E2483

Environmental Assessment Summary Report

for

Jiangsu Wuxi Tai Lake Environment Project

China Research Academy of Environmental SciencesMay 2010

Table of Content

1. GENERAL INTRODUCTION..................................................................................3

1.1 PROJECT BACKGROUND......................................................................................................................31.2 EA BASIS...............................................................................................................................................31.3 APPLICABLE STANDARDS...................................................................................................................41.4 METHODOLOGY OF EA.......................................................................................................................41.5 ASSESSMENT COVERAGE....................................................................................................................51.6 GENERAL FRAMEWORK OF ENVIRONMENTAL IMPACT ASSESSMENT REPORT......................5

2. PROJECT DESCRIPTION........................................................................................5

3. ENVIRONMENT BASELINE..................................................................................7

3.1 NATURAL ENVIRONMENT....................................................................................................................73.2 SOCIO-ECONOMIC CONDITION................................................................................................................83.3 CURRRENT ENVIRONMENT QUALITY...............................................................................................8

4. PREDICTION AND ASSESSMENT OF ENVIRONMENTAL IMPACT....9

4.1 ENVIRONMENTAL IMPACT ASSESSMENT IN CONSTRUCTION PERIOD......................................94.1.1 Water Environment....................................................................................................................94.1.2 Solid Waste Impact..................................................................................................................104.1.3 Impact on Ecologic Environment........................................................................................114.1.4 Impact on Ambient Air............................................................................................................114.1.5 Impact on Acoustic Environment........................................................................................11

4.2 ENVIRONMENTAL IMPACT DURING OPERATION PHASE.........................................................114.2.5 SLUDGE DISPOSAL IMPACTS.............................................................................................................124.3 ENVIRONMENTAL RISK ASSESSMENT........................................................................................134.4 ENVIRONMENTAL MITIGATION MEASURES...................................................................................14

5. ANALYSIS OF ALTERNATIVES.........................................................................17

5.1 INTRODUCTION...............................................................................................................................175.2 WASTEWATER TREATMENT PROCESS OPTIONS.....................................................................17

6 RESETTLEMENT ACTION PLAN AND SOCIAL IMPACT ANALYSIS17

6.1 RESETTLEMENT PLAN...................................................................................................................176.1.1 Land Acquisition and Resettlement..................................................................................176.1.2 Resettlement and Compensation program....................................................................186.1.3 Resettlement Cost Estimate................................................................................................19

6.2 SOCIAL IMPACTS ASSESSMENT..................................................................................................19

7 ENVIRONMENTAL MANAGEMENT PLAN.....................................................19

7.1 INSTITUTIONAL ARRANGEMENT..................................................................................................197.2 ENVIRONMENTAL MONITORING PLAN.......................................................................................197.3 ENVIRONMENTAL BUDGET...........................................................................................................23

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8 PUBLIC CONSULTATION AND INFORMATION DISCLOSURE.............24

8.1 PUBLIC CONSULTATION.................................................................................................................248.2 INFORMATION DISCLOSURE.........................................................................................................25

9 CONCLUSIONS..........................................................................................................25

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1. General Introduction

1.1 Project Background This project consists of Changguangxi wetland rehabilitation works, Huishan fourth phase wastewater treatment and re-use works, dredging works in Meiliang Lake, and several non-physical components related to environmental management. These works are all located within the Wuxi part of the Tai Basin.

The Tai Basin is located within the Yangtze River Delta and has a total catchment area of 36,900km2. The basin is experiencing rapid economic development while still facing severe challenges in management of its water resources. The challenges include conflicting demands for limited water resource and deteriorating quality in surface waters, particularly in the Tai Lake which is officially regarded as one of the three most polluted lakes in China.

In May 2008, the State Council approved the “Master Plan for Integrated Water Environment Management in the Tai Basin” (the Plan hereafter) which thus becomes the primary guidance for water pollution control in the Tai Lake. Responding to the Plan, Wuxi Government has developed an Implementation Plan that list a series of priority interventions. The components of this Project are among the priority interventions.

An environmental impact assessment (EIA) report and environmental management plan (EMP), collectively known as the EA documentation, has been compiled by the China Research Academy of Environmental Sciences. This document is a summary of the EA documentation.

1.2 EA Basis The laws and regulations for the EA for this project are included in Table 1-1 below.

Table 1-1 EA BasisI Laws and Regulations1 The Law of the People’s Republic of China on Environment Protection

(December 26, 1989) 2 The Law of the People’s Republic of China on Environmental Impact

Assessment (October 28, 2002) 3 The Law of the People’s Republic of China on Water Pollution

Prevention (February 28, 2008) 4 The Law of the People’s Republic of China on Air Pollution Prevention

(April 29, 2000) 5 The Law of the People’s Republic of China on Environmental Noises

Pollution Prevention (October 29, 1996) 6 The Law of the People’s Republic of China on Solid Waste

Environmental Pollution Prevention and Control (December 29, 2004) 7 The Law of the People’s Republic of China on Water Resources

(August 29, 2002) 8 The Law of the People’s Republic of China on Water and Soil

Conservation (June 29, 1991) 9 The Law of the People’s Republic of China on Cultural Relic Protection

(October 28, 2002) 10 The Regulations on Environmental Protection Management of

Construction Project (November 18, 1998) 11 Pilot Method for Public Participation in EA (February 22, 2006) 12 The Procedures on Environmental Information Disclosure (Draft) (April

21, 2007) 13 The Regulations on Approval Procedure of Environmental Impact

Assessment Documents for Construction Projects (December 11,

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2008) 14 Notice on Strengthening Water Environmental Protection in Key Lakes

(January 12, 2008) 15 “10th Five-Year Plan” on Water Pollution Prevention and Control in the

Tai Lake (January 2002) 16 The Regulations of Environmental Protection in Jiangsu Province

(October 31, 2006) 17 The Regulations on Ecological Environment Protection for Agriculture

in Jiangsu Province (February 1, 1999) 18 The Regulations on Lake Protection in Jiangsu Province (March 1,

