EPD approved Green Island Cement to conduct a specified process (an Incinerator) in Tuen Mun
The Environmental Protection Department (EPD) granted on 25 November 2003 a licence to the Green Island Cement (GIC) Company Limited allowing the company to conduct a specified process (an Incinerator) in Tuen Mun.
Background
| 2. | GIC proposed to build a co-combustion pilot plant at No. 7, Lung Yiu Street , Tap Shek Kok, Tuen Mun, N.T. The pilot plant aims to collect data on co-combustion technology for an academic research project jointly undertaken by GIC and the Hong Kong University of Science and Technology (HKUST). | |
| 3. | GIC applied for a specified process licence on 30 October 2002 and the particulars of the application were published in local newspapers on 27 May 2003. Under the Air Pollution Control Ordinance(APCO), the public had the opportunity to object, within 30 days after the notice was published, to GIC's application on air quality or health grounds. At the close of the 30-day public notification period, 195 objections were received. | |
The Application
| 4. | According to GIC's application, the pilot plant will burn no more than 40 tonnes of municipal waste per day. Municipal waste will be received and processed within 24 hours in an enclosed building under negative pressure in order to control odour. The waste will be fed to the combustion chamber where it will be burnt for about 30 minutes. The ash generated will be sampled and analysed. It will either be stored in totally enclosed systems or solidified before disposal at landfills. The exhaust gas will be directed to the secondary combustion chamber inside which the gas will be kept at or above 1200 oC for at least 4 seconds to ensure complete destruction of all organic compounds. Lime (calcium oxide) in excessive quantity will be used to remove hydrogen chloride and other acidic gases thus controlling the formation of dioxins. The exhaust gas will be further treated to reduce nitrogen oxides and particulates before discharging into the atmosphere through a 114 metres tall chimney to ensure effective dispersion. Thermodynamic data will be collected to evaluate the feasibility of recovering heat energy from the exhaust gas for power generation. The pilot plant will be operated for a cumulative period of 16 weeks at the maximum. | |
Objections
| 5. | Under Section 14(4)(b) of the APCO, any person may object to the granting of a licence to GIC on the following grounds - | |
| (a) | air quality ground: that the project would tend to inhibit the attainment or maintenance of any relevant air quality objective; or | |
| (b) | health ground: that the emission of noxious or offensive emissions would be, or likely to be, prejudicial to health. | |
| 6. | During the 30-day public notification period, a total of 195 objections were received from 189 individuals and 6 organisations. | |
| 7. | Of the 195 objections received, 128 objectors did not provide any ground for objection. It was therefore not possible to consider their objections further in accordance with the provisions of the APCO. | |
| 8. | The grounds for objection of the remaining 67 objectors were related to air quality and health. Their concerns are summarised in Appendix 1. As four of them had provided very comprehensive comments to GIC's air pollution control plan, we decided to convene hearings with them and thereafter with GIC. We met the four objectors on 14 August 2003 to discuss their concerns and seek supplementary information from them to substantiate their demands. We also met GIC on 15 August 2003 to relay to them the objectors' main concerns and clarify certain technical aspects. While the objectors were most concerned about the impacts on air quality and health, they made several suggestions to better monitor the operation of the pilot plant. Having considered the objectors' suggestions, GIC agreed to set up a local environmental monitoring committee, comprising 2 nominations from GIC, 2 from HKUST and 4 from Tuen Mun District Council. GIC found the suggestions on heavy metal and dioxins monitoring not viable because the technologies proposed were either still being developed or had no local technical support. Instead, they would adopt methods comparable with the international practices for heavy metal and dioxin monitoring such as those in the United States and Europe. | |
| 9. | Having carefully reviewed the objectors' concerns and GIC's responses, we consider that the operation of the pilot plant will not have any significant impact on air quality objectives or public health. Our response to the objections raised is summarised in Appendix 2. | |
| 10. | We have also received other comments objecting to GIC's proposed project on grounds other than those specified under the APCO. These comments and our views are summarised respectively in Appendix 3 and Appendix 4. | |
| The decision | ||
| 11. | Having considered all the relevant information, we are satisfied that: | |
| (a) | GIC is capable of providing and maintaining the best practicable means as required by the APCO (including proper monitoring of its emissions) for the prevention of the emission of air pollutants from the pilot plant; | |
