Initial Environmental Examination

November 2011 Project no. 43901-01

Municipal Waste to Energy Project (People’s Republic of China)

Suzhou Phase III Waste-to-Energy Subproject

Prepared by China Everbright International Limited for the Asian Development Bank (ADB)

This initial environmental examination report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section of this website.

In preparing any country program or strategy, financing any project, or by making any designation on or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area. Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy () Limited The Report of Environmental Impacts of the BOT Project of Suzhou Phase Waste-To-Energy Power Plant

Construction Unit: Everbright Environmental Energy (Suzhou) Limited

201111

I Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Content

1 Overview ...... 1

1.1 Preface ...... 1

1.2 Basis of Compilation ...... 3

1.3 Assessment Purposes and Working Principles ...... 9

1.4 Assessment Factors ...... 10

1.5 Assessment Grade ...... 11

1.6 Assessment Range ...... 15

1.7 Object of Environment Sensitivity Protection ...... 16

1.8 Assessment Standard ...... 17

1.9 Process of Assessment ...... 26

2 Environment Overview ...... 28

2.1 Overview of Natural Environment ...... 28

2.2 Overview of Social Economy ...... 33 2.3 Overview of Regional Master Plan and Environmental

Protection Plan ...... 36

3 Reviews on Existing projects ...... 50

3.1 Overview of Existing Projects ...... 50

3.2 Overview of Technological Process ...... 52

3.3 Raw and Auxiliary Materials Consumption ...... 58 3.4 Water Supply, Drainage and Water Balance of Existing

Projects 62

3.5 Discharge Conditions of Main Pollutants ...... 64 3.6 Official and Written Reply of Existing Projects and

Implement Condition of “Three-meanwhile” Policy ...... 73

3.7 Main Environment Problems of Existing Projects ...... 81

3.8 The Measures of “Using New Method to Improve Old One” ...... 81

4 Engineering Analysis of Phase Expansion Project ...... 83

II Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

4.1 The Necessity of Phase Expansion Project ...... 83

4.2 Basic Composition of Phase Expansion Project ...... 84

4.3 Overview on the Geographic Positions of the Plants ...... 88

4.4 Overview on Land Occupation and Plan Layout of the Plants .... 88

4.5 Overview of Projects and Equipment ...... 90

4.6 General Information of Raw and Auxiliary Materials ...... 107

4.7 Public Auxiliary Projects...... 109

4.8 The Production and Discharge of Main Pollutants ...... 115

4.9 Summary of Pollutant Discharge ...... 136

5 Comment on Pollution Prevention Measures ...... 139

5.1 Comment on Air Pollution Prevention Measures ...... 139

5.2 Comment on Water Pollution Prevention Measures ...... 153

5.3 Comment on Noise Pollution Prevention Measures ...... 160

5.4 Comment on Solid Waste Pollution Prevention Measures ...... 161

5.5 Underground Water and Soil Prevention Measures ...... 165

5.6 Greening Measures ...... 166

5.7 Summary List of “Three-meanwhile” Acceptance Check ...... 167

6 Industrial Policies, Cleaner Production and Recycling

Economy Analysis ...... 173

6.1 Industrial Policies ...... 173

6.2 Cleaner Production ...... 174

6.3 Recycling Economy ...... 190

7 Investigation on Regional Pollution Sources and Investigation

and Evaluation of Present Environmental Quality Condition . 192

7.1 Investigation on Regional Pollution Sources ...... 192 6 3 ΣPi(10 m /a) ...... 195

Ki(%) 195

7.2 Investigation on Present Environmental Quality Condition ...... 195

III Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

7.3 Environmental Quality Review and Analysis ...... 211

8 Predicative Analysis on Environmental Impact ...... 215

8.1 Prediction and Evaluation on Ambient Air Impact ...... 215

8.2 Analysis on the Environmental Impact of Surface Water ...... 244

8.3 Prediction and Assessment of Noise Environmental Impact ...... 245

8.4 Analysis on the Environmental Impact of Solid Waste ...... 250

8.5 Analysis on the Environmental Impact of Soil ...... 251

8.6 Analysis on the Environmental Impact of Ground Water ...... 251 8.7 Analysis on the Environmental Impact during Waste

Transportation ...... 255

9 Analysis on Environmental Impact During Construction

Period ...... 256 9.1 Noise Environmental Impact Assessment and Control

Measures During Construction Period ...... 256 9.2 Waste Water Environmental Impact Assessment and Control

Measures During Construction Period ...... 259 9.3 Waste Gas Environmental Impact Assessment and Control

Measures During Construction Period ...... 259 9.4 Ecological Environmental Impact Assessment and Control

Measures during Construction Period ...... 261

10 Risk Assessment ...... 262

10.1 Overview ...... 262

10.2 Risk Identification ...... 262

10.3 Assessment Grade Determination and Assessment Range ...... 265

10.4 Analysis on Sources ...... 267

10.5 Analysis on Accident Consequences ...... 268

10.6 Risk Control Measures for Current Project ...... 274

10.7 Formulation of Accident Contingency Plan ...... 278

IV Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 10.8 Contingency Prevention of the Expansion Project and Its

Contingency Plan ...... 283

10.9 Summary of Risk Assessment ...... 284

11 Emission Control ...... 285

11.1 Emission Control Factors ...... 285

11.2 Emission Application ...... 285

11.3 Emission Balance Plan ...... 286

12 Public Participation ...... 287

12.1 Purpose of Public Participation ...... 287

12.2 Principles of Public Participation...... 287

12.3 Methods of Public Participation ...... 288

12.4 Result Analysis of Public Participation Questionnaire Issued . 288

12.5 Online Publication Investigation ...... 298

12.6 Participating Hearing of the public ...... 298

12.7 Grievance Redress Mechanism...... 299

12.8 Investigation Conclusion of Public Participation ...... 300

13 Feasible Analysis of Site Selection ...... 302

13.1 Consistency Analysis to Urban Planning ...... 302 13.2 Consistency Analysis to Environmental Sanitation

Professional Planning ...... 303 13.3 Consistency Analysis on Important Environmental

Protection Targets ...... 304 13.4 Consistency of Environment Development [2008] No. 82

Regulation ...... 305

13.5 Environmental Impact Analysis ...... 310

13.6 Analysis on Reasonability of General Layout ...... 311

13.7 Summary ...... 312

14 Economic Cost-benefit Analysis ...... 314

V Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

14.1 Economic Benefit Analysis ...... 314

14.2 Environmental Benefit Analysis ...... 315

14.3 Social and Economic Environmental Impact ...... 320

15 Environmental Management and Detection Plan ...... 321

15.1 Basic Objectives of Environmental Management ...... 321

15.2 Management Responsibilities and Measures ...... 321

15.3 Environmental Management Responsibilities ...... 321

15.4 Environmental Monitoring Responsibilities ...... 322

15.5 Environmental Supervision ...... 323

15.6 Environmental Monitoring Plan ...... 325

15.7 Standardization Requirements for Sewage Outfall ...... 329

16 Conclusion and Suggestions ...... 331

16.1 Project Overview ...... 331 16.2 Ambient Quality Situation and Main Environmental

Protection Objectives ...... 331

16.3 Main Pollution Prevention Measures ...... 334

16.4 Environmental Feasibility ...... 336

16.5 Analysis on Clean Production...... 338

16.6 Environmental Impact Forecast Results ...... 339

16.7 Emission Control...... 342

16.8 Public-participated Investigation ...... 342

16.9 Final Conclusions on Environmental Assessment ...... 343

16.10 Suggestions and Requirements ...... 343

VI Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

1 Overview

1.1 Preface As a famous historic and cultural city as well as an important scenic tourist city, Suzhou is one of the cities with the fastest economic development in River Delta. The city covers an area of 8,488 km2, with an urban area of 1,650 km2. At the end of 2009, its registered permanent residents were 6.3329 million, of which 2.4021 million lived in urban area. During the process of economic development, Suzhou put Qizishan Refuse Landfill Site into operation to disposal its municipal domestic waste in 1993, with the design storage capacity of 4.7 million cubic meters and the effective capacity of 4.2 million cubic meters, with the designed service life of 15 years. Since the rate of growth of domestic waste exceeds the expected value, the discharge quantity of Suzhou municipal domestic waste in 1993 was between 280~300t/d, which reached 1,300t/d in 2002 and 3,000t/d at the end of 2006, according to the statistics data of Suzhou Public Municipal Works Administration. Facing the restrictions of objective conditions, such as natural, social environment of Suzhou, selection and storage capacity of refuse landfill site, fast growth of domestic waste in urban area of Suzhou, it is urgent for Suzhou to choose proper approach of domestic waste disposal to solve the problem of sustainable development. From May of 2002 to December of 2003, relevant departments of Suzhou municipal government had declared and completed the environmental assessment of “3×350t/d Domestic Waste Waste-to-Energy Project of Suzhou SuNeng Waste-to-Energy Co., Ltd.” (hereinafter referred to as Phase Project), planning to use the reserved site of Qizishan Refuse Landfill Site to build a garbage incineration power plant with daily treatment of domestic waste of 1,000t. The project had its environmental impact assessment accomplished by State Power Environmental Protection Research Institute and had been replied by Environmental Protection Department in Suzhou Environment Management [2003] No. 229 in December, 2003. In 2004, China Everbright International Limited had been brought in by Build-Operate-Transfer (BOT) pattern of government investment invitation and

1 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Everbright Environmental Protection Energy (Suzhou) Co., Ltd. was established to take charge of the establishment of Phase Project and the operation management of the first 25 year, and change the enterprise name according to Regulations of the People's Republic of China on Administration of Registration of Companies. In accordance with Suzhou Environment Acceptance (2007) No. 380, Phase Project had passed the acceptance of environmental protection organized by Jiangsu Environmental Protection Department. As domestic waste of Suzhou increases, Everbright Environmental Protection had invested RMB 450 million to implement the Phase extension project “2×500t/d garbage incinerator + 20MW turbo generator unit” (hereinafter referred to as Phase Project); meanwhile, in order to make full use of resources, the extension project would establish comprehensive utilization of slag project. The environmental impact assessment of the project had been accomplished by China Bluestar Lehigh Engineering Corporation. The project had been replied in Environment Audit [2008] No. 25 by the Ministry of Environmental Protection in March, 2008. Phase Project was constructed and put into operation in 2009 and past the acceptance of environmental protection organized by Ministry of Environmental Protection in Environment Acceptance [2010] No. 84. The data of online monitoring, acceptance monitoring, routine monitoring operated in Phase Project and Phase Project show that, through the purification of the process of “lime cream de-acidification by semi-dry process + activated carbon adsorption + bag dust separation”, the concentration of pollutants in the discharged gas of the flue gas is lower than the requirements of the standard selected in assessment (see 1.8.2 Standard of Pollutants Discharge), the discharge concentration of dioxins reaches the EU 2000 Standard (hereinafter referred to as EU Standard). Suzhou Qizishan Refuse Landfill Site and garbage incinerating power plant has become the only approach to dispose the domestic waste of Suzhou at present and in the future. In order to maximize the comprehensive utilization of resources, reduce environmental pollution, further promote the environmental bearing capacity of Suzhou, and realize the fast, sustainable and healthy development of Suzhou, Everbright Environmental Protection Energy (Suzhou) Co., Ltd. decides to invest RMB 750 million to establish Phase Extension Project, with the extension of “3×500t/d garbage incinerator + 2×15MW generator unit”, under the substantial support of local government department.

2 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited In accordance with relevant regulations, such as Law of the Peoples Republic of China on Assessment of Environmental Effects and Environmental Protection Management Measures for Construction Project, Institute of Environmental Science of the Ministry of Environmental Protection had accepted the delegation of Everbright Environmental Protection Energy (Suzhou) Co., Ltd. in March, 2011 to take charge of the environmental impact assessment of the Phase Extension Project of the Domestic Waste Waste-to-Energy project of the company, as well as the formulation of the environmental impact report of the project. After accepting the entrustment, the assessment unit had formulated the environmental impact assessment of the project and submitted it for approval, based on field investigation, collection of basic data and preliminary analysis of engineering pollution discharge condition.

1.2 Basis of Compilation

1.2.1 National Laws and Regulations 1Environment Protection Law of the People’s Republic of China, December 26, 1989; 2Law on the Prevention of Air Pollution of People's Republic of China, revised on April 29, 2000; 3Law of the People's Republic of China on Prevention and Control of Water Pollution, June 1, 2008; 4Law of the People's Republic of China on Prevention and Control of Pollution from Environmental Noise, revised on October 29, 1996; 5Law of the People's Republic of China on the Prevention and Control of Environmental Pollution by Solid Wastes , revised on December 29, 2004 6Law of the Peoples Republic of China on Assessment of Environmental Effects, September 1, 2003; 7Energy Conservation Law of the People’s Republic of China, January 1, 1998; 8Law of the People's Republic of China on Renewable Energy, January 1, 2006; 9Cleaner Production Promotion Law of the People's Republic of China,

3 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited January 1, 2003; 10 Decision of the State Council on Several Issues Concerning Environmental Protection, State Development No. (96) 31; 11Regulations on the Administration of Construction Project Environmental Protection, the State Council Decree No. 253 in 1998; 12Circular of Opinions on Enhancing Industrial Water Conservation, State Economic and Trade Resource (2000) Decree No. 1015 of State Economic and Trade Commission; 13Decision on Implementing the Scientific Concept of Development and Stepping up Environmental Protection by the State Council, State Development [2005] No. 39; 14“The Eleventh Five-Year Plan” National Environment Conservation Laws and Regulations Construction Plan, Environmental Development [2005] No. 131; 15Instructional Advice of State Environment Protection Administration on Promoting Circular Economy, Environmental Development [2005] No. 114; 16 Classification Catalogue for Environment Impact Assessment of Construction Project, Ministry of Environmental Protection Decree No. 2, September 2, 2008; 17Circular of Enhancing Environment Impact Assessment Management and Preventing Environmental Risk, State Environmental Protection Administration Environmental Development [2005] No. 152; 18Circular of National Development and Reform Commission on the issuance of Relevant Management Rules on Renewable Energy Generation, National Development and Reform Commission Development and Reform Energy [2006] No. 13; 19The Notice about Speeding up Electric Power Industry Adjustment and Help it Develop Healthily and Orderly, National Development and Reform Commission Development and Reform Energy [2006] No. 661; 20 Interim Provisions for Environment Impact Assessment Public Participation, State Environmental Protection Administration Environmental Development [2006] No. 28; 21Circular of State Environmental Protection Administration on Work for

4 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Reporting the Total Emission of Major Pollutants, Environmental Development [2006] No. 98; 22 Circular of State Environmental Protection Administration, State Economic and Trade Commission, Ministry of Science and Technology on Hazardous Waste Disposal Policy, Environmental Development [2001] No. 199; 23Technological Policy for Treatment of Municipal Solid Wastes and Its Pollution Prevention, Ministry of Construction, Ministry of Science and Technology, State Environmental Protection Administration, Jian Cheng [2000] No. 120; 24National Dangerous Wastes Catalogue, Ministry of Environmental Protection of the People’s Republic of China, National Development and Reform Commission of the People’s Republic of China Decree No. 1, June 6, 2008; 25 Measures for Administration of Hazardous Waste Manifest, State Environmental Protection Administration, October 1, 1999; 26Provisions for Documents of Classification and Approval on Environment Impact Assessment of Construction Project, Ministry of Environmental Protection of the People’s Republic of China Decree No. 5, January 16, 2009; 27Rules on Further Strengthening Industrial Policy and Credit Policy to Coordinate and Control Credit Risks, National Development and Reform Commission Development and Reform Industry [2004] No. 46; 28Guideline Catalogue for Industrial Restructuring (2011 version); 29 Circular of State Environmental Protection Administration on the Issuance of Guidelines on Total Amount Distribution of Sulfur Dioxide (Environmental Development [2006] No. 182); 30 Official Reply of the State Council on the Control Plan of the Total Emission of National Main Pollutants During the “Eleventh Five-Year Plan”, and its Annex Control Plan of the Total Emission of National Main Pollutants During the “Eleventh Five-Year Plan”, the State Council Guo Han [2006] No. 70; 31 Circular on Further Strengthening Environment Impact Assessment Management of Biomass Waste-to-Energy Projects, Ministry of Environmental Protection, Development and Reform Commission, Bureau of Energy, Environmental Development [2008] No. 82, September 4, 2008; 32Town Appearance Sanitation Regulations, the State Council Decree No.

5 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 101, June, 1992; 33 Administrative Measures for Urban Living Garbage, Ministry of Construction Decree No. 27, August, 1993; 34 State Planning Commission, Ministry of Construction, State Environmental Protection Administration, Ji Investment [2002] No. 1591, Circular on Boosting the Industrialization Development of Urban Sewage and Garbage; 35National Development and Reform Committee, etc. Development and Reform Huan Zi [2004] No. 73, Circular on the Issuance of List of Resources for Comprehensive Use (2003 Revision); 36 Control over Licensing for the Discharge of Key Pollutants in and Taihu Lake Basin (Trial Implementation), State Environmental Protection Administration, October 1, 2001; 37General Office of the State Council Transmitted the Circular of Ministry of Environmental Protection on the Guideline of Promoting Air Pollution Joint Prevention and Control and Improving Regional Air Quality (State Office Transmit [2010] No. 33).

1.2.2 Local Policy, Laws and Regulations (1) Environmental Air Quality Functional Regionalization of Jiangsu Province; (2) Classification of Surface Water Function Category of Jiangsu Province; (3) Jiangsu Environmental Protection Act, implemented on August 16, 1997; (4) Interim Provisions on the Control of Total Amount of Discharged Pollutants of Jiangsu Province (1993 Provincial Government Decree No. 38); (5) Several Stipulations Concerning Sewage Outlet Setting and Standardized Management (Jiangsu Environment Control [1997] No. 122); (6) Circular of Doing Good Job in the Environmental Management of Construction Project (Jiangsu Environment Management [2006] No. 98); (7) Guidance Catalogue for Industrial Structure Adjustment of Jiangsu Province (Jiangsu Government Issue [2006] No. 140); (8) Policies and Measures of Jiangsu Province on Promoting Environmental Protection (Jiangsu Government Issue [2006] No. 92), July, 2006; (9) Jiangsu Province Noise Pollution Control Regulations, The Standing Committee of the Tenth People's Congress of Jiangsu Province, No. 108,

6 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited implemented on March 1, 2006; (10) Circular of Provincial Government on Policies and Measures Concerning Promoting the Construction of Conservation-minded Society, Jiangsu Government Issue [2006] No. 60, May 4, 2006; (11) Circular of Provincial Government on Opinions Concerning the Implementation of Energy Conservation and Emission Reduction of Jiangsu Province, Jiangsu Government Issue [2007] No. 63; (12) Circular of the Issuance of the Standard of Formulating the Content of Recycle Economy in Regional Development and Environmental Impact Assessment of Construction Project (Trial Implementation), Jiangsu Environmental Protection Department, February, 2004 (Jiangsu Environment Control [2005] No. 50); (13) Circular of Provincial Government on Implementation Plan of Water Environmental Comprehensive Control in Taihu Lake Basin of Jiangsu Province, (Jiangsu Government Issue [2009] No. 36); (14) Circular of Provincial Government Office on the Issuance of Jiangsu “the Eleventh Five-Year Plan” Document of Responsibility on Reducing Total Amount of Water Pollutants (Jiangsu Government Issue [2007] No. 97); (15) Taihu Lake Water Pollution Prevention and Control Regulations of Jiangsu Province, revised in 2007; (16) Guidance Catalogue for Suzhou Industrial Development, Jiangsu Government [2007] No. 129; (17) Circular of Municipal Government Office Transmitted the Working Points of Water Pollution Prevention and Control Taihu Lake Basin of Suzhou in 2010,Jiangsu Government Office [2010] No. 112; (18) Circular of Issuing the Implementation Opinions on Further Strengthening the Implementation of Emission Reduction of Main Pollutants, Jiangsu Government [2007] No. 148; (19) Circular of Issuing the Review Management Measures of Regional Balance Plan of the Total Discharge Amount of Main Pollutants of Construction Project in Jiangsu Province, (Jiangsu Environment Office [2011] No. 71); (20) Circular of Further Normalizing Public Participation and Hearing System in Environmental Assessment of Planning and Construction, (Jiangsu Environment Office [2011] No. 173); (21) Solid Waste Pollution Control Regulations of Jiangsu Province (2010).

7 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

1.2.3 Local Plans and Data of the Project Site (1) Suzhou Urban Master Plan (2007-2020); (2) Eleventh Five-Year Planning on Environmental Protection of Suzhou; (3) Professional Plan of Suzhou on Environmental Hygiene (2006-2020); (4) Master Plan of Mudu Town in Wu County; (5) Environmental Protection Plan of Mudu Town in Wu County.

1.2.4 Technical Basis (1) Technical Guidelines for Environmental Impact Assessment-General Principles (HJ/T2.1-93); (2) Technical Guidelines for Environmental Impact Assessment- Atmospheric Environment (HJ2.2-2008); (3) Technical Guidelines for Environmental Impact Assessment- Surface Water Environment (HJ/T2.3-93); (4) Technical Guidelines for Noise Assessment (HJ2.4-2009); (5) Technical Guidelines for Environmental Impact Assessment- Groundwater Environment (HJ610-2011); (6) Technical Guidelines for Environmental Risk Assessment on Projects (HJ/T169-2004); (7) Provisions of Jiangsu Province on Standardization Formulation of Main Content of Environmental Impact Report of Construction Projects (Trial Implementation); (8) Industrial Standard of People's Republic of China Technical Code for Projects of Municipal Household Garbage Incineration (CJJ90-2009), Ministry of Construction, September 1, 2002; (9) Industrial Standard for Environment Protection of People's Republic of China Specification for Formulating Environmental Impact Statement of Thermal Power Plant Construction Project (HJ/T13-1996, issued by State Environmental Protection Administration, Ministry of Power Industry); (10) Standard for Pollution Control on the Household Garbage Incineration (GB18485-2001); (11) Standard for Pollution Control on the Landfill Site of Household Garbage

8 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited (GB16889-2008); (12) Standard for Pollution Control on Hazardous Waste Storage (GB18597-2001).

1.2.5 Documents and Replies Relating to the Project (1) Power of Attorney for Environmental Assessment; (2) Circular of Provincial Development and Reform Committee on Implementing Preliminary Work of Phase Extension Project of Suzhou Domestic Waste Waste-to-Energy Project, Su Development and Reform Investment Fa [2011] No. 240; (3) Advisory opinions on environmental Assessment of construction project, Advisory [2011] No. 40; (4) Application Report of the Project.

1.3 Assessment Purposes and Working Principles

1.3.1 Assessment Purposes It is required to analyze the impact degree and range on surrounding environment according to the main pollutants discharged by the project, argue the environmental feasibility of engineering construction and advancement and rationality of environment protection safety measures on technology and economy, and further put forward measures and suggestions for preventing, controlling and reducing pollution, so as to provide basis for the design of environment protection facilities and environmental management.

1.3.2 Working Principles 1. According to the “3R Principle” of reduction, reuse and recycle, it is required to realize the recycle of resources across industries, promote resource utilization, comprehensively utilize waste, safety disposal, aiming for promoting the coordination of society, economy and ecology environment. 2. It is required to stick on the principle of “cleaner production”, “standard discharge” and “control on the total amount of pollutants” according to the rules of Regulations on the Administration of Construction Project Environmental Protection, and strengthen the assessment content of cleaner production technology and

9 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited environmental protection control countermeasures. 3. It is required to conscientiously implement national regulations and policies, analyze and assess the planning consistency of the project, rationality of engineering and pollution prevention and control, feasibility of site selection. 4. It is also required to do engineering analysis well, analyze the impact degree and range of the project on environment through environmental impact forecasting by combining the environmental characteristics of the geographical position of the proposed project, put forward feasible environmental protection measures, minimize the discharge amount of pollutants, and work out real and reliable assessment conclusion, so as to provide basis for environmental protection control and environmental management.

1.4 Assessment Factors See Table 1.4-1 for the assessment factors of the project.

Table 1.4-1 Environmental Assessment Factors Current Condition Assessment Factors Impacted Assessment Total Amount Item Factors (Analysis) Control Factors

Dust, SO2, NO2, HCl, SO2, NO2, PM10, NH3, H2S, HCl, HCl, HF, PM10, SO2, NOx, CO, Atmosphere HF, CO, Cd, Pb, Hg, fluoride, CO, Pb, Cd, dioxin Cd, Pb, Hg, dioxins, NH3, H2S dioxins Surface pH, COD, DO, ammonia nitrogen, - - Water SS, total phosphorus, oil type pH, permanganate index, ammonia nitrogen, Cr6+, Cd, Hg, Pb, total Groundwater - - escherichia coli, nitrite nitrogen, fluoride, total hardness

Noise Equivalent sound level Ld(A) - pH, cadmium, mercury, arsenic,

Soil copper, lead, chromium, zinc, nickel, - - dioxin

Ecology Plant, farmland ecology - Discharge amount of Solid Wastes Output, utilization amount, disposal amount of industrial solid wastes industrial solid wastes

10 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 1.5 Assessment Grade

1.5.1 Assessment Grade of Environment and Air According to the analysis results of preliminary engineering, the main

atmosphere pollutants of the project include NOx, SO2, HCl, etc. In accordance with the requirements of Technical Guidelines for Environmental Impact Assessment- Atmospheric Environment (HJ2.2-2008), it is required to choose estimation pattern to classify the atmospheric environment assessment of the project, individually calculate

the standard rate of maximum ground level concentration Pi for all pollutants, the

longest distance D10% corresponding to that when ground level concentration reaches 10% of standard limit value, see Table 1.5-1 for the calculation results of main pollutants. The results are calculated according to the estimation pattern. Pmax, fly ash

solidification in-organization, is 20.16%; the biggest D10% appears at 803.66m. According to assessment grading criteria (Table 1.5-2), the assessment grade of this project is Level . It is stipulated in Technical Guidelines for Environmental Impact Assessment- Atmospheric Environment (HJ2.2-2008) that “it shall be not less than Level for the special items with its discharged pollutant having serious hazard to human health or ecological environment”. Therefore, the atmosphere assessment grade of this project is defined as Level . To assess the impacts of the project on Mudu Town, the assessment range takes the range with the center of project exhaust funnel and the radius of 3 km.

Table 1.5-1 Calculation Result Sheet of Estimation Pattern Maximum Appearance Standard Rate Concentration Distance of Assessment of Maximum Recommended Pollution Pollutant of Downwind Maximum Standard Ground D10% [m] Assessment Source Direction Concentration [ug/m3] Concentration Grade [ug/m3] [m] [%]

Dust 1.43 1,000.0 450.00 .32

SO2 1.43 1,000.0 500.00 .29

NO2 23.11 1,005.0 240.00 9.63 Incinerator HCl 0.73 1,005.0 50.00 1.46 HF 0.14 1,000.0 20.00 .70 Pb 0.07 1,005.0 10.70 .66 Hg 0.01 1,005.0 .90 .78

11 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Cd 0.01 1,005.0 10.00 .07 Dioxin 0.00 1,000.0 .00 .29 Ammonia Refuse Chute 5.24 123.0 200.00 2.62 H2S 0.61 123.0 10.00 6.07 Fly Ash pm10 90.73 96.0 450.00 20.16 803.66 Solidification

Table 1.5-2 Assessment Grade Assessment Grade Criterion of Assessment Grade Level Pmax ≥ 80%, and D10% ≥ 5km Level Others

Pmax < 10%, or D10% < the closest distance of pollution source Level from boundary of factory

1.5.2 Surface Water Environment Assessment Grade With respect to industrial waste water recycling, only the pipe of domestic sewage is connected to new sewage treatment plant. According to the relevant provisions of Technical Guidelines for Environmental Impact Assessment (Surface Water) (HJ/T2.3-93), the water assessment grade is brief analysis.

1.5.3 Noise Assessment Grade The quality standard for noise of the region where the project is located implements the Level standard of Environmental Quality Standard for Noise (GB3096-2008). Through forecasting, the added value of the noise at the boundary of the factory is less than 3dB (A), thus the quality standard for noise of the project is defined as Level , according to the requirements of Technical Guidelines for Environmental Impact Assessment (HJ2.4-2009).

1.5.4 Groundwater Environment Assessment Grade The construction project belongs to I project that may cause pollution to groundwater. According to Technical Guidelines for Environmental Impact Assessment HJ610-2011, it is required to make sure the assessment and range of groundwater by selecting aeration zone antifouling property, vulnerable water-bearing bed, sensitivity of groundwater environment, sewage quantity and complexity of

12 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited sewage quality. In accordance with Table 6 and Table 12 of Technical Guidelines for Environmental Impact Assessment HJ610-2011, the groundwater environmental impact grade of this project is Level and the assessment range is the round area with the project as the center and the radius of 6km. The assessment indicator and assessment standard of all items are showed in the following tables:

Table 1.5-3 Aeration Zone Antifouling Property Grade Grade Penetrability of aeration zone rock (soil) The thickness of single rock (soil) bed of Mb ≥ 1.0m, coefficient of permeability of k Strong 10-7cm/s, continuous and stable distribution The thickness of single rock (soil) bed of 0.5mMb1.0m, coefficient of permeability of k10-7cm/s, continuous and stable distribution Middle The thickness of single rock (soil) bed of Mb≥1.0m, coefficient of permeability of 10-7cm/sk10-4cm/s, continuous and stable distribution Weak Rock and soil bed fail to meet the conditions of the above “strong” or “middle” Note: The “rock (soil) bed” refers to the first rock (soil) bed under the underground base of the construction project; the coefficient of permeability of aeration zone rock (soil) bed refers to the coefficient of permeability of aeration zone rock soil when it is saturated.

Table 1.5-4 Grade of Vulnerable Water-bearing Bed of Construction Project Grade Position of the project site and vulnerable water-bearing bed property The area with strong coefficient of permeability of unconfined aquifer and aeration zone rock property (for instance, sand and gravel); area that has close relationship with Easy groundwater and surface water; area that goes against dilution and self-purification of pollutant in groundwater Area with multiple water-bearing bed system and close relationship of water power Middle between beds Difficult Other areas beyond the above situation

Table 1.5-5 Sensitivity of Groundwater Environment Grade Groundwater environment property of the project site Quasi conservation area of centralized model drinking water source field (including the Sensitive built water source field under operation, for backup or emergence, as well as water source

13 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited field under construction and planning); other conservation areas relating to groundwater set by national or local government beyond centralized model drinking water source field, like special groundwater resource conservation area such as hot water, mineral water and warm spring Supply runoff area beyond quasi conservation area of centralized model drinking water source field (including the built water source field under operation, for backup or More emergence, as well as water source field under construction and planning); distribution Sensitive area beyond special groundwater resource (for instance, mineral water, warm spring, etc.) conservation area, as well as the environmental sensitivity areas that are not listed in the above sensitivity grade Insensitive Other areas beyond the above areas Note: 1. The “environmental sensitivity area” in the table refers to the environmental sensitivity area relating to groundwater defined in Classification Catalogue for Environment Impact Assessment of Construction Project. 2. in case the water-bearing bed (water-bearing system) is located at the boundary of supply area or runoff area and discharge area; the sensitivity grade shall be upgrade by one level.

Table 1.5-6 Sewage Quantity Grand Grade Total Amount of Sewage Discharge (m3/d)

Large 10,000 Middle 1,000~10,000 Small 1,000

Table 1.5-7 Complexity of Sewage Quality Complexity of Sewage Type of Pollutant Sewage Quality Indicator Quality Grade Quality Indicator That Needs Predict Complex Type of Pollutant2 6 Quality Indicator That Needs Type of Pollutant2 Predict<6 Middle Quality Indicator That Needs Predict Type of Pollutant=1 6 Quality Indicator That Needs Simple Type of Pollutant=1 Predict<6 In accordance with the engineering investigation report and hydrogeology survey of the area where the project is located, the indicator assessment results of the project

14 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited are showed in Table 1.5-8.

Table 1.5-8 Single Indicator Assessment Grade Table Aeration Zone Vulnerable Sensitivity of Assessment Sewage Complexity of Antifouling Water-bearing Groundwater Indicator Quantity Sewage Quality Property Bed Environment Bed rock (the thickness of single rock (soil) bed of Mb≥1.0m, Other areas Other areas Type of pollutant Assessment coefficient of beyond the 2, quality 600 beyond the indicator that Result permeability above 1,000 above areas needs predict of k situation 6 10-7cm/s, continuous and stable distribution) Assessment Strong Difficult Insensitive Small Complex Grade

1.5.5 Ecological Environmental Impact Assessment Grade Since this project has little impact range, ecological impact and change degree, the major ecological impacts are analyzed briefly.

1.5.6 Risk Assessment Grade This project is a domestic waste Waste-to-Energy project, which does not belong to toxic, combustible and explosive substances, with the risk assessment of Level , according to the judgment basis of assessment grade. Please see the section of risk assessment for details.

1.6 Assessment Range (1) Assessment Range of Air It is a circle range with the funnel of the proposed site of the project as center and a radius of 3km.

15 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited The analysis range of garbage repository in-organization stinky impact covers an area within 500m of garbage repository. (2) Assessment Range of Surface Water It covers an area within 10km of the upstream and downstream of outlet of sewage treatment plant in new area. (3) Assessment Range of Noise It covers an area within 200m of and beyond the proposed project plant. (4) Assessment Range of Groundwater It is a circle region with the project as center and a radius of 6km. (5) Assessment Range of Ecological Environment It covers an area within 200m of and beyond the proposed project plant. (6) Assessment Range of Risk It covers an area within 3km from risk source.

1.7 Object of Environment Sensitivity Protection See Table1.7-1 Table 1.7-3, Figure1.7-1 Figure 1.7-2 for object of environment sensitivity protection and see Figure 4.3-1 for the overview of surrounding environment of the project. No garbage transportation line is added in this extension project. Most of the existing transportation roads are the main roads of the city, not going through concentration residential district.

Table 1.7-1 Object of Environmental Protection Environmental Name of Environmental Environment Position Distance (m) Scale Remarks Factor Protection Object Function Mudu Town (Ancient 200,000 WNW 2,600-6,300 Town Area) people 3,600 Original Gusu Village W 2,000 household Air 20 Level of Qizi District of Gusu Now they N 1,200 Environment Village household GB3095-1996 are merged 3,100 Fenghuang District of as Gusu SW 1,650 Gusu Village household Village 7,500 Suzhou University of E 2,300 Science and Technology people

16 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Environmental Name of Environmental Environment Position Distance (m) Scale Remarks Factor Protection Object Function

Renji Nursing Home N 750 20 beds Shangfangshan Forest 2 SE 1,600 5.002 km Park Class of Noise Boundary of Factory — — — GB3096-93 Class of Xujiang River N 1,500 — Surface Water GB3838-2002 Jiangnan Canal NE 5,000 — Class

Table 1.7-2 Object List of Important Ecological Environmental Protection S.N. Name Leading Ecological Function Mudu Landscape and Famous Protection of Natural and Humanistic 1 Scenery Landscape Qizishan Ecological Public Water Conservation and Protection of 2 Welfare Forest Biological Diversity

Table 1.7-3 Object List of Water Environmental Protection along Garbage Transportation Line Number Protection Object Scale Function Industrial Water, Agricultural 1 Jiangnan Canal Medium-sized Water, Class Industrial Water, Agricultural 2 Xujiang River Medium-sized Water, Class

1.8 Assessment Standard

1.8.1 Environment Quality Standard (1) Ambient air quality standard It is required to execute the Level standard and its modification list of

Ambient Air Quality Standard (GB3095-96) for SO2, NO2, TSP, PM10, CO, fluoride and Pb; the “maximum allowed concentration of harmful materials in the air of residual district” of Hygienic Standards for the Design of Industrial Enterprises

(TJ36-79) shall be executed for such special pollution factors as HCl, NH3, H2S and Hg; the environment standard of former Yugoslavia shall be referred to for Cd; the

17 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited environment standard of Japan shall be referred to for the dioxin in the air. See Table 1.8-1 and table 1.8-2 for its standards.

Table 1.8-1 Ambient Air Quality Standard Limit Value of Time of Value Pollutant Concentration Standard Source Taking (mg/m3)

Annual Average 0.06 SO 2 Daily Average 0.15 Hour Average 0.50 Annual Average 0.10 PM10 Daily Average 0.15 Annual Average TSP 0.20 Daily Average 0.30 Annual Average 0.08 NO2 Level Standard of Ambient Daily Average 0.12 Air Quality Standard Hour Average 0.24 (GB3095-1996) Daily Average CO 4 Hour Average 10 Daily Average 3 Fluoride 7μg/m Hour Average 20μg/m3 Annual Average 1.0μg/m3 Pb Seasonal Average 1.5μg/m3 Daily Average* 3.5μg/m3 Hour Average * 10.7μg/m3 Daily Average Hg 0.0003 Hour Average* 0.0009 Hygienic Standards for the NH3 Once 0.20 Design of Industrial Enterprises H2S Once 0.01 (TJ36-79) Once HCl 0.05 Daily Average 0.015 Once Cd 0.01 Standard of Yugoslavia Daily Average 0.003 Annual Average 0.6pg/m3 Environment Standard Daily Average* 1.65pg/m3 formulated by Central Dioxins Environmental Commission of Once* 5pg/m3 Japan EPA * The standard for the hour average concentration of Pb, Hg and dioxins shall be calculated by the proportion of once sampling daily average, seasonal average and annual average of 10.330.140.12, the once concentration standard for Pb, Hg and dioxins shall be taken as 0.0107mg/m3, 0.0009mg/m3 and 5pg/m3.

18 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 1.8-2 Limit Value for the Concentration of Sulfur Dioxide and Fluoride for Protecting Corps Seasonal Daily Any Sensitivity Average Pollutant Average One Type of Corps of Corps Concentration Concentration Time Growth Winter wheat, spring wheat, barley, buckwheat, soybean, sugar beet, sesame, rape, green Sensitive 0.05 0.15 0.50 vegetable, Chinese cabbage, lettuce, cucumber, Corps pumpkin, courgette, potato, apple, pear, grape, Sulfur alfalfa, clover, cocksfoot and ryegrass Dioxide Rice, corn, oat, sorghum, cotton, tobacco, mg/m3 Medium Sensitive 0.08 0.25 0.70 tomato, eggplant, carrot, peach, apricot, plum, Corps orange and cherry Broad bean, rape, sunflower, cabbage, taro, Resistant 0.12 0.30 0.80 Corps strawberry Winter wheat, peanut, cabbage, pea bean, apple, Sensitive pear, peach, apricot, plum, grape, strawberry, 1.0 5.0 Corps cherry, white mulberry, alfalfa, ryegrass and cocksfoot Fluoride Barley, rice, corn, sorghum, soybean, Chinese μg/dm2.d Medium Sensitive 2.0 10.0 cabbage, leaf mustard, cauliflower, orange and Corps clover Sunflower, cotton, tea, fennel, tomato, eggplant, Resistant 4.5 15.0 Corps hot pepper and potato Maximum Allowable Concentration of Pollutants in Atmosphere for Protection Crops Basis GB9137-1988 Level

(2) According to Jiangsu Surface Water (Environment) Function Regionalization, among the relevant river channel, water body near the engineering, XuJiang River (from Mudu ship lock to Jiangnan Canal) belongs to Class water body, Jiangnan Canal (Suzhou) belongs to Class water body, and the and standards in Table 1 of Environmental Quality Standards for Surface Water (GB3838—2002).

19 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Table 1.8-3 Environmental Quality Standards for Surface Water Unit: mg/L Item Class Standard Class IV Standard Basis

pH 6~9 DO ≥5 ≥3 COD ≤20 ≤30 Permanganate ≤6 ≤10 Index Table 1 of Environmental Quality Standards for Surface Water BOD 5 ≤4 ≤6 (GB3838—2002) Ammonia

Nitrogen ≤1.0 ≤1.5

Total Phosphorus ≤0.2 ≤0.3 Petroleum ≤0.05 ≤0.5 Table 2 of Environmental Quality Chloride ≤250 Standards for Surface Water (GB3838—2002)

※ Level and Level of SS ≤30 ≤60 Environmental Quality Standards for Surface Water Resources (SL63-94)

(3) The Class 3 standard of Environmental Quality Standard for Noise (GB3096-2008) shall be executed for noise.

Table1.8-4 Environmental Quality Standard for Noise Unit: dB (A) Type Daytime Nighttime

Class 3 Region 65 55 Basis Environmental Quality Standard for Noise (GB3096-2008)

(4) The Class standard of Quality Standard for Ground Water (GB/T14848-93) shall be executed for groundwater.

Table 1.8-5 Quality Standards for Ground Water Unit: mg/L (Exclusive of pH) Permanganate Total Ammonia Hexavalent Total Item pH Index Hardness Nitrogen Chromium Cadmium Class 6.5~8.5 3.0 450 0.2 0.05 0.01 Standard Value Item Mercury Lead Total Nitrite Fluoride Chloride

20 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Permanganate Total Ammonia Hexavalent Total Item pH Index Hardness Nitrogen Chromium Cadmium Escherichia Nitrogen Coli Class 0.001 0.05 3.0 0.02 1.0 250 Standard Value Basis Quality Standard for Ground Water (GB/T14848-93)

(5) The Class standard of Environmental Quality Standard for Soils (GB15618-1995) shall be executed for soil.

Table 1.8-6 Environmental Quality Standards for Soils Unit: mg/kg (Exclusive of pH) Arsenic Chromium Copper pH Value Cadmium Mercury (Paddy Lead Nickel (Paddy Zinc (Farmland) Field) Field)

<6.5 0.3 0.3 30 250 40 250 200 50 6.5-7.5 0.3 0.5 25 300 50 300 250 100 >7.5 0.6 1.0 20 350 60 350 300 100 Basis Class Standard of Environmental Quality Standard for Soils (GB15618-1995)

1.8.2 Pollutant Discharge Standard (1) Waste Gas Technical Indicator for Index Table 1 standard of Standard for Pollution Control on the household garbage Incineration (GB18485-2001) shall be executed for technical indicator for index. See Table 1.8-7 for specific index. Table 1.8-7 Technical Performance Index for Incinerator Heat Scorching Temperature of Smoke Residence Oxygen Content of Smoke at Item Reduction Rate of Incinerator ℃ Times the Outlet of Incinerator % Incinerator Slag % ≥850 ≥2 Index 6-12 ≤5 ≥1,000 ≥1

Technical Requirements for Chimney of Incinerator

21 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited The height of the chimney of incinerator shall be determined according to the requirements of environmental impact assessment, but not lower than the height stipulated in Table 1.8-8. The total capacity of daily garbage incineration of single incinerator is 500t and the height of chimney is 80m, which meet the requirements of standard.

Table 1.8-8 Requirements for the Height of Chimney of Incinerator

Treatment Quantity (t/d) <100 100~300 >300 Minimum Allowed Height of 25 40 60 Chimney (m) Note: In case there are several garbage incinerators simultaneously in a factory, the total treatment quantity of all incinerators shall be the assessment basis. In case there are buildings within a radius of 200m around the chimney of incinerator, the height of chimney shall be higher than the highest building by more than 3m. For the chimney that fails to reach the requirement, its limit value of air pollutant discharge shall be executed by the 50% stricter than the limit value stipulated in Table 2.5.3-2. For the domestic waste incineration plant composed by several incinerators, the smoke shall be concentrated to a chimney to discharge or applied by multi-tube concentration discharge. The chimney or gas flue of incinerator shall be set permanent sampling hole and installed with sampling monitoring platform according to the requirements of GB/T16157-1996.

Air Pollutant Discharge Standard In accordance with the environment assessment and reply of Phase engineering, the pollutant of domestic waste incineration smoke shall execute the requirements of EU 92 Standard on the basis of meeting Standard for Pollution Control on the Household Garbage Incineration (GB18485-2001), and CO and dioxin shall refer to EU 2000 Standard (DIRECTIVE 2000/76/EC), see the black part of Table 1.8-9. The discharge of odor pollutants at the boundary of factory shall execute the Level standard of newly built extension project in the boundary standard value of odor pollutant of Emission Standards for Odor Pollutants (GB1455493), see Table 1.8-10.

22 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 1.8-9 Air Pollutant Discharge Standards for Domestic Waste Incineration Meaning of Meaning of EU 2000 S.N. Pollutant Number GB18485-2001 Number EU 92 mg/m3 mg/m3 mg/m3 Value Value Blackness Measured Ringelmann Measured Ringelmann Ringelmann 1 of Gas Value Level 1 Value Level 1 Level 1 Average Smoke Average 2 Measured 50 Measured 30 10 Dust Value Value Average Average Day 3 SO2 260 300 50 Hour Value Value Average Average Day 4 NOx 400 / 200 Hour Value Value Average Average Day 5 CO 150 100 50 Hour Value Value Average Average Day 6 HCl 75 50 10 Hour Value Value Average Average

7 Hg Measured 0.2 Measured 0.1 0.05 Value Value Average Average

8 Cd Measured 0.1 Measured 0.1 0.05 Value Value Average Average

9 Pb Measured 1.6 Measured / 0.5 Value Value Average Average

10 dioxins Measured 1TEQng/m3 Measured 0.1TEQng/m3 0.1TEQng/m3 Value Value Average Average

11 HF Measured / Measured 2 1 Value Value

Table 1.8-10 Factory Boundary Standard Value of Odor Pollutants S.N. Pollutant Limit Value of Concentration, mg/m3

23 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited S.N. Pollutant Limit Value of Concentration, mg/m3

1 NH3 1.5 2 H2S 0.06 3 Odor Concentration 20 (Non-dimensional)

(2) Waste Water A small amount of garbage leachate of this engineering spray back to incinerator, the rest shall be used to recycle cooling water after pre-treatment by supporting leachate treatment plant and reaching the standard of water supply for open recycling cooling water of The Reuse of Urban Recycling Water--Water Quality Standard for Industrial Uses (GB/T19923-2005). See Table 1.8-11 for the standard of reuse water.

Table 1.8-11 Limit Value of Industrial Reuse Water Standard Value (Unit: mg/L, pH Name of Pollutant Standard Source non-dimensional)

pH 6.5-8.5 COD ≤60 BOD ≤10 Water supply for open recycling cooling water of The Chlorine ion ≤250 Reuse of Urban Recycling Ammonia Nitrogen Water--Water Quality Standard for Industrial Uses (Calculated by N) ≤10 (GB/T19923-2005) Total Phosphorus

(Calculated by P) ≤1

The domestic sewage is taken over by Suzhou New District Sewage Treatment Plant, executing the Class standard of Integrated Wastewater Discharge Standard GB8978-1996. The discharge of sewage plant shall execute Discharge Standard of Main Water Pollutants for Municipal Wastewater Treatment Plant & Key Industries of Taihu Area (DB32/T1072-2007), and Class(A) standard of Discharge Standard of Pollutants for Municipal Wastewater Treatment Plant (GB18918-2002). See Table 1.8-12 for standards.

Table 1.8-12 Limit Value of Takeover and Discharge Standard for Waste Water Pollutant

24 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Standard Value (Unit: mg/L Name of pH non--dimensional) Standard Source Pollutant Takeover Standard Discharge Standard

pH 6~9 COD ≤500 50 BOD ≤300 10 Takeover standard: SS ≤400 10 Integrated Wastewater Discharge Standard Fluoride ≤20 / (GB8978-1996) Sulfide ≤1.0 1.0 Discharge standard of tail TAs 0.1 ≤0.5 water of sewage plant: THg ≤0.05 0.001 Discharge Standard of Main T Water Pollutants for Cd ≤0.1 0.01 Municipal Wastewater TPb ≤1.0 0.1 Treatment Plant & Key Industries of Taihu Area T Cu ≤2.0 0.5 (DB32/T1072-2007) and 6+ TCr/Cr ≤1.5/≤0.5 0.05 Class(A) standard of Ammonia Discharge Standard of Pollutants for Municipal ≤35 58 Nitrogen Wastewater Treatment Plant (GB18918-2002) Total Nitrogen / 15 Phosphate 0.5 (Calculated by P) ≤8

(3) Noise The noise of factory boundary shall execute the corresponding standard limit value in Emission Standard for Industrial Enterprises Noise at Boundary (GB12348-2008), see Table 1.8-13.

Table 1.8-13 Emission Standards for Industrial Enterprises Noise at Boundary Type Daytime (dB) Nighttime (dB) 3 65 55 Emission Standard for Industrial Enterprises Noise at Boundary Basin (GB12348-2008)

(4) Solid Waste General solid waste shall execute Standard for Pollution on the Storage and Disposal Site for General Solid Waste (GB18599-2001);

25 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Standard for Pollution Control on the Landfill Site of Municipal Solid Waste (GB16889-2008); Hazardous waste shall execute Standard for Pollution Control on Hazardous Waste Storage (GB18597-2001).

1.9 Process of Assessment See Figure 1.9-1 for assessment technical route.

26 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

AcceptanceAcceptance of of Engagement Engagement

Field Investigation Preliminary Engineering Analysis Data Collection

Investigation and Assessment of Current Environmental Situation Implementing Environment Assessment Natural and Social Natural and Social Current Situation Monitoring of Investigation

Determination of Engineering Analysis Analysis of Cleaner Production Protection Object

Environment Impact Forecast and Assessment

Environment Impact Forecast and Assessment during Production Period Environment Impact Forecast and Assessment during Construction Period

Environmental Impact Environmental Assessment for Other Risk Analysis Assessment for Ambient Impact Assessment Environmental Factors, Assessment Air for Water such as Noise and Solid Waste

Assessment for Pollution Prevention and Control Measures

Compliance Analysis of Industrial Policy

Feasibility Analysis of Project Site Selection Comprehensive Analysis

Control of Total Amount of Pollutant

Compiling Environment Impact Report Environmental Economic Cost-benefit Analysis

Public Participation Review and Modification of Report

Environment Monitoring and Management Plan

Figure 1.9-1 Flow Diagram of Environment Impact Assessment

27 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 2 Environment Overview

2.1 Overview of Natural Environment

2.1.1 Geographical Position Everbright Environmental Protection Energy (Suzhou) Co., Ltd. is located at the south to Qizi village, Wuzhong District, Suzhou, 3# and 4# cols at the north side of Qizishan Mountain, with the geographic coordinates of 120°31′E and 31°15′N, under the jurisdiction of Mudu Town, Wuzhong District, Suzhou. The site of the factory is located at the south of Qizishan Mountain, 1.5 km north to Qizi village, 2km from Xujiang River, 2.4 km from Sufu Road, 5.5 km from Mudu town, about 13 km from Suzhou City, with convenient transportation. See Figure 2.1-1 for the geographical position of the factory.

2.1.2 Geologic, Topographic and Morphologic Features

2.1.2.1 Geologic, Topographic and Morphologic Features of Suzhou Suzhou is located at the composite part of Neocathaysian second giant uplift zone and the east extension of Qinling mountains transmeridional complex structure zone, with a complex structure. The fold formed by Indosinian movement is dismemberented severely, destroyed by the fault block and magmatism of later period. The structural patterns of the area include Cathaysian structure, East-west structure, North-west structure, Nappe structure, Neocathaysian structure and arcuate structure. The geological structure of Suzhou is formed in Proterozoic Era, belongs to south China platform, composed by limestone, sandstone and quartzite. Most of the surface is piled by the loose deposit layer of Cenozoic Quaternary, with the thickness of several hundred meters generally. The urban area of Suzhou is alluvial plain, the previous Quaternary stratum is underdeveloped, and the widely distributed stratum is Maoshan Group and Wutong Formation quartz sandstone and sandshale. The deposit conditions of eastern plain and quaternary deposit of western bedrock intermountain depression are entirely different, and they belong to two deposit units. In the eastern plain, the Quaternary stratum is deeply covered, while that in the western plain is exposed to the surface.

28 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited The urban area of Suzhou is close to mountain and lake. The topography of its western part is high and flat and hills, such as Tianping Mountain, Lingyan Mountain, are located at the southwest of the suburban; the eastern part of the city is low, with lakes, such as Yangdeng Lake, and Zhantai Lake. The elevation of the town is 4.2~5.2m and that of outskirts is about 3.8m (the elevation of Wusong).

2.1.2.2 Geologic, Topographic and Morphologic Features of Site Area The site of the project is located as the deluvial layer in front of mountain at the east of Wanlv Mountain, with flat terrain. The lower stratum is Quaternary system silty clay, angular gravel; gravel interlayer and quartzite of Devonian system middle lower Maoshan Group. See the following table for the geological structure.

Stratum Features Gray yellow, yellow brown, plastic and stiff-plastic, angular Silty clay layer gravel and gravel are found in some parts, density, with the base Quaternary bearing force standard of 150~250kPa. strata Mixed color, angular, big and small ones, with the composites of Angular gravel, quartz sandstone and muddy siltstone, filled by silty soil, silty gravel layer clay, with the base bearing force standard of 200~300kPa. The upper part is intensive weathered layer, gray yellow, brick red, weathered into block, with the thickness of 1-4m; the lower quartz sandstone Devonian part is medium, slight weathered, gray yellow, gray white, fine Quartzite of system granted structure, middle thick structure, silicon shale middle lower stratum cementation, slity sandstone and mudstone are found in some Maoshan Group parts. The buried depth of roof of bedrock is between 5 to 15 meters. Comprehensive analysis assessment is done based on the Investigation Report on Suzhou Qizishan Landfill Site that there is no such adverse geologic phenomena as activity fault going through and landslip, and regional structure has no impact on the stability of the site of the factory.

2.1.2.3 Geological Overview of Fly Ash Landfill The existing engineering fly ash is transported to Everbright Environmental Protection (Suzhou) Solid Waste Disposal Co., Ltd. to be solidified and buried. “Suzhou Solid Waste Landfill Site” of Everbright Environmental Protection

29 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited (Suzhou) Solid Waste Disposal Co., Ltd. is the “Eleventh Five-Year Plan” pollution prevention and control project of Taihu Basin approved by the State Council, for which Suzhou municipal government have implemented public investment and approve it as the only Landfill site for solid hazardous waste in Suzhou. This hazardous solid waste Landfill site is located at the east of this project, at the 3# and 4# cols of the north side of Qizishan Mountain, and the site area belongs to hilly region, with the hilly mountain belonging to Qizishan Mountain. The mountain sweeps in a curve and the cross valley at the north side of its main peak develops, and 1# to 5# cols are parallel to each other in pinniform. The site is located at the southeastern wing of Mudu syncline, taking on the landform of being ringed on three sides by mountains and valleys in the middle, along the main peak of Qizishan Mountain at the south, extension mountain ridge at east and west sides, forming independent geographic and geomorphic unit. The area of catchment is about 0.6km2. The elevation of the main peak of Qizishan Mountain is 274.4m, the elevation of ridge lines at both sides range from 20 to 150m, and that of the bottom of trench is between 10 and 30m. The stratum of the site area is Devonian system middle lower Maoshan Group and Quaternary slide rock—slope deluvial stratum. The bedrock is composed by Devonian system middle lower Maoshan Group quartz sandstone and muddy slity sandstone. The upper part is covered by Quaternary slide rock-- slope deluvial deposit sediments with different thicknesses. Quaternary cover layer mainly distributes in col, as well as the mountain slope. The plain beyond the site is Quaternary alluvial layer.

2.1.3 Climatic Features Located at the middle of Taihu Lake water system in the southeast of Yangtze River Delta, Suzhou area belongs to northern subtropical monsoon climate, four seasons, sufficient heat, plentiful rainfall, hot rainy season and long frost free season. Commonly, spring is from March to May, summer is between June and August, autumn is from September to November, and winter is between December to next February, longer winter and summer and shorter spring and autumn. The annual average temperature is 15.7℃, with the highest temperature of 39.3℃ and the lowest temperature of -9.8℃. The average annual rainfall is 1,094mm, with the highest rainfall of 1,783mm and the lowest rainfall of 604mm, and the annual average rainfall

30 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited day is 130d, with the rainfall period concentrating from June to September, and the rainfall of June accounts for 15% of annual rainfall. The annual average foggy day is 25d, with the annual average sunshine duration of 1,996h, annual average evaporation capacity of 1,291mm annual average relative humidity of 80%. The annual average wind speed is 4.6m/s, the biggest wind speed in 30 years is 28m/s, and most wind directions are SE wind, followed by NNE; northwest wind is common in winter and southeast wind is common in summer. See Table 2.1-1 for main climatic features.

Table 2.1-1 List of Suzhou Year-round Climate Features Meteorological Elements Value Meteorological Elements Value Annual Average Annual Average 15.7 1094mm Temperature Rainfall Extremely ℃ Maximum Temperature Highest 39.3 Rainfall 1783mm Annual Rainfall Temperature Extremely ℃ Minimum Annual Lowest -9.8 604mm Rainfall Temperature Annual Average ℃ 4.6m/s Annual Average Rainfall Day Wind Speed Wind Speed Biggest Wind 28m/s Annual Average Foggy Day Speed in History Year-round Annual Average Sunshine Commonest Wind SE Duration Direction Wind Secondary Annual Average Evaporation Direction Prevailing Wind NNE Capacity Direction Prevailing Wind Annual Average Relative Direction in SE Humidity summer

2.1.4 Hydrological Condition

2.1.4.1Land Hydrology Suzhou is a city rich in water resource, with a large amount of lakes and rivers. The lakes include Taihu Lake, Yangdeng Lake, Kuncheng Lake and , and rivers include Jiangnan Canal, Wangyu River, Xujiang River, Loujiang River and Taipu River, with water area of 1,950km2, among which that of lakes is 1,825.83km2 (the water area of Taihu Lake is about 1,600km2), accounting for 93.61%; there are 22

31 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited backbone rivers, 212km long, with the area of 34.38km2, accounting for 1.76%; the area of ditches is 44.32km2, accounting for 2.27%; the area of ponds is 46.00km2, accounting for 2.36%. The main functions of Jiangnan Canal include shipping, agricultural irrigation, flood discharge and industrial water; the water of rivers flow from west to east, from north to south, with the average flow rate of 32.5m3/s, monthly low water flow of 20m3/s; the average flow rate is 0.14m/s; the water quality goal of functional regionalization is Class IV water body. Xujiang River originates from the water outlet of Taihu Lake, goes through Xukou Town, Mudu Town and Xikuatang Industrial Park, and separates into two branches near Hengtang, with the southern branch going through Shi Lake channel flowing into Shi Lake near Yuecheng Bridge and the eastern branch flowing into new canal. The two branches converge at Baodai Bridge and old canal. The Xujiang River is 12km long (from Xukou to Wufu Bridge). During the period of water pouring, the water quality of Xujiang River is good, flowing from west to east. During the period of back flow, its water quality becomes worse, affected by Suzhou moat and Jiangnan Canal with poor water quality. According to observation data, the times of backflow for Xujiang River are about 30d a year. Ponds and pits scatter all over the site like stars in the sky, some have perennial stagnant water. Qinglong Creek—creek developed among cross valleys, mainly originates from the natural water outlets of No.1 col and No.4 col (the outcrops of descending springs), flows into Xujiang River at the northeast of Qizi village, about 2km long and 2-3m wide, perennial streams. See Figure 2.1-2 for the regional water system conditions.

2.1.4.2 Underground Hydrology During the period of site selection for Phase engineering (2002-2003), Engineering Prospecting Team of the Fourth Geological Brigade of Jiangsu Geology and Mineral Bureau had implemented comprehensive investigation, and no obvious geological activity has appeared in the site, therefore the geological investigation data is suitable for the assessment of underground hydrology conditions. The results of this investigation indicates that the underground hydrology and geological condition are simple, and the site area is the landform of being ringed on three sides by mountains

32 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited and valleys in the middle, steep terrain, the flow direction of surface water is consistent with that of shallow groundwater, i.e. collecting from the surround of the site to the mountain, then discharging out of the area along west-northwest direction, forming the independent geographic and geomorphic unit and hydrological unit with single supply and discharge. The bedrock of mountain is Devonian system middle lower Maoshan Group quartz sandstone and muddy sandstone, with small permeability and water absorption, better water-resisting layer, which can effectively prevent the groundwater of the site from overflowing to neighbor col. Aquifer around project site, is bedrock fracture aquifer, bear pressure partly, with the coefficient of permeability K of 0.003~0.031 m/d. Another aquifer is Quaternary void aquifer, which can be divided into two layers. The upper layer is phreatic aquifer, occurring in the surface shallow stratum, with tiny water content, and it has close relationship with surface water, directly supplied by atmospheric precipitation. The lower layer is micro-confined aquifer, occurring in the gravel layer (Q1), with the coefficient of permeability of 0.17~0.25m/d, supplied by upper phreatic and bedrock void water. The buried depth of groundwater of the site is 1~5m, and the type of groundwater is heavy calcium carbonate type groundwater, which has no corrosivity to concrete.

2.2 Overview of Social Economy

2.2.1 Administrative Division Nowadays, Suzhou has seven districts, namely Canglang, Pingjiang, Jinchang, Industrial Park District, High-tech Dirstrict (Huqiu), Wuzhong and Xiangcheng, and five counties, namely , , Wujiang, and , with the regional area of 8,488.42 km2, 1,650 km2 of which is urban area. See Table 2.2-1 for the land and population distribution of the whole city and its counties.

Table 2.2-1 Land and Population Distribution of the Whole City and Its Counties Population by the End of 2006 Region Land Area *km2 (Ten Thousand People)

33 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Whole City 8,488.42 616.07 Urban Area 1,649.72 230.15 Zhangjiagang 772.40 88.78 Changshu 1,094.00 105.48 Taicang 620.00 46.14 Kunshan 864.90 66.68 Wujiang 1,092.90 78.84 *The land area without that of large lakes of the city or its counties

Covering an area of 672 km2, Wuzhong District has 8 streets and 7 towns, namely, Changqiao Street, Yuexi Street, Guoxiang Street, Hengjing Street, Xiangshan Street, Suyuan Street, Longxi Street, Chengnan Street, Luzhi Town, Mudu Town, Xukou Town, Dongshan Town, Guangfu Town, Xishan Town and Linhu Town. As the important economy town, Mudu Town has powerful economic strength. The maximum distance of the town from east to west is 7.35 km and that from south to north is 8.9 km, with the total area of 34.05 km2. The town is located in the east to the southwestern outskirt of Suzhou, south to Hengjing Town and Yuexi Town, west to Xukou Town and Zangshu Town, north to Fengqiao Town and Suzhou National High-tech Development Zone. In 1985, Mudu Town was listed as the tourism open town of Suxichang Economic Development Zone in Yangtze River Delta, Suzhou industrial satellite town and is awarded “Civilization Unit” of Jiangsu Province for many years. It also ranked the ninth of the top 100 towns with strong comprehensive strength in rural areas of Jiangsu Province and has ranked among modernization sample town, nationwide billion town and China top 100 towns. In 2007, replied by Jiangsu government Reply [2007] No. 64 of Jiangsu Province, Wuzhong District was allowed to allocate Shanrenqiao neighborhood committee of Xukou Town, four village committees, namely Zangdong, Zangzhong, Zangbei and Zangxi village committees, to Mudu Town. After the adjustment of administrative division, the area of administrative region of Mudu Town is 70.3 km2, with the population of 80,000, governing 8 neighborhood committees and 10 village committees.

2.2.2 Social Economy In 2010, the economy of Suzhou developed smoothly: the city had accomplished regional production value of RMB 482.03 billion, an increase of 15.5% over the

34 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited previous year calculated by comparable price; general local budget revenue is RMB 40.02 billion, with an increase of 26.3%; the fixed assets investment of the whole society is RMB 210.7 billion, with an increase of 12.7%. It cultivated and expanded leading industries, such as high-quality grain and oil, characteristic aquatic product, efficient gardening and ecological forestry, carried out high-quality production, standardization management and industrialization operation, and realized agriculture capacity and efficiency increasing. It also enhanced quality construction for agricultural products and safety supervision, newly built 35 pollution-free agricultural production origins, increased 35 pollution-free agricultural products, 188 kinds of green food and 4 kinds of organic food. The establishment of agriculture insurance system improved the risk resistance ability of agriculture. The total output of grain reached 1.235 million tons, with an increase of 11.5%. The grain production base outside of the city was consolidated continuously and the level of grain storage was promoted greatly. The relocation and expansion project of Suzhou grain wholesale market was accomplished as scheduled, thus the grain wholesale market system was established comprehensively. Industrial economy develops healthily, with the total output reaching RMB 1,530 billion, an increase of 26.3%; the main business income of above-scale enterprises increases 24.5%, realizing the increase of profit and taxes of 35%; the output value of high-tech products accounts for 32% of the industrial output value of above-scale enterprises, with an increase of 0.9% over the previous year; various distinctive industrial bases are built and the agglomeration degree of manufacturing industry increases continuously. The increase speed of service industry is accelerated, and finishes added value of RMB 157.4 billion, with an increase of 15.7%, an increase of 1.5% in the proportion of total regional production value. Urban and city markets are flourishing, with the retail total sales of consumer goods increasing 16.6%. The cargo handling capacity of Suzhou Port reaches 150 million tons and the traffic volume of containers reaches 1,240 thousand standard containers, respectively increasing 26.6% and 65.1%. The establishment of financial ecology gets achievement, the loan balance of domestic and foreign currency of financial institutions at the end of the year increase 23.1% and 25.2% respectively than that at the beginning of the year. The premium income of the whole year increases 11.5% and the turnover increases by 2 times. The development of new tourism product and market development are intensified and the accepted domestic and foreign tourists

35 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited respectively increase 13% and 16.3%, with the gross income of tourism increasing 21.5%. Conference and exhibition industry presents good developmental momentum and Suzhou Electronic Manufacturer Exposition becomes the largest professional exhibition for electronic information in China. The scale of commercial service, community service, information service, soft ware and animation is expanded further.

2.3 Overview of Regional Master Plan and Environmental Protection Plan

2.3.1 Current Master Planning The current master plan of Suzhou is the Suzhou Urban Master Plan (1996-2010) (hereinafter referred to as Master Plan (1996-2010)) approved by the State Council on January 10, 2000. The chapter of environmental protection of Master Plan (1996-2010) defines that domestic waste of Suzhou shall be finally disposed in Qizishan Refuse Landfill Site and it is required to realize the development direction of source classification bagging collection, gradually translate from total content sanitary landfill to the combination of landfill and incineration, finally incineration dominated. With the rapid development of city of Suzhou and the acceleration of urban and rural integration, Master Plan (1996-2010) cannot meet the demands for the current situation and sustained, rapid and healthy development of Suzhou.

2.3.2 Revised Overview of Regional Master Plan and Environmental Protection Plan Since February of 2004, Suzhou had engaged itself in the revision of Master Plan (1996-2010) and had finished Suzhou Urban Master Plan (2007-2020) (hereinafter referred to as Master Plan (2007-2020)) this year, and had passed experts argumentation on July 30, 2007.

