1                                  Introduction

1.1                            Background

In response to the Hong Kong SAR Government’s initiative to develop bulk waste reduction facilities to tackle Hong Kong’s waste disposal crisis, Green Island Cement Company Limited (the Project Proponent) established a pilot demonstration waste-to-energy facility (consisting of a Materials Recovery/Recycling Facility (MRRF) and a Co-Combustion Plant) (hereafter this facility is referred to as the Co-Combustion Pilot Plant (CCPP)) within the Green Island Cement Plant (GICP) site at Tap Shek Kok, Tuen Mun (see Figure 1.1a). 

The aims of the CCPP were to determine the technical and economic issues associated with the operation of a MRRF as part of an integrated waste management system; to demonstrate that the CCPP will meet the requirements of the Guidance Note on the Best Practical Means for Incinerators (Municipal Waste Incineration) (BPM 12/1 (08)) issued by the Environmental Protection Department (EPD); and to obtain engineering data to refine the design of the Co-Combustion Plant. 

The construction and installation of the CCPP was completed in February 2005 and commissioning tests were carried out in April and July/August 2005 in order to demonstrate its performance.  Continuous operation of the CCPP was started in early October 2005.  During the operation period, the cumulative operating time of the facility was 11 weeks and no more than 24 tonnes per day of Municipal Solid Waste (MSW) were treated.  After achieving the research objectives, the operation of pilot plant was stopped on 17 December 2005. 

1.2                            Objectives

The decommissioning of such municipal waste incinerator is classified as a Designated Project under Item 3 of Part II Schedule 2 of the Environmental Impact Assessment Ordinance (EIAO) and hence the decommissioning of the CCPP (hereafter referred to the Project) is classified as a DP and requires an Environmental Permit (EP) prior to the decommissioning works. 

A Project Profile (PP-315/2007) for the decommissioning of the CCPP was submitted to EPD for application of an EIA Study Brief under the EIAO and Study Brief (ESB-164/2007) was issued on 7 June 2007 which sets out the scope of the work for this EIA Study.

An Environmental Impact Assessment (EIA) Study has been conducted to evaluate the potential environmental impacts due to the Project in accordance with the EIA Study Brief and the guideline on assessment methodology provided in the Technical Memorandum on Environmental Impact Assessment Process (EIAO-TM).   The overall objectives of the EIA Study are to provide information on the nature and extent of potential environmental impacts arising from the Project; to recommend appropriate mitigation measures to control the potential environmental impacts so that it complies with the requirements of the EIAO-TM, and to confirm the environmental acceptability of the Project.  Key environmental issues identified in the EIA Study Brief include air quality, land contamination, water quality and waste management implications.

The general approach for the assessment includes a description of the baseline environmental conditions, identification and evaluation of potential impacts and recommendations for mitigation measures and establishment of the environmental monitoring and audit requirements.  The assessments in this EIA Study are conducted using well-proven and internationally accepted methods based on reasonable worst-case conditions.


2                                  Project Description

2.1                            The CCPP

 

The pilot plant to co-combust MSW with cement production was developed by the Green Island Cement Company Limited (GIC) in collaboration with the Chemical Engineering Department of the Hong Kong University of Science and Technology (HKUST).  The pilot demonstration was funded by the Innovation and Technology Fund under the University-Industry Collaboration Programme.    

Continuous operation of the plant was started in early October 2005 and completed in December 2005.  No more than 24 tonnes of MSW were treated per day during the pilot demonstration of the CCPP.  During the operation of pilot plant, the GIC and HKUST obtained satisfactory results and sufficient design and operational data on the Co-Combustion technology.  All MSW delivered to the site was treated and no MSW is currently stored on-site.  All the Co-Combustion residues (including bottom ash and fly ash) were securely packed in labelled sealed bags and stored in the covered waste reception hall of the MRRF building.

The pilot demonstration has fulfilled its objectives and the CCPP was closed down on 17 December 2005.  It is necessary to demolish the whole pilot plant so that the Project Site could be released for the operation and future development of the GICP.   