| (b) | the emissions from the pilot plant will not have any unacceptable impact on the attainment and maintenance of any relevant air quality objective; and | |
| (c) | the emissions from the pilot plant will not have any unacceptable impact on public health. | |
| 12. | A specified process (an Incinerator) licence was granted to GIC on 25 November 2003. | |
| Environmental Protection Department November 2003 |
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| Appendix 1 - The objectors' concerns | |
| 1. | The pilot plant will cause air pollution and pollute the environment. (click here to see EPD's response) |
| 2. | The release of heavy metals and dioxins from the proposed pilot plant will have adverse impact on health. (click here to see EPD's response) |
| 3. | The release of heavy metals and dioxins from the pilot plant will have adverse impact on the ecology. (click here to see EPD's response) |
| 4. | Emissions from the pilot plant will damage the ozone layer. (click here to see EPD's response) |
| 5. | The pilot plant is too close to Tuen Mun. It should be away from Tuen Mun. (click here to see EPD's response) |
| 6. | Incineration violates the principle of environmental protection and the concept of developing Hong Kong as a green city. The Government should give up the incineration policy and promote recovery of waste. (click here to see EPD's response) |
| 7. | The pilot plant operation will be lengthened from about 16 weeks to years if a licence is granted to GIC. (click here to see EPD's response) |
| 8. | The pilot plant will incinerate more than 40 tonnes of municipal waste if a licence is granted to GIC. (click here to see EPD's response) |
| 9. | The accuracy and credibility of the air quality assessment done by GIC are questionable. (click here to see EPD's response) |
| 10. | There could be health risk other than those caused by air pollution, for example, contamination of food by dioxins. (click here to see EPD's response) |
| 11. | There are concerns about the impact of the pilot plant on the environment as no environmental impact assessment has been conducted. (click here to see EPD's response) |
| 12. | The heavy metals, including beryllium, arsenic, chromium and cobalt emitted from the stack should be individually monitored. The sampling and analytical methods used for monitoring heavy metals should be specified. Continuous emission monitoring of heavy metal emissions from the stack is recommended. (click here to see EPD's response) |
| 13. | The emission of particulates from the stacks should be monitored continuously. (click here to see EPD's response) |
| 14. | Continuous monitoring of dioxins such as the AMESA system developed in Belgium would give the most accurate and reliable measurement of the emission of dioxins from the pilot plant. (click here to see EPD's response) |
| 15. | The exhaust gas may leak from the main stack to the stack for lime cooling. Stack monitoring of the latter should be the same as the former. (click here to see EPD's response) |
| Appendix 2 - EPD's response | |
| 1. Will the pilot plant cause air pollution and pollute the environment? | |
| 1.1 | The by-products produced from the pilot plant are mainly ash and air pollutants. |
| 1.2 | As the ash will either be stored in totally enclosed systems or solidified followed by proper landfill disposal, air pollution is the only major residual environmental concern that needs to be tackled. |
| 1.3 | To evaluate the impact of the pilot plant on air quality, computer model developed by the United States Environmental Protection Agency has been used and EPD's published guidelines on the selection of computer models and model parameters have been followed to predict the air quality under the worst possible scenario. The modelling results show that the emissions from the pilot plant will not have any unacceptable impact on the attainment and maintenance of any relevant air quality objective. |
| 2. Will the release of heavy metals and dioxins from the proposed pilot plant have adverse impact on health? | |
| 2.1 | The pilot plant is required to comply with emission limits for heavy metals and dioxins that are in line with the most stringent international standards. |
| 2.2 | A risk assessment has been conducted to evaluate the health risk associated with the potential carcinogenic air pollutants emitted from the pilot plant including dioxins and heavy metals. The total health risk is found to be 2 x 10-9 per year which is lower than the acceptable risk level under the Technical Memorandum (TM) of the Environmental Impact Assessment Ordinance (EIAO). The risk assessment shows that emissions from the pilot plant should not have any unacceptable impact on public health. |
| 3. Will the release of heavy metals and dioxins from the pilot plant have adverse impact on the ecology? | |
| 3.1 | As mentioned in section 1 above, air pollution is the only major residual environmental concern. Any significant impact on the ecology would only be caused by the air emissions from the pilot plant. The computer air model has demonstrated that the pilot plant will not have any unacceptable impact on the attainment and maintenance of any relevant air quality objective nor any unacceptable impact on public health even under the worst case scenario. It is therefore unlikely that the pilot plant will cause any unacceptable adverse impact on the ecology due to its emissions. |
