Policy Comments & Advocacy

Green Power would like to draw your kind attention to our concerns about the above-captioned Project Profiles (PP).

1. Green Power supports the decommissioning of coal-fired power plants in view of their high emission of greenhouse gas and air pollutants. However, regarding the above-captioned project (the Project), we are concerned about its environmental impacts on the nearest villages at Lung Kwu Tan during the decommissioning and demolition operation, and potential health/life and environmental hazards of any remained chemicals/pollutants in the Project sites and facilities.

2. Most of the areas in vicinity to the Project site are unoccupied countryside places and brownfields. There is also a cluster of villages at Lung Kwu Tan near to the Project site. These places are highly vulnerable to illegal and “legal” dumping and any fly-tipping of wastes generated from this project will be hard to combat. Even if such incidents are spotted, reinstatement can seldom be implemented because of various reasons such as land ownership, landuse zoning and etc.

3. In view of the ineffective enforcement and remedial measures, generation, transportation and disposal of solid wastes, soil/debris and construction and demolition (C&D) materials should be under stricter control. GPS or equivalent system will be implemented to monitor the positions of dump trucks. The dump trucks, especially the loaded ones, should be only allowed to transport the wastes, soil/debris and C&D materials via designated routes and it is recommended to designate vulnerable areas such as countryside places, fish ponds, agricultural lands and coastal areas and villages as “no-go” areas to prevent fly-tipping. An “instantaneous” alarm system to alert persons-in-charge and supervisory staff should be utilised that dump trucks will trigger the alarm system when they encroach these no-go area.

4. The solid wastes generated from the Project, including the 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 ultra-fine materials such as the furnace bottom ash, fly ash, precipitators and flue gas cleaning residues should be carried out in a fully enclosed environment such that leakage of fugitive emissions is not anticipated.

5. If barges/vessels are used for transporting any materials related to the Project, it is appreciated to equip the real-time GPS Tracker on the vessels to combat the waste dumping at sea problem. Such a surveillance system should be capable of detecting and reporting any suspected irregularities in a timely manner.

6. Deterrent and penalty clauses should be incorporated in the work contracts to penalize any unauthorized or environmentally damaging dumping activities.

7. Measures or adequate work plans should be devised for any chemicals which will be encountered or potentially come across during any procedures in the decommissioning and demolition of the Project site. The targeted chemcials should include, but not limited to, transformer PAHs, residual in oil separator system, stored materials in sulphur stores, sodium hypochlorite, dirts and dust generated from electrical and mechanical devices and machineries.

8. Since there are many toxic materials present in the Project site, which have both acute (e.g. sodium hypochlorite) and chronic (e.g. PAHs) health, environmental and ecological hazards, Discharge of surface runoff and stormwater to the sea and streams/water channels should be prohibited. Dykes should be installed around the Project site boundary to avoid discharge of surface runoff and unintended or accidental spillage of chemicals to the environment.

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).