2005) 19 The Regulations on Water Pollution Prevention and Control in Tai Lake

within Jiangsu Province (June 5, 2008) II The Safeguard Policies of the World Bank1 The World Bank OP/BP4.01(Environment Assessment), (January 1999) 2 The World Bank OP/BP4.12 (Non-volunteer Immigrants) (1990.6) III Technical Guidelines

1Technical Guidelines on Environmental Impact Assessment, General Rules (HJ/T2.1-93) issued by the State Environmental Protection Administration

2Technical Guidelines on Environmental Impact Assessment, Air Environment (HJ/T2.2-2008) issued by the State Environmental Protection Administration

3Technical Guidelines on Environmental Impact Assessment, Surface Water Environment (HJ/T2.3-93) issued by the State Environmental Protection Administration

4Technical Guidelines on Environmental Impact Assessment, Acoustic Environment (HJ/T2.4-1995) issued by the State Environmental Protection Administration

5Technical Guidelines on Environmental Impact Assessment, Non-polluting Ecological Impact (HJ/T19-1997) issued by the State Environmental Protection Administration

1.3 Applicable Standards The applicable standards are included in Table 1-2.

Table 1-2 Applicable StandardsCategory Ref

. Name of standard

Environment quality standard

1 Ambient Air Quality Standard (GB3095-1996) 2 Surface Water Quality Standard (GB3838-2002) 3 Groundwater Quality Standard (GB/T14848-93) 4 Soil Environment Quality Standard (GB15618-1995) 5 Acoustic Environment Quality Standard (GB3096-2008)

Pollutant discharge standard

6 Integrated Standard for Air Pollutants Emission (GB16297-1996)

7 Odor Pollutants Emission Standards (GB14554-93) 8 Integrated Standard for Wastewater Discharge (GB8978-

1996) 9 Standard for Pollutant Discharge from Urban Wastewater

Treatment Plants (GB18918-2002) 10 Noise Limits on Boundaries of Construction Sites

(GB12523-90) 11 Noise Standard on Boundaries of Enterprises (GB12348-

2008) 12 Standard for Pollution Control in Storage and Disposal

Sites of Ordinary Industrial Solid Wastes (GB18599-2001) 13 Standard for Pollutants Control of Sludge for Agricultural

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Application (GB 4284-84)

1.4 Methodology of EA The comments and suggestions made by the World Bank task team during

the EA preparation should be followed; Information regarding the EA should be collected and baseline information

should be carefully analyzed; Scoping and screening procedures should be followed; Impact, both the positive and negative, direct and indirect should be assessed

with corresponding mitigation measured developed; Alternative analysis should be carried out through of the EA preparation which

covers the “with and without project” scenario; The requirements on the public consultation and information disclosure set

forth in the OP 4.01 should be followed.

1.5 Assessment Coverage The coverage of EA is based on the scope of each sub-EA, including two parts, the directly impacted area and indirectly impacted area. The area where the Project components are located is deemed as the directly impacted area. The area outside of the directly impacted area but indirectly impacted by the Project is deemed as the indirectly impacted area, which mainly include the objects of primary concern adjacent to the directly impacted area.

1.6 General Framework of Environmental Impact Assessment Report The environmental impact assessment report includes totally 14 chapters as follows: (1) General Introduction, (2) Policy, Law and Administrative Framework, (3) Project Description and Analysis, (4) Environment Baseline, (5) Analysis of Current Environment, (6) Environmental Impact Prediction and Assessment, (7) Mitigation Measures, (8) Environmental Risk Analysis, (9) Alternative Comparison, (10) Analysis on Environmental Benefits, (11) Analysis Social Impacts, (12) Environment Management and Monitoring Plan, (13) Public Consultation and Information Disclosure, and (14) Conclusions and Suggestions.

2. Project Description

The general information of the Project is summarized in Table 2-1.

Table 2-1 Basic compositions of the Project SN Subprojects Cost estimate

(million USD) Implementing unit

1Changguangxi

Wetland Rehabilitation

Works

81.485 Binhu District Urban Development Company of

Wuxi City

2Huishan fourth

phase wastewater treatment and re-

use works

22.512Wuxi Hushan Water Treatment Co. Ltd

3 Meiliang Lake dredging works

76.259 Wuxi Key Hydro Projects Construction and

Management Office

4

Capacity building for

water environment management

11.259

-

5

Detailed information of each project component is given in Table 2-2 through table 2-4.

Table 2-2 Changguangxi Wetland Rehabilitation WorksSN Composition Description

1 Constructed wetland

2 subsurface constructed wetlands, each 10,000m2 ; 1 free flow surface constructed wetland, 620,000 m2;

2Wetland

rehabilitation works

Restoration of hardened soils; 418628 m2; Water system canaling work, creating 227,000 m2

water surface and 20,502 m water front

3Vegetation

works Totally 2.438 million plants; Stocking of 42 t spiral shells and 12.4 t fish

4 Road works 2.4 km wooden viaducts, 25 bridges and 800 m covered bridges.

5 Tourism facilities 8 booths, 12 scenic sites, and 8 water platforms.

6Wetland

management works

500 m2 administrative and meeting room, monitoring station 500m2, sample room and lab 1,500m2.

Table 2-3 Huishan fourth phase wastewater treatment and re-use worksComposition Description

Huishan fourth phase wastewater treatment plant

Capacity is 25,000m3/d; A2/O process with deep bed denitrification filter; Class A standard for treated effluent

Phase 1 water reuse works Capacity is 150,000m3/d; Ultra-filtration system is adopted; Treated effluent quality can meet the general requirement within its service scope

Pipelines for water re-use works Pipe diameter is DN150~DN600, and pipe length 2,530m.

Note: The wastewater interceptors have been built during the previous phases of the plant

Table 2-4 Meiliang Lake Dredging WorksSN Compositions Description1 Dredging works Dredging area 22.9 km2, total amount of

dredged sediments 5.417 million m3

2 Sediment discharge site

Totally 4 sediment discharge sites (Kongwan and Baimao No. 1, 2 and 3), with a total area 290,000m2 and total capacity 2,238,000m3.