2.2                            Demolition Methodology

The CCPP has been decommissioned after the completion of the pilot demonstration.  All structures and the associated foundation, and plant and equipment will be dismantled, cleaned (where necessary) and removed from the Project Site for reuse, recycled or disposal.  The concrete slab of the Project Site will be demolished and the site will be backfilled with a layer of imported clean soil.   The Project Site area will be levelled and landscaped.   Figure 2.2a shows the general layout plan of the CCPP.   Figures 2.2b to 2.2d show the details of the plant and equipment and structure to be demolished.

The selection of preferred demolition/dismantling methods has made reference to the common demolition methods in Hong Kong and the characteristics of the Project such as size of the CCPP, building materials, degree of potential contamination, demolition/dismantling duration, etc to avoid adverse environmental impacts.  

The main system and MRRF building of the CCPP are mainly made of steel while the fire service water tank and pump house are made of concrete.  In a view of small size of the CCPP, the best option for dismantling the steel structures (eg the MRRF Building) and process equipment (eg the Co-Combustion unit) will be by loosing the flanges /cutting and lifting of the segments to the ground level.   Mechanical cutting and thermal cutting are most common and will not cause significant environmental impacts.   The sequence of the demolition works will be from the top to the bottom of the structures.   

For the small concrete structures of the fire service water tank and pump house, the structure will be demolished by jack hammer, pneumatic or hydraulic breaker. 

The overall sequence of demolition works is as follow:

·           Cordon off the site and erection of hoarding;

·           Disconnect the utilities (except for the power and water supplies to the fire services pump room and water tank);

·           Dismantling and removal of all plant and equipment inside the MRRF building;

·           Dismantling and removal of the Co-Combustion unit;

·           Cleaning of the Co-Combustion unit within the enclosed cleaning workshop inside the MRRF building;

·           Demolition of the steel structure of the MRRF building;

·           Demolition of the fires services pump room and water tank;

·           Demolition of the concrete slab and shallow footing foundation;

·           Backfilling the site with clean soil;

·           Provision of surface water drains at the site;

·           Landscaping the Project site area. 

The whole demolition process will be conducted in a safe manner for the protection of the workers and to minimise occupational health and safety hazards.  

The duct works of the Co-Combustion unit and the gas cooler will be dismantled by removal of the bolts or cutting at the joints.  The openings (both ends of ducts) will be immediately sealed with 2 layers of fire retardant polyethylene sheets to prevent escape of any dust within the duct.  The sheets will be secured with duct tapes.  The capped equipment sections/pieces will be lowered to ground level by crane and transported to the cleaning workshop for cleaning. 

The refractory bricks of the rotary kiln will be removed before lifting the whole equipment down to the ground.  The refractory bricks will be placed in sealed bags and disposed of at a designated landfill.  The internal wall will be properly cleaned with wet cloths or other suitable absorbents to remove the loose dust deposits.  The steel frame of the equipment will then be cut into manageable sections and sold to scrap metal recyclers. 

The pumps and control panels of the fire services system will be dismantled and sold.  All water in the water tank will be drained out.  The concrete wall of the water tank and the pump house will be demolished and removed by a pneumatic drill mounted backhoe.  The concrete structures will be damped down before and during the demolition works to control dust.  The steel reinforcement will be recovered as far as practicable for recycling.  The broken concrete will be disposed of at the public fill reception facilities.  The load will be properly covered with tarpaulin to minimise dust during transportation.

The materials recovery/recycling equipment (including shredder, conveyor belts, picking station, magnetic separator, eddy current separator, etc) in the MRRF building will be disassembled using powered mechanical hand tools and removed.  Most of the plant and equipment are still in good serviceable conditions and will be sold to other MRRF operators or second hand equipment vendors.   After the completion of the cleaning works (see Section 2.3) the MRRF building will be demolished progressively from top to bottom.  The external non-loading bearing cladding or any non-structural elements will be removed first.  Crane and lifting gear will be used where possible to support the structural beams and columns whist they are being cut and lowered to the ground.  Air-powered wrenches, cutting torches, cranes and similar industrial equipment will be used.   The steel beams and column will be cut to manageable size to facilitate transportation.  This together with the metal claddings and scrap metals from the MRRF equipment will be sold to the scrap metal recyclers.

