6                        Waste management implications

6.1                 Introduction

6.1.1           This section identifies the types of wastes that are likely to be generated during the construction of the drainage improvement works and evaluates the potential environmental impacts that may result from the handling and disposal of these waste arisings. The main solid waste management implications are related to excavated materials from earthworks for the river improvement works.  Mitigation measures and good site practices, including waste handling, storage and disposal have been recommended with reference to the applicable waste legislation and guidelines.

6.2                 Environmental Legislation, Policies, Plans, Standards and Criteria

6.2.1           The following legislation relates to the handling, treatment and disposal of wastes in the Hong Kong SAR and was 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 Regulation; and

·        Dumping At Sea Ordinance (Cap. 466).

 

Waste Management

6.2.2           The Waste Disposal Ordinance (WDO) prohibits the unauthorised disposal of wastes.  Construction waste is not directly defined in the WDO but is considered to fall within the category of “trade waste”.  Trade waste is defined as waste from any trade, manufacturer or business, or any waste building, or civil engineering materials, but does not include animal waste.  Under the WDO, wastes can be disposed of at sites licensed by the Environmental Protection Department (EPD).

6.2.3           Under the regulation of WDO, the Chemical Waste (General) Regulation 1992 provides regulations for chemical waste control, and administers the possession, storage, collection, transport and disposal of chemical wastes.  The EPD has also issued a ‘guideline’ document, the Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes (1992), which details how the Contractor should comply with the regulations on chemical wastes.

6.2.4           The Public Cleansing and Prevention of Nuisances Regulation provides control on illegal tipping of wastes on unauthorised (unlicensed) sites.

 

 

 

 

Construction and Demolition (C&D) Materials

6.2.5           The current policy related to the dumping of C&D material([1]) is documented in the Works Branch Technical Circular No. 2/93, ‘Public Dump’.  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 Provisions) Ordinance requires that dumping licences are obtained by individual or companies who deliver public fill to public filling areas.  The licences are issued by the Civil Engineering and Development Department (CEDD) under delegated powers from the Director of Lands.

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

6.2.7           Measures have been introduced under Environment, Transport and Works Bureau (ETWB) TCW No. 33/2002 to enhance the management of C&D material including rock, and to minimise its generation at source.  The enhancement measures include: (i) drawing up a Construction and Demolition Material Management Plan (C&DMMP) at an early design stage to minimise C&D material generation; (ii) vetting of the C&DMMP prior to upgrading of the project to Category A in the Public Works Programme; and (iii) providing the contractor with information from the C&DMMP in order to facilitate him in the preparation of the Waste Management Plan (WMP) and to minimise C&D material generation during construction.  Projects generating less than 50,000m3 C&D material or importing less than 50,000m3 fill material are exempt from the C&DMMP.   A new technical circular ETWB TCW 15/2003 was recently issued to introduce additional measures to enhance waste management on construction sites.  The circular sets out the policy and procedures requiring contractors to prepare and implement an enhanced WMP to encourage on-site sorting of C&D material and to minimise their generation during the course of construction.

6.2.8           The ETWB TCW No. 34/2002 sets out the management framework for dredged/excavated sediment.  This Technical Circular outlines the procedures to be followed in assessing and classifying sediment and explains the marine disposal arrangement for the classified material.  The sediment quality criteria for the classification of sediment are presented in Table 6.1. Dumping permits from EPD are required for marine disposal of dredged/excavated materials.

6.3                 Assessment Methodology

General

6.3.1           The methodology for assessing potential waste management impacts during the construction phase of the Project included the following tasks:

·        estimation of the types and quantities of wastes to be generated as a result of construction activities;

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

·        evaluation of the opportunities for reducing waste generation;

·        identification of disposal options for each type of waste;

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

 

Excavated Riverbed Material

6.3.2           A sediment quality characterization survey was carried out in February 2003 to characterise the level of contamination in the riverbed material of Sai Kung River, Pak Kong River and Ho Chung Channel for the purpose of this EIA. The works comprised sampling by hand-auger at a total of eight locations within the three river channels to obtain samples for chemical testing (Figure 6.1).  The methodology for the sampling and laboratory testing of the riverbed samples was agreed with EPD prior to the commencement of the survey.