3 Sediment storage site Capacity 4.192 million m3;

4 Residual water treatment works

Residual wastewater is 28,150,000m3, and flocculants consumption amount is about 563t;2 sets of dosing and mixing equipment and on-line water quality monitoring equipment.

5Restoration works on sediment discharge and storage sites

Cofferdam removal and land leveling area is 560,000m3, woodland planting area is 330,000m2.

The dredged sediments will be initially discharged into four existing discharge sites to remove pore water of the sediment. Polymers will be added to solidify the sediments so as to allow for easy transportation to the Hongwan storage site, 8 km from the discharge sites.

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3. Environment Baseline

3.1 Natural Environment

Geographic Location

The project involves Hongshan Town, Binhu District, Huishan District and Meiliang Lake area in Wuxi Municipality. Most part of the project involves rural area. The location of the project components is shown in Figure 3-1.

Figure 3-1 Project Location

Water System

Wuxi is located within Tai Basin, an important part of the Yangtze River system. The river system is well developed in the city of Wuxi., which mainly consists of the Tai Lake, Jinghang Canal and the Yangtze River. The Jinghang Canal drains through the city, thus becoming the core of the river system in the city.. Meiliang Lake is a part of the Tai Lake, and located in the northeast of the Tai Lake.

Climate

Wuxi is located in the sub-tropical area where a maritime monsoon climate dominates. The climate is characterized by distinct seasons and rich rainfall. Average annual precipitation is 1,048 mm. The annual temperature averages 15.5OC. Most of rainfall occurs in summer.

Landform

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MeiliangSub-projects

Huishan sub-projects

Changguangxi sub-projects

Meiliang Lake

The main landforms in the city include alluvial plain and low land such as rivers and lakes. Low hills are distributed in some areas.

Natural Resources

The rich water resources, abundant arable land and agricultural scenes form the major natural resources of the city.

3.2 Socio-economic Condition

The project area is densely populated. It has densely distributed settlement centers convenient transportation conditions. Its prosperous economy is centered on light industry.

There is no physical cultural heritage nor the settlement centers of ethnic minorities. People to be affected by the project are Han nationality.

3.3 Current Environment Quality Surface Water

In order to understand the current status of surface water quality within the project area, a surface quality sampling and analysis program has been conducted with totally 31 sampling points distributed across the area.

Changguangxi Subproject Area The results of the sampling and analysis program indicate that the water quality in the 4 points can not meet the required Class III standard with organic pollutants being the pollutants of primary concern. The main pollutants are permanganate indicator, BOD5, COD and total nitrogen, which exceed the standard by the Max. time of 1.517, 0.52, 1.18 and 4.10 respectively.

Meiliang Lake Subproject Area The results indicate that COD and total nitrogen at 12 points in the Meiliang Lake area exceed the standard; BOD5, ammonia nitrogen, petroleum, total coliform and dissolved oxygen exceeds the standard at some points; and Other monitoring factors can meet the Class-III surface water quality standard.

Huishan Subproject Area The results indicate that water quality at 5 points in the Xibei Canal can not meet the Class-IV standard with ammonia nitrogen, total phosphorus, total nitrogen and BOD5 being the primary concern.

Groundwater

Totally nine sampling points are established for groundwater quality assessment. The results indicate that the main pollutants exceeding the standard are pH and faecal coliform; other pollutants can meet the required Class III for groundwater quality.

Sediment quality in Meiliang LakeTotally 60 sediment sampling points are established in the dredging area with 197 samples collected. The analysis results indicate that the average concentration of heavy metals can meet “Pollutants Control Standard for Sludge for Agricultural Application” (GB4284-84), and the Class III in “ Environmental Quality Standard for Soils ” (GB15618-1995). The Results of sediment analysis are summarized below.

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Heavy metal

Hg As Cu Pb Cr Cd

Average concentration (mg/kg)

0.4784 11.95 48.83 43.31 60.73 0.246

GB 4284-84 15 75 500 1000 1000 20

Acoustic Environment Although most parts of the project area are in the rural area, heavily affected by industrial operation and busy traffic, the monitored noises value can not meet the Class I of the Acoustic Environment Standard (GB3096-2008).

Ambient Air The results of ambient air monitoring program indicate that the ambient air quality is fairly good in the project area and can meet the Class II in Standard for Ambient Air Quality (GB3095-96)..

Soil All the results of the soil sample and analysis program indicate that the soil quality in both the Changguangxi area and the Meiliang Lake area can meet the Class III of the “Environmental Quality Standard for Soils” (GB15618-1995).

Ecological Environment The result of the assessment of the current ecological environment indicates that the primary problems in the eco-system include poor water quality, degradation in bio-diversity and loss of ecological aesthetics.

4. Prediction and Assessment of Environmental Impact

4.1 Environmental Impact Assessment in Construction Period 4.1.1 Water Environment

Impact of Suspended Solids

The dredging works in Meiliang Lake and the construction of the Changguangxi component will disturb sediments, causing diffusion of suspended solids. Adoption of better dredging technology and equipment is expected to effectively mitigate the concern of suspended solids diffusion. Construction of the Changguangxi component will be carefully scheduled to avoid rainy season, so as to reduce the impact on the water quality to an acceptable level. ,It is expected that the impact of suspended solids is limited, and will disappear immediately after the completion of the construction. Therefore, it would not have severe impact upon the quality of surface water.

Impact of Wastewater from Sediment Discharge Sites

The dredging works in the Meiliang Lake will produce 5.417 million m3 sediments high in water content. A large amount of tail water will be generated during the process of solidification in the discharge sites. After physical and chemical treatment process to the Class 1 of the Integrated Standard for Wastewater Discharge (GB8978-1996),, the tail water will be discharged into Meiliang Lake, causing impact upon the quality of lake water.

According to the predicted results, affected by the discharge of the treated tail water, the concentration of TP and TN in the Meiliang Lake within 400 m from the discharge point will decrease as distance increases and will approach the background values at 600 m.