2.3.2.1 Designated Function of the City It is clearly defined in Master Plan (2007-2020) that to adapt the demand for rapid, healthy and sustainable development, it is required to apply the development strategy of “entering the west of Shanghai in the east, expanding Pingxiang in the north, optimizing Songwu in the south and controlling Taihu Lake in the west,

36 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited centering the main city” and establish “green mountain, clear water and new paradise” with the theme of harmonious society: i.e. developing Suzhou into world famous historic and cultural city and scenic tourist city, national high and new technology industry base, one of important center cities in Yangtze River Delta. See Figure 2.3-1 for the master Plan of the city.

2.3.2.2 Urban Function World famous historic and cultural city and scenic tourist base, national high and new technology industry base; secondary business, trade and logistics center in Yangtze River Delta; one of innovation and Research & Development industry bases in Yangtze River Delta; one of the most attractive places of residence in Yangtze River Delta; municipal center of politics, economy and culture; municipal comprehensive service center.

2.3.2.3 Urban Scale In 2020, the population of central urban area is 3.5 million and the scale of construction land is 373 km2, with the average urban construction land per person are 105m2/ person.

2.3.2.4 Environmental Protection (1) Green Space System Plan at Central Urban Area Ecological “repair” is one of important contents of Master Plan (2007-2020); the Green Space System Plan at Central Urban Area is “one belt, three rings and five wedges”: One belt: the open space and green belt at the both sides of the . Three rings: green ring along moat, green ring of the Grand Canal - Dushu Lake - Jinji Lake - Yangcheng Lake - Shanghai-Nanning Expressway - Sanjiaozui and the green ring of the periphery of central urban area. Five wedges: based on the three-level green centers formed by Taihu Lake, Yangcheng Lake and Jinji Lake, western green wedge composed by Dayang Mountain, Tianping Mountain and Lingyan Mountain; the four-angle mountain and water green wedge of the central city composed by northeastern Yangcheng Lake, southeastern Cheng Lake, southwestern Shangfang Mountain, Shi Lake, nouthwestern Sanjiaozui

37 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited and Cao Lake. Taihu Lake is the water source for many cities around the lake, and it is also located at the upper stream of Taipu River, the water source of Shanghai, directly affecting the ecological safety and urban safety of Yangtze River Delta; Taihu Lake is located at the upper stream of Suzhou municipal water net and its water quality directly affects the ecological environment quality of the municipal area of Suzhou; it is also the regional green center and permanent open space of Yangtze River Delta, the common ecological landscape resource of the area, how to protect it is the initial problem to treat Taihu Lake. The “controlling Taihu Lake in the west” of Master Plan (2007-2020) refers to implement step control in the area west to Taihu Lake, north to Wang Pavilion, south to Xukou, east to Yang Mountain and the east foot of Tianping Mountain, protect the ecological resource and natural and human resources at the east bank of Taihu Lake, strictly control the construction of urbanization in the western area, use good land for excellent use, and make every effort to create Taihu Lake- the green core of Yangtze River Delta, into world famous place for tourism and holidays. (2) Environment and Health Plan for Urban Area and Central Urban City and Municipal Infrastructure Plan (Part) Forecast of domestic waste amount: the total amount of domestic waste in urban area from 2005 to 2020 is about 16.44 million tons and the daily amount of domestic waste in urban area is 3,500 tons by the end of the plan. Disposal method of domestic waste: recently, sanitary landfill is dominated (accounting for 60%), supplemented by incineration treatment (accounting for 40%); for a long run, incineration treatment is dominated (accounting for 70%), supplemented by landfill (accounting for 30%). Site selection and construction of sanitation facilities: based on forecast, at the end of planning period, the daily amount of domestic waste in urban area will reach 3,500 tons, and the total amount of domestic waste will exceed 16 million tons in the next 15 years; however, the rest landfill capacity of Qizishan Refuse Landfill Site is just about 2 million tons, and it is badly in need of new garbage disposal site. Since the particularity of the construction of garbage disposal plant, there are many influence factors for site selection, which need municipal government to define on the basis of comprehensive consideration on various influence factors. As Qizishan Refuse Landfill Site is used recently, the feasibility of expansion shall be considered; enhancing the operation management of existing incineration plant, accelerate the

38 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited construction of expansion project with the daily disposal capacity of 1,000 tons for Qizishan Garbage Incineration Plant (see Figure 2.3-2 for the position).

Figure 2.3-2 Site Selection for Suzhou Garbage Disposal Plant

(3) Environmental Protection Plan for Atmosphere and Surface Water Atmospheric environment: optimize energy structure and promote the proportion of gas and electrical energy in energy consumption; control the development of industries, such as fire electricity and smelting with large emission of sulfur dioxide; encourage the use of clean coal and enhance the management and supervision of automotive emission; support municipal public transit; reduce the energy consumption for industrial output value of every ten thousand yuan; improve energy utilization; reinforce the construction of natural reserves and urban forest park and increase regional greening rate. Surface water environment: amplify the water quantity to supply Taihu Lake

39 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited from river and reduce the residence period of Taihu Lake and Suzhou water system; adjust industrial structure and reduce the water consumption for output value of every ten thousand yuan; improve the treatment rate of domestic sewage; implement comprehensive improvement of agricultural area source; establish municipal coordination system and reasonably plan, deploy and unified schedule industrial distribution and industrial strength.

2.3.3 Environmental Protection Plan It is required in the plan of solid waste disposal in the Eleventh Five-Year Plan and Long-term Plan of Suzhou for Environmental Protection that “making overall arrangement of and establish facilities for the collection, transportation and disposal of urban and rural domestic waste, realize the classification of garbage collection, obdurate transportation of garbage, harmless, reduction and resource recovery of garbage. Promote the development of garbage collection and disposal industry, gradually establish and perfect the social service system for environment prevention and control of demotic garbage pollution. During the ‘Eleventh Five-Year Plan’ period, the disposal of domestic waste will gradually develop from single method of sanitary landfill to multiple methods of incineration, sanitary landfill and biochemical treatment, and promote the level of domestic waste disposal and management”.

2.3.4 Professional Plan for Environment and Sanitation The chapter of the selection of the disposal technology for domestic waste in Suzhou Professional Plan for Environment and Sanitation (2006-2020) mentions that “it is planned that recently, sanitary landfill is dominated, supplemented by incineration treatment; for a long run, incineration treatment is dominated, supplemented by landfill”, with the plan as follows: “It is planned for Suzhou to apply relatively concentrated disposal plan and establish Qizishan garbage comprehensive disposal base and industrial park domestic waste incineration plant. Qizishan garbage comprehensive disposal base shall include the following facilities:  SuNeng Incineration Plant with the scale of 2,000 t/d;  Qizishan Refuse Landfill Site with the capacity of 8 million m3;  Qizishan Safety Landfill Site with the capacity of 230,000 m3;

40 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited  Food Residue Disposal Plant with the scale of 250t/d;  Standby land for long term development.”

2.3.5 Relationship between This Project and Conservation Area in Taihu Lake Basin

2.3.5.1 Relevant Provisions on Taihu Lake Water Pollution Protection Article 44 of Jiangsu Prevention and Control Regulations for Taihu Lake Water Pollution (hereinafter referred to as regulations): “the regulations shall become effective on October 1, 1996. The Taihu Lake Water Source Protection Regulations formulated by the fourteenth conference of the fifth standing committee of provincial people’s congress on May 30, 1982 shall be abrogated as of the same date.” Article 2: “These regulations apply to the pollution prevention and control of Taihu Lake body and surface waters, such as rivers, lakes, reservoirs and channels, which have impact on the water quality of Taihu Lake in the Taihu Lake Basin of the province (hereinafter referred to as Taihu Lake Basin). Taihu Lake Basin is divided into three-grade reserves (see Figure 2.3-3), namely the first grade reserve which refers to Taihu Lake body, area within 5km along the lake bank, the area 10km up the rivers into the lake and the area within 1km at both sides along banks; the second grade reserve which refers to the area 50km up the rivers into the lake and the area within 1km at both sides along bank; and the third grade reserve which refers to the other areas.” The main 13 rivers into the lake include Wujin Port, Taige Canal, Caoqiao River, Chendong Port, Hongxiang River, Dapu Port, Port, Xiaoxi Port, Zhihu Port, Dongtiao Creek, Changxing Port and Sanliqiao River. Article 29: “The following behaviors are prohibited in the first grade reserve: (1) Newly build or expand chemical pulping and paper making, chemical industry, medicine, leatherworking, brewing, dyestuff, printing and dyeing and electroplating that cause pollution to water environment, and other enterprises and projects that discharge pollutant water with nitrogen or phosphorus; (2) Directly discharge animal manure or dredged sediment from fish pond or rivers into Taihu Lake or rivers into the lake;

41 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited (3) Discharge or pour oil, acid liquor, alkali liquor, toxic waste residue and liquor, radioactive residue and liquor, pathogen-contaminated sewage, industrial waste residue, urban garbage or other wastes into Taihu Lake or rivers into the lake; (4) Clean vehicles, ships or containers that which have been used for storing oil or toxic pollutant in Taihu Lake or rivers into the lake; (5) Set new sewage draining exit at the bank of Taihu Lake, or implement aquaculture, such as enclosure, wire netting or pot, and fishing operations such as mechanical screw sucking and trawl net; (6) Engage in aquaculture or centralized model livestock and poultry raise, tourism and other activities that may cause water pollution within 1km of centralized model drinking water source; (7) Engage in sabotage, such as destroying hill-stone, forest, vegetation cover or aquatic organism.” Article 30: “It is forbidden to newly build or expand chemical pulping and paper making, chemical industry, medicine, leatherworking, brewing, dyestuff, printing and dyeing or electroplating that cause pollution to water environment that fail to comply with the requirements for environmental prevention and control, or other enterprises and projects that discharge pollutant water with nitrogen or phosphorus”.

2.3.5.2 Relationship between This Project and Conservation Area in Taihu Lake Basin See Figure 2.3-3 for Taihu Lake Basin Reserve Map. According to the regulations, the minimum linear distance between this project and the east bank of Taihu Lake is about 7km, not belonging to the range of the first-grade reserve of Taihu Lake Basin. The water in-taking river of this project is Xujiang River, whose west end is connected with Taihu Lake through Mudu ship lock and the east end is connected with Jiangnan Canal, as the outlet channel of Taihu Lake. The discharged water of the project is discharged into Jiangnan Canal after centralized processing in new district sewage plant. According to the regulations, neither Xujiang River nor Jiangnan Canal belongs to rivers into the lake. Therefore, the site of the project does not belong to the range of second-grade reserve of Taihu Lake Basin. Based on the above analysis, this project belongs to the third-grade reserve of

42 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Taihu Lake Basin.

2.3.6 Suzhou Everbright National Vein Industrial Park Plan and Construction Status in the Area near the Site

2.3.6.1 Vein Industrial Park Planning Layout According to the special conference summary of Suzhou municipal People’s Government [2007] No. 71, affirmation is given to the feasibility of the environmental protection and planning for the site selection and layout of Qizishan Refuse Landfill Site, the change of domestic waste disposal method from single landfill to the combination of garbage incineration power and landfill and the construction of Everbright Environmental Protection Industrial Park. It is required to actively promote the construction of environmental protection industrial park and implement the construction of new socialist countryside from improving the level of urban domestic waste disposal, developing recycling economy and sustainable development; make Everbright Environmental Protection Industrial Park better and stronger, farsighted, centered on the future trend of big downtown (seven districts), higher requirements is put forward to the follow-up expansion for the domestic waste disposal of Everbright Environmental Protection Industrial Park; enhance the administrative management of the environment of enterprises around surrounding areas, regulate surrounding environment, jointly guarantee the construction of first-class environmental protection industrial park and ensure the environmental quality of surrounding areas. Suzhou Everbright National Vein Industrial Park (the plan is not approved at present) is planning to build an industrial park with producing area as the center, research and development area as technical backstopping, management service area as safeguard, education base for environmental protection as window. Among them, the producing area is the core component of the park and its planning projects are as follows:  Domestic waste resource utilization planning project, mainly includes domestic waste Waste-to-Energy, domestic waste landfill site biogas power generation, garbage percolate treatment and disposal, garbage incineration ash residue resource utilization and waste heat comprehensive utilization.  Industrial hazardous waste treatment and disposal plant. The project is

43 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited planning to build a solid (hazardous) wastes Landfill site, including the safety landfill capacity of 330,000 m3, supporting waste pretreatment system, collection system, storage system and public auxiliary engineering facilities.  Garbage sorting and pretreatment center. This project is to sort, recycle and inspect the transported solid wastes in the area, to make the part that cannot be utilized finally enter into incineration and landfill treatment, so as to improve the utilization rate of resource and reduce the requirements of disposal costs and quantity for land resource.  Ecological restoration center. Ecological restoration is implemented to Qizishan Refuse Landfill Site and industrial waste safety landfill site to create ecological park; soil remediation and restoration for military shooting gallery. See Figure 2.3-4 for the schematic diagram of vein industrial park plan project relationship. See Figure 2.3-5 for the schematic diagram of vein industrial park plan project distribution.

44 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Municipal Solid wastes Radiation area Core area

Production area Ecological restoration center

Biogas Recyclable Garbage sorting and pretreatment Garbage refuse landfill Biogas Comprehensive center site Waste-to-Energy utilization Leachate

Waste heat Comprehensive Waste-to-Energy plant Percolate treatment and disposal utilization center residue

Ash

Industrial hazardous waste treatment Building materials and disposal center

Research and development Management service area Publicity and education area center

Figure 2.3-4 Schematic Diagram of Vein Industrial Park Plan Project Relationship

45 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

2.3.6.2Status of Relevant Garbage Treatment and Disposal Project near the Construction Project At present, the projects that are located in Everbright Vein Industrial Park include Qizishan Refuse Landfill Site, Everbright Environmental Protection Domestic Waste Incineration Plant, and Everbright Environmental Protection Hazardous Waste Landfill Site and Everbright Environmental Protection Biogas Power Generation project. Qizishan Refuse Landfill Site belongs to urban council and others are operated by Everbright Environmental Protection Investment and BOT. . Qizishan Refuse Landfill Site Built in 1993, with the designed service life of 15 years, Suzhou Qizishan Refuse Landfill Site is among the first batch of domestic waste sanitary landfill sites built according to Technical Code for Sanitary Landfill of Domestic Refuse (CJJ17-88) issued by the Ministry of Construction in 1988. The landfill site belongs to typical valley landfill site, applying vertical waterproof curtain, and it was awarded as sample project of the construction of landfill site of the Ministry of Construction in 1990s. Due to the rapid development of economy and the acceleration of urbanization, the output quantity of domestic waste exceeds the predicted amount. Although Everbright Environmental Protection Energy (Suzhou) Co., Ltd. had incinerated a part of domestic waste after its putting into operation in the second half of 2006, the Phase Project of Qizishan Refuse Landfill Site had been sealed at the end of 2007 ahead of schedule. The expansion engineering of Qizishan Refuse Landfill Site was started in 2006, with the investment of RMB 339 million, construction capacity of 7.8 million m3, daily treatment quantity of 1,600t and the service life of 16 years, mainly including reconstruction of old site and construction of new site. The reconstruction of old site mainly includes reconstruction of leachate layered drainage system, biogas layered drainage system of old site and vertical waterproof curtain and build new closure system; the new site include the expansion of garbage dam and access route, and newly built horizontal impermeable system, leachate collection and guide system, leachate regulating tank and treatment system, landfill gas collection pipe system (it shall be sent to the biogas power generation plant that belongs to Everbright Group after collection). For the expansion engineering, Jiangsu Academy of Environmental

46 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Science formulated environment impact report, which was replied by Environmental Protection Department of Jiangsu Province on October 9, 2006. The expansion engineering was started on April 28, 2007. At present, it has been completed and put into operation. Household garbage landfill site has its supporting leachate treatment plant, with the designed treatment scale of 1,200t/d. At present, upgrading reconstruction is implemented for it and the upgrading reconstruction engineering will apply MBR (A/O/O + postpositive A/O nitrification denitrification + external UF (ultrafiltration)) treatment process, with the combination of two-level RO and two-level nanofiltration as the treatment process of deep treatment technology. The tail water that reaches the special discharge limit value for water pollutants stipulated in Table 3 of Standard for Pollution Control on the Landfill Site for Domestic Waste (GB16889-2008) is discharged into Xujiang River through Qinglong Creek in the area, and it is predicted to be completed and put into operation in 2011. . Hazardous Solid Waste Landfill Site According to the overall planning for hazardous solid waste disposal facilities of Jiangsu Province, Suzhou implements financing by BOT method and attracts investors by franchise rights. Finally, Everbright Environmental Protection (Suzhou) Solid Waste Disposal Co., Ltd. invests to build a hazardous solid waste landfill site that covers the urban area (hereinafter referred to as Suzhou Hazardous Waste Landfill Site). The project has listed in National Hazardous Waste and Medical Waste Disposal Facility Construction Plan, replied by the State Council in 2004. Hazardous solid waste landfill site serves for the urban area of Suzhou, with the scale of the initial stage of 100,000 m3 and the investment of RMB 78 million. The final scale is 600,000 m3 and the total investment is about RMB 253 million. The environment assessment report of the project has been replied by Environmental Protection Department of Jiangsu Province (Suzhou Environment Management [2006] No.93); with incineration disposal residue involved in the disposal types of solid waste (HW18). The initial engineering has been put into operation on July 4, 2007. At present, Phase expansion engineering is prepared. . Domestic Waste Waste-to-Energy Plant The domestic waste Waste-to-Energy plant serves for the domestic waste yielded in the urban area of Suzhou. The treatment scale of Phase engineering is to

47 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited incinerate 1,050 ton domestic waste each day, and it was approved to formally change into commercial operation on July 18, 2006. In October, 2007, Everbright Environmental Protection began to construct Phase expansion engineering with daily incineration capacity of 2,050 ton and to construct the supporting furnace clinker comprehensive utilization project. The Phase engineering had been completed and put into operation in 2009, and passed the acceptance of environmental protection in April, 2010. According to environmental protection acceptance supervision and supplementary supervision data, the concentration of discharged gas meets the assessment standard and the concentration of discharged dioxins is 0.01 ~ 0.1TEQ ng/Nm3, meeting European standard. The domestic waste Waste-to-Energy plant has established the supporting furnace clinker comprehensive utilization brick making project, leachate treatment station project. . Biogas Power Generation of Domestic Waste Landfill Site Biogas power generation project use the landfill gas yielded in domestic waste landfill site as secondary energy to generate power. The two 1,250kw internal combustion generating sets were in incineration plant, sharing the lines to grid with Waste-to-Energy plant, and they were put into commercial operation in August, 2006, with the annual output electricity of about 18.7 million Kwh. A new 1,250kw box-type internal combustion generating set was added in Phase project, and they were put into commercial operation in June, 2008. The three sets of biogas power generation project can generate about 28 million Kwh, reducing the discharge of carbon dioxide gas by 110,000 tons.

2.3.7 New Plan for Xujiang River, Mudu Town, Wuzhong District, Suzhou Mudu Town, Wuzhong District, Suzhou is planning to establish Xujiang city along the Xujiang River, with the planning range stretch north to Sufu Road, south to West Baodai Road, west to south Jinfeng Road, east to the boundary of town and district, expect the built block, for instance, Kaima Square, and water area, with the actual planning land area of 4.6km2. It is planned to build nine functional areas in Xujiang urban area, including vigorous center zone, headquarters economic zone, commercial cluster zone, garden creative zone, auto culture subject zone, livable

48 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited communities, auto theme park zone, mountain leisure park zone and Binjiang leisure zone, the last three ones of which is the regions dominated by open space. See Figure 2.3-6 for the land use map of this plan. The place where Everbright Environmental Protection project lies belongs to the land for sanitation facilities. At present, the plan is in public notification stage and its reply is not completed.

49 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

3 Reviews on Existing projects

3.1 Overview of Existing Projects From May, 2002 to December, 2003, related government department of Suzhou Municipality declared and completed the environmental impact assessment work of 3×350t/d Domestic Waste Waste-to-Energy Project of Suzhou SuNeng Waste-to-Energy Co., Ltd. (hereinafter referred to as Phase Project), planning to build a garbage incineration power plant with a daily treatment capacity of 1,000t domestic waste at the reserved land in Qizishan Refuse Landfill Site. The environment impact assessment of this project was conducted by State Power Environmental Protection Research Institute, and in December, 2003, Jiangsu Environmental Protection Department has given a written reply in the form of Suzhou Environmental Management [2003] No. 229. In 2004, China Everbright International Ltd. was introduced by government through investment invitation of BOT pattern, and Everbright Environmental Protection Energy (Suzhou) Co., Ltd. was established to take charge of the construction of PhaseProject and the operation management for the first 25 years, and enterprise name was changed according to Regulations of the People's Republic of China on Administration of Registration of Companies. According to Suzhou Environment Acceptance (2007) No. 380, PhaseProject has passed the final environment protection acceptance conducted by Jiangsu Environmental Protection Department. With the continuous increase of domestic waste in Suzhou City, Everbright Environmental Protection Energy (Suzhou) Co., Ltd. had invested RMB 0.45 billion to construct PhaseProject expansion project of “2×500t/d garbage furnace + 20MW turbo generator set” (hereinafter referred to as Phase Project) in October, 2007. This expansion project will have a support project for the comprehensive utilization of slag so as to use the resources more effectively. The environment impact assessment of this project was conducted by China Bluestar Lehigh Engineering Corporation, and the environment protection department made a written reply in the form of Environment Audit [2008] No. 25 in March, 2008. Phase Project was put into operation in 2009 and had passed the

50 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited final environment protection acceptance conducted by environment protection department in the form of Environment Acceptance [2010] No. 84. Everbright started to construct leachate treatment plant to avoid having environmental risk when transporting leachate and to reduce potential environmental impact in 2010. This project had a written reply from Suzhou Municipal Environment Protection Bureau. Table 3.1-1 shows the existing projects and the performance investigation of environment protection formalities.

Table 3.1-1 Summary of Environment Protection Formalities Performance of Existing Projects

No. Project Reference No. Acceptance No. Acceptance content

Domestic waste Suzhou incinerating project Suzhou Environment 3×350t/d mechanical Environment 1 with an incineration Management [2003] grate furnace Acceptance capacity of 3×350t/d No. 229 +2×12MW generator (2007) No. 380 Phase Project 2×500t/d garbage 2×500t/d mechanical incinerator +20MW grate furnace turbo generator set, Environment +1×20MW generator, a Environment Audit 2 supporting project of Acceptance product line with an [2008] No. 25 comprehensive [2010] No. 84 annual production utilization of slag capacity of 100,000 m3 Phase Project ash building blocks Suzhou Environment Daily treatment Leachate treatment 3 Construction / capacity of 1,000t project of waste [2011]No. 186 leachate

Table 3.1-1 shows floor plans of existing projects site. The current situation of main works and public auxiliary works of existing projects is shown in table 3.1-2.

Table 3.1-2 Current Situation of Main Works and Public Auxiliary Works of Existing Projects

Major equipment and Actual output in Name Design capacity Remarks facilities 2010

51 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Furnace 3×350t/d+2×500t/d 3×350t/d+2×500t/d Reciprocating grate furnace Exhaust-heat 3×26.7t/h+2×42.3t/h 3×26.7t/h+2×42.3t/h Incineration boiler Main works Actual energy output in 2010 Turbo system 2×9MW+1×20MW 2×9MW+1×20MW generator sets is 28,102.45KWh garbage 16,000m3+15,000m3 16,000m3+15,000m3 storehouse With annual With annual Two product lines(six Units), Slag comprehensive production capacity production capacity with designed daily production Supporting utilization system of 100,000 m3 of 40,000~50,000 capacity of 200,000 standard project building blocks m3 building blocks bricks With a daily With a daily Leachate treatment plant treatment capacity treatment capacity of 1,000t leachate of 509t Water Process water 6,000m3/d 2,400~2,960m3/d Xujiang river Domestic supply — 2,100t/a Municipal pipe network Public water Chemical water treatment auxiliary 2×20t/h 2×20t/h station works 6,800m3/h+ 6,800m3/h+ Force air cooling tower 7,000m3/h 7,000m3/h Air compressor 5×24m3/min 5×24m3/min Garbage storehouse is wholly enclosed and runs under micro-negative pressure; using “SCR denitration+semi-dry process deacidification+active Waste gas carbon adsorption+bag filter” to remove dusts in the incineration flue gas; denitration efficiency≥70%,desulfurization efficiency≥80%, HC1removal efficiency≥97%, dust removal efficiency≥99.9%, discharge fume from 80m chimney Production waste drainage shall be put into cyclic utilization rather than outward discharge; domestic sewage enters into sewage plant in new district Environment after being treated in septic tank; little leachate shall be injected back into protection Waste water incinerators, the rest enters into sewage plant in new district after processed project by supporting leachate treatment station, and the design treatment capacity of the leachate treatment station is 1,000t/d Construct support slag comprehensive utilization project in Phase Project , Solid wastes make bricks by comprehensive utilization of slag, with a designed annual production capacity of 100,000 m3 bricks; fly ash should be transported to hazardous waste landfill solidification for safe landfill Noise Decrease window area of plant, equip with sound proof cover and muffler, set up sound insulation watch room, reduce the noise by greening

3.2 Overview of Technological Process

3.2.1 Existing Garbage Incineration System Both PhaseProject and PhaseProject use Kepple Seghers’ grate furnace, with the same technological processes of garbage incineration and generating

52 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited electricity as shown in Table 3.2-1.

53 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

17 18 Flue gas

emission

12 13 4

10 26 16 3 5 11

9 14 6 8

1 2 19 7 15 20 22 23 Exist in design but not

put it in24 hazardous waste 21 Fly ash Everbright Environme Leachate Slag Furnace Protection (Suzhou) haz

54 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 3.2-1 Sketch Map of Technological Processes and Pollution Production Link Of PhaseProject and PhaseProject

(13) Active carbon storage bin Label declaration (14) Bag-type dust collector (1) Tipping stage (15) Induced draft fan (2) Garbage dump pit (16) Calandria chimney (3) Crane operating room (17) Steam turbine (4) Crane, grab bucket (18) Generator (5) Feed hopper (19) Slag salving machine (6) Feed thruster (20) Slag storehouse (7) Primary air fan (21 Leachate collecting bin (8) Incineration grates (22) Exhaust-heat boiler clinker (9) Secondary air fan (23) Flyash bin (10) Exhaust-heat boiler (24) Flyash solidification workshop (11) Desulfurization and deacidification by

calcium spurt

(12) Lime cream tank

55 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited (1) Garbage truck enters into discharging hall of garbage storehouse and discharge the domestic waste into the storehouse through discharge door. Discharge door is equipped with electro-mechanical device to prevent odor from garbage storehouse over spilling. A suction opening for primary air fan is set at the side face of garbage storehouse to keep negative pressure in garbage storehouse and avoid having accumulation of odor and methane gas; the air in the storehouse is extracted by primary air fan and used as combustion-supporting air of incinerator.

Discharging hall

Isolated visual working chamber  Feed to in garbage storehouse 1 incinerator Isolated visual working chamber in garbage storehouse 2

Garbage grip travelling crane

Garbage storehouse is designed to hold domestic waste which can be incinerated for 5~7 days, the domestic waste discharged in garbage storehouse should be fermentated by stacking, to lead out the leachate and make sure that the garbage storehouse can accept garbage normally when equipment are broken or overhauled. In order to make sure that the components of garbage in incinerators are well-proportioned and can combust steadily, the storehouse has been equipped with jaw clamshell crane to feed garbage to incinerator and mix, cast, convey and agitate garbage. The operation of crane is remotely controlled by control room which is thoroughly isolated from garbage storehouse and has such functions as weighing,

56 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited overload protection, anti-swing, tripping, anti-collision. The crane puts garbage into hopper, and then garbage enter into incinerator for burning through supply pipe and hydraulic handspike. (2) The heat energy produced from the garbage combustion in incinerators can generate vapor while passing through exhaust-heat boiler and then vapor is conversed into electrical energy through turbo generator set. The slag and clinker respectively derived from incinerator and exhaust-heat boiler can be made into bricks in the supporting comprehensive utilization brick field. (3) The garbage incineration flue gas is treated by adopting group technology of SNCR denitration, semi-dry process (lime cream neutralization reaction tower), active carbon injection device and bag type dust collector, with the following features: high operating flexibility, high efficiency of removing harmful substances, less reactant consumption, not generating high-concentration chloride wastewater, low emission concentration of heavy metal and dioxin-like compounds, being easy to control and low composite cost.

Slag exit Rotator spray lime cream deacidification tower

Active carbon feeder

This system adopts SNCR denitration to make removal efficiency of nitrogen oxides ≥ 50%; adopts 90 percent CaO which shall be grinded to 325 meshes through grinding machine, mixed into 12~15% lime cream, and deacidificated in absorbing tower (desulfurization efficiency ≥ 80%, antichloration efficiency ≥ 95%). After flue

57 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited gas gets out of the tower (around 150℃), the dusts, heavy metal and dioxins shall be removed by using active carbon and dust collector (collection efficiency ≥ 99.8%). After calcium slag from deacidification tower and fly ash from bag type collector were preprocessed, they will be put into bag and send to Suzhou hazardous wastes landfill for safe disposal.

3.2.2 Existing Slag Comprehensive Utilization System The slag comprehensive utilization project which has been co-constructed by Everbright Environmental Energy(Suzhou) Co., Ltd. and Shenzhen Hua Hongqin Environment-Friendly Building Material Development Co. Ltd is the supporting project of Phase expansion project to incinerate garbage and generate energy. It takes advantage of slag from Phase Project and Phase Project , with an annual production capacity of 100,000 m3 clinker blocks, and it has produced 30 million perforated bricks and solid bricks (around 45,000 m3) in 2010. The technological process of slag utilization plan is shown in Fig. 3.2-2.

Metal recovery Recycle bin Slag from Clinker Concrete incineration storage Storehouse plant yard Sorting Twin-shaft and mixer Composite additive breaking Storage Uncombusted material yard Sandstone Incineration

garbage Storage Sale storehouse Jolt-moulding User machine yard maintain

Fig.3.2-2 Technological Process of Slag Comprehensive Utilization

3.3 Raw and Auxiliary Materials Consumption

3.3.1 The Source and Dosage of Fuel The fuels of PhaseProject and PhaseProject includes domestic waste and light diesel. 1the source of domestic waste

58 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited According to the BOT agreement between our company and Suzhou Bureau of Municipal Public Utilities, the domestic waste used for PhaseProject and Phase Project should be transported from specified refuse transfer stations to discharging hall by enclosed transporters and breech loading enclosed transporters provided by Division of Environment Sanitation Management of Suzhou Bureau of Municipal Public Utilities (now named Suzhou Environment Sanitation Division) and then unloaded into garbage storehouse. Suzhou Environment Sanitation Division takes charge of the transportation of domestic waste. At present, those garbage used for incineration come from the following several refuse transfer stations in Fig. 3.3-1. The existing transit routes are: (1) East Taihu Rd- West Taihu Rd-West Baodai Rd-our plant; (2) Changjiang Rd- West Baodai Rd- our plant; (3) S230-West Baodai Rd- our plant, most of transit routes are arterial road and there are no any aquatic environment sensitive targets like water-source protective zone and water catchment along those routes, without going through concentrated residential area. According to the requirements of Standard for Pollution Control on the Domestic Waste Incineration (GB18485-2001), the project only accepts domestic waste from Suzhou Municipality rather than hazardous wastes. 2Incineration amount of garbage According to the weighing statistical data of accepted domestic waste, the capacity of PhaseProject and PhaseProject is 941,200 t (in table 3.3-1); Annual operating time is more than 8,000 h. The average accepted garbage amount has been up to 2,580 t/d. After high moisture content of 20.08% being removed (discharge leachate by stacking them in garbage storehouse), the average amount in the incinerators has been up to 2,090 t/d, higher than the designed operating load.

Table 3.3-1 Statistics of Disposing Amount of Domestic Waste In 2010 Amount of Amount of Discharge amount Concentration of Period entering plant disposing of leachate(t) leachate (%) garbage(t) garbage(t)

Jan~Dec,2010 941,154 752,152 189,002 20.08 Daily average 2,580 2,055 525 20.08

3Garbage composition analysis A. Current situation of garbage composition

59 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited According to the analysis report of Suzhou garbage heat value presented by Everbright Environmental Protection Energy (Suzhou)Co., Ltd. to GuangZhou Institute Of Energy Conversion, Chinese Academy of Sciences in Jun 2006, the heat value, component, technical analysis and elemental analysis of existing domestic waste for incineration are shown in Table 3.3-2 ~ table 3.3-6.

Table 3.3-2 Heat Value Analysis of Existing Domestic Waste for Incineration Higher calorific Lower calorific Content of Lower calorific value of value of combustible value of garbage Project combustible combustible constituent in dry entering furnace constituent in dry constituent in dry basis (%) (kJ/kg) basis (kJ/kg) basis (kJ/kg) Value 64.25 22,182.8 20,711.3 5,415.7

Table 3.3-3 Component Analysis of Existing Domestic Waste for Incineration Organic matter Inorganic matter Animals Sand Component Others and Paper Plastic Metal Glass and plants soil Component of dry 20.97% 6.60% 28.23% 1.56% 10.92% 23.26% 8.46% basis Component of raw 36.72% 7.03% 24.22% 0.78% 5.47% 17.97% 7.81% refuse

Table 3.3-4 Technical Analysis of Existing Domestic Waste for Technical Incineration Technological analysis Volatile matter Fixed carbon Ash contents Moisture Technological analysis of combustible in dry 74.88% 8.07% 17.05% 0.00% basis Technological analysis 48.11% 5.19% 46.70% 0.00% of garbage dry basis Technological analysis 15.48% 1.67% 32.93% 49.93% of raw garbage

Table 3.3-5 Elemental Analysis of Existing Domestic Waste for Incineration

60 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Elemental analysis C% H% N% S% O% Elemental analysis of combustible in dry 50.73 6.54 3.06 0.39 22.23 basis Elemental analysis of 32.60 4.20 1.97 0.25 14.28 garbage dry basis Elemental analysis of 16.32 2.10 0.98 0.13 7.15 raw garbage

4The source and dosage of auxiliary fuel According to existing operating statistics, owing to such operations as moving, mixing, stacking and feeding, after 5~7 days’ storage and fermentation in garbage storehouse, the range of garbage heat value in incinerators is nearly steady, which is the prerequisite of combustion condition stabilization within incinerators, so, no more auxiliary fuel is needed during operation. Auxiliary fuel is needed only when starting the incinerators of PhaseProject and PhaseProject , the fuel helps incinerators reach burning temperature. Auxiliary fuel is light diesel, transported by supplier to tank farm within plant by tank truck and then put into oil fuel tank with vehicle-mounted oil pump. Oil feed pump in oil pump room nearby oil fuel tank can supply diesel to incineration room if diesel is needed. Every incinerator can consume 3~5t diesel at each cold boot while 1~2t at warm boot, a 20 m3 oil fuel tank is set in oil fuel tank area and there is a fire prevention cofferdam being separated from plant side. Auxiliary fuel--0# light diesel can be purchased from market and Table 3.3-6 shows main quality control indexes.

Table 3.3-6 Main Quality Indexes of 0# Light Diesel

3 Main quality indexes consistencyg/cm LHVMJ/kg S% Targeted value 0.829320 42.9 (qualified products) ≤1.0

℃ 3.3.2 Other Auxiliary Materials Consumption

The 12-15% Ca (OH) 2 slurry mixed from CaO during the garbage combustion can be used for gas deacidification and active carbon shall be used to remove organic pollutants such as heavy metal ion/particle and dioxin-like compounds. According to

61 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited the production statistics in 2010, the consumption of lime and active carbon are 9,310t/a and 294.08t/a respectively. The garbage consumption is 1.5kg/t for 20% ammonia water for SNCR denitration and 1,044t/a ammonia water was consumed in 2010 according to statistics.

3.4 Water Supply, Drainage and Water Balance of Existing Projects The process water of existing projects is taken from Xujiang River and domestic water comes from municipal supply net.

3.4.1 Water Supply There is a water intake pumping station equipped with two water intake lift pumps, two integration water purification units and a fresh water storage tank on the south bank of Xujiang River. Each water purifier has a designed water purification capacity of 150 m3/h, but in order to ensure water quality during actual operation, the water purification capacity of each water purifier can only be maintained at about 100 m3/h. Supply water to plant uses DN350 carbon steel pipes. In 2010, PhaseProject and PhaseProject consumed 2,700~2,960 m3/d (around 123m3/h) water in summer and 2,500~2,600 m3/d(around 108 m3/h) in winter. So, water purification station of existing projects still has residual deliverability of 80 m3/h (1,920 m3/d).

3.4.2 Drainage A small part of leachate in PhaseProject and PhaseProject can be injected back into incinerators and surplus enter into sewage plant in new district for centralized treatment after being pre-processed by supporting leachate treatment station during actual process; Domestic sewage enters into effluent treatment plant in new district for centralized treatment through municipal waste pipe net; the water drained from cooling tower shall be used for cooling slag dragging machine, no other kinds of waste water need to be discharged.

62 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 3.4.3 Water Balance According to the statistical average data of existing projects at PhaseProject and Phase Project, Fig. 3.4-1 shows water balance of existing projects. Backwash water from water pumps, catch water and film system is mainly offered to leachate pretreatment station.

Loss 2,065 Loss 315

2,390 325 10  Taking away slag Cooling Cool and flushing cinder of dragveyer

8,200 t/h 200 t/h

Loss 240 Xu Jiang River 2,960 240 12~15%lime furnish preparation Loss 126 Loss 35

255 161 35 Chemical water treatment Boiler circuit Greening, road sprinkler

94 Rinsetereace and vehicle

512 Leachate equalization Leachate in garbage pond 606 80 Back-ejecta 526 Incinerator Loss 25 75 (Reverse osmosis rinsing Leachate treatment water) 80 (Reverse osmosis rinsing station 656 water)

Tap water Loss 41.5 Enter into 156.5 effluent processing plant in new 41.5 Water used for blending in brick 684 developed area for centralized Loss 7 processing after 35 28 processed by Tap water municipal waste pipe net

Fig. 3.4-1 Water Balance Diagram of Existing Projects (Unit: T/D)

63 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

3.5 Discharge Conditions of Main Pollutants Analyze pollutants discharge condition of existing projects in line with acceptance data of Phase Project in 2009 and routine monitor data after stable operation of existing sanitary installation of Phase Project and Phase Project in Oct, 2010.

3.5.1 Atmospheric Pollutants Discharge Conditions 1Controlled waste gas Existing projects use the methods of SNCR denitration + semi-dry process deacidification + active carbon adsorption + bag type dust exhaust system to treat incineration flue gas. The acceptance and monitoring time of incineration flue gas from Phase Project is from 9th Jul to 10th Jul in 2009, three times per day, and the data area is shown in Table 3.5-1.

Table 3.5-1 Acceptance and Monitoring Data of Atmospheric Pollutants from Phase Project

Phase Project Product Effluent 4# incinerator 5# incinerator line concentration Effluent Effluent standard Emission Emission

mg/m3 concentration concentration Pollutants rate kg/h rate kg/h mg/m3 mg/m3

Dust <30 16.1~20.0 1.08~1.59 15.5~18.6 1.48~1.64

SO2 <260 6~11 0.76~1.43 6~12 0.81~1.54

NOX <400 167~175 21.8~24.6 166~185 20.5~22.9 HCl <50 5.1L~8.95 ~1.21 4.0L~7.99 ~0.972 fluorid <2.0 0.25~0.46 0.022~0.041 0.26~2.42 0.024~0.209 CO <100 30~35 3.88~4.82 38~47 4.7~5.6 Pb <1.6 0.011~0.111 0.002~0.015 0.001L~0.098 ~0.012 Hg <0.1 0.003L / 0.003L / Cd <0.1 0.0001L~0.0061 ~0.00083 0.0001L~0.0017 ~0.0006 Blackness <1 level <1 level <1 level of flue gas

Routine monitor data after stable operation of existing sanitary installation of

64 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited PhaseProject and PhaseProject in Oct, 2010 is shown in Table 3.5-2.

Table 3.5-2 Monitoring Concentration Table of Atmospheric Pollutants from Existing Projects (26th ~28th, Oct) Unit: mg/m3 Product Phase Project Phase Project Discharge line standard Pollutant 1#incinerator 2#incinerator 3#incinerator 4#incinerator 5#incinerator Dust 1270 1300 1390 1440 1490

SO2 0.015L 0.015L 0.015L 0.015L 0.015L

NOX 143 178 176 140 186 HCl 172 245 195 245 2080 Product fluoride 0.305 0.456 0.607 1.32 0.294 concentration CO 20.4 18.6 20.6 22 21.8 Pb 0.125 0.342 0.045 1.94 0.049 Hg 0.000376 0.000428 0.000401 0.000217 0.000081 Cd 0.03 0.068 0.044 0.138 0.049 Dust <30 4.18 4.21 4.37 4.48 4.39

SO2 <260 0.015L 0.015L 0.015L 0.015L 0.015L

NOX <400 123 164 159 113 166 HCl <50 1.78 11.4 3.06 37.2 2.86 Fluoride <2.0 0.023 0.032 0.016 0.048 0.024 Effluent CO <100 20.2 17.6 19.8 21.2 20.8 concentration Pb <1.6 0.003L 0.002 0.005 0.007 0.003 Hg <0.1 7.58×10-5L 7.58×10-5L 7.58×10-5L 7.58×10-5L 7.58×10-5L Cd <0.1 0.0004L 0.0004L 0.0004L 0.0004L 0.0004L Blackness of Flue <1 0 0 0 0 0 gas

Continued Table 3.5-2 Monitoring Concentration Table of Atmospheric Pollutants from Existing Projects (29th ~30th, Oct) Unit: mg/m3 Product Phase Project Phase Project Discharge line standard Pollutant 1#incinerator 2#incinerator 3#incinerator 4#incinerator 5#incinerator Dust 1300 1390 1350 1460 1430

Product SO2 0.015L 0.015L 0.015L 0.015L 0.015L concentration NOX 132 174 161 152 183 HCl 154 246 79.1 304 2210

65 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Fluoride 0.352 0.597 0.401 1.23 0.841 CO 20.4 22.4 21.1 20.6 20.0 Pb 0.006 0.003 0.004 0.003 0.727 Hg 0.000102 0.000107 7.58×10-5L 0.000128 7.58×10-5L Cd 0.003 0.006 0.006 0.005 0.050 Dust <30 4.23 4.07 4.39 4.32 4.16

SO2 <260 0.015L 0.015L 0.015L 0.015L 0.015L

NOX <400 119 169 155 135 176 HCl <50 11.4 30.7 2.37 1.74 1.53 Fluoride <2.0 0.026 0.015 0.029 0.018 0.122 Effluent CO <100 19.6 21.6 20.3 19.6 19.7 concentration Pb <1.6 0.003 0.003L 0.003L 0.003L 0.003L Hg <0.1 7.58×10-5L 7.58×10-5L 7.58×10-5L 7.58×10-5L 7.58×10-5L Cd <0.1 0.0004L 0.0004L 0.0004L 0.0004L 0.0004L Blackness

of <1 0 0 0 0 0 exhaustion

In accordance with acceptance data and supplementary monitor date of Phase Project, acceptance data of PhaseProject and the sampling analysis conducted by Center for Environmental Quality Test, Tsinghua University in 2010, the monitoring date of effluent concentration of dioxin-like compounds is shown in Table 3.5-3.

Table 3.5-3 Effluent Concentration Table of Dioxin-Like Compounds from Existing Projects Unit: TEQng/m3 Product line Phase Project Phase Project

1#incinerator 2#incinerator 3#incinerator 4#incinerator 5#incinerator Monitoring time Acceptance of

PhaseProject in <0.020 / / 2006 Supplementary 0.052 monitor in 2007 Acceptance of

Phase Project 0.068 0.066 in 2009

66 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Routine monitor in 0.017 0.0071 0.014 0.0079 0.0067 2010

In accordance with acceptance and monitor report of Phase Project, the discharge of atmospheric pollutants from existing projects is shown in Table3.5-4.

Table 3.5-4 Discharge Amounts of Atmospheric Pollutants Amount ratified in Acceptance and Category Name environment impact monitoring discharge assessment (t/a) amount (t/a)

Dust 48.21 38.08 SO 247 18.17 Waste gas 2 NOx 694.1 362.3 HCl 19.29 10.91

Dioxin 0.3855gTEQ 0.19g

2Discharge condition of fugitive gas The factory boundary in organizing monitoring results of acceptance of Phase Project from 9th to 10th July., 2009 are shown in Table 3.5-5. Since 30% transporters in Suzhou are unclosed transporter, those leachate dropped to roads before transporters enter into plant and then are vaporized into air, as a result, the odor concentration level at factory boundary exceeds standards. By enhancing the frequency of watering and cleaning in roads and full implementation of garbage compression and sealing transportation, the odor concentration level at factory boundary came up to the standards during 10th ~11th Sep. in 2009 when repetition measurement was carried out.

Table 3.5-5 Factory Boundary Concentration of Gas from Fugitive Source in the Acceptance Monitoring of Phase Project

Pollutant Particulate Sulfureted Odor concentration Ammonia (dimensionless) matter hydrogen (mg/m3) Monitoring (mg/m3) (mg/m3) 9th~10th, Jul 10th~11th,Oct site Up wind 0.28~0.36 0.08~0.24 0.001L~0.004 <10~32 <10 Down wind 1 0.49~0.57 0.07~0.16 0.001L~0.006 <10~52 <10 Down wind 2 0.47~0.55 0.08~0.33 0.001L~0.006 <10~34 <10 Down wind 3 0.47~0.55 0.07~0.25 0.001L~0.005 <10~44 <10~18

67 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Evaluation criterion 1.0 1.5 0.06 20

In accordance with routine monitor data at factory boundary during 26th ~27th Oct. 2010, the discharge condition of gas from fugitive sources is shown in Table 3.5-6. Each kind of gases from fugitive sources at factory boundary has come up to the standards.

Table 3.5-6 Monitoring Condition of Factory Boundary Concentration of Gas from Fugitive Source

Pollutant Particulate Sulfureted Ammonia Odor

matter 3 hydrogen Monitoring 3 (mg/m ) 3 (dimensionless) Point (mg/m ) (mg/m ) Up wind(G1) 0.05~0.08 0.072~0.078 0.0214~0.021 7~10 Down wind 1(G2) 0.087~0.117 0.144~0.231 0.03~0.033 13 Down wind 2 (G3) 0.113~0.147 0.09~0.306 0.023~0.036 7~10 Down wind 3(G4) 0.07~0.087 0.134~0.257 0.036~0.044 8~14 Evaluation criterion 1.0 1.5 0.06 20

The fugitive discharge monitoring points at factory boundary are shown in Fig. 3.1-1.

3.5.2 Discharge Condition of Aquatic Pollutants During acceptance monitoring period of Phase Project, there was a small part of leachate back-ejecta and the surplus was transported into effluent treatment plant in new developed area by connecting-pipe after processed by leachate treatment station in Qizishan Mountain domestic waste landfill. Domestic sewage has been transported to effluent treatment plant in new developed area by connecting-pipe after processed in cesspool. The drainage cooling system has been comprehensively used for cooling slag dragging machine and flushing cinder, no waste water drained outward. The drainage from boiler system has been comprehensively used for greening, street watering after simple neutralized and no waste water drained outward. The drainage from chemical water treatment station has been comprehensively used for wash water of tipping stage and cool slag dragging machine, no waste water drained outward. The outlet concentration of leachate tank and domestic sewage

68 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited during 9th~10th Jul. 2009 are shown in table 3.5-7. The concentration of ammonia nitrogen in domestic sewage is higher than connecting-pipe standards in a certain range, but has come up to the standards in repetition measurement during 9th ~10th Sep.

Table3.5-7 Acceptance Monitoring Condition of the Concentration of Waste Water Pollutants Connecting-pipe Leachate tanker Domestic Pollutant Unit standard of sewage outlet sewage outlet plant in new district

pH dimensionless 7.29~7.78 7.1~7.46 6~9 24.0~36.6/ Ammonia nitrogen mg/L 1430~1520 35.0 1.62~16.5 Total phosphorus mg/L 79~212 3.1~3.71 8.0 Suspended substance mg/L 2280~2360 50~90 400 319~385/ COD mg/L 42100~47400 500 55.8~187 BOD mg/L 2420~3050 154~188 300 Petroleum mg/L 1.57~6.25 20 Total mercury mg/L 0.00099~0.00146 0.05 Total chromium mg/L 0.237~0.346 1.5 Hexavalent chrome mg/L 0.092~0.103 0.5 Total arsenic mg/L 0.034~0.0474 0.5 Total plumbum mg/L 0.12~0.14 1.0 Total cadmium mg/L 0.002~0.004 0.1 Animal and mg/L 8.65~11.6 100 vegetable oils

LAS mg/L 1.84~3.5 20

Note: data of ammonia nitrogen and COD in domestic sewage were monitored for two times: first/repetition monitoring.

The supporting leachate processing plant of existing projects in Everbright factory was started in Jul. 2009, completed and begun debugging in May 2010 and put into operation in Sep. 2010. A little leachate of existing projects had backed into furnace and the amount of back-ejecta is around 80t/d according to operation data in 2010; the surplus along with domestic sewage was transported into sewage plant in

69 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited new district by connecting-pipe after processed by matching leachate pre-treatment station. The routine monitoring data of environmental protection facilities of Phase Project and Phase project after stable operation is shown in Table 3.5-8.

Table 3.5-8 Routine Monitoring Condition of Concentration of Waste Water Pollutants Leachate process station Domestic Standard Pollutant Unit inlet outlet sewage outlet value

Ammonia nitrogen mg/L 1010 5.40 8.89 35.0 Total phosphorus mg/L 48.5 6.87 2.61 8.0 Suspended mg/L 1800 18.0 132 400 substance

COD mg/L 26000 118 98.3 500 BOD mg/L 9000 38.6 26.5 300 Petroleum mg/L 6.13 0.963 20 Total mercury mg/L 0.02L 0.02L 0.05 Total chromium mg/L 0.789 0.004 1.5 Hexavalent chrome mg/L 0.012L 0.012L 0.5 Total arsenic mg/L 0.03L 0.03L 0.5 Total plumbum mg/L 1.69 0.03L 1.0 Total cadmium mg/L 0.045 0.003L 0.1 Animal and mg/L 1.57 100 vegetable oils

LAS mg/L 0.342 20

In accordance with acceptance monitoring report, the discharge condition of aquatic pollutants in existing projects is shown in Table 3.5-9.

Table 3.5-9 Discharge Amounts of Aquatic Pollutants Amount ratified by Acceptance and Category Name environment impact monitoring discharge assessment(t/a) amount(t/a) Amount of Waste water 104590 85500 waste water (amount of waste water COD 89.96 34.16 connecting-pipe) SS 37.17 4.41 NH3-N 3.5 2.38

70 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

3.5.3 Noise Emission Condition The monitoring results of noise at factory boundary during Phase Project acceptance in 9th ~10th Jul. 2009 is shown in Table 3.5-10. Because of the influence of cooling tower and fan, there are two monitoring points exceeded in day-time and four monitoring points exceeded in night-time. But there are no noise-sensitive points within 400 meters out of plant, and no residents can be disturbed.

Table 3.5-10 Acceptance Monitoring Results of Noise at Factory Boundary Unit: Db A

Monitoring Day-time Night-time Monitoring point location site 9th,Jul 10th,Jul 9th,Jul 10th,Jul Northwest of factory N1 74.9 74.2 71.6 71.5 boundary

N2 North of factory boundary 74.5 74.2 73.2 73.0 Northeast of factory N3 58.6 58.1 54.2 54.4 boundary

N4 East of factory boundary 51.2 50.8 48.9 49.2 Northeast of factory N5 50.4 50.1 47.1 47.5 boundary

N6 North of factory boundary 55.9 54.7 53.4 52.8 Northwest of factory N7 61.7 61.2 59.5 58.4 boundary

N8 West of factory boundary 60.5 60.9 57.4 58.0 Standards 65 55

Under failure free operation condition of our factory on 28th Oct. 2010, the monitoring data of noise around all factory boundary showed that noise at factory boundary both in day-time and night-time had came up to the requirements of three classes standards of the Emission Standard for Industrial Enterprises Noise at Boundary (GB12348-2008).

Table3.5-11 Routine Monitoring Data of Noise at Factory Boundary Unit: Db (A)

71 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Monitoring point Monitoring site Day-time Night-time location Southwest of factory N1 59.7 53.3 boundary West of factory N2 60.6 54.1 boundary Northwest of factory N3 63.8 54.6 boundary North of factory N4 54.5 49.8 boundary Northeast of factory N5 58.4 53.5 boundary East of factory N6 60.9 54.4 boundary Southeast of factory N7 64.5 53.6 boundary South of factory N8 60.8 53.1 boundary Standards 65 55

Table 3.1-1 shows positions of acceptance monitoring points and routine monitoring points of noise at factory boundary. It is reported that leachate treatment station had not been completed when being checked and accepted, so noise monitoring points of west of factory boundary have located nearby cooling tower, as a result, the acceptance results exceeded standards. The location of factory boundary noise monitoring points when routine monitoring is different from the location when acceptance monitoring, leachate treatment station can decrease the noise of cooling tower.

3.5.4 Discharge Condition of Solid Pollutants Solid wastes include slag, fly ash and in plant domestic waste. In line with requirements of environment impact assessment and Standard for Pollution Control on the Domestic Waste Incineration GB18485-2001, the way to deal with slag of existing projects is to make bricks by comprehensive utilization in matching brick yard; fly ash and active carbon should be processed safely in Suzhou Dangerous and Waste Landfill; the collected inplant domestic waste should be processed by garbage

72 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited incineration line directly. In accordance with monitoring data, the loss on ignition of slag incineration during Phase Project acceptance in 9th ~10th Jul. is from 0.36% to 0.62%, and that of slag incineration on 28th, 30th Oct. 2010 is from 0.981% to 4.36% which came up to the standards of less than 5% according to Standard for Pollution Control on the Domestic Waste Incineration (GB18485-2001).

3.5.5 Discharge Amount Statistics of the Three Wastes In accordance with acceptance monitoring report of Phase Project , the discharge amount of atmospheric pollutants in existing projects are shown in Table 3.5-12.

Table 3.5-12 Discharge Amounts of Pollutants in Existing Projects Amount ratified by Discharge amount Category Name environment impact t/a assessment(t/a)

Dust 38.08 48.21 SO 18.17 247 Waste gas 2 NOx 362.3 694.1 HCl 10.91 19.29 Dioxin 0.19g 0.3855gTEQ Waste water Waste water amount 85500 104590 (amount of waste COD 34.16 89.96 water SS 4.41 37.17

connecting-pipe) NH3-N 2.38 3.5

Slag 0 0 Industry waste Fly ash and active 0 0 residue carbon Domestic waste 0 0

3.6 Official and Written Reply of Existing Projects and Implement Condition of “Three-meanwhile” Policy By contrast with the official and written reply of Phase Project (Suzhou Environment Management [2003] No. 229) and the official and written reply of Phase Project (Environment Audit [2008] No. 25), the construction condition of existing projects and the condition of sanitary installation is shown in Table 3.6-1.

73 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 3.6-1 The Official and Written Reply of Environment Impact Assessment of Existing Projects and the Implement Condition of Sanitary Installation Official and written reply of environment impact Implementation condition of No. Compliance assessment sanitary installation Phase Project Suzhou Municipality environment No hazardous waste could be mixed with domestic sanitation division should take waste to burn. Suzhou Municipality should carry charge of implementing and making 1 out overall sorting of garbage as soon as possible to Consistent sure that no hazardous waste should avoid hazardous waste mixed with domestic waste be mixed with domestic waste to so as to take best advantage of resource utilization. burn. In accordance of the requirements of “distribution of rain and sewage, diverting waste water from clean water” to construct drainage In accordance of requirements of “distribution of system in plant site; enhance rain and sewage, diverting waste water from clean water-saving measurements and all water ” to construct drainage system in plant site; of industrial waste drainage should The way to enhance water-saving measurements and all be utilized in cyclic; domestic process industrial waste drainage should be recycled; sewage should be processed in 2 leachate is domestic sewage should be treated in effluent effluent treatment plant in new different from treatment plant in new district. Garbage storehouse developed area. Garbage storehouse the replied way should be equipped with leachate collecting device; should equipped with leachate all leachate should be burned without outward collecting device, little leachate drainage. can be back-ejecta and surplus enter into effluent treatment plant in new developed area after being pre-processed in plant and having come up to the standards. Take high-efficient measurements to remove dust, Take high-efficient measurements to desulfurize and denitrate and to wash and adsorb to remove dust, to desulfurize and pollutants like dioxin, HCL and HF, making sure denitrate and to wash and adsorb 3 Consistent that concentration of atmospheric pollutants can pollutants like dioxin, HCL and HF, come up to the standards; make further make sure that the concentration of argumentation of treatment scheme of dioxin and atmospheric pollutants can come up

74 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Official and written reply of environment impact Implementation condition of No. Compliance assessment sanitary installation heavy metal which are presented in report and to the standards. accident pre-warning and countermeasure of this treatment scheme in the chapter of preliminary design on environment protection, if necessary, more credibility and efficiency alternative scheme should take into account. Arrange block planning of plant site reasonably, Take advantage of denoise high-noise device should be installed far away from measurements like silencing and factory boundary and take advantage of denoise 4 sound insulation to ensure the noise Consistent measurements like silencing and sound insulation to of factory boundary can come up to ensure that the noise of factory boundary can come the standards. up to the standards. Formulate differentiate and management system on Disposal site of fly ash is located at clinker and safely landfill of fly ash and clinker Everbright Environment Protection belonged to hazardous waste should put into effect; (Suzhou) hazardous solid waste 5 enhance the environment management of storage Consistent landfill. Transport fly ash to this and transportation and outward transportation, landfill by truck, solidify and then construct inplant temporary field(storage) of clinker landfill. in line with requirements of standards. In accordance with the requirements of the Setting of Pollution Discharge Outlet and Office Procedure Install all kinds of pollution of Renovate Standard in Jiangsu Province (Suzhou discharge outlets in line with 6 Environment Control [1997] No.122 ) to install all requirements, no signs. Chimney Consistent kinds of pollution discharge outlets and signs. should be equipped with permanent Chimney should have permanent sampling hole and sampling hole. equipped with sampling monitoring platform. In accordance with the requirements of Greening Standards of Urban Settlement and Organization in Jiangsu Province (DB32/139-95), design greening Percentage of coverage of greenbelt 7 scheme reasonably within plants, construct factory Consistent in plant is 30%. boundary greenbelt with trees like tall arbor, and percentage of coverage of greenbelt in plant should be not less than 30%. Enhance knowledge education on safety in Formulate corresponding risk 8 production for employees, carry out responsibility prevention and emergency Consistent system of safety in production, and formulate risk treatment scheme.

75 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Official and written reply of environment impact Implementation condition of No. Compliance assessment sanitary installation prevention and emergency treatment scheme. Organize some activities for In accordance with the requirements of “Opened promoting friendship with Factory Information”, inform corresponding corresponding resident 9 residents about information of environment Consistent nonscheduled to introduce management and the environment quality around condition of environment plant site once per year. management. Request Center for Environmental Paying great attention to the pollution of dioxin, we Quality Test, Tsinghua University to should monitor the concentration of dioxin track and monitor concentration of 10 Consistent periodical in line with requirements of environment dioxin in 2010 and the results has protection department when everything is ready. been kept in the archives and be put on records. Phase Project Take low noise measurements for cooling tower and get done with greening in administration quarter before trial production of Phase Project , take advantage of plane Reform some issues in existing projects such as figure of Phase Project to factory boundary noise nearby cooling tower is enlarge factory boundary to higher than standards, scarce capacity to make lime decrease noise. Add a set of lime The way to cream and the way to process leachate immediately cream preparation device in Phase process 1 to meet requirements of laws and regulations and Project which used for leachate is criterion on environment protection; complete sweetening treatment of incinerator different from leachate treatment plant on schedule. All remarks in Phase Project. Build leachate that in the reply are one of necessary conditions of trial production back-ejecta station to make part of of these projects. leachate back-ejected, surplus should enters into sewage disposal works in new district by connecting-pipe after processed by supporting leachate treatment station in Everbright factory. Use domestic waste collected in a unified way by Use domestic waste collected by 2 Consistent environment protecting departments as fuel, process refuse transfer stations as fuel and

76 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Official and written reply of environment impact Implementation condition of No. Compliance assessment sanitary installation other industrial waste medical waste and hazardous no industrial waste, medical waste waste except domestic waste is forbidden. or hazardous waste is accepted. Invest 14,350,000 on five incinerators of Phase Project and two used for fume denitrification and adopts SNCR Using following methods to control smoke denitration which use ammonia as pollutants: remove nitric oxides by selective reducer. Make sure residence time catalytic reduction SCR), remove acid gas in flue of incinerating gas is not less than gas by neutralization with semi-dry process, two seconds in condition when providing high efficiency bag dust collector and temperature is not less than 850℃. active carbon sprayer to adsorb and remove more Incinerating gas should be dioxin-like compounds and heavy metal. Make sure discharged through 80m-height residence time of fume is not less than two seconds chimney after processed by in condition when temperature is not less than semi-dry process deacidification + 850℃. Two incinerators share one 80m height active carbon adsorption + bag chimney to exhaust smoke. Further optimize design filter. The concentration of of incinerator, the removal rates of smoke pollutants pollutants should meet the 3 Consistent in incinerator should not less than the requirements requirements of Standard for presented in the report. Monitor combustion Pollution Control on the Domestic temperature, carbon monoxide, oxygen content in Waste Incineration incinerator and to measure the dosage of active (GB18485-2001), and dioxin carbon along with local environment protection should refer to and carry out the departments. Follow the requirements of Standard emission limit in Directive for Pollution Control on the Domestic Waste 2000/76/EC Of the European Incineration (GB18485-2001) to discharge smoke Parliament and of the Council on pollutants, and dioxin should refer to and carry out the Incineration of Waste the emission limit in Directive 2000/76/EC Of the (0.1ngTEQ/m3). Monitor European Parliament and of the Council on the combustion temperature, carbon Incineration of Waste (0.1ngTEQ/m3) monoxide, oxygen content in incinerator and to measure the dosage of active carbon together with local environment protection departments. Conscientiously implement control measurements Adopt enclosed design in garbage 4 Consistent of dust nuisance and odor in the process of tipping stage and garbage transport

77 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Official and written reply of environment impact Implementation condition of No. Compliance assessment sanitary installation collection, transportation and storage of domestic system, refuse storage pond and waste, adopts enclosed design in refuse tipping refuse transport system should be stage and refuse transport system, refuse storage operated in negative pressure, the pool and refuse transport system should be operated structure used for process leachate in negative pressure, the structure used for process shall be equipped with sealing leachate shall be equipped with sealing system. system. The fugitive discharge Un-organization discharge atmospheric pollutants at atmospheric pollutants at factory factory boundary should follow the requirements of boundary should follow the Integrated Emission Standard of Air Pollutants requirements of Integrated (GB16297-1996) and discharge odor pollutants Emission Standard of Air Pollutants should follow the requirements of Emission (GB16297-1996) and Emission Standards for Odor Pollutants (GB1455493) Standards for Odor Pollutants (GB1455493) According to the principles of “distribution of rain “Distribution of rain and sewage, and sewage, diverting waste water from clean diverting waste water from clean water” design, construct and improve drainage water”, part of leachate and wash system in plant site and to increase the utilization water of tipping stage is rate of water. Process water based on water quality, back-ejecta, surplus connect to part of leachate and wash water of tipping stage is effluent treatment plant in new back-ejecta, surplus connect to effluent treatment district for centralized treatment plant in new developed area for centralized along with domestic sewage after 5 treatment along with domestic after pre-processed Consistent being pre-processed respectively respectively and has come up to connecting-pipe and having come up to standards. Other waste water should be recycled connecting-pipe standards, after being pre-processed and having come up to concentration of connecting-pipe quality requirements of reuse water without can meet three classes of Integrated draining outward. No outlet can be set in plant. Waste Water Discharge Standard Connecting-pipe standards follows three level of (GB8979-1996). Surplus waste Integrated Waste Water Discharge Standard water should be utilized cyclical. (GB8979-1996) Optimize plane arrangement of plant site, install Optimize plane arrangement of high-noise device reasonably. Choose low-noise plant site, choose low-noise device, device to decrease source intensity of noise of those adopts measurements like sound 6 Consistent devices. Carry out noise reduction measurements insulation and noise elimination to like sound insulation and noise elimination on make factory boundary noise meet high-noise devices. The intensity of noise at factory three classes of Emission Standard

78 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Official and written reply of environment impact Implementation condition of No. Compliance assessment sanitary installation boundary should meet three classes of Standard of for Industrial Factories Noise at Noise at Boundary of Industrial Factories Boundary (GB12348-2008) (GB12348-90) and avoid noise problems. In strict accordance with the relevant regulations, treat and dispose solid waste by sorting, and achieve “recycle, reduction and safe”. Incineration fly ash, after being treated, should be processed as hazardous waste by certain organizations which Incineration fly ash should be land have qualifications to process hazardous waste after filled safely after solidification 7 solidification processed, and the measurements to processed by Suzhou hazardous Consistent collect; store and transport those waste should waste landfill. Comprehensively follow relevant government regulations of Standard utilize slag. for Pollution Control on Hazardous Waste Storage (GB18597-2001). Avoid other industrial solid waste bringing secondary pollution based on overall comprehensive utilization. Implement precautionary measure of environment risk and emergency preplan and install leachate Implement precautionary measure of environment adjusting tank with total capacity of risks; draw up environment risk emergency preplan. 11,000 m3. Take strict antiseepage Install leachate adjusting tank with adequate measurement on refuse storage pit, capacity to avoid discharge without be processed. leachate collection pool and sewage Take strict antiseepage measurement on garbage treatment station, set up storage pit, leachate collection pool and sewage 8 groundwater monitoring points to Consistent treatment station, set up necessary groundwater monitor the quality of groundwater monitoring points to monitor the quality of periodical. Blowout the furnace as groundwater periodical. Implement the need of production and pollution-prevention measures of exhaust pollution accident, foul gas in garbage when abnormal operation mode appears or during storehouse can be processed by maintenance. deodorization device located at incinerator by blower and then discharged. Cooperate with local government to make a good No sensitive buildings like school 9 control job of stand-off distance of projects, ensure and residential area within the Consistent no sensitive buildings like school and residential scope of stand-off distance. Pay

79 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Official and written reply of environment impact Implementation condition of No. Compliance assessment sanitary installation area within the scope of stand-off distance. Pay attention on opinions of the mass abundant attention on opinions of the mass and and relevant propaganda and relevant propaganda and explanation shall be well explanation shall be well done. done. We commit Zhejiang Province Environmental Monitoring Center to monitor concentration of dioxin Set up a monitoring point to monitor the in atmosphere at nearest sensitive concentration of dioxin in atmosphere at nearest point of down-wind of predominant sensitive point of down-wind of predominant wind wind direction and the high ground direction within plant site and the high ground concentration point within plant site concentration point respectively. Set up a and concentration of dioxin in solid monitoring point to monitor the concentration of at up-wind and down-wind of dioxin in soil at up-wind and down-wind of predominant wind direction within 10 predominant wind direction within plant site plant site respectively before debug Consistent respectively before debug incinerator. The results incinerator. The results should be should be presented to Jiangsu Environmental presented to Jiangsu Environmental Protection Department and put on records. After the Protection Department and put on projects having been put into operation, we should records. After the projects having have a good job of tracking and monitoring of the been put into operation, we commit concentration of dioxin and the result should be put Center for Environmental Quality on records. Test, Tsinghua University to track and monitor the concentration of dioxin and the results should be put on records. Follow the relevant government regulations to install normative Follow the relevant government regulations to pollutants outlet and storage install normative pollutants outlets and storage (treatment) area, install on-line (treatment) area, install on-line continuous 11 continuous monitoring device of Consistent monitoring device of flue gas and smoke, sulfur fume and smoke, sulfur dioxide, dioxide nitric oxides with local environmental nitric oxides with local protection department. environmental protection department.