6.3.3           The riverbed samples were tested in the laboratory for the following parameters:

(i)                  Metals concentrations including chromium (Cr), copper (Cu), mercury (Hg), lead (Pb), cadmium (Cd), nickel (Ni), zinc (Zn), silver (Ag) and arsenic (As).

(ii)                Concentrations of organic compounds: total polychlorinated biphenyls (PCBs) and polyaromatic hydrocarbons (PAHs).

6.3.4           The chemical contaminant criteria under the management and classification system for excavated material destined for marine disposal are listed in Table 6.1 below.

 

Table 6.1     Sediment Quality Classification Criteria

 

Contaminants

LCEL

UCEL

Heavy Metal (mg/kg dry weight)

Cadmium (Cd)

1.5

4

Chromium (Cr)

80

160

Copper (Cu)

65

110

Mercury (Hg)

0.5

1

Nickel (Ni)

40

40

Lead (Pb)

75

110

Silver (Ag)

1

2

Zinc (Zn)

200

270

Metalloid (mg/kg dry weight)

Arsenic

12

42

Organic-PAHs (µg/kg dry weight)

PAHs (Low Molecular Weight)

550

3160

PAHs (High Molecular Weight)

1700

9600

Organic-non-PAHs (µg/kg dry weight)

Total PCBs

23

180

Source:   Appendix A of ETWB TCW No. 34/2002 Management of Dredged / Excavated Sediment

Note:      LCEL –   Lower Chemical Exceedance Level

                            UCEL –  Upper Chemical Exceedance Level

 

6.3.5           Sediments are categorised with reference to the LCEL and UCEL, as follows:

Category L           Sediment with all contaminant levels not exceeding the LCEL.  The material must be dredged, transported and disposed of in a manner that minimises the loss of contaminants either into solution or by suspension.

Category M          Sediment with any one or more contaminant levels exceeding the LCEL and none exceeding the UCEL.  The material must be dredged and transported with care, and must be effectively isolated from the environment upon final disposal unless appropriate biological tests demonstrate that the material will not adversely affect the marine environment.

Category H          Sediment with any one or more contaminant levels exceeding the UCEL.  The material must be dredged and transported with great care, and must be effectively isolated from the environment upon final disposal.

                                                              

6.3.6           For projects with disposal requirements of less than 50,000 m3 Category L sediment, the allocation of sediment disposal space had been delegated to Director of Environmental Protection (DEP) in accordance with ETWB TCW No. 34/2002.

6.3.7           The chemical testing results of the riverbed samples as compared with the classification criteria are presented in Table 6.2.  The chemical testing results indicate that Category L material was found at all sampling locations apart from SK1, HC1 and PK3.  Category M material was found at sampling location SK1 in terms of PAHs and zinc, at sampling location HC1 in terms of copper and zinc, and at sampling location PK3 in terms of lead.   

 

Table 6.2   Contaminant Levels of Riverbed Soil Samples and their Categories

 

Sampling Station No.

LMW

HMW

Total

PCBs

Metals

Overall Category

PAHs

PAHs

mg/kg

µg/kg

µg/kg

µg/kg

Ag

As

Cd

Cr

Cu

Ni

Pb

Zn

Hg

HC1

<550

<1700

<3

<0.1

5.8

0.07

12.7

70

6.4

24.2

262

0.05

M

HC2

<550

<1700

<3

<0.1

2.2

<0.02

4

3.7

2.5

6.5

36.6

0.02

L

HC3

<550

<1700

<3

<0.1

3.2

0.09

5.3

8.7

2

18.3

70.7

0.04

L

PK1

<550

<1700

<3

<0.1

3.8

0.7

31.9

31.2

8.3

21.7

118

0.05

L

PK2

<550

<1700

<3

<0.1

3.5

0.07

8.7

14.8

4.1

25.5

69

0.03

L

PK3

<550

<1700

<3

<0.1

4.2

0.22

11.1

33.7

7.3

76.9

171

0.1

M

SK1

910

3680

<3

<0.1

7.7

0.22

11.9

23

19.8

44.7

222

0.06

M

SK2

<550

<1700

<3

<0.1

3.2

0.07

5.6

4.6

1.4

14.8

64.8

0.03

L

 

Notes:

1.        LMW = Low molecular weight PAHs, that is, acenaphthene, acenaphthylene, anthracene, fluorene, naphthalene and phenanthrene.