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The impact of the wastewater from the sediment discharge site is limited and will disappear immediately after the construction is completed.

Wastewater from the Construction The wastewater is generated mainly from the machinery washing and domestic source. As the works are scattered across the project area only small amount of wastewater is to be generated, the impact on surface water quality is to be minor once after the treatment measures such as grease separation are taken. In addition, the impact will disappear immediately after the construction is completed.

4.1.2 Solid Waste Impact Dredging Works

The sediments produced in dredging process in the Meiliang Lake area will amount at 5.417 million m3 with high water content. After sedimentation and solidification, the amount will be reduced to 4.192 million m3. The dredged sediment will cause severe negative impacts on the environment in terms of air-borne dust, soil erosion and vegetation damage if it is not properly handled.

The sediment quality analysis results indicate that the heavy metal content of the sediments can meet the Class III of the Standard for Soil Environment Quality (GB15618-1995) as well as the Pollutant Limits for Sludge for Agricultural Application (GB4284-84).. Letter of content has been signed with potential users of the sediments which will be utilized as backfilling earth in the Wuxi Industrial Park Zone after it is solidified. The users are responsible for hauling the sediments to the sites.

Sediment discharge sites and temporary storage sites will be reclaimed with vegetative establishment after the sites are closed.

Construction Solid Waste

The project will involve demolition of large amount of houses and enterprises, thus great quantity of construction solid waste will be generated. Un-controlled disposal of the construction solid waste will not only reduce the landscape aesthetics but also cause air-borne dust in windy days. As the construction solid wastes contains no hazardous or toxic materials, they can be re-used by the public utilities or planning authorities in foundation works or embankment works. The remaining can be conveyed to Wuxi Taohuashan Sanitary Landfill Facility for using as cover soils.

As some part of the area is paved with asphalt which needs to be removed during the site preparation, the waste asphalt pavement should be hauled to qualified entities for disposal.

After removal of enterprises, the soil in the site may be a concern that it is polluted by the industrial operation. To investigate the soil quality, the EA team has conducted a monitoring program for the soil in the factory area. The monitoring results show that the soil quality can meet Class III of Environmental Quality Standard for Soils (GB15618-1995) , thus they can be used in greening works in the Project area and need not be removed.

Domestic Solid Waste

The construction workers will generate large quantity of domestic solid waste, which may breed pest and rodents, spread diseases and cause bad visual impacts if not properly handled. Therefore, it should be timely collected and hauled to the sanitary landfill facility

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By proper disposal of domestic solid waste, it will not produce severe impact upon the surrounding environment.

4.1.3 Impact on Ecologic Environment Impact on Ecologic Environment

The construction of the Project will cause adverse impact on local aquatic and terrestrial ecological environment. However such impact is temporary and reversible. The impact will disappear after the project is built.

Impact on Soil Erosion

Soil erosion will occur during the process of the construction of wastewater treatment plants, reclaimed water pipelines and site preparation etc. It is estimated that the amount of soil erosion caused by the project is 1,184t with the site preparation be the primary source for soil erosion. Construction in rainy season will cause soil erosion, but this impact can be sufficiently mitigated by proper measures.

4.1.4 Impact on Ambient AirThe impact on ambient air quality is mainly caused by construction activities, vehicular emission, vehicle movement and odor from dredging works. The impact of air-borne dust typically is limited to 100m from the source and 50 m for odor from dredging works. The sensitive receptors of the project are all more than 100 m from the construction sites, and the impact will disappear immediately after the construction is completed.

4.1.5 Impact on Acoustic EnvironmentNoise is mainly generated from various construction equipment and transport vehicles. It is projected that, the noise level at the distance 80m from the construction area can generally meet the Class I of Standard for Environmental Noise in Urban Areas (GB3096-93). There are no sensitive receptors within 100m from construction sites and the noise impact on the residents near the site is minor.

4.2 Environmental Impact during Operation Phase4.2.1 Surface Water Impact

A surface water quality model recommended by the Technical Guideline is used to forecast the water quality in the Xibei Canal which receives the treated effluent of 10,000 m3/d from the component of Huishan Fourth Phase Wastewater Treatment and Re-use Works. The recorded worst flow rate in history is adopted as the fundamental condition for the modeling.

The result of the model indicates that after the project is operational, the maximum increment of COD, NH3-N and TP at the control section that is 1900 m from the outfall is 0.4mg/L, 0.09mg/L and 0.007mg/L respectively. However, the concentration of NH3-N and TP in the water at the control section already exceed the Class IV standard. Such minor increment contributed by the project will not cause severe impact on the water quality downstream in Xishan District.

4.2.2 Pollution Load Reduction

The project is intended to help reduce pollution loads into the Tai Lake. The information on pollution load reduction to be achieved by the Project is given in Table 4-1 below.

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Table 4-1 Pollution Loads Reduction by the ProjectProject

ComponentPollution Load Reduction (unit: t/a except for dredging

works)COD SS NH3-N TN TP

Changguangxi Wetland

Rehabilitation Works

- - 0.24 4.8 0.12

Huishan fourth phase

wastewater treatment and re-use works

2,326.9 84.8 219.1 228.1 21

Sum total 2326.9 84.8 219.34 232.9 21.12Meiliang Lake

dredging works

Organic matter 195,200

- 12100 790

4.2.3 Odor Impact

The odor intensity in the sludge thickening tank and aeration tank is the greatest. However it will be attenuated to an acceptable level at the distance of 150m from the source. The nearest sensitive receptor of Huishan subproject is 250m from the wastewater treatment plant, thus the odor from this plant will not affect the sensitive receptors. The distance of the buffer zone of the Huishan subproject is 100m.

4.2.4 Noise impact analysis

As the nearest sensitive receptor is 250 m from the boundary of the Wuishan Wastewater Treatment Plant, it is expected that the noise during the operation of this plant will not affect the receptors. The pumping station is built underground and no acoustic sensitive receptors are near the station, thus the noise will not cause severe impact.