2.3                            Cleaning Methodology

After all the machinery and equipment were removed, half of the MRRF building will be converted into a cleaning workshop for cleaning works.   The cleaning workshop will be provided with forced ventilation and a slight negative pressure would be maintained within the cleaning workshop during the cleaning works.  The exhaust air from the cleaning workshop will be cleaned using a High Efficiency Particulate Air (HEPA) filter prior to discharge to the atmosphere. 

It is expected that a small quantity of residues (e.g. fly ash, bottom ash) will remain inside the Co-Combustion unit since the operation of the CCPP was completed.  All residues remaining in the CCPP system will be removed by a vacuum cleaner with a HEPA filter.  Any residues attached within the equipments will be removed by a combined method of scraping and cleaning.  The internal surfaces of the equipments will be cleaned by wet wiping.  To minimise the exposure of residues, the workers will wear appropriate personal protection equipment (including face mask, protective gloves, overcoat, and safety boots).

The scraped lining material will be placed in sealed bags and disposed of at a designated landfill.  The filtered materials, and cloths used for wet wiping will be packed in sealed bags and disposal of at a designated landfill.  With proper precautionary measures and handling procedures in place, contamination of steel structure of the MRRF is not anticipated.

After completion of the cleaning process of the Co-Combustion equipment and removal of the equipment, the cleaning workshop will be vacuum cleaned and wet wiping.  The cleaning materials will be disposed of at designated landfill.

2.4                            Project Planning and Implementation

The tentative programme for the demolition, cleaning and disposal works is shown in Table 2.4a.

Table 2.4a      Tentative Programme for the Demolition, Cleaning and Disposal Works of CCPP

Tasks

Tentative Date

Issue of Environmental Permit by EPD

June 2009

Issue of Buildings Department Permit

July 2009

Demolition Works Tendering

June 2009

Site Preparation for Demolition Works

July 2009

Demolition and Cleaning

August to December 2009

Disposal of Scrap Materials

September to December 2009

Backfilling & Re-surfacing

December 2009

Completion of Demolition and Decommissioning

December 2009

 


3                                  Environmental IMpacts  

3.1                            Introduction

The environmental outcomes associated with the demolition and cleaning of the CCPP have been assessed in the EIA Study.  The key findings and recommendations are summarised below. 

3.2                            Air Quality

The number of construction plant and equipment (1 to 2 mobile cranes, and 1 to 2 backhoe (with pneumatic drill mounted on the backhoe)) used for the demolition works will be limited.  Only a few dump trucks/lorries will be working on site at any one time to remove the demolished concrete and scrap metals.  The air emissions from the operation of these plant and equipment will be minimal and it is therefore not anticipated that it will cause adverse air quality impact to the identified Air Sensitive Receivers (ASRs).

The additional road traffic generated during the decommissioning of the CCPP will be small (i.e. a maximum of 10 truck trips per day associated with the disposal of C&D materials).  The potential air quality impacts due to vehicular emissions are therefore, expected to be minimal.

The Co-Combustion unit will be dismantled by removal of the bolts or cutting at the joints.  The openings (both ends of ducts) will be immediately sealed with two layers of fire retardant polyethylene sheets to prevent escape of any dust from the duct.   The sheets will be secured with duct tapes.  The capped equipment sections/pieces will be lowered to ground level.   The segments of the equipment will be transported to the cleaning workshop within the MRRF building.  No significant dust and air emissions will be generated from this activity.

After removal of the materials recovery equipment from the MRRF building, the MRRF will be used as the cleaning workshop for the Co-Combustion unit.  The cleaning workshop will be provided with forced ventilation and maintained with a slight negative pressure during the cleaning works.  The exhaust air will be cleaned with a HEPA filter prior to discharge to the atmosphere.  The internal wall of the ducts and equipment will be damped with water spray and properly cleaned with wet cloths.   The potential dust/residues release to the atmosphere due to the cleaning process will be minimal. 

