Dr. CHUI Ho Kwong, Samuel, JP
Director of Environmental Protection
EIA Ordinance Register Office
Environmental Protection Department
(E-mail: eiaocomment@epd.gov.hk)
Green Power would like to draw your kind attention to our comments about the above-captioned EIA report.
1. The proposed “advanced air pollution control system” for the I∙PARK2 chimney (Section 3.6.2.1) should be technically feasible to control the air emission levels and odour impacts for the incinerator. Since diverse advanced techniques are included in the system, automated irregularity detection and reporting mechanisms should be provided to alarm operational problems. When irregularity is detected at any part of the system, the incinerator should be shut down immediately until the problems are fully fixed.
2. Measurement of the dioxin and furans, heavy metals, and total organic carbon at the operational phase (EM&A, Section 2.3.1) should be more frequently conducted to keep a close monitoring of the quality of the emission.
3. In order to “minimise the impact on air quality”, it is assumed that marine vessels associated with I·PARK2 will “switch to electric power while berthing” (Section 3.8.1.1.3). In this view, only hybrid-powered (fuel and electric) marine vessels should be allowed to perform the daily refuse delivery jobs during the operational phase.
4. The solid wastes generated from the proposed Project, including the construction and demolition (C&D) materials, chemical wastes, incinerator bottom ash, fly ash, etc., should be properly stored, transported, and finally disposed of at the designated facilities in accordance with the regulations. In particular, transportation of the incinerator bottom ash, fly ash and flue gas cleaning residues should be carried out in a fully enclosed environment such that leakage of fugitive emissions is not anticipated.
5. It is appreciated to equip the real-time GPS Tracker on MSW containing vessels to combat the waste dumping at sea problem (Section 6.6.2). Such a surveillance system should be capable of detecting and reporting any suspected irregularities in a timely manner. Besides, deterrent clauses should be incorporated in the work contracts to penalize any dumping at sea activities.
6. The Project site is located within the Deep Bay Water Control Zone. Therefore, the Zero Discharge Policy should be strictly observed for discharge of wastewater during both the construction and operational phase.
7. Effluent outfall is needed for discharge of brine water from desalination plant and seawater cooling effluent from seawater cooling system (if adopted) into the sea. Although seawall effluent outfall will be adopted and located at the artificial seawall with low ecological and fisheries value, and marine species of conservation importance and recognized sites of conservation importance are not located at and near the Project area, monitoring of physiochemical parameters of water quality at sensitive sites should be included in EM&A, including but not limited to, seagrass beds, oyster farms, horseshoe crab habitats. Action plans should be devised and included in EM&A under the Environmental Permit if parameters, especially water temperature and salinity, exceed levels that will impose potential or proven negative impacts on vulnerable species or habitats.
8. According to the results of the thermal impact assessment (Section 5.7.2.1.3), a temperature elevation of 0.2oC to 0.8oC is anticipated at Ha Pak Nai and Sheung Pak Nai in the wet season due to the air-cooled system. Research has revealed that an elevation of about 0.4oC in seawater temperature could induce adverse impacts on seagrass species, therefore the thermal impacts on seagrass should not be neglected especially under the current scenario of global climate change.
9. The waters around the Black Point next to the Project site have been identified as the “hot spot” of Chinese White Dolphin (CWD). Even though the abundance of CWD dropped in recent years, significant bounce back of CWD usage from zero appearance have been observed in the past. Therefore, the potential ecological impacts on CWD induced by the increased marine traffic should be assessed and addressed.
10. In order to demonstrate the superiority of waste-to-energy technology to landfilling in combating climate change, the CO2-equivalence of unit weight (both with typical water content and without water content) should be calculated for common ingredients of combustible municipal solid waste.
Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).
Green Power would like to draw your kind attention to our comments about the above-captioned EIA report.