2.        HMW = High molecular weight PAHs, that is, benzo[a]anthracene, benzo[a]pyrene, chrysene, dibenzo[a,h]anthracene, fluoranthene, pyrene, benzo[b]fluoranthene, benzo[k]fluoranthene, indeno[1,2,3-c,d]pyrene and benzo[g,h,i]perylene.

3.        Values in underline indicate Category M sediment under ETWB TCW No. 34/2002.

 

6.4                 Identification of Evaluation of Environmental Impacts

6.4.1           The construction activities to be carried out for the proposed Project would generate a variety of wastes that can be divided into distinct categories based on their composition and ultimate method of disposal.  The identified waste types include:

·        construction and demolition (C&D) materials;

·        chemical waste; and

·        general refuse.

 

6.4.2           The nature of each type of waste arising is described in the following section, together with an evaluation of the potential environmental impacts associated with these waste arisings.

 

Construction and Demolition (C&D) Materials

6.4.3           Construction of the river improvement works would involve earthworks for the new river channel to the required profile and formation levels. The excavated materials would comprise mostly soil, sand, gravel and small rocks from the fields and river/stream channels.  Based on the proposed design of the river improvement works, the total volume of excavated materials to be generated from the construction of the Project was estimated by the Project Engineer to be approximately 67,200 m3.  

6.4.4           The results of the sampling and laboratory testing provided information on the characteristics of the excavated materials from the riverbed.  The samples collected at all 8 sampling locations were described as alluvial sand, and some gravel was described in the samples from the Pak Kong River. A possible cause for the moderate levels of copper and zinc recorded at sampling location HC1 in the Ho Chung Channel and zinc recorded at sampling location SK1 in the Sai Kung River could be livestock waste discharges.  Construction works were observed in close proximity to SK1 and a possible cause for the moderate level of PAHs recorded could be localised spillage or leakage of vehicle or equipment oil.  Road re-surfacing works have also been carried out recently for Tai Mong Tsai Road, immediately adjacent to SK1.  Sampling location PK3 was located adjacent to village houses and a small vehicle workshop. 

6.4.5           Uncontaminated excavated materials from the river improvement works would be suitable for disposal to a public filling area.  The reported levels of zinc, copper, lead and PAHs in the samples collected at sampling locations SK1, HC1 and PK3 did not exceed the Dutch B level for soil,([2]) and therefore the riverbed material is considered to be not contaminated in this regard. The excavated riverbed soil at sampling location HC1 is proposed to be re-used on-site as far as practicable, with surplus excavated materials disposed to a public filling area.  (SK1 and PK3 are located outside the excavation area for the proposed new channels for the drainage improvement works to the Sai Kung River and Pak Kong River, respectively).     

6.4.6           It was estimated by the Project Engineer that approximately 13,700 m3 of the excavated materials from the river improvement works would be of suitable characteristics for reuse on-site for backfilling of temporary drainage channels and as fill material in the construction of embankments.  Temporary stockpiles of excavated materials would be required on-site before disposal.  Considering the unpolluted nature of the excavated materials, reuse on-site would not result in any unacceptable environmental impact.  It is proposed that small cobbles and rocks from the existing rivers be re-used in the recreated channel beds as far as possible, subject to suitable size requirements.  Surplus excavated soil, sand, gravel and rock would be transported by trucks to the designated barging point for disposal at the designated public filling area, or transported directly to the public filling area. 

6.4.7           C&D material would also be generated from the demolition of existing crossings over the river channels and structures.  The volume of C&D material was estimated by the Project Engineer to be approximately 9,900m3 and would comprise mostly concrete, brick and cement plaster/mortar. C&D waste would be generated during site clearance and the estimated volume of C&D waste for a contract of this size was approximately 26,700 m3.  These C&D wastes would comprise vegetation and top soil and would be delivered to a designated landfill site for disposal.  A summary of the estimated volumes of excavated material generated from earthworks for the new river channels, as well as C&D material generated from the demolition of existing crossings and structures and from site clearance is presented in Table 6.3 below.