| 4. Will the emissions from the pilot plant damage the ozone layer? | |
| 4.1 | The air pollutants emitted from the pilot plant do not contain any ozone depleting substances specified under the Montreal Protocol on Substances that Deplete the Ozone Layer. It is unlikely that the emissions from the pilot plant will cause damage to the ozone layer. |
| 5. Is the plant too close to Tuen Mun? | |
| 5.1 | In assessing the impacts of the pilot plant on air quality, the computer model demonstrates that the relevant air quality objectives in Tuen Mun area will not be violated and the calculated total health risk is lower than the acceptable level under the TM of the EIAO. It is therefore concluded that although the pilot plant is located in Tuen Mun, it will not have any unacceptable adverse environmental impacts on the local residents of Tuen Mun. |
| 6. What is the government's waste management policy and its relationship with the pilot plant? | |
| 6.1 | The pilot plant is a research project jointly undertaken by GIC and the HKUST. It does not represent the direction towards which the Government's policies on waste management and sustainable development are proceeding. |
| 6.2 | While the Government has been promoting waste minimization, reuse and recycling, there is still a large amount of waste which cannot be recycled. In mid-2002, we invited international waste management industry to express interest to provide large-scale waste treatment technologies in Hong Kong. An advisory committee comprising mainly non-official members has been established to evaluate the proposals received and advise Government on the type of large-scale waste management facilities most suitable for Hong Kong. The Government will consult the public before making a final decision. |
| 7. Will the pilot plant operation period be extended? | |
| 7.1 | The licence has been granted with the condition that the total cumulative operation period shall not be longer than 16 weeks. It will be an offence if this licence condition is violated. GIC have advised that it will not be economical to operate a pilot plant of research scale for a long period of time and they have no plan to extend the operation period. |
| 8. Will the pilot plant incinerate more than 40 tonnes of municipal waste? | |
| 8.1 | The licence has been granted with the condition that the average daily amount of municipal waste incinerated over any 3 consecutive days shall not be more than 40 tonnes. It will be an offence if this licence condition is violated. |
| 9. What measures are in place to ensure that the air quality assessment done by GIC is accurate and credible? | |
| 9.1 | GIC is required to comply with EPD's guidelines on the selection of computer models and model parameters for air quality assessment. We have checked the assessment submitted by GIC and are satisfied that the assessment results are accurate and credible. Moreover, GIC's air pollution control plan including the air quality assessment had been made available for public inspection during the public notification period. |
| 10. What health impact will be caused by means other than air pollution emitted from the pilot plant? | |
| 10.1 | As mentioned in section 1 above, air pollution is the only major residual environmental concern. As the most stringent emission standards have been imposed upon GIC and the assessment has shown that the relevant air quality objectives will not be violated, it is unlikely that food, which is mainly imported, will be contaminated by the air pollutants emitted from the pilot plant. |
| 11. What are the impacts of the pilot plant on the environment? | |
| 11.1 | Under the EIAO, projects that could have adverse impact on the environment are classified as designated projects and they are required to conduct environmental impact assessments. |
| 11.2 | The pilot plant is not a designated project because of its small processing capacity, which is less than 40 tonnes of municipal waste per day. Moreover, it will only be in operation for a maximum of 16 weeks. Thus, the plant is unlikely to cause any unacceptable environmental impact. |
| 11.3 | As mentioned in section 1 above, air pollution is the only major residual environmental concern that needs to be addressed in GIC's licence application. The air quality assessment shows that the pilot plant will not have any unacceptable impact on the attainment and maintenance of any relevant air quality objective or any impact on public health even under the worst case scenario. |
| 12. How will heavy metals be monitored? | |
| 12.1 | GIC will individually monitor beryllium and all the heavy metals (including arsenic, chromium and cobalt) listed in the best practicable means for incineration. |
| 12.2 | GIC will use USEPA Method IO-3.1, 3.4 and 3.5 for sample collection and to use inductively coupled plasma spectroscopy or inductively coupled plasma mass spectroscopy for sample analysis. At least one sample will be collected per month. |
