessment Methodology

3.5.42 The assessment on the dispersion of Methyl Isobutyl Ketone as an odour source from the ship-building operation was carried out using the software "Industrial Source Complex Short Term Version 3 (ISCST3)" developed by Trinity Consultants Incorporated. This model is based on the principle of Gaussian dispersion and is widely acceptable by authorities world-wide including the Hong Kong Environmental Protection Department (EPD) and the United States Environmental Protection Agency (USEPA). Selected section of a typical ISCST.LST result file for odour emission assessment has been enclosed in Appendix 3H for reference.

3.5.43 The modeling parameters were as per the VOC impact assessment above.

3.5.44 The Methyl Isobutyl Ketone concentrations predicted were then converted to Odour Units using the odour threshold. Odour threshold values were obtained from the US National Library of Medicine, Toxicology Data Network, Chemical Information Page.

3.5.45 Since the estimated Methyl Isobutyl Ketone concentration is hourly averaged, an odour conversion factor of 27 (Stability Class C) was used to convert the hourly concentration to 5 second concentration in order for comparison with the odour criteria. The conversion factor was referenced to EPD’s published guideline “Guidelines on Choice of Models and Model Parameters”. Section 3.8 of the said guideline provided conversion factors from 1-hour to 5-sec for odour impact assessment results. It was also stated in under the same section of the guideline that the conversion factors, when used with the ISCST results “may not be suitable for assessing the extreme close-up impacts of odour sources”. A more conservative factor of 27 for stability class C was therefore used. Conversion factors for all six stability classes are listed in the following for reference:

Stability Category	1-hour to 5-sec Conversion Factor
A & B	45
C	27
D	9
E & F	8

3.5.46 A limit value of 5 odour units (based on an averaging time of 5 seconds), as stipulated in Annex 4 of the EIAO-TM has been adopted for this assessment.

Results

3.5.47 Odour impact from the potential continuing shipyard operation upon the proposed development has been quantitatively assessed. The predicted highest 5 second average odour level at podium, 1/F, 4/F and 7/F were presented graphically in Figure 3.14 to Figure 3.17. The levels of these contours were 13.0mPD, 18.0mPD, 26.4mPD, 34.8mPD respectively.

3.5.48 The highest level of impact was expected to be between 4/F and 7/F as a drop in predicted concentration was observed between 4/F and 7/F.

3.5.49 The predicted odour levels at the proposed development are well below the 5 odour units limit. It can be concluded that future residents of the proposed development would not be exposed to unacceptable odour impact from the shipyard operations.

Odour from Canteen operations (Wing Shan Industrial Building)

3.5.50 Wing Shan Industrial Building was 70% vacant at the time of submission of this report. Repeated site visits and the lease schedule both indicated that the remaining tenants operate mainly as godown with a canteen on top floor.

3.5.51 The canteen operation provides a typical fast food menu with lunch dishes, and morning/afternoon tea items of assorted beverages, sandwiches and instant noodles.

3.5.52 Although there is only one canteen operation at Wing Shan Industrial Building, it has been stipulated in Wing Shan Industrial Building’s lease condition that 10% of the total floor space can be used as canteen.

3.5.53 These canteen operations posed as potential sources of odour nuisance. Assessment has been carried out to ascertain whether odour generation from the maximum canteen operations could amount to environmental nuisance.

Site observations

3.5.54 Site visits were carried out during peak and non-peak hours. It was observed that the main clientele is construction site workers in the Yau Tong area, and the peak service hours are mostly during lunch.

3.5.55 The cooking utilities comprise a frying area, which was hooded with an air wash. Next to the frying area was a beverage counter. It was also observed that a separate room at the back of the main kitchen area was used to steam food.

3.5.56 The exhaust of the canteen faces directly onto Cha Kwo Ling Street, which is away from the planned residential blocks.

3.5.57 An existing air wash offered some reduction of odour at source.

3.5.58 The site visits had revealed that normal restaurant odour within the canteen area. There was noticeable odour detected outside the restaurant, e.g. in the lift and on the floor below.

3.5.59 Wing Shan Industrial Building was 40m deep. With the separation of 17m between Wing Shan Industrial Building and the closest planned residential block, the exhaust is some 52m away from the first residential dwelling.