The chemical analysis of the Co-Combustion residues contains very low concentration of heavy metals and extremely low concentration (in part per trillion levels) of dioxins and furans.  The proposed demolition method has been carefully designed to minimise potential release of residues during the dismantling and cleaning of the plant and equipment.  With the implementation of control measures recommended in EIA Report, the emissions of the residues will be effectively controlled.  The emissions of dioxins and heavy metals associated with the residues will therefore be minimal and will not cause adverse air quality impact to the identified ASRs.

After the completion of the cleaning of the co-combustion unit, the cleaning workshop will be cleaned.   The MRRF building will be disassembled.  Crane and lifting gear will be used where possible to support the structural beams and columns whist they are being cut and lowered to the ground.  Air-powered wrenches, cutting torches, cranes and similar industrial equipment will be used.  The air emissions from the operation of these plant and equipment will be minimal and no adverse air quality impact is anticipated. 

The concrete structures (fire services water tank and pump house, concrete slab and foundation) will be sprayed with water immediate prior to and regularly during the demolition works to control potential of dust emissions.  The broken concrete and scrap metals will be placed in separate skips and removed off-site as soon as practicable.   With the implementation of the proposed dust and air control measures, it is not anticipated that the demolition of the concrete structures will cause adverse dust impacts to the identified ASRs.

The CCPP Site will be backfilled with imported clean soil and restored into an open area.  Due to the relative small area of the CCPP site and small volume of soil to be handled on site at any one time, it is not anticipated that the minor earthworks will cause adverse dust impact to the identified ASRs with the implementation of the dust control measures described in the Air Pollution Control (Construction Dust) Regulation. 

GIC will implement good site practices and dust control measures stipulated in the Air Pollution Control (Construction Dust) Regulation and the recommended mitigation measures presented in the EIA Report throughout the demolition and cleaning works.  With respect to the nature of the works and the small scale of the concrete structures, the demolition and cleaning works will not cause adverse air quality impact to the identified ASRs.

3.3                            Land Contamination

The assessment of land contamination sources and the potential impacts to sensitive receptors were investigated in accordance with the EPD’s Guidance Manual for Use of Risk-based Remediation Goals (RBRGs) for Contaminated Land Management (the RBRG Guidance Manual), the associated Guidance Note for Contaminated Land Assessment and Remediation, and the EPD’s Guidance Notes for Investigation and Remediation of Contaminated Sites of Petrol Filling Stations, Boatyards, and Car Repair/Dismantling Workshop.  

Site appraisal comprising a site visit, and a review of background information and land history in relation to possible land contamination was conducted.  Potential sources of contamination and associated impacts, risks or hazards are identified in the Contamination Assessment Plan.  Land contamination assessment was carried out and results presented in the Contamination Assessment Report.  The results of the site investigation works determined that:

·       Total petroleum hydrocarbon (TPH)/ benzene, toluene, ethyl benzene, and xylene (BTEX) were below the reported detection limits in any of the soil samples collected;

·       Concentrations of priority pollutant metals detected were well below the RBRG standards; and

·       Levels of PCBs, dioxins and furans analysed in all samples were well below the RBRG values.

Excavation works proposed for the demolition works will be limited to the concrete sub-structures and underground storage tank.  No soil excavation or groundwater extraction will be required for the Project and hence no off-site disposal of soil and groundwater will be required.

The substructure areas of the Project Site will be filled using clean imported fill materials and rehabilitated as green lawn and open area.  The potential for human contact with any underlying contamination in the future is considered low.   As the result of the above, no potential impact from the contaminated soil is anticipated.

The Project Site’s future use remains industrial (manufacture of cement and cement related products) and is surrounded by remaining areas of the GICP.  It is considered that the only potential receptors at risk might be site workers involved in decommissioning and demolition works.  As the contaminants analysed were either not detected or with concentrations well below the RBRG guideline values, the potential risk to the workers due to demolition activities will be minimal. 

