China - Tai Basin Urban Environment Project : environmental assessment (Vol. 2 of 5) : Supplementary information on the environmental impact assessment

E808 Volume 2 Supplementary Information to Environmental Impact Assessment Lake Tai Urban Environment Project (February 2004) This is prepared as a supplementary to both the Environmental Impact Assessment (EIA) and Environmental Management Plan (EMP). As such, it serves as an integral part of the project EA documents and will be attached to the original EA as an addendum. This supplementary information has been prepared in response to World Bank comments dated February 1, 2004 on the project EIA and EMP and the following information has been presented in the same section numbers as those in the original comments. 1. Analysis of Alternatives 1.1 Alternative Option of Industrial Pollution Prevention/Control. We understand that the options of industrial pollution prevention and control versus centralized municipal wastewater treatment plants have been explained by the World Bank Project Task Team. The EA team wants to provide the following additional response. One of key principles in the environmental laws and regulations of China is "polluters pay" and as such industries will need to control their discharges and emissions at their own costs rather than using public funds from the government. The role of the government is to enact and enforce regulations and control and discharge standards. The NDRC and MOC have set up the standards requesting all industries to recycle 60% of their effluent and the SEPA has a series of very specific discharge standards for various industries. At the provincial level, Jiangsu Province has its own Clean Production plan, which outlines clean production and discharge reduction targets for the industries in the province. Governments of all levels intend to fully enforce the regulations, standards and targets and are expected to keep and improve their enforcement efforts. Under the regulatory requirements, industries have to meet discharge standards, either to the sewers or to the environment directly by investing in industrial wastewater treatment and control facilities. By the regulations, the industries are allowed to discharge conventional and non-hazardous waste such as COD to the municipal sewers leading to centralized municipal wastewater treatment plants, to allow better efficiency and economy of scale. 1.2 Alternative Options for WWTP Sites The project involves six WWTPs, of which Loujiang, Fuxin and Dongting WWTPs are the second phase of existing WWTPs already in operation or to be in operation soon in their respective same locations. In all three WWTPs, space for the second phase expansions have been reserved and acquired and therefore there is no option on alternative sites. The assessment for alternative WWTP sites for Huishan and Anzhen WWTPs have been presented in the original EA report. Two alternative sites have been proposed for Wuzhong WWTP during the project FIllE COPY  preparation: one is located in the industrial zone (Alternative II) and the other is located by the South Ring Road near Dalonggang River (Alternative I). The exact locations of these sites are shown in the maD below and the comDarison of I | . ''___\ I-. i_, I _ ' kr. ,1 ' \ ____ ____ lI_ _ t, ---__ \ -. | I X,, ~~~~~~~~~~~* I.*X*- '--tr- 1 ! # 1l~~~~~~ IE II C s, ,A Legend r____ _ . R . ^ l tc ~ f ruzhong WIP E g | _ __ _ 11_* Puep Stetion F,L f River L * _ _ _ _ - \ _ _ District Boundary Proposed Tai Basin Urban Environment Project (TBUEP) M WH ,.4' Rl 3-12 q IF0j1 - _ Table 1.2-1 Comparison of Wuzhong WWTP Sites Alternative I Alternative II * Effluent discharges into sewers and more directly to the Grand Canal, thereby helping * Effluent will be discharged through open to improve the community environment. ditches and affecting the community Grand Canal has greater assimilative * Located in urban and residential areas capacity than the receiving water body under * Close to sensitive water body and potential alternative I impacts to surface water * Located in industrial zone with little impacts * Location not easy for sewer network and to residents pumping station siting * Far away from sensitive water body * On 100 flood plain * Easy for sewer network and pumping stations layout * On 100 flood plain Based on the above analysis and comparison, alternative II site is preferred because of its less impacts expected to the surrounding communities and the environment. In particular, Alternative I site is located near the Dalonggang River, which discharges to Lake Tai directly, which is therefore designated as a control section of water body (sensitive water body). If the WWTP is located at this site, Dalonggang river would be  the receiving water body for the final effluent which and through which Lake Tai would be impacted adversely. With regard to flood control, both alternative sites are equal - meeting the at least 100 year flood plain requirement. With all factors considered, Alternative II site is therefore selected as the Wuzhong WWTP site in the project. 1.3 Alternative Options for WWTP Sludge Management Options In the original report, six possible options for sludge management and disposal have been identified and compared by listing the advantages and disadvantages of each of the options (Table 4.4-5). These six options are incineration, wet oxidation, anaerobic digestion, natural drying, composting and landfill. The EA team made its comparison and analysis of these options based on the general knowledge of these options as well as the local conditions. Incineration will have emissions causing secondary contamination. Wet oxidation and digestion are sludge processing technologies, used primarily as a method for sludge stabilization and as such they are not options for sludge disposal. Both natural drying and composting will require very large land spaces, which are scarce in the densely populated project cities. Such large scale operation in open space and areas with long time raining and hot seasons each year in the project cities would bring massive environmental problems to the sites and the surrounding areas. Compost would also have market problems for its products, which may be very limited in the south Jiangsu area. Furthermore, all of the above options are not final and would require further disposal options for all sludge or processing residues. The EA therefore concludes that landfill is the best option for sludge disposal given the local conditions, provided that the landfill operation will comply with applicable pollution control standards and meet impact mitigation requirements. 