The main difference between implement condition of existing projects and the

80 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited original environment impact assessment report and its official and written reply is the way to process leachate: the back-ejecta of all leachate cannot put into practice in mechanical efficiency furnace; when conducting the environment impact assessment of Phase Project , leachate was pre-processed by leachate treatment plant of Qizishan Mountain domestic waste landfill, the Everbright factory has completed the matching leachate pre-treatment station, and this station can avoid environment risk when transporting leachate and low down potential impact to environment.

3.7 Main Environment Problems of Existing Projects To sum up, the sanitary installation completed by Everbright Environmental Protection Energy (Suzhou) Co., Ltd. are complete and all in good condition, and the waste water, waste gas and noise from existing projects can come up to the standard to discharge. Treatment of solid waste is reasonable and has achieved zero discharge. At present, the way to process fly ash is solidification treatment in hazardous waste landfill. Considering there has risk accidents during transportation, transport fly ash after solidification and chelate can meet the requirement of environment protection better.

3.8 The Measures of “Using New Method to Improve Old One” Bing aimed at above problems and further management requirements of environment protection arise in the operation of factory, Everbright Environmental Protection Energy (Suzhou) Co., Ltd. will take following steps of “using new method to improve old one” as well as enlarge Phase : 1Solidification and chelate of fly ash within plant site;

2Improve combustion control system—control the stirring times of fire grate, decrease output of smoke of waste gas by control air leakage strictly and low current velocity of exhaust gas; 3Ensure that discharge concentration of exhaust can come up to EU 2000 Standard by choosing hop-pocket remove dust efficiently, cleaning and sootblowing; 4Add dry process deacidification system to further decrease the output of acid fume like HCl in exhaust by injecting lime slaking in flue before the exhaust has entered into hop-pocket;

81 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 5Upgrade reconstruct project for leachate process station, and add advanced treatment technological of “nanofiltration + reverse osmosis”.

82 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

4 Engineering Analysis of Phase Expansion Project

4.1 The Necessity of Phase Expansion Project

In accordance with the Professional Plan of Suzhou on Environmental Hygiene (2006-2020) (Approved by Department of Construction of Jiangsu Province in 2007), it is expected that the overall output of domestic waste of Jiangsu Province will reach 3,390 t/d in 2010 and 4,740 t/d in 2020, for details see Table 4.1-1.

Table 4.1-1 Prediction Table of Garbage Amount of Suzhou City Year 2010 Year 2020 Quantity Quantity Quantity Quantity Area Name per capita per capita per capita per capita kg/p.d t/d kg/p.d t/d Inner city and Wuzhong Urban Area 1.23 1270 1.23 1310 Downtown Inner ring area of Suzhou Area Beltway Highway 0.98 1740 1.14 2910

Subtotal - 3010 - 4220 Outer ring area of Suzhou Beltway Highway 0.86 350 1.05 460

Scenic Areas 0.4 30 0.5 60 Total - 3390 - 4740

According to the Information Bulletin on Prevention and Control of Environmental Pollution by Solid Waste of Suzhou City (Year 2009) issued by the Municipal Environmental Protection Bureau in Jun. 2009, the output of domestic waste of Suzhou City in 2009 is 1,554,300 tons (about 4,258 t/d) which has far exceeded 3,390 t/d, the output of domestic waste of 2010 predicted in Professional Planning of Environmental Sanitation in Suzhou City (2006-2020). At present, however, the in the Phase and Phase projects of Everbright Environmental Protection Energy (Suzhou) Co., Ltd, the garbage disposal capacity is

83 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited about 2,580t/d, and the average amount of garbage entering incinerator after removing the high moisture content 20.08% (amount of leachate from garbage dump where garbage is kept) reaches 2,090 t/d, slightly more than designed operating load; Phase of Qizishan Refuse Landfill Site in Suzhou City with a storage capacity of 4.7 million cubic meters has been filled up. After vertical pile expansion on former address in 2009, the storage capacity is increased by 7.8 million cubic meters (which is expected to serve 16 years and the designed disposal capacity is about 1,600 t/d). As the domestic waste output increases with years, the burden of Qizishan Refuse Landfill Site and Everbright Garbage Incinerator Plant has become more and more heavy, and the capacity of existing garbage disposal facilities cannot meet the needs of social life. As the only garbage landfill in Suzhou City, if Qizishan is filled up, the garbage disposal in Suzhou City will be a great problem, and it is impossible for Suzhou to find another land suitable for dumping garbage at present. When the time comes, it will inevitably cause a scene of garbage siege. Therefore, it is very necessary for Everbright Environmental Protection Energy (Suzhou) Co., Ltd to carry out its Phase Expansion Project.

4.2 Basic Composition of Phase Expansion Project

Table 4.2-1 Basic Components of Phase Expansion Project

Phase Expansion Project of Domestic Waste Incinerating Power Project of Project Name Everbright Environmental Protection Energy (Suzhou) Co., Ltd Construction Everbright Environmental Protection Energy (Suzhou) Co., Ltd Unit 3 sets of mechanical grate furnace, each with a designed incineration capacity of Principal Part 500t/d. The designed incineration capacity of Phase is 1,500t/d; of the Project Two 15MW condensing turbo-generator sets; dump pit with a volume of about 22,150 m3. An annual power generation of 194.9 million KWh, 18% of which for station Products Plan service, and the power sent into grid is expected to reach 156 million KWh. Comprehensive Auxiliary Relying on the existing block production line, with an utilization system of Projects annual production expected to be 35,000 m3 Slag

84 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Relying on existing processing capacity, the maximum leachate production capacity of this project in summer is Leachate treatment 480 t/d. The leachate treatment station adds an advanced plant treatment technology of “nanofiltration + reverse osmosis” for upgrading and reconstruction, after which, the waste water can be reused. Fly-ash One set of cement solidification system with a processing solidification capacity of 15 t/h shall be constructed in the hazardous workshop waste landfill. This system consists of motor truck scale, discharging platform, garbage discharge doors, dump pit, garbage grinder and garbage feeding grabs, of which, the garbage Garbage discharge discharge doors number 6 and are of hydraulic type; the and supply system dump pit can store 8,860 tons of garbage which approximates the storage volume of 6 days; the grabs total 3 (one of them is standby). Set one 1,200 m3 leachate reservoir under the garbage Public Leachate reservoir dump pit, which can store leachate of about 2.5days. auxiliary Use 0# diesel fuel. This project relies on the oil tank of projects Firing system existing engineering, without constructing new ones. The salt water elimination system of boiler adopts first Chemical water level reverse osmosis + mix bed technologies, with a preparation system processing capacity of 20 t/h. Water purification Rely on the existing intakes and water purification system system. Draft cooling tower 3×3,000m3/h Air-pressure system Gas supply capacity of 3×24Nm3/min Set two fly-ash storages, each with an effective volume of 300 m3, one slag pit with an effective volume of 1,500 m3. The slag shall be sent to brickfield for comprehensive Environmental use. Construct one fly-ash solidification device in the land Ash&slag disposal protection for Phase project of hazardous waste landfill, after system projects solidification, the fly ash which pass the pollutant inspection shall be sent to the domestic waste landfill, and the fly ash which pass the pollutant inspection shall be sent to the hazardous waste landfill.

85 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited SNCR is adopted for denitration. Each incinerator connects one set of fume purification system in series, three sets of devices being arranged parallelly. The fume Fume treatment shall be treated by adopting semi-dry deacidification system tower + dry deacidification + active carbon injection system + bag dedusting. The treated fume which reaches the standards shall be exhausted through the 80m 3-tube chimney. Slight amount of leachate will be injected back to the furnace and the rest will be reused after been treated by Wastewater supporting treatment station and reaches the standards. treatment system The domestic wastewater shall be sent to wastewater disposal plant through tubes. Other factory effluent shall be reused. Dump pit adopts negative pressure. Both the primary and Deodorization secondary air needed for burning shall be taken from the System dump pits. Deodorizer shall be set. Construction RMB 750 millionincluding environmental protection investment of RMB 159.6 investment million which accounts for 21.28% of total investment. Floor Space 40 mou are newly expropriated. Number of the Another 65 persons are newly employed. staff Working Three shifts one day, eight hours one shift, 333 days (8,000 hours) one year system Note: There is no heat user around this project; therefore, the condensing units are constructed for Waste-to-Energy.

Table 4.2-2 Changes on the Main Projects after the Completion of Phase Expansion Project Before Expansion After Expansion Changes

Incinerator 3×350t/d+2×500t/d 3×350t/d+2×500t/d +3×500t/d Expansion Expansionpower Condensing Power Output: Power Output: output will Principal part turbo-gener 281,024,500 KWh 475,924,500 KWh increase of the project ator set 194,900,000KWh Garbage 16,000m3+15,000m3 16,000m3+15,000m3+22,150m3 Expansion dump

86 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Comprehen sive Annual production Based on the Annual production of utilization of 40,000-50,000 m3 existing block 75,000-85,000 m3 block system of block production line Slag Based on the Auxiliary Leachate Leachate treatment existing station, The treatment capacity reaches Projects treatment capacity of about carry out designed scale, 1,000t/d. station 509t/d upgrading and reconstruction Rely on the Add one set of cement Fly-ash hazardous waste solidification system with a solidificatio Newly Constructed landfill for treatment capacity of 15t/d in n workshop solidification hazardous waste landfill. Adopt 0#diesel oil, Firing Adopt 0#diesel oil, one 20m3 Based on the one 20m3 oil System oil reservoir. existing system reservoir. Chemical Public water 2×20t/h 3×20t/h Expansion auxiliary treatment projects Draft 3 3 3 cooling 6,800 m /h+7,000 6,800 m /h+7,000 m /h+9,000 Expansion m3/h m3/h tower Air Expansion 5×24 m3/min 8×24 m3/min compressor 5 sets of waste gas treatment devices, the fume is treated 8 sets of waste gas treatment by adopting SNCR devices, the fume is treated by denitration + Environmental adopting SNCR denitration + semi-dry protection semi-dry deacidification tower Expansion Waste gas deacidification projects + dry deacidification + active tower + dry carbon injection system + bag deacidification + dedusting. active carbon injection system + bag dedusting.

87 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

The leachate shall The leachate treatment station be piped after been adds a advanced treatment treated through technology of “nanofiltration + supporting treatment reverse osmosis” for upgrading The leachate shall plant Waste and reconstruction, after which, be reused after Domestic water the waste water can be reused; treatment and will wastewater shall be Domestic wastewater shall be be not discharge. piped piped; Other factory Other factory wastewater shall wastewater shall be be reused. reused.

4.3 Overview on the Geographic Positions of the Plants The project of generating power from waste incineration of Everbright Environmental Protection Energy (Suzhou) Co., Ltd is located at foot of Qizishan to the southeast of Mudu Town in Wuzhong District in Suzhou City, about 5.5 km away from Mudu Town and 13 km from the main city zone of Suzhou City. The Phase expansion project is located at south of the existing Phase and Phase projects, facing Qizishan to the south; 200 m east away from the project are Qizishan refuse landfill and Suzhou Hazardous Waste Landfill; Wuzhong Solid Waste and other environmental protection enterprises at the west. The geographic positions of plants are shown in Fig.2.1-1 and the ambient environment of the plants is shown in Fig.4.3-1.

4.4 Overview on Land Occupation and Plan Layout of the Plants The Project is located on the south of the existing plant, with an acquired area of 27,681 m2. The acquired land is primarily the flat land before Qizhishan and now covered by a small amount of shrubs and weeds. The general information on land occupation of phrase expansion projects is shown in Table 4.4-1.

Table 4.4-1 General Information on Land Occupation Items Value Remarks

Plant area 27,681 m2

88 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Floor space of buildings and 18,911.5 m2 structures

Building density 54.7% Calculate area with floor area 26,471.4 m2 ratio

Floor area ratio 0.88% Area of roads (including 49,01.3 m2 parking area)

Greening area 8,757 m2 Rate of green coverage 30% Length of enclosing wall 500m

Giving consideration to the requirements of production technology, transportation, fire prevention, environment protection, sanitation, construction and life, etc., combining the landform, geology, weather and other natural conditions of the plant and partly relying on the existing publish and auxiliary projects, the general arrangement plan of the plant has made overall arrangement for all building, structures, pipelines and transportation routes, striving for reasonable and compact arrangement, safe and economical operation and being easy for overhaul. The plane layout of the plant is shown in Fig.4.4-1. The general physical arrangement goes as follows: 1Major producing area of Phase The major producing area is main machine hall where the garbage discharging platform, garbage dump pit, boiler incineration room, main control building, steam turbine room and power house are combined, with internal functions clearly assigned and interference-free. The trucks for transporting garbage pass in and out from the materials entrance. 2Production supporting area of Phase The production supporting area mainly includes cooling tower, fly ash solidification workshop and chemical water treatment station, etc. This area is located outside the major producing area and the air compressor station is located inside the main machine hall. Oil tank, leachate treatment station and so on rely on the existing projects and need no additional construction. Office area and living area rely on the existing projects and need no additional construction.

89 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited In addition, there are green belts on both sides of roads and around the buildings in the plant to reduce the influence of noise and odor on the environment. The plane layout of the plant shall give attention to requirement of landscape for demonstrating the modern, green and environmental corporate image.

4.5 Overview of Projects and Equipment

4.5.1 Overview and Construction Schedule of the Project This project is to construct 3 sets of 500 t/d incineration systems and 2 sets of 15MW Waste-to-Energy systems which is used to produce medium-temperature medium-pressure superheated steam (400℃, 4.0MPa) by adopting technology of generating power from garbage incineration in mechanical grate furnace, and assorted condensing steam turbine set. The process technology is the same as that of the existing project. The construction schedule of this project is shown in Table 4.5-1.

90 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 4.5-1 The Progress Schedule of the Project

Working timemonth No. Project Name 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 Project demonstration and previous work Compilation and approval of the report on 2 environmental impact assessment

3 Compilation and approval of the project declaration

4 Preliminary design and examination

5 Construction design

6 Land-leveling operation

7 Equipment purchase/processing and manufacturing

8 Civil engineering

9 Equipment installation

10 Verification in cool state for equipment

11 Verification in thermal state for equipment

12 Final acceptance

91 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 4.5.2 Technological Flow Like the existing engineering, this project still adopts reciprocating grate incinerator. The whole process system consists of garbage crushing system, garbage feeding system, auxiliary fuel supply system, incineration system, fume purification treatment system, slag draining system, ash&slag integrated processing system, steam-water system, instrumentation control system, chemical water treatment system, electrical control system, steam turbines and power generation system, air cooling system and power access system, etc. The technique flowchart of generating power from garbage incineration in this project is shown in Fig.4.5-1, and the technical process is presented as follows:

92 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Dry Deacidification

Fig.4.5-1 Technique Flowchart of Generating Power from Garbage Incineration in This Project

93 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 4.5.2.1 Fuel Receiving and Delivery System After entering the factory from materials entrance and being weighed by the weight bridge, the garbage trucks, following instruction, drive ion the garbage discharge hall to dump the garbage ion the garbage dump pit. After being mixed by grab of crane, the garbage is sent to the incinerator. View A viewing platform shall be set before the entrance of the weight bridge. The garbage trucks and the garbage in them shall meet the requirements of Agreement on Garbage Supply and Transport. The trucks which are not approved by parties, the wastes which cannot be treated according to the agreement and the non-permissive garbage which are not approved by both parties are not allowed to enter the factory. Weighing System In the current project, three sets of 50 ton weight bridges (the size of platform is 3.4×14m) are set near the materials entrance of the plant, adopting automatic electric truck scale system. The output signal of the weight bridge is connected to computer database to record time, truck number, total weights and net weight and other data. Garbage Discharge Hall The garbage discharge hall is designed for garbage trucks to drive in, drive backward, discharge and drive out as well as for urgently repairing track. The discharge hall, with ground height of 9m, top elevation of 17m, length of 116m and width of 32m, 2-3 times of the turning radius of the probable largest truck, is set with an upward driveway and downward driveway. The discharge area has no obvious control mark to conduct trucks to discharge garbage. The discharge hall is fully enclosed structure, and the door and window is designed gas tight to prevent odor from leaking out. There are wastewater-leading grooves in discharge hall, which are used for collecting the garbage leachate falling in drops when the garbage is discharged from trucks and leading the leachate into the leachate collecting pit. Then the leachate will be pumped into the leachate treatment system in the wastewater treatment station. Garbage Discharge Door The garbage dump pit is provided with 6 garbage discharge doors which is designed gas tight. The airtight construction is designed for prevent the dusts or odor from the garbage as well as mosquitoes entering the platform. After entering the

94 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited platform, the trucks will drive to the discharge door to which the control room gives a signal. Dam board shall be set before all the discharge doors to prevent the delivery trucks turning over the garbage pit. Garbage Dump Pit Covering a land of 23.7 m × 60.3 m, the garbage dump pit can store 8,860 tons of garbage, which is able to meet the demand for processing garbage about 6 days. The garbage pit is of reinforced concrete structure and of semi-underground type. The air in the pit will be pumped into the incinerator by the primary air fan above the pump pit so as to control the accumulation of odor and methane gas and keep the garbage dump pit in negative pressure. Some water will sweat out during the course of garbage storage; the garbage pit is therefore designed with a 2% longitudinal gradient which is advantageous of leading the leachate. Stainless steel sewage bar screen is installed at the bottom of the wall before the garbage pit in order to drain the leachate to the leachate pond which has an effective volume of 1,200m3 and can store the garbage leachate about 2.5days. Leachate back-injection device shall be set at the outlet of the separator. A small amount of leachate injects back and the rest part will be pumped into the leachate treatment station. Anticorrosion treatment is adopted in the garbage dump pit, leachate collection groove and leachate collection pond for fear the leachate might corrode the concrete wall. Indraft device is added in the leachate collection groove and leachate collection pond so as to inhale the foul gas into the garbage dump pit during the overhaul period. Garbage Transportation 3 sets of garbage cranes are set on the top of the garbage dump pit, each with a loading capacity of 15 tons, one of which for standby use. Set 3 sets of 10m3 hydraulic driving grabs, one of which for standby use. The standby grab is placed in the warehouse for the convenience of timely replacement. A weighing device is set on the trolley frame of the crane, providing the functions of metering, pre-alarm and overloads protection. The weighing device can also display and record various parameters of materials put into production in the crane room. The crane can feed raw materials into 3 sets of incinerators as well as convey, mix and stack transfer the garbage. The garbage shall be stockpiled in the designated area in order to ensure that the garbage as fired is mixed evenly and burns steadily. In view of the severe

95 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited environment in the garbage storage pit, the crane operators operate in the crane control room over the lateral side of the garbage storage pit. The crane is equipped with manual operation system and semi-automatic operation function and can achieve fast switching between them. Each control chair in the control room controls one lifter. In addition, one set of wireless remote controller is provided for emergencies and repair. Firing and Auxiliary Fuel Oil System The firing system of the boiler consists of the fuel oil system, main body of boiler burner, ignition device, flame detector and corresponding controller and safe protection device. The fuel oil system consists of oil tank, oil filter and oil feed pump, adopting piping-main scheme, with the oil supply and oil return main pipes close to the incinerator burner. The existing project has one buried steel oil tank with a volume of 20m3 and two oil feed pumps, one of which for standby use, with a discharge capacity of 3.6m3/h, discharge pressure of 2.5MPa and model of 3Gr42x6A. No new oil-supply system is needed to be added in this project. At ignition, both the lighting up burner and auxiliary burner shall be put into use. When the incinerator is heated to 300~400℃, withdraw the lighting up burner, and then evenly heat the hearth with auxiliary burner. When the hearth is heated to 850℃, put the garbage into it; if the calorific value of garbage is too low to make the afterburner flue gas temperature meet the requirement of “flue gas temperature ≥850℃ and retention time ≥2s”, the auxiliary burner will operate automatically, which will completely remix the hazardous materials in the fuel gas and make them meet the requirement for environmental protection.

4.5.2.2Incineration System The incinerator of this project adopts the combustion technology of slanting reciprocating pusher-type mechanical grates, and the design parameters are shown as follows:

Maximum 8,000kJ/kg Lower calorific value of the Minimum 4,200kJ/kg garbage Design point 6,700kJ/kg

96 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Annual water content ≤ 50% Annual ash content ≤ 25% Single-furnace rated treatment 500t/d Single-furnace maximum 550t/d Temperature of primary air ~220 Temperature of secondary air ~20 ℃ Rated mechanical load of grate 283 kg/(m℃2·h) furnace

Through the isolated operation on the travelling crane and garbage grab in the garbage storehouse, the garbage in the storehouse is lifted in the feed hopper and then charged to the entrance of the incinerator grate through the feed spout. The expansion joints shall be used for connecting the feed hopper with the feed spout. The self-start nozzle fire extinguishing system and closing valve for closing the feed hopper during when stop the incinerator for overhaul and avoiding the flame or spark entering the garbage storehouse when the feed spout or feed hopper catch fire. A material level monitor shall be set in the feed spout to communicate with the central control room and garbage isolation control room. The infeeding operation shall be conducted in accordance with the alarm signal given by the material level monitor. The garbage in the incinerator continuously rolls and mix on the hearth and complete the whole process of drying, catching fire and burning. The incinerator gate is divided into 3 areas separately for drying, gasification and burning through. Each incinerator gate can be independently controlled by hydraulic control system. The incinerator gate is made of heat-proof wear-resisting alloy steel. The hydraulic control system controls the running speed of the incinerator gate and communicates with the central control room. A monitoring camera is equipped on the rear wall of the incinerator to monitor the combustion process in the incinerator, supply the fume temperature and negative pressure value at the burning layer and first flue duck and automatically control the input and withdrawing of the auxiliary combustion system according to the datum of oxygen and so on contained in smoke gases at the boiler exit. All these data shall communicate with the central control room. A small amount of leachate in the leachate regulation tank shall be injected into the incinerator through pipeline and nozzle, and the injection rate shall be regulated according to the combustion condition in the incinerator supplied by the monitoring system to reduce the discharged capacity of leachate and improve the coking

97 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited condition in the incinerator. The primary air is extracted from the garbage storehouse and heated to 220℃ by the primary air preheater (with a single-stage extraction steam as heat source) before being blowed in the ash hopper at the bottom of the incinerator. The primary air is used for drying, gasifying, burning and burning out the garbage and cooling the incinerator grate. The primary air is controlled by frequency converter and distributed into different grate areas through adjustable valve for drying and combustion. The secondary air in the incinerator is mainly for supplying enough combustion air so that the combustible material in the flue gas can burn fully. The nozzle of the secondary air is generally arranged crossed on the front and back walls of the first flue duck, and the quantity, pipe diameter and position of the nozzle can ensure height turbulence caused by the flue gas in the combustion chamber, which decomposes the hazardous gas through full combustion.

4.5.2.3 Turbo Generator and Thermodynamic System The heat energy generated in the incinerator can generate vapor through exhaust-heat boiler and then converse into electrical energy through turbo generator set. This project has allocated two 15MW extraction condensing turbo generator sets. The exhaust-heat boiler of this project is the water-tube boiler with single boiler drum, natural circulation and balanced ventilation. The flue duct of boiler is made up of 3 access shafts + 1 horizontal channel + 2 fuel economizers. The heating surface of the exhaust-heat boiler is set in such a way that the temperature of the flue gas can fall below 250℃ by rapid cooling. Since the temperature range of 250~500℃ is susceptible to dioxin, in the design of the exhaust-heat boiler, the detention time of flue gas in this temperature range is minimized to avoiding dioxin. The three radiating flues under the boiler supporting structure partly expand downward while other part and the horizontal flue expand upward freely. The convection bank is supported by the top collecting box on the side wall and can expand freely. The technical parameters of the exhaust-heat boiler go as follows:

Rated garbage disposal capacity t/d 500

Maximum continuous evaporation t/h 42.8

Rated steam outlet pressure MPaG 4.0

98 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Rated steam outlet temperature 400 Working pressure of boiler drum MPaG 4.5 ℃ Working temperature of boiler drum 257 Boiler feed temperature 130 ℃ Pollution discharge rate % ~2 ℃ ℃ Exhaust gas temperature 195-5+10 Flue gas resistance Pa ~800 ℃ Boiler thermal efficiency % ≥80.5 Exhaust flue gas level (design point) Nm3/h 9.8×104

The exhaust-heat boiler supplies superheated steam of 4.0MPa and 400℃ which enters into the steam turbine to works on and drives the generator to generate electricity. After that, the exhaust steam enters into the steam condenser and become condensation water which, pressurized by the condense pump and pass through two-stage vapor extractor, gland steam heater, low pressure heater and deaerator, returns to the exhaust heat boiler from boiler feed pump after deoxygenation. The steam used for the low pressure heater and deaerator is supplied by running turbine through steam extraction. A two-stage vapor extractor is set in the steam-water system to make the steam condenser keep certain vacuity and thereby enable steam turbine get the best possible economical efficiency. The drain tank and drainage pump can collect drainage water in relevant equipment and pipelines in the system and sent it to the deaerator, thereby reduce the steam and water loss and improve the economical efficiency of the system. The main steam system is equipped with a set of steam bypass system. When the steam turbine is being examined or disorderly close down, the steam generated in the incinerator/exhaust-heat boiler condenses through the bypass system. The bypass system capacity is designed as 120% of the rated capacity of one set of steam turbo generator. Turbine tripping without boiler tripping can ensure the garbage disposal capacity.

4.5.2.4 Flue Gas Purification System The flue gas generated from the garbage incinerator contains a lot of dust, chlorine hydride, hydrogen fluoride, sulfur dioxide and other acidic harmful gas and such poisonous substance as dioxin and heavy metal, etc.

99 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited By improving combustion control system (controlling the times of stirring fire grate, strictly controlling the air leakage and reducing the flue gas flow rate), this project can reduce the amount of the flue dust in the exhaust air. The project also reduces the discharge amount of nitrogen oxide by adopting low nitrogen burner and SNCR denitration. The flue gas purification system still adopts the flue gas treatment system of the existing project, which consists of semi-dry deacidification tower, dry deacidification system, active carbon adsorption, bag-type dust collector, ash-conveying system and flue gas online monitoring facilities, etc, each incinerator equipped with one set. Flue gas of about 190℃ generated from the fuel economizer of the exhaust-heat boiler enters into the spray drying reaction tower from its top. In the meanwhile, the alkaline absorbent (lime hydrate solution) spurts out rapidly in the form of fogdrop from the spinner nozzle and the fogdrops have large specific surface area, which ensures good contact between the absorbent and flue gas. The flue gas and liquid fogdrops together downwards, and most acid gases (such as HCI, HF, SO2, etc.) are removed by absorption. The afterheat makes the water content in the serofluid evaporates and the resultant of reaction are discharged in the form of dry solid. Before the flue gas enters into the bag-type dust collector, inject the lime hydrate into the flue again to further remove the acidic gases in the flue gas and reduce the discharge amount of HCI, HF and so on; afterwards, inject active carbon to absorb dioxin and heavy metal in the flue gas. The particulates carried in the flue gas are detented by the filter cloth of highly efficient bag-type dust collector and form a filter layer. When the flue gas passes the filter layer formed by the particulates, the gaseous pollutant can still react with the non-reacted lime in filter layer and thereby been further purified. The ash captured by the dust collector is periodically removed by the deashing device. The treated flue gas will be again drawn into the 80-meter chimney-group for discharge. The ash collected by the purification system, after being sent to the solidification workshop by tank lorry for solidification treatment and reach the standards, is transported to the landfill. The amount of lime injected into the semi-dry deacidification tower is about 5,775 t/a, the amount of lime injected into the dry deacidification system is about 2,100 t/a, and the amount of injected active carbon is about 258t/a. The detailed process is shown as below:

100 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Lime hydrate Lime Active SNCR solution hydrate carbon Denitration Bag-type dust

Flue Semi-dry collector gas Draft Chimney deacidification Fan tower

Flyash collecting system

Fig. 4.5-2 Flue Gas

4.5.2.5 Ash & Slag Disposal System Slag disposal system: the slag discharging amount of single set 500t/d incinerator is about 121.68t/d (40,560t/a), and the overall slag discharging amount of Phase expansion project is 365.04t/d (121,680t/a). The slag generated after the garbage combustion falls into the water cooling-type slag discharge machine and is exhausted into the slag pit. Then the slag will be loaded into the dump truck by grab and transported to the brick field for comprehensive use. The finer garbage which leaks from the gap of grate is sent to the slag pit by the grate leaking slag conveyor. The slag, covering an area of 5.6m×53.55m, 5m deep, can store about 3.5 days’ slag of 3 sets of incinerators under the rated load. The cooling water of the slag discharge machine shall be used circularly. Fly ash treatment system: the fly ash amount of single set 500t/d incinerator is about 16t/d (5,328t/a), and the total fly ash amount of Phase expansion project is 48t/d (15,984t/a). Among the flue gas entering into the deacidification reaction tower, the larger particulates, by centrifugal force, are attached to the wall of the reaction tower and finally fall on the bottom of the reaction tower. The collections at the bottom of the deacidification reaction tower are resultants of deacidification reaction and mixtures of the resultants, which fall in the ash hopper of the reaction tower; the fly ash (including active carbon and lime hydrate injected in) contained in the flue gas is trapped by bag-type dust collector to the ash hopper. All fly ash in the ash hopper is sent to the fly ash storehouse by shell-type conveyor and finally to the solidification workshop. The solidification workshop of this project is set in the land for the Phase expansion of fly ash solidification workshop, and the fly ash generated after garbage of the whole factory are burnt out is sent to the hazardous waste landfill by tank trucks.

101 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited The fly ash and reactants are solidified by using cement. Set up one cement solidification system with a treatment capacity of 15t/h, which mainly consists of ash storehouse, cement silo, weighing box, dust valve, measuring hopper, moulding machine, water spraying system and control system. The two ash storehouses, each with a volume of 300m3, can store about 6 days’ ash of 3 sets of incinerators under normal operation; one cement silo with a volume of 60m3, is arranged at the left side of the flue gas purification area. The cement is sent to the cement silo through pneumatic conveying. The fly ash reactant stored in the ash storehouse, according to certain mixing ratio, is mixed with cement and coagulator and then put into the blending bunker through the dust valve. After mixed up through vibrating blending bunker, the fly ash enters the moulding machine for shaping. The fly ash generated by the incineration in this project, after solidification and chelation, is checked once a week by Everbright Environmental Protection Energy (Suzhou) Solid Waste Disposal Limited. If the check result meets the landfill requirements defined in the Standard for Pollution Control on the Landfill Site of Household Garbage (GB16889-2008), the fly ash will be sent to the Qizishan domestic waste landfill; if not, the fly ash shall enter into the hazardous waste landfill for safe landfill.

4.5.2.6 Leachate Treatment System The garbage is transported into the garbage dump pit for storage, and the water contained in the garbage will exude gradually. Measured by the maximum amount in summer, it is estimated about 480 m3/d. The leachate contains a certain amount of heavy metal and other poisonous substance, the composition of which is complicated. The bottom of the garbage dump pit is designed with a dip angle of 2°, which makes the leachate and other sewage flow into the bottom of the garbage discharge outlet and the lateral leachate collecting gutter and, after filtered by stainless wire net, enter into the leachate collecting sump which has been given anti-seepage treatment. A small amount of leachate is injected into the garbage incinerator through atomizing nozzle for high-temperature incineration and segmentation, and the rest shall be reused after been pumped into the leachate pre-treatment station for treatment.

102 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 4.5.3 Main Equipment and Environmental Protection Facilities Main equipment and environmental protection facilities of this project are shown in Table 4.5-2 and Table 4.5-3.

Table 4.5-2Main Equipment of This Project Items Unit Parameters Mechanical grate Category incinerator Rated garbage t/d 3×500 incineration amount

Fuel value kJ/kg 8,860 Hearth temperature 850~900 Retention time of flue gas ℃s 2 in hearth ≥ Incinerator/exhaust-heat boiler3 Temperature at flue gas sets 190 outlet

Clinker ignition losses %℃ < 3 Steam temperature 400 Steam pressure MPa℃ 4.0 Rated evaporation t/h 126 Feed-water temperature 130 Boiler thermal efficiency %℃ 81 Category Condensing Rated power MW 2×15 Rated inlet steam pressure MPa 3.8 Steam turbines2sets Rated inlet steam 390 temperature

Rated inlet steam amount t/h℃ 150 Rated Rotation speed rpm 3,000 Rated power MW 2×15 Power factor 0.8 Generator2sets Rated Rotation speed rpm 3,000 Outlet voltage kV 10.5 Excitation ways Brushless excitation Inclined Mode Garbage discharge door6 dragging type

Size mm H×W5,000×3,800

103 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Items Unit Parameters

Mode Double-beam bridge type Hoisting capacity t 2×15 Grab crane2 Span m 31.2 Sling height m 32.6 Cart travelling distance m 80 Electro-hydraulic Mode multi-peel Garbage hopper3 Grab volume m3 3×10 Closing/opening time s 13/7 Garbage feeder3sets Transport capacity t/h 3×10 Slag discharge machine6sets Transport capacity t/h 6×5 Grate slag leakage conveyor Transport capacity t/h 6×2 6sets

Air quantity Nm3/h 3×18,086 Primary draft3sets Rotation speed rpm 1,450 Electrical motor V 380 Air quantity Nm3/h 3×44,649 Secondary draft3sets Rotation speed rpm 1,450 Incinerator wall cooling fan Air quantity Nm3/h 3×15,777 3sets Rotation speed rpm 1,450 Flow rate m3/h 4×60 Condensate pump4sets Pump lift mH2O 120 Flow rate m3/h 3×75 Boiler feed pump3sets Pump lift mH2O 600 Feed-water temperature 130 Flow rate 3 m℃/h 2×50 Boiler feed pump2sets Pump lift mH2O 600 Feed-water temperature 130 Rated output t/h℃ 2×75 Working pressure Mpa 0.27 Extracted water 130 Medium pressure deaerator temperature

2sets Water inlet temperature ℃ ≥50 Oxygen content in mg/l℃ extracted water ≤0.016

Deaerating water tank m3 35

104 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Items Unit Parameters One-stage revise Chemical preparation system Technology osmosis+mixed bed 1set Processing capacity t/h 20 Compressed air system3sets Air demand Nm3/min 3×24

Table 4.5-3 Overview of the Environmental Protection Facilities of This Project Items Unit Parameters

Amount of flue gas Nm3/h 3×100,000 Inlet flue gas Deacidification 190 temperature reaction tower Flue gas retention time ℃s > 4 3sets Flue gas outlet 150 temperature

Amount of flue gas Nm℃3/h 3×100,000 Inlet flue gas 150 temperature

Bag-type dust Effective filtration area m℃2 3,200 collector3sets Filtration rate m/min 0.8 Working resistance Flue Pa < 1,200 gas Bag-type filtration PTFE+PTFE coating treatment material Lime hydrate

injection system Injection quantity kg/h 3×85 3sets Active carbon

injection system Injection quantity kg/h 3×20 3sets

Mode Telescope feed Height m 80 Chimney Inner diameter of the m 3×2.0 outlet Monitor many relevant parameters such as concentration of flue Flue gas online dust (particulates), SO2, NOx and CO, flue gas flow rate, monitoring temperature, humidity and oxygen content, etc, and record the discharge rate and total discharge amount ,etc. High-efficiency bag-type dust Flue gas control measures Method collector

105 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Items Unit Parameters

Dust removal efficiency % 99.9 Outlet concentration mg/m3 ≤ 10 Semi-dry reaction tower+dry Method deacidification SO control measures 2 Reduction ratio % 85 Outlet concentration mg/m3 ≤ 50 Combustion control Method method+SNCR denitration NO control measure X Reduction ratio % 50 Outlet concentration mg/m3 ≤ 200 Strengthen the combustion in incinerator and improve the Method CO control measures secondary draft head to allow more complete combustion. Outlet concentration mg/m3 ≤ 50 Semi-dry reaction tower+dry Method deacidification HCl and HFcontrol measures Removal rate % 96 3 Outlet concentration mg/m HCl≤10 mg/m3HF≤1 mg/m3 “3T”active carbon Method absorption+bag-type dust Organic pollutant (dioxin) control removal measure Removal rate % 99.9 Outlet concentration ≤ 0.1TEQ ng/m3 Semi-dry method+ dry Method deacidificationbag-type dust Cadmium control measure removal Removal rate % 80 Outlet concentration mg/m3 ≤ 0.05 Semi-dry method+ dry Method deacidificationbag-type dust Lead control measure removal Removal rate % 99 Outlet concentration mg/m3 ≤ 0.5 Semi-dry method+ dry Method deacidificationbag-type dust Quicksilver control measure removal Removal rate % 80 Outlet concentration mg/m3 ≤ 0.05 Close the garbage discharge room and garbage dump pit; Draft fan intakes air to form Odor control measure Method slight negative pressure in the garbage pond; Draft fan extracts air to incinerate; set deodorizer.

106 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Items Unit Parameters Discharge comes up to the Effect standards A small amount of leachate is injected back, and the rest treated in the matching leachate treatment station is reused for re-circulated cooling water after reach the quality standard of reuse water; the drainage part of the chemical water treatment system is used for lime slurry preparation, part of Method which is used for water Drainage treatment measure utilization in brick field and the rest is used for water spraying on roads and discharge platform; the cooling tower drainage is reused for deslagging cooling water; the domestic sewage is connected with pipes to the sewage treatment plant in new district. Leachate disposal Inject back 50t/d, reuse 430t/d t/d capacity after pre-treatment

Method Comprehensive utilization Slag disposal measure Disposal capacity t/d 365.04 Those passing the solidification inspection are sent to the domestic waste landfill and Method Fly ash control measure those not passing the inspection are sent to the hazardous waste landfill. Disposal capacity t/d 48 Present noise control indicators to the equipment suppliers; set muffle, sound proof casing and Method two storied door and window; Noise control measure control the window size of the steam turbine room, etc. Ensure that the noise at the Effect boundary of the factory comes to the standards. Plant trees and grass with strong adsorbility on both sides Method Greening measure of the roads and around the factory buildings. Greening coefficient % 30

4.6 General Information of Raw and Auxiliary Materials

107 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 4.6.1 Fuel Similar to the existing project, the major fuel of the Phase expansion project is domestic waste, with light diesel as starting up and combustion-supporting fuel. The designed domestic waste treatment scale of Phase expansion project is 1,500 t/d, and three 500 t/d incinerators are adopted. Similar to the existing project, the service coverage is still the urban area of Suzhou City, and this project will not establish new transportation lines. The domestic waste are transported by the sealed haulage trucks and breech loading sealed haulage trucks in the environmental sanitary administration of Suzhou from the designated garbage transfer stations to the discharge hall expanded in this phase and discharged into the garbage storehouse. The construction of this project has greatly reduced the amount of garbage entering into the Qizishan Refuse Landfill Site. According to the existing engineering operation cases, auxiliary fuels are needed when start up the incinerator to make the incinerator temperature reach the operating condition required for garbage incineration. Under the design conditions, 4~6t/incinerator fuel oil is consumed for each cold start and 2~3t/incinerator fuel oil is consumed for each warm start. One 20m3 oil tank is set in the oil tank area of the existing project, which can meet the fuel oil demand when the 3 incinerators of Phase start at the same time. Therefore, no new oil storage will be established for Phase project. The technical analysis and element analysis on the garbage fuels and light diesel used in Phase expansion project are same as those in section 3.3.1.

4.6.2 Main Auxiliary Materials The main auxiliary materials needed in the process of garbage incineration are shown in Table 4.6-1.

Table 4.6-1 The Usage of the Main Auxiliary Materials in This Project Year’s target No. Items Unit target (kg/h) Remarks (t/a)

1 Lime 984.4 7,875 2 Active carbon 32.26 258 3 Ammonia liquor 93.75 750 Concentration: 20%

108 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

4.7 Public Auxiliary Projects

4.7.1 Water Supply and Drainage

4.7.1.1 Water Supply The domestic water of this project is from the tape water and the production water is from Xujiang River. The designed maximum daily fresh water replacement is 1,779 t/d, of which 1,681 t/d from river water and 98t/d from tape water. The tape water is used for office and living use, chemical examination use in laboratory, brick field compounding-purpose water, water service in leachate treatment station; the river water is mainly used for production, including water implementation for circulation and cooling system, chemical water treatment system and wash water. In the existing project, a raw water pumping station is established on the south bank of Xujiang, the pure water supply being maintained around 200m3/h. The water consumption of Phase and Phase in the summer of 2010 is about 2,700~2,960 m3/d (about 123 m3/h), and the water consumption in winter is about 2,500~2,600 m3/d (about 108 m3/h). The residual water deliverability of water purification station of the existing project is about 1,920 m3/d (80 m3/h). Because this project needs to replenish industrial water consumption of about 1,779 m3/d (74 m3/h), the existing project can be relied on. The water consumption of this expansion project is shown in Table 4.7-1.

Table 4.7-1 Table of Water Consumption of Phase Expansion Project

Feed Water Amount of water Name consumption reusable Remarks amount m3/d water m3/d m3/d

Domestic water 10 10 0 Tap water Brick field

compounding-purpose 30 30 0 Tap water water 112 Water service for leachate 11258/54 0 Tap water /River 58/54

109 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited treatment station purification Makeup water comes from river purification Circulating cooling and the reusable water 1,732 1,270 462 make-up water comes from the advanced treatment of leachate Chemical water treatment 184 184 0 River purification system make-up water Lime compounding-purpose 173 173 0 River purification water Water used for cooling the Water discharged from slag dragging machine and 233 0 233 the cooling tower flushing slag

Boiler feedwater 116 0 116 Chemical water Water discharged from

Water for washing terrace 68 0 68 the chemical water treatment Water sprayed on 25 0 25 Boiler drainage greenbelt and roads

Total 2,683 1,779 904

4.7.1.2 Drainage This project adopts wastewater segregation system and the main drainages go as follows: Compared with the leachate discharge quantity of existing project, the summer maximum discharge quantity of garbage leachate is about 374t/d which enters into the leachate regulating basin together with the discharge platform washing water of 68t/d. And then, 50t/d is injected back to incinerator and the rest 392t/d enters into the supporting leachate treatment station; after advanced treatment, 462t/d is reused for circulating cooling water and 24t/d concentrated water is sent to the incinerator for incineration. The domestic wastewater of 8t/d is sent to the sewage treatment plant in new district through pipeline. The 25t/d water discharged from the boiler steam-water system is clean water

110 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited which is used for greening and road watering.

4.7.1.3 Water Balance Diagram The water balance of Phase expansion project is shown in Fig. 4.7-1 and that of the whole plant after finishing Phase can be seen in Fig. 4.7-2.

462 Loss 1,499 Loss 226 233 Cooling the slag dragging 7 Take away slag 1,270 Cooling machine and flushing slag tower 4,500t/h 140t/h

Xujiang River Loss 173

173 1,681 12~15%lime slurry compounding Loss 25 Loss 91 184 Chemical water 116 treatment Steam-wat Greening, road er system 25 watering 68 68 Washing terrace and trucks 374 Leachate Leachate in regulating basin garbage storehouse 442 Inject back 50 Incinerator 392 Loss 18 54Reverse osmosis wash water 462 58 Reverse osmosis wash Leachate treatment 24 Incinerator station

Tape water Loss 30 98

30 Brick field compounding-purpose water

Loss 2 Discharged to the sewage 10 8 treatment plant in new Living water district through municipal

sewer net

Fig. 4.7-1 Water Balance Diagram of Phase Expansion Project Unit: t/d

111 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

1,084 Loss 3,581 Loss 541 3,055 558 17 Take away slag Cooling tower Cooling the slag dragging machine and flushing 14,200t/h 340t/h Loss 173 Xujiang River 4,036 413 12~15%lime starry Loss 217 Loss 60 Chemical water Steam-wat 439 treatment 277 60 er system Greening, road

162 162 Washing terrace and trucks 886 Leachate Leachate in garbage treatment

1,048 Inject back 130 Incinerator 918 Loss 43 129Reverse osmosis wash 1,084 138 Reversal osmosis wash Leachate 58 treatment station Incinerator

Tape water Loss 71.5 254.5

71.5 Brick field

Loss 9 45 36 Discharged to the Living sewage treatment

water

Fig.4.7-2 Water Balance Diagram of the Whole Factory Unit: t/d

4.7.1.4 Chemical Water Treatment Boiler feed water is demineralized water which is made by adopting the technology of reverse osmosis plus mixed bed, with the following technological processes: filter the production water with multi-medium filter and active carbon filter, add scale inhibitor in the filtering water to avoid scale formation, and pour the

112 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited filtering water to precision filter for further filtration. After boosting pressure, the filtering water enters into the reverse osmosis equipment and then the mixed bed and the qualified demineralized water will be finally produced through precision filtration. The concentrated water produced during the reverse osmosis process is taken as deslagging water, and the residual acid and alkali liquid, after neutralization, is drained to the cooling tank and discharged outside after its temperature falls. Water quality index of the demineralized water:

Hardness ≈ 0 mol/L Electricity conductivity ≤ 0.3μs/cm Silicon dioxide ≤ 200μg/L The water preparation is set in the water decontaminated room under the discharge hall. Design one water preparation system with a water preparation capacity of 20t/h which can operate both automatically and manually. The acid and alkali liquid for the system shall be transported to the acid or alkali storage tank by trucks. The main equipment include multi-medium filter, mixed bed, precision filter, raw water tank, intermediate water tank, clean water tank, various pumps and acid or alkali storage tank.

4.7.2 Power Supply System This project has an annual generation capacity of 194.9 million KWh, 18% of which is supply for the factory and 156 million KWh is expected to be sold. In this phase, the electric generating plan plans to connect to the established 110kV electricity grid, and the former 110kV wire connection in Phase shall be reconstructed. After reconstruction, the main supply is connected to the 110kV gold cat through an 110kV cable and become an 110kV circuit. The spare wire, through an 110kV cable, contact with the GIS outgoing feeder, which forms two 110kV incoming feeders. For the 110kV electric main connection mode, it is planned to adopt single bus scheme. For the 10kV bus, sectionalized single-bus connection scheme is adopted. The voltage at the outlet of the electric generator is 10.5kV, separately connected to the sections and of the 10kV bus and finally connected into the grid after increasing voltage through 25,000kVA and 20,000kVA. For the 10kV station electric auxiliary system, the power plant plans to adopt single bus the 10kV station high-voltage equipment and station transformer of boiler 6

113 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited and boiler 7 are powered by the section of 10kV bus, and the new added No.1 generator shall be connected into section of the bus. The 10kV station high-voltage equipment and station transformer of boiler 8 are powered by the section of 10kV bus, and the new added No.2 generator shall be connected into section of the bus. The 0.4kV station electric auxiliary system adopts sectionalized single-bus connection. Single boiler corresponds to a single station working transformer and one section of 0.4kV bus. Set one standby station transformer with the a capacity same as that of the working transformer, corresponding one section of standby bus, and the two buses are connected by a bus-bar switch.

4.7.3 Compressed Air System The compressed air system is divided into compressed air for general use and instrument compressed air. The compressed air for general use is used for pneumatically transmission and blowing and the instrument compressed air is used for instruments, meters and bag-type dust collectors, etc. Three non-lubricated air compressors are set in the compressed air station, with same parameters: 0.8MPa, 24.0m3/minute. Compressed air station is located inside of the main machine hall.

4.7.4 Storage and Transportation The total transportation of Phase expansion project is about 806,300t/year, and details are provided in the table below. The domestic waste of 659,300t/year, combustion-supporting light diesel of 150t/year, lime of 7,875t/year, active carbon of 258t/year and ammonia water of 750t/year are transported in; ash and slag of 13.8t/year are transported out.

Table 4.7-2 Table of Annual Transportation Quantity Unit: ten thousand t/a Quantity transported Quantity Items Item in transportation out

Domestic waste 65.93 Ash 1.6 Combustion-supporting light 0.015 Slag 12.2 diesel

Lime 0.7875

114 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Active carbon 0.0258 Ammonia water 0.075 Total 66.8333 Total 13.8

4.7.4.1Fuel Storage 1Storage in the garbage storehouse A garbage dump pit is set in the plant of this project, covering an area of 23.7m × 60.3m, and it can store 8,860 tons of garbage which can meet the treatment amount demand for about 6 days. The garbage dump pit is enclosed to prevent odor from escaping. And deodorizer shall be set. There is a slope gradient of 2% in the width direction of the garbage dump pit. 6 grille doors are set near the garbage in-taking tank so as that the garbage sewage can flow into the sewage tank along the sewage ditch through the grille doors. The odor in the dump pit is extracted out by primary air fan and used as combustion-supporting air in the incinerator. 2Diesel storage One 20m3 oil tank is set in the oil tank area of the existing project, which can supply the fuel enough for starting up 3 incinerators of Phase at the same time. Therefore, there is no need to add new oil house for Phase project.

4.7.4.2 Fuel Transportation Similar to the existing project, the domestic waste are still transported by the sealed haulage trucks and breech loading sealed haulage trucks in the environmental sanitary administration of Suzhou from the designated garbage transfer stations to the discharge hall expanded in this phase and discharged into the garbage storehouse. No new transportation route is established for the Phase expansion project.

4.8 The Production and Discharge of Main Pollutants

4.8.1 The Production and Discharge of Wastewater 1Wastewater source and treatment The wastewater generated from the garbage incineration plant, by its source and pollutant property, can be divided into high concentration organic wastewater and low

115 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited concentration wastewater. The high concentration organic wastewater mainly comes from the garbage leachate and the water for washing terrene and trucks, and the low concentration wastewater is domestic sewage, water drained from the chemical water treatment system, boilers and cooling tower. Because the pollution factor from the garbage leachate is of high concentration and complicated composition, according to the operation experience of the existing project, this project plans to inject a small amount of leachate back to the incinerator, the rest entering into the supporting leachate treatment station together with the water washing terrace and trucks for advanced treatment. After reach the reusable water quality standards, the leachate shall be reused as circulating cooling make-up water. The domestic sewage shall be sent to the sewage treatment plant in new district through pipeline. The water drained from the chemical water treatment system is used for washing the terrace and trucks; water from circulating cooling system is used for cooling the slag dragging machine and rushing slag; the water from steam-air system of boiler is used for greening and road watering. 2Wastewater generation and drainage The maximum amount of the garbage leachate generated in summer of Phase expansion project is about 374t/d, which enters into the leachate regulating basin together with 68t/d of water washing discharge platform and trucks. Of which, 50t/d is injected back to the incinerator and the rest 392t/d enters into the supporting leachate pre-treatment station for treatment. The existing treatment technology is anaerobic treatment + SBR + ultrafiltration membrane technology. In this upgrading and reconstruction, “nanofiltration+reverse osmosis” technology is adopted. When the leachate reaches the reusable water quality standards after advanced treatment, 462t/d is reused as circulating cooling make-up water. The 24t/d of concentrated water is injected into the incinerator for incineration. The domestic sewage of 8t/d is sent to the sewage treatment plant in new district through pipeline. Based on the data of the existing project and like projects, the pollutant concentration of leachate and water washing terrace and trucks of this project before and after treatment are shown in Table 4.8-1. The pollutant concentration of all streams of wastewater before and after treatment is shown in Table 4.8-2. Table 4.8-1 Production and Treatment of Such high Concentration

116 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Wastewater as Leachate

Pollutant production Reuse of pollutant Wastewater Wastewater Reuse amount Main Concentration Amount Treatment mode Main Concentration name amount (t/a) pollutant (mg/L) t/a pollutant (mg/L) (t/a) COD 35000~50000 4,359~6,227 Wastewater 153,846 BOD 12000 COD 60 1,494.50 16,650t/a is injected back; of / Leachate 124,542 SS 3000 373.63 the rest, after treated by the BOD 10 / NH3-N 2000 249.08 anaerobic NH3-N 10 / TP 250 31.14 treatment+SBR+ultrafiltration TP 1 / Water for COD 5000 113.22 membrane technology and BOD 2000 45.29 advanced treatment, washing SS 500 11.32 1,533,846t/d is reused and 7,992t/d of concentrated truck and 22,644 NH3-N 300 6.79 water enters into the terrace TP 20 incinerators for incineration. 7,992t/d 0.45

117 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 4.8-2 Production and Drainage of All Streams of Wastewater of This Project Pollutant production Wastewater Discharge/reuse of pollutants Wastewater The place Wastewater drainage/reuse where the amount Main Concentration Amount Treatment mode Main Concentration Discharge wastewater name amount (t/a) pollutants (mg/L) t/a pollutants (mg/L) amount(t/a) is t/a) discharged COD 35000~50000 4,359~6,227 COD 60 - BOD 12000 1,494.50 16,650t/a is injected back; of BOD 10 - Leachate the rest, after treated by the Reused as 124,542 SS 3000 373.63 NH3-N 10 - NH -N 2000 249.08 anaerobic TP 1 - 3 treatment+SBR+ultrafiltration circulating TP 250 31.14 membrane technology and 153,846 cooling Water for COD 5000 113.22 advanced treatment, washing BOD 2000 45.29 153,846t/d is reused and make-up SS 500 11.32 7,992t/d of concentrated 22,644 water. truck and NH3-N 300 6.79 water enters into the incinerators for incineration. terrace TP 20 0.45 COD 400 1.07 COD 400 1.07 Sent to the BOD 200 0.53 BOD 200 0.53 SS 150 0.40 SS 150 0.40 sewage Domestic NH3-N 35 0.09 NH3-N 35 0.09 treatment 2,664 / 2,664 sewage plant TP TP through pipeline 5 0.01 5 0.01 Water 77,589 COD 50 3.88 / 77,589 COD 50 - Reused for

118 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

drained discharging from the slag and SS 20 SS 20 cooling cooling tower 1.55 - Water pH 10~11 pH 10~11 - drained COD 50~100 1.13~2.26 COD 50~100 - Reused for BOD 20~50 0.45~1.13 BOD 20~50 - from washing 22,644 / 22,644 chemical trucks and SS 20~50 0.45~1.13 SS 20~50 - treatment terrace system Water Reused for drained 8,325 pH 10~11 - / 8,325 pH 10~11 - road from boiler watering

119 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 4.8.2 Production and Exhaustion of Waste Air

4.8.2.1 Flue Gas from Incinerators The Phase expansion project adopts the incinerators and flue gas treatment equipment same as those of existing project. Based on the supplementary monitoring data after monitoring for acceptance and stable running of the existing project and combining the “using new method to improve old one” measure and designed parameters the Phase expansion project plans to adopt, the source intensity of the pollutants in the flue gas of this expansion project is estimated in accordance with the EU 2000 emission standard. The detailed monitoring data are presented in Section 3.6.1. 1Components of flue gas The domestic waste in our country are not classified effectively and have complex component, especially the plastic package, battery, disused electronic products which have many poisonous and harmful substance and are inclinable to cause dust, acidic gas, heavy metal and dioxin to exhaust with flue gas during the incineration, the harmful gases including NOx, SO2, HCl, HF, CO, etc. The main component analysis on the flue gas goes as follows: Dust The ash and inorganic substances in the garbage produce dust during incineration, part of which goes out of the incinerators with the flue gas flow. In addition, the lime and active carbon powder injected in the incinerator during the flue gas incineration forms dust when the flue gas becomes dry under high temperature. The larger part of ash produced during the garbage incineration is discharged in the form of bottom ash. After been purified in semi-dry neutralizing tower and bag-type dust collector, the dusts of large granules are removed, and the discharged dusts are mainly PM10. Based on the monitoring data, the dust discharge concentration is between 4.07~20.0 mg/m3. During this expansion project, enterprises plan to reduce the amount of dusts in exhaust air by improving combustion control system (controlling the times of stirring the grate, strictly controlling air leakage and lowering the flow rate of flue gas); and use the bag with high dust collection efficiency and clean the bag timely to keep the 3 average outlet density of dust under 10 mg/m , thus the discharge amount of PM10 is 2.05kg/h, 16.37t/a.

120 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Acidic components HCl: urban garbage contain plastic materials and many kinds of organic chloride which are mainly generated through the thermal decomposition of organchlorine, for example, PVC plastic, sterilized or bleached chlorine garbage will generate HCL during combustion, while the chlorine element contained as chloride (such as NaCl) in kitchen waste cannot produce HCL. Based on the monitoring data of the existing project, the average emission concentration of HCL is 6.5mg/m3. This project has further reduced the HCL concentration by adopting “using new method to improve old one” measures and increasing dry deacidification procedures. According to the design parameters, the removal rate of HCL can be improved to 96%, and the HCL emission concentration estimated below 5.1mg/m3 which reaches the EU 2000 emission standard. Therefore, the emission amount is 1.04kg/h, 8.35t/a. HF: fluorid is generated from the combustion of fluorocarbon in the garbage, such as fluoroplastics and fluoride varnishes, etc, the formation mechanism of which is similar to that of HCL, with little amount. Based on the monitoring data of the existing project, the average emission concentration of HF is 0.95mg/m3, which reaches the EU 2000 emission standard 1mg/m3. This project has further reduced the HF concentration by adopting “using new method to improve old one” measures and increasing dry deacidification procedures. According to the design parameters, the removal rate of HCL can be improved to 96%, and the HCL emission concentration can be strictly kept below1mg/m3. Therefore, the emission amount is 0.2kg/h, 1.64t/a.

SO2: according to the operating experience of the existing project, the light diesel fuel is not consumed expect during the time of firing incinerator when the auxiliary fuel is used. Therefore, the SO2 generated from the exhaust air incineration mainly comes from the domestic waste. The sulfur contained in the domestic waste has been greatly reduced after the Ban on Free Plastic Bags is implemented. Based on the monitoring data of the existing project, the average emission concentration of SO2 is 10.5mg/m3, far below EU 2000 emission standard 50mg/m3. This project has further reduced the SO2 concentration by adopting “using new method to improve old one” measures and increasing dry deacidification procedures. Therefore, the SO2 emission concentration can be strictly kept below10mg/m3, with an annual emission amount of 16.37t/a. NOx: mainly comes from the thermal decomposition and oxidizing combustion

121 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited of nitrogen compound, the rest from thermal combustion (below 1100℃) of nitrogen in air. This project adopts the SNCR denitration technology. According to the monitoring data, the emission concentration of nitric oxides is lower than 170.7mg/m3. Therefore, its emission concentration can be strictly kept below 180mg/m3 and the emission amount of nitric oxides is 36.83kg/h, 294.62t/a. CO: part of CO comes from the thermal decomposition of carbonide in the garbage and the other part is from the imperfect combustion. The higher the garbage combustion efficiency is, the smaller the CO content in the exhaust air becomes. According to the monitoring data, the emission concentration of CO is lower than 37.5mg/m3 which are below EU 2000 emission standard 50mg/m3. Therefore, its emission concentration can be strictly kept below 50mg/m3 and the emission amount of nitric oxides is 10.23kg/h, 81.84t/a. Heavy metal The heavy metals in the flue gas are generally generated from the thermal decomposition of metallic compounds or metallic salts contained in the garbage including mixed coating materials, printing ink, battery, luminous tube, mercury materials and electronic circuit board, etc. The volatile metals include mercury, lead, antimony, arsenic, copper, gallium, zinc and so on; nonvolatile metals include aluminum, ferrum, barium, calcium, magnesium, kalium, silicon and titanium, etc. Part of the volatile metals is discharged by being attached to flyash and the nonvolatile metals are mainly present in the slag. According to the monitoring data, the emission concentration of Cd and Hg is lower than detection limit, and the emission concentration of Pb is lower than 0.05mg/m3; since the acceptance concentrations of Cd and Hg are lower than their detection limits, in order to conservatively estimate the influence of heavy metal, the emission amount of heavy metals in the exhaust air of this project is calculated on the basis of design data. According to the design data, the emission concentration of Pb, Hg and Cd are respectively controlled at 0.5mg/m3, 0.05mg/m3 and 0.05mg/m3. See table 4.8-2. Dioxins Dioxin-Like compound refers to any of a class of compounds able to combine with the aromatic hydrocarbon receptor Ah-R and cause a series of biochemical reactions.

122 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited During the incineration of domestic waste, the formation principle of dioxins is considerably complicated. Domestic and overseas research findings so far are not sufficient. The known formation routes probably are: A. During the combustion, the dioxins are generated from chlorine precursors which include polyvinyl chloride, chlorobenzene and pentachlorophenol, etc. During the combustion, the dioxins can also be generated from the molecule of precursors by decomposition, freeradical condensation or other molecular reaction. Most of these dioxins can be decomposed in the high-temperature combustion conditions; B. When superfluous unburning-out substances are generated in the flue gas due to imperfect combustion and encounter adequate catalyzers (mainly are heavy metal, especially copper) and a temperature environment of 300~500℃, the dioxins decomposed in high-temperature combustion will reform. The pollution prevention techniques against dioxins can be divided into the following three classes: . Inhibit the formation of dioxins through improving combustion state; . Let the high-temperature flue gas pass the heating surface at the boiler tail to lower its temperature to about 160℃, after that the flue gas enters into the flue gas treatment system, which can effectively avoid dioxins reformation in the 300~500℃ temperature environment; . Adsorb the dioxin fine grains condensed in the low-temperature flue gas with active carbon and collect them with dust collector. This project, by adopting 3T technology, reduces and controls the formation of dioxins from its source. Active carbon absorption is adopted in the flue gas treatment system. According to the monitoring data, the emission concentration of dioxins is lower than 0.079 ngTEQ /m3; therefore, after a series of pollution prevention measures are implemented in this project, the concentration of dioxins in the exhaust flue gas can reach the EU standard of 0.1ngTEQ/m3. Conservatively estimated with EU standard, the maximum emission amount of dioxins is 20.46ugTEQ/h, 0.1637g/a. For incinerating flue gas, this project adopts the treatment system of “SNCR denitration+semi-dry deacidification+dry deacidification+active carbon absorption+bag-type dust collector”, and the treated flue gas is discharged from the 80m 3-tube chimney. The formation and emission of exhaust gas are shown in Table 4.8-2.

123 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 4.8-1 Production and Treatment of Such high Concentration Wastewater as Leachate

Pollutant production Reuse of pollutant Wastewater Wastewater Reuse amount Main Concentration Amount Treatment mode Main Concentration name amount (t/a) pollutant (mg/L) t/a pollutant (mg/L) (t/a) COD 35000~50000 4,359~6,227 Wastewater 153,846 BOD 12000 1,494.50 COD 60 / 16,650t/a is injected back; of Leachate 124,542 SS 3000 373.63 the rest, after treated by the BOD 10 / NH3-N 2000 249.08 anaerobic NH3-N 10 / TP 250 31.14 treatment+SBR+ultrafiltration TP 1 / Water for COD 5000 113.22 membrane technology and BOD 2000 45.29 advanced treatment, washing SS 500 11.32 153,3846t/d is reused and 7,992t/d of concentrated truck and 22,644 NH3-N 300 6.79 water enters into the terrace TP 20 incinerators for incineration. 7,992t/d 0.45

124 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 4.8-2 Formation and emission of atmospheric pollutants in Phase expansion project

Producing status Emission Emission parameter Removal Emission Exhausted Formation Treatment Emission Inner Tempera Emission amount Pollutants Concentration rate Concentration standard Height source gas amount amount measure diameter ture 3 3 (mg/m3) 3 (mg/m ) % (mg/m ) (m) (Nm /h) kg/h t/a kg/h t/a (m) (℃) Dust 10000 2,046 16,368 99.9 10 2.05 16.37 30 SO 2 67 13.64 109.12 85 10 2.05 16.37 260 Incinerat NO SNCR X 360 73.66 589.25 50 180 36.83 294.62 400 or denitration+ HCl 127.5 26.09 208.69 semi-dry 96 5.1 1.04 8.35 50 chimney deacidification+ HF 2 of Phase 10 2.05 16.37 dry 90 1 0.20 1.64 3tubes× CO 204,600 80 150 50 10.23 81.84 deacidification+ 0 50 10.23 81.84 100 DN2.0 Pb active carbon 5 1.02 8.18 90 0.5 0.10 0.82 1.6 expansio absorption+ Hg 0.5 0.10 0.82 bag-type dust 90 0.05 0.01 0.08 0.1 n project Cd collector 0.5 0.10 0.82 90 0.05 0.01 0.08 0.1 0.1ng 20.46 0.1ng Dioxin - - - - ≤ ≤ ≤0.1637 TEQ/Nm3 ug/h g/a TEQ/m3

125 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 4.8.2.2Offensive Odor In this project, offensive odor mainly comes from garbage dump pit, garbage weigh house and leachate treatment station, and the main components of the odor are sulfide and low fat. China’s Technical Code for Projects of Municipal Household Garbage Incineration (CJJ90-2009) states that the effective capacity of garbage storage tank shall be determined according to the rated incineration amount of 5-7days. The garbage storage tank of this project can store 8,860 tons garbage (6 days). The garbage dump pit is of enclosed reinforced concrete structure, with 6 discharge doors. A forced gas-extraction system is set above the pit, and a negative pressure device is set to control the accumulation of offensive odor. During the normal operation, the gas in the enclosed garbage storage tank shall be extracted and used as combustion-supporting air for incinerators. Thus, the odorous substances will decompose in high temperature. As the incinerators consume a vast amount of combustion-supporting air, the garbage storage tank can be kept in good negative pressure state, and the offensive odor will not cause environmental pollution. According to the monitoring results on the emission of offensive odor in the garbage storage tank of this project, combing the relation between odor strength and concentration and undertaking design and operation management in accordance with 3 3 the specification, the odor concentration [NH3] < 3.79mg/m , [H2S] < 0.30mg/m . Referring to the method of the measuring the odor pollutants amount of domestic waste landfill, the estimates of production rate of odor from the garbage storage tank is shown in Table 4.8-3.