Results

3.5.60 With the given distance separation, insignificant odour source (based on site observation) the air wash facility and the nature and service capacity of the canteen, cumulative odour impact generated from the existing and allowable canteen is not expected to be of concern.

3.6 Land Contamination Impact from Adjacent Industrial Operation

3.6.1 Land contamination was confirmed by previous land contamination impact assessment exercises. Soil remediation in terms of biopiling, solidification and landfilling were proposed and will be carried out at the contaminated area within the proposed development area prior to construction works. However, land contamination is also highly suspected at YTML 2-4, although no sampling and soil analysis was conducted at that site due to inaccessibility. The conclusion was drawn with reference to the land use history of the site and analysis results from site with similar land use history.

3.6.2 It has been qualified in a land contamination assessment for Package 1 of the Yau Tong Bay development (Reclamation of Yau Tong Bay) that further site investigation in the form of detailed visual inspection and sampling will be carried out when access can be gained upon the dissenting partners’ consent to participate in the development.

3.6.3 It has been qualified from the same that among the dissenting lots, only YTML2-4 are suspected of land contamination, based on information such as history of use, site visits, and preliminary visual inspections.

3.6.4 After completion of the soil remediation at the consenting lots, contaminants level in the soil within the development boundary shall be within stipulated standards. In order to avoid migration of contaminants to the cleaned soil from YTML2-4, a vertical geomembrane mounted on concrete setting could be installed along the site boundary adjacent to the contaminated site. The geomembrane will act as a physical barrier, preventing contaminants to migrate towards the development site. The concrete surface will provide a stable basis for securing the geomembrane. The geomembrane shall extent to at least 1 m below lowest groundwater level, which can ensure effectiveness of the barrier during low tides as well as high tides.

3.6.5 A conceptual diagram showing the cross-section of the membrane and the sites is contained Figure 3.18. The geomembrane is only necessary for the scenario when YTML2-4 is not joined together with the rest of the development lots. Should YTML2-4 become a consenting partner in time for the site to be developed with the rest of the development, the geomembrane will not be necessary. This geomembrane is only a temporary measure, which can be removed once all land remediation, including that at YTML2-4, is satisfactorily completed.

3.7 Proposed Mitigation Measures

3.7.1 Although the scenario of coexistence of residential and industrial area within future Yau Tong Bay CDA cannot be resolved at this stage, the environmental problems arising from I/R interface can be effectively alleviated or mitigated by a series of mitigation measures such as:

· Provision of noise barriers

· Provision of tall building podium

· Careful re-arrangement of building layout

· Sufficient set back of residential tower and school from polluting source – the minimum buffer distances for mitigating the environmental impacts of I/R interface problems are summarized in Table 3.3

· Proper development phasing arrangement – Figure 3.4 and 3.5

· Use of noise tolerant building design for residential towers

· Provision of open space to act as buffer area from polluting industrial uses at Dissenting Lots

· Termination of short-term waivers for polluting industrial activities

3.7.2 Application of the above mitigation measures for each of the Dissenting Lots is summarized in Table 3.4 to Table 3.7.

Table 3‑3 Minimum Buffer Distances for Mitigating the Environmental Impacts of I/R Interface

Dissenting Owners	Buffer for Mitigating Noise Impacts (m)	Buffer for Mitigating Dust / Odour Impacts (m)	Buffer Distances to be Provided (m)
Timber yards / Sawmills operation	· Minimum 40m from residential towers^[1] · Minimum 36m from school^[1] · Minimum 30m from single aspect building	As per noise imapct	· Minimum 40m from residential towers[1] · Minimum 36m from school[1] · Minimum 30m from single aspect building
Shipyard Operation	· Minimum 68m from residential towers · Minimum 62m from school^[2]	As per noise impact	· Minimum 68m from residential towers · Minimum 62m from school[2]
Canteen Operation (Wing Shan Industrial Building)	· Minimum 16m from single aspect towers · Minimum 70m from school	As per noise impact	· Minimum 16m from single aspect towers · Minimum 70m from school

[1] Buffer distance with 15m high podium for screening

[2] Buffer distance with high-rise office building on top of a 15m high podium for screening