| 12.3 | GIC's proposal is comparable with the international practices adopted for heavy metal monitoring such as those in the United States and Europe. |
| 12.4 | Regarding continuous emission monitoring of heavy metals, the emerging technologies are still under laboratory research and trial development. It is noted that with the exception of some prototype systems, commercial grade products are still not available in the market. |
| 13. How will particulates be monitored? | |
| 13.1 | GIC will monitor continuously the opacity which is widely regarded as an acceptable surrogate for particulates monitoring. |
| 14. How will dioxins be monitored and should AMESA system be adopted? | |
| 14.1 | It is inappropriate to require GIC to adopt a specific brand or product name in dioxins monitoring. It is considered more appropriate to specify the sampling and testing methods that are accepted internationally. There are proven commercial products available in the market. |
| 14.2 | GIC will use USEPA Method 23 or CARB Method 428 to collect samples and gas chromatography-mass spectroscopy to analyse the samples. At least one sample will be collected per month. |
| 14.3 | GIC's proposal is comparable with the international practices adopted for dioxin monitoring such as those in the United States and Europe. |
| 15. What measures will be adopted to prevent exhaust gas leaking from the main stack to the stack for lime cooling? | |
| 15.1 | The two stacks will be isolated by a tipping valve. The pressure inside the stack for lime cooling is higher than that of the main stack. The differential pressure will draw air from the former to the latter and hence close the tipping valve. As such, leakage of exhaust gas during normal operation is unlikely. |
| 15.2 | The pressure at the two sides of the tipping valve will be continuously monitored. If the pressure inside the stack for lime cooling is lower than that of the main stack, the operator will be required to shut down the plant immediately. |
Appendix 3 - Other comments
1. The pilot plant will have adverse impact on the environmental hygiene of Tuen Mun area. (click here to see EPD's response)
2. The pilot plant will have adverse impact on the employment rate of the grass roots in Hong Kong. (click here to see EPD's response)
3. The pilot plant will have adverse impact on the traffic of Tuen Mun area. (click here to see EPD's response)
4. The public is concerned about the Government's ability to monitor the operation of the pilot plant and stop the experiment when adverse effects become apparent. (click here to see EPD's response)
| Appendix 4 - EPD's response to other comments received | |
| 1. Will the pilot plant have adverse impact on the environmental hygiene of Tuen Mun area? | |
| 1.1 | GIC will use enclosed refuse collection vehicles to transport municipal waste to the pilot plant. All the refuse collection vehicles will be washed externally by disinfectant before leaving the pilot plant. The waste will be processed inside an enclosed compound. In addition, the licence will require GIC to maintain in the pilot plant good housekeeping, with which the plant should not cause any local environmental hygiene problems. |
| 2. Will the pilot plant have adverse impact on the employment rate of the grass roots in Hong Kong? | |
| 2.1 | The pilot plant will only handle 40 tonnes of waste per day and the whole project will last for a cumulative period of 16 weeks at the maximum. It is therefore unlikely that the pilot plant will have any significant impact on the employment market or affecting the employment rate of the grass roots. |
| 3. Will the pilot plant have adverse impact on the traffic of Tuen Mun area? | |
| 3.1 | There will unlikely be any adverse impact on the traffic of Tuen Mun area because no more than 10 round trips of refuse collection vehicle are required per day for transportation of waste to the pilot plant. |
| 4. How will EPD monitor the operation of the pilot plant and stop the experiment when adverse effects become apparent? | |
| 4.1 | Before putting the pilot plant into operation, GIC is required to verify to the satisfaction of EPD its ability to use the best practicable means for controlling emission of air pollutants and to comply with all the terms and conditions of the specified process licence. |
| 4.2 | When the pilot plant is in operation, GIC will be required to continuously monitor the representative process parameters and the exhaust gases to ensure that the emissions of air pollutants are within the specified limits. All the continuous monitoring data will be relayed continuously and instantaneously to EPD's offices allowing EPD to keep the plant operation under close surveillance. |
| 4.3 | GIC has agreed to set up a local environmental monitoring committee with 4 members to be nominated by Tuen Mun District Council and 4 members by GIC and HKUST. The plant operation will be subject to public scrutiny. |
| 4.4 | GIC is also required to submit on a monthly basis to EPD a report of its environmental monitoring results. |
| 4.5 | EPD will take enforcement actions, including stopping the plant operation, against GIC if non-compliance with the licence terms and conditions is confirmed. |