Table 4.8-3 Estimates of Odor Production Amount Odor NH3 H2S Formation source

Summer30℃ 0.049kg/h 0.0051kg/h Garbage storage tank Winter15℃ 0.035kg/h 0.0035kg/h

After the above control measures are implemented, the escape amount of offensive odor has been largely reduced. Under normal circumstances, the amount of offensive odor pumped into the incinerators by primary air fan accounts for 95% of the production amount, and about 5% offensive odor unorganizedly spreads into the

126 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited atmosphere. Since the air in the garbage storage tank cannot be incinerated during the incinerator shutdown and overhaul (all the 3 incinerators shut down) , in order to prevent the odor escaping to the atmosphere, the garbage incineration plant is equipped with double-circuit power supply to ensure no electricity failure while incinerator shutdown. Therefore, exhaust system is set in the garbage storage tank to ensure that the odor can be sent to the deodorization device in the main incineration house during the incinerator shutdown. Finally the odor shall come to standards and be discharged after purification and deodorization, with a removal rate of 70%.

Thus, the source intensity of the fugitive emission of NH3 and H2S is shown in Table 4.8-4.

Table 4.8.4 Fugitive Emission Parameters of Odor NH3 and H2S

Fugitive Average Source intensity of the fugitive Position of emissionkg/h emission height Pollutants Normal Abnormal pollution source 2 aream m condition condition

Garbage storage NH3 0.0025 0.0147 tank, discharge 68*55=3,740 12 H2S platform 0.0003 0.0015

4.8.2.3 Fugitive Dusts Located in the hazardous waste landfill, the supporting fly ash solidification workshop is designed for solidifying the fly ash of the whole factory. The fly ash is transported to the fly ash solidification workshop by tank wagon. The solidification process is fully enclosed, and the raising dust, passing the dust collector, is discharged from roof. The fly ash amount of this project is about 15,984t/a, and that of the existing project is about 21,845t/a. Therefore, the total fly ash amount of the whole factory is 37,829t/a, considering that the dust raising coefficient is 5% and the efficiency of the bag dust collector is 99.9%, the emission amount of the fly ash of the whole factory after passing the dust collector is 1.41t/a and the emission height of the ash storehouse is 10m.

127 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 4.8-5 The Emission of the Fugitive Dust of the Project Generating capacity per Generating Pollution Pollutan Height No. Aream2 hour capacity source t m kg/h t/a Fly ash 48*25 = 1 solidification Dust 10 1200 workshop 0.24 1.89

4.8.3 Noise The main noise sources of the garbage incineration plant include exhaust-heat boiler steam emptying pipe, high-pressure steam blow pipe, steam turbo generator net, air fan (blowing fan and draft fan), air compressor, water pump, pipeline system and garbage transportation vehicles, and the minor noise sources include crane, feed water treatment equipment, flue gas cleaner and vibration screen, etc. In view of the acoustical characteristics, most of the noises from the garbage incineration plant are aerodynamical noise, and the next are electromagnetic vibration noise and mechanical vibration noise. The frequency spectrum of the noise from the garbage incineration plant is generally concentrated within the frequency range of 125~4,000Hz. The range and positions of the A-weighted sound level of various noise sources are shown in Table 4.8-6.

Table 4.8-6 The Newly Added Noise Source of the Phase Expansion Project Minimum Sound level Sound distance from after noise Main noise sources Quantity level Treatment measures the factory reduction dBA boundarym dBA Boiler steam 2 140 S75 Buffle 100 emptying pipe Grip bucket crane Sound insulation for 2 85 S50 75 for lifting garbage buildings Air fan (blowing Install sound proof 6 95 S55 85 fan and draft fan) box and baffle

Steam turbo 2 100 S105 Sound insulation 90

128 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited generator net devices and baffle 4three for operation Sound insulation, Air compressor 90 S、E40 80 one for install baffle standby Sound insulation for Water pump 4 90 W50 80 buildings Cooling tower 3 85 S55 - 85

4.8.4 Production and Treatment of Solid Wastes The newly added solid wastes of this project mainly include slag from incinerators, fly ash and domestic waste, with a total production capacity of 138,000t/a. 1Slag After been discharged from incinerator bottom, the slag of garbage incineration passes the slag remover and then be cooled by water, and finally transported to the slag disposal pit. According to the leaching test data conducted on the similar domestic waste, the slag belongs to general solid waste and its main components are oxide of silicon, calcium, aluminum, ferrum, manganese, natrium and phosphoric and scrap metal. Based on the data on engineering design, the slag production capacity of this project is 121,680t/a. The slag shall be sent to the supporting slag multiple purpose brick field for comprehensive utilization and made into ash-slag blocks. 2Fly ash During the garbage incineration, the fly ash are mainly from the convective heating surface of the boiler as well as the gravity settling and rapping settling at the tail, and also from fly ash (including the particulates contained in the flue gas and the compound produced from the reaction between the particulates and lime, as well as the active carbon powder for absorbing air pollution and so on) collected during the deacidification and dust removal of flue gas purification system. The main components of the fly ash include SiO2, CaO, Al2O3, Fe2O3, such reaction resultants as sulphate, sodium salt and sylvite, as well as such heavy metal elements as Hg, Mn, Mg, Sn, Cd, Pb, Cr and dioxin at trace level and other kinds of pollutants, which belong to hazardous wastes. The Circular on Further Strengthening Environment Impact Assessment Management of Biomass Waste-to-Energy Projects (Ministry of Environment Protection, National Development and Reform Commission, National

129 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Energy Board, Environment & Development No. 82, [2008]) states “actively encourage the comprehensive utilization of incineration fly ash, but the technology adopted shall ensure the complete destroy of dioxins, the effective fixation of heavy metals and no secondary pollution during production and use.” The Standard for Pollution Control on the Landfill Site of Household Garbage specifies that “the fly ash generated from household garbage incineration and the wastewater and slag from medical wastes shall be treated in such a way that they can enter the household garbage landfill (specific conditions omitted)”. The fly ash of about 16,000t/a in this project shall be identified after solidification and chelation. If it can reach the landfill standards in the Standard for Pollution Control on the Landfill Site of Household Garbage (GB16889-2008), shall be sent to Qizishan Refuse Landfill Site for sanitary landfills; if it does not meet the above requirements, sent to Suzhou hazardous waste landfill for safe landfills. 3Domestic waste This project newly employs 65 persons. If the domestic waste produced from routine office work and everyday life is calculated by 0.5kg/p·d, the domestic waste will be about 10.2t/a, which shall be sent to the incinerators of this project for incineration. 4Waste active carbon residue In this project, during the flue gas treatment, the trace quantity of dioxins and heavy metal and other poisonous substances are absorbed by injecting active carbon. The active carbon generally blend with fly ash, so it can be solidification after collection, with a production amount of about 258t/a. The production and treatment of solid wastes are shown in Table 4.8-7.

Table 4.8-7 Production of Solid Wastes Production Serial No. Waste name Treatment method (t/a) No. Sent to brick field for comprehensive 1 Incinerator slag 121,680 72 utilization

2 Fly ash 15,984 HW18 Shall be identified after solidification and chelation, those reach the landfill Waste active 3 258 HW18 standards shall be sent to domestic carbon waste landfill for sanitary landfills;

130 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited and those not meet the standards shall sent to hazardous waste landfill.

4 Domestic waste 10.2 99 Incinerated in the factory Total 137,932.2 -

4.8.5 Discharge of Pollutants under Abnormal Conditions The abnormal working conditions of this project mainly include the following conditions: first, the semi-dry flue gas treatment facility supported for the incinerators cannot reach the normal treatment efficiency; second, the accidental discharge of dioxin when the incinerators do not operate steadily; third, the accidental discharge of odor when the incinerators are shutdown for overhaul; four, the leachate leakage accident.

4.8.5.1When the Treatment Efficiency of the Semi-dry Flue Gas Treatment Facility Decreases In this project, it is planned to adopt the semi-dry reaction tower and bag-type dust collector to purify the flue gas and the main equipment include semi-dry neutralizing tower, bag-type dust collector, draft fan and neutralizer feeding system and so on. After the waste air passes the flue gas purification system, the smoke (mill) dust, chlorine hydride and other gases in the flue gas will be exhausted out to the atmosphere through a chimney with a height of 80 meters. Under the normal condition, the dust removal rate of the flue gas purification system is 99.9%, and the removal rate of chlorine hydride is 95%. The man-made or mechanical failures which probably occur in the flue gas treatment system will directly influence the operation of flue gas purification system.

Under the normal conditions, if the removal rates of PM10 and chlorine hydride are respectively 99.9% and 96%, the emission rates of PM10 and chlorine hydride are

3kg/h. If the removal rates of PM10 and chlorine hydride under the abnormal conditions are respectively 90% and 80%, the emission rates of PM10 and chlorine hydride respectively are 300kg/h and 15kg/h.

4.8.5.2The Emission of Dioxin When the Incinerators Are Not Running Steadily

131 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Theoretically speaking, when the retention time of flue gas in 850℃ reaches 2 seconds, most organic substances can burn out thoroughly in the incinerators, generating little dioxin. However, the incinerators cannot operate steadily and continuously when start up (temperature rise) and shut down (blow out), and thus will generate dioxin. In this project, ignition (closed incinerator) will start up the ignition combustion system. If the measures are not been put into force, the concentration and production capacity of the dioxin generated during the garbage incineration will be apparently higher than those in normal conditions. According to the relevant data --- the tests conducted in Britain’s six companies on the garbage incinerator starting under abnormal working condition, when the incinerator starts, the concentration of dioxin at the outlet of the incinerator is 2 or 3 times higher than that under normal working condition. In consideration of the extreme unfavorable conditions, if active carbon absorption and bag-type dust collector cannot run normally at this time, the maximum emission concentration of dioxin at the outlet of chimney can reach 5ngTEQ/Nm3. At this point, the amount of waste gas is about 240,000m3/h, lower than that under normal conditions; and the emission capacity of dioxin is 1,200ugTEQ/h, the duration time not exceeding one hour. The accident of this kind is caused because the production control is ineffective, temperature of incinerator is too low, the CO content in flue gas is too high, and the active carbon absorption and bag-type dust collector cannot run normally. Therefore, the probability of this accident is extreme low. The emission source intensity of incineration flue gas under accidental conditions is shown in Table 4.8-8.

Table 4.8-8 Atmospheric Pollutant Source Intensity under Abnormal Conditions Emission Emission parameters Amount of Removal Inner flue gas Pollutant rate Concentration Emission Height Temperature diameter Nm3/h % (mg/m3) ratekg/h (m) (℃) (m)

HCl 80 50 15 300,000 3tubes × Dust 90 1000 300 80 150 DN2.0 240,000 Dioxin - 5ngTEQ/Nm3 1,200ug/h

132 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 4.8.5.3 The Offensive Odor Emission When the Incinerators Shut down In general circumstance, the 3 sets of incinerator systems established in this project will not be put into overhaul at the same time, and the odor from the garbage dump pit is extracted by air fan to the incinerators for incineration. However, in the circumstance where all the three incinerators shut down, emergency measures shall be taken for treating the odor. When the boiler stops due to accident or overhaul, the gas exhausted from the garbage dump pit shall be given deodorization treatment, with an air change rate of about 1~1.5 times/h, adopting the active carbon exhaust gas cleaner to remove odor. The active carbon exhaust cleaner is divided into inlet section, filtration section and outlet section. After enter from the inlet, the odor will be filtered in the filtration secretion where active carbon exists, with most organic exhaust gas absorbed to the active carbon grains and final discharged into atmosphere. The deodorization device is installed on the roof of the building near the garbage pit. The garbage pit is 100m away from the exhaust funnel of the incinerator, and there is no enough power for incinerator to draw the odor in the exhaust funnel and discharge, so the odor shall be discharged nearly after been deodorized on the roof of the building near the garbage pit.

The main components of the odor are NH3 and H2S. Based on the monitoring data of similar projects, the emission of odor under accidental conditions is shown in Table 4.8-4.

4.8.5.4The Abnormal Discharge of Leachate Considering that the leakage accident takes place in the sewage tank for leachate of the construction project and if the wastewater leakage time is 30 minutes, the concentration of COD in the leachate is 41,000mg/L, and the amount of pollutant COD actually leaked is 854.17kg.

4.8.6 Reduction of Pollutants by Using New Method to Improve Old One 1Reduction of exhaust emission This project is domestic waste incineration project, with certain environmental

133 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited sensitivity. In order to increase the domestic waste treatment capacity without increasing pollution in air environment, Everbright Environmental Protection Energy (Suzhou) Co., Ltd plans to, with the existing project reaching the standards, further improve its performance and take the following measures of “using new method to improve old one” in the Phase expansion project to ensure that the concentration of the dust in the incineration flue gas can reach EU 2000 emission standard. On this basis, the dust emission amount of Phase and Phase will be reduced so as to keep the emission amount of air pollutants of the whole factory under the existing total amount ratified after the completion of Phase expansion project. The main measures of “using new method to improve old one” against waste gas include: (1) improve the combustion control technology---to reduce the dust amount in the exhaust gas by controlling the times of stirring state, strictly controlling the air leakage amount and reducing the flow rate of flue gas; (2) select the bag of high efficiency of dust collection and clean the bag in time to ensure that the emission concentration of flue gas can reach EU 2000 Standard; (3) add the dry deacidification system and inject lime hydrate into the air flue before the flue gas enters into the air flue to further reduce the emission amount of HCL and other acidic gas in the dust. Based on the flue gas amount monitored for the acceptance of Phase and Phase and EU 2000 standards of emission connection, the changes on the emission amount of air pollutants of the existing project after the completion of measures of “using new method to improve old one” are shown in Table 4.8-9.

Table 4.8-9 The Changes on the Emission Amount of Air Pollutants of the Existing Project after the Completion of Measures of “Using New Method to Improve Old One” Emission after technical Current situation of upgrading emission Emission Emission Average Pollutant Emission Emission Emission reduction source monitored concentration amount amount t/a concentration (mg/m3) t/a t/a (mg/m3) Incineration Dust 10 23.58 17.9 38.08 14.50 chimney of SO 2 10 17.30 10.5 18.17 1 the existing NO X 170.7 362.30 170.7 362.3 0

134 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited project HCl 5.1 8.56 6.5 10.91 2.35 HF 0.95 2.02 0.95 2.02 0 CO 37.5 90.29 37.5 90.29 0 Pb 0.05 0.12 0.05 0.12 0 Hg 0.003 0.006 0.003L 0.006 0 Cd 0.002 0.004 0.002 0.004 0 0.073ngTE 0.073ngTEQ/ Dioxins ≤ ≤ 0 Q/Nm3 ≤0.19g/a Nm3 ≤0.19g/a

2Reduction of water pollutants While constructing the Phase expansion project, it is planned to upgrade the existing leachate treatment station and add the advanced treatment technique of “nanofiltration+reverse osmosis”. After advanced treatment, if the leachate meets the standard for the make-up water for the open circulating cooling water system specified in The Reuse of Urban Recycling Water. ―Water Quality Standard For Industrial Uses (GB/T19923-2005); it can be reused as circulating cooling water. The upgrading can reduce the emission amount of leachate of the existing project by 656t/d, which is shown in Table 4.8-10.

Table 4.8-10 Changes on the Wastewater Discharge of the Existing Project after the Completion of “using new method to improve old one” The reuse after technical Current situation of discharge upgrading Reduction Discharge Concentration Pollutants of discharge source Concentration of of water Discharge t/a the water reused through amount (mg/m3) pipeline t/a (mg/m3) Amount of wastewater 218,448 218,448 COD Wastewater 60 500 109.22 109.22 after BOD5 10 leachate 300 65.53 65.53 SS treatment / 400 87.38 87.38 NH -N 3 10 35 7.65 7.65 TP 1 8 1.75 1.75

135 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 4.9 Summary of Pollutant Discharge

4.9.1 “Three Accounts” of the Pollutants of Phase Expansion Project The “Three Accounts” of the pollutants of this project are shown in Table 4.9-1.

Table 4.9-1 List of the “Three Accounts” of the Pollutant of This Project Unit: t/a Pollutant amount Final Name of Production Reduction Category discharged discharge pollutant amount amount through amount pipeline Amount of wastewater m3/a 258,408 255,744 2,664 2,664 COD 4,478.27 4,477.20 1.07 0.13 Wastewater BOD 5 1,540.78 1,540.24 0.53 0.03 SS 387.35 386.95 0.40 0.03 NH -N 3 255.97 255.88 0.09 0.01 TP 31.60 31.59 0.01 0.001 Dust 16,368 16,351.63 / 16.37 SO 2 109.12 92.75 / 16.37 NO X 589.25 294.63 / 294.62 HCl 208.69 200.34 / 8.35 HF 16.37 14.73 / 1.64 Waste gas CO 81.84 0 / 81.84 Pb 8.18 7.36 / 0.82 Hg 0.82 0.74 / 0.08 Cd 0.82 0.74 / 0.08 Dioxins - - / 0.1637g/a Industrial solid 137,922 137,922 0 waste Solid waste / Domestic waste 10.2 10.2 / 0

136 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 4.9.2 Collection of the Pollutants of the Whole Factory after the Completion of Phase Expansion Project

The accounting of “Three Accounts” of the pollutants of the whole factory after the completion of this project is shown in Table 4.9-2. It is clear from the table that the discharge amount of the pollutants of this project can be balanced in the existing total amount ratified for the whole factory.

Table 4.9-2 Statistics of the Discharge Amount of Pollutants before and after the Expansion of the Factory δt/aε

This project Reduction through Amount the Discharge discharged Discharge of Reduction measures amount Ratified from Category Name the established Production amountOr Discharge of “using of the total pipeline of projects amount disposal amount new whole amount the whole amount method to factory factory improve old one” Amount of 11,988 wastewater 227,772 258,408 255,744 2,664 218,448 11,988 104,590*

COD 0.60 113.89 4,478.27 4,477.20 1.07 109.22 5.73 89.96* Wastewater BOD 5 68.33 1,540.78 1,540.24 0.53 65.53 3.33 0.12 SS 91.11 387.35 386.95 0.40 87.38 4.13 0.12 37.17* NH -N 3 7.97 255.97 255.88 0.09 7.65 0.42 0.06 3.5* TP 1.82 31.60 31.59 0.01 1.75 0.09 0.01 Dust 38.08 16,368 16,351.63 16.37 14.5 39.95 48.21

SO2 18.17 109.12 92.75 16.37 1 33.54 247 NO X 362.3 589.25 294.63 294.62 0 656.92 694.1 HCl 10.91 208.69 200.34 8.35 2.35 16.91 19.29 Waste gas HF 2.02 16.37 14.73 1.64 0 3.66 CO 79.60 81.84 0 81.84 0 161.44 Pb 0.11 8.18 7.36 0.82 0 0.93 Hg 0.006 0.82 0.74 0.08 0 0.086 Cd 0.004 0.82 0.74 0.08 0 0.084

137 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Dioxin 0.19g/a - - 0.1637g/a 0 0.3537g/a 0.3855g/a Industrial 0 137,922 137,922 0 0 solid waste 0 Solid waste Domestic 0 10.2 10.2 0 0 waste 0 *Note: in the former assessment report and written reply, the leachate shall be sent to leachate treatment plant set in Qizishan landfill for treatment, therefore, the total amount ratified for wastewater and water pollutants of the existing project does not include the discharge amount of leachate.

138 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

5 Comment on Pollution Prevention Measures

5.1 Comment on Air Pollution Prevention Measures The waste gases of the project are flue gases produced from destructor, which contains many pollutants, mainly acid waste gases (SO2, HCl and HF, etc.), smoke and dust, NOX, CO, heavy metal (Hg, Cd and Pb, etc.) and dioxin and so on. Air pollution prevention primarily focuses on reducing pollutant generation from the source: Phase expansion project uses the same reciprocating grate furnace system with hydraulic control gear as the existing project. Each grate bar is divided into 3 sections: the first section is drying zone, the second is preheating zone and the third is burning zone. Each section is composed of fixed grate bar and movable grate bar, overlapping with each other. Primary air could blow from the –lower-grate bar into it to provide oxygen for burning rubbish and cool off the grate bar. The structure of this grate enables rubbish to be stirred, smashed up and fully contacted with oxygen. Burning control program can adjust the rolling speed of the grate and primary air rate in each section automatically, make primary air pressure up to optimum proportions and ensure the fully burning of domestic waste on the basis of burning conditions inside of the furnace. This process could give off a mass of heat which keeps the whole furnace at a higher temperature (above 850℃) and reduces the production of all kinds of pollutants effectively, such as CO and organic pollutant, etc. To guarantee a fully decomposition of hyperoxic-organic pollutant, the upper furnace is designed with a vertical flue of nearly 20m in height (the first channel of burning boiler), which makes flue gases stay more than 2 seconds above 850℃, and an auxiliary air (its temperature is adjustable) snout is allocated at the access point of this flue, which can make full mixing of flue gases (in 3T control method). A burner is placed above the left and right side wall of auxiliary air snout respectively. As the heat output from rubbish burning is lower, the burner would be put into use automatically to ensure flue gases stay at least 2 seconds above 850℃. Through the above measures, a majority of organic pollutants produced in burning process could be broken down and decomposed and the final density of organic pollutants, especially dioxin, in boiler exit could be decreased maximally.

139 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited On the basis of the current project operation experience of Everbright Environmental Protection Energy (Suzhou) Co., Ltd, the inside of furnace adopted the

SNCR denitration system with ammonia as deoxidizer to decline the emission of NOx. Semi-dry process deacidification tower + dry process deacidification+ activated carbon absorption+bag type collector are used for dealing with flue gases in the burning furnace, which can ensure that the emission of incineration flue gases are stable, reliable and can reach its standards. Each burning furnace has one set of fume treatment system.

5.1.1 Control of NOx

The NOX produced in burning process are mainly in three ways: thermal NOx is produced from nitrogen of the air by oxidation at high temperature; fuel NOx is produced from nitrogen compound contained in the fuel material by oxidation after thermal decomposition in the burning process; prompt NOx is produced by the reaction of nitrogen of the air with hydrocarbon in the burning process. Presently,

NOx control technology mainly contains all sort of low NOx burning technologies, such as air-staged combustion, fuel-staged combustion, and flue gas denitrification technology, such as SCR and SNCR, etc.

SNCR, i.e. selective non catalyst reduction technology, could reduce NOx into nitrogen and water by chemical reaction, without catalyst, at high temperature

(850~1100℃) through puffing -NH3 reducer like nitrogen and urea solutions into flue gases. According to the Circular on Further Strengthening Environment Impact Assessment Management of Biomass Power Generation Projects, Environmental-development No. 82, 2008, it is required “to build up domestic waste project in metropolis areas or areas where control of NOx is specially required, and to set up necessary denitration unit. In other areas, it is expected to leave room for NOx deprivation”. In Jul. 2009, Everbright Environmental Protection Energy (Suzhou) Co., Ltd introduced the destructor flue gases denitration technology and key equipment, which can be used for the transformation of SNCR denitration technology for the existing 5 sets of destructors with ammonia as reducer, from Sweden Petro Miljö Company. This transformation is general contracted, carried out and finished by

140 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Shanghai Techspray Co., Ltd. The denitration system is steadily operated now and the 3 average volume of NOx emission is controlled below 150mg/m . Phase expansion project will use the same denitration technology as the 3 existing project, which can reach the density requirement of 180mg/m for NOx in the EU 2000 Standard and is far below the 400mg/m3 standard defined in the GB18485-2001Standards for Pollution Control on Domestic Waste Burning.

5.1.2 Control of Acid Gases On the basis of the existing project processing unit, with the measure of “using new method to improve old one”, acid gases are control by adopting Semi-dry process deacidification tower + dry process deacidification methods. Quench tower Flue gases discharged from the flue of exhaust-heat boiler are still of high temperature. After entering the quench tower, they can be cooled off to the appropriate temperature to keep a higher efficiency in the latter reaction. Spraying system of lime slurry This system is composed of lime storage bin, connecting pipeline and lime slurry sprayer, etc., which is used for supplying the three burning line of Phase expansion project. Lime (CaO) is sent into lime storage bin through pneumatic system, with antibridging device set on the top. And then, spraying lime slurry into the reaction tower to make deacidification reaction. The spraying volume of lime slurry is controlled by the online flue gases monitor system and temperature instrumentation in the absorbing tower exit. Semi-dry neutralization reaction tower The inside of this device is equipped with lime slurry nozzle and water nozzle. The lime slurry sprayed in the reaction tower, after being atomized, is of very large specific surface which can fill up the space of the whole tower, hence ensures the fully contact of absorbent with flue gases. In the lime slurry mist, flue gases occurs deacidification reaction with Ca(OH)2, and acid gases, such as SOx, HCl and

HF, etc. are removed after occurring neutralization reaction with Ca(OH)2. At the same time, temperature of flue gases presents further decline. Through the treatment, flue gases are released from the upper tower. At the horizontal flue, there is a cyclone, which separates part of the flue gases back into tower for further reaction to improve

141 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited the reaction efficiency, leaving the remaining gases enter into a bag dust collector through connecting flue. As semi-dry desulfurization method is adopted, the utilization efficiency of neutralizer (dry powder) inside deacidification tower is of larger improvement in extent than dry desulfurization, which accelerates the efficiency of neutralization reaction and increases the deprivation rate of acid gases. The advantages of semi-dry flue gases reaction tower in this project are as follows: 1. Depickling neutralizer is supplied in form of dry powder, thus avoids the complex and cloggy pulping system. In addition, it is easy to operate and maintain and of low failure rate; 2. Depickling neutralization products are discharged in form of solid grain avoided the complex and costly wastewater treatment equipment and further reduced the constructing and operating cost; 3. The existing project runs stably and reaches the standards with guaranteed maintenance. Dry deacidification With the measure of “using new method to improve old one”, this project adds a dry deacidification system. Jet slaked lime into its storage bins through pipelines; and then, adjust the dosing through air conveying distributor; finally, spray them into the front flue of cloth bag through the roots blower and spraying pipeline, to go for further acid gases removing from flue gases. With reference to the existing project operation monitoring data, the efficiency of semi-dry deacidification in Phaseandis about 78%.; And with reference to the data supplied by equipment supplier and the design data that efficiency of dry deacidification is above 82%. Therefore, the removing rate of acid gases can reach 96% through semi-dry deacidification tower +dry deacidification measures. By replacing the old by the new, all sorts of acid gases emission can reach the discharge concentration standards of EU2000.

5.1.3 Control of Heavy Metal Species and Particulate Matter The key point to prevent pollution is to control the generation of pollutants from its source. Hence, in applying the measure of “using new method to improve old one” in this project, productions of smoke and dust matters in waste gases are declined by

142 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited improving burning control system — taking measures such as control the frequency of stirring grate, control air leak volume strictly and reduce flue gases’ velocity. Heavy metal pollutants exist in flue gases in forms of solid and gas. As flue gases temperature drops, part of the gas matters would transform into solid and liquid granula that can be collected by bag type collector. However, for heavy metals with high volatility, e.g. Hg, there is still part of them exist in flue gases in form of gas even though the fume cleaning system is operated at the lowest temperature. In such case, it needs to be absorbed by active carbon and removed by bag type collector finally. According to the operating experience, heavy metal pollutants could achieve better cleaning effect as fume cleaning system runs at the lower limit of controlling temperature. Bag type collector can separate fly ash in flue gases, reactant in reaction tower and active carbon absorbed with heavy metals and organic pollutants. With reference to the existing project operation monitoring data, the existing dust collection efficiency, by using bag type collector in Phaseand is around 98%. Phase expansion project is planned to use new high efficient bag filter to improve old one. According to the data supplied by equipment supplier, this type of filter is of favorable system design and stable operation, with dust collection efficiency above 99.9%, which could guarantee that the discharge of particulate matters can reach the national standards. Highly active PTFE laminating bag, which this project adopted, is the advanced bag type collector relatively at present. Laminating surface is smooth and able to bear chemical species. Covered to the surface of general filter material, it could act as a disposable dust layer; dust could be fully trapped in the laminating surface, thus filtering in the surface layer can be fulfilled; in addition, owing to the smooth laminating surface, it is of mighty chemical stability—anti-aging, hydrophobic, which makes the dust trapped in its surface easy to flake off and prolongs the performance life of filter material. Compared with general filter materials, its advantages are: 1. Laminating aperture is between 0.2μm and 3μm, so that its filtering efficiency could reach above 99.99% on the average, nearly close to zero release. Porosity won’t be changed after removing ash, which keeps its dust collection efficiency at high level. 2. At first using of laminating filter material, its pressure loss is more than general filter materials. After putting it into service, its loss changes little with the using time going,

143 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited however, the loss from general materials would increase with the extend in using time. 3. In using general filter materials, it’s easy for dust to enter into it and piles up until the pore is plugged firmly and couldn’t carry on working. But, in using PTFE laminating material, the filterable dust is easy to be removed from the surface. With its fine deashing effect, long cycle and low deashing pressure intensity, laminating filter’s performance life is prolonged. In addition, product operating cost is also declined.

5.1.4 Control of Dioxin

5.1.4.1Theoretical Basis Dioxin Matter In a broad sense, dioxin species belongs to polychlorobiphenyl (PCB), however, it is separated into a single species for its particularity. In general, dioxin refers to polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofuran (PCDFs). According to the atomicity that replaced H atom and their locations, PCDDs has 75 substitutive derivatives, and that of PCDFs is 135. PCDD/Fs are a sort of three-ring aromatic organic compound with high toxicity. It is solid at normal temperature and pressure, and characterized by its higher smelting point, water insoluble and fat soluble, hence, PCDD/Fs are easy to be accumulated in living body. Furthermore, they are easy to be absorbed by surface of earth and mineral. In normal environment, they are rather stable with low biological metabolism process. Though in the same sort of dioxin chlorides, there are large differences in their physical and chemical property. Even between the isomers of the same polychlorinated dibenzo-p-dioxins also exists obvious variation in their nature. Toxicity and Poison Mechanism The toxicity of all dioxins isomers is different from each other, in which 2, 3, 7, 8- tetrachlorodibenzo-p-dioxin (2, 3, 7, 8-TCDD) is the strongest, characterized by colorless or white crystalline solid, up to 1000 times of the toxicity of potassium cyanide. Therefore, it is called the poison with the strongest toxicity on earth. Presently, the toxicity of 2, 3, 7, 8-TCDD is defined as 1 in the international, and the relative toxicity of its isomer is figured in toxicity equivalent factor (TEF), see table 5.1-1.

144 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 5.1-1 International Toxicity Equivalent Factor of Dioxin International toxicity Dioxin equivalent factor 2378-TCDD 1 12378-PeCDD 0.5 123478-HxCDD 0.1 PCDDs 123678-HxCDD 0.1 123789-HxCDD 0.1 1234678-HpCDD 0.01 12346789-OCDD 0.01 2378-TeCDF 0.1 12378-PeCDF 0.05 23478-PeCDF 0.5 123478-HxCDF 0.1 PCDFs 123678-HxCDF 0.1 123789-HxCDF 0.1 234678-HxCDF 0.1 1234678-HpCDF 0.01 1234789-HpCDF 0.01 12346789-OCDF 0.001 Other PCDDs and PCDFs 0

Formation Principle of PCDDs,PCDFs According to relevant studies, the followings are the formation principle of dioxin in burning rubbish: Pyrosynthesis: i.e. PCDD is formed at high temperature gas phase. As refuse come into the initial dry stage in incinerator, except from water, low boiling point organism with carbon and hydrogen components would react with oxygen in the air to make water and CO2. This comes into being oxygen deficit temporarily, which makes part of the organism react with HCl to produce PCDD. In incinerate technological standards, hypoxia status is estimated per concentration of CO. De novo synthesis: at low temperature (250~350℃), macromole carbon (carbon residue) reacts with organic or inorganic chlorine in the matrices of fly ash to produce PCDD. In carbon residue oxidizing, 65%~75% of which are transformed into CO and about 1% chlorbenzene and then converted into PCDD. For carbons in fly ash, the higher gasification rate of that, the more production of PCDD.

145 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Precursor synthesis: incomplete combustion and misproportion catalytic reaction in fly ash surface can form many kinds of organic gas phase precursor, e.g. polystream phenol and diphenyl oxide, and then these precursors would be further reacted to PCDD. In the early fly ash, which produces aluminosilicate after burning at high temperature, there are fixed transition metal and carbon residue. Fly ash granula forms into a large absorbing surface. While it is out of the furnace for cooling off, many surface reactions occurs among products of incomplete combustions on the granula surface, and between products of incomplete combustion and other precursors; and alternately, fixed metal and its metal-salt occurs many condensation reactions to make surface active chloride. Then PCDD is made by absorbing in the surface of flying granula through many complex organic reactions. The temperature used to burning refuse is 750℃. In the case of oxygen excess, it’s the most possible time to make incomplete combustions. In practice, it depends on furnace lines, operating state and combustion condition to estimate the leading mechanism. To sum up, the precondition to produce PCDD is: there must be organic or inorganic chlorine, oxygen, and transition-metal cation being catalyst. Accordingly, production of PCDD/Fs is mainly caused by chlorine sources in rubbish and incomplete combustion. To sum up, the precondition to produce PCDD/Fs is: there must be organic or inorganic chlorine, oxygen, and transition-metal cation being catalyst; in particular, copper plays a decisive role in the fly ash catalytic reaction occurred in burning process. Therefore, there are three ways that can be used to keep PCDD/Fs from being produced: Improve combustion condition by reducing PICs and carbon residue volume; Prevent chlorination process (including measures like spraying ammonia, etc.); Prevent biaryl synthesis (poisoning the catalyst by spraying ammonia, etc.). Combustion and decomposition of organic unfriendly materials In the process of domestic waste incineration, many unfriendly materials (POHC) are produced, among which PCDD and PCDF are of enormous toxicity and carcinogenic. After being discharged with flue gases, they would migrate in the environment, occurring chemical reaction, photochemical reaction and metabolism and biodegradation, and be accumulated up permanently with character of durability.

146 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited At present, organic unfriendly materials that attracted universal attentions are mainly methylbenzene, chlorethene, dioxin and dioxin-like chlordiphenyl (PGBS), etc. Those materials could be broken down and decomposed at high temperature. The fail temperatures are shown in table 5.1-2.

Table 5.1-2 Data Sheet on Fail Temperature of POHC

Spontaneous At failure rate of 99.99%, the Lower limiting POHC ignition temperature stays at temperature temperature 1 second 2 seconds

Acrolein 430 234 549 524 Acrylonitrile 677 418 729 703 Propenol 566 378 635 580 Allyl chloride 621 485 691 649 Benzene 690 562 733 717 Chlorbenzene 621 389 667 646 12 dichloroethane 732 638 764 744 Ethane 582 413 658 634 Alcohol 692 515 742 720 Ethyl acrylate 677 423 708 680 Ethene 538 383 611 589 Ethyl formate 649 450 720 694 Ethanethiol 593 455 644 618 236 371 299 712 789 7—tetrachlorodibenzene Chloromethane 649 537 840 808 Methyl ethyl ketone 815 632 869 823 Propane 649 516 699 675 Propene 649 466 721 704 Toluene 649 455 714 675 Spasmolytol 690 536 727 702 Vinyl acetate 510 232 594 570 Chlorethene 621 427 662 692

5.1.4.2 Countermeasures of Dioxin Prevention in This Project Pollution prevention techniques of dioxin can be concluded into the following three categories:

147 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 1. Prevent dioxin-like matters from being produced through improving combustion condition.

Incinerator in this project achieves “Three T” control principles, namely, turbulent mix burned gas with air, enough burning time and combustion-air supply that is available in high-temperature zone, and good assurance to prevent dioxin-like matters from being produced. Incinerating gas stays above 2s inside the furnace and combustion zones above secondary air; temperature of flue gases is above 850℃; ensure plenty of oxygen supply; make sure to meet the requirement of “temperature at the exit of gas is no lower than 850℃ and staying time of gas shouldn’t be less than 2s” as per Pollution Control Standards of domestic waste Combustion,GB18485-2001. In such case, production of dioxin could be reduced effectively. 2. Absorb precursors surviving in end gas and prevent it from re-synthesis into dioxin-like matters by adopting high efficient incinerating flare system. High-temperature flue gases produced from combustion could be cooled to about 190℃ after entering into quench tower. Such case can effectively prevent it from re-synthesis into dioxin-like matters at temperature of 300~500℃.

3. Absorb dioxin granulae clotted in low temperature flue gases by active carbon, and collect them by dust collector. To further enhance the removing effect, it is needed to use active carbon as absorbent and set-up transmission, metering, anticlogging and spraying devices for active carbon powder. According to the accept and routine monitoring data of Phase project, emission control measures adopted in this project can effectively keep the discharge volume of dioxin below 0.1ngTEQ/Nm3 (see table3.6-3) and reach the emission standards of EU. To sum up, since the combustion temperature of this project is strictly keeps above 850℃ and the time flue gases staying in furnace is no less than 2s, with stable combustion, dioxin production is avoided effectively. With the following quenching measure, dioxin re-synthesis is prevented significantly. Through the final absorbing by active carbon in effluent gas treatment system, concentration of dioxin is further declined. All the process guaranteed the reaching of emission standards.

148 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 5.1.5 On-line Flue gases Monitoring Devices On-line flue gases monitoring device system can analysis the emission of source pollution gas monitor the discharge amount in succession online, as well as many criterions such as gas parameter, dust loading and gas pollutant, etc. Its functions are real-time display, listing parameters, printing report forms, storing and displaying historical data, analyzing graphic chart and diagram, overproof alarm, accident alarm, status display and identification, etc.; The system data can be shared through MODEM/GPRS remote transmission or connecting with other computers within the local area network. The system is of anti-correction and standardization functions. Online monitor device mainly checks the relating parameters of smoke and dust

(granula matters), SO2, NOX, CO and HCl concentrations, flue gas amount, temperature, humidity and oxygen content, etc., and count emission rate and total emission. It is clear that, in this project, gas enters into the bag type collector finally through the process of denitration in heat recovery boiler, incinerating the end gases in semi-dry fume reaction tower, dry deacidification, and then absorbing by active carbon. Through this process, most of the smoke and dust and unfriendly matters are removed. At last, gas that reaches the emission standard after cleaning is discharged into the air through a three-tube chimney of 80m in height.

5.1.6 Control of Malodor

5.1.6.1Control Malodor under Normal Operating Condition Malodor in destructor plant is mainly derived from the solid waste itself. Basically, it occurs near garbage storage pit, rubbish discharging lobby, leachate storage pit and incinerator, etc. In this project, to prevent malodor from spilling, the following control measures are taken to treat the main malodor polluting sources such as rubbish storage pit and rubbish discharging lobby, etc.: 1 Adopt sealed compressive self-unloading rubbish carrier vehicle; set-up rubbish discharge gate at the access to the main house unloading platform of destructor plant. 2 Adopt refuse pit with close framework; absorb primary air from the top of rubbish storage pot to support combustion in incinerators; keep refuse pit at status

149 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited of negative pressure in normal operation to avoid escaping of odor. 3 Regulate the operating management of domestic waste to reduce odor production; stir rubbish by use of bucket grab to avoid anaerobic fermentation of rubbish, so as to reduce the malodor production. 4 Keep the residue storage pit at closed and negative pressure status by use of closed residue conveying system. Odor is sent by blower fan to rubbish storage pit as primary air in combustion process. 5 In operational stage, the main measure to control odor is to strengthen control on the closeness of rubbish pit, for instance, do the best to reduce the off -production frequency of the whole plant, keep primary air suction system running normally, adopt closed vehicle for entering-plant rubbish truck, close the discharge gate of rubbish storage pool after use, etc.

5.1.6.2Control Malodor under Accident Conditions In the period of stop operation and overhaul owing to boiler accident, malodorous gas in the rubbish pit can’t be cleaned through incinerating combustion. Therefore, the rubbish storage pit needs to be kept closed, and gases in the pit can be discharged after being deodorized by active carbon exhaust gas cleaner. Frequency of air change is about 1~1.5 times per hour. The processes in the cleaner can be divided into three stages: air intaking stage, filtering stage and air-out stage. Odor enters into the cleaner through the air inlet; and then, filtered by active carbon in the filtering stage, most of the organic gases are absorbed on active carbon granulae; finally, it is blown into the atmosphere by exhaust fan. Deodorizing devices are installed in the building roof beside the refuse pit. Each destructor is equipped with a set of deodorizing devices. Therefore, measures of odor pollution control are feasible in this project.

5.1.7 Measure of Preventing Fly Ash by Solidifying Dust The self-contained fly ash solidifying workshop of this project is located in hazardous waste landfill site. Fly ash produced from combustion is transported to that workshop by tank lorry. The solidifying process of fly ash is totally- enclosed. Part of the fly ash enters into the air after dust emission and is discharged from roof after dedusting through bag type collector.

150 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

5.1.8 Reachability Analysis on Flue Gases Pollution Control Technologies in This Project According to datum on the existing project acceptance and routine monitor, indexes of all the pollutants in flue gases are able to meet the relevant national standards, among which the performance of dioxin-like pollutants reach the EU standards limit, 0.1 ng-TEQ/Nm3. Therefore, this project adopted the same fume processing technique as the existing project, which can ensure that flue gases can be discharged stably and reach the standard. After taking the measure of “using new method to improve old one”, discharge concentration of dust in incinerating smoked gases of the whole plant is guaranteed to reach 10mg/m3 in EU 2000 Standard.

151 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 5.1-3 Treatment Effect of Flue Gases in This Project Production status Discharge condition Removing rate Effluent standard Pollutants Concentration Production Treatment measures Concentration Speed Effect % (mg/m3) (mg/m3) (kg/h) (mg/m3) (kg/h)

Smoke and dust 30

10000 2046 99.9 10 2.05 Discharge after reaching the standard SO 2 67 13.64 85 10 2.05 260 SNCR denitration NOX 400 360 73.66 + 50 180 36.83 HCl 127.5 26.09 semi-dry reaction 96 5.1 1.04 50 tower HF 2 10 2.05 + 90 1 0.20 CO 50 10.23 dry deacidification+ 0 50 10.23 100 Pb Active carbon 5 1.02 absorption 90 0.5 0.10 1.6 Hg 0.5 0.10 + 90 0.05 0.01 0.1 Cd bag type collector 0.5 0.10 90 0.05 0.01 0.1 0.1ng 0.1ng Dioxin - - - ≤ ≤20.46 TEQ/Nm3 ug/h TEQ/m3

152 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

5.2 Comment on Water Pollution Prevention Measures

5.2.1 Drainage System This project adopts the clean water (rainwater) and sewage shunting system. A small amount of leachate injects back and the rest part enters into self-contained percolate preprocessing station for treatment. Until reaching the standards, it is recycled to cool off make-up water in circulation. House wastewater and oily dining wastewater is taken over by effluent treatment plant in the new district after being processed by septic tank and oil trap respectively. In the chemical water treatment system, drainage section is used for mixing lime slurry, part of which is used for charge mixture of brick field and the rest is used for watering down in road and unloading platform; cooling tower drainage is recycled as slag off cooling water.

5.2.2 Measures of Leachate Treatment In Phase expansion project, the maximum Leachate production is about 480t/d. It is poured into leachate regulating reservoir together with 56t/d sparge water used in unloading platform, among which 50t/d puffs back to furnace leaving the remaining 486t/d enter into existing self-contained leachate treatment plant for treatment.

5.2.2.1 Present Operational Status of Percolate Treatment Station The self-contained percolate disposal station of Everbright Waste Incineration Power Plant was started to construct in Jul., 2009 and was completed and began to debug in May, 2010. It is officially put into use in Sep, 2010. The designed treatment capacity of percolate disposal station is 1000t/d. In 2010, leachate production in the existing Phaseand projects is around 525t/d, among which back-injection amount is about 80t/d and handling capacity of the station is about 509t/a. Therefore, the remaining disposal capacity of the station is around 491t/d, which is enough to treat the newly added leachate in this expansion project. The existing disposal technological flow is: regulating reservoir→preprocessing system of first and secondary order reactive precipitation→UBF anaerobic

153 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited system→SBR aerobic system→SBR effluent buffer pool→build-in ultrafiltration membrane system→drain off system. The above technological process can remove all the high density organic pollutant, ammonia nitrogen and phosphor existed in leachate at a higher rate. It is also operated stably. The processes can be seen in chart5.2-1.

Chart 5.2-1 Technological Flow Chart of the Self-contained Garbage Leachate Preprocessing Station

Preprocess System Preprocess system is composed of regulating reservoir, mixing tank, first order reaction tank, first order desilter, intermediate water pool, secondary order reaction tank, secondary order desilter, outlet sump and its associated equipment, ect. The main function of regulating reservoir is to regulate volume and quality of water, in order to reduce the potential impact load in the latter processing system caused by uneven water. First and secondary order reactive precipitation system mainly takes measure of coagulation sedimentation by putting chemical preparations into leachate to remove most suspended matters and colloidal substances contained in the leachate, and so as to release the processing load that the next structures would bear. Waste water flows automatically into first order reaction tank after mixing with lime in mixing tank, and then, enters into secondary order reaction tank to mix with flocculent. After reaction to form large flocs unit granula, it is separated by settling down from the second tank.

154 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Supernatant enters into effluent pool and then is lifted to UBF system by horizontal centrifugal pump. Sludge precipitated and stored in bagger is drained into sludge thickener for dewatering treatment periodically UBF Anaerobic System UBF anaerobic system is composed of UBF reaction tank (first and secondary order reaction tank), degassing desilter, intermediate water pool and its associated equipment, ect. This system adopts two odors UBF and slaking under mesothermal temperature. Functions of the first order are: hydrolyze and liquefy solid organic into organic acid; release load impact, dilute unfriendly matters and intercept and hold on to hard-degradation solid matters. Functions of the secondary order are: keep on the rigorous anaerobic condition and pH value to profit methane bacteria production; degradate organic matters to produce digestion gas which contains the major methane, and intercept and hold on to suspended solid to improve the quality of effluent water. This system uses diving mixer for internal recycle device, and return-sludge flow pump equipped outside the tank for outer recycle device. The secondary order UBF effluent comes into degassing deposit in degassing desilter to guarantee effluent effect. SBR Aerobic System SBR aerobic system is composed of SBR reaction tank, SBR effluent buffer pool, SBR pump room and its associated equipment, ect. SBR system adopts jet pump and efflux aerator combination system to add enough oxygen to raw waste water, so as to provide metabolism with sufficient oxygen in reaction of aerobic bacteria with organic matters within water, so that organic matters in water can be produced into harmless inorganic matters such as CO2 and water, etc. Aerating volume is offered on the basis of liquid level variation, which ensures the stable operation in biochemical treatment stage with high efficiency. SBR reaction tank takes measure of influent and effluent intermittently. Operating process is finished in five steps: influent, reaction, precipitation, effluent and set aside. The reaction period is 16 hours from entering wastewater to setting aside (this period is adjustable under practical condition). Ultrafiltration System Ultrafiltration system is composed of membrane cisterna, membrane module

155 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited cleaning tank (keep acid and base tank separately), clean water tank, self-contained pump room and its associated equipment, ect. Function of this system is, to a further extent, to remove pollutants (organic matters, COD and BOD, etc.) that are not degradated in biochemical system, so that water output index can be ensured to reach the design requirement. Combined with raw water quality and water utilizing requirement, the main task for treatment of raw water is to remove organic pollutants such as COD, BOD and ammonia nitrogen, etc. Given the convenience of cleaning and replacing wastewater, membrane box uses multi-sets and multi-tank structure located inside membrane treating room. Each structure parameter can be seen in table 5.2-1.

Table 5.2-1 Structure Parameter Effective Effective Title volume depth Quantity Remarks m3 m Regulating 6,270 5.5 3 reservoir Mixing tank 8 2.0 1 First order reaction 30 2.2 3 tank First order 285 2.5 2 desilter Preprocessing Intermediate 175 5.85 1 system water pool Secondary order 14.4 1.8 2 reaction tank Secondary order 128 2.25 1 desilter Outlet sump 238 5.6 1 Reaction Divide it into two cases: first 10,500 10.5 3 UBF tank order and secondary order anaerobic Degassing precipitation 232 2.7 1 system tank Intermediate 614 9.0 1 water pool SBR SBR aerobic reaction 8,160 5.0 6 system tank

156 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Effluent 566 3.0 1 buffer tank Set plane skylight and vent fan Pump house 4.0 1 on its top Membrane Ultrafiltration 156 3.5 5 cisterna system Clean water 105 3.0 1 tank

Treatment efficiency and effect in each processing stage can be seen in table 5.2-2. Effluent standard is in accordance with the three class standards and norms of table 4 and table 1 regulated in the Integrated Wastewater Discharge Standard GB8978-1996. Emissions standards of ammonia nitrogen and total phosphorus are in comply with table 1 norms defined in the Quality Discharge Standard of Sewage Drained to Municipal Sewer (CJ3082-1999).

Table 5.2-2 Effect Analysis on Each Processing Technology Unit: pH zero dimensionand others in mg/L

Title COD BOD NH3-N SS TP pH Quality of influent water 100 Regulating 60,000 40,000 2,000 8,000 5~7 reservoir Predicted quality of effluent water 51,000 34,000 2,000 8,000 100 5~7 Removing rate (%) 15 15 0 0 0 Quality of influent water Preprocessing 51,000 34,000 2,000 8,000 100 6~9 system Predicted quality of effluent water 35,700 23,800 1,800 1,200 100 6~9 Removing rate (%) 30 30 10 85 0 Quality of influent water 35,700 23,800 1,800 1,200 100 6~9 UBF system Predicted quality of effluent water 3,570 2,380 1,800 600 100 6~9 Removing rate (%) 90 90 0 50 0 Quality of influent water 3,570 2,380 1,800 600 100 6~9 SBR system Predicted quality of effluent water 714 238 18 180 100 6~9 Removing rate (%) 80 90 99 70 0 Quality of influent water Ultrafiltration 714 238 18 180 100 6~9 system Predicted quality of effluent water 357 95.2 9 18 8 6~9 Removing rate (%) 50 60 50 90 92 Emission standards 500 300 35 400 8 6~9

5.2.2.2 Upgrading and Reconstruction Plan This upgrading and reconstruction project is planned to add the “nanofiltration+reverse osmosis (NF+RO)” technology. In general, the two systems

157 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited contain preprocessing equipment, reverse osmosis/nanofiltration equipment and post treatment equipment. Preprocessing part is used for adjusting raw water quality to meet the influent water quality requirement for reverse osmosis and nanofiltration system. Post-treatment part is used for adjusting components of water produced from NF and RO process to match the recycling requirement, and to meet the discharge standard of concentrated water on the other hand. In general, quality of water produced from single order RO can’t match the recycling requirement. In order to decline water-producing concentration as much as possible, the RO system is connected in series. Namely, water produced from the former order RO is used for influent in the next order RO. Thus, it is called multi-order RO system (see the following figure).

According to the design data, table 5.2-3 shows the removing rate of all sorts of pollutants through the advanced treatment technology.

Table 5.2-3 Removing Rate of pollutants through the Advanced Treatment Technologies

CODcr BOD5 NH3-N SS Processing unit mg/L mg/L mg/L mg/L Influent concentration 357 95.2 9 18 NF Predicted effluent concentration 142.8 38.08 8.1 9 Removing rate % 60 60 10 50 RO Influent 142.8 38.08 8.1 9

158 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

concentration Predicted effluent concentration 28.56 9.52 4.86 4.5 Removing rate % 80 75 40 50 Recycling standard ≤10 ≤10 -

In this way, after advanced treatment, leachate can reach the make-up water standard of open-circuit cooling water system defined in the Reuse of Urban Recycling Water—Water Quality Standard for Industrial Uses (GB/T19923-2005) , which is reused for circulating cooling make-up water spraying into incinerator together with RO concentrated water for combustion.

5.2.3 Feasibility Analysis on Piping Waste Water

5.2.3.1Overview of Sewage Plant in New District Sewage of this project enters into the first effluent treatment plant in the new district of Suzhou (“sewage plant in new district”, in short) through municipal sewer grid for concentration processing. Sewage plant in new district is established in 90s of the last century, located at the crossing of South Yunhe Rd and Zhuyuan Rd, along the west side of Jinghang Grand Canal in new district of Suzhou. It has been on business more than ten years and keeps good operating status now. Design processing size of the whole plant is 80,000t/d. Currently, all the three phases project have been put into operation with three-tank-alternating oxidation ditch technique. The plant provides concentrated treatment of industrial and house wastewater for new district of Suzhou, and its surrounding towns and villages. It always takes the responsibility of processing leachate that has been preprocessed in Qizishan Refuse Landfill Site. According to the tailwater automatic monitoring statistics of the plant, its tailwater is puffed into the canal only after reaching the standard, and has never been discharged over the standard. Such case has been stably operated in a long time since it was put into operation officially. On the basis of environmental impact assessment on expansion project of the plant, as the possibility of wastewater comes from the upstream canal is 90% (4.2m3/s), its effect distance on the downstream canal is 4,860m; and as that possibility is 50% (19.5m3/s), the distance is 1,470m; since the Xukou watergate will be closed as Xujiang river flows back, the discharged tailwater won’t flow back to Taihu lake.

159 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited The actual taking-over volume of wastewater of the plant is about 60,000t/d at present, and its remaining processing capacity is nearly 20,000t/d. For the existing leachate in Phaseandprojects of Everbright Environmental Protection Energy (Suzhou) Co., Ltd, it is piped into the sewage plant in new district together with domestic wastewater after being preprocessed and reaching the taking-over standard. The current project piping volume on hand is 704t/d, which accounts 3.52% of the plant’s remaining processing capacity.

5.2.3.2 Analysis of Water Quality According to the project analysis chapter, pollutant concentration of house sewage in this project is low: COD≤500mg/L, BOD≤300mg/L, which reaches the piping standard of the plant.

5.2.3.3 Analysis of Water Quantity In the construction of Phase expansion project, upgrading and reconstruction plan is adopted in leachate treatment plant. Leachate is not discharged after advanced treatment, which can reduce 656t/d taking-over wastewater; the newly added wastewater of this project is about 8t/d. Therefore, after taking the measure of “using new method to improve old one”, wastewater piping volume is declined largely. Wastewater piped by the whole plant is only 36t/d, accounting 0.18% of the plant’s remaining processing capacity. To conclude, it’s feasible for this project to pipe wastewater into sewage plant in new district.

5.2.4 Analysis on Measures to Treat Leachate in Accident State The existing project is constructed with a leachate accident collecting system of 11,000m3 to be used for fender system. At the accident state of furnace shut down, leachate flows from the bottom of rubbish unloading outlet and the lateral leachate collector ditch, through the curb under the anti-seepage leachate collector ditch and rubbish store and the leachate storage tank, after being filtered by stainless wire net grid, into leachate balancing tank for temporary storage.

5.3 Comment on Noise Pollution Prevention Measures

160 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited The noise source of this project mainly comes from air force equipment and high-power water pump, etc., e.g. turbo unit and wind turbine, etc. Most of the noise is caused by wind turbine, condenser, steam turbine generator, water pump, air discharge (safety valve) and vapor leakage, etc. To ensure that noise at the plant boundary meet the emission standard, this project takes the following measures: (1) Adopt low-noise equipment for control valve and safety valve of furnace exhaust piping, set small-hole exhaust muffler for stream boiler, and reduce the vibration between valve and muffler. (2) Make sound proof box for wind turbine and equip it with muffler. (3) Take vibration, noise control measures to all sorts of pumps. (4) Make sound proof effect by Fiberglas for turbo unit, install sound-proof chamber, take vibration reducing measure, and install muffler at air inlet/outlet. (5) Use building materials with good sound-proof and sound deadening properties for stream turbine room and boiler house, etc. (6) Enhance management and mechanical equipment maintenance, and test the noise level frequently to clean up the potential hazard. (7) Aim for rational distribution; take greening measure to isolate noise. (8) Plant sound-proof greening belt to set-up a planting barrier.

5.4 Comment on Solid Waste Pollution Prevention Measures

5.4.1 Prevention Measures Solid waste of destructor plant mainly contains clinker, fly ash, sludge of leachate processing station and domestic waste of the plant, etc.

5.4.1.1Ways to Treat Slag Slag produced from incinerator is discharged in form of dry type. At the bottom of each incinerator, there is a slag discharge opening placed in the water cooling type grid plate. After burning the waste, the produced slag drops into water-cooling slag hoist through the discharge opening, and then it is discharged into cinder pit; the thin refuse leaking from grate slit is transported to cinder pit by grate ash leakage conveyor. Finally, slag is loaded upon tip lorry by grab crane and then transported to the self-contained brick field for comprehensive utilization.

161 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited According to the monitoring data, during acceptance period of Phaseproject from Jul.9, 2009 to Jul.10, 2009, ignition loss percentage of slag is 0.36%~0.62%, and the testing result of that in Oct.28, 2010 and Oct.30, 2010 is 0.981%~4.36%, all of which reaches the standard defined in the Standards for Pollution Control on Household Garbage Burning GB18480-2001that percentage should not be more than 5%, and can be land filled directly or put into comprehensive utilization. Therefore, the slag produced from this project can be comprehensively used in its self-contained brick plant.

5.4.1.2Treatment Measures of Fly ash Fly ash refers to reaction products of gas disposal system and smoke dust filtered by bag type collector. It is listed in National Dangerous Wastes Catalogue with serial number of HW18802-002-18. According to the Circular on Further Strengthening Environment Impact Assessment Management of Biomass Waste-to-Energy Projects, Environmental-development N. 82 of 2008, in this garbage power project, “fly ash burning is in the class of hazardous waste, and it is required to be stored and treated in accordance with the Standard for Pollution Control on Hazardous Waste Storage GB18597-2001and Standard for Pollution Control on the Security Landfill Site for Hazardous WastesGB18598-2001. It is required to promote comprehensive use of incinerated fly ash in the case that the adopted technology is sure to breakdown dioxin totally and fix heavy metals effectively, and no secondary pollution is caused in the process of producing and using of fly ash. After Standard for Pollution Control on the Landfill Site for Household Garbage is put into effect, it is also available for furnace cinder and fly ash to be disposed as per the new standard. ” It is regulated in Standard for Pollution Control on the Landfill Site for Household Garbage GB16889-2008 that “after treatment, domestic waste incinerating fly ash and medical waste incinerating residue (including fly ash and bottom slag) must meet the following terms before going for landfill disposal in domestic waste landfill site: 1water content must be less than 30%2dioxin content must be less than 3μgTEQ/Kg 3concentration of harmful component exists

162 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited in leachate, made in accordance with HJ/T300, must be lower than the limit defined in table 1.” For fly ash produced from incinerated in this project, it is tested once a week by Everbright Environmental Protection Energy (Suzhou) Solid Waste Disposal Holdings Limited after solidifying chelation. Through their judgment, if it reaches the requirement of entering domestic waste landfill site, it can be transported to Qizishan Refuse Landfill Site for landfill. Otherwise, it is still transported to hazardous wastes landfill site for safety landfill as hazardous waste.

Fly ash Solidifying System Fly ash in destructor flue gases is collected by bag type collector together with the reaction matters produced from deacidification tower. Then fly ash is transported from the bottom fly ash removal apparatus of bag type collector to tank lorry. At last, all fly ash of the whole plant is delivered to its solidifying workshop by tank car for further treatment. The self-contained flying solidifying workshop is located in the site of Phase expansion project of Everbright Environmental Protection Energy (Suzhou) Solid Waste Disposal Limited (namely, the landfill site for hazardous waste). In the workshop, there is a cement bin 60m3 and two ash bins (both of them are 300m3 in volume). Cement is transported to cement silo by pneumatic. Fly ash stocked in ash bin, reaction matter, cement and coagulant are put into blending bunker as per certain proportions through cinder valve. After mixing those by vibrating blending bunker and putting them into solidify forming machine for shaping treatment. Then, the formed drying solid is transported by motor vehicle to refuse landfill site for landfill treatment or temporarily stocked in the plant, and then follow suit.

Property Analysis of Fly ash The sample of that fly ash is sent to Suzhou Environmental Project Quality Detection Co., Ltd. in Jiangsu province for its heavy metal content testing and Environmental Quality Inspection Center of Tsinghua University for dioxin content testing once a year. According to the mixing fly ash detection report on the 5 incinerators of the company’s existing project from Environmental Quality Inspection Center of

163 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Tsinghua University from Nov.16, 2010 to Nov.26, 2010, its dioxin content is 680ngTEQ/Kg, which is much lower than the limit figure, 3μgTEQ/Kg.

Introduction of Landfill Site Qizishan Refuse Landfill Site in Suzhou was established in 1993. The 4,700,000m3 storage capacity of Phasehas been filled up. In 2009, the site was expanded vertically by 7,800,000 m3 on its former address (it is expected to serve 16 years with designed disposal capacity of about 1600t/d). The newly expanded storage has been completed and put into use. Hazardous solid waste landfill site serves the urban areas of Suzhou with an investment of RMB 78 million and size of 100,000m3 in Phaseproject. Ultimately, its size reaches 600,000m3 with investment of about RMB 253 million. The report on environmental impact assessment of this project has been given a written reply (Suzhou environmental administration N.93, 2006) by Jiangsu Environmental Protection Hall, which states that incinerating residue contains in the class of solid waste treatment (HW18) and Phase project can be put into production officially on Jul.4, 2007. Presently, Phaseexpansion project is under preparation.

5.4.1.3 Other Wastes Solidify the waste active carbon produced from waste gas treatment together with fly ash, and then, landfill it. Other solid waste, such as domestic waste and duolite, etc. is incinerated in the destructor plant.

5.4.2 General Requirement for Storage and Convey of Solid Waste According to the Standard for Pollution Control on the Storage and Disposal Site for General Industrial Solid WasteGB18599-2001, the requirements for storage and disposal site operational management of general industrial solid waste are as follows: Hazardous waste and domestic waste are forbidden to be mixed in the storage and disposal site of general industrial solid waste.

164 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Operator of storage and disposal site should establish inspection and maintenance system to inspect equipment periodically such as dike, dam, and diversion channel, etc. As long as potential deterioration or disorder is found, necessary measures should be taken timely, so as to guarantee its normal operation.

5.4.3 Requirement for Storage and Convey of Hazardous Solid Waste According to the Hazardous Waste Disposal Policy, Environmental Development, N.199, [2011], the requirements for hazardous waste storage are as below: For hazardous waste that has been produced, given it can’t be recycled or treated in the short run, its producer must set-up special facilities for hazardous waste storage, as well as hazardous waste mark. Hazardous waste mustn’t be transferred to any unit without license in any form or stocked in non-hazardous waste storage facilities. Hazardous waste storage facility should have related matching equipment and be managed as relevant regulations. Skirting that could block leakage should be constructed; Materials of floor and skirting should be firm and water tight; in addition, isolation facility and wind- proof, sun-proof and rain-proof equipment are also a must. Foundational infiltration proof layer should be clay bed with thickness above 1m and osmotic coefficient less than 1.0*10-7cm/s; Foundational infiltration proof layer can also adopt high density polyethylene or other artificial anti seepage materials with thickness above 2 mm and osmotic coefficient less than 1.0*10-10cm/s. For places used for storage of liquid and semisolid hazardous waste, the floor must be hard and corrosion proof without any slit. Opposite zone of Incompatible hazardous wastes must be isolated by isolating room. Hazardous wastes (fly ash, ect.) in this project must be temporarily stored as per the above requirements.

5.5 Underground Water and Soil Prevention Measures

165 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited In order to prevent soil and underground water from being polluted, the project pays highly attention to the antiseepage measures of refuse pit, leachate collecting tank, accident tank and fly ash disposal system, etc. With reference to the local geological conditions of natural foundation layer, natural clay, and single-layer synthesize material or double-layer synthesis material is adopted to make the antiseepage under layer of refuse pit, leachate collecting tank, accident tank and fly ash disposal system. In case the saturated permeability coefficient of natural foundation layer is less than 1.0×10-7cm/s and thickness of that no less than 2m, natural clay antiseepage underlayer can be adopted. In case the saturated permeability coefficient of natural foundation layer is less than 1.0×10-5cm/s and thickness of that no less than 2m, single-layer synthesis material antiseepage underlayer can be adopted. Single-layer synthesis material underlayer should be no less than 0.75m in thickness and, after being compacted, its saturated permeability coefficient be less than that of natural clay antiseepage underlayer, 1.0×10-7cm/s, or other material antiseepage underlayer with the equal and above water proof effectiveness. In case the saturated permeability coefficient of natural foundation layer is no less than 1.0×10-5cm/s or thickness of that no less than 2m, double-layer synthesis material antiseepage underlayer should be adopted. Double layer synthesis material underlayer should be no less than 0.75m in thickness and, after being compacted, its saturated permeability coefficient be less than that of natural clay antiseepage underlayer, 1.0×10-7cm/s, or other material antiseepage underlayers with the equal and above water proof effectiveness; water transmit layer and leak detection layer should be laid in the space between its two layers. High density polyethylene that meets the specifications regulated in CJ/T234 or other synthesis materials with equal authenticity should be used for making synthesis material antiseepage underlayer

5.6 Greening Measures Greening is a great advantage to prevent pollution and protect environment. Planting trees and flowers in each open area of the plant can increase the greening level, purify the air, adjust temperatures, reduce noise, beautify environment and improve the self-cleaning capacity of the environment, which is also one of the fundamental measures to protect environment. In particular, greening is also the key

166 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited content of enterprise environmental protection. It is an important part in constructing a civilization and clean garden-like factory. Therefore, greening should be considered as the important part of this project and planned at the stage of general plan layout. The planned greening rate of this project is 30%. Suitable greening plants is chosen to be planted on the basis of the plant detail condition and pollution characters of this project and by taking comprehensive account of the property of discharged pollutants and local climate condition. In addition, given the safety guarding requirement of building structures and underground pipe networks for green plants, greening design is taken into consideration in the unified planning of the whole factory as per esthetic aspect. Antisoil tree species is selected as per the character of air pollutant as well as the local climate and quality of soil, e.g. acacia, spindle tree, tree of heaven and fortunes paulownla, etc. in the class of arbor tree.

Principles of Afforestation Planning: Production zone: make greening plan according to all conditions of the plant, e.g. management, repair and fire control, etc. High dirt resistant deciduous tree and hedge can be planted around production shop to reduce noise and clean air. Greening along both side of road: there should be planted with roadside trees, mainly megaphanerophyte with perfectly straight branch and lush branches and leaves, laid out symmetrically. Meanwhile, hedge should be planted between two of each trees to form a green- wall belt. Greening around the plant: in the arrangement of general layout, a green belt of 2-3m in width should be set aside to form a tree-protecting belt combining arbor and shrub.