4.2.5 Sludge Disposal Impacts

This Project alone will generate about 4 tons/day excess sludge containing 80% moisture. The sludge will be hauled to the municipal sludge disposal center, about 10 km southwest to the WWTW by a tanker.

The sludge disposal center is established through the internal permitting procedure of Wuxi EPB which designates this center a role to dispose of all the municipal sludge in Huishan District. Financial sustainability of the sludge center is guaranteed by the subsidy allocated by Wuxi Municipal Government, although the agreement has set a unit rate of RMB 100 for disposing of each ton of sludge with 80% water content. This center is also an integral part of the municipal sludge management planning in the city of Wuxi which requires municipal sludge produced in municipal WWTWs in Huishan District be hauled to this center for disposal.

This sludge center is designed to be capable of disposing of 250 t/d sludge. Currently the idle capacity is about 50 t/d. The sludge will be initially piled in the workshop to accumulate to an amount capable of sustaining continuous operation of the equipment for a certain period. Then the sludge will be mixed with coal at a mass ratio of 3:7 before being conveyed to the vessel of the fluidized bed furnace. Residue from the furnace will be used to produce brick by a proprietary process.

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Water curtain is used to remove the dust and SO2 from the flue gas before its discharging through a stack at a height of 15 m, and the wastewater will be conveyed to the local industrial wastewater treatment plant for treatment.

There are no sensitive receptors in the areas surrounding the sludge disposal center. .

Sludge haulage is another potential environmental concern. Potential leakage and odors from sludge as well as the heavy haulage truck emissions would affect the environment and residents along the haul routes. The hauling route has been carefully selected so as to avoid densely populated area or business area.

4.3 Environmental Risk Assessment Environmental Risk during Construction

The primary environmental risks during construction include the accidental discharge of the residual water from the sediment discharge site under the Meiliang Lake dredging works. Four existing sediment discharge sites will be used by the Project. It is predicted that, under the condition of accidental discharge, the contribution of the TN and TP at the location about 800m from the sediment discharge sites is below the Class III in Environmental Quality Standard for Surface Water. Therefore, such risk should be carefully managed on the sediment discharge sites and mitigation measures should be established.

Environment Risk during OperationThe primary environmental risks during operation include the direct discharge of the untreated wastewater from the wastewater treatment plant. It is predicted that the COD concentration at the outfall under the accidental discharge scenario exceed the standards, and the COD concentration within 2,500 m downstream of the outfall can not meet the Class IV standard. Therefore, the wastewater treatment plant should be carefully designed to avoid any risks by adopting double-power supply and standby pumps. Meanwhile, the operation procedures and rules must be followed during operation so as to prevent any accident, and the environmental management authorities should supervise the operation of the sewage treatment plant to improve the management of the plant.

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4.4 Environmental Mitigation MeasuresDetailed mitigation measures are given in Table 4-2 and 4-3 for the environmental protection and mitigation measures in the construction and operation stages.

Table 4-2 Environmental Mitigation Measures during Construction StageEnvironmental Issue Mitigation Measures

1. Surface water pollution

Better schedule for sediment discharge, from the area near the outfall to the area far from the outfall, to extend the retention time of the wastewater in the sediment discharge site;

Increase bunks within the sediment discharge site to facilitate the settling of the solids; Increase overflow elevation of the outfall in the sediment discharge sites to extend the retention time of

wastewater; Emergency measure for additional addition of coagulants in the sediment discharge site outfall or the subsequent

settling tank; Strengthen monitoring of the water quality of the residual wastewater from the sediment discharge sites; Periodically remove the sediments in the settling tanks; Install oil separation device on construction ships; Water-tight flange connection should be adopted in connecting the pipelines for sediment conveyance. Routine

inspection and check should be maintained on the pipelines; The boundary embankment of the sediment discharge sites should be routinely inspected; Warning signs should be set up around the sediment discharge sites; The construction of wetland restoration works should be well scheduled to avoid rainy season; Domestic wastewater from construction camps should be collected by local municipal department and forbidden

from discharging into rivers; Settling tanks and oil separation tanks should be provided on site of machinery and vehicle washing. Wastewater

should not be discharged into municipal sewers and should be reused on site; The sites for construction, material stockpile,, such as fuels and chemicals should be kept far away from rivers

and ditches. Powder materials should be covered; and The sites for construction and material storage should be planted with grass or provided with soil filter net, to

prevent soil erosion by rainfall.2．Noise Equipment with low noise is preferable. Maintain machinery and vehicles in good conditions;

Forbid construction in night time (22:00-6:00) with noisy machine; Coordinate work hours as much as possible to avoid impacts to sensitive receptors; Use temporary barriers if necessary to control noise at sensitive receptors;

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Environmental Issue Mitigation Measures Construction sites should be far away from sensitive receptors; and Workers should be provided with protective device such as ear plug when working near noisy equipment.

3. Air Pollution The river dredging works should be scheduled in low flow season, and the dredged sediments should be transported to the site designated by relevant department;

The rivers will be manually dredged and the sediment will be stored in bags and periodically transported out; Dredged sediments and domestic solid waste should be transported out by tankers; The dredging works should be scheduled to avoid summer and windy days; The sediment discharge sites should be located as far as possible from residential area; The sites for house demolition should be surrounded with fence at a height at least of 1.8 m. during house

demolition water spray should be carried out; The powder materials should be transported using tanker; The main access roads should be paved. Contractors will be requested by contracts to provide at least 1 water

spray vehicle at each bid section to water the unpaved ground and access roads; Wind barriers should be provided on the upwind of the sediment discharge site during the addition of solidifying

agents. Solidified sediments should be compacted and planted with vegetative cover; Equipment or vehicles with low fuel consumption and emission should be preferred; the solid waste is banned from burning on site. The cleaner fuel or electricity should be used for cooking on site.

4. Solid waste

Agreement should be signed with users of the dredged sediments; The recyclables in the construction solid waste should be collected, and the remaining should be transported to

the site designated by relevant departments for disposal. Permit should be obtained for transportation of the solid waste;

The asphalt from demolition of paved area should be collected and transported to the disposal facilities operated by certified organizations;

Solid waste generated in construction camps should be collected to designated place, and be cleaned by sanitation agency.