Table 6.3            Summary of C&D Material Volumes (Bulk Volumes)

 

Improvement Works

C&D Material (m3)

Inert

(Disposal to public filling area)1

 

Non-inert

(Disposal to landfill)2

Excavated material from earthworks for river channels:

Sai Kung River/Sha Ha Stream

Pak Kong River

Ho Chung Channel

 

67,200

(13,700 m3 to be re-used on-site)

 

 

Demolition of existing river crossings and structures

7,600

2,300

Site clearance

--

26,700

Notes:

1) The proposed public fill site is fill bank at Tseung Kwan O Area 137

2) The proposed landfill site is South East New Territories (SENT) Landfill

 

 

Chemical Waste

6.4.8           The maintenance and servicing of construction plant and equipment may possibly generate some chemical wastes, for instance, cleaning fluids, solvents, lubrication oil and fuel. Maintenance of vehicles may also involve the use of a variety of chemicals, oil and lubricants.

6.4.9           Since a large number of the construction activities will be carried out in close proximity to river and stream channels and residential dwellings, chemical wastes arising during the construction phase may pose environmental, health and safety hazards if not stored and disposed of in an appropriate manner as stipulated in the Waste Disposal (Chemical Waste) (General) Regulations. The potential hazards include:

·    toxic effects to workers;

·    adverse impacts on water quality from spills and associated adverse impacts on fresh water biota; and

·    fire hazards.

6.4.10       Materials classified as chemical wastes will require special handling and storage arrangements before removal for appropriate treatment at the Chemical Waste Treatment Facility at Tsing Yi.  Wherever possible opportunities should be taken to reuse and recycle materials.  Mitigation and control requirements for chemical wastes are detailed in Section 6.5.10.  Provided that the handling, storage and disposal of chemical wastes are in accordance with these requirements, adverse environmental impacts are not expected to result. 

 

General Refuse

6.4.11       Throughout the construction stage, the workforce would generate general refuse comprising food scraps, waste paper, empty containers, etc.  Release of general refuse into the river and stream channels should not be permitted as introduction of these wastes is likely to have detrimental effects on water quality in the area.  Effective collection of site wastes would be required to prevent waste materials being blown around by wind, flushed or leached into the aquatic environment, and odour nuisance.  The work sites may also attract pests and vermin if the waste storage area is not well maintained and cleaned regularly.  Disposal of refuse at sites other than approved waste transfer or disposal facilities can also result in similar impacts.

6.4.12       With the implementation of the recommended waste management practices at the site, adverse environmental impacts would not arise from the storage, handling and transportation of refuse.

6.5                 Mitigation Measures

Good Site Practices and Waste Reduction Measures

6.5.1           Appropriate waste handling, transportation and disposal methods for all waste arisings generated during the construction works should be implemented to ensure that construction wastes do not enter the river and stream channels.

6.5.2           It is expected that adverse impacts from waste management would not arise, provided that good site practices are strictly followed.  Recommendations for good site practices during construction include:

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

·           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 the Chemical Waste Treatment 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 (including the disposal sites) should be proposed; and

·           A Waste Management Plan should be prepared and submitted to the Engineer for approval.  One may make reference to ETWB TCW No. 15/2003 for details.

 

6.5.3           In order to monitor the disposal of C&D material at landfills and public filling areas, as appropriate, and to control fly tipping, a trip-ticket system should be included as one of the contractual requirements to be implemented by an Environmental Team undertaking the Environmental Monitoring and Audit work.  One may make reference to ETWB TCW No. 31/2004 for details.

6.5.4           Good management and control can prevent the generation of significant amounts of waste.  Waste reduction is best achieved at the planning and design stage, as well as by ensuring the implementation of good site practices.  Recommendations to achieve waste reduction include: 

·        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;

·        maximising the use of reusable steel 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 minimise amount of waste generated and avoid unnecessary generation of waste.

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

 

Construction and Demolition Material

6.5.6           The C&D material generated from the river improvement works would comprise public fill, being excavated soil and small rocks.  To minimise off-site disposal of public fill, the excavated materials with suitable characteristics/size should be reused on-site as fill material as far as practicable, such as for backfilling of temporary drainage channels or construction of embankments, and small cobbles and rocks should be used in the construction of the recreated channel bed. 