5.7 Summary List of “Three-meanwhile” Acceptance Check According to the Environment Protection Law of the People’s Republic of China, the design, as well as construction and setting to work, of anti-pollution facilities in the construction project must be done with the principal part of the project simultaneously. However, the “Three-meanwhile” acceptance check of anti-pollution facilities construction is a forceful measure to control new pollution source and total pollutant emission volume and keep environment from deteriorating strictly. This

167 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited project must be applied to environmental protection department for “Three-meanwhile” acceptance check in preproduction stage. The detailed implementation schedules are: Construction unit is to apply to its local environmental protection competent department for preproduction qualification. Construction unit is to invite environmental monitoring department to detect the discharged pollutant concentration at each sewage draining exist under normal production condition. Construction unit is to apply to its local environmental protection competent department for “Three-meanwhile” acceptance check. The following table shows the “Three-meanwhile” Acceptance Check after finishing the project construction.

Table 4.7-1 Summary List of “Three-meanwhile” Acceptance Check Treatment Investment on Treatment effect, measures environmental execution Pollution amounts, Finish Items Pollutants protection standard or sources size and time RMB, ten planned processing thousand requirement capacity, ect. Smoke control system with 3 sets of

SO2, NO2, semi-dry Reach the Carry Incinerati PM10, HCl, HF, reaction tower+ discharge out in on waste Cd, Hg, Pb and dry standard of EU the gas dioxin deacidification 2000 same +active Waste gases 3,500 time carbon+ bag with type collector project Fly ash Reach the constru solidifyin Bag type dust concentration ction PM10 standard within g dust collector the factory emission boundary

Refuse Malodor gases, Negative Reach the concentration

168 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Treatment Investment on Treatment effect, measures environmental execution Pollution amounts, Finish Items Pollutants protection standard or sources size and time RMB, ten planned processing thousand requirement capacity, ect.

malodor e.g. H2S, NH3, pressure, standard within the factory etc. deodorizer boundary A small amount of leachate pH, COD, leachate is injected back and BOD, SS, Waste leachate and the terrace ammonian, Pb, remaining part is collecting recycled after vehicle As, Hg, Cd, system advanced sparge Cr6+ and Cu, treatment in its self-contained water etc. leachate Waste water 4,000 processing station COD, BOD, Househol SS, ammonia d waste / Piping nitrogen, total water phosphorus Other Neutralization waste pH Recycle pit water Install sound proof device Power - and add unit muffler at the air inlet/outlet Induced Add draft fan sound-proof and - box and forced Reach the muffler draft fan standard within Noise 260 Add the factory All sorts sound-proof boundary - of pumps box and muffler Air Insulate sound compress - and add or muffler Adopt Stream - boiler low-noise

169 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Treatment Investment on Treatment effect, measures environmental execution Pollution amounts, Finish Items Pollutants protection standard or sources size and time RMB, ten planned processing thousand requirement capacity, ect. safety valve and control valve; add muffler and take vibration reducing measure General Comprehensive industrial utilization and Cinder solid processing waste disposal Hazardo Fly ash and Solid waste zero Solid waste Solidify and 450 us solid waste active discharge landfill waste carbon Househol Incineration d solid domestic waste disposal in the waste plant Adopt antiseepage underlayer in materials of natural clay, No pollution to Waste storage pit, leachate single-layer soil and Antiseepage collecting tank and flying 250 artificial underground ash solidifying workshop synthesis water material and double-layer artificial material Beautify

Greening Covering rate of factory greening is 30% 180 environment and reduce noise

170 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Treatment Investment on Treatment effect, measures environmental execution Pollution amounts, Finish Items Pollutants protection standard or sources size and time RMB, ten planned processing thousand requirement capacity, ect. Prevent risk accident from happening to the

Set up accident emergency measure and maximum limit; Accident management system; improve waste water if it does emergency pipe grid 30 happened, deal measures with it the existing support for leachate accident emergency tank is 11,000m3 effectively to keep the risk at one’s acceptable level Environmental management Establish environmental management and (institution and monitoring system; take pollution prevention 100 monitoring measures during construction period ability, etc.) Divert waste water from clean water and build Divert waste up waste pipe grid; an exhaust mast water from (three-tube exhaust mast with 80m in height); clean water and normalize the discharge exit of waste water plainly sewage and gases; a set of on-line flue gas analyzer, a draining exit by 500 set of pH and COD monitor used for install flow monitoring the temperature and flow speed of meter and pollutants and flue gases; the monitor signal is on-line monitor, transmitted and shown in the display screen of etc. control room and plant gate. Put down the 1solidify and chelate fly ash in the “Using new existing factory method to discharge 2improve combustion control 6,690 improve old amount of system——take measures such as control the one” pollutants. Total frequency of flipping grate, control air leak amount of that

171 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Treatment Investment on Treatment effect, measures environmental execution Pollution amounts, Finish Items Pollutants protection standard or sources size and time RMB, ten planned processing thousand requirement capacity, ect. volume strictly and reduce velocity of flue can’t be more gases to reduce the production of smoke dust than the contained in waste gases approved 3adopt high-efficiency dedusting cloth amount bag; clean the bag by blowing fly ash timely to ensure that emission concentration of flue gases reach the standard of EU 2000; 4add dry deacidification system and jet slaked lime into the flue through which flue gas passes, so as to further reduce the discharge volume of acid gases, e.g. HCl, contained in flue gases; 5upgrade and reconstruct the leachate treatment plant and add an advanced processing technology, “NF+RO”. Total 15,960

172 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

6 Industrial Policies, Cleaner Production and Recycling Economy Analysis

6.1 Industrial Policies (1) The Waste-to-Energy plant constructed in the project belongs to the encouragement catalogue of “20. The reduction, resource recovery and harmless treatment and comprehensive utilization engineering for downtown garbage and other solid wastes in Article 38, Environmental Protection and Resource Conservation Comprehensive Utilization” in Guideline Catalogue for Industrial Restructuring (2011 version) of National Development and Reform Commission Decree No.40. (2) The construction of this project complies with the encouragement catalogue of “the reduction, resource recovery and harmless treatment and comprehensive utilization engineering for downtown garbage and other solid wastes” of Guidance Catalogue for Industrial Structure Adjustment of Jiangsu Province. (3) It is stated in Item 100 of “domestic waste treatment technology and equipment” of Article 6 of “Environmental Protection and Resource Comprehensive Utilization”, Article 6 of Guideline of Developing High Tech Industrialization First in Important Field (2004) formulated by National Development and Reform Commission, Ministry of Science and Technology and Ministry of Commerce, that: Domestic waste is distinguished by many production source, complex and unstable character, big pollution influence range, thus it is difficult to reach the aim of effectively govern pollution, reduction and resource recovery by virtue of single treatment technology or equipment. The key points of recent industrialization include garbage selection technology and equipment, large-scale garbage incineration disposal equipment and thermal recovery and utilization system and equipment; garbage landfill leachate treatment technology and equipment; garbage landfill gas (methane) recovery and utilization technology and equipment. (4) This project uses domestic waste to generate power and control the emission of all pollutants to comply with the “3.2 Encouraging garbage incineration waste heat utilization and recovery and utilization of landfill gas, and thermophilic composting of organic garbage and methane produced by anaerobic digestion” and “3.3 It is required

173 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited to avoid and control secondary pollution during the process of garbage recovery and comprehensive utilization” of Technological Policy for Treatment of Domestic wastes and Its Pollution Prevention, which is issued by Ministry of Construction, State Environmental Protection Administration and Ministry of Science and Technology (May 29, 2000). Therefore, this project construction complies with national and local relevant industrial policies.

6.2 Cleaner Production

6.2.1 Advanced Technology and Management Support As the investment, construction and operator with the biggest production scale and high standard for operation emission in China, Everbright International Limited has 12 Waste-to-Energy projects at present. All completed and operated projects are online with local environmental protection authorities and listed to the public to accept supervision from government and the mass. At present, the company has many kinds of qualifications, such as professional contractor qualification for environmental protection engineering, operation qualification for environment pollution control facilities and safety production permit, and has various professional technicians of research and development, engineering management, field adjustment and power plant operation. It is also the comprehensive environmental protection enterprise with leading technology, good engineering performance and excellent growth in Waste-to-Energy industry. Through years of experience in the construction and operation of Waste-to-Energy, Everbright Environmental Protection Energy (Suzhou) Co., Ltd. makes its Stage engineering and Stage engineering operate in good condition to ensure the “three wastes” steadily reach standard of emission, thus to ease the increasing demand for domestic waste disposal of Suzhou.

6.2.2 Comparison of Disposal Plans The method of domestic waste disposal is restricted by economic development level, natural conditions and traditional customs, and changes according to national conditions, usually including the disposal methods of landfill, incineration,

174 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited composting and recovery (recycling on the basis of garbage classification). According to the statistics by the Warmer Bulletin, No. 44, 1995, the magazine published by World Energy Fund, see Table 6.2-1 for the statistics of domestic waste disposal methods in 18 developed or more developed countries in Europe, America and Asia.

Table 6.2-1 Statistics of Domestic waste Disposal Methods in 18 Countries in Europe, America and Asia Disposal Incineration Landfill Composting Recovery Total Method Accumulative 721 856 97 126 1,800 Ratio % Translation 40.1 47.6 5.4 7.0 100.0 Ratio %

It is found in the statistic data that the countries with landfill disposal accounting for the major proportion are those with large geographical area or little population, such as America, Canada, Finland, Italy, Spain, Norway, Britain, etc. while countries with incineration disposal accounting for the major proportion are those with small geographical area or large population, such as Japan, Denmark, Luxembourg, Singapore, Switzerland, Sweden, etc. In general, landfill and incineration are the main disposal methods for domestic waste at present. In recent ten years, the proportion of garbage incineration disposal rises year by year, such as that of America in 1990 is 18%, but it has exceeded 40% at present, and that of Singapore increases almost to 100% from 85%. The characteristics of sanitary landfill method are low cost (1/15-1/8 of incineration method; 1/5-1/3 of composting disposal method), wide applicable scope, and it can control secondary pollution under scientific site selection and applying necessary environmental measures, reasonable landfill site structure. The urban garbage in China has high content of inorganic substance, low calorific value, and big water content and the sanitary landfill will be applied in a long time under the current economic conditions. For more than a decade, the disposal capacity through sanitary landfill in China has been increased to current over 70% from the 11% at the beginning of 1990s.

175 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Composting disposal refers to use microorganism to break down the organic matters in garbage under control conditions. This method depends on the organic components of garbage. In case the organic matter is degraded to reach harmless requirements through long-time anaerobic fermentation, a large amount of composting can be gotten through selection, which can be used to improve the fertility of soil. However, offensive odor is easily yielded during fermentation, whose technological conditions are difficult to control. In addition, composting products also have matters that are difficult to degrade, for instance, glass particles. In recent years, the heavy metal residues of composting are gaining increasing attention and the selection of composting technology is very careful. Incineration method is a high temperature heat treatment technology, which can realize the harmless, reduction and resource recovery of garbage through oxidation and combustion reaction. By March, 2005, about 20 incineration plants had been completed and put into operation in Shanghai, Beijing and Shenzhen, but its investment cost is high, suitable for cities with developed economy. Recovery treatment is to implement garbage classification first and select garbage treatment method according to the types of garbage. At present, the sorting collection of urban garbage in China is preliminarily implemented in some big cities, such as Beijing and Shanghai, and most regions still apply mixed collection. While garbage classification in foreign countries has formed a type of normative system and common residents also have high sense of classification. See Table 6.2-2 for the characteristics of landfill, incineration and composting disposal method. From comparison, the disposal method of incineration can effectively reduce garbage weight and volume and land for landfill, and obtain certain energy efficiency. Through proper purification treatment of incineration gas and safety treatment of fly ash, it is possible to control secondary pollution and realize reduction, harmless and partly resource recovery. It is the ideal garbage treatment technology for cities with developed economy and limit land resource, as well as one of the methods for the multiple comprehensive treatment development of urban garbage.

176 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 6.2-2 Comparison of Domestic Waste Disposal Method Item Sanitary landfill Incineration High temperature composting The content of organic matter shall be more than 40~ Adaptability Applicable to general garbage Thermal value shall be not less than 5,000kJ/kg 60% Reliability Reliable Reliable Reliable Operation safety Prevention of fire and explosion Good Good Difficult to select site, with limit capacity of Site selection Easy to select site. Easy to select site. landfill site. Area Big Small Moderate Simple process equipment, easy to operate, Complex process equipment, high requirements for Simple process equipment, it can be solved by sewage Treatment process difficult to sewage treatment, disposable operation management, reliable technology, run treatment, long treatment period, residue needs to be landfill site continuously round-the-clock landfilled The residue needs to be landfilled, accounting for more than Non-composting matter needs to be landfilled, Final disposal None 15% of the initial amount accounting for more than 30% of the initial amount Sanitary landfill for methane recovery and The thermal energy or electrical energy can be used by the There is certain difficult to carry out composting Product market the methane can be used to generate power society, with good economic benefits market and various measures are needed. Energy meaning Some have Continuous operation None Recover soil utilization or regenerate soil Garbage sorting can recycle some matters and transform Resource utilization Used as fertilizer and recycle part matter resource resource utilization Underground water Needs impermeable protection and leakage Smallest possibility Smallest possibility pollution may still happens Atmospheric pollution Controlled by measures such as air guide The purification treatment of gas can control atmospheric Little odor

177 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Item Sanitary landfill Incineration High temperature composting and cover pollution It is needed to control the content of harmful Soil pollution It is limited to landfill site area None substances Impact on environment Big Smallest Smaller Management level General Higher Higher Working environment Bad Good Worse Unit investment RMB 150,000~ 250,000 Yuan/t RMB 400,000~ 600,000 Yuan/t RMB 300,000~ 500,000 Yuan/t

178 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 6.2.3 Advancement of the Selected Furnace Model According to combustion method, the model of furnace can be divided into mechanical stoker incinerator, fluidized bed incinerator, rotary kiln incinerator and thermal pyrolysis incinerator. See Table 6.2-3 for the comparison of the comprehensive performance of typical furnace models.

Table 6.2-3 Comparative Statement of the Comprehensive Performance of Typical Furnace Models (Incinerators) Item Mechanical Fluidized bed Rotary kiln Thermal stoker incinerator incinerator incinerator pyrolysis gasification incinerator Stoker style Mechanical No stoker No stoker No stoker stoker Main transmission Stoker None Furnace bogy Garbage mechanism feeding Pressure of Low High Low Low combustion air Contact between Better Better Better Good garbage and air Firing up Faster Fast Slow Fast Secondary No need No need Need Need combustion chamber Temperature of flue Low Middle Lower High gas Dust content of flue Lower Higher Higher Lowest gas Area Big Small Middle Middle Garbage broken Need Need No need No need situation Volume of Bigger Small Big Bigger combustion furnace Status of Still Still Rotary Still combustion furnace Unburned residue Less 5% Little ≤2% Less 5% Little 3%

179 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Operation Convenient Convenient Convenient Convenient Thermal value Wide Low High Low applicable to garbage Applicable garbage Higher High Lower Low water content Garbage treatment Big Big Middle Small amount of single furnace History of garbage Long Longer Longer Short incineration Equipment High Low Lower Lower investment Maintenance Many Less Less More workload

Stoker Incinerator Mechanical stoker incinerator is the earlier developed garbage incinerator model. The forms of mechanical stoker incinerator change according to the structure and mode of motion, but the basic principle of combustion is similar. Garbage is implemented stratified combustion on stoker and the ash residue is discharged out of furnace after dryness, combustion. All stokers apply different methods to loosen the garbage layers and make garbage fully contact with air, thus to reach ideal combustion effect. The air for the combustion of garbage is sent from the bottom of the stoker. According to thermal value and water of garbage, the wind sent into furnace can be heat wind or cold wind, and different stoker structures have different stoker ventilation ways. According to the mode of motion and structure, the models of mechanical stoker incinerator include reciprocate stoker, rolling stoker, multistage wave stoker and pulse cast stoker. The main model includes reciprocate stoker and rolling stoker. The advantages of stoker furnace include: • Mature technology, especially, it is used almost for all large-scale incineration plant and is the most popular model to dispose domestic waste incineration with the biggest amount; • It can adapt to the features of high water and low thermal value of domestic waste and it can ensure full combustion of garbage without adding auxiliary fuel;

180 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited • Reliable and convenient to operate, strong adaptability to garbage and difficult to cause secondary pollution; • Low requirements to the pretreatment of garbage and relatively low operation fees; • Long service life, stable and reliable, and convenient to operate and maintenance.

Fluidized Bed Incineration Technology Fluidized bed technology was used to incinerate industrial sludge in 1960s, to incinerate domestic waste in 1970s, and it was popularized in Japan in 1980s with the market share of 10%. But at the late 1990s, the application in domestic waste incineration decreased significantly because of the increase of smoke emission standard and disadvantages of fluidized incinerator, such high fly ash quantity and fly ash hot burning reduction rate and difficult to control. The incineration mechanism of fluidized bed incinerator is similar to that of coal fluidized bed, which uses the big thermal content of bed material to ensure the full combustion of garbage, and garbage is fed until the bed material is heated to about 600℃, keeping the temperature of bed layer at 850℃. Fluidized bed incinerator can implement incineration treatment to any garbage, full combustion. But troubles are easily to happen to the garbage with strict requirements for crush pretreatment. In recent years, fluidized bed incinerator is used to a certain degree in China, but most fluidized bed incinerators cannot incinerate commonly without coal. Therefore, there are disputes on garbage incineration application, which need to be further perfected.

Thermal Pyrolysis Incinerator Thermal pyrolysis incinerator refers to one that can break down organic matters at certain temperature (500~600℃) under anoxia or non-oxidation atmosphere, and the organic matters will undergo thermal pyrolysis to change it into thermal decomposition gas (burning mixture); Then lead the thermal decomposition gas into combustion chamber for combustion, thus to break down organic pollutants, and the waste heat can be used to generate electricity and provide heat. The pyrolysis technology is widely used and is applied to deal with various kinds of garbage. Since it is affected by garbage features and the features of follow-up thermal pyrolysis gas

181 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited (thermal value and components), the combustion is difficult to control, the ash residue is difficult to burn fully and the discharge is difficult to reach standard. Moreover, in Europe and Japan, thermal pyrolysis always applies rotary kiln incinerator and fluidized bed incinerator, which can burn out ash residue and melt to glass ash residue together with combustion melting furnace. This technology is used in developed countries, but it requires high thermal value of garbage, high costs of plant construction, and its operation cost is two times of that of mechanical stoker.

Rotary Kiln The rotary kiln incineration system is designed from the rotary burning kiln widely used in the firebrick lining of concrete industry. Garbage is fed from the front end on the top of the slant and slowly rotary kiln, with the forward velocity controlled by rotation speed, so as to make the garbage finish dryness, combustion and cooling of ash in the conveying process in rotary kiln, and the cooled ash residue is discharged out from the end behind the furnace kiln. The whole furnace body of rotary kiln can be made by welding the cooling pipe and steel plate with holes, or adding fire protective lining to the interior of steel barrel. The furnace body shall be inclined to the downside and can be divided into three blocks, namely dryness mixture, combustion and post-combustion, supporting by front and rear rolling wheels, chain wheel drives wheel to rotate furnace body and garbage is on furnace body and obtain good flapping of copper and transmitted forward because of rotation. The preheated air goes into kiln through the steel plate with holes at the bottom to make garbage combust fully. The features of rotary kiln include wide fuel adaptability, incinerating wastes with different performance, with a few mechanical parts and little faults, and continuous operation for a long time. But the heat efficient of rotary kiln is low, in case auxiliary fuel is needed, the consumption is much, the discharged gas has low temperature and offensive odor, which need deodorization device or incineration in high temperature post-combustion chamber. Since the kiln body is long with big area and the strict requirements for the stoker structure of post-combustion chamber, it has high cost and price. Rotary kiln is usually used to industrial wastes with complex components and toxicity and harness and medical garbage, with little application in present domestic waste incineration.

182 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited At present, the large-scale incinerator widely applied in China is mechanical stoker incinerator and fluidized bed incinerator. It is stated in Technological Policy for Treatment of Domestic Wastes and Its Pollution Prevention, which is issued by Ministry of Construction, State Environmental Protection Administration and Ministry of Science and Technology that “Current waste incineration is supposed to use grate furnace-based mature technology and the use of other type of incinerators shall be carefully decided”. Meanwhile, combining with the successful cases of Phase engineering and Phase engineering , the Stage engineering still applies the mechanical stoker from Kepple Seghers company of Belgium, easy to management and maintenance. According to the Current National Focus on Encouraging and Development Environmental Industry Equipment (Products) Catalogue (2007) issued by State Environmental Protection Administration and National Development and Reform Commission, the technology conditions of Phase expansion engineering comply with the main indicators and technical requirements of “63. Incineration Equipment for Solid Wastes”, the performance of garbage grabbing crane complies with the main indicators and technical requirements of “64. Garbage Grabbing Crane”, so as to encourage and develop environmental protection industrial equipment.

6.2.4 Advancement of Pollution Treatment Facilities Gas purification technology is determined by the pollutant component, density and implemented emission standard in the waste gas yielded during the process of garbage incineration. Normally, gas purification technology mainly controls acidic gas (HCl, HF and SO2), particulate matter, heavy metal and organic poisons (dioxin and furan), and acidic gas desorption and particulate matter gathering is the key to technology design. At present, gas purification technology mainly includes dry purification, semi-dry purification, wet purification, NOx purification and activated carbon injection. Each technology has many combinations, which are introduced briefly as follows. (1) Dry Purification It was widely used before 1980s. With the increasing strict environmental protection standard, its application becomes less and less. The typical technology is the combination of dry absorption reaction tower and bag filter. The smoke yielded by

183 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited combustion directly enters into dry absorption reaction tower and occur chemical neutralization reaction and generate harmless neutral salt particles, then enters into the downstream bag filter, where the reaction product, dust in smoke and absorbent that doesn’t take part in reaction are gathered, thus to reach the purpose of purification. The removal rate for HC1 of this method is generally 80%~90%. Dry purification has simple technology, low investment, no waste water, small equipment corrosion, high gas temperature and no white smoke generated. Its disadvantages include large agent dosage, with the excess coefficient reaching over 3, and the deacidification efficient of 50%~80%. In order to adapt to the increasing requirements of environment, this method is not used frequently.

(2) Semi-dry Purification The semi-dry Purification technology is the garbage incineration gas treatment technology that is widely used in domestic and foreign garbage incineration plants. Its absorbent mainly applies Ca (OH) 2; the typical technology is the combination of spray dry reaction tower and bag filter.

Ca (OH) 2 applies pneumatic transport and it becomes salt through spray humidifier and acidic gas reaction. Fluidized absorbent has large reaction area with smoke, water spray inside of the tower increases the activity of absorbent, effectively increasing the reaction rate of absorbent and the acidic gas within the tower and enhancing the absorption effect. The smoke with a large amount of saccharoid enters into the downstream bag filter from reaction tower and some lime without reaction is attached to filter bag and react again with the acidic gas that goes through the filter bag, thus to further promote the removal rate.

The semi-dry purification technology has high rate of SO2 removal, that of HC1 can reach over 90%, and that of heavy metal can reach over 99% (except mercury), with little drag usage, without waste water. And its disadvantages include the decrease of gas temperature, generating white smoke.

(3) Wet Purification This technology is widely used in some countries with developed economy and technology, and the typical technology is the combination of wet scrubber tower and bag filter. Wet scrubber tower can obtain optimum efficiency to the control of SO2

184 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited and HC1, with the absorption efficiency controlled by the seep of acidic gas spread to alkaline absorption droplet. In case of design, it is required to increase the contact area and time of gas and liquid, and increase the density of absorbent in rising droplet. The alkaline liquor used in wet scrubber tower is usually NaOH solution and lime Ca (OH) 2 solution. Since slaked lime is cheap, slaked lime solution is dominated. Slaked lime solution reacts with acidic gas and forms calcium salt and its washing water shall be clarified, concentrated and filtered, so as to prevent the deposit in equipment. The great advantage of wet purification technology is the high acid removal rate, which is proved by foreign actual performance: its removal rate of HC1 can reach over 95% and that of SO2 can reach over 80%, it also has high removal rate to organic pollutant and heavy metal. Its disadvantage is that it generates waste water with high concentration of organic chlorine salt and heavy metal which can only be discharged after reaching standard through treatment, with high equipment investment and operation fees.

(4) Activated Carbon Injection To ensure the emission of heavy metal (especially Hg) and organic toxicant (dioxin and furan) reach the lowest standard, some foreign companies gradually apply activated carbon spray absorption as the auxiliary measure of gas purification. Activated carbon has great specific surface area, which has strong absorption ability to heavy metal and dioxin. Normally, activated carbon spray is used together with bag filter and activated carbon nozzle is placed at the inlet end of bag filter (forward as much as possible), thus activated carbon can strongly mix with smoke and absorb certain quantity pollutants. Although it doesn’t reach saturation, it can be attached to the filter bag of bag filter and contact again with smoke, so as to increase the absorption and purification to pollutants and make it discharge at a lower concentration.

(5) NOx Purification The aforementioned technologies has higher removal rate to acidic gas, organic matters and heavy metal, but not to NOx. Due to the limitations of furnace low nitrogen combustion technology, although applying improved combustion technology can reach certain NOx control effect, it is required to implement denitration treatment

185 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited to combustion smoke to further reduce the emission of NOx. The popular denitration technology for smoke can mainly divided into dry method, semi-dry method and wet method. Dry method includes selective noncatalytic reduction method (SNCR), selective catalytic reduction (SCR) and electron beam joint desulfurization denitration method; semi-dry method includes activated carbon joint desulfurization denitration method; wet method includes ozone oxidation absorption method. At present, dry denitration is widely. Dry SNCR is to spray reductive agent into the second combustion area of garbage incinerator to reduce nitrogen oxide, while

SCR is to reduce nitrogen oxide into N2 through catalyst. Under the function of catalyst, the reaction can be finished under 400℃. Considering from technical feasible, economic feasible, the existing Phaseengineering and Phaseengineering apply the garbage incinerator smoke denitration technology of Petro Miljö company from Sweden, to finish SNCR denitration technical reconstruction to the existing 5 incinerators by using ammonia water as reluctant. At present, the denitration system 3 operates stably with the average NOx value controlled under 200mg/m . See Table 6.2-5 for the typical technology comparison of smoke purification.

Table 6.2-5 Typical Technology Comparison of Smoke Purification Dry absorption + Bag Semi-dry absorption + Wet absorption + Bag Item Compared filter Bag filter filter Emission

concentration of <300 <200 <60

SO2 Emission

concentration of <80 <30 <30 HCl Emission

concentration of <30 <10 <10 particulate matter Removal rate of heavy metal and Higher High High organic toxicant Output of fly ash More Normal Less

186 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Output of sludge None None More and waste water Engineering Lower Normal High investment Operational cost Higher Normal High

After the completion of Phase expansion engineering, through “bring the old by the new” measure, the smoke purification system of the factory applies SNCR denitration + semi-dry neutralization tower + dry deacidification + activated carbon absorption + bag filter, absorb dioxins and heavy metal after denitration and deacidification, discharge to air after final dedusting. According to the acceptance of current engineering, results of the routine monitoring data and designed data analysis, applying the aforementioned smoke treatment methods can ensure all pollutants in incineration smoke stable and standard discharge.

6.2.5 Automatic Control Level This project applies international advanced DCS automatic control system and uses color LCD/keyboard as main monitoring and control method in centralized control room to realize the monitoring and control of the whole garbage power station, including three garbage incinerators, two steam turbine generator units and various auxiliary system and auxiliary equipment, thus to finish data collection (DAS), analog control (MCS), sequential control (SCS) and chain safeguard.

6.2.6 Energy and Resource Utilization After the project is completed and put into operation, the daily treatment capacity of domestic waste is 1980t/a and the annual treatment quantity is 659,300 ton/year. It not only reduces garbage capacity effectively and save the area of garbage landfill site, but implements recovery and comprehensive utilization to the waste heat of garbage. Thus it can be seen that applying domestic waste incineration Waste-to-Energy has significant benefit to the recovery and utilization of energy.

6.2.7 Pollutant Emission Level According to the operation monitoring data of current engineering and the

187 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited requirements of technology design for this expansion engineering during the development process of the enterprise, the emission concentration of the incinerator waste gas pollutant of this engineering is designed in accordance with EU 2000 Standard. Compared domestic, international and EU standards, it can meet the control level required in China and the emission of pollutants of this project can reach domestic advanced level. See Table 6.2-6 for the control level of the emission concentration of engineering incinerator pollutants.

Table 6.2-6 Control Limit Value for Domestic Waste Incineration Smoke and Designed Indicators for Pollutant Emission Item The project National Standard EU 92 EU 2000

Dust ≤30 80 50 10 HCl ≤10 75 50 10 HF ≤1 / 2 1 CO ≤150 150 100 50 SO2 ≤260 260 300 50 NOX ≤400 400 / 200 Cd ≤0.1 0.1 0.1 0.05 Hg ≤0.2 0.2 0.1 0.05 Pb ≤1.6 1.6 / 0.5 3 DioxinngTEQ/m ≤0.1 1.0 0.1 0.1 Smoke blackness ≤1 1 Clinker ignition losses (%) ≤2% 5.0

While establishing expansion engineering, it is required to take the measure of “bring the old by the new” to further reduce the emission quantity of gas, such as dust and HCl.

6.2.8 Environment Management Level This project sets smoke continuous monitoring system whose online data can be accessed to by relevant government departments through the reserved communication interface, online monitoring management.

188 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 6.2.9 Water Saving Measures Upgrading reconstruction is implemented to leachate treatment station, which can not only reduce the emission of waste water pollutant, but also increase the recovery rate of recycled water, reduce the consumption of fresh water, thus to realize recycling utilization. The usage of circulating water of this project is 4,500m3/h, that of fresh water is 1,779m3/d, and the total amount of recycle water is 880m3/d. Through calculation, the recycling utilization rate of water of this project is 98.4%, and the repeated utilization rate of this project is 99.2%.

6.2.10 Comparison of Cleaner Production Indicators See 6.2-7 for the comparison of cleaner production indicators of energy consumption and water consumption of phase engineering and current engineering. As is shown in the table, the indicators of phase engineering cleaner production has increased than that of current engineering by certain degree.

Table 6.2-7 Comparison of Cleaner Production Level Indicators phase Current phase Current phase Domestic unit expansion Project indicator engineering engineering engineering Design capacity 350×3 500×2 500×3 (t/d) Incinerator Mechanical Mechanical Mechanical model incinerator stoker incinerator stoker incinerator stoker Thermal value Production of the feed-in 1,200~1,300 1,200~1,300 1,200~1,300 technical garbage indicator (kcal/kg) Electric energy production per 330 350 390 ton of garbage (kwh/t) Lime Material consumption 12.35 12.35 15.75 consumption (kg/t garbage)

189 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Consumption of activated carbon 0.32 0.32 0.516 (kg/t garbage) Dioxin (TEQ <0.079 (Average) <0.079 (Average) 0.05 (Average) ng/m3) Dust (mg/m3) Emission 4.07~20.0 4.07~20.0 <10 3 indicator of SO2mg/m 10.5 (Average) 10.5 (Average) <10 3 pollutants NOXmg/m <171 <171 <180 HClmg/m3 6.5 (Average) 6.5 (Average) <5.1 (Average)

3 COmg/m <37.5 <37.5 <50 Recycling 82 82 98.4 Water utilization rate consumption Repeated 82.7 82.7 99.2 utilization rate Electricity 1,984.9 2,433.2 3,548.3 (10,000 kwh/a) Tap water Energy 68.5 75.8 54.4 (10,000 m3/a) consumption Compressed air 1,070.4 1,070.4 912 (m3/a)

Diesel oil (t/a) 120 120 150

6.2.11 Conclusion Stage expansion engineering applies mechanical stoker incinerator to dispose domestic waste with high coefficiency of equipment safety, low cost of equipment manufacturing and operation; Operation realizes fully mechanization and automatization; strong adaptability to domestic waste, it reaches domestic advanced level on energy consumption and pollutant control and emission. While establishing expansion engineering, it is required to take the measure of “bring the old by the new” to further reduce the emission quantity of gas, such as dust and HCl, thus to increase the recovery rate of recycled water, reduce the consumption of fresh water, thus to realize recycling utilization.

6.3 Recycling Economy This project incinerates domestic waste and use the waste heat of incineration to

190 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited generate electricity. The project that makes wastes resource recovery realizes recycling economy. Pollution at different degrees are brought to surrounding environment and groundwater caused by the sewage, methane and offensive odor naturally generated in landfill site and occupation of large amount of land. To properly solve the impacts of domestic waste on ecological environment and develop recycling economy, the end treatment method dominated by incineration and supplemented by sanitary landfill is mainly applied to domestic waste, changing the traditional treatment method of direct landfill for primary domestic waste. The advantages of incineration treatment include greatly reducing garbage volume and weight, with the ash residue after incineration can be used comprehensively; fast speed of garbage treatment without long-term storage; the energy can be recovered to used in Waste-to-Energy and heat supply; through reasonably organize incineration process and comprehensive optimum design of incinerator system, the secondary pollution can be lowered to the lowest degree, thus to reach the emission indicator. According to statistics, 97% of urban garbage in China cannot be disposed at present, which can only be piled or landfilled. The losses of cities in China caused by garbage are between RMB 25 billion and RMB 30 billion each year. In case they are recovered, an output over RMB 250 billion can be created. As early as the middle of the last century, developed countries in Europe and America had begun to research Waste-to-Energy by garbage and harmless treatment, which are gradually put into commercial operation between 1960s and 1970s under the substantial support and promotion of governments. Nowadays, countries in Europe and America have populated and promoted Waste-to-Energy by garbage, for instance, German has 78 plants and America has nearly 400 plants. Due to the shortage of land resource, Japan spare no efforts to promote Waste-to-Energy by garbage and the incineration rate has reached 73%, ranking the first place all over the world. At present, the treatment of domestic waste shall stick to the principle of “reduction, resource recovery and harmless”, reduction is the inevitable requirement for garbage treatment and resource recovery is the development direction of garbage treatment. This project adapts to the trend of industrialization of garbage treatment, use the waste heat yielded from garbage incineration to generate electricity, and realize reduction (over 85%), resource recovery (annual export electricity of 156 million kwh,

191 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited comprehensive utilization of ash residue) and harmless (solidification landfill of fly ash) of domestic waste.

7 Investigation on Regional Pollution Sources and Investigation and Evaluation of Present Environmental Quality Condition

7.1 Investigation on Regional Pollution Sources

7.1.1 Investigation and Evaluation of Ambient Pollution Source According to the emission declaration statistic data of enterprises within the scope of evaluation, see Table 7.1-1 for the emission condition of each enterprise, in 3 3 3 which, the standard value of SO2, dust and NOX is 0.5mg/m , 0.45mg/m , 0.24mg/m respectively.

Table 7.1-1 Investigation on Present Condition of Ambient Pollution Sources (unit: t/a) Item Coal SO Soot NO Enterprise Name 2 X Suzhou Wuzhong Fengye Adhesive Factory 36 0.576 0.27 0.274 Suzhou Peacock Food Additive Co., Ltd. 180 2.88 0.135 1.368 Suzhou Changlin Chemical Industry Co., Ltd. 480 7.68 3.6 3.648 Suzhou Fuda Chemical Fiber Printing & Dyeing Co., Ltd. 1,500 24 11.25 11.4 Suzhou Wuzhong Chuanmu Chemical Co., Ltd. 70 1.12 0.525 0.532 Specialty Chemicals (Suzhou) Inc. 218.55 6 0.318 0.335 SANYO Energy (Suzhou) Co., Ltd. 1,046.126 14.36 1.52216 1.67 Total 3,530.676 56.616 17.62016 19.227

Evaluation Method Adopt equiscalar pollution load method and pollution load ratio method for comparison.

The equiscalar pollution load of a certain pollutant in the waste gas: Pi

Pi  Qi /C0i

3 Where, C0i refers to the evaluation criterion of pollutants (mg/m )

Qi Refers to the absolute emission of pollutants (t/a).

192 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

The equiscalar pollution load of a certain pollution source (factory): Pn

j PnPii 3,2,1 ...... j  i1 The total equiscalar pollution load within the evaluation area: P

k PPnn 3,2,1 .....k  n1 The pollution load ratio of a certain pollutant in the pollution source or

evaluation area: Ki Pi Ki  100% Pn The pollution load ratio of a certain pollution source within the evaluation area:

Kn Pn Kn  100% P Evaluation Result See Table 7.1-2 for the evaluation results of air pollution sources which are calculated based on the equiscalar pollution load method:

Table 7.1-2 Equiscalar Pollution Load and Equiscalar Pollution Load Ratio P (Flue Item P (SO ) P (NO ) Kn 2 dust) X ΣPn Enterprise Name 109m3/a 109m3/a 109m3/a % 109m3/a Suzhou Wuzhong Fengye Adhesive Factory 1.2 0.3 1.1 2.6 2 Suzhou Peacock Food Additive Co., Ltd. 5.8 0.2 5.7 11.6 6 Suzhou Changlin Chemical Industry Co., Ltd. 15.4 4.0 15.2 34.6 16 Suzhou Fuda Chemical Fiber Printing & 48.0 12.5 47.5 108.0 50 Dyeing Co., Ltd. Suzhou Wuzhong Chuanmu Chemical Co., Ltd. 2.2 0.6 2.2 5.0 2.3 Specialty Chemicals (Suzhou) Inc. 12.0 0.4 1.4 13.7 6.4 SANYO Energy (Suzhou) Co., Ltd. 28.7 1.7 7.0 37.4 17 ΣPi(109m3/a) 113.3 19.7 80.1 212.9 100 Ki(%) 38.5 13.9 43.1 100

We can conclude from the table above that within the evaluation area the main air pollution type is coal-fired flue gas pollution, the main air pollution enterprises are SANYO Energy (Suzhou) Co., Ltd. and Suzhou Fuda Chemical Fiber Printing &

Dyeing Co., Ltd., and the main pollutants are SO2 and NOX with the equiscalar load ratio of 50% and 17% respectively.

193 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

7.1.2 Investigation and Evaluation on Water Pollution Source See Table 7.1-3 for the emission statistic data of the sewage disposal plants within the evaluation area. It can be seen that the emissions of the sewage disposal plants within the evaluation area are large and the sewage emissions account for 70.3% of the statistic data.

Table 7.1-3 Emission Data of Water Pollution Sources Within the Evaluation Area (unit: t/a) Item Sewage Total COD Ammonia nitrogen Enterprise Name 10,000 t/a phosphorus Suzhou Wuzhong Suxin Water Disposal Co., Ltd. 45 45 6.75 0.225 Suzhou Wuzhong Mudu Sewage Disposal Plant 730 438 109.5 3.65 Suzhou Wuzhong Xukou Sewage Disposal Plant 150 90 22.5 0.75 Suzhou New District Sewage Disposal Plant 2,190 1,095 109.5 10.95 Total 3,115 1,668 248.25 15.575

Adopt equiscalar pollution load method and pollution load ratio method for comparison.

The equiscalar pollution load of a certain pollutant in sewage: Pi

Pi  Qi /C0i

Where, C0i refers to the evaluation criterion of pollutants (mg/L);

Qi Refers to the absolute emission of pollutant (t/a).

The equiscalar pollution load of a certain pollution source (factory): Pn

j PnPii 3,2,1 ...... j  i1 The total equiscalar pollution load within the evaluation area: P

k PPnn 3,2,1 .....k  n1 The pollution load ratio of a certain pollutant in the pollution source or evaluation area: Ki Pi Ki  100% Pn

194 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited The pollution load ratio of a certain pollution source within the evaluation area:

Kn Pn Kn  100% P Evaluation Result See Table 7.1-4 for the evaluation results of sewage pollution sources which are calculated with the esquiscalar pollution load method based on the above pollutant emissions of pollution sources. And the standard values of COD, ammonia nitrogen and total phosphorus are 20mg/L, 1.0mg/L and 0.2mg/L respectively. Of all the pollution sources, the esquiscalar emission of Suzhou New District is the biggest, accounting for 53.5%. Of all the pollution factors, the esquiscalar emission of ammonia nitrogen is the biggest, accounting for 60.6%.

Table 7.1.4 Evaluation Results of Pollution Sources P P Item P Ammonia Total Kn COD n ΣPn Enterprise Name 106m3/a nitroge phosphorus 106m3/a % 106m3/a 106m3/a Suzhou Wuzhong Suxin Water Disposal Co., Ltd. 2.25 6.75 1.125 10.125 2.5 Suzhou Wuzhong Mudu Sewage Disposal Plant 21.9 109.5 18.25 149.65 36.5 Suzhou Wuzhong Xukou Sewage Disposal Plant 4.5 22.5 3.75 30.75 7.5 Suzhou New District Sewage Disposal Plant 54.75 109.5 54.75 219 53.5 ΣPi(106m3/a) 83.4 248.25 77.875 409.525 Ki(%) 20.4 60.6 19.0

7.2 Investigation on Present Environmental Quality Condition

7.2.1 Monitoring and Evaluation of Present Ambient Air Quality Condition (1) Setting of Monitoring Points Based on the scope of evaluation area and the all-year predominant wind direction, and in consideration of factors of this project such as the emission condition of atmospheric pollutants and protected objects, 6 ambient air quality monitoring points are set totally. The average predominant wind direction in winter in past few years is ENE; see

195 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Table 7.2-1 and Fig.1.7-1 for the details of atmospheric monitoring points.

Table 7.2-1 Position of Air Monitoring Points Dire Distance S/N Monitoring Point Monitoring Items Remarks ction (m) Shangfang PM , SO , NO , HCl, CO, Actual G1 SE 1,600 10 2 2 Mountain Fluoride, Cd, Hg, Pb, H2S, NH3 Measurement Actual Measurement Qizi Lot, Gusu CO, Cd, Hg, Pb , SO , NO , for CO, Cd, G2 NNE 1,200 2 2 Village PM10, NH3, H2S, Fluoride, HCl Hg and Pb; Citation for other items PM , SO , NO , HCl, CO, Actual G3 Fenghuang Lot SW 1,100 10 2 2 Fluoride, Cd, Hg, Pb, H2S, NH3 Measurement Former Lita PM , SO , NO , HCl, CO, Actual G4 NW 600 10 2 2 Village Fluoride, Cd, Hg, Pb, H2S, NH3 Measurement Former Tiangou PM , SO , NO , HCl, CO, Actual G5 NW 1,350 10 2 2 Village Fluoride, Cd, Hg, Pb, H2S, NH3 Measurement Mudu Town PM , SO , NO , HCl, CO, Actual G6 NW 3,000 10 2 2 (Guzhen District) Fluoride, Cd, Hg, Pb, H2S, NH3 Measurement

(2) Monitoring Time and Frequency Monitoring time: From April 20, 2011 to April 27, 2011; the monitoring factors include PM10, SO2, NO2, HCl, CO, Fluoride, Cd, Hg, Pb, H2S and NH3. For the hourly concentration of SO2, NO2, CO, HCl, H2S and NH3, sample for 7 days and 4 times each day; for the average daily concentration of SO2, NO2 and CO, sample for 7 days and 18 hours each day; for the average daily concentration of PM10, sample for 7 days and 12 hours each day; for the average daily concentration of Fluoride, sample 7 days and 12 hours each day; for the average daily concentration of Cd, Hg and Pb, sample 7 days and 4 times each day. Refer to Environmental Evaluation Data (the New Xujiang City in this report is the Qizi Lot in this report) of Expansion Project of Everbright Environmental Protection (Suzhou) Solid Waste Disposal Co., Ltd. for the data (SO2, NO2, PM10, NH3, H2S, Fluoride, HCl) of Qizi Lot, Gusu Village, the monitoring time is from April 11 to April 17, 2011. The monitoring frequency shall follow the national standards. (3) Sampling and Analysis Method: According to the relevant provisions and requirements of Environmental Monitoring Technical Norms, Monitoring and Analysis Methods for Air and Waste Gas and National Ambient Air Quality Standard issued by State Environmental Protection Administration. (4) Evaluation on the Monitoring Results: Adopt single factor index method. The

196 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited formula is as follows:

Iij  Cij / S j

Where, I ij refers to the single factor quality index of j pollutant at the point of i;

Cij Refers to the actually measured average daily concentration value of j pollutant at the point of i (mg/m3);

S j Refers to the standard average daily concentration (or reference standard) value of j pollutant at the point of i (mg/m3). See Table 7.2-2 for the meteorological parameters during the monitoring period.

Table 7.2-2 Meteorological Parameters during the Monitoring Period Atmospheric Temperature Relative Wind Wind Speed Date Time Pressure (K) Humidity (%) Direction (m/s) (kPa) 1st Time 287 101.3 75 East Wind 3.1 2nd Time 289 101.3 73 East Wind 2.7 2011/4/20 3rd Time 292 101.3 68 East Wind 2.6 4th Time 294 101.3 66 East Wind 2.7 1st Time 291 102.1 63 E-S Wind 2.4 2nd Time 293 102.1 62 E-S Wind 2.7 2011/4/22 3rd Time 296 102.1 58 E-S Wind 2.7 4th Time 297 102.1 51 E-S Wind 2.7 1st Time 293 102.1 68 E-S Wind 2.3 2nd Time 295 102.1 63 E-S Wind 2.6 2011/4/23 3rd Time 297 102.1 61 E-S Wind 2.5 4th Time 298 102.1 58 E-S Wind 2.3 1st Time 294 102.2 67 E-S Wind 2.8 2nd Time 296 102.2 61 E-S Wind 2.8 2011/4/24 3rd Time 298 102.2 57 E-S Wind 2.7 4th Time 301 102.2 47 E-S Wind 3.1 1st Time 291 102.1 47 E-S Wind 2.9 2nd Time 295 102.1 38 E-S Wind 3.1 2011/4/25 3rd Time 297 102.1 35 E-S Wind 2.7 4th Time 298 102.1 31 E-S Wind 2.3 1st Time 298 102.3 38 W-S Wind 2.8 2nd Time 301 102.3 29 W-S Wind 2.9 2011/4/26 3rd Time 302 102.3 25 W-S Wind 3.2 4th Time 302 102.3 23 W-S Wind 3.3 1st Time 289 102.1 75 E-S Wind 2.4 2nd Time 293 102.1 63 E-S Wind 2.7 2011/4/27 3rd Time 294 102.1 57 E-S Wind 2.8 4th Time 296 102.1 51 E-S Wind 2.7

197 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 7.2-3 The Monitoring Results of Present Ambient Air Quality Condition within the Evaluation Area Hourly Average Value Average Daily Value Maximum Maximum Maximum Item Monitoring Point Concentration Range Over-standard Concentration Over-standard Pollution Over-standard Over-standard (mg/m3) Rate (%) Range (mg/m3) Rate (%) Index Multiple Multiple Shangfang Mountain 0.02~0.061 / / 0.026~0.046 / / 0.31 Qizi Lot, Gusu Village 0.01~0.07 / / 0.022~0.054 / / 0.36 Fenghuang Lot 0.023~0.061 / / 0.025~0.040 / / 0.27 SO 2 Former Lita Village 0.015~0.055 / / 0.020~0.050 / / 0.33 Fomer Tiangou Village 0.022~0.059 / / 0.020~0.041 / / 0.27 Mudu Town (Guzhen District) 0.023~0.061 / / 0.024~0.073 / / 0.49 Shangfang Mountain 0.017~0.078 / / 0.040~0.061 / / 0.51 Qizi Lot, Gusu Village 0.009~0.086 / / 0.022~0.061 / / 0.51 Fenghuang Lot 0.016~0.071 / / 0.019~0.089 / / 0.74 NO 2 Former Lita Village 0.020~0.069 / / 0.011~0.057 / / 0.48 Former Tiangou Village 0.015~0.077 / / 0.030~0.058 / / 0.48 Mudu Town (Guzhen District) 0.045~0.071 / / 0.043~0.083 / / 0.69 Shangfang Mountain / / / 0.11~0.13 / / 0.87 Qizi Lot, Gusu Village / / / 0.098~0.13 / / 0.87 Fenghuang Lot / / / 0.11~0.13 / / 0.87 PM 10 Former Lita Village / / / 0.11~0.13 / / 0.87 Former Tiangou Village / / / 0.11~0.13 / / 0.87 Mudu Town (Guzhen District) / / / 0.11~0.13 / / 0.87 Shangfang Mountain 0.001~0.004 / / / / / 0.40 Qizi Lot, Gusu Village 0.002~0.007 / / / / / 0.50 Fenghuang Lot 0.001~0.005 / / / / / 0.50 H S 2 Former Lita Village 0.002~0.005 / / / / / 0.60 Former Tiangou Village 0.002~0.006 / / / / / 0.60 Mudu Town (Guzhen District) 0.002~0.005 / / / / / 0.50 Shangfang Mountain 0.017~0.044 / / / / / 0.88 HCl Qizi Lot, Gusu Village 0.003L~0.054 3.6 1.08 / / / 1.08

198 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Hourly Average Value Average Daily Value Maximum Maximum Maximum Item Monitoring Point Concentration Range Over-standard Concentration Over-standard Pollution Over-standard Over-standard (mg/m3) Rate (%) Range (mg/m3) Rate (%) Index Multiple Multiple Fenghuang Lot 0.020~0.047 / / / / / 0.94 Former Lita Village 0.018~0.050 3.6 1 / / / 1.00 Former Tiangou Village 0.017~0.049 / / / / / 0.98 Mudu Town (Guzhen District) 0.020~0.044 / / / / / 0.88 Shangfang Mountain 0.01~0.1 / / / / / 0.50 Qizi Lot, Gusu Village 0.03L~0.04 / / / / / / Fenghuang Lot 0.01L~0.1 / / / / / 0.50 NH 3 Former Lita Village 0.01L~0.08 / / / / / 0.40 Former Tiangou Village 0.01L~0.11 / / / / / 0.55 Mudu Town (Guzhen District) 0.01L~0.11 / / / / / 0.55 Shangfang Mountain 0.9L / / / / / / Qizi Lot, Gusu Village 0.9L~4.38 / / / / / 0.22 Fluoride Fenghuang Lot 0.9L / / / / / / (μg/m3) Former Lita Village 0.9L / / / / / / Former Tiangou Village 0.9L / / / / / / Mudu Town (Guzhen District) 0.9L / / / / / / Shangfang Mountain 1~2.5 / / / / / 0.25 Qizi Lot, Gusu Village 0.9~4.4 / / / / / 0.44 Fenghuang Lot 1.1~3.3 / / / / / 0.33 CO Former Lita Village 0.9~7.1 / / / / / 0.71 Former Tiangou Village 1.1~2.6 / / / / / 0.26 Mudu Town (Guzhen District) 1.1~3.6 / / / / / 0.36 Shangfang Mountain 0.003L / / / / / / Qizi Lot, Gusu Village 0.003L / / / / / / Hg(μ 3 Fenghuang Lot 0.003L / / / / / / g/m ) Former Lita Village 0.003L / / / / / / Former Tiangou Village 0.003L / / / / / /

199 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Hourly Average Value Average Daily Value Maximum Maximum Maximum Item Monitoring Point Concentration Range Over-standard Concentration Over-standard Pollution Over-standard Over-standard (mg/m3) Rate (%) Range (mg/m3) Rate (%) Index Multiple Multiple Mudu Town (Guzhen District) 0.003L / / / / / / Shangfang Mountain 0.0001L~0.001 / / / / / 0.093 Qizi Lot, Gusu Village 0.0001L~0.001 / / / / / 0.093 Fenghuang Lot 0.0001L~0.001 / / / / / 0.093 Pb Former Lita Village 0.0001L~0.001 / / / / / 0.093 Former Tiangou Village 0.0001L~0.001 / / / / / 0.093 Mudu Town (Guzhen District) 0.0001L~0.001 / / / / / 0.093 Shangfang Mountain 0.0003~0.0011 / / / / / 0.11 Qizi Lot, Gusu Village 0.0002~0.001 / / / / / 0.10 Fenghuang Lot 0.0003~0.0009 / / / / / 0.09 Cd Former Lita Village 0.0002~0.0009 / / / / / 0.09 Former Tiangou Village 0.0004~0.0008 / / / / / 0.08 Mudu Town (Guzhen District) 0.0001~0.0007 / / / / / 0.07 *note: Undetected value is indicated as “detection limit L”.

200 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

From the table above, it can be seen that the hourly concentration of SO2, NO2,

H2S, CO and NH3 of all monitoring points can meet the level II standard of Ambient

Air Quality Standard, and the average daily concentration of PM10, SO2, NO2, CO and Fluoride can meet and higher than the level II standard of Ambient Air Quality Standard, but the concentration of Hg and Fluoride is undetected. At Qizi Lot, Gusu Village and Former Lita Village, there is a over-standard (the standard limit value is 0.05mg/m3) of the hourly concentration of HCl respectively, with the over-standard rate of 3.6%. Through investigation, around the monitoring area are Suzhou Wusheng Iron & Steel Co., Ltd., Chunhua Wiredrawing Co., Ltd., etc., which are enterprises discharging HCL. According to the Phase II Project Environmental Evaluation Report, there being over-standard of HCl emission in Mudu Town and Gusu Village within the evaluation area before the construction of Phase II Project, and the monitoring result of this time is better than that in 2007. In consideration that the Everbright Phase III Expansion Project would help to reduce the HCl emissions, so that the ambient concentration of HCL would be further decreased.

7.2.2 Investigation and Evaluation of Present Surface Water Environment Quality Condition

7.2.2.1 Monitoring on Present Surface Water Condition (1) Monitoring Arrangement: Based on the characteristics of river network within the area as well as the pollutant-contained water bodies, four monitoring sections are arranged totally. See Table 7.2-4 and Fig.2.1-2 for their specific positions.

Table 7.2-4 Arrangement of Monitoring Sections of Surface Water Environment River Section Position of Monitoring Points Monitoring Item Remarks 500m at the upstream of sewage Sulphide, Fluoride, W1 outlet of New District Sewage volatile phenol Plant pH, SS, chroma, Jiangnan Actual permanganate index, Canal 500m at the downstream of Measurement COD , BOD , total W2 sewage outlet of New District Cr 5 nitrogen, ammonia Sewage Plant nitrogen, total phosphorus, petroleum, sulphide,

201 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Fluoride, THg, total chromium, total nickel, volatile phenol 3500m at the downstream of W3 sewage outlet of New District Sewage Plant Sulphide, fluoride, volatile 100m at the upstream of the phenol Xujiang W4 interaction between Canal and River Xujiang River

(2) Monitoring Items: pH, SS, chroma, permanganate index, CODCr, BOD5, total nitrogen, ammonia nitrogen, total phosphorus, petroleum, sulphide, Fluoride, THg, total chromium, total nickel, volatile phenol. (3) Monitoring Time and Frequency: From April 22 to April 24 2011. Frequency: sample and monitor for three consecutive days and once each day. (4) Monitoring and Analyzing Methods: According to the provisions and requirements of the Environmental Monitoring Technical Norms and Standard Methods for the Examination of Water and Wastewater issued by State Environmental Protection Administration. (5) Evaluation on Present Surface water Environmental Quality Condition Evaluation Method: Adopt single factor pollution index method; Calculation method of over-standard rate:  = the number of over-standard×100%/the total number of measurement The single factor pollution index shall be calculated with the following formula: P  C / S i i th Where, Ci refers to the actually measured concentration value of the i

th pollutant; Si refers to the standard value of the i evaluation factor. The pollution index of PH shall, according to the Guidelines, be calculated as follows The standard index of pH is:

0.7  pH j S pH, j  pH j≤7.0 0.7  pH Sd

pH j  0.7 S pH, j  pH j>7.0 pH Su  0.7

Where, SpHj: the standard index of water quality parameter pH at the point of j;

pHj: the pH value at the point of j;

pHsu: the pH upper limit specified in surface water quality standard;

202 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

pHsd: the pH lower limit specified in surface water quality standard;

SDOj: the standard indexes of water quality parameter DO at the point of j;

DOf: the saturation value of dissolved oxygen at this temperature (mg/L);

DOj: the actual dissolved oxygen value (mg/L);

DOs: the standard dissolved oxygen value (mg/L);

Tj: the temperature at the point of j (℃).

7.2.2.2 Evaluation on the Monitoring Result of Present Surface Water Environment Condition See Table 7.2-5 for the quality statistics and evaluation result of surface water environment. From Table 7.2-5 it can be seen that the sulphide and violate phenol at W1, W3 and W4 sections can meet the corresponding standard, the ammonia nitrogen, total nitrogen, total phosphorus and SS at W2 section are over-standard, and all the other monitoring factors can meet the IV water quality standard of Environmental Quality Standards for Surface Water (GB3838-2002). In Taihu Basin, the over-standard of ammonia nitrogen, total nitrogen and total phosphorus is commonly seen, and Suzhou Municipal Government has already prepared Regulation Plan for Taihu Basin, which also put forth regulation plan and requirements for Suzhou section of Jiangnan Canal: do well in sewage interception, desilting and water distribution of Canal; make control of the total emissions of pollutants in this Basin; regulate pollution sources in villages; transform waste disposal plants and raise their standards. Through the above regulation measures, the water quality of Canal has been improved gradually.

203 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 7.2-5 Quality Monitoring Data Statistics and Evaluation of Surface Water Environment (unit: mg/L, ℃) pH (dimensionless) Monitoring Section Monitoring Item Fluoride pH Sulphide COD Ammonia Nitrogen SS Permanganate Index Total Phosphorus Volatile Phenol Total Chromium Total Mercury Petroleum Total Nitrogen Nickel Chroma BOD Maximum Value 0.97 / 0.005L / / / / / 0.0022 / / / / / / / Minimum Value 0.90 / 0.005L / / / / / 0.0014 / / / / / / / 0.94 / / / / / / / 0.0017 / / / / / / / W1 Average Concentration Maximum Single Factor 0.004 / / / / / / / 0.22 / / / / / / / Index Over-standard Rate (%) / / / / / / / / / / / / / / / / Maximum Value 1.00 7.60 0.005 19.3 2.56 344 3.8 0.52 0.0026 0.059 0.00018 0.14 5.69 0.002L 64 2.5 Minimum Value 0.80 7.50 0.005L 13.3 1.90 210 3.4 0.18 0.0018 0.003L 0.00014 0.05 4.98 0.002L 8 2.0L 0.92 / / 16.8 2.26 300 3.6 0.37 0.0023 / 0.00017 0.12 5.30 / 41 / W2 Average Concentration Maximum Single Factor 0.004 0.3 0.1 0.64 1.71 5.73 0.38 1.73 0.26 / 0.18 0.28 3.79 / / 0.42 Index Over-standard Rate (%) / / / / 100 100 / 66.7 / / / / 100 / / / Maximum Value 1.00 / 0.005L / / / / / 0.0022 / / / / / / / Minimum Value 0.84 / 0.005L / / / / / 0.0014 / / / / / / / 0.92 / / / / / / / 0.0017 / / / / / / / W3 Average Concentration Maximum Single Factor 0.004 / / / / / / / 0.17 / / / / / / / Index Over-standard Rate (%) / / / / / / / / / / / / / / / / Standard Value Level IV 250 6~9 0.5 30 1.5 60 10 0.3 0.01 0.05 0.001 0.5 1.5 / / 6 Maximum Value 0.88 / 0.006 / / / / / 0.0021 / / / / / / / Minimum Value 1.02 / 0.005L / / / / / 0.0012 / / / / / / / 0.94 / / / / / / / 0.0015 / / / / / / / W4 Average Concentration Maximum Single Factor 0.004 / 0.03 / / / / / 0.42 / / / / / / / Index Over-standard Rate (%) / / / / / / / / / / / / / / / / Standard Value LevelIII 250 6~9 0.2 20 1.0 30 6 0.2 0.005 0.05 0.0001 0.05 1.0 / / 4 *Note: Undetected value is indicated as “detection limit L”.

204 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

7.2.3 Evaluation on Present Acoustical Environment Quality Condition (1) Arrangement of Monitoring Points: Arrange 7 monitoring points at the boundary of factory and 1 monitoring point at office and living area. See Fig 4.3-1 for details. (2) Monitoring item: equivalent sound level A. (3) Monitoring time and frequency: Monitoring time and frequency: two days from April 21to April 22, 2011, once respectively in daytime and nighttime. (4) Monitoring and analyzing method: According to the relevant provisions and requirements of Environmental Monitoring Technical Norms issued by State Environmental Protection Administration (5) Evaluation on Monitoring Results: Evaluate them by comparing with Environmental Noise Standard for Urban District. See Table 7.2-6 for monitoring results.

Table 7.2-6 Environmental Noise Monitoring Results Unit: dB (A) Monitoring Monitoring Daytime Nighttime Position Position In the north of N1 53 55 43 44 east boundary In the south of N2 57 56 46 42 east boundary In the east of N3 56 56 43 44 south boundary In the west of N4 55 57 42 46 south boundary In the south of N5 58 57 47 44 west boundary In the north of N6 55 55 43 42 west boundary In the west of N7 58 58 43 46 north boundary The living area in N8 56 58 43 47 the factory Standard Value 65 55 All meet the All meet the All meet the All meet the Results standard standard standard standard

The monitoring results indicate that the acoustical environment quality around the proposed factory is good. The noise level of all monitoring points in both daytime

205 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited and nighttime can all meet the level III standard of Environmental Quality Standard for Noise (GB3096-2008).

7.2.4 Monitoring and Evaluation of Present Ground Water Condition (1) Arrangement of monitoring points: Arrange one monitoring points respectively at project site, the boundary of hazardous waste landfill yard and Qizi Lot, see Fig.1.7-1 for details. The monitoring point of hazardous waste landfill yard is at the upstream, and that of Qizi Lot is at the downstream. (2) Monitoring Items: pH, permanganate index, ammonia nitrogen, Cr6+, Cd, Hg, Pb, nitrite nitrogen, Fluoride, total hardness. (3) Monitoring frequency: Actual measurement for project site, with the monitoring time of April 25, 2011, once totally. Refer to Environmental Evaluation Data of Extension Project of Everbright Environmental Protection (Suzhou) Solid Waste Disposal Co., Ltd. for the data of Qizi Lot, Gusu Village, with the monitoring time of from April 11 to April 12, 2011. (4) Monitoring and analyzing method: According to the provisions and requirements of Standard Methods for the Examination of Water and Wastewater issued by State Environmental Protection Administration. (5) Evaluation method: by comparing with Level III standard of Quality Standard for Ground Water (GB/T14848—93). (6) Monitoring and evaluation result: See Table 7.2-7 for the monitoring and evaluation result of ground water Table 7.2-7 Monitoring Results of Ground Water Quality and Evaluation List Unit: mg/L

Monitorin Monitoring Permanganat Total pH Cr6+ Cd g Position Date e Index Mercury D1: Project 2011.4.25 7.12 1.6 0.004L 0.00015 0.001L Site D2: The boundary of 0.00001L 2011.4.11~4.1 0.0002L~ hazardous 7.69~8.16 1.6~2.8 0.004L ~ 2 0.0045 waste 0.00008 landfill yard

206 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

D3: Qizi 2011.4.11~4.1 7.61~7.66 1.4~1.6 0.004L 0.00002 0.002L Lot 2 Standard Value 6.5-8.5 3.0 0.05 0.001 0.01 Meet the Meet the Meet the Meet the Meet the Result standard standard standard standard standard Monitorin Monitoring Nitrite Total Ammonia Pb Fluoride g Position Date Nitrogen Hardness Nitrogen D1: Project 2011.4.25 0.01L 0.003L 0.49 104 / site D2: The boundary of 2011.4.11~4.1 0.004L~0.01 0.71~0.9 0.091~0.13 hazardous / / 2 1 6 9 waste landfill yard D3: Qizi 2011.4.11~4.1 0.091~0.09 0.004L / 0.8~0.8 / Lot 2 6 Standard Value 0.05 0.02 1.0 450 0.2 Meet the Meet the Meet the Meet the Meet the Result standard standard standard standard standard Note: undetected value is indicated as “detection limit L”.

By comparing with the Quality Standard for Ground Water (GB/T14848-1993), it can be seen from Table 7.2-7 that the underground water quality at the project site, hazardous waste landfill yard and Qizi Lot all meet Level III water standard.

7.2.5 Monitoring and Evaluation of Present Soil Condition (1) Arrangement of monitoring points: arrange one monitoring point respectively at the farmland nearby the Former Tiangou Village and Qizishan in the south of factory. See Fig1.7-1 for details. (2) Monitoring items: pH, Cd, Hg, As, Cu, Pb, Cr, Zn, nickel. (3) Monitoring frequency: once on April 24, 2011 for T1 and T2. (4) Monitoring method: According to relevant national specifications for the monitoring and analysis of soil environment. (5) Monitoring result and evaluation: See Table 7.2-8 for monitoring results. By comparing with the Level II standard of Environmental Quality Standard for Soils (GB15618-1995), it can be seen that all heavy metal index are lower that the

207 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited evaluation standard, meeting the Level II standard of Environmental Quality Standard for Soils (GB15618-1995), which indicates that the present soil environment condition is good.

Table 7.2-8 Soil Environment Monitoring Result Unit: mg/kg Monitoring pH Cu Pb Zn Cr Cd Nickel Hg As Point T1: Farmland nearby 8.1 20.8 28.4 89.4 59.9 0.079 29.9 0.274 6.34 Former Tiangou Village Standard >7.5 100 350 300 350 0.6 60 1.0 20 Value T2: Qizishan 7.0 20.9 21.6 91.6 55.7 0.094 31.8 0.068 19.1 Standard 6.5~7.5 100 300 250 300 0.3 50 0.5 25 Value

7.2.6 Monitoring and Evaluation of Present Dioxin Condition

7.2.6.1 Monitoring and Evaluation of Present Dioxin Atmospheric Environment Quality Condition (1) Monitoring Arrangement Monitor the present dioxin condition according to Environmental Development (2008) No. 82 Document: Arrange one monitoring point respectively at the nearest sensitive point at the downwind of the all-year predominant wind direction and the heaviest fallen concentration point of pollutants. The all-year predominant wind direction is E-S wind; in consideration of there being no sensitive point at the upwind, arrange monitoring point at NNE (less-predominant upwind direction); the nearest sensitive point at the downwind is Tiangou Village. See Fig.1.7-1 for detailed arrangement.

Table 7.2-9 Arrangement for the Monitoring of Present Condition

Name of Monitoring Direction against Monitoring Environmental No. Point factory/distance Item Function Zoning G2 Qizi Lot, Gusu Village NNE /1200 Former Tiangou Dioxin Class II G5 NW /1350 Village

(2) Monitoring time, monitoring factor and sampling frequency

208 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Monitoring time: April 23, 2011. The monitoring frequency shall follow the national standard. (3) Sampling and analyzing method Adopt EPA Method 8290 (4) Monitoring results

Table 7.2-10 Monitoring Results Unit: TEQpg/Nm3 Name of Monitoring Average Daily S/N Standard Value Result Point Monitoring Result Meet the Qizi Lot, Gusu Village 0.615 G2 standard 1.65 Former Tiangou Meet the 0.786 G5 Village standard

Note:* According to the provisions in the Technical Guidelines for Environmental Impact Assessment-Atmospheric Environment, the conversion relation among momentary concentration, average daily concentration and average annual concentration is 1, 0.33, 0.12, so if average annual concentration of dioxin is converted to average daily concentration, it is 1.65pgTEQ/Nm3. According to the monitoring result, the dioxin atmospheric concentration nearby this project can meet relevant standards.

