The HSBC Cairo Regional Processing Center is a new 18,000 square meter building located in Giza, Egypt, approximately 40 kilometers northwest of Cairo. Unlike Cairo, which is located in the fertile Nile Valley, Giza is sited in the desert climate that typifies most of Egypt. The site is previously undeveloped, and the geology of the site is several meters of sand sitting about 20 m above bedrock. The average annual rainfall in Cairo is 24 mm (0.95"), 75% of which occurs between December and March. Stormwater management is not considered an environmental issue in this climate, since the sandy soils allow for total absorption of all normal storm events. Thus, erosion control for stormwater is not a common practice in this climate.
The dry climate, however, does make the site prone to wind-borne erosion and air pollution generation from dust. Constructing the building will require excavating approximately 80,000 cubic meters (104,000 cubic yards) of earth, of which approximately 20,000 cubic meters (26,000 cubic yards) will be stockpiled for backfill.
The prerequisite requirements make mention of dust pollution control, but the referenced EPA Construction General Permit do not address dust control specifically. Egypt does not have an environmental law analogous to EPA Construction General Permit. The relevant Egyptian environmental regulations are delineated in Section II Article 41 of "Law #4 of 1994: Promulgating the Environmental Law" (see below). Thus, the local environmental law is the more stringent than the absent dust regulation from the EPA Permit, but it still relatively vague. To ensure compliance with this prerequisite above and beyond the requirements of the Environmental Law, the Cairo-based project architect ARCHIMID has included strict language in the project documents to ensure minimal erosion and wind-borne dust generation (see below).
Please confirm that the design team's approach of not implementing stormwater measures but instead going to great lengths to minimize airborne dust pollution will meet the intent and requirements of the prerequisite, given the vastly different climate and challenges with which this project is grappling. We look forward to your response.
Excerpt from HSBC CRPC Tender Documents (Design Development Documents) Project Manual - Section 01495 Health, Safety & Environment, Section 6.3 Air Pollution Prevention:
The PM [Project Manager] will monitor the cumulative effect of simultaneous construction activities on air quality. In addition, the Contractor will take the following steps to protect air quality:
a. Development of aggressive measures to reduce dust and air pollution during construction.
b. Water sprays to treat excavated materials at major points of transfer (i.e. unloading onto conveyor belts or trucks). Water sprays shall be used on exposed soils and excavation to reduce dust.
c. Dump trucks hauling loose material such as, but not limited to, sands, gravels, muck, excavation spoils and soils shall be covered with tarpaulins or other load covering that can be securely fastened and shall be equipped with tight fitting tailgates that can be securely fastened in the closed position and will not permit wet or dry materials being hauled to leak or trickle out.
d. The Contractor shall implement appropriate measures to prevent deposition of material on public ways. Street sweeping service shall be provided as necessary to ensure that any material that is tracked onto public ways is immediately removed.
e. Construction Sites will be fenced to reduce wind-borne dust.
Excerpt from (Egypt) Law #4 of 1994: Promulgating the Environmental Law - Section II Article 41
All organizations and individuals shall be held, when carrying out exploration, excavation, construction or demolition works, or when transporting the resultant waste or debris, to take necessary precautions to secure the safe storage or transportation thereof. The authority granting the building or demolition license shall indicate these requirements in the license in the manner set forth below:
That on-site storage of waste or debris be affected with due regard to the requirements of safety and the unobstructed movement of traffic and people. Waste liable to dispersal shall be covered to avoid air pollution.
That waste or debris resulting from excavation, demolition and construction works be transported in special containers or receptacles on trucks equipped and licensed for this purpose and meeting the following conditions:
Fitted with a special box or an air-tight cover to prevent loose particles of waste and debris from escaping into the air or dropping on the road.
Provided with special loading and unloading equipment.
In good condition according to the rules of safety, solidity and lights and fitted with all safety equipment.
The applicant is requesting confirmation of compliance with SSp1 requirements, although the project did not implement measures to protect against stormwater erosion, only measures to protect against wind erosion. The applicant's project is located in Giza, Egypt, a desert area with an average annual rainfall of approximately 0.95" and therefore an area with minimal stormwater erosion concerns, yet one that is prone to soil erosion due to wind.
The referenced standard, Stormwater Management for Construction Activities (USEPA Document No. 832R92005), is a performance based standard that states, "your selection of the best soil erosion and sediment controls for your site should be primarily based upon the nature of the construction activity and the conditions which exist at the construction site." It is apparent from the description above that erosion due to stormwater is not a concern that needs to be addressed in the Erosion and Sedimentation Control Plan. Applicable Internationally; Egypt.
Related Addenda (Corrections & Interpretations)