5．Ecology

The boundary of the construction sites should be cleared defined; occupation of farmland out of the site boundary should be banned;

Soil erosion control measures should be in place on the construction site near surface streams and borrow pits; The dredged sediment discharge sites should be caped with vegetative establishment after the dredging works is

completed; The thickness of sediments to be dredged should be carefully controlled; and Close communication with weather forecast department should be kept and the unpaved ground should be

covered before heavy rains. 6. Social impact Clean drinking water should be provided to the construction camps;

Workers should be provided with health inspection before the construction is commenced; Health management system should be established;

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Environmental Issue Mitigation Measures Route for material hauling should be carefully selected; Where the access road need to cross existing roads, the route should be carefully selected in cooperation with

local people; Construction sites should be enclosed and warning signs should be set where the water re-use pipeline is being

constructed; workers should be designated to guide people through the construction section in rush hour; and The material transport plan should be carefully developed to avoid the rush hour on existing roads.

7. Risk management Water quality monitoring system should be installed at the outfall of the sediment discharge site; Water tight flanged pipes should be used in construction of the pipeline for sediment discharge; Routine inspection on the sediment discharge pipeline should be maintained; Pressure meters should be installed on the sediment discharge pipeline to monitoring the leakage.

Table 4-3 Environmental Mitigation Measures during Operation Stage1．Air pollution Trees should be planted around the wastewater treatment plant to minimize the odor impact;

The activated oxygen method should be used in the process units emitting odor2. Surface water pollution Operation procedure for the wastewater treatment plant should be strengthened;

The industries discharging into the wastewater treatment plant should be monitored for water quality.3．Noise Silencer should be installed on the outlet of blowers in the wastewater treatment plant.

4. Sludge Sludge from wastewater treatment plant should be transported with tankers to the municipal sludge

disposal center for disposal; Contract should be signed with the disposal center.

5. Risk Wastewater storage tanks should be constructed in the key polluting industries; Double power line should be provided in the wastewater treatment plant; Emergency response plan should be developed in the wastewater treatment plant.

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5. Analysis of Alternatives

5.1 Introduction

During project development, various alternatives have been screened and compared with technical, economic and environmental criteria. In terms of the environmental assessment of alternatives, the primary objective was to identify and adopt options with the least adverse environmental impacts. The evaluation and comparison has included the following component options:

Processes of constructed wetland; Methods for dredging and treatment of dredged sediment; Equipment for dredging works; Locations for sediment discharge sites; Wastewater treatment processes; and The scenario of with and without the project.

5.2 Wastewater Treatment Process Options The priority for wastewater treatment in the Tai Basin is the removal of pollutants that impact adversely upon the surface water quality. The most critical pollutant in this context is organic matter expressed as COD, TN, TP and NH3-N.

The following criteria formed the basis of identifying the most appropriate wastewater treatment proposal.

Comply with the required wastewater discharge standard of Class 1 A; Appropriate in respect of local conditions; Proven in operation at or close to the scale proposed; Capable of supporting competitive bidding; and Representing the least cost option.

Two alternative processes were considered for the secondary treatment of wastewater and compared against the above criteria. The two process options are the modified SBR (CAST) and modified A2/O with the latter being identified as the preferred and least cost option for secondary wastewater treatment.

Two alternative processes were considered for the advanced treatment of the effluent from the secondary process and compared above the criteria. The two process options are the submerged ultra-filtration, and ultra-filtration plus RO with the former being identified as the preferred and least cost option for secondary wastewater treatment. The Huilian Thermal Power Plant, a user of the reclaimed water with the highest requirement for water quality, will install a RO system within its plant boundary to treat the reclaimed water to its standard.

6 Resettlement Action Plan and Social Impact Analysis6.1 Resettlement Plan6.1.1 Land Acquisition and ResettlementThe Project will involve 852.3 mu land under the practice of exchange of contracted land right , affecting 970 households with 3,014, people. This project also will involve temporary occupation of 504.68 mu land and demolition of 211,600 m2 houses that directly affect 970 households. This Project also will involve demolition of 238,400 m2 industrial structures, affecting 57 enterprises

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and 1752 workers. Moreover, the Project shall affect 10 categories of various surface attachments.

6.1.2 Resettlement and Compensation programBased on the legal framework and the actual conditions in Wuxi City and affected areas, the compensation standards for each types of land acquisition have been established as follows:

Transfer of contracted land

According to the provisions specified in the Opinions of Wuxi City on Transfer of Contracted Rural Land Management Right with Urban Social Security in Urban Area (for Trial Implementation) Wuxi Municipal Government No. [2009] 181), all contracted rural land management rights shall be transferred with urban social security. A total payment of RMB35,000 for each person for personal social security shall be paid by local government finance. Any person eligible for social security can collect the social security money according to the regulations on urban social security policy.

Temporary land occupation

The land to be temporarily occupied by the Meiliang Lake Dredging Works shall be compensated in monetary term and farm land be restored to its previous use after the land occupation is completed. The land to be temporarily occupied by Huishan fourth phase wastewater treatment and re-use works is state-owned land; the land of temporary occupation is existing roads, thus no compensation is needed. The ground structures affected during the construction of pipeline shall be restored by the contractors and the cost will be included into the contract price.

Rural house demolition

According to the Procedures of Wuxi City on Relocation of Houses on Collectively-owned Land in Urban Areas (Wuxi Municipal Government No. [2004]363) and Opinions on Execution of Procedures of Wuxi City on Relocation of Houses on Collectively-owned Land in Urban Areas (Binhu District Government No. [2005]62) etc., the compensation for the residential house to be demolished will be made in the form of monetary compensation or property right exchange.