7.2.6.2 Monitoring of Dioxin Soil Environmental Quality Condition (1) Monitoring Point and Time Monitor the present Dioxin condition according to Environment Development (2008) No. 82 Document: Arrange one monitoring point respectively at both the upwind and downwind of the predominant wind direction in the factory. For the downwind, it is recommended that agricultural soil nearby the heaviest fallen concentration of pollutants. See Fig.1.7-1 for monitoring arrangement.

Table 7.2-11 Monitoring Arrangement for Present Soil (Dioxin) Quality Condition Monitoring Time and S/N Name of Monitoring Point Monitoring Item Frequency G1 Qizishan Dioxin April 24, 2011, once

209 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Farmland nearby the G2 Tiangou Village

(2) Monitoring Result Adopt EPA Method 1613. See Table 7.2-12 for results of present soil condition monitoring.

Table 7.2-12 Soil Environment Monitoring Result Unit: TEQng/Kg Name of Monitoring Monitoring S/N Standard Value Result Point Result Meet the G1 Qizishan 1.73 standard 250 Farmland nearby the Meet the G2 1.70 Tiangou Village standard

The evaluation of dioxin shall be in accordance with the environmental standard (250 ng/kg) issued by Japan Environmental Agency. From Table 7.2-12, it can be seen that all the dioxins are undetected, which indicates that the present soil environmental quality condition of project site is good.

7.2.7 Investigation on Present Ecological Environmental Quality Condition

7.2.7.1 Vegetation Distribution Condition Suzhou is located in the mixed evergreen and deciduous forest of north subtropical zone, with abundant varieties of plants. In this area, there are 217 kinds of tracheophyte (variant included), which fall under 87 families, of which there are 13 varieties falling under 11 genuses, 9 families, ferns; 5 varieties falling under 5 genuses, 4 families, gymnosperm; and 199 varieties falling under 170 genuses, 74 families, angiosperm. If classified by vegetation type, the mixed evergreen and deciduous forest is zonal vegetation: casuarina includes castanopsis sclerophylla, schima superba, phoebe sheareri, holly, etc; coniferous forest is mostly man-made forest, including masson pine, white bark pine, Qingcha, loblolly pine, etc. Taihu Basin, with abundant water source, stable water level and suitable water quality, has all kinds of water plants and fishes. The project site is located in Mudu Town, Wuzhong District, Suzhou and

210 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited classified as land for the disposal of domestic waste. There are almost no natural vegetation left due to damages arising out of long-term agricultural and industrial production activities, unordered mining activities and garbage landfilling. The natural vegetation in this area are mainly distributed in the mountains in the south and east of Qizishan, i.e. needle-leaved forest, broad-leaved deciduous forest, mixed evergreen and deciduous forest, bamboo forest, scrub, etc. The main tree species include ginkgo, loblolly pine, metasequoia, camphor tree, chukrasia tabularis, Huaxiang, Zhizhi, Celtis occidentalis, mao bamboo, Chinese pink, Zelkova schneideriana Hand-Mazz, cypress, Dalbergia hupeana, Buxus sinica, etc. The artificial ecological system has all kinds of economic tress planted after the implementation of afforestation project, mainly including loblolly pine, independent bosque, line trees, etc. Due to many reasons such as planning and transformation, the former Qizi Village has been moved to the other location, and there are no crops production and livestock breeding in this area. The project site is located in the ravine plain extended from the 3# and 4# cols of Qizishan. The newly acquired land is mainly located in the ravine plain in front of Qizishan, with a few shrubs and ruderals. The strike of west of Qizishan is approximately EW inclining to north, and that of the east side to 3# col is NE 56° inclining to NW. The mountain is distributed like an arch and formed a relatively large valley to the north. The 3# and 4# cols are paralleled. The elevation of main peak of Qizishan is 294.4m; longitudinal grade is appropriately 1:4; and cross fall is appropriately 1:2. In all the cols there are vegetations, with pines and firs (appropriately 5~6m) as the main varieties. Of all the cols, the 3# col's vegetation is particularly prosperous, followed by 4# col with small wild bamboo growing in its lower part.

7.2.7.2 Investigation on Important Creatures and Eco-sensitive Area In Suzhou City there are no large wild and rare animals, only with wild animals like bat, snakes and birds. And there are no important creatures and eco-sensitive area within 500m around the project site.

7.3 Environmental Quality Review and Analysis

211 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited According to Environmental Impact Report on the Phase II Expansion Project and Supporting Slag Recovery Project of Everbright Environmental Protection Energy (Suzhou) Co., Ltd., see Table 7.3-1 for the monitoring data statistics of ambient air, surface water, ground water and soil before the construction of Phase II project.

Table 7.3-1 Analysis on Environment Quality Change (I) Air (Unit: mg/m3) Average Daily Monitoring Momentary Concentration Range Concentration Range Result Factor 2007 2011 2007 2011

SO2 0.007L~0.495 0.015~0.061 0.004~0.147 0.02~0.073 None NO2 0.009~0.19 0.015~0.078 0.023~0.099 0.011~0.089 None Over-standard in Mudu Town, Former Qizi Village, Technological PM10 / / 0.049~0.365 0.11~0.13 Institute, Yaofeng Village and factory in 2007, but no over-standard in 2011 Over-standard in Mudu Town, Gusu Village in 2007, and one over-standard HCl 0.01L~0.056 0.017~0.054 / / respectively in Qizi Lot of Gusu Village and former Lita Village in 2011 HF 0.001L 0.9L / / None Pb 0.0005L~0.0037 0.0001L~0.001 / / None Hg 0.05Lμg/m3 0.00 3Lμg/m3 / / None Cd 0.05Lμg/m3 0.0002~0.001 / / None NH3 0.004L~0.19 0.01L~0.11 / / None H2S 0.002L~0.006 0.001~0.006 / / None Dioxin / 0.615~0.786pg/m3 / / None Contrastive analysis: The ambient air quality in 2011 is better than that in 2007

(II) Surface Water (unit: mg/L) Monitoring Concentration Range Result Factor 2007 2011

212 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Over-standard at point of 500m up the drain outlet and 3500m down the drain outlet of New District COD 16.1~42.3 13.3~19.3 Sewage Disposal Plant as well as 100m in front of the intersection of Xujiang River and Jiangnan Canal in 2007, but no over-standard in 2011 Over-standard at point of 500m up the drain outlet and 3500m down the drain outlet of New District BOD 3.3~8.6 2.0L~2.5 Sewage Disposal Plant as well as 100m in front of the intersection of Xujiang River and Jiangnan Canal in 2007, but no over-standard in 2011 CODMn 3.7~9.2 3.4~3.8 None Over-standard at point of 500m up the drain outlet and 3500m down the drain outlet of New District Sewage Disposal Plant as well as 100m in front of Ammonia 0.78~13.1 1.9~2.56 the intersection of Xujiang River and Jiangnan Nitrogen Canal in 2007, and over-standard at the point of 500m down the drain outlet of New District Sewage Disposal Plant in 2011 Over-standard at point of 500m up the drain outlet and 3,500m down the drain outlet of New District Total 0.01L~0.52 0.18~0.52 Sewage Disposal Plant in 2007, and over-standard Phosphorus at the point of 500m down the drain outlet of New District Sewage Disposal Plant in 2011 Fluoride 0.67~0.97 0.8~1.02 Sulphide 0.001L~0.04 0.005L~0.006 Over-standard at point of 500m up the drain outlet and 3500m down the drain outlet of New District Sewage Disposal Plant as well as 100m in front of SS 85~160 210~344 the intersection of Xujiang River and Jiangnan Canal in 2007, and over-standard at the point of 500m down the drain outlet of New District Sewage Disposal Plant in 2011 Total 0.0001L 0.00014~0.00018 None Mercury Total 0.05L 0.003L~0.059 None Chromium Contrastive analysis: The COD and BOD of surface water in 2011 is improved than that in 2007

(III) Underground Water (Unit: mg/L) Monitoring Concentration Range Result Factor 2007 2011 CODMn 0.6~2.7 1.4~2.8 None Ammonia 0.01L~0.13 0.091~0.139 None Nitrogen Cr6+ 0.004L 0.004L None total mercury 0.00001L 0.00001L~0.00015 None Cd 0.0001L 0.0002L~0.0045 None Pb 0.001L~0.02 0.004L~0.011 None Nitrite 0.11~0.74 0.003L None Fluoride 0.12~0.84 0.49~0.96 None Contrastive analysis: There is no bid difference between ground water factor in 2011 and that in 2007

(IV) Soil (Unit: mg/kg)

213 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Monitoring Concentration Range Result Factor 2007 2011 Cu 23.6~27.1 20.8~20.9 None Pb 26.8~59.9 21.6~28.4 None Zn 76.7~123 89.4~91.6 None Cr 53.3~63.7 55.7~59.9 None Cd 0.037~0.54 0.079~0.094 None Nickel / 29.9~31.8 None Hg 0.046~0.336 0.068~0.274 None As 6.84~10.5 6.34~19.1 None Contrastive analysis: There is no big difference between soil factor in 2011 and that in 2007

Through comparison, it can be seen that the present surface water environment condition now is better than that before the construction of Phase II project, and there is no difference for soil monitoring factor which indicates that this project doesn’t contribute much to the environment.

214 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

8 Predicative Analysis on Environmental Impact

8.1 Prediction and Evaluation on Ambient Air Impact

8.1.1 Order and Scope of Evaluation The order of evaluation for this project is Level II, and Scope of evaluation is the circular area within a radius of 3km from the pollution source.

The evaluation and prediction factors include SO2, PM10, NO2, CO, HCl, HF, Cd, Pb, Hg and dioxin. The prediction contents include: (1) Ambient air protection objects, ground level concentration at mesh point and the maximum ground level hourly concentration within the evaluation area under all-year hourly meteorological condition; (2) Ambient air protection objects, ground level concentration at mesh point and the maximum ground level daily average concentration within the evaluation area under all-year daily meteorological condition; (3) Ambient air protection objects, ground level concentration at mesh point and the maximum ground level annual average concentration within the evaluation area under all-year long-term meteorological condition; (4) Analysis on foul gas impact; (5) The maximum ground level hourly concentration of ambient air protection objects and the maximum ground level hourly concentration within the evaluation area under hourly or momentary hourly meteorological condition under unusual emission; (6) Calculation of atmospheric environment protection distance.

8.1.2 Emission Source Parameters The emission parameters for the regular atmospheric pollutants of this project are given in Table 8.1-1. And the emission parameters for fugitive atmospheric pollutants of this project are given in Table 8.1-2. Through investigation, there are no projects under construction or proposed that discharge pollutants of same kind.

215 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 8.1-1 Emission Parameters for the Regular Smoke Pollutants of This Project Normal Point Sources Unit Unusual Conditions Conditions Name / Exhaust Funnel of Incinerator Coordinate (X, Y) (mm) (00) Altitude at the bottom of exhaust funnel m 7.06 Height of exhaust funnel m 80 Inner diameter of exhaust funnel m 3 Speed at exhaust gas outlet m/s 11.10 Temperature at exhaust gas outlet K 428 Annual emission frequency h 7920 Once per 2~3h Emission condition - Continuously Occasionally

SO2 g/s 0.57 / PM10 g/s 0.57 142.5 NO2 g/s 10.23 / CO g/s 2.84 / Prediction factor HCl g/s 0.29 1.16 HF g/s 0.056 / Cd g/s 0.0028 / Pb g/s 0.028 / Hg g/s 0.0028 / Dioxin g/s 5.68E-09 2.68E-07 Note: NO2/NOX=0.9

Table 8.1-2 Fugitive Emission Parameters Southwest Corner of Areal Areal Source Angle Factor Initial Annual Source Parameter against Pollution Altitude Emission Emission Emission due Source X Coordinate Y coordinate m Length Width Height Hours Condition Speed north Name m m m m m h g/s/m2 °

NH3 1.86E-07 Dump pit 90 -30 7.08 68 55 45 3 7920 Continuously H2S 2.23E-08 Fly ash Stabilizing 230 -145 26.5 48 25 45 >10 7920 Continuously PM10 5.55E-05 Facilities

8.1.3 Predictive Mode of Ground Level Concentration Adopt AERNID mode recommended by the Appendix A of Technical Guidelines for Environmental Impact Assessment-Atmospheric Environment (HJ2.2-2008). AERMOD, as one of Industrial Source Complex Model, can simulate the short-term (average hourly, average daily) and long-term (average annual) concentration distribution of pollutants discharged by point source, a real source and body source based on the data characteristics of atmospheric boundary layer, which

216 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited applies to both rural or urban area and simple or complex topography. AERMOD has considered the impact of wake flow of buildings, namely smoke flume downwash. This mode uses hourly continuous preprocessed meteorological data to simulate the average concentration distribution in not less than one hour. The predictive mesh spacing is set as 100m.

8.1.4 Meteorological Parameters In this project we adopt the all-year daily and hourly meteorological data in 2009, of which the ground level meteorological data is from Wujiang meteorological station, which is located in 120°37’ east longitude and 31°10’ north latitude, with a altitude of 9m and a distance of appropriately 18 km from project site and having a similar geographical feature with the evaluation area. Upper altitude sounding data used in this report is from the simulate data of MM5 mesoscale model, with the horizontal grid resolution of 27km×27km, and the terrain-following coordinate is used in vertical direction and there are 40 layers totally from 1000 hpa to 100 hpa. The original data used in this mode include terrain clearance, land use, land-water body symbol, vegetation composition, etc. These data are from USGS. And the original meteorological data adopt the reanalyzing data of NCEP/NCAR. The extraction location of upper altitude sounding data is 112.77° east longitude and 31.13° north latitude. The upper altitude sounding data parameters include time (hour, day, month, year), the layer of sounding data, the air pressure of every layer, altitude, temperature, wind speed and wind direction (expressed as angle), and the data frequency is twice each day (08:00 and 20:00, Beijing Time) See Table 8.1-3 ~ Table 8.1-7 and Fig. 8.1-1 ~ Fig. 8.1-4 for meteorological data statistics:

Table 8.1-3 Monthly Variation of Annual Average Temperature Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Temperature ℃ 3.5 8.7 10.5 16.6 22.2 26.2 28.9 28.2 25.1 21.0 11.0 5.9

Table 8.1-4 Monthly Variation of Annual Average Wind Speed Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Wind Speed m/s 2.4 2.7 2.5 2.6 2.3 2.0 2.2 2.5 2.3 1.9 3.0 2.3

217 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Table 8.1-5 Daily Variation of Seasonal hourly Average Wind Speed Hour Wind 1 2 3 4 5 6 7 8 9 10 11 12 Speed m/s Spring 1.7 2.0 2.0 1.9 2.0 2.2 2.4 2.7 2.8 2.9 3.1 3.0 Summer 1.6 1.8 1.8 1.8 1.8 1.9 2.2 2.4 2.4 2.6 2.8 2.7 Autumn 2.0 2.1 2.1 2.1 2.2 2.3 2.5 2.6 2.6 2.8 3.0 2.8 Winter 1.9 2.4 2.3 2.3 2.4 2.3 2.2 2.3 2.4 2.7 3.0 3.0 Hour h Wind 13 14 15 16 17 18 19 20 21 22 23 24 Speed m/s Spring 3.1 3.3 3.0 2.8 2.8 2.6 2.5 2.6 2.1 2.0 2.3 1.8 Summer 2.7 2.9 2.6 2.5 2.6 2.3 2.2 2.3 1.9 1.8 2.0 1.7 Autumn 2.8 2.9 2.6 2.5 2.5 2.4 2.3 2.4 2.2 2.1 2.2 2.0 Winter 3.1 3.3 3.0 2.8 2.7 2.4 2.3 2.2 1.9 1.9 2.4 2.0

Table 8.1-6 Monthly Variation of Annual Average Wind Frequency Wind Directio n N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW C Wind Frequency% Jan 7.8 6.9 6.6 5.5 7.0 5.1 4.7 2.7 3.5 1.6 1.9 2.3 7.7 8.3 12.6 14.0 1.9 Feb 4.6 9.4 11.6 15.8 11.3 7.7 8.9 4.8 4.6 0.6 0.3 0.3 3.3 8.0 4.3 2.8 1.5 Mar 5.5 7.8 10.0 12.2 12.1 7.9 9.2 8.7 3.2 1.6 2.0 1.9 2.6 4.2 5.2 5.2 0.5 Apr 6.3 5.7 6.0 5.1 13.9 16.1 13.9 7.9 4.2 0.6 1.3 1.9 2.8 3.5 4.7 5.4 0.8 May 3.0 3.2 6.0 8.9 14.5 14.2 16.0 8.9 5.8 0.9 1.6 0.9 3.2 3.5 4.3 4.4 0.5 Jun 1.5 4.0 2.8 5.3 6.8 12.6 14.0 10.3 8.1 9.0 7.6 6.5 5.8 2.1 1.7 1.0 0.8 Jul 3.4 1.3 3.9 7.4 9.1 9.0 11.0 15.5 8.5 5.5 5.4 5.4 4.6 2.2 2.6 3.1 2.3 Aug 4.2 5.1 12.5 23.8 14.9 5.9 5.1 3.6 2.6 2.6 3.4 3.9 2.3 4.2 1.1 2.4 2.6 Sep 7.6 10.4 13.9 24.7 18.1 4.4 3.2 2.9 0.7 0.7 0.7 0.4 1.3 1.1 3.3 6.0 0.6 Oct 6.2 11.4 10.6 13.7 7.3 8.2 10.8 5.5 5.1 2.0 3.9 2.7 2.6 1.6 2.6 3.1 2.8 Nov 10.6 7.1 5.1 3.1 3.5 3.8 6.8 4.4 2.8 2.5 1.5 2.1 3.5 8.2 18.5 15.7 1.0 Dec 9.1 8.1 8.1 9.3 5.2 2.3 3.5 2.4 2.8 2.2 3.0 4.8 7.7 8.2 12.4 9.1 1.9

Table 8.1-7 Average Annual Wind Frequency and Its Seasonal Change Wind Direction N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW C Wind Frequency% Spring 4.9 5.6 7.3 8.8 13.5 12.7 13.0 8.5 4.4 1.0 1.6 1.6 2.9 3.7 4.8 5.0 0.6 Summer 3.0 3.5 6.4 12.2 10.3 9.1 10.0 9.8 6.3 5.7 5.4 5.3 4.2 2.8 1.8 2.2 1.9 Autumn 8.1 9.7 9.9 13.8 9.6 5.5 7.0 4.3 2.9 1.7 2.1 1.7 2.4 3.6 8.1 8.2 1.5 Winter 7.3 8.1 8.7 10.0 7.7 5.0 5.6 3.2 3.6 1.5 1.8 2.5 6.3 8.2 10.0 8.8 1.8 Average Annual 5.8 6.7 8.1 11.2 10.3 8.1 8.9 6.5 4.3 2.5 2.7 2.8 3.9 4.6 6.1 6.0 1.4

218 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Fig. 8.1-1 Monthly Variation Curve of Average Annual Temperature

Fig. 8.1-2 Monthly Variation Curve of Average Wind Speed

Fig. 8.1-3 Daily Variation Curve of Seasonal Hourly Average Wind Speed

219 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Fig. 8.1-4 Seasonal and Annual Average Wind Rose Map

8.1.5 Terrain Parameter Through investigation, within the evaluation scope of this project in the north side are mainly industrial enterprises and in the south side are mainly mountains. Therefore, relevant land surface parameters (albedo, Bowen ratio and surface roughness) shall be used accordingly for these two sides.

220 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Near-Surface Parameters Surface Bowen Parameter Surface Roughness Degree Season Albedo Spring 0.162 0.565 1.0 Summer 0.177 1.115 1.0 -90~90 Autumn 0.191 1.255 1.0 Winter 0.525 1.5 1.0 Spring 0.162 0.565 0.05 Summer 0.177 1.115 0.1 90~270 Autumn 0.191 1.255 0.01 Winter 0.525 1.5 0.001

The terrain data is the “SRTM 90m Digital Elevation Data” loaded from US website, with the resolution of 90m.

8.1.6 Prediction Results of Ground Level Concentration under Normal Condition (1) Prediction and Analysis of Maximum Regional Concentration Based on predictive calculation, under normal condition and in consideration of combined contribution of projects under construction and proposed, the maximum fallen hourly concentration of pollutants discharged by this project to the evaluation area is given in Table 8.1-8. The hourly fallen concentration isoline map of all waste gas and pollutants within the evaluation area is detailed in Fig. 8.1-8. From the analysis on predictive results, it can be seen that the hourly maximum fallen contribution value of all pollutants can meet the requirements of Level II standard.

Table 8.1-8 Maximum Hourly Concentration Contribution of Pollutants Under Normal Condition Predictive Result Type of Percentage X coordinate Y coordinate Occurrence Pollutant Contribution Concentration against against P6 against P6 Time of Value (ug/m3) standard (%) (m) (m) Maximum Value Hourly 0.96964 0.19 -100 -300 07.03.11 Average Daily 0.51994 0.35 -300 -800 04.01 SO 2 Average 0.05832 0.10 -500 -100 Annual Hourly 17.40255 7.25 -100 -300 07.03.11 Average Daily 9.33151 7.78 -300 -800 04.01 NO 2 Average 1.04666 1.31 -500 -100 Annual Average Daily 40.34521 26.90 400 0 07.07 PM Average 10 4.53283 4.53 400 -100 Annual HCl Hourly 0.49333 0.99 -100 -300 07.03.11

221 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Average Daily 0.26453 1.76 -300 -800 04.01 Hourly 0.10207 0.51 -100 -300 07.03.11 HF Average Daily 0.05473 0.78 -300 -800 04.01 Hourly 0.05103 0.48 -100 -300 07.03.11 Average Daily 0.02737 0.78 -300 -800 04.01 Pb Average 0.00307 0.31 -500 -100 Annual Hourly 0.0051 0.57 -100 -300 07.03.11 Hg Average Daily 0.00274 0.91 -300 -800 04.01 Hourly 0.0051 0.05 -100 -300 07.03.11 Cd Average Daily 0.00274 0.09 -300 -800 04.01 Hourly 0.00966 0.19 -100 -300 07.03.11 Average Daily 0.00518 0.31 -300 -800 04.01 Dioxin Average 0.00058 0.097 -500 -100 Annual NH3 Hourly 0.82953 0.41 100 -200 09.18.24 H2S Hourly 0.09945 0.99 100 -200 09.18.24

Note: The unit of dioxin concentration is pg/m3.

SO2 Average Hourly

222 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

SO2 Average Daily

SO2 Average Annual

223 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

NO2 Average Hourly

NO2 Average Daily

224 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

NO2 Average Annual

PM10 Average Daily

225 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

PM10 Average Annual

HCl Average Hourly

226 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

HF Average Hourly

Pb Average Hourly

227 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Pb Average Daily

Pb Annual Average

228 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Hg Average Hourly

Hg Average Daily

229 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Cd Average Hourly

Cd Average Daily

230 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Dioxin Average Hourly (10-3pg/m3)

Dioxin Average Daily (10-3pg/m3)

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Dioxin Average Annual (10-3pg/m3)

NH3 Average Hourly

232 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

H2S Average Hourly Fig. 8.1-5 Pollutant Concentration Contribution Distribution

(2) Predictive Analysis on the Concentration of Sensitive Point Based on the prediction results, the statistical analysis of the maximum hourly fallen concentration of all sensitive points within the evaluation area is given in Table 8.1-9. Use detection limit as the background value for undetected value, and use the maximum value of every point as the background value of dioxin monitoring. It can be seen that, if the maximum background value plus the “carry-the-old-with-the-new reduction” are considered, the concentration value of pollutants at all the sensitive points can meet the requirements of level II standard.

Table 8.1-9 Prediction of Concentration Contribution of Monitoring Points Maxim Maximu Carry-the- Contribu um Percentag Main Types of m old-with-th Superimpose tion Backgr e Against Evaluation Pollutants Concentra Occurre e-new d Value Value ound Standard Point tion nce reduction (ug/m3) (ug/m3) Value (%) Time (ug/m3) (ug/m3) Hourly 05.19.07 0.51105 61 0.00374 61.50731 12.30 Average 05.15 0.07307 46 SO2 Daily 0.00059 46.07248 30.71 Shangfang Average 0.00969 Mountain Annual 0.00011 0.00958 0.02 Hourly 05.19.07 9.17192 78 87.17192 36.32 NO Average 2 05.15 1.31141 61 Daily 62.31141 51.93

233 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Maxim Maximu Carry-the- Contribu um Percentag Main Types of m old-with-th Superimpose tion Backgr e Against Evaluation Pollutants Concentra Occurre e-new d Value Value ound Standard Point tion nce reduction (ug/m3) (ug/m3) Value (%) Time (ug/m3) (ug/m3) Average 0.00493 Annual 0.00493 0.01 Average 05.15 1.31141 130 Daily 3.96784 127.34357 84.90 PM 10 Average 0.05153 Annual 0.05 Hourly 05.19.07 0.26001 44 0.46875 43.79126 87.58 HCl Average 05.15 0.03718 Daily 0.03718 0.25 Hourly 05.19.07 0.05379 0.9 0.95379 4.77 HF Average 05.15 0.00769 Daily 0.00769 0.11 Hourly 05.19.07 0.02690 1 1.02690 9.60 Average 05.15 0.00385 Pb Daily 0.00385 0.11 Average 0.00051 Annual 0.00051 0.05 Hourly 05.19.07 0.00269 0.003 0.00569 0.63 Hg Average 05.15 0.00038 Daily 0.00038 0.13 Hourly 05.19.07 0.00269 1.1 1.10269 11.03 Cd Average 05.15 0.00038 Daily 0.00038 0.01 Hourly 05.19.07 0.00509 0.00509 0.10 Average 05.15 0.00073 Dioxin Daily 0.00073 0.04 Average 0.00010 Annual 0.00010 0.02 NH3 Hourly 05.31.01 0.09203 100 100.09203 50.05 H2S Hourly 05.31.01 0.01103 4 4.01103 40.11 Hourly 08.17.08 0.38299 0.00499 0.37800 0.08 Average 06.28 0.09557 SO2 Daily 0.00045 0.09512 0.06 Average 0.01187 Annual 0.00009 0.01178 0.02 Hourly 08.17.08 6.87374 6.87374 2.86 Average 06.28 1.71523 NO2 Daily 1.71523 1.43 Average Qizi Lot, 0.00604 Annual 0.00604 0.01 Gusu Average Village 06.28 1.71523 Daily 3.07059 -1.35536 -0.90 PM 10 Average 0.06915 Annual 0.07 Hourly 08.17.08 0.19486 0.35130 -0.15644 -0.31 HCl Average 06.28 0.04862 Daily 0.04862 0.32 Hourly 08.17.08 0.04032 0.9 0.94032 4.70 HF Average 06.28 0.01006 Daily 0.01006 0.14

234 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Maxim Maximu Carry-the- Contribu um Percentag Main Types of m old-with-th Superimpose tion Backgr e Against Evaluation Pollutants Concentra Occurre e-new d Value Value ound Standard Point tion nce reduction (ug/m3) (ug/m3) Value (%) Time (ug/m3) (ug/m3) Hourly 08.17.08 0.02016 1 1.02016 9.53 Average 06.28 0.00503 Pb Daily 0.00503 0.14 Average 0.00062 Annual 0.00062 0.06 Hourly 08.17.08 0.00202 0.003 0.00502 0.56 Hg Average 06.28 0.00050 Daily 0.00050 0.17 Hourly 08.17.08 0.00202 1 1.00202 10.02 Cd Average 06.28 0.00050 Daily 0.00050 0.02 Hourly 08.17.08 0.00382 0.00382 0.08 Average 06.28 0.00095 Dioxin Daily 0.00095 0.06 Average 0.00012 Annual 0.00012 0.02 NH3 Hourly 11.22.24 0.12458 0.12458 0.06 H2S Hourly 11.22.24 0.01494 0.01494 0.15 Hourly 12.23.09 0.47384 61 0.00403 61.46981 12.29 Average 02.16 0.19905 40 SO2 Daily 0.00022 40.19883 26.80 Average 0.02150 Annual 0.00005 0.02145 0.04 Hourly 12.23.09 8.50425 71 79.50425 33.13 Average 02.16 3.57246 89 NO2 Daily 92.57246 77.14 Average 0.01094 Annual 0.01094 0.01 Average 02.16 3.57246 130 Daily 3.78210 129.79036 86.53 PM 10 Average 0.08858 Annual 0.09 Hourly 12.23.09 0.24108 47 0.43462 46.80646 93.61 Fenghuang HCl Average 02.16 0.10127 Lot Daily 0.10127 0.68 Hourly 12.23.09 0.04988 0.9 0.94988 4.75 HF Average 02.16 0.02095 Daily 0.02095 0.30 Hourly 12.23.09 0.02494 1 1.02494 9.58 Average 02.16 0.01048 Pb Daily 0.01048 0.30 Average 0.00113 Annual 0.00113 0.11 Hourly 12.23.09 0.00249 0.003 0.00549 0.61 Hg Average 02.16 0.00105 Daily 0.00105 0.35 Hourly 12.23.09 0.00249 0.9 0.90249 9.02 Cd Average 02.16 0.00105 Daily 0.00105 0.04 Dioxin Hourly 12.23.09 0.00472 0.00472 0.09

235 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Maxim Maximu Carry-the- Contribu um Percentag Main Types of m old-with-th Superimpose tion Backgr e Against Evaluation Pollutants Concentra Occurre e-new d Value Value ound Standard Point tion nce reduction (ug/m3) (ug/m3) Value (%) Time (ug/m3) (ug/m3) Average 02.16 0.00198 Daily 0.00198 0.12 Average 0.00021 Annual 0.00021 0.04 NH3 Hourly 08.16.01 0.11685 100 100.11685 50.06 H2S Hourly 08.16.01 0.01401 5 5.01401 50.14 Hourly 09.14.11 0.62065 55 0.00308 55.61757 11.12 Average 06.24 0.23174 50 SO2 Daily 0.00019 50.23155 33.49 Average 0.03688 Annual 0.00003 0.03685 0.06 Hourly 09.14.11 11.13911 69 80.13911 33.39 Average 06.24 4.15915 57 NO2 Daily 61.15915 50.97 Average 0.01876 Annual 0.01876 0.02 Average 06.24 4.15915 130 Daily 0.66702 133.49213 88.99 PM 10 Average 0.18274 Annual 0.18 Hourly 09.14.11 0.31577 50 0.56927 49.74650 99.49 HCl Average 06.24 0.11790 Daily 0.11790 0.79 Hourly 09.14.11 0.06533 0.9 0.96533 4.83 Former HF Average Lita 06.24 0.02439 Daily 0.02439 0.35 Village Hourly 09.14.11 0.03267 1 1.03267 9.65 Average 06.24 0.01220 Pb Daily 0.01220 0.35 Average 0.00194 Annual 0.00194 0.19 Hourly 09.14.11 0.00327 0.003 0.00627 0.70 Hg Average 06.24 0.00122 Daily 0.00122 0.41 Hourly 09.14.11 0.00327 0.9 0.90327 9.03 Cd Average 06.24 0.00122 Daily 0.00122 0.04 Hourly 09.14.11 0.00618 0.00618 0.12 Average 06.24 0.00231 Dioxin Daily 0.00231 0.14 Average 0.00037 Annual 0.00037 0.06 NH3 Hourly 06.01.22 0.17348 80 80.17348 40.09 H2S Hourly 06.01.22 0.02080 5 5.02080 50.21 Hourly 05.19.07 0.59869 59 0.00319 59.59550 11.92 Average Former 06.24 0.09118 41 SO Daily 0.00047 41.09071 27.39 Tiangou 2 Average Village 0.01361 Annual 0.00008 0.01353 0.02 NO2 Hourly 05.19.07 10.7448 77 87.74482 36.56

236 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Maxim Maximu Carry-the- Contribu um Percentag Main Types of m old-with-th Superimpose tion Backgr e Against Evaluation Pollutants Concentra Occurre e-new d Value Value ound Standard Point tion nce reduction (ug/m3) (ug/m3) Value (%) Time (ug/m3) (ug/m3) 2 Average 06.24 1.63654 58 Daily 59.63654 49.70 Average 0.00692 Annual 0.00692 0.01 Average 06.24 1.63654 130 Daily 2.26996 129.36658 86.24 PM 10 Average 0.06471 Annual 0.06 Hourly 05.19.07 0.30459 49 0.54912 48.75547 97.51 HCl Average 06.24 0.04639 Daily 0.04639 0.31 Hourly 05.19.07 0.06302 0.9 0.96302 4.82 HF Average 06.24 0.00960 Daily 0.00960 0.14 Hourly 05.19.07 0.03151 1 1.03151 9.64 Average 06.24 0.00480 Pb Daily 0.00480 0.14 Average 0.00072 Annual 0.00072 0.07 Hourly 05.19.07 0.00315 0.003 0.00615 0.68 Hg Average 06.24 0.00048 Daily 0.00048 0.16 Hourly 05.19.07 0.00315 0.8 0.80315 8.03 Cd Average 06.24 0.00048 Daily 0.00048 0.02 Hourly 05.19.07 0.00596 0.00596 0.12 Average 06.24 0.00091 Dioxin Daily 0.00091 0.06 Average 0.00014 Annual 0.00014 0.02 NH3 Hourly 01.27.06 0.10926 110 110.10926 55.05 H2S Hourly 01.27.06 0.01310 6 6.01310 60.13 Hourly 05.19.07 0.30192 61 0.00633 61.29559 12.26 Average 06.24 0.06050 73 SO2 Daily 0.00071 73.05979 48.71 Average 0.00462 Annual 0.00023 0.00439 0.01 Hourly 05.19.07 5.41863 71 76.41863 31.84 Average 06.24 1.08588 83 NO Daily 84.08588 70.07 Mudu 2 Average Town 0.00235 Annual 0.00235 0.00 Average 06.24 1.08588 130 Daily 9.77388 121.312 80.87 PM 10 Average 0.02237 Annual 0.02 Hourly 05.19.07 0.15361 44 0.27693 43.87668 87.75 HCl Average 06.24 0.03078 Daily 0.03078 0.21

237 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Maxim Maximu Carry-the- Contribu um Percentag Main Types of m old-with-th Superimpose tion Backgr e Against Evaluation Pollutants Concentra Occurre e-new d Value Value ound Standard Point tion nce reduction (ug/m3) (ug/m3) Value (%) Time (ug/m3) (ug/m3) Hourly 05.19.07 0.03178 0.9 0.93178 4.66 HF Average 06.24 0.00637 Daily 0.00637 0.09 Hourly 05.19.07 0.01589 1 1.01589 9.49 Average 06.24 0.00318 Pb Daily 0.00318 0.09 Average 0.00024 Annual 0.00024 0.02 Hourly 05.19.07 0.00159 0.003 0.00459 0.51 Hg Average 06.24 0.00032 Daily 0.00032 0.11 Hourly 05.19.07 0.00159 0.7 0.70159 7.02 Cd Average 06.24 0.00032 Daily 0.00032 0.01 Hourly 05.19.07 0.00301 0.00301 0.06 Average 06.24 0.00060 Dioxin Daily 0.00060 0.04 Average 0.00005 Annual 0.00005 0.01 NH3 Hourly 03.31.01 0.04156 110 110.04156 55.02 H2S Hourly 03.31.01 0.00498 5 5.00498 50.05

8.1.7 Analysis on Fugitive Emission Concentration in the Factory Adopt AERMOD to predict the fugitive concentration of fly ash, H2S and ammonia at the boundary of factory under all-year meteorological condition, see Table 8.1-10 for the prediction results. The prediction indicates that the fugitive concentration of fly ash, H2S and ammonia can meet the standard.

Table 8.1-10 Prediction of Fugitive Concentration at the Factory Boundary Standard Concentration Concentration Maximum Meet the standard or Pollutant Contribution Value at the Value not (mg/m3) Factory Boundary (mg/m3) NH3 S 0.8342 1.5 Meet the standard H2S S 0.0009 0.6 Meet the standard TSP E 0.3042 1.0 Meet the standard

8.1.8 Analysis on Odorous Impact Source of Odor Pollutants and Their Nature Before the waste incineration, it should be stored for about 3~5 days in order to guarantee the normal operation of waste incineration plant as well as to increase heat

238 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited value by dewatering the waste. During the stacking period, it would produce choking odorous and toxic substances such as H2S, thiol and so on. Compared with waste landfill, the impact of waste incineration is much lighter. There are more than 4,000 odorous substances that can be smelled by people, of which more than 40 kinds may have an impact on ecological environment and human health. The main odorous substances produced by urban domestic wastes are sulphide and lower aliphatic amine. The odor irritates people's sense organ to make us feel unpleasant and irksome, and some components such as H2S, thiol, amine and ammonia can severely and directly harm respiratory system, endocrine system, circulating system and nervous system. Long-term exposure to one or more kinds of low concentration of odorous substances may result in olfactory fatigue and anosmia, and even cause dysfunction of cerebral cortex. Analogy Investigation and Analysis on the Foul Odor of Waste Incineration Plant According to investigation on enterprises of same kind, its odorous gases are mainly produced from two links including waste discharging platform (inclusive of waste storage pit) and waste belt conveyer, and the incinerated flue gases don’t have much to do with the foul odor. Upon high temperature combustion, the odor strength of clinker becomes less than it before. The primary dir feed of incinerator uses the air in the storehouse, so the store house is under negative pressure, which is unfavorable of emission of foul odor. The severest moment is at the time of inspection and repair in the incinerator, we can close the door and windows of waste storehouse to prevent the foul odor from flying outside. There are 3 incinerators totally, so we should inspect and repair them respectively to guarantee that the storehouse is always under negative pressure so as to reduce the adverse effects at the time of inspection and repair. The emission of foul gases also has something with weather condition. Generally speaking, the odor strength is little under dry weather and it would has less impacts on environment; but in rainy day, under low pressure and high humility, the odor strength is heavy and it would have bigger impacts on environment. Investigation indicates that generally speaking there is no obvious environmental impact of foul odor on area more than 50m from the workshop. In this project the waste receiving, storing and conveying are all completed under closed condition and there is no open storage yard and manual separation yard. According to the

239 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited investigation on fugitive emission source produced by sites of same kinds, the degree of foul odor produced by wastes in external environment is level 2~3, its strength ranging from cognition to obvious, its main sensory response ranging from “just to be recognized" to “easy to be recognized”, with foul odor sensory distance of about within 50m. Prediction on the Concentration at the Boundary of Factory

According to the prediction, the maximum hourly concentration of NH3 and H2S at the boundary of factory is 0.3mg/m3 and 0.031 mg/m3 respectively, which meets the 3 3 concentration requirements (NH3 1.5mg/m , H2S 0.06 mg/m ). In case of accidents (boiler accident or inspection and repair), the waste storage pit should be kept closed, the exhaustion should be deodorization treated, with ventilation frequency of 1~1.5 times/h. The waste gas was routed to active carbon waste gas cleaning and deodorization facilities via the aspirating hole above the pit and pipe. The active carbon cleaning cartridge includes air intake section, filtering section and air-out section. The foul gases will enter the cartridge from the air intake section, conduct filtering and be discharged to the air by exhaust blower after most of the foul gases are absorbed on the active carbon. According to the monitoring and statistical data of projects of same kind, after deodorization treatment in case of accidents, the emission concentration of NH3 is 3 -5 3 about 0.056mg/m and that of H2S is about 7×10 mg/m , which has little impacts on environment and will not cause odorous impact on protection objects.

8.1.9 Predictive Result of Maximum Concentration Under Unusual Conditions According to the predictive results, the maximum hourly concentration value of pollutants under unusual conditions is given in Table 8.1-11. Based on the predictive results shown in Table 8.1-11, it can be seen that the contribution value of regular waste gases such as PM10, HCl and dioxin on ground level hourly concentration under unusual conditions is higher that that under normal conditions. Under unusual conditions, the regional maximum ground level hourly concentration of HCl and dioxin can still meet the requirements of relevant environmental quality standards, but that of PM10 is over-standard. Under unusual conditions, the contribution value of the maximum hourly ground

240 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited level concentration of PM10, HCl and dioxin at all sensitive points within the evaluation area is higher than that under normal conditions but can meet the relevant environmental quality standard.

Table 8.1-11 Prediction on the Average Hourly Concentration of Monitoring Points Main Occurrence Time Percentage Contribution Value of Evaluation Pollutant (year, month, day, against Standard This Project (ug/m3) Point hour) (%)

Maximum PM10 07.03.11 768.43291 170.76 Regional HCl 07.03.11 0.49333 0.99 Value Dioxin(pg/m3) 07.03.11 0.00966 0.19 PM10 05.07.04 58.61553 13.03 G1 HCl 05.19.07 0.26001 0.52 Dioxin (pg/m3) 05.19.07 0.00509 0.10 PM10 02.10.23 113.09715 25.13 G2 HCl 08.18.08 0.19486 0.39 Dioxin (pg/m3) 08.18.08 0.00382 0.08 PM10 02.06.02 82.40278 18.31 G3 HCl 12.23.09 0.24108 0.48 Dioxin (pg/m3) 12.23.09 0.00472 0.09 PM10 11.08.03 151.92214 33.76 G4 HCl 09.14.11 0.31577 0.63 Dioxin (pg/m3) 09.14.11 0.00618 0.12 PM10 11.08.03 71.04797 15.79 G5 HCl 05.19.07 0.30459 0.61 Dioxin (pg/m3) 05.19.07 0.00596 0.12 PM10 02.02.06 23.91872 5.32 G6 HCl 05.19.07 0.15361 0.31 Dioxin (pg/m3) 05.19.07 0.00301 0.06

8.1.10 Protection Distance of Atmospheric Environment Protection Distance of Atmospheric Environment Adopt the recommended atmospheric environment protection distance mode to calculate the protection distance of fugitive source. See Table 8.1-12 for the calculation results.

Table 8.1-12 Pollution Source Strength of Fugitive Emission and Calculation Results of Atmospheric Environment Protection Distance Emission Areal Source and Waste Waste Storehouse Fly ash Stabilizing Pollutants Storehouse NH3 H2S Dust Emissions (g/s) 0.00069 0.000083 0.05 Emission Height (m) 12 12 5 Emission Area (m2) 68*55 68*55 48*25 No Atmospheric Environment No over-standard No over-standard over-standard Protection Distance (m) point point point

241 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Width of sanitary protection zone The formula for width of sanitary protection zone is as follows: Q 1 c (.)BLc  0 25r2 0.50 L D CAm 3 Where: Cm refers to standard momentary limit value (mg/m ); Qc refers to the control level (kg/h) that can be reached by fugitive emissions of hazardous gases; L refers to the width of sanitary protection zone required by industrial enterprises; A, B, C and D refer to calculation factors. According to the average wind speed in past five years in this area and classification of atmospheric pollution source of industrial enterprises, A, B, C and D shall be 470, 0.021, 1.85 and 0.84 respectively. See Table 8.1-13 for the source strength and parameters for calculating the width of sanitary protection zone.

Table 8.1-13 Calculation Parameters for the Width of Sanitary Protection Zone and Calculation Result Pollution Calculation Pollutant Q (kg/h) C (mg/m3) S(m2) L(m) Source c m Value (m) Waste NH 0.0025 0.2 0.26 50 3 3,740 Storehouse H2S 0.0003 0.01 0.01 50 Fly ash Dust 0.18 0.15 1,200 86.7 100 Stabilizing

Arrangement of Protection Distance Based on the calculation results of both atmospheric protection distance and width of sanitary protection zone, use the outside envelope line as the protection distance of this project. The width of sanitary protection zone for waste storehouse and fly ash stabilizing site shall be 100m from their boundary. Also, based on the Environment Development (2008) No. 82 Circular on Further Strengthening Environment Impact Assessment Management of Biomass Waste-to-Energy Projects, saying “the environment protection distance for new, rebuilt or expansion projects shall be not less than 300m”. Therefore, the environment protection distance shall be 300m from the boundary of factory. In consideration of the requirements for the protection distance of existing projects that the environmental protection distance for Phase I and II projects are 300m, in the environmental evaluation of leachate processing project the width of

242 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited sanitary protection distance for this processing station is determined to be 400m. Therefore, taking all aspects into consideration, when the Phase III project is completed, the environmental protection distance for the whole plant is 400m from west boundary, 300m from east and south boundary and 100m from fly ash stabilizing workshop, see Fig. 4.3. Within such protection distance, there are no sensitive objects such as residential area. Meantime, taking the requirements for the width of sanitary protection zone of other neighboring waste disposal projects, see Table 8.1-14 for details.

Table 8.1-14 The Protection Distance Arrangement of Neighboring Projects and Distribution of Sensitive objects Sensitive Point Enterprise Project Arrangement of Protection Distance within the Protection Distance City Qizishan Domestic With protection distance of 300m from None Government Waste Landfill Site the boundary Hazardous waste With protection distance of 800m from None landfill yard the boundary Everbright Domestic Waste 400m for west boundary, 300m from Group Incineration Power east and south boundary and 100m None Plant from fly ash stabilizing workshop

From Fig.4.3-1, it can be seen that the protection distance (800m) arranged for hazardous waste landfill yard can meet the protection distance requirements of both the Qizishan domestic waste landfill site and Everbright domestic waste incineration power plant, and there are no sensitive points such as residential area.

8.1.11 Summary of Atmospheric Environment Impact Under the normal emission condition of regular waste gas, the maximum hourly concentration plus the background value can meet relevant environmental quality standard. The meet-the-standard emission of waste gas pollutants has little contribution to all waste gas pollutants in neighboring area; taking the sum of background value and maximum value as well as “carry-the-old-with-the-new reduction”, the concentration value of pollutants at all sensitive points can meet the requirements of level II standard.

Under unusual conditions, the contribution value of regular waste gas (PM10, HCl and dioxin) emissions is much higher than that under normal conditions. Under

243 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited unusual conditions, the regional maximum hourly concentration of HCL and dioxin resulting from the emission of project waste gas can still meet the requirements of relevant environmental quality standards. PM10 under unusual conditions is over-standard. The contribution value of the maximum hourly ground level concentration of PM10, HCl and dioxin at all sensitive points within the evaluation area are all higher than that under normal conditions but can meet the relevant environmental quality standards. Upon deodorization treatment, the concentration of foul gases at the boundary of factory can meet the standard; in case of accidents such as inspection and repair and furnace shut down, the foul gases discharged after deodorization treatment have little impacts on environment. The final environmental protection distance for this project is 400m from the west boundary, 300m from the east and south boundary and 100m from fly ash stabilizing workshop. Within such protection distance, there are no sensitive objects such as residential area. Meantime, taking the requirements of the width of sanitary protection zone of other neighboring waste disposal projects, the protection distance (800m) arranged for hazardous waste landfill yard can meet the protection distance requirements of both the Qizishan domestic waste landfill site and Everbright domestic waste incineration power plant, and within such area there are no sensitive points such as residential area. In short, the waste gases discharged by this project have little impacts on ambient air and won't cause functional degradation of project site.

8.2 Analysis on the Environmental Impact of Surface Water In this project the organic wastewater is mainly from waste leachate, terrace and vehicle washing water and domestic wastewater. The water discharged from cooling tower, boiler and chemical water treatment will be recycled totally and not be drained to outside. The wastewater leachate of Phase III project, together with the unloading platform and vehicle flushing water, will enter into leachate regulating reservoir, little of which are back into furnace and the remaining enters into the supporting leachate pretreatment station for treatment. The existing treatment process is anaerobic treatment plus SBR plus ultrafiltration membrane process, and this time the

244 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited “nanofiltration plus reverse osmosis” are added to upgrade the standard for advanced treatment, and then the water is used as circulation cooling makeup water after it meets water quality standard while the concentrated water is sprayed to incinerator for incineration. After the measure such as “carry-the-old-with-the-new” of leachate treatment station is completed, the wastewater emissions of this factory will be much lower than it now. After the project is completed, the wastewater emissions of this factory will be 11,988t/a. The wastewater mainly includes domestic wastewater, which will be routed to New District wastewater plant in for treatment. New District wastewater plant is located in the west of the Canal, with an area of 117 mu. Its total wastewater disposal capability is 80,000t/d. Biochemical treatment of three-tank oxidation ditch will be adopted and the wastewater will only be discharged to the Canal after meeting the standard. Predictive evaluation has been conducted for the impact of Phase III project (with the final disposal capability of 80,000t/d) to water environment and the evaluation results are as follows: (1) Under the unfavorable condition that the Canal upstream inflow is 4.2m3/s (90% flow satisfying ratio), the impact distance of wastewater plant is 4,860m down the drain outlet; (2) Under the condition that the Canal upstream inflow is 19.5m3/s (normal inflow, 50% flow satisfying ratio), the impact distance of wastewater plant is 1,470m down the drain outlet; (3) When Xujiang River is of back current, the wastewaters discharged from wastewater plant will back-flow into Xujiang River along the bank side, but the water gate at Xukou will be closed at that time to prevent wastewater from flowing into Taihu Lake. According to the analysis results above, after the project is completed the wastewater centralized-treated by New District wastewater will meet the standard and not cause adverse effects on Taihu Lake.

8.3 Prediction and Assessment of Noise Environmental Impact

8.3.1 Analysis on Noise Source Strength Noise source of the project mainly comes from air feeder, induced draught fan and steam turbine generator unit of the boiler system, air compressor of public works,

245 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited air blower and sump pump of circulating cooling water system and sewage disposal system. See Table 8.3-1 for generating condition of noise sources.

Table 8.3-1 Project Noise Source Condition List The Nearest Noise Level Noise Distance to Management after Noise Major Noise Source Quantity Level Factory Measures Reduction dB (A) Boundary dB (A) (m) Boiler Steam 2 140 S75 Muffler 100 Evacuation Waste Grabbing Noise Insulation of 2 85 S50 75 Crane Building Fan (Induced Add Acoustic Draught, Air 6 95 S55 Chamber and 85 Supply) Muffler Steam Turbine Noise Insulation 2 100 S105 90 Generator Unit Equipment, Muffler 4 (3 in Use Noise Insulation, Air Compressor and 1 in 90 S、E40 80 Add Muffler Preparation) Noise Insulation of Water Pump 4 90 W50 80 Building Cooling Tower 3 85 S55 - 85

8.3.2 Prediction Model of Noise Transmission Adopt prediction model of multi-point source and equidistant noise attenuation, and refer to correct value at the most unfavorable meteorological condition. The noise transmission of cement plant from noise source to noise point, it is affected by many factors including transmission distance, air absorption and reflection of restraining mass, screening, so noise attenuates gradually, forecast the impact to plant area in accordance with HJ2.4-2009 Technical Guidelines for Noise Impact Assessment after the project is carried out. Main calculation formulas applied in the prediction are as follows: Noise level calculation formula of single outdoor point to the prediction point The octave frequency band noise power level of known noise source (from 63Hz to 8KHz 8 octave frequency band of midband frequency of nominal band), octave frequency band noise pressure level Lp(r) of prediction point position can be calculated in accordance with formula (1):

Lp r)(  Lw  Dc  A (1)

A  Adiv  Aatm  Agr  Abar  Amisc In the formula: Lw—Noise Power Level of Octave Frequency Band, Db;

246 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Dc—Directionality Calibration dB; to omnibearing point noise resource exposed to free space, Dc=0dB. A—Attenuation of octave frequency band, dB;

Adiv—Attenuation of octave frequency band caused by geometric divergence, dB;

Aatm—Attenuation of octave frequency band caused by atmospheric absorption, dB;

Agr—Attenuation of octave frequency band caused by ground effect, dB;

Abar—Attenuation of octave frequency band caused by noise barrier, dB;

Amisc—Attenuation of octave frequency band caused by other multi-aspect effects, dB.

If noise pressure level Lp(r0) of octave frequency band which closes to some point of noise source is known, noise pressure level Lp(r0) of octave frequency band of prediction position with the same direction can be calculated in accordance with formula (2):

Lp r)(  Lp (r0 )  A (2)

Noise level of prediction point A LA(r), it can be calculated in accordance with formula (3) through utilize noise pressure level of 8 octave frequency band:

8 pi rL )(1.0[  Li ] LA r)(  10lg{10 } (3) i1 th In the formula: Lpi(r)—prediction point (r), noise pressure level of the i octave frequency band, dB;

Li —Weighting networks A correction of i Octave frequency band, dB. If it can not get octave frequency band power level of noise source or noise pressure level of octave frequency band, and it only can get noise power level A or noise level A of some point, it can make approximate calculation in accordance with formula (4) and (5):

LA r)(  LAw  Dc  A (4) Or

LA r)(  LA (r0 )  A (5) A can chose the octave frequency band which matters noise level A most to calculate, generally, it can chose octave frequency band with center frequency is 500Hz to estimate. Calculation method of noise power level when indoor noise source is equivalent to outdoor noise source

247 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Set noise pressure level which close to the opening (or window) indoor, outdoor is Lp1 and Lp2. If indoor noise field of indoor noise source lies in is diffuse noise field, then outdoor noise pressure level of octave frequency band can be calculated approximately in accordance with formula (6):

Lp2  Lp1  (TL  )6 (6) In the formula: TL—Partition wall (or window) Transmission Loss of Octave Frequency Band, dB. Calculate caused noise pressure level of octave frequency band in accordance with formula (7) when some indoor noise source closes to space enclosing structure: Q 4 L  L 10lg(  ) (7) p1 w 4r 2 R In the formula: Q—Directionality Factor; it generally refers to omnidirectional noise source, when noise source is in the room, Q=1; when it is set at the center of a wall, Q=2; when it is set at the angle of two walls, Q=4; when it is set at angle of three walls, Q=8. R—Room Constant R  S /(1), S is internal surface area of the room, m2;  is average noise absorption coefficient. r—The distance between noise source and some point closes to space enclosing structure, m. Then calculate i octave frequency band noise pressure level caused by all indoor noise sources at space that close to space enclosing structure in accordance with formula (8):

N 1.0 LP1ij L 1iP T)(  10lg(10 ) (8) j1

In the formula: LP1i(T)—noise pressure level superposition of i octave frequency band caused by n indoor noise sources that close to space enclosing structure, dB;

LP1ij—i octave frequency band noise pressure level of indoor noise source j, dB; N—total number of indoor noise sources When the indoor noise field is approximate diffuse noise field, calculate noise pressure level that closes to outdoor space enclosing structure in accordance with formula (9):

L 2iP T)(  L 1iP T)(  (TLi  )6 (9)

In the formula: LP2i (T)—noise pressure level superposition of i octave frequency

248 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited band caused by n outdoor noise sources that close to space enclosing structure, dB;

TLi—i octave frequency band transmission loss of space enclosing structure, dB; Then switch noise pressure level and transmission area of outdoor noise source to equivalent outdoor noise source in accordance with formula (10), and calculate octave frequency band noise power level of equivalent noise source when central position is at acoustic area (S).

LW  LP2 T)( 10lg s (10)

Then calculate A noise level of prediction point in accordance with prediction method of outdoor noise source. Noise Contribution Value Set A noise level caused at prediction point by the ith outdoor noise source is L , Ai work time of the noise source at T period is ti; A noise level caused at prediction point th by the j equivalent outdoor noise source is LAj, work time of the noise source at T period is tj; so the contribution value (Leqg) of project being built to prediction point is :

N M 1 1.0 LAi 1.0 LAj Leqg  10lg[ (ti10  t j10 ]) (11) T i1 j1 In the formula: tj—work time of noise source j at T period, s;

ti—work time of noise source i at T period, s; T—time used to calculate equivalent noise level, s; N—number of outdoor noise sources; M—number of equivalent outdoor noise sources. Calculation of Prediction Value at Prediction Point

1.0 Leqg  1.0 Ldqb Leq 10lg(10 10 ) (12) In the formula: Leqg—equivalent noise level contribution value of construction project noise source at prediction point, dB(A);

Leqb—background value of prediction point, dB(A).

8.3.3 Noise Prediction Results and Assessment Select and use monitoring point of noise current situation as assessment point of noise prediction, use the above prediction models and prediction plant area noise of the project, see Table 8.3-2 for the result.

249 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Table 8.3-2 Acoustic Environmental Quality Impact Prediction Results List Unit: dB (A) Prediction Monitoring Value of Noise Superposition Environment Prediction Point Contribution Current Situation Value Standard Value Value Day Night Day Night Day Night East of the North N1 54.1 43.5 54.5 46.5 65 55 Factory Boundary 43.5 North of the N2 East Factory 56.5 44.5 56.7 46.6 65 55 Boundary 42.4 South of the N3 East Factory 56.0 43.5 56.4 47.6 65 55 Boundary 45.5 East of the South N4 56.1 44.5 56.3 46.5 65 55 Factory Boundary 42.3 West of the South N5 57.5 45.8 57.6 47.1 65 55 Factory Boundary 41.2 South of the West N6 55.0 42.5 55.2 45.0 65 55 Factory Boundary 41.5 North of the West N7 58.0 44.8 58.2 47.4 65 55 Factory Boundary 43.9 West of the North N8 57.1 45.5 57.3 47.5 65 55 Factory Boundary 43.3

We can conclude from Table 8.3-2, boundary noise of the project impacts the superposition of contribution value and background value, plant area (prediction point) noise meet type 3 standard in Emission Standard for Industrial Enterprises Noise at Boundary (GB12348-2008).

8.4 Analysis on the Environmental Impact of Solid Waste After fly ash solidification is completed and it is qualified through leaching inspection, it can be transported to Qizishan waste landfill plant for treatment. Slag from house refuse incineration plant has been used for brick-making, it has been put into practical application, it’s relative reasonable and feasible treating measures, which not only can prevent from environmental pollution, but also can

250 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited reach recycling purpose. Slag in the project will be transported to brick factory for comprehensive use. Other solid waste including water treatment sludge and house refuse is general waste, and they will be incinerated in the incinerator, it is feasible, and with little impact to environment. So solid waste dealing measure in the project is feasible, which is with little impact to environment.

8.5 Analysis on the Environmental Impact of Soil Majority of waste gas generated in project operation period is burn flue gas, with trace heavy metal, dioxin, which may sedimentate at surrounding soil surface. Heavy metal accumulates in the soil, and leads to physicochemical properties of the soil changed, and the fertility drops, and it may also enter the food chain, and impact human heath. Dioxin type organics sedimentate in the soil, if it is exposed in the sun, it will resolve in several days; but if it is embedded in the soil, its half-life period will be over 10 years, which may pollute the soil. The project is equipped with flue gas disposal system, which takes strict managing measures to flue gas burning, it can reduce heavy metal dioxin’s impact to the soil to minimum, and it will guarantee soil environment quality is free of deterioration. Set many layers of impervious material at waste repository and bottom and side wall of the drainage pool to prevent from polluting the soil. Contrast before and after construction of project phase II, key pollution factors in the soil monitored in 2011 and 2007, the results showed a little change, which indicates the existing project has relative little contribution to the soil environment. Therefore, the project has little impact on the soil after adopting reasonable and effective pollution control and precautionary measures.

8.6 Analysis on the Environmental Impact of Ground Water

8.6.1 Prediction Range According to Technical Guidelines For Environmental Impact Assessment- Ground Water (HJ610-2011), the prediction range is 6km circular area centered as the project.

251 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

8.6.2 Prediction Factors It has determined prediction factor is Fluoride under normal emission condition in accordance with project waste water emission features and ground water monitoring material. Under abnormal condition, take leakage of drainage pool into major consideration, prediction factor is COD.

8.6.3 Prediction Model for Normal Emission According to requirements in Guidelines for Environmental Impact Assessment, prediction model will adopt partial least-squares regression statistical model, to Prediction the project water drainage’s impact range and degree on ground water quality. Standardize dependent variable vector and independent variable matrix and mark as F0, E0. Key shortcut calculation procedures of one variable partial least square regression are as follows: EF' w  h10 h ' EFh10

th E h1 w h ' Ethh1 ph  2 th

Eh E h1 t h p' h

In the formula: th is the hth principal component, w h is the corresponding th principal axis to h principal components; ph is the coefficient when use the h principal component conduct least squares regression to independent variable residual matrix, Eh is independent variable residual matrix. Calculate quadratic sum of prediction error: n 2 PRESShi() y y()i i1

In the formula, y()i is to get rid of the ith sample and use the rest n-1 samples to construct regression model, the prediction value of the ith sample point through calculation. Every time draw a main component, it should reject some sample one by one to calculate PRESSh . Quadratic sum of all prediction error: n 2 SShi() y yi i1 th yi is dependent variable prediction value of the i sample point through

252 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited constructing regression model by all the samples. According to effectiveness criterion:

Qh1  PRESS h / SS h1  0.0975, to judge whether to draw h main components, if meeting effectiveness criterion, then continue to draw main components, conduct regression of F0 and m main components according to m extracted main components t1, t2,…,tm, then:

F0 rt 1 1  r 2 t 2 ...  rmm t Then get the regression equation of original dependent variable and independent variable through the above formula. (1) Fluoride Partial Least-squares Regression Equation According to relevant analysis results of rainfall –Fluoride concentration, the factors impact –Fluoride concentration includes: pt , pt1 , pt2 , Qt1 , where t, t-1, t-2 indicates the tth, t-1th and t-2th year respectively, p , Q indicates annual rainfall and concentration respectively. Adopt partial least-squares regression and combine stepwise regression to determine the number of variable, the after designed model is as follows:

8.6.4 Prediction Model of Abnormal Emission In consideration of drainage pool leakage trouble of the project, waste water leakage time is calculated as 30 minutes, COD concentration in drainage liquid is about 41,000mg/L, then actual leaked pollutants is COD for 854.17kg. According to requirements in Guidelines for Environmental Impact Assessment, as leaking time is relatively short, suppose inject instantly during leaking, take no account of attenuation, prediction model will adopt porous media, one-dimensional injecting hydrodynamic dispersion equation, prediction the project’s maximum impact degree to ground water environment quality of downstream sensitive point under abnormal emission condition. The area the construction project lies in is approximate average isotropy, which takes x=0 as indefinite long straight boundary, then along x positive direction, there is well-distributed one dimensional flow. The mathematic model is: CCC 2  DUC     x   t  0 tL  x2  x

Cx,tt =0  m () x

253 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Cx,tx  0 t  0 Get solution through Fourier transformation:

()x ut 2 mw/  C(,) x t  e 4DtL 2n DL t Where: x -Distance to injecting point, m; t-Time, d; C(,) x t- Pollutants concentration at x point at t time, mg/L; m-Injected tracer quality, kg; w-Sectional area, m2; u-Water velocity, m/d; n-Effective porosity, dimensionless; 2 DL-Longitudinal dispersion coefficient, m /d;

8.6.5 Prediction Result Impact Analysis According to rainfall statistical material of Suzhou in many years, in the year with the least rainfall, according to prediction regression equation, in the project area, average concentration of Fluoride is 0.75/mg. Under normal water drainage situation of the project, when the rainfall reaches the least amount in the past years, Fluoride concentration in ground water quality of the project area can reach III type water quality standard in ground water environmental quality standards Table 1. Under abnormal working situation, the project has the least impact on ground water quality in the well at the nearest 1,200m at downstream-Qizi Lot, Gusu village. The maximum impact is: COD concentration has increased 0.55mg/L, obviously, drainage liquid has little impact on well water quality at downstream 1,200m point in assessment range, COD in the ground water quality still can reach III type water quality standard in ground water environmental quality standards Table 1. The project has prepared impermeable measures at leakage could happen area, especially waste repository and drainage liquid pool. Therefore, it has the least impact on water in plant area. At the same time, through the contrast of monitored ground water before and after the project construction (in 2011 and 2007), pollution factors have a little change, which indicates the existing project has relatively little contribution to ground water environment, thus, the project has little impact on ground water after adopting reasonable and effective pollution control and risk prevention measures.

254 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 8.7 Analysis on the Environmental Impact during Waste Transportation After the project is completed, total waste transportation amount is 1,500t/d, waste transportation amount is calculated as 5t load truck (dust cart), there are 200 trucks entering the area for transporting waste every day. Waste transportation route of the project is consistent with the existing transportation route. Transport frequency of the trucks has certain increase, so the enterprise shall pay attention to its impact on surrounding sensitive points on transport routeline. Transportation will adopt airtight vehicle, it will slow down when passing populated area and bridge, no honking, waste transportation will have little impact on routeline environment after adopting the above measures.

255 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 9 Analysis on Environmental Impact During Construction Period

Works to be completed at the plant area during the construction period of this project includes: Civil works, utilities, auxiliary works, process equipment installation, electrical, telecommunication, instrument installation works and other supporting works. It is estimated that the overall construction period of the plant will be 18 months. It is inevitable that waste water, waste gas, noise and solid waste, etc. will be generated due to construction activities during the construction period. The construction period is characterized with periodicity, temporality and instability, which will exert some environmental impact on the circumstances with the construction noise and dust as the most.

9.1 Noise Environmental Impact Assessment and Control Measures During Construction Period

9.1.1 Main Noise Sources Noise is the main pollutant during the construction period, mainly from noises generated from civil construction machinery such as pile driver, bulldozer, mixer, transportation vehicles, etc. Noise strength is generally 75~105dB (A). Table 9.1-1 shows the main construction equipment and noise value of the project. During the actual construction process, generally many equipment works together and all kinds of noise radiation overlay, so the noise level will be higher and the radiation impact range will be greater. Table 9.1-1 Construction Machinery Noise Source Intensity Average Sound Level A at S/N Equipment Name Quantity (set) 5m Distance Unit: dB (A) 1 Pile Driver 2~3 94 2 Concrete Mixer 3~5 82 3 Bulldozer 2~3 77 4 Excavator 3~5 84 5 Crane 5~6 85 6 Electric Welder 10~20 90 7 Automobile 5-8 90

256 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Average Sound Level A at S/N Equipment Name Quantity (set) 5m Distance Unit: dB (A) Electric Saw - 100 Loader 2~3 89

9.1.2 Noise Assessment Standard Noise environment impact assessment of construction activities is conducted in accordance with Noise Limits for Construction Site (GB 12523-90), see Table 9.1-2. Table 9.1-2 Noise Limits for Construction Site Construction Noise Limit LeqdB(A) Main Noise Source Stage Daytime Nighttime Earthwork Bulldozer, Excavator, Loader, etc. 75 55 Construction Piling All kinds of pile drivers, etc. 85 Prohibited Concrete Mixer, Vibrating Rod, Structure 70 55 Electric Saw, etc. Crane, Decoration 65 55 Elevator, etc.