1.4 Alternative Options for Sediment Disposal According to applicable regulations and standards of China, sediment with heavy metal contents not exceeding agricultural application standards in the "Pollutant Discharge Standards of Urban Wastewater Treatment Plants" (GB18918-2002) may be used in agricultural, wood and landscaping lands. It may also be allowed to be disposed in waste land and abundant or acquired fish ponds. But, any sediment or sludge applied in agricultural lands must also meet the "Pollutant Control Standards in Agricultural Application of Sludge" (GB4284-84) including relevant requirements stipulated in the standards. One key requirement is that sludge must be pre-treated through high temperature composting or digestion before applied in agricultural land. If heavy metals exceed these standards but the leaching test results do not exceed "Hazardous Waste Identification Standards - Leaching Toxicity Identification" (GB50805.3-1996), the sediment may be disposed of in a landfill. To prevent groundwater and surrounding environment contamination, the landfill needs to be designed according to sanitary landfill standards by providing low permeable bottom layers, storm water control, leachate collection and treatment, daily cover, as well as other control measures. Application rates should not exceed 2000 kg per mu per year in general".  Except one section, the sediment sampling and testing show that heavy metal contents in the sediments do not exceed GB18918-2002 standards and as such the sediments can be disposed of through agricultural land or piling in waste/abandant land. While it is possible that the sediment may be applied in agrilcutural for disposal, the very limited and diminishing agricultural land in the areas near urban Suzhou are unable to accept the large amount of sediments to be produced during dredging operation. Furthermore, the sediments contain many inert materials from dumping of solid waste from the urban areas over the years, such as plastics, glass, scrape metals, woods, etc. Sediments with these materials are clearly not suitable for agricultural land application. At the same time, the sediments do not need special control disposal such as landfilling based on the test results of sediment samples collected in the proposed dredging areas. The proposed Sanjiaozhui site is zoned as green area in Suzhou's master plan. The current land utilization is fish ponds, water ponds and other forms of land drepression, suitable for sediment piling and disposal. Once the piling operation is completed, the site will be landscaped by planting trees, lawns and other vegetation. This is a safe disposal option and compliance with the city planning. The World Bank comments raised the concern about the testing results presented in Table 5.6-4 of the original report. This is due to a translation error in the English EA document. The areas left blank in this table for lead, nickel, and cyanide are actually concentrations below the detection limits. The original Chinese EA has clearly so indicated but errors occur in the English EA. This note serves as a record to correct the error and all blank spaces in Table 5.6-4 of the EA document should read "Below detection limits". The leaching test results of the sediments as shown in Table 5.6-4, with the correction mentioned above, indicate that none exceed the standards and sediments are not hazardous. The original approach of leaving Xiaomiduqiao river undredged was based on the considerations that the heavy metal contents in the sediments may be so high that the sediments were hazardous and Suzhou currently does not have the ability to handle large quantities of hazardous materials. However, when results from all tests including leachign test of a sediment sample from Xiaomiduqiao river are carefully re-evaluated, it becomes clear that although the conventional tests show that some heavy metals from sediments in this area exceeded the agricultural application standards, the leaching test of the sediment sample shows the sediment is not hazardous indicated by the lower than standard concentrations for hazardous materials. In other words, the sediment from this area has been contaminated by heavy metals to the extent that it is not suitable for agricultural land application as a disposal method and thus not be suitable to dispose the sediment from this area in the Sanjiaozui site. Given the sediment contamination status, the available options may be: i) leave the sediment undredged since the section is located in a dead end section of the river; ii) dredge the sediment and dispose it in Qizishan municipal solid waste landfill site which is designed as a sanitary landfill with storm water control, infiltration control, leachate colletion and treatment and other environmental control in its design; the sediment may be disposed in the same zone in the landfill which is dedicated to dispose WWTP sludge (more discussion on this below); and iii) dredge the sediment  and dispose it using another method such as a special controlled zone in the Sanjiaozui site. Each of these methods have advantages and drawbacks as well as unknows. To make an infornned decision with an objective to have the least impacts to the environment, it has been decided a further study about the sediments at the site and disposal method will be engaged at the early stage of the project prior to commencing dredging (the dredging is to implement in fall of 2004 to 2005). The expert panel convened by SEPA for the EIA review on February 8 2004 also requested "further study is needed to demonstrate the environmental feasibility and reasonning of the non dredging approach". This further study will include additional sediment sampling and testing for contaminanted sediment delineation, landfilling approach evaluation, special zone in the Sanjiaozui site evaluation, environmetal impact of different options, etc. As indicated at the beginning of this note, the information presented herein is supplementary to both the original EIA and EMP reports. As such, the specific actions and mitigation measures including the further study for the Xiaomiduqiao sediment dredging approach described above and other parts of the note are deemed supplementary to the EMP. . 