Enterprise relocation

According to the Procedures of Wuxi City on Relocation of Houses on Collectively-owned Land in Urban Areas (Wuxi Municipal Government No. [2004]363), Measures for Industrial Layout Adjustment and Enterprise Relocation and Reconstruction in Urban Areas (Wuxi Adjustment No. [2005]01) and Opinions of Wuxi City on Relocation of Nonresidential Buildings on Collectively-owned Land in Urban Areas (Wuxi Relocation Office No. [2006]04) etc., the compensation for enterprise relocation shall be generally made through the combination of monetary compensation and relocation.

Ground attachments and special facilities

The compensation standards for ground attachments and special facilities will be determined by the documents regarding compensation for house demolition and relocation in Wuxi City.

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6.1.3 Resettlement Cost EstimateThe resettlement cost includes 5 items: the fees for land requisition; compensation for house demolition compensation for enterprise demolition, compensation for surface attachments, and other costs. The total cost estimate for resettlement is , RMB904, 790,100 for this project.6.2 Social Impacts AssessmentThe primary social impacts in the construction stage include the impacts on the human health and local traffic conditions, but these impacts are short term and will disappear after the construction is completed. These impacts can be avoided or mitigated by appropriate measures. The other social impact of primary concern is the livelihood of the people affected by land acquisition, but this impact can be mitigated by appropriate resettlement. plan.

In the operation phase, the impacts will be positive, such as promoting regional economic development, increased property values for land and real estate, improved recreation and environmental aesthetics to the communities of the project area; and increased revenue from tourism; and improvement of regional landscape.

7 Environmental Management Plan

7.1 Institutional ArrangementSeveral organizations will take responsibility for environmental management and monitoring.

Wuxi Project Management Office will take the ultimate responsibility for environmental protection and management. This organization is the overall leading agency for project implementation;

Binhu District Urban Development Company, Wuxi Huishan Wastewater Treatment Plant and Wuxi Key Hydro Projects Construction and Management Office will be responsible for day to day environmental management during the construction phase and operation phase. Their responsibilities will include engagement of professional supervision and monitoring services, allocation of budget for environmental management, response to environmental monitoring reports and the taking of appropriate mitigation actions. They will also handle any environmental events which may occur during construction and operation;

Jiangsu Provincial Environmental Commission and Wuxi Municipal EPB will be responsible for enforcement of environmental regulations and standards and review of environmental monitoring reports;

Wuxi Environmental Monitoring Station operated will undertake environmental monitoring of air quality, noise, water quality, and other impacts on the environment from the project construction and operations; and

Contractors will be responsible for implementing the mitigation measures for implementation phase.

A training program will be undertaken during project implementation for management and technical staff from the above organizations. Training course contents will include environmental regulations, wastewater treatment technologies, environmental monitoring, sludge handling and disposal, and handling and responses to environmental incidents.

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7.2 Environmental Monitoring PlanThe environmental monitoring plans for the construction and operation stages are given in Table 7.1 to Table 7.3.

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Table 7.1 Environmental Monitoring Plan for Changguangxi Wetland Rehabilitation Works

Stage Environment Monitoring point Monitoring index Monitoring frequency

Monitoring institution

Responsible unit

Supervision organization

Construction stage

Ambient air2 points around construction site, with one upwind and one leeward

TSP,PM102 days/quarter, 2 times/day

Wuxi Environmental Monitoring Station

Wuxi Chengkai Investment Co., Ltd.

Wuxi Municipal Environment Protecton Bureau

Noise

4 points around the construction sites where residential blocks are nearby

dB(A)1 day/quarter, 2 times/day, each time for day and night

Operation stage

Ambient air 2 points NH3、H2S 1 day/quarter, 2 times/day

Surface water

3 points at the constructed wetland, with one at the inlet, one inside the wetland and one at the outlet

COD,BOD5,NH3-N, TP and TN

1day/quarter, 1 time/day

Table 7.2 Environmental Monitoring Plan for Huishan fourth phase wastewater treatment and re-use works

Stage Environment Monitoring point Monitoring index Monitoring frequency Monitoring institution

Responsible unit

Supervision organization

Construction stage

Ambient air

2 points around construction site, with one upwind and one leeward

TSP,PM102 days/quarter, 2 times/day Wuxi

Environmental Monitoring Station

Wuxi Hushan Water

Treatment

Wuxi Municipal Environment Protecton BureauNoise

1 point around the construction sites where residential

dB(A)1 day/quarter, 2 times/day, each time for day and night

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blocks are nearby

Operation stage

Ambient air2 points on the boundary of the plant

NH3, H2S and odor concentration

1 day/quarter, 2 times/day

Surface water

Outfall, section of No. 5 bridge and section of Zhangtang Bridge

pH,COD,BOD5,SS,ammonia nitrogen, TN, TP, oil, etc..

1day/quarter, 1 time/day

4 points at the wastewater outlets of major enterprises

Determined according to characteristics of wastewater

1 day/month, 1 time/day

4 points of the wastewater inlets of wastewater treatment plant

pH,COD,BOD5,SS,ammonia nitrogen, TN, TP, flow rate

1 day/month, 1 time/day

1 point at the outfall of wastewater treatment plant

pH,COD,BOD5,SS,ammonia nitrogen, TN, TP, flow rate

Online monitoring system

Noise2 points on the plant area and boundary of pump station

dB(A)2 days/quarter, and one time for each day and night

Table 7.3 Environmental Monitoring Plan for Meiliang Lake dredging works

Stage Environment

Monitoring objects Monitoring index Monitoring points Frequency

Monitoring institution

Responsible unit

Supervision organization

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Construction stage

Water environment

Residual wastewater from sediment discharge site

pH,SS,CODMn,TP,TN,NH3-N

Drain outlet of each sediment discharge site and settling tank

1day/month, 1 time/day

Wuxi Environmental Monitoring Station

Wuxi Key Hydro Projects Construction and Management Office

Wuxi Municipal Environment Protecton Bureau

Pore water of sediment within dredging area

ORP(Eh),NH3-N,PO4

3-P,TOC Dredging area 1day/month, 1 time/day

Tai Lake area

Water temperature,SD,SS,CODMn,BOD5,TN,TP,chlorophyla,pH,DO,volatile phenol,oil,NH3-N