9.1.3 Noise Impact Analysis A. Forecast Content Forecast noise values of construction site at different construction stages. B. Forecast Method Use point noise source attenuation along with distance mode to calculate the impact of single equipment noise on the forecast spots to forecast the impact of many equipment noise on site by overlaying. C. Forecast Mode Noise Source Attenuation along with Distance Mode:

L(r)=L(r0)-20log(r/r0)- L

Where, L(r) ——the noise level dB(A) generated△ by the point source at the forecast point

L (r0)——Known noise level dB(A) at the reference position r0. L——Attenuation value caused by various factors D. Forecast Result △ Without considering any sound barrier, see Table 8.1-3 for single equipment noise source attenuation value along with distance. The construction equipment noise limit at daytime is within 100m, and if such high noise equipment as pile driver, electric welder, and crane are not used at nighttime, the standard will be met. So,

257 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited piling is forbidden at nighttime. Traffic Noise Impact Analysis during the Construction Period The in-and-out of earthwork and construction materials during the construction period will make the traffic flow in some places much greater. It is estimated that the transportation vehicles will increase to 50 shift/day. All the vehicles are high-tonnage trucks which sound level is above 85dB (A). For the transportation is discontinuous which doesn’t contribute much to the traffic noise. But in order to avoid the residents and private and public institutions on both sides from being impacted, the transportation of construction materials is prohibited during 22:00~6:00 at nighttime to avoid the increase of night traffic noise level. Meanwhile the peak hour shall also be avoided to prevent traffic jam.

Table 9.1-3 Single Equipment Noise Source Attenuation Value Along with Distance Unit: dB (A) Equipment 5m 10 m 20 m 30 m 50 m 80 m 100 m 150 m 200 m Name Pile Driver 94 88.0 82.0 78.4 74.0 69.9 68.0 64.5 62.0 Concrete Mixer 82 76.0 70.0 66.4 62.0 57.9 56.0 52.5 50.0 Bulldozer 77 71.0 65.0 61.4 57.0 52.9 51.0 47.5 45.0 Excavator 84 78.0 72.0 68.4 64.0 59.9 58.0 54.5 52.0 Crane 85 79.0 73.0 69.4 65.0 60.9 59.0 55.5 53.0 Electric Welder 90 84.0 78.0 74.4 70.0 65.9 64.0 60.5 58.0

9.1.4 Noise Control Measures To reduce the impact of construction noise on the circumstance, the following noise pollution control measures are suggested during construction: 1 Enhance construction management, reasonably arrange construction time and strictly follow relevant regulations on construction noise management to prohibit high noise construction at nighttime; 2 Use low noise construction equipment as far as possible. For example, replace pneumatic tools with hydraulic ones, and try our best to use the construction method that causes low noise at the same time. 3 Set necessary sound-proof wall around high noise equipment or construction boundary to lower the external radiation of noise. 4 All preparations shall be ready, minimize the operation time of mixer before continuous concrete casting.

258 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

9.2 Waste Water Environmental Impact Assessment and Control Measures During Construction Period Main sources of waste water during the construction period are flushing water of construction materials, concrete curing drainage, equipment hydraulic testing water and domestic waste water of construction workers. It is estimated that the waste water generated by construction and production is 20t/d, and main pollutant is SS, and the petroleum materials leaked from construction machinery. Domestic waste water is about 5-8t/d, main components are COD, ammonia nitrogen, TP, SS, etc. Additionally, there are also other pollutants such as coliform, grease and surfactant. Control measures: 1 The flushing water of sandstones, concrete curing water, equipment hydraulic testing water and flushing water of equipment and vehicles shall be led to the pre-set settling pond and recycled after being settled, no external drainage is allowed. 2 The construction company shall enhance sewage treatment, especially toilet sewage shall be discharged into the cesspool, and then put in the sewage pipe network and random discharge is prohibited. 3 Enhance the management of fuel oil, engine oil and lubricant, etc. used by various kinds of vehicles and equipment. All waste oil shall be concentrated and collected for treatment. Random pouring and discharge into nearby rivers is prohibited. 4 Enhance the maintenance of construction machinery to avoid oil leakage from construction machinery.

9.3 Waste Gas Environmental Impact Assessment and Control Measures During Construction Period Main waste gas during the construction period is dust and construction waste gas on the construction site. The construction waste gas mainly comes from mixing, the off-gas discharged by the freight cars entering and leaving the site, waste gas from the temporary canteen for the construction team and the waste gas from the driving equipment of construction machinery (such as diesel engine, etc.). The ground will be excavated during the construction process, so dust is

259 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited inevitable and brings some bad impact on the environment. The main source of dust is the followings: Mechanic excavation, waste soil stack, transportation, concrete mixing and surface exposure. Analogy survey shows that, the severest dust comes from transportation, loading and unloading of the construction materials and concrete mixing, and the range of its impact is within 200m of the construction site, and the area 100m downwind is impacted the most by dust. Then the dust generated by the earthstone work in dry and gale weather. After some protection measures are taken, the impact range of the construction dust will generally be 50m outside the plant, so the area within this range will be impacted apparently, so the impacts of construction dust on nearby Songchao Village is very small. The following measures must be taken to lower the impact of dust and construction waste gas on the environment: 1 The trucks shall be intact and without overload, and covering and sealing measures shall be taken to avoid materials from leakage; 2 The construction waste and domestic waste shall be cleaned up timely and the site shall be leveled in time. Water shall be sprinkled when the work level is dry to prevent secondary dust; 3 The construction site must be enclosed; 4 The temporary piling area must be covered; 5 Earthwork excavation and backfilling, etc. is prohibited in gale weather. The solid waste environment impact assessment during the construction period and control measures: The solid wastes during the construction period are domestic garbage and construction garbage, the treatment measures are as follows: 1 The domestic garbage generated during the construction period will be disposed in a unified manner by local environment and health departments, and will be cleaned out of the site timely; 2 The metal dogs, timber and construction material scraps and waste concrete, etc. generated during the construction period shall be collected and treated by special staff and cars.

260 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 9.4 Ecological Environmental Impact Assessment and Control Measures during Construction Period The planned plant site neither belongs to river source, drinking water protection zone, natural protection zone, scenic spot, tourist resort; nor belong to cultural relic protection zone or important resource abundant areas designated by the state, province (autonomous region), and municipality directly under the Central Government. The expanded project is located in the valley plain formed by the northward stretch of 3#, 4# col of Qizishan. The newly-required land is mainly the valley plain in front of Qizishan, which is mainly covered by a few bushes and weeds. There is no agricultural production and husbandry within 500m range of the project. Therefore, the ecological impact of this project construction is very small. But for that Qizishan is in the south of the project, it is suggested that the company do water and soil conservation well during the construction period. As stated above, the noise, waste gas, waste water and solid waste generated during the construction period will exert some impact on the environment. But if the construction company seriously makes the organization (including workforce, schedule plan and construction level management, etc.), and conduct housekeeping, enhance the ecological protection near the plant area and abide by the suggestions on environmental protection above, the project construction period will exert no impact on the environment.

261 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

10 Risk Assessment

10.1 Overview The environmental risk is a kind of serious pollution incident spread by environmental medium, and caused by spontaneous causes or human activities which is highly uncertain. The environmental risk assessment is to analyze hidden environmental risk incidents, the probability and consequence of the incidents, so as to determine corresponding safety measures. This is a waste Waste-to-Energy Project; domestic waste is not dangerous waste, so the possibility of malignant environmental incidents during storage and transportation is low. But harmful smoke will be generated during waste incineration, so there is certain potential environmental risk in incident discharge. In accordance with the requirements of No. 82 HF (2006) Notice on Risk Assessment on Major Environmental Accident Hidden Danger, Circular of Enhancing Environment Impact Assessment Management and Preventing Environmental Risk, Notice on Enhancing Environment Impact Assessment of Biomass-to-Energy Projects and Technical Guidelines for Environmental Risk Assessment on Projects (TJ/T169-2004), environmental accident risk assessment shall be conducted on this project to come up with necessary control measures to realize the goal of lowering the risk and extent of risk and protecting the environment.

10.2 Risk Identification

10.2.1 Material Risk Identification In accordance with addendum a of the Technical Guidelines for Environmental Risk Assessment on Construction Projects, see Table 10.2-1 for the determination standard of the material danger Table 10.2-1 Identification Standards for Material Danger LD50 (Rat LD50 (Rat through LC50 (Mouse through Material Classification through mouth), skin), mg/kg inhalation for 4 h), mg/L mg/kg

262 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited LD50 (Rat LD50 (Rat through LC50 (Mouse through Material Classification through mouth), skin), mg/kg inhalation for 4 h), mg/L mg/kg Extremely toxic <5 <10 <0.1 material Extremely Toxic 5

Based on the analysis of raw material used and pollutants generated, the relevant pollutants are HCl, CO, NH3, H2S and light diesel. Analyze in accordance with Materials Risk Characteristics Table (see Table 10.2-2).

Table 10.2-2 Identification of Major Materials Risks of This Project

Poison, Flammable, Flammable, Explosive Poisonous material determination standard No. 3, general poison in Table 1 addendum of Technical Guidelines for Environmental Risk Assessment on Projects HCl (HJ/T169-2004). Not the poison in List of Toxic Chemicals (2002). Categories 8.1, in List of Dangerous Chemical acid corrosive, S/N 81013. If mixed with the air, an explosive will be formed, if met with open light and highly heated it will flame and explode. Explosion limit (v%):12.5-74.2, LC50: 1807ppm 4 h (rat inhale). CO Flammable material determination standard No. 1 in Table 1 addendum A of Technical Guidelines for Environmental Risk Assessment on Projects (HJ/T169-2004). Categories 2.1, in List of Dangerous Chemical acid corrosive, S/N 21005. Not the poison in List of Toxic Chemicals (2002). Poisonous material determination standard No. 3, general poison in Table 1 addendum A of Technical Guidelines for Environmental Risk Assessment on NH3 Projects (HJ/T169-2004). If mixed with the air, an explosive will be formed, if met with open light and highly heated it will flame and explode. Not the poison in List of Toxic Chemicals (2002). If mixed with the air, an explosive will be formed, if met with open light and H2S highly heated it will flame and explode. LC50: 1807ppm 4 h (rat inhale). Not the poison in List of Toxic Chemicals (2002). Diesel is the mixture of all groups of hydrocarbons with C16~C23 boiling range of Light Diesel 200~380℃, its volatility is smaller than gasoline, density (20℃) 0.80~0.85, flash

263 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

point 45~55 , explosion limit 1.5~4.5%, fire risk Class-2B. Flammable material determination standard No. 3 in Table 1 addendum A of Technical Guidelines for Environmental℃ Risk Assessment on Projects (HJ/T169-2004).

10.2.2 Identification of Major Risk Sources Main risk sources are at the environmental treatment devices lot, select light diesel, HCl, CO, NH3 and H2S as discerning factors, see the standards in Table 1 addendum A of Technical Guidelines for Environmental Risk Assessment on Projects (HJ/T169-2004), GB18218-2000 Major Risk Identification, see Table 10.2-3 for the specific result of major risk identification of this project. As shown in Table 10.2-3, there is no major risk source in this project.

Table 10.2-3 Identification of Major Material Risks of This Project Production Site Storage Site Result of Material Threshold Utilization Threshold Major Risk Utilization/Generation/Existence Classification Quantity /Generation/Existence Quantity Source Quantity (T) Quantity (T) Identification Generation Quantity 21.08 Non-major HCl 20 No 50 Kg/H, Treated Immediately. Risk Source Generation Quantity 8.45 Kg/H, Non-major CO 2 No 5 Treated Immediately. Risk Source Generation Quantity 0.68 Kg/H, Non-major NH 40 No 100 3 Treated Immediately. Risk Source Generation Quantity 0.012 Non-major H S 2 No 5 2 Kg/H, Treated Immediately. Risk Source Non-major Light Diesel Maximum Storage 25T N 30 NO Risk Source

10.2.3 Identification of Possible Hazards During Production The major environmental risks in project incineration operation are: (1) Abnormal burning, the temperature of the smoke excessively high, the bag is damaged, so that dust removal is compromised; (2) Flue gas cleaning treatment control malfunction or lime, activated charcoal injection malfunction, causing excessive discharge of pollutants; (3) Accumulation of flying dust in the deduster, explode when met with fire source, or the activated charcoal quality fails to meet the standard, leading to excessive discharge of such material as dioxin group; (4) For the problems of structure, anti-leakage, the leachate leaks and pollutes nearby underground water; (5) Improper gas exhaust, resulting in higher pressure in the furnace;

264 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited (6) Improper management on the coal site leads to fire etc. accident when met with fire source; (7) Leachate accident discharge when maintenance or furnace stops; (8) Odor accident discharge when maintenance or furnace stops.

10.3 Assessment Grade Determination and Assessment Range

10.3.1 Assessment Grade In accordance with the probability of risk accident in foreign countries in incinerator operation, its severity, consequence of influence on human and environment, we come up with an accident risk grade 4 and risk grade, see Table 10.3-1.

Table 10.3-1 Accident Risk Probability and Grade Category Accident Severity and Accident Risk Rating L M H C Accident Severity Low Medium High Catastrophic First Serious Serious aid of injury injury Consequence of Influence on Human Many death minor reversible reversible injury some death minor Serious Irreversible reversible reversible injury Injury injury injury (10-year) Consequence of Influence on Environment on site To places To places To places outside the outside the outside the site site site Frequency Probability Possibility Accident Risk Grade time/year grade Once a year at > 10-1 the maximum 1 3 2 1 1 possibility About Once every 100 10-3 to 10-1 2 3 3 2 1 years Probabilit y of 10,000 accidents Low Possibility 10-5 to 10-3 3 3 3 3 2 once 10,000 years Lowest Possibility 10-5 once 4 3 3 3 3 1,000,000 years

265 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Accident Risk Grade: 1 represents unacceptable, 2 represents medium, and 3 represents acceptable. In accordance with the comparative operation of incineration power plants in France and Japan, generally the residual risk probability is about grade 3-4 after prevention measures are taken, the residual risk probability is mainly grade 3, 2 is rare. See Table 10.3-2 for environmental risk grade analysis of this project.

Table 10.3-2 Project Environmental Risk Grade Analysis Residual Consequence of Potential S/N Type of accident Prevention measure accident risk grade risk grade 1 Abnormal burning, flue The bag is damaged, Smoke temperature gas temperature is too and deduct 2 control, Contingency 3 high influenced sprinkling 2 Flue gas cleaning Stop feeding, treatment control Excessive discharge incinerator enters malfunction or lime, of pollutants 1 closure process 3 activated charcoal injection malfunction 3 Accumulation of flying Clean the dust timely, dust in the deduster, Excessive discharge metal equipment explode when met with of such material as 2 grounding, inject N2 if 3 fire source, or the dioxin group. needed activated charcoal quality fails to meet the standard 4 For the problems of Nearby Underground water structure, anti-leakage, the underground water quality control, leachate leaks polluted 2 incineration furnace 3 stops 5 Improper gas System exhaust exhaust, higher Stop feeding malfunction pressure in the 2 automatically 3 furnace

In accordance with Technical Guidelines for Environmental Risk Assessment on Projects and poison degree of risk material, major risk source and local condition of environmentally sensitive place to conduct material evaluation classification work. There is no major risk source in this project, but due to the fact that the poison of the risk material is relatively high and that the surrounding place is environmentally sensitive, we determine the risk grade of this project as grade II.

10.3.2 Assessment Range In accordance with Technical Guidelines for Environmental Risk Assessment on Projects (HJ/T169-2004), based on the harm threshold and position of sensitive zone, determine the impact range of hazardous chemicals and specify the atmospheric

266 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited environmental assessment Grade 2 range which shall be at least 3km from the source point. Main environmental protection goals within this project assessment see Table 10.3-3 and Fig. 1.7-1.

Table 10.3-3 Main Environmental Protection Goals within the Range of Risk Assessment Environmental Environmental Distance Environmental Protection Direction Scale Remarks Factor (m) Function Object Name Mudu Town 200,000 WNW 2,600-6,300 (ancient area) Persons Former Gusu 3,600 W 2,000 Village Households Qizi Lot,Gusu 20 N 1,200 Village Households Now Fenghuang 3,100 Unified Lot, Gusu SW 1,650 Air Households GB3095-1996 as Gusu Village Environment Medium II Village Suzhou University of 7,500 E 2,300 Science and Persons Technology Renji Nursing N 1,100 20 Beds Home Shangfangshan SE 1,600 5.002km2 Forest Park GB3838-2002 Xujiang River N 1,500 — Medium III Surface Water Jiangnan NE 5,000 Class IV Canal —

10.4 Analysis on Sources

10.4.1 Analysis on Accident Sources Through analysis, the main accident sources are as follows: (1) The impact on the circumstances when incinerator and its accessory semi-dry flue gas treatment device do not reach the normal treatment efficiency. (2) The impact on the circumstances when incinerator starts (heats up) and stops (flames out) or due to management or personal factors such as the incinerator temperature is not high enough and the discharge of dioxin is abnormal. (3) The impact on the circumstances when the furnace shuts down or during maintenance when the stink prevention measures don’t work, resulting in discharge of

267 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited stink materials. (4) The impact of leachate leakage on the circumstances. (5) The impact on the circumstances when the amount of CO in incinerator is excessive thus leading to explosion. (6) The impact of the fire and explosion risk when light diesel leakage on the circumstances.

10.4.2 Maximum Credible Accident The analysis of accident risk identification and accident factors show that, main project environmental risks lie in accident discharge of flue gas treatment system and leachate leakage. When incinerator’s accessory semi-dry flue gas treatment device doesn’t reach the normal treatment efficiency, resulting in the waste gas that doesn’t meet the standard will go into the atmosphere, polluting the surrounding air which will heavily impact the environment. Leachate leakage will cause underground water environmental pollution or surface water pollution. Once there is an accident, it will severely impact environmental quality, life and asset. Therefore, in accordance with project material identification, major risk source identification, potential risk identification during production, the cause of accidents, the severity of accident consequence, the maximum credible accident of the project is: ◆Accident discharge of flue gas treatment system ◆Underground water pollution results from leachate leakage. Based on the results of maximum credible accident, see Table 9.4-1 for accident source intensity.

Table 10.4-1 Accident Source Intensity and Probability Table Position of Leakage Accident Occurrence Accident Setting Accident Source No. Probability Treatment Flue Gas Suppose that accident discharge time is 1 Measure Treatment Accident 1 6.8×10-4/a hour, the time from accident discharge System doesn’t begins to feeding and incinerator stops Work Garbage geomembranes of the garbage Garbage Leachate Accident 2 1×10-4/a storage pit ruptures, resulting in leachate Storage Pit Leakage leakage and underground and soil pollution.

10.5 Analysis on Accident Consequences

268 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 10.5.1 Forecast and Calculation of Atmospheric Accident under Abnormal Working Conditions The following things of planned project environmental risks under abnormal working conditions shall be taken into consideration: one is the waste gas discharge when incinerator and its accessory semi-dry flue gas treatment device don’t reach the normal treatment efficiency; two is dioxin accident discharge when the operation of incinerator is not stable; when incinerator stops for maintenance, odor accident discharges. See 8.1 for relevant forecast and evaluation. When we take a conservative consideration, dioxin material’s impact on human body is analyzed as follows: In accordance with the (Environment Development No. 82[2008]) Circular on Further Strengthening Environment Impact Assessment Management of

Biomass Waste-to-Energy Projects, dioxin accident risk assessment takes 4TEQpg/kg of daily human resistible intake as reference, and the allowable amount into human body take 10% daily resistible intake. Suppose that the average weight of every healthy adult is 60kg, the allowable inhale limit of everybody is 1TEQpg/person·h. Data shows that, generally average inhale of the average person is 0.0042m3, hourly average inhale 0.252 m3. After calculation, the dioxin concentration limit into human body through breath is 3.97TEQpg/m3. Under project abnormal working conditions, after the maximum hourly concentration caused by regular waste gas discharge overlying with local ones, it still meets corresponding environmental quality standard requirements. Under abnormal working conditions, the maximum hourly ground concentration value of sensitive points in the evaluation range are all higher than normal working conditions, but when overlaid with this bottom it still meets corresponding environmental quality standard, and continuous abnormal working time is no more than 1 hour. Therefore, analyzing from the aspect of human health, dioxin under accident conditions is acceptable.

269 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 10.5.2 Odor Pollutant Accident Discharge Caused by Malfunction of Odor Pollutant Control Measures and the Impact on Ambient Environment The causes of malfunction of odor pollutant control measure are: the incinerator stops, primary air fan stops air suction from the garbage pool, the probability of the occurrence at most once a year or twice a year, lasting for 2-4 days. When the boiler accident stops or maintenance, the garbage storage pit should be sealed, if the waste is to be discharged, it must undergo deodorization treatment, change the gas 1~1.5 times per hour, the waste gas will be sucked to the activated charcoal waste gas cleaning and deodorization device via the air suction hole on the upper side of the garbage storage pit. The activated charcoal waste gas purifier has the following sections: air inlet section, filter section, air outlet section, after the waste gas comes into through the air inlet it will be filtered by the activated charcoal in the filtering section, the majority of the odor is absorbed by activated charcoal grains, then discharged into the atmosphere by the exhaust fan. What’s more, by enhancing spraying deodorization, we can lower the amount of odor to the greatest extent. The odor pollutant amount is relatively small under accident state, which exerts little impact on circumstance.

10.5.3 Impact of Leachate on Underground Water The project impacts the residents’ wells drinking water of the nearest Gusu village Qizi lot 1200m away under abnormal working conditions is relatively small, its greatest impact is that the COD concentration increases by 0.55mg/L, so we can see that under abnormal working conditions, impact of leachate on the residents’ wells drinking water of 1,200m away downstream is not obvious, and its underground water quality can still meet III water quality in Table 1 of Quality Standard for Underground Water. This project has done the anti-leakage at where leakage is possible, especially the storage and leachate pool. So, its impact on the underground water in the parameter of the factory lot is small.

270 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 10.5.4 Analysis on Explosion Accident Caused by Excessive Amount of CO in Incinerator and the Impact on Ambient Environment Under normal conditions, the CO generation concentration is 100mg/m3, and its volume ration is 8.0×10-5, far lower than CO explosion limit (v%)12.5-74.2, so under normal conditions, it is free of explosion accident. The probability of explosion accident caused by excessive amount of CO is also very low, no relevant report to date. The causes of excessive amount of CO are: the wind supply of the air fan (primary, overfire air fan) is insufficient, thus large amount of CO is generated at the same time the air supply of the sir fan doesn’t increase dramatically, and large amount of CO is accumulated in hearth and waste heat boiler. But to this project the probability of this is low, and it won’t last for a long period, no more than 1 hour. The CO concentration generated at this time is 493mg/m3 with the volume ratio 3.9×10-6, far lower than CO explosion limit (v%)12.5-74.2, the probability of explosion is quite low. Should there be an explosion, such pollutants as HCl would be leaked to the circumstances and severely impact it.

10.5.5 Risk of Fire and Explosion Caused by Diesel Leakage The most probable accident is that the stored oil leaks and causes fire and explosion. After the tank fire breaks out, the radiant heat by oil burning will impact the nearby oil tank and the buildings, even cause a new fire. This is destructive to the circumstances. In accordance with the analysis of the main risk factors and harmful factors, we will use US DOW Chemical Company (DOW)’s Fire, Explosion Risk Assessment (the 7th edition) to conduct the fire, explosion risk assessment of this project. We use the relevant index calculation sheet and safety compensation index calculation sheet of each unit in US DOW Chemical Company (DOW)’s Fire, Explosion Risk Assessment. The result of risk grade is listed in the following Table 10.5-5, as a control of US DOW Chemical Company (DOW)’s Fire, Explosion Risk Assessment (Table 10.5-4). As we can see from Table 10.5-5, after safety compensation, the risk grade of each unit all lower by a grade, the fire, explosion risk of oil tank in this project is lower, which is in the acceptable range. Based on the calculated fire and explosion index, we can get the exposure radius by referring to the drawings or by calculation. See Table 10.5-6 for the calculated

271 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited exposure radius and exposure territory area of each unit.

Table 10.5-2 Fire and Explosion Indexes (F&EI) Calculation Table Item Oil Storage of the Project Selected Typical Material Light Diesel Material Factor MF 10 1. General Process Risk Range of Risk Index Basic Factor 1.00 1.00 A Exothermic Reaction 0.3-1.25 B Endothermic Reaction 0.2-0.40 C Treatment and Conveyance of 0.85 0.25-1.05 Material D Enclosed or Indoor Process 0.25-0.90 Unit E Channel 0.20-0.35 F Discharge and Leakage Control 0.25-0.50 0.5 General Process Risk Coefficient 2.35

(FI) 2. Special Operation Risk Basic Factor 1.00 1.00 A Toxic Material 0.20-0.80 B. Negative 0.50 Pressure(<500mmHg) C Operation within and around

the Burning (a) Tanked Flammable Liquid 0.50 0.50 (b) Process Malfunction or 0.30 Sweeping Failure (c) Always within the Range of 0.80 Burning D Dust Explosion 0.25-2.00 E Pressure (Refer to drawings) F Low Temperature 0.20-0.30 G Quantity of Flammable and 1.08

Instable Material (a) Liquid and Gas in the Process (b) Liquid and Gas in Storage

(Refer to drawings) (c) Flammable Solid in Storage

and Dust in the Process H Corrosion and Abrasion 0.10-0.75 0.20 I Leakage(Joints and Sealing) 0.10-1.50 0.10 J The Equipment Using Open

Fire K Hot Oil Heat Exchange System 0.15-1.15 L Rotating Equipment 0.5 (F2) Special Process Risk Factor 2.88

272 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

(F2) Process Unit Risk Factor (F3=F1×F2) 6.77 (F&EI=F3×MF) Fire, Explosion Index (F&EI=F3×MF) 67.7

Table 10.5-3 Safety Measure Compensation Indexes Calculation Table

Range of Compensation Item Oil Storage of the Project Index 1. Process Control Safety Compensation Index (CI) Contingency Power Source 0.98 0.98 Cooling Device 0.97-0.99 0.99 Anti-explosion Device 0.84-0.98 Contingency Cutting Device 0.96-0.99 0.98 Computer Control 0.93-0.99 Inert Gases Protection 0.94-0.96 Operation Guideline/Procedures 0.91-0.99 0.92 Chemical Activated Material Check 0.91-0.98 Other Process Risk Analysis 0.91-0.98 C1(The Product of Index - ) 0.87 2. Material Isolation Safety Compensation Index (C2) Long-distance Control Cutting Valve 0.96-0.98 0.98 Spare Blowdown Device 0.96-0.98 Discharge System 0.91-0.97 Interlock Device 0.98 C2(The Product of Index - ) 0.98 3. Fire Prevention Facilities Safety Compensation Index (C3) Leakage Check Device 0.94-0.98 0.98 Steel Structure 0.95-0.98 0.98 Firefighting Water Supplying System 0.94-0.97 0.97 Special Fire-fighting System 0.91 Sprinkler System 0.74-0.97 0.89 Water Curtain 0.97-0.98 Foam Extinguisher 0.92-0.97 0.94 Portable Fire Extinguisher/Water Gun 0.93-0.98 Cable Protection 0.94-0.98 0.94 C3 (The product of index - ) 0.73 Safety Measures Compensation C=C1×C2×C3=0.63 0.64 The Fire Risk Index after Compensation 43.3

Table 10.5-4 Fire Explosion Index and Risk Grade Table Range of Fire Explosion Index Risk Grade 1~60 Lowest 61~96 Low

273 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

91~127 Medium 128~158 Likely >159 Probable

Table 10.5-5 Risk Grade Comparison Before and After Safety Measure Compensation Table Before Compensation After Compensation Assessment Unit F&EI Risk Grade F&EI Risk Grade Oil Storage of the 61.5 Lower 36.9 Lowest Project

Table 10.5-6 Oil Storage Exposure Radius and Territory Area of the Project Item Oil Storage of the Project Fire Explosion Index 61.5 Exposure Radius (m) 15.2 Exposure Area (m2) 838

10.6 Risk Control Measures for Current Project

10.6.1 Countermeasures for Incinerator Waste Gas Treatment System Pollution Accident Discharge Risk Special staff will be in charge of daily environmental management, to set up the system of “Environmental Management Staff Responsibility” and “Environmental Accident Control Measures” to enhance supervision and management of incinerator waste gas treatment system. Enhance the periodical check and maintenance of waste gas treatment system, if any potential accident spotted, resolve it in no time. Install flue gas online monitor to monitor the waste gas control effect online. Import the waste gas treatment equipment and devices those are technically advanced and effective to ensure that the discharged pollutants meet the standards. When the incinerator starts, preheat the bag deduster with electricity. When the temperature reaches the requirement, start the incinerator and bag deduster at the same time.

10.6.2 Control Measures for Explosion Accidents Caused by Excessive Amount of CO in Incinerator In order to avoid explosion accidents caused by excessive amount of CO in incinerator, the following control, buffer and Contingency measures shall be taken, (1)

274 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Monitor the amount of O2 in the incinerator to see the incomplete burning, to timely adjust the burning to ensure the complete burning of the garbage; (2)interlock the draft fan and ventilator, once the draft fan stops for malfunction, the ventilator must also be shut down, the incinerator shuts down at the same time. (3) Pay attention to hearth negative pressure to avoid positive pressure. (4) If unfortunately the incinerator stops due to explosion inside the incinerator, air supply shall be stopped and increase air draft section time of the ventilator; (5) properly conduct daily check and maintenance of the incinerator to rule out accidents.

10.6.3 Countermeasures Against Oil Tank Leakage and Explosion Risk Strictly follow relevant national regulation of safe production, take B production and storage safety technical measures and abide by the B industrial fire prevention regulations and norms; Establish and perfect periodical safety check system under the safe production responsibility system, conduct periodical maintenance of the pipes and valves of the oil storage tank to timely spot accident potential and rule it out; Enhance safety awareness, strengthen safety education and staff’s safety awareness, seriously implement safety regulations and systems to avoid staff’s wrong behaviors, and formulate corresponding contingency measures; Smoke and fire prohibited around the light diesel storage tank; Make sure that cofferdam has been set around the diesel storage tank to avoid diesel leakage to the outside circumstances when light diesel leakage occurs.

10.6.4 Countermeasures against Odor Pollutant Accident Discharge Caused by Failures of Odor Pollutant Control Measures To prevent odor pollutant accident discharge, take the following control, buffer and contingency measures: 1 Enhance daily check and maintenance of incinerator to lower accident probability; 2 Buffering measures: Enhance garbage pool spraying deodorization to reduce odor generation; 3 Set deodorization devices at the garbage unloading platform, discharge the

275 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited odor via the roof after the gas inside the unloading hall is deodorized by the deodorization devices to prevent the odor from leaking freely.

10.6.5 Other Accident Control Measures (1) Enhancing Safety and Fireproof Measures The firefighting equipment set in the incineration plant is in line with the relevant requirements in Code for Design of Extinguishers Distribution in Buildings (GBJ140-1997), and check periodically to test the firefighting equipments function and change timely. Set main firefighting water hose in the project lot, distribute it in a ring, the branch pipes are independent. If one branch pipe is damaged for fire, the main firefighting pipe can ensure that there is still enough water; set fire extinguisher in the incinerator workshop, set fire hydrant in the parameter and enough alarm and escape shall also be set. The area distribution of the fireproof lot shall be in line with relevant requirements in Code for Fire Protection Design of Building (GBJ140-1997). Take relevant lightning protection and explosion-proof measures, and the design is in line with requirements in Design Code for Protection of Structures Against Lightning (GB50057-2000) and General Rules for Designing the Production Facilities in Accordance with Safety and Health Requirements (GB5083-1985). Incineration workshop, transformer room, coal warehouse shall be designed in accordance with fireproof rating 1, other construction (structure) shall be no lower than rating 2; The building fireproof rating shall not be lower than rating 2 when coal initiation ignition and auxiliary burning is applied in incinerator. The buildings mentioned above shall be isolated from other rooms by a fireproof wall. (2) Anti-leakage Measures Leakage is one of the accident sources of the environmental risks of this project, the main measures to prevent material leakage are: Globe valve and pumping system must be installed on clean sewage pipe (storm sewer), pumping system connected to the sewage treatment station of this project. Make the operation procedures stricter, especially the filling ratio of the tank trough. Formulate a reliable equipment check and maintenance plan to prevent accidents caused by improper equipment maintenance. Where the poisonous gas and flammable gas may leak, set poisonous gas or

276 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited flammable gas inspection in accordance with the standard, to test the poisonous gas concentration in the operation environment at any time, and set a gas alarm plate in the control room and lead the signal into the DCS system so as to take necessary measures. Strengthen inspection during operation. Establish such normative management institutions as the evaluation, approval, operation, monitor, rescue, Contingency procedures, accident report, etc. (3) Establish and Perfect Safe Environment Management System. A special department responsible for safety management shall be set. Its main responsibilities are fully responsible for the safe production of the whole factory, follow safe production law, regulations, enhance safe production management, establish and perfect safe environment management responsibility system, implement management staff and fund, perfect safe production conditions to assure safe production. Coordinate with relevant authorities and design and construction unites to strictly follow the “3 same time” at the design, construction and acceptance, etc. of the project. Take corresponding prevention measures against possible unsafe measures to wipe out accident potentials. Should there be any accident, effective measures must be taken to lower the damage caused by accidents and environmental pollution. In accordance with the requirements of Regulations on Enterprise Staff Labor Safety, Health, Education Management (No. 405 Ministry of Labor Issue [1995]), we should establish a periodical safety education training evaluation system to continuously improve production, management staff’s safe operation skill and self-protection awareness. Enhance the monitor, check, periodical maintenance of the equipment to assure that the equipments and devices are in good state. As to the accidents occurred or near misses, malfunctions, abnormal process conditions, wrong operation, etc. we should make a meticulous record and analyze the causes thoroughly, and find out correction measures. Collect, analyze the related cases both at home and abroad, compare the specific conditions of the projects to enhance effective measures on such aspects as safety technology, management to avoid the occurrence of similar accidents. Record and analyze various kinds of inspection goals and leakage points and check points. Treat and correct the unsafe factors timely. 277 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Formulate an contingency plan and link it with regional contingency plan, try our best to use social assistance to minimize loss and environmental pollution.

10.7 Formulation of Accident Contingency Plan Everbright Environmental Protection Energy (Suzhou) Limited has made the Summary of Accident Contingency Plan during the operation of current project, which targets the Waste-to-Energy Project accident risk and comes up with countermeasures and Vein Industrial Park joint-action program.

10.7.1 Purposes of Formulating Risk Accident Contingency Plan The purpose of formulating risk accident contingency plan is to make the most of the plan at the fastest speed, organize orderly rescue to control the accident and lower its damage and the loss it causes when the accident occurs.

10.7.2 Basic Requirements of Risk Accident Contingency Plan Basic requirements of risk accident contingency plan are: scientific, pragmatic and authoritative. Risk accident Contingency rescue work is a very scientific work, we must conduct scientific analysis and argument to make a strict, unified, complete contingency plan; the plan shall be in line with the actual conditions of the project, it is characterized by being pragmatic, simple, easy to grasp, etc; it shall also make clear the responsibilities, authority limit, task, work standard, reward and punishment, etc. to make it an institution of our company to ensure that it is authoritative.

10.7.3 Environmental Risk Contingency Institution Setting and Responsibilities Targeting possible environmental risks, we should set up a leadership group for Contingency rescue under accident conditions (it is suggested that the HSE group takes this responsibility). The leadership group for Contingency rescue is a permanent organ that is set up by our company to prevent and tackle various kinds of sudden accidents, whose man responsibilities are: (1) Prepare and modify accident contingency rescue plan. (2) Organize and establish the rescue team and organize training and exercises. (3) Check how the safety work is implemented.

278 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited (4) Check and urge the prevention measures of major accidents and preparation of contingency rescue. (5) Issue and cancel orders in the contingency actions. (6) Responsible for reporting the accident to the upper governmental organs and neighboring institutions and the residents nearby. (7) Responsible for investigating the causes of accident, tackle accident in a proper way and summarizing the lessons.

10.7.4 Procedures for Tackling Risk Accidents There shall be a complete procedure diagram for tackling the project risk accident. Should be there be any contingency accident, we must follow the risk accidents tackling procedure diagram to tackle it. The basic structure chart of company risk accident contingency organization system is as Fig. 10.7-1, which shall be perfected in accordance with the actual conditions of the enterprise. See Fig. 10.7-2 for planned structure chart of company risk accident contingency organization.

279 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Fig. 10.7-1 Company Risk Accident Contingency Organization System Structure Chart

280 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

GovAdministration

CorCommanding team

CorTechTeamm CorRescueTeam CorLogisticMaterial CorMedicare Team team

Fig. 10.7-2 Accident Contingency Organization Structure Chart

10.7.5 Risk Accident Tackling Measures To effectively tackle risk accident, there should be practical tackling measures. Project risk accident contingency measures includes: The establishment of such systems as equipment, accident site commanding, rescue, communication, etc. site contingency measures plan, accident danger inspection team, site withdrawal and remedy measures plans, etc. (1) Establish alarming communication system and accident tackling leadership system. (2) Formulate effective accident-tackling contingency plan which shall be recognized by relevant departments and effectively cooperate with relevant departments. (3) Make responsibilities concrete, and make each department and relevant staff. (4) Formulate an implementation plan by which we can control land reduce incident impact, its degree and remedy measures. (5) Oversee site accident management and the process of accident-tackling, which shall be the responsibility of staff or staff in relevant department who

281 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited is experienced in accident-tackling. (6) To improve accident-tackling team’s coordination rescue level and actual capacity, check contingency comprehensive operation of rescue system, improve actual capacity, we should carry out contingency rescue exercise.

10.7.6 Risk Accident Contingency Inspection When waste gas accident occurs, it shall be reported to upper organs immediately, and upper organs will arrange the accident contingency inspection, in which project characteristic factors of surrounding sensitive points is paid special attention to (Dioxin is temporarily not included for its long inspection cycle).

10.7.7 Risk Accident Contingency Plan The contingency plan of the planned project must be prepared in mean time to cope with possible contingency risk accidents. Should there be any accident we can initiate Contingency treatment under full preparation. The risk accident contingency plan includes: the classification of contingency state, contingency plan area and accident grade, contingency protection, Contingency medical treatment, etc. So the followings shall be included in the risk accident contingency plan:

Table 10.7-3 Key Points of Sudden Environmental Risk Accident Contingency Plan

S/N Item Content and Requirements 1 Contingency Plan Lot Risk Target: Environmental protection 2 Contingency Organ, Personnel Factory, regional contingency organs, personnel Formulate the grade of plans and graded response procedures. In accordance with controllability, severity and Plan Graded Response range of impact, stick to the principle of “company 3 Conditions self-rescue, the seat plays major part”, when it exceeds company’ capacity in the contingency plan, shall require upper contingency plan initiated in time 4 Contingency Rescue Support Contingency devices, equipments, etc. Alarm and Communication, Formulate the alarm and report-to-police way, notification 5 Contact Way way, control under contingency situations,

282 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

A professional team will be responsible for the supervision Contingency Environmental and inspection on site, evaluate accident property, parameter 6 Inspection, Disaster-relief, and consequence, to provide decision-making reference for Rescue and Control Measures the commanding department Contingency Inspection, Accident site, nearby area, control firefighting area, control Protection Measures, 7 and removal pollution measures and corresponding Leakage-removal Measures and equipment Equipment Personnel Withdrawal, Poison contingency dosage regulation on people in accident Evacuation, Contingency Dosage site, factory nearby area, the and accident affected zones, 8 control, Withdrawal withdraw organization plan and rescue, medical care and Organization Plan public health Formulate contingency state ending procedures Accident Contingency Rescue Accident site remedy, recovery measures 9 Closure Procedure and Recovery Nearby area accident alarm removal measures and remedy, Measures recovery measures. After the formulation of contingency plan, arrange 10 Contingency Training Plan personnel training and exercises in mean time. Public Education and Conduct public education, training and release relevant 11 Information information in the areas near our factory Set a special record for contingency accident, set up file and 12 Record and Report special report system, set up a special department for management Preparation and formulation of attachments related to 13 Attachments contingency accidents.

10.8 Contingency Prevention of the Expansion Project and Its Contingency Plan Our company has formulated effective accident risk prevention measures and a series of practical and feasible contingency plan during the operation of the project Phase I, II, see 10.6, 10.7 for details. Combine with risk prevention measures and contingency plan during Phase I, II, we will systematically connect this project with current project risk prevention measures to effectively cope with accidents and maximally reduce harm to human health and environment by flue gas excessive discharge, waste water And dangerous waste constituent leakage to air soil or waters due to fire, explosion or other sudden and non-sudden incidents. As to different grades of risk accident, we have different response plan, which has built a joint-action mechanism together with current project, vein industrial park, etc.

283 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Should the risk accident be severe, which severely impacts the environmental interests of third party institution and the populace, and cause severe environmental impact which need to be reported to upper leaders by the person takes full responsibilities of the contingency team, and the upper leader will immediately inform Suzhou Environmental Contingency and Accident Investigation and Suzhou Administration Center for Solid Waste,. They will arrange the specific contingency rescue to lessen its impact on the environment. The member of contingency team will do the reserve job of the accident site to prevent it from enlarging and solve the remedy problem of the participants.

10.9 Summary of Risk Assessment Based on accident risk analysis and calculation, the maximum credible accident is the accident discharge and odor accident discharge when the accessory of the incinerator-the semi-dry flue gas treatment devices doesn’t reach its normal treatment efficiency.

Under abnormal working conditions, regular waste gas PM10, HCl, dioxin discharge contributes more to ground hourly concentration than normal working conditions. The maximum HCl, dioxin ground hourly concentration caused by regular waste gas discharge, after it is overlaid with this bottom, still meets corresponding requirements of environmental quality standard; but as to PM10, and it still fails to meet the standard. Maximum HCl, dioxin ground hourly concentration of various sensitive points in the evaluation range contributes more than normal working conditions, but when it is overlaid with this bottom, it still meets corresponding requirements of environmental quality standard. So the impact of dioxin under accident state and from the aspects of human health, it is still acceptable. When the boiler shuts down or is in maintenance, the garbage pit shall be sealed, and the odor discharged to the atmosphere after it is cleaned by activated charcoal waste gas treatment devices, and the discharge amount of odor is little under accident state and its impact on the circumstance little. So when the conditions that inspection enhanced, risk control measures established and practical contingency plan made, the environmental risk of this project is still acceptable.

284 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

11 Emission Control

In accordance with such national, provincial regulation as Administration Rules on Construction Environment, Interim Provisions on the Control of Total Amount of Discharged Pollutants of Jiangsu Province (Order No. 83 by the provincial government), Circular of Issuing the Review Management Measures of Regional Balance Plan of the Total Discharge Amount of Main Pollutants of Construction Project in Jiangsu Province (Jiangsu Environment Office No. 71, 2011), pollutant emission control must be carried out, and pollution quota in Jiangsu’s newly built, expanded and reconstructed construction projects, after they got them can they construct and produce. This emission control analysis provides basis for the application of discharge quota by analyzing the total discharge amount of the main pollutants of this project, checking project emission control indexes.

11.1 Emission Control Factors In accordance with total emission control requirements of Jiangsu Province and combined with project construction and pollutant discharge characteristics, the total emission control factor by the assessment is:

Waste Air Pollutants: SO2, NOx.

Water Pollutants: CODCr, NH3-N。

Other factors (dust, dioxin, HCl, HF, Hg, Cd, Pb, CO, BOD5, SS, TP, etc.) will be the evaluation quotas.

11.2 Emission Application See Table 11.2-1 for the total emission of pollutants of this project.

Table 11.2-1 Emission Application of This Project Unit: t/a This project Amount Takeover of Discharge Amount Carry-the-old-with-the-new Amount Discharge Approved Categories Name Amount of Cutting Amount of Reduction Amount of whole Amount Amount Generation (or Discharge Factory Amount of

285 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Disposal) Amount of Waste 11,988 Water 227,772 258,408 255,744 2,664 218,448 11,988 104,590* Waste COD 113.89 4,478.27 4,477.20 1.07 109.22 5.73 0.60 89.96* Water BOD5 68.33 1,540.78 1,540.24 0.53 65.53 3.33 0.12 SS 91.11 387.35 386.95 0.40 87.38 4.13 0.12 37.17* NH3-N 7.97 255.97 255.88 0.09 7.65 0.42 0.06 3.5* TP 1.82 31.60 31.59 0.01 1.75 0.09 0.01 dust 38.08 16368 16,351.63 16.37 14.5 39.95 48.21 SO2 18.17 109.12 92.75 16.37 1 33.54 247 NOX 362.3 589.25 294.63 294.62 0 656.92 694.1 HCl 10.91 208.69 200.34 8.35 2.35 16.91 19.29 HF 2.02 16.37 14.73 1.64 0 3.66 Waste Gas CO 79.60 81.84 0 81.84 0 161.44 Pb 0.11 8.18 7.36 0.82 0 0.93 Hg 0.006 0.82 0.74 0.08 0 0.086 Cd 0.004 0.82 0.74 0.08 0 0.084 Dioxin 0.19g/a - - 0.1637g/a 0 0.3537g/a 0.3855g/a Industrial Solid 0 137,922 137,922 0 0 Solid Waste 0 Waste Domestic Solid 0 10.2 10.2 0 0 Waste 0 Remarks: in the original environmental assessment report and its approval, leachate liquid will be sent to the leachate liquid treatment plant at Qizishan landfill, so leachate discharge volume is not included in current project waste water volume and approved total waste water volume.

11.3 Emission Balance Plan Phase III project will ensure that there will be no new waste gas pollutant and waste water pollutant emission cut via carry-the-old-with-the-new reduction, which will be balanced in current approved total emission. Properly treat the industrial solid waste and general waste to realize solid waste zero discharge, no need to apply for total emission.

286 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

12 Public Participation

12.1 Purpose of Public Participation The construction of any project will have favorable or unfavorable impact on the surrounding natural and social environment which will directly or indirectly affect public interests of neighborhood areas. The public will have different attitudes from respective interests. “Public Participation” of environmental impact assessment is to have public survey during the environmental impact assessment which is to understand the attitude and viewpoint of various circles to engineering construction. The purpose of public participation in the environmental assessment: Understand the viewpoint and attitude of surrounding public to the project construction and understand the impact scope of the project to society, economy and environment to make environment impact assessment democratization and publicity.

12.2 Principles of Public Participation According to the document spirit of Interim Provisions for Environment Impact Assessment Public Participation (Environment Development 2006 [No. 28] and the characteristics of the project, the following principles are determined: Reflect the right to know of the public for important events of social development and economic construction, protect the interest of general public, and strengthen the public’s participation awareness of environmental protection. Through the on-site investigation, the public will know the production and operation condition and the implementation of environmental protection measures after the refuse incineration power pant is established including beneficial and harmful impact, long-term and short-term impact and if the impact can be accepted or not - widely and conveniently. Comprehensively reflect the attitude of the public to the environmental, local economic construction and community life impacts caused by the project. The object of public participation should be typical, true and extensive with public participation style-equality. The project is a waste incineration power plant with great sensitivity, so we focus

287 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited on investigating the resident representatives’ opinions of the project in the assessment scope.

12.3 Methods of Public Participation There are many ways for public participation. Public participation in the environmental assessment adopts online notice, newspaper notice and public participation questionnaire and public hearings, and the investigation is combined by representativeness and randomness. “Public Participation Questionnaire” chooses the most significant and sensitive questions to the public relation and answers questions mainly by ticking “√” for the public’s convenience and textually describes if necessary.

12.4 Result Analysis of Public Participation Questionnaire Issued

12.4.1 Investigation Methods and Principles Public participation of the environmental impact assessment adopts the style of questionnaire and the investigation is combined by representativeness and randomness. In the questionnaire design, we choose the most significant and sensitive questions to the public relation and answer questions mainly by ticking “√” for the public’s convenience. See Table 12.4-1 for the questionnaire.

Table 12.4-1 Questionnaire of Public Participation in Environmental Protection Construction Project Waste-to-Energy Project Phase III, Project Construction Everbright Environmental Energy North Side of Qizi Col, Suzhou City Name Site (Suzhou) Limited

288 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Project Introduction: To comprehensively utilize resources to a minimum, reduce the environmental pollution, further improve environmental carrying capacity of Suzhou and achieve fast, healthy and sustainable development, under the strongly support of local government, Everbright EnvironmentalProtection Energy (Suzhou) Co., Ltd. decides to use reserve land and surrounding more than 50 acres idle land, invest RMB 0.75 billion and have “4×500t/d incinerator + 2×20MW turbo generator unit” construction of third-phase extension engineering based on the successful operation of first and second-phase engineering of Waste-to-Energy Project. “3×350t/d incineration and waste heat generating project” of first-phase engineering built by Everbright Environmental Protection Energy (Suzhou) Co., Ltd. on the north side of Qizishan Col in Suzhou City was put into production formally in July, 2006 and “2×500t/d incinerator + 20MW turbo generator unit” were put into production formally in May, 2009. The acceptance data shows that the incinerator outlet waste gas and smoke dust, sulfur dioxide, nitric oxide, HCl, carbon monoxide, Hg, Cd and Pb all meet the secondary standard of Pollution Control on the Household Garbage Incineration (GB18485-2001), dioxins emission can reach the EU standards and fluorides meet the Table 2 secondary standards of Air Pollutant Emission Standards (GB16297-1996). Boundary particulate matter, ammonia, hydrogen sulphide and odor concentration fugitive discharge concentration all meet the standard requirements. Main equipment of third-phase expansion engineering still adopts Belgium Seghers incinerator, the tail gas adopts the handling style of “Semi-dry reaction tower + SCR denitration + activated carbon + bag-type dust collector” and the dioxin emission in the smoke implements EU II standards. Odor gas is handled with negative pressure. The drainage of the project adopts sewage separation system, a small emission of leachate is sprayed to the incinerator and the other is adapted after the treatment of leachate treatment station. The slag is comprehensive utilized and the fly ash is safely disposed in the landfill site of hazardous waste which will not cause secondary pollution. Situation of Investigated Person Unit Situation of Investigated Person Name Gender Unit Name Age Occupation Size Main Product Phone Education Nature Competent Number Degree Department Home City (County) Country Unit Address City (County) Country Address (Street) (Street) 1. Whether you are satisfied with current situation of environmental quality (Please specify the reason if

289 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited unsatisfied) ฀A Very Satisfied ฀B Quite Satisfied ฀C Unsatisfied ฀D Very Unsatisfied 2. Whether you know/understand the proposed project in this district ฀A Do not Understand ฀B Know a Little ฀C Very Clear 3. How do you understand the project information ฀A Television, Broadcast ฀B Newspaper ฀C Internet ฀D Folk Information ฀E Others 4 According to what you already know, the project causes damage/impact to the environmental quality ฀A Serious ฀B Quite Big ฀C Ordinary ฀D Little ฀E Unclear 5. Do you think what kind of environmental problem will be caused by the project ฀A Atmospheric Environment ฀B Water Environment ฀C Solid Waste ฀D Unclear 6., From environmental protection perspective, what kind of attitude do you hold about the project and briefly explain why: ฀ASupport ฀B Against 7. What do you suggest and require about the environmental protection in the project

12.4.2 Participants Totally 110 questionnaires are distributed in the research and 104 effective ones are returned (Rate of return is 94.5%). The age range of investigated persons: Residents and workers around the proposed project site, age scope 21-71, male 64, female 40. The participants all accept primary education and the occupations include farmer, worker, teacher and doctor. The statistics of participants can be seen in Table 12.4-2 and the details of investigated object can be seen in Table 12.4-3.

Table 12.4-2 Participant Information Table Percentage of Percentage Item Person-time the Total Item Person-time of the Total (%) (%) Worker 22 9.0 20-30 30 Farmer 186 76.2 31-40 27 Position Cadre 7 2.9 41-50 33 Others 29 11.9 51-60 7 Primary 36 14.7 61 4 School Age Junior High 108 44.3 Unfilled 3 School Senior Education High 58 23.8 School Technical Male Secondary 8 3.3 64 61.5 School Gender University 6 2.4 Female 40 38.5 Vacancy 28 11.5

290 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Table 12.4-3 Basic Information of Participants Attitude about S/N Name Gender Age Home or Unit Address Contact Phone the Project Gusu Village, Mudu Zhou 1 Male Town, Wuzhong Support Chunhua 32 County 13962100462 Gusu Village, Mudu Yu 2 Female Town, Wuzhong Support Yongfang 37 County 13814812355 Gusu Village, Mudu Wei 3 Male Town, Wuzhong Support Xiaolei 24 County 13915543473 Gusu Village, Mudu 4 Wu Wei Male Town, Wuzhong Support 30 County 66262427 Gusu Village, Mudu 5 Chen Wei Male Town, Wuzhong Support 46 County Gusu Village, Mudu Sun 6 Male Town, Wuzhong Support Quanlin 53 County 15050131275 Yaofeng Village, Mudu Wang 7 Male Town, Wuzhong Support Benli 63 County 6629153 Yaofeng Village, Mudu Zhu 8 Female Town, Wuzhong Support Yingling 39 County 66517729 Yaofeng Village, Mudu Cai 9 Female Town, Wuzhong Support Wenqing 37 County 15150429469 Yaofeng Village, Mudu Chen 10 Male Town, Wuzhong Support Peipei 60 County 66262025 Zhang Yaofeng Village, Mudu 11 Yongshen Male Town, Wuzhong Support g 67 County 66515769 Yaofeng Village, Mudu 12 Liu Ping Male Town, Wuzhong Support 33 County 13862598372 Yaofeng Village, Mudu Qiu 13 Male Town, Wuzhong Support Leibin 35 County 13806200816 Gusu Village, Mudu 14 Xu Cheng Male Town, Wuzhong Support 46 County 66573851 Yaofeng Village, Mudu Wang 15 Male Town, Wuzhong Support Yongyuan 37 County 16 Yang Lin Female 44 High-tech Zone 68092192 Support Gusu Village, Mudu Zhou 17 Male Town, Wuzhong Support Chunhua 32 County 13962100462 18 Gao Wei Female 55 High-tech Zone 68786905 Support

291 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

19 Zhang En Male 48 High-tech Zone 68091496 Support Zhang 20 Female High-tech Zone Support Lijun 47 68247000 Gusu Village, Mudu Yang 21 Male Town, Wuzhong Support Guocheng County Gusu Village, Mudu Yu 22 Male Town, Wuzhong Support Changbao 53 County Gusu Village, Mudu Shen 23 Male Town, Wuzhong Support Xueyuan 46 County 13912708324 24 Zhu Min Female 28 Wuzhong 13915558395 Support Gusu Village, Mudu 25 Li Bin Male Town, Wuzhong Support 26 County Gusu Village, Mudu Wang 26 Male Town, Wuzhong Support Qiang 26 County Gusu Village, Mudu Wu 27 Male Town, Wuzhong Support Chunhua 34 County Yaofeng Village, Mudu Zhang 28 Female Town, Wuzhong Support Chun fang 35 County 66361722 Yaofeng Village, Mudu Yan 29 Female Town, Wuzhong Support Minjuan 35 County 66369536 30 Chen Bin Female 41 Wuzhong 66596370 Support Zhao 31 Female Wuzhong Support Luhua 30 Zhao 32 Male Wuzhong Support Yunfeng 25 13862090972 33 Sun Zhe Female 23 Wuzhong 13375199312 Support Yaofeng Village, Mudu Xie 34 Male Town, Wuzhong Support Bentong 24 County 13306137058 Yaofeng Village, Mudu 35 Le Yu Male Town, Wuzhong Support 23 County 18913195930 Yaofeng Village, Mudu 36 Wang Mei Male Town, Wuzhong Support 26 County 13306133822 Yaofeng Village, Mudu Han 37 Female Town, Wuzhong Support Yingying 41 County 6659397 Yaofeng Village, Mudu Tang 38 Female Town, Wuzhong Support Zhiyu 24 County 66262100 Yaofeng Village, Mudu Zhang 39 Female Town, Wuzhong Support Lingling 23 County 66262100 Gusu Village, Mudu Zhu 40 Female Town, Wuzhong Support Weifang 42 County

292 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Gusu Village, Mudu 41 Li Zhu Female Town, Wuzhong Support 49 County Gusu Village, Mudu 42 Jin Fagen Male Town, Wuzhong Support 46 County Gusu Village, Mudu Chen 43 Female Town, Wuzhong Support Huiyun 44 County Gusu Village, Mudu Xu 44 Female Town, Wuzhong Support Guihua 41 County Gusu Village, Mudu Chen 45 Male Town, Wuzhong Support Shiying 44 County Gusu Village, Mudu Qian 46 Male Town, Wuzhong Support Yulong 51 County Gusu Village, Mudu 47 Yu Wei Male Town, Wuzhong Support 43 County 13406002231 Gusu Village, Mudu Zhu 48 Female Town, Wuzhong Support Jianying 40 County Gusu Village, Mudu Qian 49 Female Town, Wuzhong Support Caiyuan 49 County 15050110124 Gusu Village, Mudu Meng 50 Female Town, Wuzhong Support Lanmei 46 County 66266051 Yu 51 Male Wuzhong District Support Fuyuan 41 66211741 Gusu Village, Mudu 52 Pan Wei Male Town, Wuzhong Support 40 County 66264987 Gusu Village, Mudu Qian 53 Male Town, Wuzhong Support Jianguo 47 County Gusu Village, Mudu Wang 54 Male Town, Wuzhong Support Xiaosheng 51 County Gusu Village, Mudu Zhang 55 Male Town, Wuzhong Support Wen 49 County Gusu Village, Mudu Wang 56 Male Town, Wuzhong Support Wenhua 37 County Gusu Village, Mudu Yu 57 Male Town, Wuzhong Support Dangfeng 57 County Gusu Village, Mudu Wu 58 Male Town, Wuzhong Support Peiying 48 County Yaofeng Village, Mudu Wang 59 Female Town, Wuzhong Support Zhefa 40 County 66793382

293 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Wang 60 Female Wuzhong District Support Wenjun 46 66793382 Yaofeng Village, Mudu Chen 61 Male Town, Wuzhong Support Caihua 24 County 33793316 Gusu Village, Mudu Gao 62 Male Town, Wuzhong Support Xixiang 26 County 66793316 Gusu Village, Mudu Wang 63 Male Town, Wuzhong Support Jiaqi 26 County 64 Gao Hong Female 26 Qingkou, Wuzhong 66793316 Support Gusu Village, Mudu 65 Qian Li Male Town, Wuzhong Support 26 County Wu Mudu Town, Wuzhong 66 Male Support Xiaoming 27 County 66793316 Jin Mudu Town, Wuzhong 67 Male Support Mingfang 49 County Gusu Village, Mudu Ma 68 Female Town, Wuzhong Support Xuedong 43 County 13862006278 Mudu Town, Wuzhong 69 Zhu Wei Female Support 26 County Gusu Village, Mudu Chen 70 Female Town, Wuzhong Support Chen 23 County 15995430630 Gusu Village, Mudu Xu 71 Female Town, Wuzhong Support Yanhua 24 County 15151717650 Gusu Village, Mudu Pan 72 Male Town, Wuzhong Support Shuiyuan County Gusu Village, Mudu 73 Chen Xin Male Town, Wuzhong Support 47 County 13912779928 Yang Yan Chai Nursing 74 Female Support Yayun 22 Home 15950014852 Zhang Yan Chai Nursing 75 Female Support Qinna 23 Home 15051582643 Zhang Yan Chai Nursing 76 Female Support Jinjin 26 Home 13402534433 Yan Chai Nursing 77 Meng Pan Female Support 23 Home 15862311066 Yan Chai Nursing 78 Wang Mei Female Support 25 Home 15250116214 Gusu Village, Mudu Kang 79 Male Town, Wuzhong Support Wenhua 45 County 13862564385 Gusu Village, Mudu Qian 80 Male Town, Wuzhong Support Hailin 47 County 13962525881 Gusu Village, Mudu Song 81 Male Town, Wuzhong Support Fugen 50 County 82 Shu Male 53 Gusu Village, Mudu Support

294 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Fuyuan Town, Wuzhong County Gusu Village, Mudu Sheng 83 Male Town, Wuzhong Support Hongxing 35 County Gusu Village, Mudu Fei 84 Male Town, Wuzhong Support Canlan 49 County Gusu Village, Mudu 85 Zhao Fei Male Town, Wuzhong Support 35 County Gusu Village, Mudu Chen 86 Male Town, Wuzhong Support Jianchun 47 County Gusu Village, Mudu Yang 87 Female Town, Wuzhong Support Yuezhen 47 County 13814857500 Gusu Village, Mudu Xu 88 Female Town, Wuzhong Support Shuimei 71 County Gusu Village, Mudu Wei 89 Male Town, Wuzhong Support Jiangang 33 County Gusu Village, Mudu Chen 90 Male Town, Wuzhong Support Guohua 40 County Gusu Village, Mudu Wang 91 Male Town, Wuzhong Support Shuicai 65 County 13506201657 Gusu Village, Mudu Wang 92 Male Town, Wuzhong Support Aiguo 55 County 13862058011 Gusu Village, Mudu Rui 93 Male Town, Wuzhong Support Huogen 50 County Gusu Village, Mudu Lu 94 Male Town, Wuzhong Support Yunwei 55 County Gusu Village, Mudu 95 Ye Yinling Female Town, Wuzhong Support 57 County Gusu Village, Mudu Chen 96 Male Town, Wuzhong Support Yongyuan 41 County Gusu Village, Mudu Rui 97 Female Town, Wuzhong Support Yufang 33 County Gusu Village, Mudu 98 Qian Bin Male Town, Wuzhong Support 26 County Gusu Village, Mudu Tang 99 Female Town, Wuzhong Support Xiaoyan County Gusu Village, Mudu Wang 100 Male Town, Wuzhong Support Jialin 47 County 15195683185

295 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

Gusu Village, Mudu Rui 101 Male Town, Wuzhong Support Huoyuan 44 County Gusu Village, Mudu Zhang 102 Male Town, Wuzhong Support Haojie 17 County 13814872932 Gusu Village, Mudu 103 Lu Jinfang Female Town, Wuzhong Support 46 County 66266120 Yaofeng Village, Mudu 104 Liu Lin Female Town, Wuzhong Support 41 County 66793382

12.4.3 Investigation Results The public investigation results can be seen in Table 12.4-4.

Table 12.4-4 Statistic of Public Investigation Results

Statistic of Options, Number and Ratio 1. Are you satisfied D. Very A. Very Satisfied B. Satisfied C. Unsatisfied with the current Unsatisfied situation of environmental 35/33.6% 61/58.7% 8/7.7% quality? 2. Do you A. Do not B. Know a Little C. Very Clear know/understand the Understand proposed project in 3/2.9% 99/95% 2/1.9% this district? 3. How do you A. Television, B. C. D. Folk E. Others understand the Broadcast Newspaper Internet Information project 5/4.8% 40/38% 52/50% 41/39% 1/1% information? 4. According to C. A. Serious B. Big D. Little E. Unclear what you already Ordinary know, the project causes damage/impact to 2/1.9% 17/16% 52/50% 28/27% 5/4.8% the environmental quality 5. Do you think A. Atmospheric B. Water C. Solid Waste D. Unclear what kind of Environment Environment environmental problem will be 69/66% 12/12% 14/13% 9/8.7% caused by the project? 6. From A. Support B. Oppose environmental protection perspective, what kind of attitude do 100/100% you hold about the project and briefly explain why: And:

296 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited The satisfaction of public to the current situation of environmental quality of proposed project site 35 of investigated public (33.6%) are very satisfied with the current situation of environmental quality of proposed project site, 61 of investigated public (58.7%) are quite satisfied with the current situation of environmental quality of proposed project site and 8 of investigated public (7.7%) are not satisfied with the current situation. Understanding of Public to the Project 101 of investigated public (96.9%) say that they know clearly or a little about the construction of the project and 3 of investigated public (2.9%) say that they know little about the construction of the project. 4 of investigated public (4.8%) know something about the project from television and broadcast, 40 of investigated public (38%) know the project from the newspaper, 52 of investigated public (50%) know the project from Internet and 41 of investigated public (39%) know the project from folk information. Through the public participation investigation, the openness of the project is further expanded. Damage/impact of the project to the environmental quality When being asked with “Damage/impact of the project to the environmental quality”, 2 of investigated public (1.9%) think that damage/impact is “serious”; 17 of investigated public (16%) think that damage/impact is “quite great”; 52 of investigated public (50%) think that damage/impact is “ordinary”; 28 of investigated public (27%) think that damage/impact is “little”; 5 of investigated public (4.8%) say with an unclear attitude. What kind of environmental problem will be caused by the project? When being ask with “What kind of environmental problem will be caused by the project”, 69 residents (66%) say “Atmospheric environment”, 12 residents (12%) say “Water environment”, 14 residents (13%) say “Solid Waste” and 5 residents (4.8%) choose “Unclear”. Overall attitude to the project Investigated residents all support the project with no objection. Opinions and suggestions of public to the environmental protection of the project The investigation shows that many public propose that environmental protection approval authority shall examine and approve strictly according to the relevant regulations; reduce the pollution discharge and strengthen the supervision of environmental protection facilities; have financial assurance of environmental

297 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited protection treatment; implement “Three-Meanwhile” regulation strictly and manage the three wastes seriously to guarantee standard discharge with high starting point and requirements and the environmental protection authority shall have inspection and supervision regularly, and strengthen the management.

12.5 Online Publication Investigation The construction company has two online publications of the project in http://wzhbj.gov.cn/ (Environmental Protection Agency website of Wuzhong District, Suzhou City) and http://nies.org/ (Nanjing Research Institute of Environmental Science Website of Environment Ministry) between March 21, 2011 and April 1, 2011 and July 4, 2011 to July 18, 2011 for introducing the overview of the project, the possible environmental impact caused by the environment, environmental protection measures to be taken and environmental impact assessment conclusion of the project and asking for opinions and advices of public to the project construction. Currently, the public feedback opinions to the online publication have not been received. And the detail of online publication can be seen in the attachments.

12.6 Participating Hearing of the public According to the Circular of Further Normalizing Public Participation and Hearing System in Environmental Assessment of Planning and Construction (Jiangsu Environment Office [2011] No. 173), the hearing announcement is published by the construction unit (Everbright Environmental Protection Energy (Suzhou) Limited.) in the Suzhou Daily on June 18, 2011. During the open enrollment, 136 application forms are received, and 18 of them are selected as hearing representatives and 19 of them are selected as audit representatives. They attend the environmental impact assessment public participation hearing of the third-phase expansion project hold in book collection club of Mudu Town on July 8, 2011. The representatives were from Gusu Village, Yaofeng Village, Fenghuang Cemetery, Xujiang City, surrounding enterprises and institutions, Mudu Town government and City Municipality and Appearance Bureau. The representatives proposed the environmental protection of public concern after the representatives listened to the project overview and environment impact introduced by construction unit and environment assessment unit. Construction unit,

298 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited environment assessment unit and relevant experts answered all the questions and reported the sensitive problems with special attention such as dioxin and odor to the public. The representatives participating the meeting all supported the third-phase expansion project construction.