1. The proposed “advanced air pollution control system” for the I∙PARK2 chimney (Section 3.6.2.1) should be technically feasible to control the air emission levels and odour impacts for the incinerator. Since diverse advanced techniques are included in the system, automated irregularity detection and reporting mechanisms should be provided to alarm operational problems. When irregularity is detected at any part of the system, the incinerator should be shut down immediately until the problems are fully fixed.
2. Measurement of the dioxin and furans, heavy metals, and total organic carbon at the operational phase (EM&A, Section 2.3.1) should be more frequently conducted to keep a close monitoring of the quality of the emission.
3. In order to “minimise the impact on air quality”, it is assumed that marine vessels associated with I·PARK2 will “switch to electric power while berthing” (Section 3.8.1.1.3). In this view, only hybrid-powered (fuel and electric) marine vessels should be allowed to perform the daily refuse delivery jobs during the operational phase.
4. The solid wastes generated from the proposed Project, including the construction and demolition (C&D) materials, chemical wastes, incinerator bottom ash, fly ash, etc., should be properly stored, transported, and finally disposed of at the designated facilities in accordance with the regulations. In particular, transportation of the incinerator bottom ash, fly ash and flue gas cleaning residues should be carried out in a fully enclosed environment such that leakage of fugitive emissions is not anticipated.
5. It is appreciated to equip the real-time GPS Tracker on MSW containing vessels to combat the waste dumping at sea problem (Section 6.6.2). Such a surveillance system should be capable of detecting and reporting any suspected irregularities in a timely manner. Besides, deterrent clauses should be incorporated in the work contracts to penalize any dumping at sea activities.
6. The Project site is located within the Deep Bay Water Control Zone. Therefore, the Zero Discharge Policy should be strictly observed for discharge of wastewater during both the construction and operational phase.
7. Effluent outfall is needed for discharge of brine water from desalination plant and seawater cooling effluent from seawater cooling system (if adopted) into the sea. Although seawall effluent outfall will be adopted and located at the artificial seawall with low ecological and fisheries value, and marine species of conservation importance and recognized sites of conservation importance are not located at and near the Project area, monitoring of physiochemical parameters of water quality at sensitive sites should be included in EM&A, including but not limited to, seagrass beds, oyster farms, horseshoe crab habitats. Action plans should be devised and included in EM&A under the Environmental Permit if parameters, especially water temperature and salinity, exceed levels that will impose potential or proven negative impacts on vulnerable species or habitats.
8. According to the results of the thermal impact assessment (Section 5.7.2.1.3), a temperature elevation of 0.2oC to 0.8oC is anticipated at Ha Pak Nai and Sheung Pak Nai in the wet season due to the air-cooled system. Research has revealed that an elevation of about 0.4oC in seawater temperature could induce adverse impacts on seagrass species, therefore the thermal impacts on seagrass should not be neglected especially under the current scenario of global climate change.
9. The waters around the Black Point next to the Project site have been identified as the “hot spot” of Chinese White Dolphin (CWD). Even though the abundance of CWD dropped in recent years, significant bounce back of CWD usage from zero appearance have been observed in the past. Therefore, the potential ecological impacts on CWD induced by the increased marine traffic should be assessed and addressed.
10. In order to demonstrate the superiority of waste-to-energy technology to landfilling in combating climate change, the CO2-equivalence of unit weight (both with typical water content and without water content) should be calculated for common ingredients of combustible municipal solid waste.
Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).
Yours faithfully,
LO Wing-fung
Environmental Affairs Manager
Green Power
Yours faithfully,
LO Wing-fung
Environmental Affairs Manager
Green Power
References
Agriculture, Fisheries and Conservation Department (2023). Monitoring of Marine Mammals in Hong Kong Waters (2022-23) —Final report. Available from: https://www.afcd.gov.hk/tc_chi/conservation/con_mar/con_mar_chi/con_mar_chi_chi/files/Final_Report_2022to23.pdf
A. Agius, L. S. Wright, and J. A. Borg (2023). Impacts of thermal effluent on Posidonia oceanica and associated macrofauna. Marine Ecology Progress Series 707: 15-29. https://doi.org/10.3354/meps14261