3.4                            Waste Management Implications

The decommissioning of the CCPP will generate a variety of wastes (including public fill (about 1,806 m3), scrap metals (about 369 tonnes), Co-Combustion residues (about 200 tonnes), refractory bricks and lining (about 345 tonnes), general refuse (about 9.1 kg d-1) and sewage (about 2.1 m3 d-1)) and recyclables (MRRF Equipment , unused reagents, etc).  The waste management implications and environmental impacts associated with the handling, storage and disposal of these wastes have been assessed.

The public fill will be disposed of at the Tuen Mun Area 38 Fill Bank.

The physical properties and chemical analysis results show that the characteristics of the Co-Combustion residues are similar to those of the typical clinker raw materials.   The residues contain very low levels of heavy metals and extremely low levels of (in the order of part per trillion) dioxins and furans, which will not have adverse impacts on the gaseous emissions and the cement plant.   The residues will be used as an alternative feedstock for the cement clinker production.     

With the proposed loading rate of 0.5% w/w of the Co-Combustion residue to other raw materials for cement clinker production, it will not adversely affect the environmental performance of the cement plant.  It will take about 7 days for the cement plant to consume all the residues.  There is no concern of long-term environmental impacts associated with the proposed residue reuse option.  This will avoid the disposal of residues at landfill. 

As a last resort, the residues will be disposed of at a landfill designated by the EPD.  The Toxicity Characteristic Leaching Procedure (TCLP) tests indicate that the concentrations of heavy metals in the leachate arising from the residues are well below the respective limits for landfill disposal.  The residues can therefore be disposed of at the designated landfill without further treatment.   An advance agreement should be obtained from the Landfill Authority (EPD) for the disposal of the residues at landfill.

The refractory bricks and lining of the Co-Combustion unit and waste generated from cleaning of the Co-Combustion unit will be placed in sealed polyethylene bags and disposed of at a landfill designated by the EPD.

The MRRF equipment is still in good serviceable condition and will be sold to other MRRF operators or second hand equipment vendors.  Scrap metals and unused reagents will be recycled.

Due the small scale of the CCPP, the quantities of public fill, chemical waste, general refuse, sewage to be generated will be small.  With the implementation of the recommended mitigation measures in this EIA Report, the handling and disposal of these wastes will not cause adverse environmental and traffic impacts.

3.5                            Water Quality

Clean surface runoff from the Project Site will be diverted to the existing drainage system of the GICP which will lead to the on-site stormwater detention pond.  Suspended solids will be settled out in the pond before discharging into the stormwater drainage.  No unacceptable impact to water sensitive receivers is anticipated.

The cleaning works will be carried out inside the cleaning workshop of the MRRF building.  During the cleaning process, wet wiping and vacuum cleaning will be used to clean the internal lining of the ducting/equipment and remove the loose dust particles deposited on the surface of the ducts and equipment.  Water flushing will not be used to clean the plant and equipment of the Co-Combustion unit and hence the wastewater generated from the cleaning works will be minimal.  All wastewater will be treated in the existing on-site wastewater treatment plant (WWTP) of the GICP. 

A small quantity of sewage (about 2.1 m3 per day) will arise from the demolition workforce.  The existing toilet facility of the GICP will be available to the construction workforce.  The sewage will be discharged to the on-site WWTP.  No adverse impact water quality is anticipated due to the treatment and disposal of sewage generated from the workforce.

With the implementation of general good site practices, the demolition of CCPP will not cause adverse water quality impact.

3.6                            Environmental Monitoring and Audit

No environmental monitoring for air quality and water quality will be required.

Monthly site audits will be undertaken jointly by the site representative of GIC and the contractor during the Project to ensure that dust control, construction waste and site runoff and are managed in accordance with the good site practices recommended in EIA Report.

An Implementation Schedule, containing the recommended mitigation measures, monitoring and audit requirements, and the implementation agent are presented in Annex C of the EIA Report.


4                                  Overall Conclusions

In accordance with the EIA Study Brief and the guidance in the EIAO-TM, the EIA Study has identified and assessed potential environmental impacts (including air quality, land contamination, waste management and water quality) associated with the Project. 

The study concludes that with the implementation of the recommended environmental control measures during the Project, no unacceptable environmental impacts are envisaged.   

Regular site audits are recommended to ensure proper implementation of the recommended mitigation measures.