12.7 Grievance Redress Mechanism Suzhou III Project has established an online monitoring system to make sure all environmental data comply with the national and regional laws and regulations. Monitor many relevant parameters such as concentration of flue dust (particulates), SO2, NOx and CO, flue gas flow rate, temperature, humidity and oxygen content, etc, and record the discharge rate and total discharge amount ,etc. Suzhou Environment & Municipal Administration Bureau and Solid Waste Management Bureau are in charge of supervision. If there is excessive discharge or pollution accident, Suzhou Environmental Protection Bureau and Construction Bureau will conduct investigation. Local citizen will directly make complaint to local government. Hold meeting with environmental protection bureau and surrounding villages and citizens. Set up complaint call: 0512-66562298. Public survey during the environmental impact assessment has been carried out. There are many ways for public participation. Public participation in the environmental assessment adopts online notice, newspaper notice and public participation questionnaire and public hearings, and the investigation is combined by representativeness and randomness. Set up complaint call: 0512-66561183. At construction phase of project, strengthen the environmental protection awareness, eliminate the illegal acts, implement different environmental protection management measures, strengthen environmental management and reduce the impact to the surrounding environment. The environmental protection administrative department will strengthen the supervision, guarantee the project operation according to the design principles and implement different environmental protection measures. Set up complaint call: 0512-66568033. When any dispute arises from project construction and operation, public may file an appeal with competent authorities. Assigned person will responsible for record and documents file. Authority, Project Company, local citizen and the complainants will implement on-site inspect. Related to the complaint from Environmental Protection

299 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited Bureau, Project Company will cooperate with local authorities on supervision and inspection. The results and amend must report to the relevant departments and publics.

12.8 Investigation Conclusion of Public Participation (1) According to the regulations of Interim Provisions for Environment Impact Assessment Public Participationt, the public participation takes fair as the principle and the public participation forms are mainly online publication, newspaper publication, issuing public participation questionnaire and holding public participation hearing. (2) The investigation result of public participation shows that all the investigated residents all support the project without objection. Some residents proposed a few requirements and suggestions. After the collection, the project shall prepare for the pollution prevention measures with high standards, guarantee standard discharge and reduce the pollutant discharge and the surrounding environment impact; require the approval department to examine and approve strictly and strengthen the daily supervision management. The public require that environmental protection approval department shall examine and approve strictly according to the national relevant regulations; reduce the pollution discharge and strengthen the supervision of environmental protection facilities; have financial assurance of environmental protection treatment; implement “Three-at-the-same-time” regulation strictly and manage the three wastes seriously to guarantee standard discharge with high starting point and requirements; after the project is put into production, environmental protection department shall examine regularly, supervise and strengthen the management. The construction unit will adopt the proposed suggestions by public, strengthen the environmental protection awareness, implement different environmental protection management measures, strengthen the environmental management and reduce the impact to the surrounding environment as much as we can. (3) Attitude about Construction Unit: Through different forms of public participation, the construction unit attaches great importance to the public opinions. The construction unit explains the proposed opinions by pubic, adopts some opinions and explains the reason for unused opinions. And they will strengthen the

300 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited environmental protection awareness, eliminate the illegal acts, implement different environmental protection management measures, strengthen environmental management and reduce the impact to the surrounding environment as much as we can. The environmental protection administrative department says that they will strengthen the supervision, guarantee the project operation according to the design principles and implement different environmental protection measures.

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13 Feasible Analysis of Site Selection

13.1 Consistency Analysis to Urban Planning

(1) Urban Overall Planning In the Suzhou Urban Master Plan (2007~2020), the Qizishan waste treatment plant will still be used explicitly and the expansion feasibility is considered. The construction project is located in the Qizishan area, Mudu Town, Wuzhong

District, Suzhou City. The area is planned as “U 42: Excrement and waste treatment land” in the Mudu Town Planning of Wuzhong District attached to the Suzhou Urban Master Plan (2007~2020). (2) Suzhou Everbright National Venous Industry Park Planning According to Professional Plan of Suzhou on Environmental Hygiene[2007] No. 71, environmental protection and planning feasibility of Qizishan waste landfill layout, change of domestic waste treatment from single landfill to the combination of incineration power plant and landfill and the construction of Everbright Environmental Protection Industry Park are affirmed. Around the future trend of large urban area (District 7), higher requirements are proposed for the follow-up expansion of domestic waste treatment in the Everbright Environmental Protection Venous Industry Park; strengthen the enterprise environmental administration of surrounding areas of Qizishan, improve the surrounding environment, ensure the environmental protection industry park to be built as top level and guarantee the environmental quality of surrounding areas. Suzhou Everbright National Venous Industry Park planning Construction (The planning has not been approved) takes production area as core, research development zone as technical support, management service zone as safeguard and environmental protection education base as the window. Everbright environmental protection incinerator is one of the projects from Everbright Environmental Protection Venous Industry Park.

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(3) Planning of Xujiang City, Mudu Town, Wuzhong District Mudu Town, Wuzhong District, Suzhou City is planning to construct Xujiang City along the Xujiang River (The planning is still in publication phase and has not been approved) and the site of Everbright environmental protection project in the planning is sanitation facility site. In conclusion, the construction of this expansion project is consistent with regional planning.

13.2 Consistency Analysis to Environmental Sanitation

Professional Planning

According to the Professional Plan of Suzhou on Environmental Hygiene (2006~2020) (Passed the assessment of experts organized by Jiangsu Provincial Construction Office), we predict that the total of domestic waste in Suzhou City will be 3,390t/d and 4,740t/d by 2020. According to the Bulletin on Prevention and Control of Environmental Pollution by Solid Waste of Suzhou City (2009) issued in June, 2010, the total of domestic waste in Suzhou urban area is 1,554,300 t (about 4,258t/d) which is greatly over the predicted total 3,390t/d by environmental sanitation planning in 2010. Currently, waste treatment capacity of first and second phase engineering of Everbright Environmental Protection Energy (Suzhou) Limited is about 2,580 t/d and the average volume entering into the incinerator is 2,090/d with 20.08% moisture content is excluded (leachate volume discharged when being stacked in the trash bin) which is a little over the operation load; first-phase storage capacity 4.7 million cubic meters of Suzhou Qizishan domestic waste landfill has been filled with waste and 8 million cubic meters storage capacity is newly increased after the vertical stacking is expanded in 2009. With the increasing of domestic waste every year, the burden of Qizishan landfill and Everbright incinerator is more and more heavy and the current waste treatment facilities can not meet the requirements of social life. Qizishan is the only landfill.

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Once it is filled with waste, the waste solution will be a great problem in Suzhou City and it cannot find a suitable site as the landfill site in Suzhou City currently.

13.3 Consistency Analysis on Important Environmental

Protection Targets

(1) Consistency of Taihu Lake Water Pollution Prevention and Control Regulations of Jiangsu Province According to the Taihu Lake Water Pollution Prevention and Control Regulations of Jiangsu Province, the nearest straight distance of the project to the east coast of Taihu Lake is about 7km and it is not belong to the Level I protection zone of Taihu Lake Basin. The river of water intaking is Xujiang River which is one of the lake outlet water channels, the west end is connected with Taihu Lake by Mudu navigation lock and the east end is connected with Jiangnan Canal. After the concentrated treatment of drainage of the project in the sewage plant of new district, it is discharged into Jiangnan Canal with meeting the standards. According to the regulations, Xujiang River and Jiangnan Canal does not belong to the lake inlet water channels, so the project site does not belong to the Level II protection zone of Taihu Lake Basin. According to the above analysis, the project belongs to the Level III protection zone of Taihu Lake Basin. (2)Consistency of Regional Planning of Jiangsu Important Ecological Function Protection Zone According to the Regional Planning of Jiangsu Important Ecological Function Protection Zone, important ecological targets in the project assessment range are Mudu Scenic Spot and Qizishan Ecological Forest. Through the environmental impact analysis on atmosphere and water and accident risk impact analysis, we can know that the project has no significant adverse effect for above protection targets. In conclusion, the project construction is not against the protection requirement of important environmental protection target.

304 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

13.4 Consistency of Environment Development [2008] No. 82

Regulation

Environment Development [2008] No. 82 regulation proposes relevant requirements in site selection, equipment mode selection, pollutant control, waste collection and transportation, environmental protection distance and public participation for Waste-to-Energy Project. Relevant discussion of the report proposes measures and requirements around them and now we will list to contrast the consistency between the project and requirements of Environment Development [2008] No. 82 regulation. It can be seen in Table 13.4-1. According to the contrast of Table 12.2-1, the project is in line with the relevant planning requirements, and the waste heat value and emission can meet the requirement of the project. Selecting advanced and reliable process and equipment and adopting feasible pollution control measures can guarantee the discharge standards of pollutants. Good environmental quality of project site will not reduce the environmental functions after the establishment of the project. Feasible odor control measures can minimize the surrounding impact and 300m environmental protection distance is set for the project. In general, the environmental risk can be accepted. Public participation result shows that the project has been accepted by most public. Generally, the project is in line with the requirements of Environment Development [2008] No. 82 regulations.

Table 13.4-1 Consistency Comparison Table of the Project with [2008] No. 82 Regulations S/N Document Requirement Implementation The project is located in the Qizishan of Suzhou City (Economically developed and rare Incineration power is adapted to the economically solid resource); according to the actual 1. Plant Site developed regions without sanitation landfill that measurement of the project, the low heat value Selection the average low heat value of waste to the of waste to the incinerator is about 5,415.7kj/kg incinerator is higher than 5,000kj/kg. which meets the requirement that the average low order heat value shall higher than 5,000kj/kg. The project site shall be in line with

305 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited

the specific requirement of “Lack of sanitation landfill and economically developed area”. Planning Consistency: The project The site selection must be line with the overall construction is in line with the relevant planning of the city, land using planning and contents of Suzhou Urban Master Plan environmental sanitation special planning (or (2007~2020) and Professional Plan of concentration disposal planning of city domestic Suzhou on Environmental Hygiene waste); in line with the site requirements of Code (2006~2020). For Urban Environmental Sanitation Facilities About Land Use: The project is expansion Planning (GB50337-2003) and Technical Code engineering and the purpose of project site is for Projects of Municipal Household municipal utilities land which is in line with the Garbage Incineration (CJJ90-2009). land use planning. The project site does not Apart from the forbidden pollution project sites by belong to urban build up area. national and local regulations, standards and Environmental Quality and Impact: Generally policies, the following areas cannot newly build the environmental quality is good in the project Waste-to-Energy Projects: (1) Urban build up area; site and it will not case the environmental (2) the area without effective reduction measures function reduction of surrounding that the environmental quality cannot meet the environmental sensitive target under the requirements; (3) the area that the environmental condition that different pollution control protection target of sensitive area cannot meet the measures are ready during the operation period. relevant standard requirements. It is in line with the site selection requirement of GB50377-2003, CJJ90-2009. The incineration equipment shall be in line with the main indicators and technical requirements of waste solid incineration equipment in Current National Focus on Encouraging and Development Environmental Industry Equipment (Products) Catalogue (2007) (1)Apart from the combustion conventional fuel quality of Waste-to-Energy Project by fluidzed bed Equipment Mode Selection and Pollutant incinerator shall be controlled less than 20% of the Discharge: The project selects mature and total emission into the incinerator, the reliable mechanical reciprocating fire grate Waste-to-Energy Project with the other incinerator incinerator incinerating process. According to 2. Technology cannot be burned with coal. It must be equipped the current relevant monitoring data of and with device of waste and raw coal feed-in record. engineering, the pollutant discharge can meet Equipment (2) Adopting advanced and mature technology and the national discharge standard. equipment from foreign countries, synchronous Heat Supply: The surrounding users without introducing mating environmental protection heat in the project. So the condensing unit is technology and on this premise of meeting the proposed for power generating. national discharge standard, its pollutant discharge limit shall meet the design and operation value of mating pollution control facility of introduced equipment. (3)Waste-to-Energy Project shall first select heat supply unit in the city or region with industrial heat load and heating heat load to increase environmental protection and social benefit.

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Combustion equipment must meet the “Incinerator The incineration equipment adopted by the technical requirements” regulated in the Standard project shall meet the “incinerator technical for Pollution Control on the household garbage requirement” regulated in the Standard for Incineration (GB18485-2001) to guarantee that the Pollution Control on the household garbage acid gases such as SO2, NOX and HCl in the smoke Incineration (GB18485-2001); smoke gas gas and other conventional smoke gas pollutants outlet temperature≥850 , smoke gas residence can meet the “incinerator atmospheric pollutant time≥2S, chimney height≥60m. Adopt SNCR discharge limit” requirement of Table 3 in Standard denitration+half dry type℃ reaction tower+dry for Pollution Control on the household garbage deacidification+activated carbon Incineration (GB18485-2001). adsorption+bag-type dust collector and The project dioxin discharge concentration shall guarantee that the acid gases such as SO2, NOX execute the EU standard (0.1TEQng/m3 in current and HCl in the smoke gas and other phase); denitration device shall be equipped when conventional smoke gas pollutants can meet the the Waste-to-Energy Project is constructed in big “incinerator atmospheric pollutant discharge cities or an area with special control requirement to limit” requirement of Table 3 in Standard for nitric oxide and the other areas shall reserve space Pollution Control on the household garbage of deprivation of nitric oxide; smoke gas Incineration (GB18485-2001). automatically successive monitoring device shall be The project dioxin discharge concentration installed. executes the EU standard (0.1TEQng/m3 in Propose requirement to auxiliary judgement current phase); smoke automatically successive measures of dioxin, have monitoring to combustion monitoring device is installed in the project. temperature in the incinerator, CO and oxygen Have monitoring to combustion temperature content, have networking with local environmental in the incinerator, CO and oxygen content, have protection department and measure the activated networking with local environmental protection carbon consumption. department and measure the activated carbon consumption. The disposal measures of acid and alkaline waste A small emission of leachate sprays, the other water, cooling water sewage and other industrial parts and vehicles, floor flush water is reused 3. Pollutant waste water; waste leachate treatment shall first after the leachate treatment station in the plant. Control consider the spray and the others shall guarantee the The other industrial water is reused completely. drainage to meet the national and local relevant The domestic sewage connecting pipe. discharge standard requirements, waste leachate The project is relying on the leachate accident collection tank with sufficient volume shall collection system 11,000m3 built by current be set; sludge or concentrated solution shall be engineering as the accident buffer facility. incinerated in the plant and cannot be handled after The sludge produced by sewage treatment it is transported outwards. station in the plant is sent to incinerator for incineration. Incineration slug and incineration fly ash collected by dedusting equipment shall be respectively collected, stored, transported and disposed. Generally, the incineration slug is industrial solid waste. The project shall set corresponding magnetic After the solidification of fly ash in the separation device to separate and recover the metal project, if it is identified to meet the for comprehensive utilization, or it shall be stored requirement of entering domestic landfill, it can and disposed by Standard for Pollution Control be sent to the Qizishan landfill; if it cannot on Hazardous Waste Storage (GB18599-2001), meet the requirements, it shall be sent to incineration fly ash is dangerous waste which shall hazardous waste landfill; be stored and disposed by Standard for Pollution Incineration slug is sent to brickfield for Control on Hazardous Waste Storage comprehensive utilization; (GB18597-2001) and Standard for Pollution The domestic waste of workers in the plant is Control on Hazardous Waste Storage disposed in the engineering incineration (GB18598-2001); it encourages the comprehensive system. utilization of incineration fly ash, but the technology shall guarantee the complete damage of dioxin and effective fixation which will not cause secondary pollution during the production and using of product. After the implementation of Standard

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for Pollution Control on Hazardous Waste Storage (GB16889-2007), the disposal of incineration slug and fly ash can be carried out by the new standard. Waste unloading, waste delivery system and waste storage tank adopt enclosed design, waste storage tank and waste delivery system adopt negative pressure operation mode, waste leachate treatment structures shall be disposed Terrible odor control measures: Waste unloading, with coverage and seal. waste delivery system and waste storage tank adopt Deodorization device is set with biological enclosed design, waste storage tank and waste activated carbon and the NH3, H2S after can delivery system adopt negative pressure operation meet the requirements of Ordor Pollutant mode, waste leachate treatment structures shall be Discharge Standard (GB14554-93). disposed with coverage and seal. Under abnormal Under the condition that the plant stops the operation condition, effective deodorization incinerator for inspection or has emergency measures shall be taken. accident, negative pressure is produced by air extraction of roofing fan and the extracting air is discharged through the activated deodorization device after the deodorization to guarantee odor leakage prevention during the inspection period. According to the Professional Plan of Encourage and advocate waste source separate Suzhou on Environmental Hygiene, collection, or subregion collection, the leachate domestic waste can be sorted by combustile produced by waste transfer station shall not enter waste, recycling, harmful waste and large into the incineration plant for improving waste waste; the engineering is not newly added receiving heat value. waste transfer route, form the current waste collection transfer route. The waste transit route of the project in the downtown area is bore by urban road network with wide road surface and good road Waste transit route shall be reasonable, the carrier condition. The transit route makes the impact vehicle shall be enclosed and have the measure of and scale of waste transit in the project to preventing the waste leachate from leakage. It shall sensitive reduce to the bare minimum. Suzhou adopt waste carrier vehicle with compactor which is environmental sanitation agency is responsible in line with the main indicators and technical for carrying the waste transit to the project site. 4. Waste requirements of Current National Focus on All the waste transit vehicles adopt Collection, Encouraging and Development Environmental compression enclosed type self-discharging Transportation Industry Equipment (Products) Catalogue (2007); waste carrier vehicle which is enclosed and and Storage impermeable to prevent the waste leachate leaking. And there is no water environment sensitive target such as drinking water source. Adopt measures of preventing the waste leachate Impermeable layer is equipped in the waste leaking to waste storage pit, and bottom and walls storage pit, and bottom and walls of accident of accident collection tank collection tank. About Odor Prevention and Control: The project adopts compression enclosed-type self-discharging waste carrier vehicle to reduce Adopt effective measures to prevent odor pollutants the odor emission in the transit; waste storage from escaping. pit adopts negative pressure and deodorizer to Dangerous waste shall not be disposed in the reduce the odor emission in the plant. Municipal Solid Waste Waste-to-Energy power About dangerous waste entering into the plant. plant: Strengthen the management and prevent the dangerous waste from entering into the waste incinerator from the very beginning. 5. Environmental impact report shall have special According to the relevant prediction, the dioxin Environmental chapters for environmental risk impact and consider pollutant in the project increases to the

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Risk the impact of dioxin and odor pollutants. surrounding environmental impact compared Accident and risk assessment standard shall be with normal condition, but it can also meet the implemented according to the tolerance acceptable relevant assessment standard requirement that daily intake of 4pgTEQ/kg in human body and is shall less than the tolerance acceptable daily allowable acceptable intake which enters into intake of 4pgTEQ/kg in human body and human body by breath shall be implemented allowable acceptable intake which enters into according to the 10% of tolerance intake. human body by breath shall be implemented According to the given impact scope by calculation according to the 10% of tolerance intake. result, environment risk prevention measures and Under accident condition, discharged odor gas emergency response plan is made to prevent the by exhaust funnel after the purification environment pollution accident from happening. treatment of activated carbon will have less impact on the surrounding environment. To prevent accident and reduce the harm, construction unit shall make environment risk prevention measures and emergency response plan to prevent the environment pollution accident from happening. According to the prediction and combing the requirements of Environment Development According to the fugitive emission source [2008] document, the final environmental calculation result of produced odor pollutants protection distance in the project is 400m out of (Ammonia, hydrogen sulphide , methyl mercaptan west boundary, 300m out of east and south and odor) and considering the environment risk 6. boundaries and 100m out of fly ash assessment conclusion properly, reasonable Environmental solidification workshop without sensitive environmental protection distance is proposed to be Protection targets such as residents within the scope. the control spacing between the project and Distance 800m protection distance range set by hazard surrounding residential area, school and hospital, and waste landfill can contain the protection and basis of planning control. The environmental distance requirements of Qizishan domestic protection distance of renovation and extension waste landfill and Everbright incineration projects shall be over 300m. power plant without sensitive targets such as residents within the range For newly increased pollutant discharge volume in 7, Total the project, regional balance plan must be proposed Volume Project waste gas pollutant will not over the and total volume indicator source must be indicated Control of current approved total volume. Pollutants clearly to achieve “Yield increase, pollutant decrease”. Through different forms of issuing questionnaire, online publication and holding The work shall be carried out strictly according to hearing in the project, public participation the Interim Provisions for Environment investigation is carried out. Investigation public Impact Assessment Public Participation includes cadres, workers, farmers and (Environment Development [2006] No.28) issued surrounding general public of the project. by State Environmental Protection Administration. There is no objection in the received The object of public participation shall include questionnaires. Some requirements and advices impacted public representatives, experts, proposed by some residents are collected: The technicists, basic level governmental organization project shall have high standard pollution 8. Public and representatives of relevant benefited public. prevention and control measures, discharge the Participation The openness of public participation shall be pollutant with standard, reduce the discharge increased and proper forum shall be organized to volume of pollutant and impact of surrounding have communication between public and relevant environment as much as we can; they also personnel. Conclude the public opinions, have require the approval authority to approve timely communication with public with different strictly and strengthen the daily supervision and opinions, feedback the construction to propose management. The construction unit accepts the improvement opinions and finally propose the public opinions, promises to strengthen opinion on the accepting or unaccepting of pubic management after the establishment and opinions. receive the supervision of environmental protection department and public supervision.

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Apart from the relevant requirements of environmental impact assessment guide, we shall focus on the following: (1) Current Situation Monitoring: Monitoring factors are determined according to the discharge standard. Before the incineration power plant is put into operation, Two monitoring points are respectively set on the nearest sensitive point of According to the document requirements, the downwind direction by the prevailing wind environment unit has finished the current direction in the plant and pollutant maximum situation monitoring of dioxin. ground concentration point to have dioxin monitoring of atmosphere; two dioxin monitoring points of soil are respectively set in the up and down wind directions by the prevailing wind direction in the plant and plant soil is recommended to be selected around the maximum ground area of pollutant concentration in the downwind direction. 9. Current (2) Impact Prediction: Before the dioxin Situation environmental quality standard has not been made, Monitoring The environmental quality in the project is referred and Impact to Japan average annual concentration standard (0.6 Prediction of pgTEQ/m3) requirements. Odor pollutant The environmental quality in the project is Environmental environmental impact prediction shall be referred to Japan average annual concentration Quality strengthened. According to the guide requirements, standard (0.6 pgTEQ/m3) requirements. it shall adopt long-term weather condition to Atmospheric environment assessment adopts calculate gradually and every day. The maximum long-term weather condition to calculate standard distance is calculated by environment gradually and every day. The maximum assessment standard and those with proper standard distance is calculated according to the conditions can be determined according to the odor environment assessment standard. concentration investigation and monitoring analogy of incineration power plant with the same process and scale.

(3) Daily Monitoring: When the incineration power plant is put into operation, have a dioxin monitoring of atmosphere and soil to smoke gas discharge and Regularly smoke gas and dioxin monitoring is above current situation monitoring stationing site in required in the environment monitoring plan of order to understand and master the dioxin condition the report after the project is finished. of Waste-to-Energy Project and its surrounding environment. The water use of Waste-to-Energy Project shall be in line with national water use policy. Using the water from urban sewage treatment plant is The project uses surface water. Water recycling 10. Water Use encouraged, and surface water use is limited and in the plant. underground water use is strictly forbidden in North China with insufficient water supply.

13.5 Environmental Impact Analysis

According to the engineering analysis result of this phase, the impact of the project to surrounding environment is mainly atmospheric pollution and the waste gas of the project can be standard discharged with taking effective measures. According

310 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited to the atmospheric environment impact analysis, atmospheric pollutants discharged by the project have little impact on surrounding protection targets. After taking strictly noise reduction measures of sound reduction and insulation to the noise caused by the project, according to the noise environmental impact analysis, boundary noise discharged by the project can reach the standards with little impact on the surrounding protection targets. The waste water of the project is discharged after the taking over treatment and the prediction result shows little impact on the surface water. The final environmental protection distance of the project is 400m out of west boundary, 300m out of east and south boundary, and 100m out of fly ash solidification workshop without sensitive targets within the range. Considering the sanitation protection distance requirement of the other surrounding waste disposal project, 800m protection distance range set by hazard and waste landfill can contain the protection distance requirements of Qizishan domestic waste landfill and Everbright incineration power plant without sensitive targets such as residents within the range. So, the construction unit implements the pollution control measures proposed by the report and the project site is reasonable from the impact of the project to the surrounding sensitive point.

13.6 Analysis on Reasonability of General Layout

According to the requirements for production process, transportation, fire-proof, environmental protection, sanitation, construction and living, the project has overall planning arrangement to all the buildings and structures, pipelines and transit route with combining with natural conditions of plant landform, geology and meteorology for reasonable and tight arrangement, less land, rapid construction, safe and economical operation and convenient maintenance. The following will have the reasonable analysis of plant layout from atmospheric environment, noise and accident risk impact. Atmospheric Environment Impact: The final environmental protection distance of the project is 400m out of west boundary, 300m out of east and south boundary,

311 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited and 100m out of fly ash solidification workshop without sensitive targets within the range. Considering the sanitation protection distance requirement of the other surrounding waste disposal projects, 800m protection distance range set by hazard and waste landfill can contain the protection distance requirements of Qizishan domestic waste landfill and Everbright incineration power plant without sensitive targets such as residents within the range. According to the above predictive result, it shows that the waste gas discharged by the project has little impact on the surrounding ambient air which will not decrease the plot environmental functions of the project. Noise Environmental Impact: Day and night noise predictive value of each boundary in the project all reaches the Level III standard under Emission Standard for Industrial Enterprises Noise at Boundary (GB12348-2008). Accident Risk Impact: Maximum credible accident in the project is set like that: when the mating smoke gas disposal facility of incinerator cannot achieve the normal treatment efficiency, the emergency discharge will happen. According to the predicted accident condition, contribution of regular waste gas (PM10, HCl and dioxin) discharge to ground hourly concentration is much higher than the normal operating condition. However, under abnormal operating condition, after the HCl and dioxin maximum ground hourly concentration caused by the discharge of regular waste gas is added with background, it can also meet the relevant environmental quality standard requirements. So under the accident condition, the dioxin impact can be accepted from the analysis of human health. When the boiler stops operation by the accident or is overhauled, waste storage pit keeps close and the odor gas is discharged into atmosphere after the treatment by activated waste gas purification deodorizing device. Under the accident condition, the discharge of odor pollutant is little and has little impact on surrounding environment. On condition that we strengthen the monitoring, establish risk prevention measures and formulate feasible emergency response plan, the environmental risk of the project can be accepted.

13.7 Summary

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Comprehensive considering the city overall planning, environmental sanitation professional planning, the impact of pollutants discharged by the construction project to surrounding residential area and accident risk impact and on condition that the construction unit implements the pollution control measures, the site selection is feasible and the management shall be strengthened to guarantee stable discharge standard of each pollutant, prevent different pollution accident from happening and improve the emergency measures.

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14 Economic Cost-benefit Analysis

14.1 Economic Benefit Analysis

The project includes 3 sets of 500t/d incineration systems and 2 sets of 15MW turbo generator units which can dispose waste of 1,500t/d every day. Capital estimation of the project includes different process systems and appurtenant production engineering. The economic indicator analysis can be seen in Table 14.1-1 after the design output is reached by the project. From the following Table, we can see that the project has a certain economic benefit.

Table 14.1-1 Economic Indicator Summary Table Numerical S/N Main Indicators Unit Remarks Value RMB Ten 1 Total Investment Thousand 75,159.37 Yuan Investment Pay-back Period Including 2 years 2 Year 10.16 (After-tax) Construction Period Annual Total Power Average Production 3 104kWh 19,015 Generation Year Average Annual Feed-in Average Production 4 104kWh 15,593 Electricity Year RMB Yuan The first 15 years is 5 Feed-in Tariff 0.636 /kWh tentative. RMB Ten Average Annual Revenue 6 Thousand 11,193.6 from Electricity Sales Yuan RMB Yuan 7 Waste Disposal Fee 70 /t Capital Internal Rate of 8 % 10.18 Return Balance Point of Profit and 9 % 59.38 Loss 10 Total Investment Rate of % 6.59 Average Value

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Numerical S/N Main Indicators Unit Remarks Value Return 11 Capital Net Profit Rate % 12.99 Average Value 12 Staff Quota Person 60

The total investment of the project is RMB 751.5937 million. When the waste disposal fee is RMB 70 Yuan/t and feed-in electricity price is RMB 0.636 Yuan / kWh, capital internal rate of return in the project is 10.18% and investment pay-back period is 10.16 years (after-tax); the project is feasible in the finance. In the economic analysis table, sensitive analysis is carried out about factors of power, electricity price, heat and total investment. The project has a certain anti-risk capability. It is greatly supported by government in the later service period and enjoying different preferential treatment of comprehensive utilization of renewable energy which can effectively improve the economic condition of incineration project to make the project have a certain economic benefit with obvious environmental and social benefit at the same time.

14.2 Environmental Benefit Analysis

14.2.1 Environmental Protection Investment Estimation

The 63th regulation of Environmental Protection Design Specifications of

Construction Project points out: “Devices, equipment, monitoring methods and engineering facilities needed by pollution control and environmental protection are all environmental protection facilities” and “The construction projects with environmental protection facilities shall list the investment estimation of environmental protection facilities. The total investment to environmental protection of the project is about RMB 159.6 million including waste gas and noise treatment. See Table 14.2-1 for main investment.

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Table 14.2-1 Main Environmental Protection Investment Summary Environmenta Treatment Control Measure l Protection Effect, Pollution (Number, scale and Investment Executive Category Pollutant Source treatment capacity of (RMB Ten Standard or Facilities) Thousand Proposed Yuan) Requirement 3 sets of flue gas purification system SO , NO , 2 2 (semi-dry reaction PM , HCl, Meets EU Burning 10 tower+dry HF, Cd, 2000 Waste Gas deacidification+activate Hg, Pb, Standard d carbon Dioxin adsorption+bag-type dust collector) Waste Gas 3,500 Boundary Fly ash Concentratio Solidificatio PM Bag-type Dust Collector 10 n meets the n Dust standard Boundary H S, NH Odor of 2 3 Negative Pressure, Concentratio Odor Waste Dodorizer n meets the Gases standard A small amount pH, COD, sprays, and BOD, SS, the others is Ammonia Waste Waste Leachate reused after Nitrogen Leachate Collection System the advanced Pb, As, treatment by Hg, Cd, leachate Cr6+, Cu treatment Waste Water 4,000 plant COD, BOD, SS, Domestic Ammonia Waster Nitrogen, / Take Over Water Total Phosphour s Other Waste pH Neutralization Tank Reuse Water Noise Power - Sound Insulation 260 Boundary

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Environmenta Treatment Control Measure l Protection Effect, Pollution (Number, scale and Investment Executive Category Pollutant Source treatment capacity of (RMB Ten Standard or Facilities) Thousand Proposed Yuan) Requirement Generator Equipment, Silencer is meets the standard add the air inlet and outlet Draught Fan, Add Sound Insulation Forced - Box, Silencer Draught Fan Different Vibration Attenuation, Pump - Sound Insulation Casings Air Sound Insulation, Add - Compressor Silencer Select low-noise type relief valve control Boiler - valve, add silencer and Exhaust adopt vibration attenuation measures General Comprehensive Industrial Slag Utilization and Disposal Solid Waste Fly Ash, Zero Solid Waste Hazardous Waste 450 Discharge of Solidification, Landfill Solid Waste Activated Waste Solid Carbon Domestic Domestic Incineration Disposal in Solid Waste Waste the Plant Select natural clay Waste Storage Pit and impermeable lining, No pollution Leachate Collection single layer synthetics to soil and Impermeable 120 Tank, Fly ash impermeable lining or underground water Solidification Workshop double layers synthetics impermeable lining Landscaping, Greening 30% Plant greening coverage rate is 30% 180 Noise Reduction

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Environmenta Treatment Control Measure l Protection Effect, Pollution (Number, scale and Investment Executive Category Pollutant Source treatment capacity of (RMB Ten Standard or Facilities) Thousand Proposed Yuan) Requirement Prevent the risk accident from happing as much as Accident Establish accident emergency measure and we can and Emergency management system (Leachate accident emergency 160 dispose Measure tank relies on the current 11,000m3) effectivelyto make the accident risk accepted Environmenta l Management Establish environmental management and (Organization, monitoring system; pollution control of 100 Monitoring construction period Capacity) Sewage Sewage separation, waste water pipe network Separation, construction; one exhaust funnel (80m high 3 pipes standardizatio bundling exhaust funnel) n setting of Standardization of Waste Water and Gas sewage A set of flue gas online analyser, a set of pH, COD 500 draining exit monitoring instrument, have real-time monitoring (Flow meter, to pollutants, smoke gas temperature and flow Online velocity, signal is showed in the display screen of Monitoring control room and factory gate Instrument) (1) Have fly ash solidification chelated treatment (2) Improve the combustion control Reduce the system——control the times of turning fire grate, current strictly control the air leakage, reduce the smoke emissions of gas flow velocity to reduce the smoke dust pollutant, the (3) Select the bag with high efficiency dedusting, total “With new to have cleaning and blowing measures for bag to 6,690 emission replace old” guarantee tha the flue gas discharge concentration does not can meet the EU 2000 standard exceed the (4) Add dry deacidification system, spray the current total slaked lime into the flue before the smoke gas goes reply into the bag to reduce the discharge of aicd gas emission such as HCl

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Environmenta Treatment Control Measure l Protection Effect, Pollution (Number, scale and Investment Executive Category Pollutant Source treatment capacity of (RMB Ten Standard or Facilities) Thousand Proposed Yuan) Requirement (5) Upgrading and standard rising modification to leachate treatment station, add advanced treatment process of “Nanofiltration+Reverse Osmosis” Total 15,960

14.2.2 Expected Environmental Effect

The project adopts perfect and reliable waste gas, waste water, noise and solid waste treatment measures to most decrease the pollutants discharged into environment with obvious environmental benefit. It shows that: Semi-dry neutralization reaction tower+dry deacidification are used to eliminate the remaining acid gas in the smoke gas such as SO2 and HCl. After the deacidification, when the heavy metal matters and dioxin in the smoke gas are eliminated by the adsorption of activated carbon, the smoke gas passes the efficient bag-type dust collector and then discharged into atmosphere by draught fan and chimney after the dust is removed. Incineration smoke gas can be discharged with standards. A small amount of leachate in the project is sprayed into the incinerator and the others takes over after the treatment in the mating leachate treatment station; the boundary noise can meet the standards after taking a series of noise reduction measures; solid waste caused by the project is disposed properly or utilized comprehensively. The impact of the “Three wastes” caused by the project to the environment is obviously reduced after reasonable treatment measures. The project uses heat produced by incineration to generate power and recycle domestic waste to get good environmental and economic benefit. The annual disposal capacity of the project is 525,000t and recycles waste heat through the incineration which not only reduces the harm of waste to environment, but also recycles the energy of waste to bring good environmental benefit with great significance in today of energy crisis.

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14.3 Social and Economic Environmental Impact

According to the waste disposal policy of “resource recovery, reduction and harmlessness” in our country, the incineration has become a relatively available urban waste disposal method. In recent years, many cities in China have built incineration power plants and some of them have produced impressive benefit with good operation experience. The project construction is in line with the waste disposal policy in China. First, the incineration of domestic waste can meet the requirements of waste reducing substantially and free a lot of waste stacking areas. Then, lots of harmful materials burned in the incinerator with high temperature become ashes and the toxicity is much smaller. After the proposed project is completed, on one hand, the highlighted city domestic problem can be solved by avoiding lots of wastes stacked on the outskirts of the town which will occupy vast farmland, impact on the landscape, pollute source of water, air and soil environment and cause damage to the living environment of urban and rural residents. After the implementation of the project, current domestic waste problem is solved. On the other hand, the positive cycle of waste resource utilization can improve the local investment environment and play an important role in pushing the local social and economic development with good social benefit. In conclusion, it is an environmental protection project for public benefit. With advantages of thorough harmlessness, obvious reduction and comprehensive utilization of waste heat and slag, the incineration treatment is a good way to solve the disposal problem of urban domestic waste and can meet the increasing demand of urban waste. So the implementation of the project has positive effect on pushing the economic and social sustainable development of Suzhou City.

320 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited 15 Environmental Management and Detection Plan

15.1 Basic Objectives of Environmental Management

Both the construction period and the operating period of this project will affect the ambient environment to a certain degree. Adverse impact on environment must be relieved and eliminated with environmental measures. In order to guarantee feasible fulfillment of environmental measures, and make sure cohesive development among social, economic and environmental benefits of this project, it is necessary to strengthen environmental management in order to make project construction meet the national guidelines for synchronous planning, synchronous development as well as synchronous implementation of economic construction, social development and environmental construction.

15.2 Management Responsibilities and Measures

Based on existing operating experience of the company, there are full-time environmental protection management personnel in charge of environmental management of Everbright Phase III Works, external environmental protection and coordination, as well as environmental monitoring, which are as follows:

15.3 Environmental Management Responsibilities

1 Implement environmental protection regulations and standard; 2 Establish various environmental management systems, check and supervise frequently; 3 Prepare project environmental protection plans and organize the implementation of such plans; 4 Lead and organize the environmental detection work of project and set monitoring files; 5 Thoroughly conduct environmental education and technical training to improve staff quality;

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6 Establish rules and regulations on pollutants discharge and environmental facility operation; 7 Responsible for daily environmental management and coordinate with environmental administration to conduct the coordination of environmental protection issues that is related to other social communities; 8 Make emergency plans for accidents and incidents, and participate in emergency treatment of such accidents and incidents; 9 Regularly check and supervise the implementation of environmental rules and regulations, and contact relevant authorities to implement environmental measures of various aspects in a timely manner to ensure that it works properly; 10Calculate the amount of activated carbon used.

15.4 Environmental Monitoring Responsibilities

1 Make annual environmental detection plan and implementation plan, and establish various regulations and institutions and implement them; 2 Timely complete various detection tasks specified in environmental detection plan, and prepare a report in accordance with relevant regulations, responsible for the submission; 3 When there is any sudden pollution accident in the project, actively participate in the accident investigation and treatment; 4 Responsible for the maintenance, overhaul and check of the detection devices to assure that detection is smoothly conducted; 5 Organize and supervise the implementation of environmental detection plan; 6 Establish project pollution source file that is based on the environmental detection to gain some knowledge of project pollutant emissions,

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discharge source intensity, discharge characteristics and related pollution treatment, comprehensive utilization.

15.5 Environmental Supervision

1 Principle of Environmental Supervision at Design Phase

The overall supervision of project design is design institution’s procedure management. The design institution of this project has come up with perfect examination and approval procedures and implements the policy of “prevention first, combines prevention and control, comprehensive treatment”. Main content of environmental supervision is as follows: The environmental protection measures and plans in Environmental Influence

Report and the needed environmental protection measures’ investment funding budget shall be implemented in initial or design documents of construction drawings. In the construction organization documents, when construction material are transported or piled, the covering measures shall be formulated in the design documents to avoid dust pollution. When construction is conducted in dry season, it shall be formulated that water shall be sprayed periodically or taking other measures. 2 Site Supervisions of Various Pollution Sources at Construction Phase Project Bidding Phase

In project bid document, the environmental protection shall be included in the corresponding articles, and the duplicate shall be sent to the environmental supervision engineer for reference and supervision management when they conduct site supervision. Site Supervision of Various Noise Sources

Site environmental protection supervision engineer shall supervise and check environmental noise of sound-sensitive buildings near the construction site. If the results exceeds environmental noise quality standard that shall be implemented, and residents life is harassed and influence residents’ life quality along the road,

323 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited environmental protection supervision engineer shall inform of the contractor to take noise-reducing measures or adjust machinery construction time. Site Supervision of Ambient Air Pollution Sources

Ambient air pollution sources include: construction sand, stone, mixed material pile dust; Flying dust generated during the material transportation will increase pollution ambient air. The severity of the above pollution sources; affecting ambient air, site environmental protection supervision engineer shall inspect environmental air quality of air sensitive points near the construction site, If the results exceed environmental air quality standard that shall be implemented, environmental protection supervision engineer shall inform the contractor of taking countermeasures and require that it the result should be within the limit value. Site Supervision of Water Pollution Sources

Water pollution sources include: the waste water generated in construction and life sewage discharge by supervision institution’s living place; the waste water discharged by mixing field (station) will directly pollute the pollution-accommodating water. To resolve the problem of above water pollution sources affecting surface water, environmental protection supervision engineer shall supervise and inspect the related items in construction site water environment water quality. If the results exceed environmental water quality standard that shall be implemented, environmental protection supervision engineer shall inform the contractor of taking countermeasures and require that it the result should be within the limit value. Construction Quality Supervision of Environmental Work Facility

The environmental project devices mainly include: flue gas treatment system, waste water treatment device, factory zone greening, etc. The construction of environmental devices is mainly the construction of structure project and parking construction, the construction project quality supervision is project quality supervision engineer and park technology staff’s responsibilities. Whether environmental effect of environmental project meets the requirements for original design or not will be the

324 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited emphasis of environmental supervision. If it didn’t after detection, the contractor shall be informed of taking remedy measures and require that it the result should be within the limit value.

15.6 Environmental Monitoring Plan

The annual budget of Environmental Monitoring is RMB 1.8 million.

15.6.1 Monitoring Objectives

Environmental monitoring is the most important link and technical support in the environmental protection. The object of developing environment monitoring: 1 Inspect the protection of naked construction face and problems of construction dust and construction waste water for timely treatment during the project construction period; 2 Inspect and track the implementation and effect of different environmental protection measures during the operation, master the dynamically change of environmental quality; 3 Understand the operation of project environment engineering facility to guarantee the normal operation of facility; 4 Understand relevant implementation of environmental monitoring in the project; 5 Provide technical support for improving surrounding environmental quality in the project.

15.6.2 Monitoring Scope

The current engineering of incineration plant has been equipped with necessary equipment and instruments which can meet the requirements for the proposed project. Combining with the current engineering atmospheric environment monitoring plan, the proposed monitoring scheme is as follows.

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15.6.2.1 Atmospheric Environment Monitoring

I. Monitoring Plan of Current Pollution Sources 1 The incinerator connected with Suzhou Environmental Protection Agency adopts smoke online monitoring equipment. Discharge volume of smoke blackness of incinerator, HF and heavy metal and its compounds is monitored annually; trust dioxin discharge volume monitoring to qualification unit annually; boundaries fugitive odor is monitored annually; 2 The sampling point of chief discharge opening in the plant has the monitoring objectives of PH, SS, COD, ammonia nitrogen, TP, TN and petroleum quarterly; flow, COD online monitor connected with Suzhou Environmental Protection Agency is equipped; 3 Boundaries noise monitoring annually; 4 There are two monitoring points in the soil which is to monitor PH, Cd, Hg, Pb and dioxin annually; 5 There are three underground water monitoring points in the boundaries to monitor PH, total coil-form, permanganate index, fluoride, ammonia nitrogen, Hg, Pb, Cr6+, Cd, nitrate, nitrite, sulfate, chloride, total dissolved solids, and total bacterial annually.

II. Pollution Sources Monitoring (1) Monitoring Section Online automatically monitoring system is installed in the flue behind the smoke purification system for the engineering waste incinerator. In addition, in the upwind direction and downwind direction, two fugitive pollutant sampling points are established respectively in the boundaries. (2) Monitoring Objectives The monitoring objectives of incineration soot online monitoring system: dust,

CO, SO2, NOx, HCI and temperature. Display screen is set in the plant doorway to

326 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited public online monitoring data. Current the items which cannot be continuous automatically monitored: Fugitive discharge monitoring of atmospheric pollutants is implemented by the requirements for Technical Guidelines for Fugitive Emission Monitoring of Air Pollutants (HJ/T55-2000). (3) Monitoring Frequency

Incinerator dust, CO, SO2, NOx, HCI and temperature is monitored by smoke online monitoring equipment which is required to connect with environmental protection agency. Monitoring period of incinerator soot blackness, HF and heavy metal and its compounds discharge volume: Quarterly. According to ENVIRONMENT DEVELOPMENT [2008] No. 82 Regulation, after the project puts into operation, at least it shall have dioxin monitoring for smoke discharge annually. So it shall trust dioxin discharge volume monitoring to qualification unit annually.

III. Environmental Quality Monitoring

Concentration of PM10, SO2 and NOx shall be sampled and monitored annually in the production and surrounding environment areas (Two protection targets in the downwind direction is selected by the wind direction). According to Environment Development [2008] No. 82 Regulation, two monitoring points (dioxin current situation assessment monitoring point in the project) are set respectively around the nearest sensitive point of downwind direction by the prevailing wind direction all the year in the plant and pollutant maximum landing concentration point to have at least annually dioxin monitoring in the atmosphere.

15.6.2.2 Water Environment Monitoring

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The monitoring objectives in the inlet and outlet of sewage treatment station are:

PH, SS, CODCr, ammonia nitrogen, TP, TN and petroleum, the monitoring period:

Once a day; and flow, CODCr online monitor is equipped. Underground Water Monitoring: Set up a point around the 30m scope of waste pit and two underground water monitoring wells respectively in the upstream and downstream of underground water flow direction, monitoring objectives: PH, fluoride, permanganate index, Cd, Cr6+, Pb, Cu, total Hg, as and nitrate annually.

15.6.2.3 Noise Monitoring

Noises of production area, living area and boundaries are monitored regularly and quarterly every year.

15.6.2.4 Soil Monitoring

Soil in the project site is monitored annually and the monitoring factors are PH, Cu, Zn, Pb, Cd, As, Hg, Cr and Ni. According to Environment Development [2008] No. 82 Regulations, two soil dioxin monitoring points are established in the upwind and downwind directions respectively by the prevailing wind direction of the plant. The monitoring point in the downwind direction is recommended to select the planting soil around the pollutant concentration maximum landing site (Current situation monitoring point can also be selected) annually.

15.6.2.5 Underground Water Monitoring

Established underground water monitoring well is used to monitor PH, total coil-form, permanganate index, fluoride, ammonia nitrogen, Hg, Pb, Cr6+, Cd, nitrate, nitrite, sulfate, chloridate, total dissolved solids, total bacterial count annually.

15.6.2.6 Clinker Monitoring

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Ash and slag discharge volume is monitored once a month.

15.7 Standardization Requirements for Sewage Outfall

The sewage outfall setting must be in line with the standardization requirements for environmental supervision department to sewage outfall. (1) Waste Water Drain Outlet (connected to pipe nozzle) Use the previous waste water drain outlet without newly draining outlet addition. (2) Exhaust Gas Emission Outlet Exhaust gas emission outlet must be in line with the regulated height and the requirements for easy sampling and monitoring in Pollution Source Monitoring Technical Specifications. The chimney or flue of the incinerator shall be equipped with permanent sampling hole and monitoring platform of sampling. Its sampling outlet is determined by authorized environmental monitoring team and central station. (3) Fixed Noise Emission Source Fixed noise is control according to the regulation and sign is set up in the boundaries noise sensitive point which has the most impact on outside. (4) Solid Waste Storage (Disposal) Site Use the special stacking site of current project to have supervision in dangerous waste fly ash regularly produced by incineration with scattering-proof, loss-proof and leakage-proof measures. (5) Requirements for Setting up Signs Environmental protection signs are produced uniformly by the Ministry of Environmental Protection of PRC and purchased from the Ministry of Environmental Protection of PRC by city environment supervision department according to the sewage discharge requirements of enterprises. Pollution outfall layout of enterprise is ordered uniformly by city environment supervision team. Set up presentation signs at ordinary pollutants outfalls (source) and set up warning signs at outfalls discharging poisonous and hazardous pollutants.

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Signs shall be set up at where is near the outfalls (sampling outlets) and notable. The top of the signs shall be 2m below the ground. Set up plane signs at where have buildings within 1m-radius area, and set up vertical signs at where have no buildings. Relevant settings of standardized pollution outfalls (such as graphic signs, metering equipment and monitoring equipment) are environmental protection facilities. The pollution discharge unit shall be responsible for daily maintenance, and no unit or individual shall remove them without permission.

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16 Conclusion and Suggestions

16.1 Project Overview

As the amount of municipal solid waste increases year by year, the burden on Qizishan Waste Landfill and Everbright Waste-to-Energy Project becomes heavier that the current capacity of waste treatment facilities can not meet the requirements for social life of Suzhou City. As the only waste landfill in Suzhou City, once Qizishan Waste Landfill is full, the waste treatment of Suzhou will become a huge issue. And the problem is it’s impossible to find another place for waste landfill in Suzhou at present. All of these will lead to a scenario of the city being surrounded by waste. Therefore, Everbright Environmental Protection Energy (Suzhou) Co., Ltd. is planning to construct the Phase-III Expansion Work with design capacity of three 500t/d mechanically reciprocating furnaces and two 15MW generating units. Total engineering investment is RMB 750 million and total environmental protection investment is RMB 159.6 million. The capacity of domestic waste incineration of entire plant will be 3,550t/d after the project is established.

16.2 Ambient Quality Situation and Main Environmental

Protection Objectives

16.2.1 Ambient Quality Situation

Air Environment Quality: The detection results generated by Jiangsu

Environmental Detection Station indicate that the hourly concentration of SO2, NO2,

H2S, CO and NH3 at each detection point can meet the Class-II standards under

Ambient Air Quality Standard, and the average daily concentration of PM10, SO2, NO2,

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CO and Fluoride can also meet and exceed the Class-II standards under Ambient Air Quality Standard. And no Hg or fluoride is tested. The hourly concentration of HCI exceeded the standard rate at Qizi Lot, Gusu Village and former Lita Village respectively, and the excessive rate was 3.6%; the investigation indicates that there are HCI emission enterprises around the detection area such as Suzhou Wusheng Steel Co., Ltd. and Chunhua Wiredrawing Co., Ltd.; according to the environmental assessment report on Phase-II, before Phase-II construction, HCI also exceeded the standard rate at Mudu Town and Gusu Village within the assessment area, and the detection results of this year have become better than those of 2007. Considering that the Everbright Phase-III Expansion Work will improve the existing Phase-I and Phase-II Works that it might reduce HCI emission, therefore, the environmental concentration of HCI will be further reduced. Water Environment Quality: According to detection results, sulfide, fluoride and volatile phenol at sections W1, W3 and W4 can meet relative standards, while ammonia nitrogen, total nitrogen, total phosphorus and ss at section W2 fail to meet the standards, and other detection factors can all meet Class-IV water quality standard under Environmental Quality Standards for Surface Water (GB3838-2002). Because ammonia nitrogen, total nitrogen and total phosphorus of Taihu Lake fail to meet the standards to a large degree, Suzhou has prepared a Taihu Lake treatment plan, and also stipulated treatment plans and requirements for Suzhou section of Jiangnan Canal, so that water quality has been improved. Acoustic Environment Quality: Acoustic environment quality of where the factory will be established is relatively good. Noise values at day and night measured at each detection point can meet Class-III standard under Environmental Quality Standard for Noise (GB3096-2008). Underground Water Quality: According to Quality Standard for Ground Water (GB/T14848-1993), underground water quality can meet Class-III standard. Soil Quality: Indexes of heavy metal in soil can meet Class-II standard under the national Environmental Quality Standard for Soils (GB15618-95), indicating that current state of soil environment quality of this area is relatively good.

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Dioxin concentration: According to detection results, dioxin atmosphere concentration and soil concentration around this project can meet relative standards. Current states of ambient air and surface water environment are better that those before Phase-II Work construction. The data of underground water and soil detection factors doesn’t change much, indicating that current work does not affect the environment that much.

16.2.2 Main Environmental Protection Objectives

The protection objectives by this project refer to Table 16.2-1 and 16.2-2.

Table 16.2-1 Environmental Protection Objectives Table Environmental Name of Environmental Environmental Direction Distance (m) Scale Remarks Factors Protection Objective Functions Mudu Town (Old Town 200,000 WNW 2,600-6,300 Area) Persons 3,600 Former Gusu Village W 2,000 Households 20 Qizi Lot, Gusu Village N 1,200 Now as Air Households Class-II under Gusu Environment Fenghuang Lot, Gusu 3,100 GB3095-1996 SW 1,650 Village Village Households Suzhou University of 7,500 E 2,300 Science and Technology Persons Shangfangshan Forest SE 1,600 5.002 km2 Park Acoustic Class-II under Factory Boundaries — — — Environment GB3096-93 Class-III Xujiang River N 1,500 — under Surface Water GB3838-2002 Jiangnan Canal NE 5,000 — Class-IV

Table 16.2-2 Important Ecological and Environmental Protection Objectives Table S/N Name Main Ecological Functions 1 Mudu Scenic Area Natural and Cultural Landscape Protection

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Qizishan Ecological and Public Headwater Conservation and Biodiversity 2 Welfare Forest Protection

16.3 Main Pollution Prevention Measures

16.3.1 Exhaust Gas Treatment Measures

(1) Exhaust Gas Incineration Exhaust gas generated by this project refers to flue gas generated by waste incinerator, including plenty of pollutants, such as acidic exhaust gases (SO2, HCl, HF, etc.), dust, NOX, CO, heavy metal (Hg, Cd, Pb, etc.) and dioxin. For exhaust gas treatment, this project applies SNCR denitration + semi-dry reaction tower + dry deacidification + activated carbon adsorption + bag-type dust remover to each incinerator. This project will set up an 80m-high three-pipe clustered exhaust stack. In order to reduce the impact on environment as much as possible, the enterprise will take exhaust gas treatment measures, and make various pollutants meet EU 2000 emission concentration standards, which is way better than the Standard for Pollution Control on the household garbage Incineration (GB18485-2001). (2) Odor Offensive odor of this project mainly comes from the waste, basically referring to waste storage pits, waste unloading halls, leachate storage pits and incinerators. To avoid offensive odor coming out, this project will take the following control measures to main offensive odor pollution sources including waste storage pits and waste unloading halls: Apply compressive and enclosed type waste tippers to deliver waste. Install waste unloading doors at the entrances and exits of unloading platforms at main building of waste incineration factory. Waste storage pits shall be airtight with suction opening on the roof. Primary air for combustion supporting of three incinerators shall be extracted from the top of waste. Under normal operating conditions, waste storage pits shall in a slight negative

334 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited pressure state to avoid offensive odor escaping. Install exhaust fans on top of the waste, which shall be started up during incinerator shutdown, to avoid combustible accumulation (such as methane) during incinerator shutdown. Air extracted shall be deodorized with activated deodorization equipment and then emitted. Operate and mange waste repository by standards to reduce the amount of offensive odor generated. By stirring and flipping the waste with grab bucket, anaerobic fermentation of waste can be avoid, and thus the amount of offensive odor can be reduced. Use airtight residue delivery system for airtight and negative pressure operation of residue storage pits. Offensive odor will be sent to waste storage pits through exhaust fans as primary air for combustion. During operation process, offensive odor is mainly controlled by enhancing the management, such as try to reduce the factory shutdown rate, guarantee ordinary operation of primary exhaust system, use closed vehicles as waste vehicles for entering the factory, close the unloading doors of waste storage pits while they are not on duty, and make the waste storage pits closed, etc. (3) Fugitive Fly Ash Solidification Dust Fly ashes generated by incineration process of this project will be sent to fly ash solidification equipment. The solidification process is completely closed. A certain amount of fly ashes after dust emission will enter the atmosphere, and then be emitted from the roof after being dedusted with bag-type dust remover.

16.3.2 Waste Water Treatment Measures

This project applies clean (rain) water and sewage separation system. A slight amount of leachate will be back sprayed to the furnace, while the remaining leachate will flow into the corresponding leachate treatment station together with floor and vehicle wash water. After being deeply treated and meeting the reclamation water quality standard, it can be reused as the make-up water for

335 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited circulation and cooling. Domestic sewage is piped to the sewage treatment plant in new area. The waster discharged by chemical water treatment system is partially used for preparing slurry with lime, and partially used for preparing formulas in brick yard. And the remaining is used to spray on roads and unloading platforms; water discharged by cooling towers is reused as slag-off cooling water.

16.3.3 Noise Treatment Measures

Noise sources of this project mainly refer to air force equipment such as blower fans, as well as water pumps and cooling towers. The project will apply low-noise equipment, sound-insulated doors and windows, shock-resistant machine bases, as well as enhance afforestation to reduce noise impact.

16.3.4 Solid Waste Treatment Measures

The slag generated by this project will be delivered to corresponding brick yard for comprehensive utilization. Fly ashes generated by this project first have to be solidified. If the inspection on solidified fly ashes shows that they meet the requirements for entering the landfill, they can be delivered to Qizishan Domestic Waste Landfill; if they do not meet such requirements, they still have to be sent to Suzhou Hazardous Waste Landfill for safety concerns. Other solid wastes mainly include the sludge and domestic wastes in sewage treatment plant of the factory, which shall be disposed in factory incineration plant.

16.4 Environmental Feasibility

16.4.1 Industrial Policy Compliance

This project will construct a domestic waste incineration power plant, which is one of the projects encouraged by the National Development and Reform

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Commission under Directive 40 Guideline Catalogue for Industrial Restructuring

(2011), which is a project for “38-environmental protection and resources conservation and comprehensive utilization; 20-urban waste and other solid waste reduction, resources-turning, and without hazards treatment and comprehensive utilization”. It is also one of the projects encouraged under Guidance Catalogue for Industrial Structure Adjustment of Jiangsu Province, which is a project for “urban waste and other solid waste reduction, resources-turning and without hazards treatment and comprehensive utilization.

This project meets the provisions under “Clause 6 Environmental Protection and Comprehensive Resources Utilization” of Priority Development High-tech Industrialization Key Field Guide (2004) stipulated by the National Development and Reform Commission, the Ministry of Science and Technology of PRC as well as the

Central People’s Government of PRC. This project generates electricity by incinerating waste, and it also controls the amounts of various pollutants discharged meet the standards. So this project meets the provisions under “3.2 encourage waste incineration, waste heat utilization, landfill gas reclamation and utilization, as well as high-temperature compost of organic waste and making methane with anaerobic digestion”, and “3.3 avoid and control secondary pollution during waste reclamation and comprehensive utilization” of Technological Policy for Treatment of Municipal Solid Wastes and Its Pollution Prevention jointly issued by the Ministry of Housing and Urban-Rural Development of PRC, the Ministry of Environmental Protection of PRC, as well as the Ministry of Science and Technology of PRC (on May 29, 2000). Therefore, the construction of this project can meet the requirements under industrial policies.

16.4.2 Planning Compliance

This project meets the requirements under Suzhou Urban Master Plan (2007~2020) and Professional Plan of Suzhou on Environmental Hygiene

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(2006~2020).

16.4.3 Analysis on the Compliance with Important Environmental

Protection Objectives

In accordance with Taihu Lake Water Pollution Prevention and Control Regulations of Jiangsu Province and Regional Planning of Jiangsu Important Ecological Functions Protected Areas, the construction of this project does not conflict with the protection requirements for important environmental protection objectives.

16.4.4 Compliance with HuanFa [2008] 82 Document

According to Environment Development [2008] 82 Document, this project meets the requirements in terms of location selection, technologies and equipment, pollutants control, environmental prevention distance, control of pollutant emissions, and public participation.

16.5 Analysis on Clean Production

This project uses mechanically reciprocating furnaces to incinerate domestic waste. It bears mature technology, high equipment safety coefficient, and low equipment manufacturing and operating costs; delivers fully mechanical and automatic operation; applies to domestic waste a lot; and reaches domestically advanced level in terms of energy consumption, pollutants control and discharge. This project follows the trend of waste treatment industrialization that it reduces the amount of waste discharge (more than 85%), turns waste into resources (sell 156,000,000 kilowatt-hour electricity and comprehensively use slag), and becomes hazardous by generating electricity with waste heat produced by waste incineration.

By taking the measure of “using the new work to promote the old ones”, the Expansion Work has reduced the amount of pollutants discharged, increased water

338 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited reclamation rate, reduced fresh water consumption, and realized recycling utilization.

16.6 Environmental Impact Forecast Results

16.6.1 Atmospheric Environmental Impact Analysis

With normal discharge of regular exhaust gases, all the maximum fall-to-the-ground hourly concentration values plus background values of SO2, PM10,

NO2, CO, HCI, HF, Cd, Pb, Hg and dioxin generated by this project can meet relavent environmental quality standards. With normal discharge of regular exhaust gases, exhaust gas pollutants discharged and reaching the standards do not contribute to various exhaust gas pollutants at sensitive points around that much, and being added up with background values, all sensitive points can meet relevant environmental quality standards and requirements. By starting this project, the maximum average daily concentration contribution values plus background values of various pollutants can meet relevant environmental quality standards. With normal working conditions, regular exhaust gases do not contribute to ambient sensitive points that much, and after being added up with background values, they can meet relevant environmental quality requirements. By starting this project and with normal working conditions, the average annual concentration contribution values of regular exhaust gas pollutants can meet relevant environmental quality requirements. With normal working conditions, the maximum average annual concentration contribution values of regular exhaust gases discharged to each and every concerned point meet the standards, and do not affect the ambient environment that much. Final environmental protection distances of this project are 400m away from western boundary, 300m away from eastern and southern boundaries, and 100 away from fly ash solidification workshop. Within this area, there are no sensitive protection objectives. Also considering the sanitary protection distance requirements

339 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited for surrounding waste treatment projects, the 800m-radius protection area for hazardous and waste landfill can include Qizishan Domestic Waste Landfill and Everbright Domestic Waste Incineration Power Plant, where there are no sensitive points such as residential communities. For foul gases after being effectively deodorized, the concentration within factory boundaries can meet the standards; under the conditions of maintenance and furnace shutdown, the emission of foul gases after being deodorized will not significantly affect the environment. In summary, the exhaust gases emitted by this project hardly affect the ambient air and will not cause the regression of environmental functions of the land block where this project is located.

16.6.2 Surface Water Environmental Impact Analysis

A slight amount of leachate will be back sprayed to the furnace, while the remaining leachate will flow into the corresponding leachate treatment station together with floor and vehicle wash water. After being deeply treated and meeting the reclamation water quality standard, it can be reused as the make-up water for circulation and cooling. After the leachate treatment station taking the measure of raising standard and reforming by “using the new work to promote the old ones”, the amount of waste water discharge of the entire factory has been significantly reduced. Domestic sewage is piped to the sewage treatment plant in new area. The waster discharged by chemical water treatment system is partially used for preparing slurry with lime, and partially used for preparing formulas in brick yard. And the remaining is used to spray on roads and unloading platforms; water discharged by cooling towers is reused as slag-off cooling water. After being treated by the sewage treatment plant in new area, water discharged by this project will hardly affect the surface water environment.

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16.6.3 Acoustic Environmental Impact Analysis

By being added up with the background value, the impact contribution value of the noises within factory boundaries during the day (forecast point) can meet Class-III standard under Emission Standard for Industrial Enterprises Noise at Boundary (GB12348-2008).

16.6.4 Solid Waste Environmental Impact Analysis

All solid wastes generated by this project will be recycled or reused in an appropriate or comprehensive way. This project will strictly implement solid waste storage and disposal standards according to relevant national and local rules and regulations, by doing so, it will not bring adverse impact on the environment.

16.6.5 Underground Water Environmental Impact Analysis

Anti-seepage measures have been taken in areas where possible seepage will happen, especially waste repository and leachate pond. Therefore, underground water around the factory will be affected slightly.

16.6.6 Risk Assessment

The maximum credible accidents of this project are set to be accident emission due to semi-dry flue gas treatment equipment corresponding to incinerators can not reach normal treatment efficiency, as well as accident emission of offensive odor. Under abnormal working conditions, the hourly concentration contribution values of regular exhaust gases PM10, HCI and dioxin emission to the ground are significantly higher than those under normal working conditions. The hourly concentration contribution values of regular exhaust gases PM10, HCI and dioxin emission to the ground plus background values can still meet relevant environmental quality standards and requirements. Within the assessment area, the maximum hourly ground concentration contribution values of PM10, HCI and dioxin at each and every

341 Municipal Solid Waste Waste-to-Energy Project Phase III Expansion, Everbright Environmental Energy (Suzhou) Limited sensitive point are higher than those under normal working conditions. However, after being added up with background values, they still can meet relevant environmental quality standards. Therefore, considering human health under accident conditions, the impact of dioxin is still acceptable. During boilers shutdown or maintenance due to accidents, waste storage pits shall be closed, foul gas shall be treated with activated carbon waste gas purification and deodorization device and then discharged to the atmosphere. In case of accidents, the discharge amount of foul pollutants is relatively small, thus it does not affect the ambient environment that much. Therefore, by enhancing monitoring, establishing risk prevention measures, as well as preparing feasible emergency plans, the environmental risks of this project will be acceptable.

16.7 Emission Control

With the measure of using the new work to improving the old ones, the Phase III Expansion Work will not contribute to the emission of waste gas pollutants of the entire factory, and will reduce the discharge amount of waste water pollutants which will be balanced within current emission as approved. All industrial and ordinary solid wastes of the entire factory are treated and disposed in a reasonable manner, so that zero discharge of solid wastes is realized without applying for emission.

16.8 Public-participated Investigation

Public participation in this project will be conducted in the forms of internet publicity, newspaper publicity, handing out public-participated questionnaires and holding public-participated hearings. No feedbacks were received during internet publicity, and no objections rose during public-participated questionnaires and hearings. In general, the public support the construction of this project.

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16.9 Final Conclusions on Environmental Assessment

In conclusion, the completion of Phase-III Expansion Work of Everbright Environmental Protection Domestic Waste Waste-to-Energy Project will be able to solve the problem of increasing domestic waste in urban Suzhou, as well as the problems of environmental pollution and land occupation caused by waste landfill.

It’ll be in favor of improving regional environmental quality in general, turning waste into resources, as well as promoting the development of recycling economy. This project meets the requirements under national industrial policies; its location meets the requirements under relative local planning; clean production techniques are applied during production process; pollution prevention measure applied are technically and economically feasible; the project can guarantee steady and standard pollutant emission that the measure of “using new work to improve the old ones” can reduce pollutant emssion, so that total pollutant discharge amount of the entire factory will not exceed current emission approved; it’s also estimated that the pollutants discharged by this work in accordance with the standards will hardly affect the ambient environment and environmental protection objectives. Upon carefully fulfilling the requirements for various environmental protection measures stipulated by this report, and strictly taking the “three at-the-same-time” environmental protection measures, the construction of this Project is environmentally feasible.

16.10 Suggestions and Requirements

1 Make sure the environmental protection funds are received and various pollution treatment measures are taken. 2 No sensitive buildings including residential buildings, schools and hospitals shall be constructed within sanitary protection area. 3 Enhance communication with the public within the affected area and

strive to obtain the public’s understanding and support.

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