6.5.7           When disposing C&D material at a public filling area, it shall be noted that the material shall only consist of soil, rock, concrete, brick, cement plaster/mortar, inert building debris, aggregates and asphalt.  The material shall be free from marine mud, household refuse, plastic, metals, industrial and chemical waste, animal and vegetable matter, and other material considered to be unsuitable by the Filling Supervisor. 

6.5.8           The C&D material generated from demolition of existing structures should be sorted on-site into inert C&D material (that is, public fill) and C&D waste.  Suitable areas should be designated within the works site boundaries for temporary stockpiling of C&D material.  Within stockpile areas, the following measures should be taken to control potential environmental impacts or nuisance:

·        covering material during heavy rainfall;

·        locating stockpiles to minimise potential visual impacts; and

·        minimising land intake of stockpile areas as far as possible.

 

Excavated Riverbed Material

6.5.9           It is anticipated that the excavated riverbed material may need to be temporarily stockpiled on-site prior to disposal off-site.  Details of environmental control measures to be taken at the stockpiling area to prevent water pollution are discussed in Section 5.  Use of water-tight trucks would be required for the transportation of excavated riverbed material to the designated barging point for disposal at the designated public filling area, or transported directly to the public filling area. 

 

Chemical Wastes

6.5.10       If chemical wastes are produced at the construction site, the Contractor would be required to register with the EPD as a Chemical Waste Producer and to follow the guidelines stated in the Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes. Good quality containers compatible with the chemical wastes should be used, and incompatible chemicals should be stored separately.  Appropriate labels should be securely attached on each chemical waste container indicating the corresponding chemical characteristics of the chemical waste, such as explosives, flammable, oxidizing, irritant, toxic, harmful, corrosive, etc.  The Contractor shall use a licensed collector to transport and dispose of the chemical wastes generated at the Chemical Waste Treatment Centre at Tsing Yi, or other licensed facility, in accordance with the Waste Disposal (Chemical Waste) (General) Regulation.

 

General Refuse

6.5.11       General refuse should be stored in enclosed bins or compaction units separate from C&D material. A reputable waste collector should be employed by the contractor to remove general refuse from the site, separately from C&D material. An enclosed and covered area is preferred to reduce the occurrence of 'wind blown' light material.

 

6.6                 Residual Environmental Impact

6.6.1           With the implementation of the recommended mitigation measures for the handling, transportation and disposal of the identified waste arisings, residual impacts would not be expected during the construction of the proposed drainage improvement works.

 

6.7                 Environmental Monitoring and Audit Requirements

6.7.1           Waste management would be the contractor’s responsibility to ensure that all wastes produced during the construction of the Project are handled, stored and disposed of in accordance with good waste management practices and EPD’s regulations and requirements. The recommended mitigation measures should form the basis of the site Waste Management Plan to be developed and implemented by the Contractor at the construction stage.

 

6.8                 Conclusions

6.8.1           The main waste arising during the construction phase would be the excavated materials from the river improvements works at Sai Kung River, Pak Kong River and Ho Chung Channel. The excavated materials would comprise soil, sand, gravel and small rocks. It was recommended that the excavated materials with suitable characteristics be reused on-site, as far as practicable, such as for fill material for backfilling of temporary drainage channels or construction of embankments.  Surplus excavated soil, sand, gravel and rock material would require disposal to a public filling area. 

6.8.2           Other wastes generated by the construction activities are likely to include general refuse from the workforce, chemical wastes from plant and vehicle maintenance, and C&D material from the demolition of existing structures and site clearance.  Provided that these identified waste arisings are to be handled, transported and disposed of using the recommended methods and good site practices are to be strictly followed, adverse environmental impacts would not be expected during the construction works.  The recommended mitigation measures should form the basis of the Waste Management Plan to be developed by the Contractor.


 



[1]       “C&D material” contains a mixture of inert and non-inert material.  The inert portion is the “public fill” and the non-inert portion is the “C&D waste”.

[2] Dutch Ministry of Public Housing, Land-Use and Environment Guidelines (the Dutch Guidelines) (1994) are used as reference criteria by the EPD for classification of contaminated soil.  In general, remediation is required for soil contamination above the Dutch B level.