Dredging area, river mouths and control points

1 day/2 months, 1 time/day

Shallow aquifer

CODMn,NH3-N,TN,TP,pH,Ni,Cu,Cr6+,Pb,Hg,Cd,As

Totally 4 points , one for each sediment discharge site

1day/2 months, 1 time/day, where necessary, frequency will be increased

Ambient air

PM TSP,PM10 Around construction sites 2 days/quarter, and 2 times/day

Odor H2SNH3

4 sediment discharge sites and 1 temporary storage site

One time prior to dredging works; one time during dredging

Noise Mechanical noises dB(A) One point within construction

sites1day/month and each time for day and night

Sediment Dredged sediment

Cd,Cr6+,Cu,Hg,Pb,As, mineral oil,Cu,Zn,Ni, benzopyrenes,TN,TP

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Ecological environment

Water are of Tai Lake

Species and quantities and biomass of phytoplankton and zooplankton; Species and quantities and biomass of benthos and hydrophyte

The same with routine water quality monitoring points of Tai Lake

1 time after completion of dredging

Operation period

Surface water

pH,DO, permanganate index ,CODCr,BOD5,NH3-N,total phosphor, total nitrogen,Hg,As,Cr6+

and oil

The same with routine water quality monitoring points of Tai Lake

2 days/month and 2 time/day for April and July

Ecologies

Species, quantities and biomass of phytoplankton and zooplankton; varieties, quantities and biomass of benthos and hydrophyte

The same with routine water quality monitoring points of Tai Lake

7.3 Environmental BudgetAccording to the regulations of the Price Bureau, Finance Department, and Environmental Protection Bureau of Jiangsu Province, and the current price of labors and materials, it is estimated that the total investment in environmental protection of the Project is RMB1, 639,000 / year

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8 Public Consultation and Information Disclosure

8.1 Public Consultation

Community stakeholders were consulted during the project EA, particularly those who will be directly affected by the Project. These included urban and rural residents near proposed pumping stations, wastewater treatment plant, and the sludge disposal site. The primary methods of public participation included public meetings/hearings, interviews, questionnaires, and use of public media such as newspapers and internet. The EA team organized and chaired the public meetings which were also attended by project planners, design engineers, and government officials from the implementing units and Wuxi EPB.

Consultation has been undertaken throughout the project preparation. Wuxi has carried out two rounds of public consultation. The first round focused on environmental screening to define public concerns, to assist identification of key environmental issues and to draw public response and comments on the initially developed mitigation measures for the potential adverse impacts identified before EA TOR finalization. The second round was designed to ensure public awareness of the EA effort and final project definition and mitigation by presenting a draft EA report to the public through information disclosure procedures. As part of the process of public consultation, a telephone hotline has been maintained in the project implementing units to solicit public comments. Table 8-1 summarizes the details of public consultation.

Table 8-1 Summary of Public Consultation Project

Component Date Participants Method

Changguangxi Wetland

Rehabilitation Works

2010.3.5-3.7

Representatives from Changjuang

community and Rengang Village, and affected enterprises;

experts from the environmental

protection bureau and Water

Conservancy Bureau

Distribution of questionnaire

2010.5.5-5.6

Interview, distribution of questionnaire, public

meetings, experts consultation

Meiliang Lake dredging works

2010.3.5-3.7

Representatives from Wutang Village, and

experts from the environmental

protection bureau and Water

Conservancy Bureau

Distribution of questionnaire

2010.4.8-4.9

Interview, distribution of questionnaire, public

meetings, experts consultation

Huishan fourth phase wastewater treatment and re-use works

2010.3.5-3.7

Representatives from Hujiadu Village; experts from the environmental

protection bureau and Water

Conservancy Bureau

Distribution of questionnaire

2010.4.8-4.9

Interview, distribution of questionnaire, public

meetings, experts consultation

By public consultation, it is known that the public concerns are primarily related to compensation for the land occupation and house demolition, and the mitigation measures for the impacts in construction stage. For the concerns on environment, the EIA team has responded in the EIA Report; for other concerns and suggestions, such as policy on demolition and relocation, are delivered to the

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relevant authorities for response.

Most of the public supports the project. They think that the project is very necessary, and they understand the information on land requisition and relocation, as well as environmental impacts regarding to the project.

8.2 Information Disclosure

An advertisement has been placed in the most popular local newspaper during the second round consultation to describe the project and its potential impacts and to invite the public to express their concerns about the project, and to inform the public the place to assess to the draft EIA report. In addition, the draft EIA report and other project related information, including project environmental information, have been placed in the offices of the implementing units for public review and comments.

In addition to the advertisement on newspaper, the information of the project as well as the draft EIA report is available at the internet

9 Conclusions

The environmental assessment for the project has drawn the following conclusions:

Wuxi has been suffering severe pollution in virtually all its rivers. As a result of the direct discharge of contaminants into its waterways, the drinking water safety is being threatened by the surface water pollution;

This project fits well into the Master Plan for Integrated Water Environment Management in the Tai Basin. This is one of the top state and provincial pollution control priorities. While this project alone cannot resolve the problem and meet the government goal for surface water quality, it will be a key step and contribute towards achieving the goal;

The Changguangxi Wetland Rehabilitation Works and Huishan fourth phase wastewater treatment and re-use works together will cut the COD load by 2326.9 t/a, SS by 84.8 t/a, NH3-N by 219.34 t/a, TN by 232.9 t/a and TP by 21.12t/d; the Meiliang Lake dredging works alone will remove organic matter 195,200 t, TN 12,100 t and TP 790 t from the Lake.;

The project will also cause some adverse impacts to the environment. During the construction phase, dredged sediments, dust, noise, construction camps, and construction solid waste will be experienced. During the operation phase, noise, odors, sludge haulage and sludge disposal will impact on the surrounding environment. With careful design and implementation of appropriate mitigation measures, however, these adverse impacts can be mitigated; and

To further ensure environmental protection and proper implementation of mitigation measures, an environmental management plan has been developed. This includes government and local organizations.

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