1.5 Alternative Options for Stormwater Collection Systems Except the old central city areas of Suzhou, all six WWTP serviced areas in this project have or will have separate stormwater and sewerage collection systems. The uncomtaminated stormwater will be collected in the separated system and discharged to surface water bodies directly, while sewerage will be collected by a different sewer system and diverted to WWTPs for treatment before discharging. 1.6 Cleaner Production and Industrial Polluction Control Action Plan in Jiangsu Cleaner Production (CP) Program in Wuxi and Suzhou is presently focused on about 600 major polluters in the Tai Basin within Jiangsu Province. The program, under Jiangsu EPB, reportedly is achieving good results in a number of larger and more profitable industrial enterprises that have been willing to invest in process improvements, although the small and medium sized industrial operations may be more difficult to tackle. In Jiangsu's Tai Lake Water Pollution Control Tenth Five-Year Plan, one section deals specifically with CP. The plan calls for CP audit of major polluters in the Basin. More specifically, the between 2001 and 2005, the number of industrial operations have been/to be audited in Wuxi and Suzhou are 11, 75, 140, 210, and 566, respectively. This audit program has been on schedule so far and is well on its way to achieve its audit target for the remaining two years in the Five-Year plan. Since 1996, 659 industrial enterprises in Jiangsu province have been audited resulting in industrial pollution reduction of 20% from the 1996 level. In the Circular About the Last Three Years Cleaner Production Implementation Plan in Jiangsu, issued by the provincial government on September 8, 2003, the government further emphasizes the control of the industrial pollution from its sources and sets the target to establish Suzhou, Wuxi, Changzhou and Zhengjiang as the CP model cities in the province. The Circular also calls for the completion of audits for all major industrial polluters in the following sectors in the province by 2004: dyeing, metallurgical, chemicals, power, construction materials, light industries. The special focus of the audit will be paid to industrial operations, which cannot be stably and consistently meet the discharge standards. The Circular reiterates again that industrial pollution control by the industries themselves is regulatory requirements and is thus mandatory. The Circular demands governments, particularly EPBs at different levels to maintain and enhance their efforts for regulatory enforcement.  2. Appropriateness of the Sanjiaozui site for sediment disposal from the Suzhou river network Sanjiaozui site selected for sediment disposal from the Suzhou river network dredging programs has been evaluated and considered appropriate because of the following considerations: . Fully compliant with the Suzhou master plan for land utilization. The Sanjiaozui site areas are zoned by the master plan to be the green areas in the future. Once the piling operation is completed, the site will be landscaped and integrated with the surrounding green areas as zoned by the master plan . The site is currently fish pond, water pond and depressed lands and converting it to green areas in the future as zoned by the city's master plan would require a large amount soil materials for land filling. The utilization of sediment would save a large amount of soil which would otherwised borrowed from the areas causing other environmental issues such as erosion, disturbance of the vegetation, transportation, etc. . The sediments from the dredged areas meet the agricultural standards and thus can be disposed of as filling materials . Sanjiaozui site is located in the suburb Suzhou, with a very few residents in the nearby areas except some scattered located rural residential housing. There is no nature reserve or landscaping or other sensitive receptors. . The site geological conditions are suitable from the loads from the sediment filling. . The site bottom has about 3.6 m of clay or silty clay with the infiltration rate of 10-7 to 10-8 cm/s. . Lake Tai basin in its natural setting is all on about 100 year flood plains. With the urbanization and develoment, flood control standards in urban centers, industrial zones, concentrated residential areas, etc. in the basin have gradually lifted to 200 year flood plains through flood control and other hydraulic facilities. The Sanjiaozui site area does not have any specificial flood control facilities and remains on the 100 year flood plain which is sufficient for this type of operation. Based on the above considerations, the EA concludes the site is appropriate for sediments disposal. 3. Appropriateness of the Qizishan and Taohuashan domestic landfill sites for WWTP sludge disposal The testing results of sludge from existing operating WWTPs (Table 4.4-1 of the EAI report) show that the sludge from the project areas is not hazardous, nor it is explosive, flammable, corrosive or radioactive. Although further tests including leaching tests have been planned and included in the EMP for sludge to be generated by the project WWTPs at the inception of their operations to confirm these nature, the sludge may be classified as Category I industrial waste which by definition in the Chinese regulations is non-hazardous. Its disospal is generally at a landfill following the standards stipulated in GB 18599-2001. The municipal solid waste landfills are proposed as the disposal sites for the sludge based on the following considerations: