E2813

Framework Environmental Assessment for BAT/BEP

Adoption towards Reduction of UPOPs Releasing

from Non-wood Pulp and Paper Sector in China

委托单位：环境保护部环境保护对外合作中心 编制单位：北京师范大学 李巍 编制日期：2009 年 12 月

ABBREVIATIONS

BAT/BEPBest Available Technologies and Best Environmental

Practices

ECF Elemental Chlorine Free

EIA Environmental Impact Assessment

EMP Environmental Management Plan

FEA Framework Environmental Assessment

NGO Non-government Organizations

NIP National Implementation Plan

NWPM Non-wood Pulp and Paper Making

TCF Totally Chlorine Free

TOR Terms of Reference

UPOPs Unintentional Persistent Organic Pollutants

WB World Bank

AOX Absorbable Organic Halogen

BOD5 Biochemical Oxygen Demand (5days)

COD Chemical Oxygen Demand

DBD Dibenzo-p-dioxins

DBF Dibenzo-p-dioxins

PCDD Polychlorinated Dibenzo-p-dioxins

PCDF Polychlorinated Dibenzo-furans

POPs Persistent Organic Pollutants

SS Suspended Solids

PM10 Particulate Matters with diameters less than 10µm

TSP Total Suspended Particulates

Contents

1 Brief Description of Project..............................................................................................1

1.1 INTRODUCTION.......................................................................................................................1

1.2 NWPM AND ITS MAJOR ENVIRONMENTAL PROBLEMS........................................................1

1.3 PURPOSE OF ENVIRONMENTAL ASSESSMENT........................................................................4

1.4 INSTITUTIONAL FRAMEWORK OF ENVIRONMENTAL ASSESSMENT.......................................5

2 Law and Regulation Framework.....................................................................................6

2.1 RELEVANT DOMESTIC LAWS, REGULATIONS, AND POLICIES...............................................6

2.1.1 Laws and Regulations...................................................................................................6

2.1.2 Industry and Environmental Protection Policies.........................................................19

2.1.3 Environmental Standards............................................................................................24

2.2 RELEVANT DOMESTIC TECHNICAL GUIDELINES.................................................................27

2.2.1 Environmental Impact Assessment Technical Guidelines............................................27

2.2.2 Technical Specifications for Cleaner Production........................................................30

2.3 ENVIRONMENTAL PROTECTION POLICIES AND ENVIRONMENTAL ASSESSMENT GUIDES OF

THE WORLD BANK...............................................................................................................33

2.3.1 Environmental Assessment Guide System of the World Bank......................................33

2.3.2 Special Requirement of the World Bank for EIA of Papermaking Projects.错误！未定

义书签。

3 Guide for Preparing and Implementing BAT/BEP Environmental Assessment........35

3.1 RESPONSIBILITY SUBJECT AND ASSESSMENT PROCEDURE OF EIA...................................35

3.1.1 Responsibility Subject.................................................................................................35

3.1.2 Environment Impact Assessment Procedures..............................................................38

3.2 PREPARATION OF ENVIRONMENTAL ASSESSMENT..............................................................40

3.2.1 Environment Impact and Risk Identification...............................................................40

3.2.2 Baseline Survey...........................................................................................................43

3.2.3 BAT/BEP Environmental Impact Analysis..................................................................49

3.2.4 Environmental Management Plan...............................................................................56

3.2.5 Public Involvement and Information Disclosure.........................................................60

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3.3 EMP IMPLEMENTATION........................................................................................................62

3.3.1 Institutional Arrangement...........................................................................................62

3.3.2 Supervision and Inspection.........................................................................................63

3.3.3 Environmental Monitoring Program...........................................................................67

3.3.4 Information Record and Report..................................................................................71

3.3.5 Training Program........................................................................................................72

Annex 1 TOR for Environmental Assessment of BAT/BEP plan in an NWPM Project........75

Annex 2 NWPM EMP Template.................................................................................................79

Annex 3 Mitigation and Management Measures against General Environmental Impacts of

BAT/BEP Plan................................................................................................................84

Acknowledgement........................................................................................................................88

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1 Brief Description of Project

1.1 IntroductionIn National Implementation Plan (NIP) of the People’s Republic of China for

Stockholm Convention on Persistent Organic Pollutants, pulping and papermaking industry has been included in the first six major industries chosen for dioxin release reduction. Due to the scarcity of timber resources, non-wood fiber pulping enterprises take a great proportion in this sector in China. These enterprises, comparatively small in size and weak in technology and management, are regarded as among heavy producers of unintentional persistent organic pollutants (UPOPs) and other pollutants. Ever since 1980s and 1990s, researches have discovered that many producing steps in non-wood pump and paper making (NWPM) may emit persistent organic pollutants (POPs); however given the general industry development level and the state’s pollutant release reduction focus, which was directed toward ordinary pollutants, the entire industry has taken few technical or management improvement to control POPs. After China’s accession to Stockholm Convention on Persistent Organic Pollutants, POPs release reduction and control have become an important component of China’s environment objectives; meanwhile, pursuant to Article 5 of the convention, each contracting party shall make and implement an action plan that takes the application and promotion of best available techniques and best environmental practices (BAT/BEP) guidelines as the core in their effort to realize the release reduction and control of unintentional persistent organic pollutants like dioxin. Under such a background, a few Chinese papermaking enterprises embarked on BAT/BEP pilot work. During 2005~2007, with the support of Italian financial grant, Foreign Economic Cooperation Office (FECO) under the Ministry of Environmental Protection of China implemented a project entitled Sino-Italian Cooperation Strategic Project of By-products Release Reduction of Unintentional Persistent Organic Pollutants in China, which involved the BAT/BEP technique pilot work of two papermaking enterprises from Shandong Huatai Paper Group and Hunan Tiger Forest & Paper Group respectively. These technique pilot projects have preliminarily short-listed some most feasible techniques available for reed pulp and straw pulp papermaking.

1.2 NWPM and Its Major Environmental ProblemsIn worldwide papermaking industry, timber takes a proportion over 90% in

pulping fiber raw materials (excluding wastepaper); while in China, because of the scarcity of forest resources and the abundance of non-wood fiber resources, non-wood fiber has always been an important papermaking raw material in this country. In spite of an upward trend of wastepaper and wood pulp consumption in China, non-wood fiber pulp still has a high proportion in pulp consumption.

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0. 000. 200. 400. 600. 80

2005 2006 2007 2008

Non-woodpul pWood pul p

Wastepaperpul p

Figure1-1 Consumption of paper pulps divided by source characters

A lot of non-wood raw materials may be used for paper making, including reed, awn, bamboo, bagasse, wheat straw, rice straw, common rush, hemp, and cotton, etc. Non-wood pulp paper making (NWPM) falls into different categories depending on different non-wood pulp raw materials; presently, one may identify four NWPM categories in China: straw pulp, bamboo pulp, reed pulp, and bagasse pulp papermaking. Judging from the data from 2007 to 2008, it can be concluded that these four raw materials remains relatively stable in their proportion of NWPM: bamboo pulp and reed pulp have increased somewhat, bagasse pulp remain stable, while straw pulp has dropped slightly.

Table1-1 Consumption quantity and proportion of non-wood pulps

Year Description Reed pulp

Bagasse pulp

Bamboo pulp

Straw pulp

Others Total

2007

Consumption

(10k ton)

144 90 120 849 99 1302

Proportion out of non-wood pulp (%)

0.11 0.07 0.09 0.65 0.08 1.00

2008

Consumption

(10k ton)

150 97 146 808 97 1297

Proportion out of non-wood pulp (%)

0.12 0.07 0.11 0.62 0.07 1.00

Papermaking industry is a great polluter. Its major environmental problems are water pollution and atmosphere pollution generated during its production process.

(1) Water pollutionPapermaking emits a great deal of wastewater. According to China

environmental statistics, Chinese papermaking industry contributed 19.2% of the nationwide industrial wastewater emission in 2007, ranking top among all the industrial sectors. A great amount of cellulose, lignin, inorganic base, tannin, resin, and protein are present in the wastewater, making the wastewater dark in chromaticity,

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high in alkalinity, rich in hard-to-degrade substances, and large in oxygen consumption; this may result in the pollution of the entire water body or serious destruction of ecological environment.

Papermaking wastewater may be largely classified into three types during the production process: pulping effluent (black liquor, red liquor, etc.), middle-stage wastewater (including cleaning, purification and bleaching water), and papermaking machine white water. Black liquor (red liquor) is a cooking effluent of chemical pulping, including black liquor generated during alkaline process and red liquor generated during acid polishing. Pollutants contained in black liquor (red liquor) exceed more than 90% of the total pollution released by papermaking industry; into the bargain, the liquor is highly concentrated and hard to degrade. Typically, the production of 1t sulfate pulp will release 1t organic substances, 400kg bases and sulfides, which are dissolved into the black liquor; the production of 1t sulfite pulp will see 900kg organic substances and 200kg oxides (calcium, magnesium, etc.) and sulfides dissolved in the black liquor. Middle-stage water is the effluent released by cooking sizing material, which is extracted from the black liquor, during such processes like screening, washing, and bleaching; this type of water, being dark yellow in color, accounts for 8~9% of papermaking pollution emission; the COD load per ton of pulp is around 310kg. Among them, the No. 1 environmental polluter is chlorine-containing wastewater generated during bleaching process, such as chlorate bleaching wastewater and hypochlorite bleaching wastewater, etc. Hypochlorite bleaching wastewater mainly contains chloroform as well as 40-plus other organic chlorides, among which chlorophenol ranks top, followed by dichlorophenol and then by trichlorophenol. Elemental chlorine bleaching (chlorine or hypochlorite) wastewater contains hypertoxic dioxin, a carcinogen posing great hazard to ecological environment and human health. White water, namely papermaking stage effluent, is generated by a paper mill during papermaking process. White water mainly contains minuscule fibers, filler, paint, and dissolved wood ingredients, plus glue, wet strength agent, preservative additives; they are mainly insoluble CODs and have a low biodegradability; the added preservatives are toxic. Up to now, black liquor recovery and treatment technology has been refined and the pollutants in black liquor can be appropriately treated; in addition, white water can be recycled in a partially or completely enclosed manner. In summary, the principal pollution source in papermaking industry is the middle-stage water. In NWPM sector, water pollution is significantly higher than wood pulp papermaking in that the former is typically small in size, underdeveloped in technology, low in black water extraction and alkali recovery, and high in water consumption.

(2) Air pollutionTwo categories of atmosphere pollutant are associated with papermaking, namely

odor and dust. Odor pollutants mainly include H2S, CH3SH, CH3SCH3, CH3SSCH3, SO2, SO3, NOx, etc. Dust is largely contributed by alkali recovery furnace dust

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(Na2SO4 and Na2CO3), sodium compounds in melts dissolving tank, and coal-fired boiler soot, etc.

(3) Solid waste pollutionSolid wastes generated during NWPM process fall into two broad categories:

inorganic wastes and organic wastes. Inorganic wastes mainly include waste solids generated by power boiler and white sludge generated during causticization section. Organic wastes mainly include grass chips, dust, bagasse pith, pulp screen slag, and wastewater sludge, etc.

In addition to releasing “three wastes” (wastewater, waste gas, and waste solids), papermaking industry may lead to forest felling or immoderate exploitation of vegetation in order to supply raw fiber materials to paper mills, thus bringing unfavorable impact on the environment, resulting in serious environmental consequences like forest destruction, vegetation degradation, soil erosion, and biology and ecotope degradation.

1.3 Purpose of Environmental AssessmentIn line with the performance of obligations by China, more and more non-wood

pulp and paper making (NWPM) enterprises must undergo BAT/BEP transformation in favor of POPs release reduction. According to the provisions of Article 24 of Chapter III of Environmental Impact Assessment Law of the People’s Republic of China (2003), environmental impact assessment (EIA) is mandatory for any construction project undergoing rebuilding, expansion, or major production technology and process variation. The implementation of BAT/BEP measure plan by an NWPM enterprise will necessarily involve production technology and process variation, therefore prediction and appraisal shall be made of the resulting environmental impact change. Meanwhile, in order to compare and then select best environmental BAT/BEP measure plan, it is necessary to conduct a systematic environmental assessment of the reduction effect of UPOPs and the associated indirect environmental impact and risks of different alternative plans. To this end, it becomes necessary to identify, analyze, and assess the possible environmental impact after the implementation of BAT/BEP measure plan. In addition, appropriate environmental assessment technical process and framework will be prepared for NWPM enterprises that adopting BAT/BEP measure plan so as to provide guidance in the next step of technical transformation EIA. This framework document specifies the scope of environmental assessment, relevant stipulations, and concerned institutions or departments, and should guarantee that EIA respects Chinese environmental assessment laws and regulations and also satisfies papermaking industrial technology, environmental protection policies, and local environmental protection standards.

1.4 Institutional Framework of Environmental AssessmentSince 1980s, China has progressively established an environmental protection

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legal system on the basis of Constitution of the People’s Republic of China and following the general principle of Environmental Protection Law of the People’s Republic of China. This legal system incorporates pollution prevention laws, resources and ecological protection laws, and disaster prevention and reduction laws, etc. On the basis of this legal system, China promulgated Environmental Impact Assessment Law of the People’s Republic of China and a spectrum of EIA technical guidelines to guide and regulate EIA work.

On the principle of human orientation and sustainable development, the World Bank requests that any project soliciting finance from it must have environmental assessment. The World Bank has put in place relevant operation policies and ten safety guarantee policies, including OP/BP 4.01—Environmental Assessment.

BAT/BEP transformation by NWPM for UPOPs release reduction is a kind of technology and management innovation made by a special industry for special pollution control. Therefore, environmental assessment of BAT/BEP transformation must be performed within the Chinese environmental assessment legal framework and shall at the same time satisfy papermaking industrial technology, environmental protection policies, and local environmental protection standards.

BAT/BEP environmental assessment may deal with the following key stakeholders: governmental environmental protection authorities and industrial administrative authorities, enterprises, industrial research organizations, environmental assessment agencies, the World Bank, and the general public and NGOs. Among them, an enterprise is the BAT/BEP player, and an environmental assessment agency is action-taker of BAT/BEP environmental assessment. Industrial research organizations are researcher and developer and provider of BAT/BEP technology whilst industrial administrative authorities are the maker of technical standards. An environmental administrative authority acts as both the approver of environmental assessment and the supervisor of enterprise environmental action, because it has the responsibility of reviewing and approving project environmental assessment report, supervising the implementation of mitigatory measures during project execution, and is also charged with environmental protection acceptance upon the completion of works and monitoring per-standard emission during production stage. The public and NGOs are stakeholders and also watchdogs of BAT/BEP transformation. (The duties and inter-relationship of different stakeholders are given in more details in Section 3.1.1).

2 Law and Regulation Framework

2.1 Relevant Domestic Laws, Regulations, and Policies

2.1.1 Laws and RegulationsFrom 1979 when China firstly officially promulgated Environmental Protection

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Law of the People’s Republic of China (Tentative), China has progressively enacted several environmental protection laws and regulations such as Law of the People’s Republic of China on Prevention and Control of Water Pollution, Law of the People’s Republic of China on Prevention and Control of Atmosphere Pollution, and Marine Environment Protection Law of the People’s Republic of China. Environment legislation has gradually developed into an environmental protection legal system consisting of integrated laws, pollution prevention laws, and resources and ecological protection laws. By now, an environmental protection legal system has been established on the basis of Constitution of the People’s Republic of China and following the principle of Environmental Protection Law of the People’s Republic of China. The legislation and revision of environmental protection laws have effectively promoted the development of Chinese environmental protection campaign.

The principal Chinese laws and regulations on environmental protection include:1) Environmental Protection Law of the People's Republic of China

(1989.12.26)2) Law of the People's Republic of China on Environmental Impact Assessment

(2002.10.28)3) Law of the People’s Republic of China on Prevention and Control of Water

Pollution (2008.2.28);4) Law of the Peoples Republic of China on Prevention and Control of

Atmosphere Pollution (2000.4.29)5) Law of the People's Republic of China on Prevention of Environmental

Pollution Caused by Solid Waste (2004.12.29)6) Law of the People’s Republic of China on the Promotion of Cleaner

Production (2002.6.29)7) Renewable Energy Law of the People's Republic of China (2005.2.28)8) Circular Economy Promotion Law of the People’s Republic of China

(2008.8.29)9) Regulation on the Administration of Construction Project Environmental

Protection (1998.11.29)10) Regulation on National General Survey of Pollution Sources (2007.10.9)11) Regulations on the Administration of Collection and Use of Pollution

Discharge Fees (2003.1.2)12) Regulations on the Safety Administration of Dangerous Chemicals

(2002.1.26)13) Provisional Regulations on Cleaner Production Auditing (2004.8.16)Pulping and papermaking industry is one of the important pillar industries in

Chinese national economy; however it is also a major polluter that is to be held responsible for the degrading of environment quality. The reasons explaining the

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heavy pollution of NWPM industry include: 1. most pulping and papermaking enterprises are small in size, backward in technique and process, and dilapidated in equipment outfit, resulting in a high material consumption and pollutant release and greatly complicating pollution treatment effort. 2. When compared against wood pulp, non-wood pulp has quite a few drawbacks that render it much more difficult to recover non-wood pulp black liquor alkali and to treat the water pollution as compared against to wood pulp process. 3. Backward technology level results in a low recovery of alkali, and the clean production is far behind international advanced level. 4. The criteria of current domestic pollutant discharging standards are too low to encourage active technology transformation and pollution control by papermaking industry. In view of this situation, the state has enacted in the past years several laws and regulations and has made relevant control and treatment policies.

Table 2-1 and Table 2-2 describe major relevant domestic laws, regulations, and provisions.

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Table 2-1 Relevant domestic laws and legal articles

Title Relevant article

Environmental Protection Law of the People's Republic of China

Article 10 Whenever pollutants are discharged in an area where the local standards for such discharging have been in place, the local standards shall be applicable.

Article 13 For the construction of projects that cause pollution to the environment, pertinent state provisions concerning environmental protection for construction projects must be respected. The environmental impact statement on a construction project must assess the pollution the project is likely to produce and its impact on the environment and stipulate the preventive and curative measures; the statement shall, after initial examination by the authorities in charge of the construction project, be submitted, according to specified procedures, to the competent department of environmental protection administration for approval. The department of planning shall not ratify the design plan descriptions of the construction project until the environmental impact report on the construction project has been approved.

Article 18 Within the scenic spots or historic sites, nature reserves and other zones that need special protection, as designated by the State Council, the relevant competent department under the State Council, and the People's governments of provinces, autonomous regions and municipalities directly under the Central Government, no industrial production installations that cause environmental pollution shall be built; other installations to be built in these areas must not exceed the prescribed standards for the discharge of pollutants. If any built installations discharge above-norm pollutants, such pollution shall be eliminated or controlled within a prescribed period of time.

Article 19 Where natural resources are being developed or utilized, measures must be taken to protect the ecological environment.

Article 24 Units that cause environmental pollution and other public hazards shall incorporate the work of environmental protection into their plans and establish a responsibility system for environmental protection, and must adopt effective measures to prevent and control the pollution and harms caused to the environment by waste gas, waste water, waste residues, dust, malodorous gases, radioactive substances, noise, vibration and electromagnetic radiation generated in the course of production, construction or other activities.

Article 25 For technological transformation of newly built industrial enterprises and existing industrial enterprises, facilities and processes that have a high rate of the utilization of resources and a low rate of the discharge of pollutants shall be used along with economical and rational technology for the comprehensive utilization of waste materials and the treatment of pollutants.

Article 26 Installations for the prevention and control of pollution at a construction project must be designed, built and commissioned

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together with the principal works of the project. No permission shall be given for a construction project to be commissioned or used, until its installations for the prevention and control of pollution are examined and considered up to the standard by the competent department of environmental protection administration that examined and approved the environmental impact report.

Article 29 If an enterprise or institution has caused severe environmental pollution, it shall be required to eliminate and control the pollution within a certain period of time.

Article 31 Any unit that, as a result of an accident or any other exigency, has caused or threatens to cause an accident of pollution, must promptly take measures to prevent and control the pollution hazards, make the situation known to such units and inhabitants as are likely to be endangered by such hazards, report the case to the competent department of environmental protection administration of the locality and the departments concerned and accept their investigation and decision. Enterprises and institutions that are likely to cause severe pollution accidents shall adopt measures for effective prevention.

Article 33 The production, storage, transportation, sale and use of toxic chemicals and materials containing radioactive substances must comply with relevant state provisions so as to prevent environmental pollution.

Circular Economy Promotion Law of the People’s Republic of China

Article 2 The term “reducing” as mentioned herein refers to reducing the consumption of resource and the production of wastes in the process of production, circulation and consumption.

Article 9 Enterprises and public institutions shall set up management systems and take measures to reduce the consumption of resources, reduce the production and discharge of wastes and improve the reutilization and recycling level of wastes.

Article 16 The state adopts a rigorous energy-consumption and water-consumption supervision and administration system toward key enterprises in high energy or water consuming industries such as steel, non-ferrous metal, coal, electric power, petroleum processing, chemical industry, building materials, building construction, papermaking, and printing and dyeing.

Article 18 The administrative department of circular economy development under the State Council shall, together with the environmental protection department and other competent departments under the State Council, issue on a regular basis a catalogue of the encouraged, restricted and deselected techniques, processes, equipment, materials, and products. It is prohibited to produce, import or sell any equipment, material or product listed in the deselected catalogue, and it is also prohibited to use any technique, process, equipment or material listed in the deselected catalogue.

Article 31 Enterprises shall develop an in-series water use system and a circulatory water use system so as to improve water reuse rate.

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Enterprises shall use advanced technologies, processes, and equipment to recycle and reuse the wastewater generated during production.

Article 35 The people’s governments at or above the county level and the administrative departments of forestry thereunder shall make vigorous efforts to develop ecology-friendly forestry, encourage forestry producers and relevant enterprises to use timber-saving technologies and timber-replacing technologies, and make comprehensive utilization of forestry wastes, wood wastes, small firewood and desert bush so as to improve the comprehensive utilization rate of wood.

Energy Conservation Law of the People's Republic of China

Article 3 The energy conservation referred to in this Law means the strengthening of energy utilization administration, adoption of measures which are technologically feasible, economically rational and affordable to the environment and society, reduction in losses and waste in all links from energy production to consumption, and more efficient and rational utilization of energy resources.

Article 7 The state practices an industrial policy favoring energy-saving and environmental protection, restricts the development of heavy energy-consuming and heavy polluting sectors, and promotes the development of energy-saving and environment-friendly sectors. The State Council, the people’s governments of provinces and autonomous regions, and municipalities directly under the Central Government shall enhance energy conservation effort, rationally readjust the industrial structure, enterprise structure, product mix, and energy consumption pattern, urge enterprises to reduce energy consumption per unit output value and per unit product, deselect outdated production technology, improve the exploitation, processing, conversion, transmission, storage, and supply of energy, and increase the use efficiency of energy. The state encourages and supports the development and utilization of new and renewable energy resources.

Article 16 The state applies a deselection system to products, equipment, and production processes that consume excessive quantity of energy. The catalogue of energy-consuming products, equipment, and production techniques to be deselected along with the implementations measures shall be compiled and published jointly by the department in charge of energy conservation under the State Council and relevant departments under the same. Producers of products that consume excessive energy during the production shall conform to the ceiling criteria designed for per unit product. Any producer that consumes energy in excess of the norm designed for per unit product shall be ordered to rectify within a specified time limit by the department in charge of energy conservation within the jurisdiction as prescribed by the State Council. Special equipment consuming excessive energy shall be subject to energy conservation examination and control as required by the State Council.

Article 30 The department in charge of energy conservation under the State Council shall, in conjunction with relevant departments under the same, formulate policies on energy conservation technologies for major energy-consuming industries such as electric power, iron & steel, non-ferrous metal, building material, petroleum processing, chemical industry, and coal in order to push forward technical transformation for

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energy conservation in enterprises.

Law of the People’s Republic of China on the Promotion of Cleaner Production

Article 2 Cleaner production as used herein means the continuous application of measures for design improvement, utilization of clean energy and raw materials, the implementation of advanced processes, technologies and equipment, improvement of management and comprehensive utilization of resources to reduce pollution at source, enhance resource utilization efficiency, reduce or avoid pollution generation and discharge in the course of production, provision of services and product use, so as to decrease harm to the health of human beings and the environment.

Article 12 The state practices a time-limited system for the deselection of obsolete production technologies, processes, equipment and products that seriously waste resources and pollute the environment.

Article 18 New construction, construction transformation and expansion projects shall conduct environmental impact assessments, analyzing and assessing the use of raw materials, resource consumption, comprehensive utilization of resources, as well as generation of pollutants and their treatment; priority shall be given to clean production technologies, processes and equipment, which maximize the resource utilization rate and generate few pollutants.

Article 19 Enterprises in the course of technological upgrading shall adopt the following clean production measures: (1) Using toxin-free, non-hazardous or low-toxin and low-harm raw materials to replace toxic and hazardous raw materials;

(2) Using processes and equipment with high utilization rate and little pollutant-generation to replace those with high resource consumption and significant generation of pollutants;

(3) Comprehensive use or recycling of materials such as wastes, wastewater, or waste heat generated during production;

(4) Using pollution prevention and control technologies that enable enterprises to comply with national or local pollution discharge standards and total discharging volume quota control of pollutants.

Article 28 Enterprises shall monitor resource consumption and waste generation during production and service provision and shall, when necessary, conduct clean production audit of production and service. Enterprises exceeding national or local discharging standards or the total volume control target of pollutants set by the local government shall conduct clean production audit. Any enterprise using toxic or hazardous materials in production or discharging toxic or hazardous substances shall periodically conduct clean production audit and report the audit results to relevant environmental protection authority and economic and trade administration authority under the local government at or above county level.

Law of the Article 2 Environmental impact assessment referred hereto means a method and system for analyzing, forecasting, and assessing the potential

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People's Republic of China on Environmental Impact Assessment

impact on the environment after the implementation of plans and construction projects, for putting forward strategies and measures to prevent or mitigate adverse impact on the environment, and for carrying out follow-up and monitoring.

Article 16 The state practices a classified administration of environmental impact assessment of construction projects on the basis of the extent of the environmental impact by the projects.

Article 21 Except where confidentiality is required according to relevant state regulations, for any construction project that may have a great impact on the environment and need an environmental impact report, the project owner shall, prior to submitting for approval the environmental impact report of the project, hold a review meeting and hearing meeting or take other actions to seek comments from relevant entities, experts and general public.

Article 24 After the approval of the environmental impact assessment document of a project and in the event of any material change in the nature, size, location, and production technology of the project or in pollution or ecological destruction prevention measures, the project owner shall resubmit an environmental impact assessment document for approval.

Article 27 In case of any situation not in conformance with the approved environmental impact assessment document during the construction or operation of the project, the project owner shall organize a post assessment of environmental impact and take improvement measures and have them submitted to the original environmental impact assessment document review and approval authority and construction project review and approval authority for filing; alternatively, the original environmental impact assessment document review and approval authority may instruct the owner to carry out a post assessment of environmental impact and take improvement measures.

Article 28 The environmental protection administrative authority shall take follow-up inspection on any environmental impact caused by a commissioned project or during the operation of the project; where grave environmental pollution or ecological destruction occurs, the causes and the responsibilities shall be identified.

Law of the People’s Republic of China on Prevention and Control of Water

Article 3 Water pollution prevention and treatment shall be done following the principle of “prevention be the first choice, prevention and treatment be integrated, and comprehensive treatment be practiced”, with the priority placed on the protection of drinking water source. Effort shall be spent to control industrial pollution, township domestic pollution, and prevent agricultural plain source pollution. Ecological treatment construction projects shall be promoted aggressively in order to prevent, control, or minimize water environmental pollution and ecological destruction.

Article 9 Discharged water pollutants shall not exceed water pollutant discharging norm or the total discharge control volume for key water pollutants specified by the state or local authority.

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Pollution Article 13 Whenever pollutants are discharged to the water body in an area where the local standards for such water pollutant discharging have been in place, the local water pollutant discharging standards shall be applicable.

Article 17 Environmental impact assessment shall be carried out pursuant to relevant laws for new, rebuilt, or expanded construction projects or other water facilities that discharge, directly or indirectly, pollutants to the water body. Any entity attempting to construct new, or reconstruct or expand existing effluent outlet in a river or lake shall firstly obtain the consent from relevant water administrative authority or watershed administrative organization. Installations for the prevention and control of water pollution at a construction project must be designed, built and commissioned together with the principal works of the project. Water pollution prevention installations shall be satisfactorily inspected by the environmental protection authority; no project shall be put into production or operation before the prevention installations have been satisfactorily inspected.

Article 18 The state practices a total volume control for the discharging of key water pollutants.

Article 20 The state practices a licensing system for pollutant discharging.

Article 29 It is prohibited to discharge oils, acid liquor, alkali liquor or hyper-toxic fluids into water bodies. It is forbidden to wash in the water body any vehicle or container that has received oils or toxic pollutants.

Article 33 It is not permitted to discharge or empty industrial waste solids, urban wastes, or other wastes into water body.

Article 35 It is forbidden to discharge or empty toxic pollutant-tainted used water or pathogen-containing wastewater or other wastes through an absorbing well or pit, crevice, or karst cave.

Article 36 It is forbidden to use any trench or pond without anti-seepage measures to convey or store toxic pollutant-containing used water or pathogen-containing wastewater or other wastes.

Article 40 Relevant departments under the State Council and the local governments at and above county level shall make well-advised industrial planning and shall request water polluting enterprises to undergo technological transformation, take comprehensive prevention and control measures, improve water reuse rate, and minimize wastewater and pollutant discharge volume.

Article 41 The state practices deselection of outdated processes and equipment that cause serious pollution to the water environment. Producers, vendors, importers or users shall, within a specified time limit, stop producing, vending, importing, or using any equipment included in the equipment catalogue as provided for in the aforesaid provision. The selector of processes shall, within a specified time limit, disuse any process included in the process catalogue as provided for in the aforesaid provision.

Article 42 The state forbids any new construction of small-sized papermaking, tanning, printing & dyeing, dyestuff, coking, sulfur refining,

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arsenic refining, mercury refining, oil refining, electroplating, pesticide, asbestos, cement, glass, steel & iron, and thermal power plant, as well as other production projects causing serious pollution to the water environment.

Article 43 Enterprises shall use clean processes that have a high raw material utilization factor and a low pollutant discharge and shall intensify the management in order to minimize the generation of water pollutants.

Article 67 Institutions and enterprises prone to water pollution accident shall work out water pollution emergency plan and shall be well prepared for emergencies, and a periodical drilling shall be maintained. Institutions or enterprises producing or storing hazardous chemicals shall take precautions to avoid discharging directly into water body any firefighting water and waste fluids that may gravely pollute water body and that are generated during safety production accidents.

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Table 2-2 Relevant domestic regulations and rulesTitle Relevant article

Regulation on National General Survey of Pollution Sources

Article 3 The term “pollution source” as mentioned herein refers to any premises, facilities, or equipment which discharge pollutants to the environment in the process of production, livelihood, or any other activity, or have adverse impact on environment, as well as other sources producing pollution.

Article 8 The subjects of national general survey of pollution sources are any entities or self-employed households within the borders of the People’s Republic of China that have pollution sources.

Article 10 The scope of general survey of pollution sources shall include: industrial pollution sources, agricultural pollution sources, domestic pollution sources, facilities for centralized treatment of pollution, and other facilities generating or discharging pollutants.

Article 11 The main items of general survey on industrial pollution sources shall include: enterprise’s basic registration information, raw material consumption, production, facilities giving rise to pollution, and the generation, control, discharge, and comprehensive utilization of various pollutants, as well as the construction and operation of different pollution prevention and control facilities.

Article 20 Any of mid- or large-sized industrial enterprise covered under the scope of general survey of pollution sources shall specify a department to fill in and complete the survey form; whist other entities shall specify a person to fill in and complete the survey form.

Provisional Regulations on Clean Production Auditing

Article 2 Clean production auditing as mentioned herein refers to such a process during which survey and diagnosis of the production and service is done in accordance with certain procedures in order to identify the causes of high energy and material consumption and heavy pollution, to bring up a proposal for reducing the use and generation of toxic and hazardous materials and for reducing energy and material consumption and waste generation, and ultimately to select a clean production scheme that is technically, economically, and environmentally feasible.

Article 3 These regulations are applicable to all the entities engaging in production or service activities and all the departments engaging in relevant management activities within the boarders of the People’s Republic of China.

Article 8 Compulsory clean production auditing shall be conducted in enterprises that carry out production using toxic or hazardous raw materials or discharge toxic or hazardous substances during production.

Toxic or hazardous raw materials or substances generally refer to hyper-toxic, highly corrosive, highly irritating, radioactive (other than nuclear power facilities or military nuclear facilities), carcinogenic, or teratogenic substances listed in List of Dangerous Goods (GB12268), List of

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Hazardous Chemicals, National Catalogue of Hazardous Wastes and Catalogue of Hyper-toxic Chemicals.

Regulations on the Administration of Collection and Use of Pollution Discharge Fees

Article 2 Any entity or self-employed business (hereinafter referred to as pollution discharger) that discharges pollution directly to the environment shall pay pollution discharge fee in accordance with the provisions herein. A pollution discharger is not required to pay pollution discharge fee if he discharges wastewater to urban centralized wastewater treatment facilities and has paid wastewater treatment fee.

Article 6 A pollution discharger shall, in accordance with the stipulations of the environmental protection administrative department under the State Council, report the type and quantity of pollutants and relevant information to the environmental protection administrative department of the government at or above county level.

Article 10 Pollution dischargers shall use automatic pollutant discharge monitoring devices, which shall have been compulsorily calibrated as per relevant state stipulations, to monitor pollutant discharging; the monitoring data will be used as reference to verify the type and quantity of pollutants. Automatic pollutant monitoring devices installed by a pollution discharger shall be calibrated on a regular basis pursuant to relevant legal provisions.

Article 12 A pollution discharger shall pay pollution discharge fee as required below:

(2) Pollution discharge fees shall be paid by the type and quantity of pollutants in accordance with water pollution prevention law for pollutants discharged to water body; pollution discharge fees payable will be redoubled, according to the type and quantity of pollutants, for pollutants discharged to water body in excess of national or local discharge criteria.

Regulation on the Administration of Construction Project Environmental Protection

Article 3 State and local pollutant discharge standards must be respected for construction projects that generate pollution; where total pollutant discharge volume control is practiced for key pollutants, such total discharge volume control requirements must also be satisfied.

Article 4 Industrial construction projects shall adopt clean production technologies that have a low energy and material consumption and produce fewer pollutants; natural resources shall be used rationally in order to avoid environmental or ecological destruction.

Article 5 Measures must be taken for reconstruction, expansion or technological transformation projects to treat previous environmental pollution or ecological destruction associated with this project.

Article 7 The state practices a classified administration of environmental protection of construction projects in accordance with the following provisions and on the basis of the extent of the environmental impact of the projects:

(I) An environmental impact report shall be prepared for a construction project that may cause major impact on the environment, giving comprehensive and detailed assessment of the pollution generated and the environmental impact caused by the construction project;

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(II) An environmental impact form shall be prepared for a construction project that may cause light impact on the environment, giving analysis or specific assessment of the pollution generated and the environmental impact caused by the construction project;

(III) An environmental impact registration form shall be filled in and submitted for a construction project that has little impact on the environment and does not need an environmental impact assessment.

Article 16 Environmental protection installations needed for the construction project must be designed, built and commissioned together with the principal works of the project.

Article 19 The project owner shall, during the trial production period, monitor the operation of the environmental protection installations and the environmental impact of the project.

Regulations on the Safety Administration of Dangerous Chemicals

Article 3 Hazardous chemicals referred hereinto include explosives, compressed gas, liquefied gases, flammable liquids, flammable solids, self-combustible substances, flammable substances when wet, oxidants, organic peroxides, toxic substances, and corrosives.

Article 4 For an entity that produces, deals in, stores, transports, or uses hazardous chemicals or disposes of hazardous chemical wastes (hereinafter referred to as hazardous chemical entity), the principal must ensure the entity’s safety management of hazardous chemicals is in conformance with pertinent laws, regulations, stipulations, and state standards and shall be responsible for hazardous chemical safety of the entity. Hazardous chemical entity personnel involved in the production, dealing, storage, transport, or use of hazardous chemicals or in disposing of hazardous chemical wastes must receive training on pertinent laws, regulations, stipulations, safety knowledge, technique, occupational and hygienic protection, and first-aid rescue, and shall not assume their post before being successfully qualified.

Article 15 For an entity engaging in production with hazardous chemicals, the production conditions must conform to relevant state standards and stipulations and a license shall be obtained in accordance with pertinent state laws and regulations; meanwhile, a safety administration regulation system must be put in place and be perfected for the use of hazardous chemicals as an effort to ensure the safe use and management of hazardous chemicals.

Article 16 Where hazardous chemicals are produced, stored or used, appropriate safety facilities and equipment for monitoring, ventilation, shading, temperature conditioning, fire prevention, firefighting, explosion-prevention, pressure releasing, gas-protection, sterilization, neutralization, damp-proof, lightning arresting, anti-static, anti-corrosion, anti-seepage, and checking dyke, or segregation operation shall, according to the type and properties of hazardous chemicals, be provided in the workshops or warehouses; meanwhile, service and maintenance shall be made as required by relevant state standards or stipulations in order to ensure they conform to safe operation requirements.

Article 17 Any entity producing, storing, or using hyper-toxic chemicals shall have a safety evaluation of its production and storage facilities

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once a year; any entity producing, storing, or using other hazardous chemicals shall have a safety evaluation of its production and storage facilities once every two years.

Article 18 Any entity producing, storing, or using hazardous chemicals shall provide telecommunication and alarm devices on the production, storage, or use premises and shall ensure they are operable under any circumstances.

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2.1.2 Industry and Environmental Protection PoliciesIn August of 2006, the then State Environmental Protection Administration

(SEPA) of China made a total volume control plan of key pollutants in China during the “11th Five-Year Plan” period. In this plan, it proposes to “promote with great effort cleaner production, develop circular economy, reduce energy consumption and waste emission, and, to a larger extent, control the total release quantity of chemical oxygen demand (COD) in major industries like electric power, metallurgy, building material, chemical, papermaking, textile, printing & dyeing, and food & brewery, etc.” In the same year, the State Council stressed, in a resolution calling for stronger energy saving effort, that “industrial energy saving shall be intensified. As an emphasis, energy saving shall be properly done in major energy consuming industries such as iron & steel, non-ferrous metal, coal, electric power, petroleum and petrochemical, chemical, and building material and in enterprises that consume more than 10 thousand standard tons of coal per year. A ten-thousand-enterprise energy saving campaign shall be organized and carried out to urge enterprises to adjust proactively their product mix, accelerate energy saving technology transformation, and cut down energy consumption.” In the meantime, it is important to “push ahead with energy saving technology advance with great effort”, “increase energy saving monitoring and administration”, mobilize general public forces to further intensify energy saving work, accelerate the building of an energy-saving society in order to realize energy-saving targets set in the “11th Five-Year” plan outlines and to shift economic and social development effectively onto a general sustainable development track.

When it comes to the issue of unintentional persistent organic pollutants (dioxins in a large part) produced in non-wood pulp and paper making (NWPM), China has also taken active actions and has made relevant policies. In Stockholm Convention on Persistent Organic Pollutants (hereinafter known as POPs Convention for short), which as passed in May of 2001 in Stockholm of Sweden, polychlorinated dibenzo-p-dioxins (PCDD) and polychlorinated dibenzo-furans (PCDF) are included in persistent organic pollutants formed and released unintentionally from anthropogenic sources and it is pointed out that the source might be the production of pulp using elemental chlorine or chemicals generating elemental chlorine for bleaching. Chinese government signed POPs Convention on the plenipotentiary conference on May 23, 2001 and ratified this convention on the Tenth Session of the Standing Committee of the Tenth National People’s Congress on June 25, 2004. This convention is effective in China as of November 11, 2004.

With the intention to carry through and implement Decision on Implementing Scientific Concept of Development and Strengthening Environmental Protection by the State Council (Guofa [2005] 39#) and the spirit of the Sixth National Conference on Environmental Protection, to conscientiously implement POPs Convention, and also to further understand POPs pollution and situation in China, in 2006 and after

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deliberation by the SEPA, a decision was made to commence nationwide POPs situation survey starting from that year. In October of 2007, the National Development and Reform Commission issued Papermaking Industry Development Policy, which covers policy targets, industry layout, fiber raw materials, technology and outfit, product mix, organization structure, resource structure, environmental protection, industry admission, investment & financing, and paper consumption, etc.

This policy makes express requirements for the control of dioxin and pertinent pollutants generated in pulping process and encourages developing and applying high yield pulping technology, biotechnology, low-pollution pulping technology, moderate enriching technology, elemental chlorine free or totally chlorine free bleaching technology, low energy-consumption mechanical pulping technology, high-efficiency waste paper deinking technologies and associated equipment. It explicitly requests the deselection of such pulping technologies and equipment as chemical straw pulp production facilities and rotary spherical digester with an annual output of 34,000t or less and narrow width and low-speed papermaking machines known to be high energy-consuming and of low technology level. In addition, it prohibits lime process pulping technology and does not allow new projects to use elemental chlorine bleaching technology.

Table 2-3 presents relevant domestic policies and their principal contents.

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Table 2-3 Relevant domestic policies and rules

Title Relevant policies and rules

Policy on Wastewater Pollution Control Technology in Straw Pulp Papermaking Industry

II. Control target

6. According to the principle of integrating development with environmental protection and given the properties of NWPM wastewater treatment, pollution treatment of NWPM enterprises need to be above certain size: 34,000t pulp/a for newly constructed wheat straw pulping enterprises, 50,000t pulp/a for other NWPM enterprises; while 17,000t/a is the minimum size required for the construction of alkali recovery facilities for alkaline chemical pulping mills.

7. Chemical pulping mills (workshops) less than 5,000t/a in size shall be banned resolutely; for small-size chemical pulping enterprises less than 17,000t/a, the environmental pollution treatment targets shall be achieved by the end of 2000 through treatment, shutdown, suspension, merging, or shifting to other businesses.

III. Technical measures

8. For technical transformation and pollution treatment, papermaking enterprises shall use clean production technologies that consume less energy and has a lower pollution load; the technology threshold shall be raised, for instance, straw pulp raw materials that contain less silicon and more fiber are preferable.

9. For technical transformation and pollution treatment, papermaking enterprises shall use clean production technologies that consume less energy and has a lower pollution load. Straw pulp raw materials having a lower silicon content and a higher fiber content shall be used; automatic baling technique, lean-chlorine or chlorine-free bleaching technology shall be employed.

16. Encouraged wastewater treatment technology researches.

Circular on Properly Performing the Deselection of Outdated Papermaking, Alcohol, Monosodium Glutamate, Citric Acid Production Capacity Issued

In papermaking industry, deselection is mainly focused on straw pulp production facilities with an annual output less than 34,000t, chemical pulping production lines with an annual output less than 17,000t (Effluent Standard for Pollutants from Pulp and Paper Industry GB3554-2001 being applicable), and papermaking mills using waste paper as raw material with an annual output less than 10,000t and discharging above-quota pollution (Announcement of Revising “Effluent Standard for Pollutants from Pulp and Paper Industry” by SEPA, Huanfa [2003] 152# being applicable) (provinces in eastern and middle regions may appropriately apply more rigorous criteria to the deselection of outdated pulping and papermaking capacity). The overall target is to deselect 6,500,000t/a of

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by NDRC and SEPA outdated papermaking capacity within the “11th Five-Year Plan” period.

State Council Circular on Printing and Distributing “the 11th Five-Year” Planning of National Environmental Protection

The deselection of heaving-polluting small papermaking, small chemical, small tannery, small printing & dyeing, and small brewery enterprises that are not in agreement with industrial polices shall be accelerated. Pollution control and technological innovation effort shall be redoubled, with the emphasis laid on papermaking, brewery, chemical, textile, and printing & dyeing sectors. It is strictly prohibited to construct heavy water pollution enterprises like chemical, papermaking, printing & dyeing enterprises on the upper reaches of drinking water reserves.

State Council Circular on Printing and Distributing Comprehensive Work Plan of Energy Saving and Emission Reduction

The immoderately quick growth of heavy energy-consuming and heavy-polluting enterprises shall be restrained; the deselection of outdated production capacity shall be accelerated, and the effort shall be doubled in deselecting outdated capacity in papermaking, alcohol, monosodium glutamate, citric acid sectors. Energy-saving and water-saving technology policy outlines shall be carried through; a range of highly potential and extensively applicable major energy saving and emission reduction technologies shall be promoted in key sectors like iron & steel, non-ferrous metal, coal, electric power, petroleum and petrochemical, chemical, building material, textile, papermaking, and construction.

National Implementation Plan of the People’s Republic of China for Stockholm Convention on Persistent Organic Pollutants

China has been performing unintentional POPs monitoring in chlorophene derivatives, tetrachlorobenzoquinone, chlorobenzene, wastewater treatment, cement, iron & steel, papermaking, medical waste incineration, etc., and papermaking (chlorine bleaching) has been included in key industries to be firstly put under control. This plan proposes the action targets of reducing and eliminating unintentional POPs release and analyzes the gap with POPs Convention and necessary measures to be taken. Meanwhile, the stress is laid on the implementation of BAT/BEP management system.

Energy Saving and Emission Reduction Work Arrangement for 2009 in China

National industry policies and project review and approval regulations shall be strictly carried through during the process of adjusting and revitalizing key industries like iron & steel, auto, shipbuilding, petrochemical, light industry, textile, non-ferrous metal, equipment manufacturing, electronic information, and logistics; the deselection effort of outdated production capacity shall be redoubled in order to deselect 500,000t of outdated papermaking capacity. Supervision over energy saving and emission reduction shall be intensified

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and targeted environmental protection enforcement campaign shall be launched; supervision and check of the performance of total discharge volume control and pollution discharge licensing shall be done particularly in 12 heavy energy-consuming and heavy pollution-discharging industries, including electrical power, iron & steel, building material, and papermaking.

Development Policy of Papermaking Industry

Article 21 The emphases of pulping and papermaking equipment R&D are: research and development of new processes, new technologies, and new equipment that use non-wood raw materials for pulping and papermaking, particularly the development of straw pulp alkali recovery technologies and equipment; water-saving and energy-saving technologies and equipment.

Article 22 Technologies of papermaking industry shall develop toward high level, low energy consumption, and less pollution. It should be encouraged to develop high yield pulping technologies, biotechnologies, low-pollution pulping technologies, moderate enriching technologies, elemental chlorine free (ECF) or totally chorine free (TCF) bleaching technologies, low energy-consumption mechanical pulping technologies, high-efficiency waste paper deinking technologies, and associated equipment.

Article 23 Pulping technologies and equipment such as chemical straw pulp production facilities and rotary spherical digester with an annual output of 34,000t or less shall be deselected; narrow width and low-speed papermaking machines known to be high energy-consuming and of low-level shall also be deselected. Lime process pulping shall be prohibited and new projects are not allowed to use elemental chlorine bleaching technique (existing enterprises shall phase out this technique). It is forbidden to import deselected and outdated second-hand pulping equipment.

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2.1.3 Environmental StandardsChina has established different environmental quality standards according to the

environmental function of different environmental media, like Environmental Quality Standards for Surface Water (GB 3838-2002), Marine Water Quality Standard (GB 3097-1997), Ambient Air Quality Standard (GB 3095-1996), and Environmental Quality Standard for Soils (GB 15618-1995). Among them, Environmental Quality Standards for Surface Water has undergone three revisions; however, its monitoring indices do not include the absorbable organic halogens (AOX), an index deserved to be monitored for effluent discharged by papermaking sector, or dioxin, which is likely to be generated during pulp bleaching process. Ambient Air Quality Standard and Environmental Quality Standard for Soils do not have dioxin monitoring index either.

In 2008, China formulated Discharge Standard of Water Pollutants for Pulp and Paper Industry (GB 3544-2008) particularly for water pollutants (including dioxin) generated during pulping and papermaking production process.

The principal standards and their main contents are given in Table 2-4.

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Table 2-4Relevant domestic environmental standards

Standard title Enforceable as of Main contents

Environmental Quality Standard for Surface Water

(GB 3838-2002)

June 1, 2002

This standard, on the basis of environmental function category and protection target of surface water, specifies the items and limit values to be controlled for water environment quality; it also defines the analysis method of water quality assessment and water quality items and stipulates the implementation and supervision of this standard. It is applicable to surface water bodies serving certain purposes like river, lake, canal, channel, and water reservoir within the borders of the P. R. China.

Marine Water Quality Standard (GB 3097-1997)

July 1, 1998This standard specifies water quality requirements for different use purposes in sea waters and is applicable to sea waters under the jurisdiction of P. R. China.

Ambient Air Quality Standard

(GB 3095-1996)October 1, 1996

This standard defines the classification of ambient air quality function area, standard class, pollutants, measuring time & concentration limits, sampling & analysis method, and validity of statistics. It is applicable to ambient air quality assessment in China.

Environmental Quality Standard for Soils

(GB 15618-1995)

March 1, 1996

This standard specifies the allowable maximum pollutant concentration indices in soil and the monitoring and measuring methods according to the function, the protection targets, and the main properties of the soil. This standard applies to soils of cultivated field, vegetable field, tea plantation, orchard, pasture, forest, and natural reserve.

Discharge Standard of Water Pollutants for Pulp and Paper Industry

August 1, 2008 This standard sets pollutant discharge limit values for pulping and papermaking enterprises or their production facilities. In addition to water pollutant discharge limit values for existing and newly constructed enterprises; this standard has also specified special water pollutant discharge limit values for places where special precautions are needed in order to avoid serious water environment pollution. Water

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(GB 3544-2008)pollutants dealt with in this standard include pH-value, chromaticity, suspended substance, BOD, COD, ammonia nitrogen, total nitrogen, total phosphorus, absorbable organic halogens (AOX), and dioxin. This standard also includes the criteria for water pollutant concentration measurement methods.

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2.2 Relevant Domestic Technical Guidelines

2.2.1 Environmental Impact Assessment Technical GuidelinesRelevant Chinese EIA technical guidelines include:1) Technical Guidelines for Environmental Impact Assessment—General

Principles (HJ/T 2.1-93)2) Technical Guidelines for Environmental Impact Assessment—Surface Water

Environment (HJ/T 2.3-93)

3) Technical Guidelines for Environmental Impact Assessment—Atmospheric Environment (HJ 2.2-2008)

4) Technical Guidelines for Environment Risk Assessment of Construction Projects (HJ/T 169-2004)

5) Technical Specifications for Monitoring of Surface Water and Wastewater (HJ/T 91-2002)

6) Specifications for Ambient Air Quality Monitoring (Tentative) (Announcement No. 4 of 2007 by SEPA)

7) Technical Specifications for Soil Environmental Monitoring (HJ/T 166-2004)Domestic technical guidelines have been prepared as regards project EIA,

environmental risk assessment, and environmental monitoring. Specific monitoring factors (excluding dioxin) have been set for pulping and papermaking industry in Technical Guidelines for Environmental Impact Assessment—Surface Water Environment (HJ/T 2.3-93) and Technical Specifications for Monitoring of Surface Water and Wastewater (HJ/T 91-2002). However, Technical Guidelines for Environment Risk Assessment of Construction Projects (HJ/T 169-2004) does not provide any technical guidance to the assessment and monitoring of papermaking industry.

Relevant domestic technical guidelines and their main contents are given in Table 2-5.

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Table 2-5List of domestic technical guidelines for environmental assessment and monitoring

Standard title Main contents

Technical Guidelines for Environmental Impact Assessment—General Principles

(HJ/T 2.1-93)

This standard specifies the general principles, methods, scope, and requirements for EIA of construction projects. It is applicable to EIA of construction projects undertaken by industrial enterprises or public institutions. EIA of other construction projects may also be made on the basis of the principles and methods set forth in this standard.

Technical Guidelines for Environment Risk Assessment of Construction Projects

(HT/T 169-2004)

These guidelines define the purpose, basic principles, scope, procedures, and methods for environmental risk assessment of construction projects. These guidelines are applicable to environmental risk assessment of new, rebuilding, expansion, or technological transformation projects that involve the production, use, storage, or transportation of toxic, harmful, or flammable products. New, rebuilding, expansion, or technological transformation projects are mainly those involving the production of chemical raw materials and chemicals that are included in Catalogue of Environmental Protection Administration of Construction Projects issued by SEPA, petroleum and natural gas exploitation and refining, information chemicals manufacturing, chemical fiber manufacturing, non-ferrous metal smelting and processing, extraction, and building material.

Technical Guidelines for Environmental Impact Assessment –Surface Water Environment

(HJ/T2.3-93)

This standard specifies the principles, methods, and requirements for surface water EIA. It is applicable to surface water EIA of construction projects undertaken by industrial enterprises or public institutions. Surface water EIA of other construction projects may also be performed on the basis of these guidelines. Assessment is classified in three levels. This standard defines compulsory water quality test items for papermaking industry, including pH-values (or alkalinity), COD, BOD, suspended substance, water temperature, volatile phenol, sulfides, Pb, Hg, lignin, and chromaticity.

Technical Guidelines for Environmental Impact Assessment—Atmospheric Environment

(HJ 2.2-2008)

This standard specifies the scope, working procedures, methods, and requirements of atmospheric EIA and is applicable to atmospheric EIA of construction projects. Regional atmospheric EIA or EIA for planning may also be done by drawing reference from this standard.

Technical Specifications for Monitoring of Surface Water and

These specifications prescribe the distribution of monitoring points and sampling for surface water and wastewater, monitoring items and relevant analysis methods, watershed monitoring, monitoring data processing and reporting,

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Wastewater

(HJ/T 91-2002)

wastewater flow rate computation method, quality assurance of water quality monitoring, and data sorting, etc. Meanwhile, basic methods have been provided for total volume control of pollutants, environmental protection acceptance monitoring of wastewater treatment facilities of construction projects, and emergency monitoring. Compulsory monitoring items for papermaking and paper product sectors included in these specifications are acidity (or alkality), COD, BOD5, AOX, pH, volatile phenol, suspended substance, chromaticity, and sulfides. Optional monitoring items are lignin and oils.

Specifications for Ambient Air Quality Monitoring (Tentative)

(Announcement No. 4 of 2007 by SEPA)

These specifications prescribe the requirements for the design and monitoring point layout of ambient air quality monitoring network, the methods and technical requirements for manual and automatic monitoring of ambient air quality, and the requirements for the management and processing of ambient air quality monitoring data. These specifications are applicable to routine ambient air quality monitoring activities made by national or local environmental protection administrative authorities in order to determine ambient air quality and prevent air pollution.

Technical Specifications for Soil Environmental Monitoring

(HJ/T 166-2004)

These specifications prescribe monitoring point stationing and sampling, sample preparing, analysis method, result representation, statistics, and quality assessment for soil environment monitoring. These specifications are applicable to the monitoring of regional soil background, cultivated soil environment, construction project soil environment, and soil pollution accidents in China.

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2.2.2 Technical Specifications for Cleaner ProductionTo promote cleaner production, increase resource utilization efficiency, minimize

or avoid the generation of pollutants, protect and improve the environment, safeguard human health, and boost sustainable economic and social development, China compiled and then enacted Law of the People’s Republic of China on the Promotion of Cleaner Production on June 29, 2002. Then, China prepared cleaner production standards for different industries starting from 2003.

Researches indicate that, along with the quick growth of pulping and papermaking industry, dioxin—an unintentional by-product generated in the process of pulping and papermaking—has caused great pollution to the ecological environment. The sources of dioxin in pulping and papermaking industry include raw materials for pulping, chlorine bleaching of pulping, pulping and papermaking from waste paper, defoaming agents, and alkali recovery. Therefore, it is important to tighten dioxin management and control during production process and pollution release stage. From 2007 till now, China has established cleaner production standards for the purpose of cleaner production in papermaking industry. These standards include Cleaner Production Standard—Process of Bleached Alkali Bagasse Pulp in Paper Industry (HJ/T 317-2006), Cleaner Production Standard—Production of Bleached Soda Straw Pulp in Paper Industry (HJ/T 339-2007), Cleaner Production Standard—Production of Kraft Chemical Wood Pulp in Paper Industry (HJ/T 340-2007), and Cleaner Production Standard—Waste Paper Pulp in Paper Industry (HJ 468-2009). In 2008, in order to normalize environmental protection acceptance upon the completion of construction projects in papermaking industry, China formulated Technical Guidelines for Environmental Protection in Paper Industry Project for Check and Accept of Completed Project (HJ/T 408-2007). Table 2-6 gives a summary of the aforesaid technical specifications.

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Table 2-6Domestic cleaner production standards and technical guidelines

Standard title Enforceable as of Main contents

Cleaner Production Standard—Process of Bleached Alkali Bagasse Pulp in Paper Industry(HJ/T 317-2006)

February 1, 2007

This standard classifies into three levels the clean production of bleached alkali bagasse pulping process in papermaking industry. Considering the characteristics of papermaking industry, six indices are used to classify the levels, they are: resource utilization, characteristic process, comprehensive utilization of wastes, generation of pollutants (before end treatment), production process and equipment requirement, and environmental management requirement.

Cleaner Production Standard—Production of Bleached Soda Straw Pulp in Paper Industry

(HJ/T 339-2007)

July 1, 2007

This standard classifies into three levels the clean production of bleached soda straw pulping process in papermaking industry. According to the general requirements of cleaner production, five indices are used to classify the levels, they are: production process and equipment requirement, resource utilization, recycling and reuse of wastes, generation of pollutants (before end treatment), and environmental management requirement.

Cleaner Production Standard—Production of Kraft Chemical Wood Pulp in Paper Industry

(HJ/T 340-2007)

July 1, 2007

This standard is applicable to the production of unbleached sulfite chemical wood pulp and bleached sulfite chemical pulp in papermaking industry and it classifies into three levels the clean production of this production process. According to the general requirements of cleaner production, five indices are used to classify the levels, they are: production process and equipment requirement, resource utilization, recycling and reuse of wastes, generation of pollutants (before end treatment), and environmental management requirement.

Guidelines for Environmental Protection in Paper Industry Project for Check and Accept of Completed Project

April 1, 2008 In this standard, the following have been specified: the determination of the scope of environmental protection acceptance work upon the completion of construction projects in papermaking industry, the principle for the selection of applicable standards, key points to be considered in engineering and pollution treatment and discharge analysis, distribution of acceptance

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(HJ/T 408-2007)

monitoring points, sampling, and analysis method, quality control and quality assurance, technical requirements for the assessment of monitoring results, and technical requirements for the scope and plan of acceptance investigation and for the preparation of report. This standard is applicable to environmental protection acceptance upon the completion of new, expansion, rebuilding, or technical transformation construction projects undertaken by pulping, papermaking or pulping-papermaking enterprises.

Acceptance monitoring factors in this standard include AOX monitoring in discharging outlet of workshop or production facilities.

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2.3 Environmental Protection Policies and Environmental Assessment Guides of the World Bank2.3.1

Environmental Assessment Guide System of the World Bank

In order to ensure its operation does not endanger humankind and the environment, the World Bank prepares the following environmental assessment guides and protection policies depending on the potential risks and negative environmental influences of its operation:

(1) OP/BP 4.01 Environmental Assessment;(2) OP/BP 4.04 Natural Habitats;(3) OP 4.36 Forestry(3) OP 4.09 Pest Management;(4) OP 4.37 Safety of Dams(5) OP 4.11 Physical Cultural Resources;(6) OP/BP 4.12 Involuntary Resettlement;(7) OD 4.20 Indigenous Peoples;(8) OP/BP 7.60 Projects in disputed areas;(9) OP 7.50 Projects on International Waterways;(10) The World Bank Policy on Disclosure of Information 2002.OP 4.01 mainly includes six components: environmental assessment instruments,

environmental screening, environmental assessment for special project types, institutional capacity, public consultation, disclosure, and implementation. Annex A provides the definition of 8 terms, Annex B describes the content of an environmental assessment report for Category A projects, while Annex C is environmental management plan (including mitigation, monitoring, capacity development and training, implementation schedule and cost estimates, integration of EMP with project).

The main content of BP 4.01 includes nine components: project category, preparation of environmental assessment report, deliberation and disclosure, project appraisal, documented recording, supervision and appraisal, function of environment department, appraisal of financed project, and special situation.

OP/BP 4.01 is designed to review the potential environmental risks and revenues of projects financed by the World Bank. The World Bank requires environmental assessment of projects proposed for its financing to help ensure that they are environmentally sound and sustainable, and thus to improve decision making. The World Bank treats environmental assessment as a process made on the basis of a through understanding of the project and the project region and during which the breadth, depth, and type of environmental impact of the project and its operation are

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analyzed and this process includes the following: evaluating a project’s potential environmental risks and impacts in its area of influence; examining project alternatives; identifying ways of improving project selection, siting, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts; and including the process of mitigating and managing adverse environmental impacts throughout project implementation. The World Bank favors preventive measures over mitigatory or compensatory measures, whenever feasible.

Environmental assessment shall take into account natural and social aspects, including in an integrated way: natural environment (air, water, and land); human health and safety; social aspects (involuntary resettlement, indigenous peoples, and cultural property), and transboundary and global environmental aspects. Environmental assessment also takes into account the variations in project and country conditions; the findings of country environmental studies; natural environmental action plan; the country’s overall policy framework, national legislation, and institutional capabilities related to the environmental and social aspects; and obligations of the country, pertaining to project activities, under relevant international environmental treaties and agreements. The World Bank does not finance project activities that would contravene such country obligations, as identified during the environmental assessment. Environmental assessment should be initiated as early as possible in project processing and should be integrated closely with the economic, financial, institutional, social, and technical analyses of a proposed project.

2.3.2 Requirement of WB Policy on Information DisclosureThe purpose of the World Bank policy on disclosure of information is arousing

the awareness of the problems associated with development, global information sharing, and ensuring the participability of the World Bank projects. Past experiences demonstrate that information sharing and consultation by governments and third-party stakeholders help improve the quality of project implementation. Ever since 1985, the World Bank expands its scope of information disclosure on a regular basis. Now, the World Bank has issued most operational guides and tries to expand wider and wider the participants of its projects.

The World Bank Policy on Disclosure of Information 2002 mainly describes pertinent policy on disclosing to the public the information held by the World Bank. For the purpose of promoting development efficiency and reducing poverty, the World Bank reiterates the acknowledged transparency and reliability of its activities. The policy text consists of four parts: the first one is Introduction and the second one provides detailed description of the World Bank policy on disclosure. The third part lists the information categories available to the public, individual, or groups. Part IV is devoted to Constraints. While every effort is made to keep constraints to a minimum, there is still some information not to be made publicly available.

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2.3.3 IFC Environment, Health and Safety Guidelines –Pulp and Paper Mills

As per OP4.01 requirement, the proposed World Bank project is also subject to the IFC’s Environment, Health and Safety Guidelines which apply for all World Bank Group members. The Environmental, Health, and Safety (EHS) Guidelines are technical reference documents with general and industry specific examples of Good International Industry Practice. The Environment, Health and Safety Guidelines – Pulp and Paper Mills are specific guidelines for pulp and paper sector contain the performance levels and measures that are generally considered to be achievable in new facilities by existing technology at reasonable costs.

The EHS Guideline for Pulp and Paper Mills includes information relevant to pulp and paper manufacturing facilities including wood-based chemical and mechanical pulping, recycled fiber pulping, and pulping based on non-wood raw materials such as bagasse, straw, and reed. It describes the industry-specific impacts and management, performance indicators and monitoring, effluents and emissions guidelines, etc.

The applicability of specific technical recommendations should be based on the professional opinion of qualified and experienced persons. When host country regulations differ from the levels and measures presented in the EHS Guidelines, projects are expected to achieve whichever is more stringent. If less stringent levels or measures than those provided in these EHS Guidelines are appropriate, in view of specific project circumstances, a full and detailed justification for any proposed alternatives is needed as part of the site-specific environmental assessment. This justification should demonstrate that the choice for any alternate performance levels is protective of human health and the environment.

A full EHS Guideline for Pulp and Paper Mills is attached as Annex 4.

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3 Guide for Preparing and Implementing BAT/BEP Environmental Assessment

3.1 Responsibility Subject and Assessment Procedure of EIA

3.1.1 Responsibility Subject

BAT/BEP transformation by NWPM for UPOPs release reduction is a kind of technology and management innovation made by a special industry for special pollutant control. According to the provisions of Article 24 of Chapter III of Environmental Impact Assessment Law of the People’s Republic of China (2003), environmental impact assessment (EIA) is mandatory for any construction project undergoing rebuilding, expansion, or major production technology and process variation. The following key stakeholders are concerned in EIA of BAT/BEP transformation in non-wood pulp and paper making (NWPM) industry: governmental environmental protection authorities and industrial administrative authorities, the World Bank, enterprises, industrial research institutes, environmental assessment agencies, and the general public and NGOs. The relationship among different responsibility subject is illustrated in Fig. 3-1.

enterprisesundergoing BAT/BEP

transformation

enterprisesundergoing BAT/BEP

transformation

filingindustrial policiestechnical standards

Reviewand

approval

Submit for

approval

General public;NGOs

General public;NGOs

environmental impact

assessment agencies

environmental impact

assessment agencies

industrialresearchinstitutes

industrialresearchinstitutes

Environmental

authorities

Environmental

authorities

World bankWorld bank

industrial authoritiesindustrial

authorities

Figure 3-1 Key stakeholders and their relations in the EIA process of adopting BAT/BEP

38

Enterprise

— The enterprise has the duty to conform to the latest national or local discharge standards in dioxin and other major pollutants and carry out necessary BAT/BEP transformation.

— Prior to BAT/BEP transformation construction, the enterprise shall invite adequately qualified EIA agency to perform EIA of the transformation works, which shall be commenced only after the environmental impact assessment report has been reviewed and approved by environmental protection authority.

— The enterprise is under an obligation to make available to the public the BAT/BEP transformation content, the expected degree of clean production after transformation, the impact upon ambient environment quality and ecological system, the influence upon public health and living, proposed environmental protection measures and anticipated effects, and the commitments to the general public; environmental information shall be disclosed to the public in a timely fashion during the course of construction and operation.

— The enterprise is obliged to provide true and correct production process parameters, pollution release data, and other necessary information to EIA agency and assist the latter in correctly and accurately assessing the environmental impact of BAT/BEP transformation.

— The enterprise is obliged to provide environmental protection works and measures as suggested in the approved EIA report and shall ensure the proper operation of environmental protection equipment.

Governmental environmental protection authority

— Environment administrative authority is expected to, in accordance with the procedures set forth in Environmental Protection Law of the People’s Republic of China, perform technical review of submitted EIA documents of BAT/BEP transformation of the enterprise.

— Upon the completion of the enterprise’s transformation works, the environmental administrative authority is to have an acceptance inspection of accompanying environmental protection facilities as per Administrative Regulations on Environmental Protection Acceptance Inspection upon Completion of Construction Projects.

— Environmental administrative authority shall perform necessary post-transformation measurement of pollution discharged by the enterprise.

— After BAT/BEP works are put into operation, the environmental administrative authority shall supervise the implementation of various mitigatory

39

measures taken by the enterprise and shall have follow-up inspection of the environmental impact and shall, in the event of any major environmental pollution and major environmental safety incident, identify the cause and locate the responsibilities. If the incident is caused by the enterprise’s failure to operate the environmental protection equipment as required, or any negligence in measures or in management, relevant provisions in Environmental Protection Law of the People’s Republic of China shall be applicable for enforcement; if the incident is due to false EIA documents supplied by EIA service provider for BAT/BEP project, Environmental Impact Assessment Law of the People’s Republic of China shall be applicable for enforcement.

Industrial administrative authority

— Industrial administrative authority shall, in accordance with national and local requirements for cleaner production and major pollutants in papermaking industry, prepare technical standards and industrial development policies for NWPM sector and compile appropriate policies to promote BAT/BEP in NWPM enterprises.

Industrial research institute

— Industrial research institutes refer to organizations conducting researches in fields related to production technologies and management techniques in papermaking; they include research bodies attached to papermaking industry, like papermaking research institutes, light industry and environmental protection research institutes, as well as research institutes attached to relevant specialties in universities. Industrial research institutes engage in the research of possible BAT/BEP plans, select and provide technical and management solutions suitable to NWPM to enterprises and provide technical support to specific BAT/BEP transformation of enterprises.

Environmental impact assessment agency

— An environmental impact assessment agency shall, following the principle of fairness, correctness, and integrity and assuming relevant social responsibilities, perform EIA on an NWPM enterprise’s BAT/BEP plan for UPOPs control pursuant to state laws, regulations, policies, and relevant administrative requirements. An EIA provider shall analyze and describe, in a scientific and professional manner, different potential environmental impacts and potential ecological risks of the BAT/BEP plan taken by the enterprise and shall propose feasible countermeasures against unfavorable environmental impacts and risks.

The World Bank

— As a financier to BAT/BEP project, the World Bank provides financial or other support to an enterprise’s BAT/BEP transformation. In BAT/BEP project environmental assessment, the World Bank not only provides support to

40

environmental assessment preparation, but also reviews and confirms the final environmental assessment report and environmental management plan.

Public and Non-governmental organization

The public and NGOs include the units and communities and other organizations or individuals within the area of environmental influence (including risks and accidents) of NWPM enterprises, particularly those units, communities, and individuals having stakes in or accepting environmental risk from the construction project; they also include those experts conversant with the industry to which the construction project is related, experts conversant with environmental issues or other necessary specific industries, and relevant experts interested in the construction project. The public and NGOs play a participation role in environmental impact assessment and assumes the responsibility of supervising the environmental behavior of the enterprise.

— The public and NGOs shall air their view on and impose requirement for the implementation of the construction project, project siting, the perception of and the attitude toward key environmental impacts of the project, environmental protection measure suggestions of the project, and project nuisances. The expression of public opinion and comments may be realized public opinion survey and hearing meeting carried out during BAT/BEP transformation EIA.

— The public and NGOs shall have public opinion supervision over the environmental behaviors of the enterprise.

3.1.2 Environment Impact Assessment Procedures

EIA of BAT/BEP transformation for UPOPs release reduction in NWPM industry is divided into six stages: environmental screening, preliminary preparation, assessment work, EI report review, environmental supervision, and environmental post-assessment. For specific procedures, please see Fig. 3-2.

41

Figure 3-2 Generic working flowchart of an EIA of adopting BAT/BEP

Environmental screening stage: The NWPM enterprise selects key environmental issues based on the achievement targets and proposed technologies of BAT/BEP transformation and determines the scope, depth, and category of assessment depending on the type of environmental issues and the environmental sensitivity in the project area.

Preliminary preparation stage: On the basis of environmental screening results, BAT/BEP transformation plan and technical design are optimized and determined; experts are selected for EIA work and the EIA service provider is contacted to agree on and complete EA service entrusting procedures. The EA provider assigns staff to carry out survey and research, collection information, visit the site and, in accordance with technical transformation characteristics, environmental characteristics, and environmental protection laws and regulations, prepare EIA implementation plan. The environmental administrative authority and the World Bank agent summon expert meeting to review the EIA implementation plan.

Assessment stage: The EIA agency, following the reviewed and approved implementation plan, performs EIA work, proposes environmental countermeasures and suggestions, comes to a conclusion, and complete EIA documents.

EIA report review and approval stage: When the EIA documents are completed, the enterprise submit them to the environmental administrative authority

42

and the World Bank agent, who will organize an expert meeting to review the report; the report will be passed if the review criteria are satisfied.

Environmental supervision stage: The environmental administrative authority and the World Bank agent oversee whether the enterprise is constructing or operating the environmental equipment as required in the EIA documents and supervise the enterprise’s pollution discharge; the public gets involved in all possible ways in the supervision over the environmental behavior of the enterprises.

Environmental post-assessment stage: When the construction and the specified operation period are completed, the participating enterprise shall furnish the World Bank with assessment results of the project environmental implementation, which shall include the assessment of the implementation degree of suggestions offered in the environmental assessment and other environmental analyses, the evaluation of the degree of influence by EA on decision-making in project preparation, assessment, and implementation stages, and evaluation of the benefits derived from the environment portion.

3.2 Preparation of Environmental Assessment

Figure 3-3 Technical flowchart of an EIA of adopting BAT/BEP

3.2.1 Environment Impact and Risk Identification

(1) Determination of EIA levels

In accordance with environmental risk screening procedures of the World Bank,

43

it is necessary to determine the scope and degree of EIA for an NWPM BAT/BEP project. By the World Bank classification standards, EIA comes into four categories: Category A, B, C, and FI. EIA classification shall be determined depending on the particular situation of each project and in accordance with the procedures of OP/BP 4.01.

Box 3-1 EIA Classification criteria of World Bank

The World Bank classifies the proposed project into four categories, depending on the type, location, sensitivity, and scale of the project and the nature and magnitude of its potential environmental impacts:

Category A: A proposed project is classified as Category A if it is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented; these impacts may affect an area broader than the sites or facilities subject to physical works. EIA for a Category A project examines the project’s potential negative and positive environmental impacts, compares them with those of feasible alternatives (including the “without project” situation), and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance. For a Category A project, the borrower is responsible for preparing a report, normally an environmental impact assessment (EIA) report (or a suitably comprehensive regional or pectoral EA).

Category B: A proposed project is classified as Category B if its potential adverse environmental impacts on human population or environmentally important areas—including wetlands, forests, grasslands, and other natural habitats—are less adverse than those of Category A projects. These impacts are site-specific; few if any of them are irreversible; and in most cases mitigatory measures can be designed more readily than for Category A projects. The scope of EIA for a Category B project may vary from project to project, but it is narrower than that of Category A EIA. Like Category A EIA, it examines the project’s potential negative and positive environmental impacts and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance. The findings and results of Category B EIA are described in the project documentation (Project Appraisal Document and Project Information Document).

Category C: A proposed project is classified as Category C if it is likely to have minimal or no adverse environmental impacts. Beyond screening, no further EIA action is required for a Category C project.

Category FI: A Category FI project involves investment of the World Bank funds through a financial intermediary, in subprojects that may result in adverse environmental impacts.

Source: The World Bank Operational Policy OP4.01 (Environmental Assessment)

(2) Environment impact identification

Environmental impact object identification in papermaking industry includes natural environment, ecological environment, and social environment factors; it shall include the identification of surface water, atmospheric environment, solid waste, biocommunity, land utilization, and key protection object. In addition to surveying the nature of regional environment and analyzing the project-specific pollutants, the emphasis is laid on environmental identification of highly toxic and environmentally

44

sensitive characteristic pollutants. Environmental impact identification can be accomplished using a matrix, depending on the project-specific features and the nature of the regional environment.

Table 3-1Identification matrix of environmental impacts

Project component

/activity

Environmental parameter

Physical environment Ecological environment Social environment

Water quality

Atm

ospheric environment

Solid waste

Acoustic environm

ent

Anim

al

and

plant com

munity

Biodiversity

Soil fertility

Protected species

Pest

Land utilization

Road and transport

Society and economy

Indigenous People

Public health

Employm

ent

Raw material procurement

Stock preparation

Cooking

Bleaching

Papermaking

Alkali recovery and power

Shipment

Sale

In addition to the general environmental impacts of NWPM industry, more attention shall be paid to those environmental impact factors associated with POPs generation and discharge. According to researches in pollution emission in papermaking, papermaking wastewater is the principal carrier of POPs emission. Water pollutants falling into the following categories deserve special attention.

a) related to POPs generation or emissionb) for which an emission limit has been set by national or local laws or

standardsc) for which a national or local total emission volume has been specifiedd) included in “to be firstly controlled” list by the state or local authoritye) having carcinogenic, teratogenic, or mutagenic propertiesFollowing the above screening rules, the following list includes the key

environmental impacts and risks for BAT/BEP plan EIA in papermaking industry.— Quantity of POPs to be controlled or reduced by BAT/BEP plan and their

45

environmental impacts— Changes to be brought about by BAT/BEP plan in the emission of key

controlled pollutants like COD and ammonia nitrogen and pollutants like AOX and their environmental impacts

— New pollutants to be introduced by BAT/BEP plan and their environmental impacts

— Safety risks in the production and in the use of hazardous chemicals as a result of BAT/BEP plan

3.2.2 Baseline Survey

Baseline survey is divided into two parts: firstly the key features of the BAT/BEP plan enterprise location, its natural environment situation, and social & economic development situation shall be surveyed, key environmentally sensitive areas, wetlands, and different reserves and heritages of historical or cultural interests in the region and their current preservation situation shall be described, detailed description shall cover the leading role of the papermaking enterprise in the region and the significant impact factors; secondly, detailed survey shall be conducted of the production, performance, pollution emission of the enterprise.

3.2.2.1 Survey of Current Regional Situation

Natural and geographical situationA current situation survey shall be performed on the geology, topography, land

features, climate, meteorology, hydrology, soil, landscape features, and geological disaster in the project area and a summarized description shall be provided. This survey may be completed by information collection, to be supplemented by site visit when necessary.

Current situation of environment quality(1) Current situation of air environment quality, current situation of the emission

and control of sulfur dioxide and NOx.(2) Current situation of surface water (rivers, lakes, reservoirs) and underground

water environment quality (including that of estuaries and in-shore waters), water supply-demand equilibrium situation, water consumption for living and industrial purposes, underground water exploitation, etc.

(3) Current situation of acoustic environment in the region, and the proportion of population suffering from above-norm noises, and the distribution of above-norm noises.

(4) Environmental function classification of the region and its control criteria.The survey of current situation of environment quality may be completed by

information collection and site visit, to be supplemented by field monitoring when

46

necessary.

Current situation of society and economy(1) Current situation of social and economic development in the project area and

the exploitation of natural resources.(2) Social, economic, and cultural survey shall include detailed investigation,

analysis, and statistics of the project implementation area and its neighboring area in addition to general survey and analysis.

(3) Discussion and analysis shall cover the supply quantity of NWPM raw materials, fresh water resources, and relevant mineral resources as well as their current exploitation quantity and exploitation prospect.

Survey of current social and economic situation can be completed by information collection, site visit, and analogue methods.

Survey of sensitive areas and key areasSurvey shall cover the distribution and current situation of sensitive ecological

areas in the project area like key water source reserves and precious and endangered wildlife habitats, as well as important natural and humanitarian scenic spots. A catalogue and distribution chart of these sensitive points shall be provided. Information collection is used largely to accomplish this task.

3.2.2.2 Current Situation Survey of the EnterpriseCurrent situation survey of the enterprise principally covers the production,

output capacity, raw materials consumed, production technology employed, pollution discharge, utilization efficiency of major resources, and environmental management system of the enterprise.

Production situation of the enterpriseCurrent production situation of the enterprise is surveyed, particularly on

bleaching, pulp washing, and cooking stage technologies and consumption of major chemicals. The survey includes the following main aspects:

— Enterprise production capability;— Raw material: type, quantity, source, and storage of raw materials;— Main

production technologies employed: production technologies employed in bleaching, pulp washing, cooking, material preparation, and alkali recovery processes and the quantity of major chemicals consumed;

— Energy and resources consumption: energy and water consumption per ton of pulp and per unit value of output.

It is recommended that process flow chart is used to illustrate all the streams of waste throughout the production process, based on which the next section can further describe how these pollution are treated, and upto what level.

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Pollution emission and treatmentEnterprise pollution emission and treatment survey mainly covers POPs-related

dioxin and AOX, as well as COD, ammonia nitrogen, and SO2, which are under special control by the state and the local government.

— Emission of wastewater, waste gas, and waste solids by existing works;— The magnitude, actual treatment capacity, technological process, and actual

performance (inlet and exit indices, removal efficiency) of pollution treatment facilities;

— Existent environmental protection problems (describe whether the major pollutants have been treated and whether the environmental protection facilities have an adequate capacity);

— Verify the generation and emission of pollutants produced by existing works in a format like Table 3-2.

Environmental management situation of the enterpriseA survey is made of the environmental management situation of the enterprise,

mainly covering the structure and staffing of environmental management division, dedicated environmental protection fund, emergency response plan, public involvement mechanism, and environmental protection awareness promotion, etc.

Table 3-2Investigation form of emissions for paper making mills

DescriptionQuantity generated

Target of total volume control

Emission quantity

Emission concentration

Wastewater

BOD5 —

CODcr

SS —

Dioxin —

AOX —

Waste gas

SO2

H2S —

NOx —

Soot —

Solid waste

Sludge — —

Ash — —

Lim mud — —

Note: 1. Unit of quantity generated or emitted: μg for dioxin, ton for other wastewater and waste gas, 10 thousand tons for waste solid; unit of discharge concentration: pgTEQ/L for dioxin, mg/L for other wastewater, and mg/m3 for waste gas.

2. National indices for total discharge volume control during the “11 th Five-Year” period are: COD and SO2.

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3.2.2.3 Baseline Survey Results of Demonstration EnterprisesWe have conducted a survey of the production, environmental pollution

emission, and environmental management of some demonstration enterprises according to the baseline survey scope and methods identified. Because of the time limit, quite a lot of figures are missing in the survey. Table 3-3 and Table 3-4 provide some information of the production technology and environmental pollution emission of the enterprises.

From the survey information of the production technologies, pollution treatment, and environmental management of these demonstration enterprises, we are allowed to reach the following conclusions:

(1) Technological equipment is found relatively backwardNWPM production lines are relatively backward, as most of these surveyed

enterprises are still using rotary spherical digester process, an outdate technology included in the deselection list by the state. Yueyang Paper, an enterprise known to have great technology and financial prowess, had been using vertical cooker until 2008 when this company introduced the advanced continuous digesting equipment. The situation is similar in bleaching process. All the enterprises are using a chlorine-rich bleaching method. So far, no enterprise is using elemental chlorine free (ECF) or totally chlorine free (TCF) bleaching technology. Shanxi Famensi Paper is still using an exceptionally backward bleaching tank H single-stage bleaching technology, a major cause to the generation of POPs in NWPM sector.

Table 3-3 Investigation of Production Situation of Demonstration Mills

DescriptionSichuan Fuhua Paper

Hunan Yueyan Paper

Guangxi Nanning

Sugar

Ningxia MCC Meili

Xinjiang Bohu Reed

Shanxi Famensi

Paper

Raw material consumption

Neosinocalamus: 275t

Reed: 670t

Bagasse: 460t

Wheat straw: 440t Reed: 250t Wheat

straw: 105t

Pulp production capacity

Bamboo pulp: 120t/d

Reed pulp: 290t/d

Bagasse pulp: 200t/d

Wheat straw pulp: 146t/d

Reed pulp: 100t/d

Wheat straw pulp: 35t/d

Main cooking technology

Batch cooking, rotary spherical digester (soda + promoter)

Batch cooking + continuous cookinghorizontal tube + rotary spherical digester

Batch cooking, rotary spherical digester

Continuous cooking, horizontal tube continuous cooking

Continuous cooking, horizontal tube continuous cooking

Batch cooking, rotary spherical digester

Main pulp washing technology

Back flush, 4-stage vacuum drum washer

Back flush, 5-stage vacuum drum

Back flush, 5-stage vacuum drum washer

Back flush, 4-stage vacuum drum washer

Back flush, 4-stage vacuum drum washer

Static back flush, horizontal belt washer

49

washer

Main screening technology

Non-closed screening

Closed screening, 2-stage pressure screening

Closed screening, 2-stage pressure screening

Non-closed screening

Closed screening, 2-stage pressure screening

Non-closed screening

Main bleaching technology

CEHP 4-stage bleaching, bleaching in bleaching tower

Improved CEpH(P) 3-stage bleaching, bleaching in bleaching tower

CEpH 3-stage bleaching (normally without introducing H2O2), bleaching in bleaching tower

CEH 3-stage bleaching, integrating moving and static bleaching

CEpH 3-stage bleaching, bleaching in bleaching tower

H single-stage bleaching, bleaching in bleaching tank

Alkali recovery

Solid treatment capacity 100t/d, alkali recovery rate 88%

2 sets of alkali recovery equipment, solid treatment capacity 270t, 530t/d, alkali recovery rate 83~85%

3 sets of alkali recovery equipment, solid treatment capacity 100t, 160t, 160t/d, alkali recovery rate 85%

3 sets of alkali recovery equipment, solid treatment capacity 130t, 100t, 110t/d, alkali recovery rate 65~70%

solid treatment capacity 400t/d, alkali recovery rate 80%

Solid treatment capacity 100t/d, alkali recovery rate 73%

Wastewater treatment system

Secondary treatment (ABR + contact oxidation), capacity 20,000t/d

Secondary treatment, capacity, 100,000t/d

Separate treatment by effluent quality, anaerobic/aerobic treatment, anaerobic treatment capacity 11,000t/dAerobic 4 series: 50,000t/d

Designed secondary treatment capacity: 50,000t/d

Secondary treatment (the principal part is BIOLAK): design capacity: 25,000t/d

Tertiary treatment (the principal part is oxidation ditch): design capacity: 30,000t/d

Table 3-4 Investigation of Pollutant Emissions of Demonstration MillsDescription

Sichuan Fuhua Paper

Hunan Yueyan Paper

Xinjiang Bohu Reed

Shaanxi Famensi

Ningxia Meili Paper

Guangxi Nanning

Sugar

Emission quantity

Emission

concentrati

on

Emission

quantity

Emission

concentration

Emission

quantity

Emission concentration

Emission

quantity

Emission concentrat

ion

Emission

quantity

Emission concentrat

ion

Emission

quantity

Emissio

n concentra

50

tion

Wastewater

BOD5 278.4 60 1430 28 30 693.5 50

CODcr 663.52 143 5800 128 150 2774 200

SS 315.52 68 1200 25 50 970.9 70

Dioxin 0.008 0.029 0.073 0.067 0.042 0.020

AOX 560

Waste gas

SO2 155.23 2194.5 1200 800

H2S

NOx 860 400

Soot 320 120

Solid waste

Sludge 0.12 — 1.02 — 2.16 — — — 0.58 —

Ash 9 — 12 — 1.44 — — — 3.5 —

Lim mud 1.095 —

0.6

—

3.492

— —

2.5

—

4.6

—

Note: the emission concentration of BOD5, COD, SS, and AOX is in mg/L and their emission quantity is in t; the emission concentration of dioxin is in ug/m3; the emission concentration of SO2, H2S, NOx, and soot is in mg/m3 and their emission quantity is in t; the emission quantity of sludge, ash, and lim mud is t.

(2) Pollution control degree varies from mill to millDue to the differences in nature, size, and technical prowess in these mills, their

pollutant treatment and control performance varies from one to another. Sichuan Fuhua Paper, for instance, being small in size and weak in technical capability, might be satisfied with a pollution control target of achieving the general pollution emission criteria set by the state. Thanks to technical transformation of wastewater treatment equipment, this mill is able to substantially meet the emission criteria in COD, BOD, and SS; however, under certain circumstances above-norm emission is also likely; still, desulphurization treatment has yet to be introduced for air pollution control. Conversely, Yueyang Paper has done a good job in the control of key pollutants like COD, ammonia nitrogen, and SO2; in the past few years, this mill registered a total emission volume less than the limit value; and now Yueyang Paper has begun to tackle the problem of AOX and dioxin emission.

(3) Persistent gaps in environmental managementStakeholders are not fully involved in environmental management. The

environmental commitments of these enterprises do not include any consideration of stakeholders’ expectation and not all the responsible parties are involved during the design of environmental planning and management. Environmental impacts exerted by construction projects or generated during production have an influence upon all the

51

other enterprises, individuals, and communities in the neighborhood; therefore, these mills shall give due consideration to the comments or expectation of the stakeholders in their environmental commitments or during the process of environmental planning and management design. Unfortunately, these demonstration enterprises are not performing satisfactorily in these regards. For example, the representatives involved in the preparation of environmental management system or environmental management policy came from the employees rather than the public: no villager or community representatives were invited in those processes; so, the true public comments or desires were not able to be reflected in an otherwise better environmental management system. POPs pollution control was not incorporated in the environmental management plan or work. None of these enterprises has included dioxin in their environmental monitoring and most of them have yet to establish or maintain a well-institutionalized environmental management recording system.

3.2.3 BAT/BEP Environmental Impact AnalysisThe process of NWPM varies slightly depending on the type of raw material.

Fig. 3-4—Fig.3-7 show the commonly used production process for wheat straw pulping, bamboo pulping, reed pulping, and bagasse pulping in China.

Figure3-4 Flowchart of Typical Wheat Straw Pulping

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Figure3-5 Flowchart of Typical Bagasse Pulping

Figure3-6 Flowchart of Typical Bamboo Pulping

53

Figure3-7 Flowchart of Typical Reed Pulping

3.2.3.1 Potential Environmental Impact of BAT/BEPThe survey of production process of NWPM demonstration mills reveals that

feasible BAT/BEP measures for POPs reduction mainly lie in process improvement, washing method optimization, and cooking enhancement, as well as other BAT/BEP measures.

Besides the pollution reduction effect, this section shall also address what will be the new pollution issues along with the new BAT/BEP.

(1) BAT/BEP measures in bleaching process Process alternatives: ECF or TCF

Adoption of an innovative bleaching process where chlorine bleaching is reduced or replaced is an effective way to cut down dioxins. Such processes include TCF bleaching methods that use O2, O3, H2O2 and enzyme, or ECF bleaching that uses ClO2 instead of Cl2.

Environmental impact: this can effectively eliminate the conditions for dioxin generation. Studies show that chlorobenzenes and chlorophenols among the organic chlorines are the starting reactants in the generation of dioxin and eliminating these substances is effective in reducing the production of dioxin. During bleaching process,

54

a large amount of organic chlorines are produced as a result of chlorination of residual lignin in the pulp. This is why we assert that reduction or substitution of Cl2 can preclude the condition for dioxin generation and thus effectively reduce dioxin products. The TCF bleaching process where O2, O3, H2O2 and enzyme are used in place of Cl2 can achieve a complete disappearance of dioxins during the bleaching process; on the other hand, it has been approved by tests and practices that if a high proportion of Cl2 is replaced by ClO2 in the ECF bleaching process, dioxins can be reduced considerably, because ClO2 is capable of higher oxidation reaction with lignin and therefore strips more lignin.

Process improvement measuresProcess is improved by adding O2, H2O2, enzyme, etc. to minimize the use of

chlorine bleaching agent.Environmental impact: the stripping of lignin is enhanced, the consumption of Cl

is considerably reduced, and less dioxin is generated during subsequent processes. Research findings show that oxygen bleaching can decrease bleaching wastewater by 50%, and significantly slash pollution load like BOD, COD, and chromaticity.

(2) BAT/BEP measures in pulp washing process Intensified pre-bleaching pulp cleaning

The content of organic matters in the aqueous phase can be reduced after pulp cleanness is improved through enhanced vacuum degree, proper location of drop legs and sprayers, and stronger sprinkling.

Environmental impact: improved cleanness of pre-bleaching pulp or organic matter reduction in aqueous phase can work to curb the generation of organic chlorines and further check the formation of dioxins.

Enhanced black liquor extractionFacilities like screw presses may be used additionally to promote the extraction

of black liquor.Environmental impact: enhanced black liquor extraction can greatly lessen the

pollution load in the pulp prior to washing and bleaching, which means a significant removal of COD, BOD, SS and other pollutants from the middle-stage water and a reduction of organic pollutants; this results in smaller risk of dioxin generation during the chlorination process.

(3) BAT/BEP measures in cooking processBAT/BEP measures in cooking process is to improve cooking process by such

methods as adding anthraquinone or polysulfide, adopting modified continuous cooking technologies (MCC, EMCC and isothermal cooking), using modified batch cooking process (RDH, Super Batch) and rapid displacement heating (RDH).

Environmental impact: the improvement of cooking process minimizes lignin

55

and thus reduces the precursor of dioxins. Adding anthraquinone or polysulfide during the digesting process produces a low Kappa number and reduces organic chlorines without affecting the pulp yield; adopting modified continuous cooking technologies (MCC, EMCC and isothermal cooking) can maintain a stable alkalinity throughout the cooking process by multistage feed of digestion reagents, then remove the stripped organic substances from the post-digestion pulp before proceeding to washing; using modified batch cooking process (RDH, Super Batch) and rapid displacement heating (RDH) can concentrate sulfides at the initial digestion, which is conducive to delignification, while the displacement at the final period of digestion can reduce the organic strength and devalue the kappa number, lowering the chances of dioxin generation in the following bleaching process.

(4) Other BAT/BEP measuresBesides the BAT/BEP measures in bleaching, washing and digestion processes,

other measures are also available to effectively reduce the risk of dioxin generation and emission, including disuse of chlorophenol-contaminated raw materials and defoaming agent containing dibenzo-p-dioxins (DBD) or dibenzo-p-furans (DBF), and improvement of sludge management and soda recovery management.

Environmental impact: considering the fact that chlorophenol, a widely used preservative, is one of the starting reactants in dioxin generation, the disuse of cholorophenol-tainted raw materials can reduce dioxins; likewise, as DBD and DBF, the components in the oil-based defoamer used in the chlorination process, are precursors of dioxins, disuse of them may reduce the risk of dioxin generation; finally, as dioxins in the papermaking wastewater are difficult to get rid of and part of them would move to and concentrate in the sludge, proper monitoring and management of sludge may help check dioxin release into the environment.

3.2.3.2 Potential Environmental Impact of BAT/BEP plans and Mitigation Measures

The BAT/BEP plans under consideration here are mainly targeted at POPs control and may bring the following environmental impacts:

— Change in consumption of energy, water and other main resources;— Change in the reduction rate of COD, ammonia nitrogen and other major

pollutants under control;— Change in risk probability of environmental accidents.The following mitigatory measures can be taken against these possible

environmental impacts:— Resource recycling measures: to intensify the effort in recycling main

resources so that the resource consumption would not substantially increase as a result of the implementation of BAT/BEP plans. For example, the rise in waster consumption resulted from intensive pre-bleaching pulp cleaning and the consequent

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increase of water investment per unit of product can be offset by fiber recovery through an advanced multi-disc saveall and promotion of white water reuse rate, so that the water consumption per unit of product would not evidently increase.

— Environmental emergency measures: to enhance the capacity for handling environmental emergencies and responding to risks of BAT/BEP plans. For instance, in case of (chemical or black liquor) leakage during a production accident, the wastewater could be diverted through neutralization pond into an emergency pool if the electricity conductivity and pH value of the water are monitored. After production is stabilized, the wastewater can be pumped slowly from the emergency pool into the grid well. By this way, it is possible to mitigate the general impact of leakage accident upon the biological treatment system.

— Hazard-free treatment measures: to promote pollution treatment capacity to counteract the possible growth of pollutant emission and secondary contamination. For instance, two-stage wastewater treatment may be upgraded to three-stage one; or alternatively, bio-chemical, physicochemical, and electro-chemical methods can be integrated in an optimized way; on the other hand, aeration time may be extended when necessary for oxidizing resin, fatty acid and other toxic compounds, so as to reduce the bio-sludge and help ensure a high treatment quality.

— Management measures: to strengthen the environmental management at some risky links to prevent the negative environmental impacts. For instance, as dioxins in the papermaking wastewater are hard to get rid of and part of these dioxins would move to and concentrate in the sludge, it is important to monitor and manage the sludge treatment rigorously. Specifically, the sludge with dioxin content beyond environment safety standards shall be retreated or hermetically buried to prevent pollution risk caused by leakage of high-dioxin sludge; besides, the sludge can be recycled in order to reduce sludge release into the environment.

Box 3-2 Energy saving measures for pulp & paper making millsThe pulping and papermaking industry, admittedly a large energy consumer, may face further

energy demand increase during BAT transformation. Therefore, the improvement of energy efficiency is crucial to lessening the environmental impact by the pulping and papermaking industry. Bagasse papermakers, for example, can take the following measures for energy conservation:

Stocks or materials should be conveyed by gravity, instead of pumping, to save electric power;

Advanced wet stockpiling and wet cleaning of bagasse may help minimize soluble impurities, so that the alkali consumption can be reduced in the cooking process and, as a result, less energy is consumed.

Enclosed medium-concentration screening machines and technologies can be employed to save power and water.

Combined Heat and Power (CHP) production and power generation by waste heat can not only to control cost but can also meet the whole or part of the electricity and gas demand, and consequently make a good use of energy.

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Adequate thermal insulation materials should be applied, where needed, to the equipment or pipes to reduce heat loss.

Daylighting should be put to good use during plant design in order to economize lighting power.

Gauges, meters and other automatic instruments can be installed in the process flow to control the consumption of electricity and gas and provide a favorable condition for practicing energy conservation management in the plant.

Source: Environmental Impact Statement of Pumiao Paper Mill under Nanning Sugar Industry Co.

3.2.3.3 Recommended Evaluation Indicator SystemThe environmental impacts of different BAT/BEP plans can be analyzed and

evaluated by the following four criteria: 1. UPOPs reduction rate; 2. release change in other pollutants; 3. per unit consumption of main energies and resources; 4. safety risk of production process. Please see Table 3-5 for more information of the evaluation indicator system.

Table 3-5 Suggested Indicators for BAT/BEP Adopting EIA

Description Indicator Unit Explanation

Reduction efficiency

POPs removal per ten thousand RMB

investment

ug/RMB10,00

0

POPs removal per unit comprehensive investment (RMB 10,000) after

implementation of BAT/BEP plans POPs removal per

unit of productug/ton of

pulpPOPs reduction per ton of pulp after implementation of BAT/BEP plans

Wastewater reduction per unit of

productt/ton of pulp

Wastewater reduction per ton of pulp after implementation of BAT/BEP plan

Resource consumptio

n

Water t/ton of pulpChange in water consumption per ton of

pulp product after implementation of BAT/BEP plans

Energy

ton of standard

coal/ton of pulp

Change in energy consumption per ton of pulp product after implementation of

BAT/BEP plans

Change in quantity of

key controlled pollutants

COD t/ton of pulp COD change after implementation of BAT/BEP plans

BOD5 t/ton of pulp BOD change after implementation of BAT/BEP plans

Ammonia nitrogen t/ton of pulp Change of ammonia nitrogen after implementation of BAT/BEP plans

AOX t/ton of pulp AOX quantity change after implementation of BAT/BEP plans

Risk and safety Accident probability %

Operation safety level of BAT/BEP plan and the probability of environmental risk

resulted from the use of hazardous substances or a production accident

Note: change in quantity of key controlled pollutants refers to the change in emission quantity of these pollutants as found in the final wastewater released by NWPM mills.

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Figure3-8 Suggested Methods for Evaluating BAT/BEP Alternatives

The evaluation formula is given below:Y=αA+βB+δC+εD

Where:Y is the comprehensive environmental impact of an alternative;A, B, C, and D are reduction efficiency, release change in other pollutants, per unit consumption of main energies and resources, and safety risk of production process respectively;α, β, δ, ε indicate the weight of corresponding indicator, which are to be assigned by experts.

Eco-compass (see Fig. 3-8) is used to assess the environmental impact of BAT/BEP alternatives and the alternative with highest score is the best solution worthy for recommendation.

3.2.4 Environmental Management PlanEnvironmental management plan (EMP) is a component of EIA, and also an

important link between the potential environmental impacts and corresponding mitigation measures. EMP has a purpose of bringing forward a set of countermeasures against inevitable environmental impacts in the project (like dioxins generated by chlorine bleaches in the bleaching process) for the sake of environment control and treatment in a technologically feasible, financially sustainable and operational way (such as the application of ECF or TCF techniques in the bleaching process), identifying the duties and authority of the contractor, the consultant, the operator and the environmental administrative authority during the construction and operation of the project, establishing rules for environmental mitigation, environmental administration and organization structure, so as to eliminate or compensate as far as possible the project’s negative effect on the society or the environment and have it

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reduced to an acceptable level. EMP usually includes major environmental impacts and corresponding mitigation measures, environmental monitoring and supervision program, training program, etc.

3.2.4.1 Preliminary Work for EMPEMP is the result of the environmental impact assessment that is commissioned

by the project owner to an environmental assessment agency, and it is the project owner’s responsibility to have it implemented. The main function of EMP is to provide the project undertaker a guideline for application of mitigation measures. This guideline needs to cover the countermeasures against potential environmental impacts, as well as the method, time and object of measure implementation. For this purpose, the NWMP mills have to take some requisite preliminary actions before the preparation of EMP. Broadly speaking, there are five steps:

The first step: Training of enterprise employees and officialsTraining the employees and officials of NWMP mills is a foundation of the

establishment of the environmental management system and the implementation of EMP, because the promotion of the awareness of the importance of environmental management can remarkably enhance the efficiency of the work. The training may largely centers on relevant standards of environmental management system and potential environmental impacts (for example, dioxin release in the wastewater) caused by the business. Training programs should be customized for employees and officials according to their different post and role.

The second step: Establishment of a task group for EMP preparationThe task group is principally responsible for setting up an environmental

management system based on the current situation of the enterprise and drafting an EMP appropriate to the development of the enterprise. The task group should consist of workers and leaders from all functional departments. The leaders’ working task may include the master plan of environmental management system, determining relevant environmental objectives and policies, dividing and assigning the work of EMP preparation. The representatives from various departments should take part in the specific work in EMP preparation, depending on their respective roles and functions and according to the assignments made by the leaders.

企业教育培训企业教育培训企业教育培训企业教育培训企业教育培训

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Figure 3-9 Working Flowchart for Preparing an EMP

The third step: Determination of environmental factors and initial reviewThe determination of environmental factors includes the determination of scope,

data collection and field inspection, and making a list of environmental impacts. Data collection is further divided into two aspects: 1. collection and compilation of rules and laws, standards, technical guidelines, polices, etc. in connection to environmental management in China, and preliminary establishment of a framework of rules and laws; 2. collection of materials with regard to the surrounding environment and the construction and operation of the project, particularly BAT/BEP plans. The field inspection is principally targeted at the internal environment and surrounding environmental of the enterprise in order to identify the key points to be addressed in environmental management on the basis of available information.

The initial review is a primary survey and analysis of the environmental problems and factors possibly faced by the enterprise according to the list of environmental factors. In most cases, focus would concentrate on the following four aspects: 1. to see whether the company operates in compliance with laws, regulations and other requires (such as whether it has a wastewater release license); data

Current situation of the environment

List of environmental

impacts

Data collection and field inspection

Focus on POPs release

Determination of scope

Relevant rules and laws

Indoctrination and training

Making environmental policies

Establishing environmental objective and indicator system

Determination of environmental factors

Initial review

EMP preparation task group

EMP outline

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collection at the last step can improve the efficiency of this job; 2. to identify the potential problems and factors of environmental impacts; the work at the last two steps can lay a foundation of this work; 3. to inspect the current management work and procedures (like which department is responsible for managing and treating dioxins in the wastewater); 4. to find out past environmental accidents, punishments, and preventive measures. In addition, comments and suggestions from related parties should be considered during the process of review.

The fourth step: Making environmental policiesEnvironmental policies represent the values of an enterprise toward potential

environmental impacts, the environmental commitments made by the enterprise toward related parties and the society, and the guideline and orientation of the enterprise’s environmental management.

The fifth step: Establishing environmental objective and indicator systemThe overall environmental objective and the environmental indicator system

should be established, based on the nature, scale and environmental impacts of the enterprise’s activities, products or services, in consideration of previous work and current situation of the environment. In this particular project, the indicator system and the objective of control and treatment should focus on POPs (mostly dioxins) generated in the process of production.

Upon the completion of the above five steps, the work may proceed to the stage of EMP preparation.

3.2.4.2 EMP StructureFor the purpose of this project, the main content of EMP includes the following

six parts. (1) Project description and backgroundThis part is a brief introduction of the NWMP new construction, rebuilding or

expansion projects.(2) Major environmental impactsFollowing the survey of the current environmental situation of the pulping and

papermaking project, this part puts its emphasis on the potential impacts of releasing dioxin into different environment media during the operation,.

(3) Mitigatory measuresMitigatory measures are flexible and cost-effective means and methods to

resolve the major environmental challenges posed by dioxin release so as to reduce the potential environmental hazards to an acceptable level.

(4) Institutional arrangementInstitutional arrangement is carried out to define the duties and powers of

environmental management division, environmental monitoring division, and other

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related divisions in a pulping and papermaking enterprise with regard to the execution of dioxin control and mitigatory measures, so that each unit can perform their roles in a coordinated way.

(5) Environmental supervision and monitoring programThe environmental supervision and monitoring procedures should be established

in a pulping and papermaking enterprise to guarantee the successful execution of mitigatory measures against dioxin release and to ensure that the environmental impacts of dioxins are reduced to an acceptable level.

(6) Training programRelated staff will receive trainings in pollution control, monitoring know-how,

equipment operation and maintenance, as well as health and safety. According to Environmental Assessment Sourcebook—Environmental

Management Plan published by the World Bank, special attention should be given to mitigatory measures, environmental monitoring and institutional arrangement.

3.2.5 Public Involvement and Information DisclosureAs required by the World Bank, the involvement of affected population, local

NGOs, and other individuals or organizations is an important part of the preparation before EIA. The Public Involvement in Environmental Assessment: Requirements, Opportunities and Issues published by the Environment Division of the World Bank stipulates that public involvement is mandatory for project preparation and shall be implemented throughout the entire process of environmental assessment. Public involvement mainly covers two aspects: dissemination of project-related information and public participation.

3.2.5.1 Information DisseminationIn the course of project preparation and environmental assessment, information

should be provided at regular intervals regarding the progress of the project and environmental assessment, in a form that is meaningful for and accessible to the participants from the public. At the initial stage of environmental assessment, the information normally includes a summary of the project description and objectives, and the potential negative impacts from the proposed project. Once the EA report for the project has been prepared, a summary of its conclusions should be disclosed. In addition, to ensure the effective dissemination of information, all forms of mass media should be utilized simultaneously, such as local television, radio, newspapers and leaflets.

3.2.5.2 Public ParticipationPublic participation is a voluntary process in which local residents and affected

groups come together to share, negotiate and control the decision-making process in the project design and management. This process invites a greater degree of

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involvement than consultation. Specifically, it falls into three stages:1) Environmental impact scoping. At this stage, public consultation usually

focuses on the fundamental work preliminary to project preparation or implementation.

2) Project preparation. Public consultation centers on the completeness of EA Terms of Reference (TOR)

3) Project implementation. The public generally participate in the monitoring and evaluation of environmental issues and environmental protection practices during the project construction period.

Public consultation, the key aspect of public involvement, should be performed during the following three phases of EA.

1) Consultation during environmental impact scoping. In the first instance, the project should establish a framework for public consultation activities; then, the project owner, related governmental authorities and public participants should take part in discussions that lead to the preparation of TORs for the EA; next, the EA task group should develop a draft of EA TOR after gathering and combining the suggestions from various parties; finally, upon dissemination of the draft TOR, the project owner should hold follow-up meetings with the public to discuss changes and additions to the issues already identified in the draft.

2) Consultation during EA preparation. During EA preparation, communication with affected groups is carried out mainly in the form of questionnaire surveys or household visits.

3) Consultation during EA draft report completion. The completed draft EA report should be publicized regarding its main contents and conclusions in the forms of seminar, simply written materials, visual representation or video. Then, a public consultation meeting is convened to discuss the draft EA report.

Please refer to Box 3-3 for the recommended methods specified in Interim Measures on Public Participation in EIA issued by the Chinese government.

Box 3-3 Recommended methods in Interim Measures on Public Participation in EIA

● Prior to submitting the environmental impact report to the environmental protection authority for review and approval or reconsideration, the project owner or the EA agency acting on his behalf may give the public feedback, in an appropriate way, about how their advice and suggestions have been received.

● Comprehensive consideration shall be given, by the project owner or the EA agency acting on his behalf and the environmental protection authority, to such factors as geographical location, occupation, professional background, expression capacity, and degree of impact and a reasonable selection of citizens, legal entities and other organizations is needed to seek advice and suggestions.

● The raw data about the advice and suggestions shall be collected and documented by the project owner or the EA agency acting on his behalf and the environmental protection

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authority.

● The project owner or the EA agency acting on his behalf shall take public opinions into serious consideration and explain, in the environmental impact report, why their suggestions are accepted or rejected. The environmental protection authority may set up an expert panel to review the statement in the environmental impact report regarding the acceptance or rejection of public opinions, to see if this acceptance or rejection is justified, and to give their advice.

● The public may lodge a complaint to the environmental protection authority and attach their detailed written opinions, if they are dissatisfied with the project owner or the EA agency acting on his behalf for not stating the reasons for rejection or for unjustified rejection of their suggestions. The environmental protection authority responsible for reviewing and approving or reconsidering the report may verify the public opinions if deemed necessary.

Source: Interim Measures on Public Participation in EIA issued by the SEPA in 2003

3.3 EMP Implementation

3.3.1 Institutional Arrangement

3.3.1.1 Environmental Management BodyIn view of the great difference in work scope and nature (temporary vs. long-

term) of environmental management between the construction period and the operation period, environmental management units should be set up separately for these two periods and multistage responsibility system should be adopted. Upon the completion of construction, the environmental management unit responsible for this period should be dissolved and that in charge of the management during operation period should be established. A certain overlap of time, however, is allowed as the case may be.

(1) Environmental supervision unit during the construction periodAn environmental supervision unit having no interest in the project shall be

established independent of the construction department to ensure the effectiveness and fairness of environmental protection. The team members are required to be duly qualified, properly experienced and capable of his work. Please see Table 3-6 for the posts in the environmental supervision unit.

Table 3-6 Environmental Supervision Units during the Construction Period

Post Number of staff

Team leader 1

Ambient air supervisor 1

Noise supervisor 1

Wastewater and solid waste supervisor 1

Complaint hotline staff 1

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(2) Environmental supervision body during the operation periodThe environmental supervision during the operation period is a long-term and

complicated task. It is recommended to set up an environmental protection division in parallel with other administrative divisions after the NWMP project is completed and put into production. Please see Table 3-7 for the settings of environmental protection division.

Table3-7 Settings of Environmental Protection Division in an Enterprise

Division Work scopeStaff

requirements

Environmental Management

Div.

Supervision and management of production process and pollution control; especially the production processes in which dioxins are possibly generated (like pulp bleaching process) and the wastewater workshop shall have supervision post to manage dioxin release into wastewater.

Largely technicians specialized

in environment engineering or analytical chemistry,.

Environmental Monitoring

and Environment Technology

Div.

Professional monitoring technicians are responsible for monitoring the ambient air and the emission of wastewater and waste gas;

The post of wastewater monitoring should be purposefully set up to oversee dioxin release;

Maintenance staff are responsible for repairing and servicing the equipment for pollution control and monitoring;

Related technicians are responsible for technical transformation of production process and pollution control.

3.3.1.2 Duties and Authorities of Environmental ManagementIt would be helpful in effectively implementing EMP if the EM duties are

distributed among functional departments or employees with adequate capability and resources and if the duties and tasks of each division or post are clearly defined. Based on this rationale, the enterprise needs to specify the duties and authorities of related departments or employees, including their responsibilities, roles or positions in the environmental management, report channels, etc., after the environmental management units are established, in order to the effective implementation of EMP. Please see Box 3-4 for the detailed departmental duties during the construction period.

3.3.2 Supervision and InspectionSupervision and inspection are a system designed to safeguard the smooth

implementation of EMP. Therefore, the tasks and corresponding responsibilities of supervision and inspection shall be fully addressed in the EMP.

3.3.2.1 Information Exchange ProceduresAccording to the requirements of environmental management, information

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exchange shall be performed, wherever necessary, among departments and posts inside an NWMP enterprise; meanwhile the enterprise shall also make information available externally (to related parties, the general public, etc.). All such communication shall be recorded, documented, and put on file. To facilitate this process, the NWMP enterprise should prescribe the rules and procedures for information exchange among different levels, departments, posts and stakeholders. Particularly, the information emphasis shall be placed on the policies, objectives and indicator concerning dioxin release and the environmental management process.

3.3.2.2 Environmental Monitoring ProceduresEnvironmental monitoring procedures shall be established by the NWMP

enterprise regarding the key environmental factors and the enterprise’s key environmental activities, which have been identified in the preliminary work of EMP preparation. These procedures cover the following four areas: (1) procedures for monitoring indicators, especially dioxins in the wastewater; (2) procedures for inspecting and servicing equipment or instrument; (3) monitoring methods and operation procedures for key pollutants (for example, how to monitor dioxin content in the wastewater); (4) procedures for training and qualification of monitoring personnel.

3.3.2.3 Corrective and Preventive MeasuresMonitoring results and related information are collected and compiled to identify

and handle nonconformance (such as the inconsistency between collected data and monitoring results), methodology and procedures are established for handling, and monitoring indicators are removed or added, so as to ensure the preset objectives are attainable. The work include: (1) studying the reasons of nonconformance (for example, the layout of monitoring points is ill-conceived); (2) applying effective corrective measures; (3) revising related methods and procedures; (4) recording corresponding results; (5) perfecting monitoring indicator system; (6) improving environmental objectives (for example, raising the level of wastewater dioxin release control without affecting the attainability of environmental objectives).

Box 3-4 Responsibilities and Duties of Departments during Construction Period

— Responsibilities of the project owner

The project owner is responsible for ensuring the implementation of related environmental management measures required by the World Bank, assisting environmental protection authority in routine environmental supervision and inspection, drafting and issuing rules and regulations in respect of environmental management in this project, monitoring environmental data, reporting to the local environmental protection bureau and the World Bank about the environmental management and protection during the construction period, and coordinating with the related authorities, agencies and NGOs in relation to the environmental management

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issues.

— Obligations of the contractor

The contractor plays a key role in environmental management, pollution control, prevention and treatment, and other related work during the project construction period. Therefore, the contractor shall meet the following requirements:

● To have a strong capacity to ensure the effective implementation of EMP;

● To be trained in environmental protection and environmental management prior to the commencement of construction;

● To incorporate the mitigatory measures for construction period in the bidding documents, and finally in the construction contract as a contractual obligation of the contractor;

● To monitor the environmental activities and periodically provide environmental performance log; the records are supervised and reviewed by the project office and the construction supervision team;

● To provide each sub-project with full-time environmental workers, who shall receive training in order to be adequately qualified for their job;

● To communicate and negotiate with local communities during the construction period, and to set up a bulletin board at each construction section, where particular construction activities and schedules are publicized, together with the contact person and contact information for complaints and suggestions in connection with the construction activities;

— Environmental consultant engineer

The consultant engineer is responsible for supervising the implementation of environmental protection measures on site.

● To make sure that all permits, requirements and EMP related to this project have been ready prior to the commencement of the construction;

● To verify that all the employees from the contractor and the operating unit are executing the environmental protection measures as required by the contract;

● To identify the occasion where special studies and activities are required, and to effectively implement special measures at regular intervals;

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● To communicate with departments, units, and posts, to give advice on remedies, to provide remedy measures for items not in agreement with the project purpose, to issue official guidance to the contractor and the operating unit;

- Environmental monitoring agency

The environmental monitoring agency is selected by the project owner according to the environmental monitoring program. The environmental monitoring agency is responsible for monitoring during the construction period in accordance with the environmental monitoring program. Specifically speaking, the agency shall establish and improve rules and regulations, and accomplish the monitoring tasks in strict compliance with environmental laws, regulations and specifications; build up a statistical archive for monitoring and analytical data, and fill and submit environmental report; complete the environmental monitoring work assigned by the environmental protection division; strengthen the maintenance and calibration of monitoring instrument and equipment to ensure the normal progress of the monitoring work.

— Environmental protection division of the World Bank

To supervise the environmental protection throughout the whole process of construction and request for environmental protection of the project according to related requirements of the Word Bank and the responses of the project owner to the related environmental issues in the construction period.

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3.3.3 Environmental Monitoring Program

3.3.3.1 Monitoring ObjectiveEnvironmental monitoring, during both the construction and the operation

period, is performed for the following purposes: to fully and promptly understand the pollution dynamics of a planned NWMP project (including the dioxin pollution during the operation period); to acquire the information about the change of environment quality and the scope of environmental impacts caused by production and wastewater discharge in the project area; to report to the authorities in a timely way, and; to provide a scientific foundation for environmental management and innovation of production and pollution control technologies of the project.

3.3.3.2 Implementation of Monitoring ProgramThe sensitive points which may be apparently polluted as shown in the

environmental impact prediction will be selected as monitoring points. Acoustic environment, ambient air, and surface water, which are mostly vulnerable to the pollution, are included in the scope of monitoring, as appropriate to the pollution situation during the construction period and the operation period. The monitoring factors are dependent on the pollutant characteristic factors determined through engineering analysis. The monitoring analysis methods correspond to the methods specified in the Environmental Monitoring Technical Specifications, Technical guidelines for Environmental Protection in Paper Industry Project for Check and Accept of Completed Project, and other specifications. In addition, the national environmental assessment standards are chosen as the assessment standards for this project.

(1) Monitoring programPlease refer to Table 3-8 and Table 3-9 for environmental monitoring program

during the construction and operation periods of NWMP project. For the monitoring program during construction, the Table 3-8 can be tailored to actual situation, i.e. if the old facility is stopped or dismantled and the new facility is installed, the monitoring program during construction can be streamlined.

Table 3-8 Environmental Monitoring Program during Construction Period

Monitoring elements

Monitoring factor

Monitoring point location Monitoring frequency

Water environme

nt and wastewater

pH, SS, COD, BOD5, water temperature,

volatile phenols, sulfides, lead,

mercury, chromaticity, etc.

The monitoring points will be arranged according to the actual situation and in compliance with Technical

Specifications for Monitoring of Surface Water and Wastewater

The sampling frequency will be set according to the actual

situation and in compliance with Technical Specifications for

Monitoring of Surface Water and Wastewater (HJ/T 91-2002)

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(HJ/T 91-2002)

Air and waste gas

TSP, PM10, SO2, NO2, CO, etc.

The monitoring points will be arranged according to the actual situation and in compliance with Technical

Specifications for Emission Monitoring of Stationary Source (HJ/T

397-2007)

The sampling frequency will be set according to the actual

situation and in compliance with Manual Methods for Ambient Air

Quality Monitoring (HJ/T194-2005)

Acoustic environme

ntLeqdB(A)

The monitoring points will be arranged according to the actual situation and in

compliance with Measurement Method for Noise from Construction

Site (HJ/T 397-2007)

The sampling frequency will be set according to the actual

situation and in compliance with Measurement Method for Noise

from Construction Site (HJ/T 397-2007)

Table 3-9 Environmental Monitoring Program during Operation Period

Monitoring elements

Monitoring location Monitoring factor Monitoring frequency

Air

Source of manageable

emission

Stock preparation

TSP.PM10The sampling frequency will be set according to

the actual situation and in compliance with

Technical Specifications For Emission Monitoring

Of Stationary Source (HJ/T 397-2007)

The sampling frequency will be set according to

the actual situation and in compliance with Manual Methods for Ambient Air

Quality Monitoring (HJ/T194-2005)

Blow tank, boiler

Soot, SO2, NO2, smoke blackness

Alkali recovery furnace

Soot, SO2

Source of non-manageable

emission

Storage yard

TSP.PM10

Plant boundary

and sensitive

target

Ammonia, hydrogen sulfide

Water quality

Discharge opening of workshop or production

facilitiesAOX, Dioxin

The sampling frequency will be set according to

the actual situation and in compliance with

Technical Specifications for Monitoring of Surface

Water and Wastewater

Inlet and outlet of domestic sewage treatment facilities

SS, pH, COD, BOD5, ammonia nitrogen, total phosphorus,

Dioxin

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(HJ/T 91-2002)

Outlet (wastewater main outlet, domestic sewage

discharge)

Chromaticity, SS, pH, COD, BOD5,

Ammonia Nitrogen, TP, TN, Petroleum,

Dioxin

Sensitive target

Surface water

SS, pH, COD, BOD5, ammonia nitrogen,

total phosphorus, total nitrogen, petroleum,

Dioxin

Sea water

DO, pH, COD, BOD5, inorganic nitrogen, active phosphate ,

Dioxin

Noise

Noise at the boundary of the plant

Continuous equivalent sound level A

The sampling frequency will be set according to

the actual situation and in compliance with Method

of Measuring Noise at Boundary of Industrial Enterprises (GB12348-

2008)

Noise at sensitive target location

Note: reference is drawn mainly from Technical guidelines for Environmental Protection in Paper Industry Project for Check and Accept of Completed Project (HJ/T 408-2007)

(2) Monitoring methodology and meansMonitoring methodology and means are decided according to the requirements

of national standards and environmental authorities. See Table 3-10 for reference with regard to the monitoring methodology and means of each monitoring factor during the construction period and the operation period.

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Table 3-10 Environmental Monitoring and Analysis Standards

Monitoring elements

Monitoring factor

Analysis method and standard

Air and waste gas

SO2

HJ/T 56-2000 Determination of Sulphur Dioxide from Exhausted Gas of Stationary Source Iodine Titration Method

HJ/T 57-2000 Determination of Sulphur Dioxide from Exhausted Gas of Stationary Source Fixed-Potential Electrolysis Method

PM10GB 6921-86 Determination of the Concentration of Airborne Particulate Matters

NO2GB/T 15436-1995 Ambient Air—Determination of Nitrogen Oxides—Saltzman Method

COHJ/T 44-1999 Stationary Source Emission—Determination of Carbon Monoxide—Non-Dispersive Infrared Absorption Method

Smoke and dust

GB 5468-91 Measuring Method for Smoke and Dust of Boiler Emission

GB/T 16157-1996 The Determination of Particulates and Sampling Methods of Gaseous Pollutants Emitted Gas of Stationary Source

Smoke blackness

GB 5468-91 Measuring Method for Smoke and Dust of Boiler Emission

Hydrogen sulfide

GB/T 14678 Air Quality—Determination of Hydrogen Sulfide, Methyl Sulfhydryl, Dimethyl Sulfide and Dimethyl Disulfide—Gas Chromatography

Water environment

and wastewater

Water temperature

GB/T 13195-91 Water Quality-Determination of Water Temperature—Thermometer or Reversing Thermometer Method

Volatile phenol

HJ 503-2009 Water Quality—Determination of Volatile Phenolic Compounds—4-AAP Spectrophotometric Method

Lead GB/T 7475-87 Water Quality— Determination of Copper, Zinc, Lead and Cadmium; Atomic Absorption Spectrometry

Mercury GB/T 7468-87 Water Quality—Determination of Total Mercury—Cold Atomic Absorption Spectrophotometry

Sulfide

GB/T 16489-1996 Water Quality—Determination of Sulfide—Methylene Blue Spectrophotometric Method

GB/T 17133-1997 Water Quality—Determination of Sulfide—Direct Development of the Spectrophotometry

Chromaticity GB/T 11903-89 Water Quality-Determination of Colority—Dilution Multiple Method

pHGB/T 6920-87 Water Quality—Determination of pH Value—Glass Electrode Method

SSGB/T 11901-89 Water Quality—Determination of Suspended Substance—Gravimetric Method

COD GB/T 11914-89 Water Quality—Determination of the Chemical Oxygen Demand—Dichromate Method

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BOD5HJ 505-2009 Water Quality—Determination of Biochemical Oxygen Demand for 5 Days (BOD5) for Dilution and Seedling Method

DOGB/T 7489-87 Water quality—Determination of Dissolved Oxygen—Iodometric Method

AOXGB/T 15959-1995 Water Quality—Determination of Adsorbable Organic Halogens (AOX)—Microcoulometric Method

DioxinHJ 77.1—2008 Water Determination of Polychlorinated Dibenzo-p-Dioxins(PCDDs) and Polychlorinated Dibenzofurans(PCDFs) Isotope Dilution HRGC-HRMS

Ammonia nitrogen

GB/T 7478-87 Water Quality—Determination of Ammonium—Distillation and Titration Method

GB/T 7479-87 Water Quality—Determination of Ammonium—Nessler

GB/T 7481-87 Water Quality—Determination of Ammonium—Spectrophotometric Method With Salicylic Acid

HJ/T 195-2005 Water Quality—Determination of Ammonia-Nitrogen Gas—Phase Molecular Absorption Spectrometry

Total phosphorus

GB/T 11893-89 Water Quality—Determination of Total Phosphorus—Ammonium Molybdate Spectrophotometric Method

Total nitrogen

GB/T 11894-89 Water Quality—Determination of Total Nitrogen UV Spectrophotometric Method—Alkaline Potassium Persulfate Digestion Method

HJ/T 199-2005 Water Quality—Determination of Total-Nitrogen Gas-Phase Molecular Absorption Spectrometry

PetroleumGB/T 16488-1996 Water Quality—Determination of Petroleum Oil, Animal and Vegetable Oils—Infrared Photometric Method

Inorganic nitrogen GB 3097-1997 Marine Water Quality Standard

Active sulfate

Acoustic environment

Noise at the boundary of

the plant

GB 12348-2008 Emission Standard for Industrial Enterprises Noise at Boundary

Noise at sensitive

target locationGB 3096-2008 Environmental Quality Standards for Noise

3.3.4 Information Record and Report

3.3.4.1 Environmental Protection ArchiveFor the effective operation of environmental management system, a sound

documentation system should be established to keep the data in the following aspects:(1) Laws and regulations (focus on the laws and regulations regarding NWPM

industry and dioxin reduction and control)

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(2) Environmental licenses (such as effluent discharge license);(3) Environmental factors and related environmental impacts (for example, the

impacts inflicted by dioxin in the discharged wastewater upon the local waters);(4) Related trainings(5) Inspection, calibration and maintenance activities;(6) Monitoring data (collection and management of monitoring data in relation to

dioxin in the wastewater);(7) Corrective and preventive measures;(8) Information on related parties;(9) Environmental review records;(10) Environmental assessment and review.In addition, the above records need to be controlled as necessary, including

marking, collection, cataloguing, filing, storage, management, maintenance, retrieving, storage period, disposal, etc.

3.3.4.2 Information ReportThe contractor, the monitoring agency and the project office shall record the

project progress, EMP implementation, environmental quality monitoring results and other information during the execution of the project, and report to competent authorities in a timely manner. The following three main parts shall be included:

(1) The monitoring agency and the contractor shall make a detailed record about EMP implementation;

(2) The project progress report (monthly, quarterly or annual as the case may be) prepared by the project office shall include EMP progress, like the progress and the results of EMP implementation;

(3) The yearly EMP implementation report of the project. The EMP implementation report generally covers the following: a) implementation of training programs; b) project progress, like the construction progress of the wastewater treatment plant; c) the public complaints, including the content of complaints, the way of handling and the degree of satisfaction; d) EMP implementation of the next year.

3.3.5 Training ProgramIn-house trainings in related knowledge and skills shall be provided to all staff of

the enterprise in order to attain the environmental policies, objectives and standards, to ensure the environmental management is performed in an effective and smooth way, and to reduce and control dioxin generated during the operation of the NWPM enterprise. In the trainings, not only the importance and significance of dioxin control should be introduced, but the knowledge, including methods and skills required for efficient accomplishment of tasks, should also be provided to the staff (for example, trainings in how to monitor the amount of dioxin in wastewater, how to use

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monitoring instruments). The environmental impacts resulted from improper operation in the work shall also be emphasized (for example, excessive use of bleaches in bleaching process). In addition, indoctrination and training are needed on the latest applicable information, like laws, regulations, internal standards, company policies, and objectives, etc. Table 3-11 is the staff training program prepared according to ISO14004.

Table 3-11 Staff Training Program

Project phase

Type of training Trainee Training purpose

Before the operation

of the project

Raising the awareness of the strategic importance of environmental management

Senior officials

To obtain effective commitment to environmental policies of the enterprise, and to achieve coordination

Promoting the overall environmental awareness

All the staff

To obtain commitment to environmental policies, objectives and standards, and to gradually develop a sense of personal responsibility

Improving skills

Employees responsible for environmental duties

To improve the environmental performance (activities) in certain divisions (operation, R&D, engineering) of the enterprise

Conformance to laws, regulations, and policies, etc.

Employees whose activities my affect the conformance

To understand the requirements of the laws and the enterprise after the training

In addition, the enterprise shall provide related environmental officers with necessary trainings in equipment operation and maintenance, environmental monitoring skills, health and safety and environmental management, and emergency response. Table 3-12 is the training program for environmental officers.

Table 3-12 Training Program for Environmental Officers

Project phase Trainee Number of persons

Construction period

Environmental protection personnel from the investing company

To be determined as per actual situation

Environmental management personnel

Environmental consultant engineer

Emergency personnel

Before the operation of the project

Environmental management personnel To be determined as per actual situationEnvironmental monitoring personnel

Environmental research personnel

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Equipment maintenance personnel

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Annex 1 TOR for Environmental Assessment of BAT/BEP plan in an NWPM Project

1 Background and Purpose

In National Implementation Plan (NIP) of the People’s Republic of China for Stockholm Convention on Persistent Organic Pollutants, pulping and papermaking industry has been included in the first six major industries chosen for dioxin release reduction. Due to the scarcity of timber resources, non-wood fiber pulping enterprises take a great proportion in this sector in China. These enterprises, small in size and lacking BAT/BEP, stand as a crucial barrier to the improvement of the overall environmental protection of NWPM industry, because of their weak capacity of UPOPs reduction and control. In order to fulfill the obligations under Stockholm Convention of comprehensive reduction in emission of POPs and other pollutants and to further the sustainable development of the industry, the Ministry of Environmental Protection and the World Bank will cooperate to carry out a UPOPs reduction project in Chinese NWPM industry with the focus on BAT/BEP transformation. The enterprises engaged in this project are required to complete an environmental impact assessment for the BAT/BEP plans in accordance with Environmental Impact Assessment Law of People’s Republic of China and the World Bank policies on environmental assessment.

2 Work Objective

The objective is to make an all-round environmental impact assessment of the BAT/BEP plans of non-wood papermaking enterprises in compliance with the applicable laws and regulations in China and the policies and procedures of the WB concerning environmental impact assessment, submit EIA report and have the report approved by environmental management authorities and the World Bank.

3 Task Requirements

The current situation of the environment in the area of the enterprise involved in BAT/BEP transformation shall be surveyed; it is also required to analyze the environmental impacts likely to be brought about by the BAT/BEP plans, determine the environmental objectives and evaluation criteria, establish mitigation measures and countermeasure against the BAT/BEP environmental impacts; and finally a completed EIA report will be presented. The detailed requirements are given below:

Task 1: Review of current operations of the project mills, in terms of all pollution streams, on-going pollution control measures, compliance status, monitoring capacity and EHS management performance.

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Task 2: Alternative Analysis

EIA will need to describe alternative analysis in terms of comparisons between “with and without project” scenario, applicable technologies if appropriate, compatibility with national, local and sector development plans, different resource conservation and waste control strategies, and technical designs.Task 3: Making an engineering analysis of the BAT/BEP transformation to identify potential environmental impacts

The potential impacts of a particular BAT/BEP plan upon the natural environment, ecological environment and social environment are identified based on the regular pattern of general environmental impacts and POPs-specific environmental impacts caused by the papermaking industry. The characteristic pollutants, highly poisonous and sensitive to the environmental impacts shall be given the greatest attention.

Task 4: Surveying the current environment situation in the project area

Current environment situation survey is divided into two areas: firstly the key features of the BAT/BEP enterprise location, its natural environment situation, and social & economic development situation shall be surveyed; secondly, detailed survey shall be conducted of the production, performance, pollution emission of the enterprise.

Task 5: Analyzing and predicting the BAT/BEP environmental impacts

Analysis should be made as to the potential BAT/BEP environmental impacts including the change in release of dioxin, COD, ammonia nitrogen and other pollutants and the change in consumption of raw materials and resources; in addition, prediction should be made about the trend of the environmental impacts.

In case of old facility decommissioning, the EIA shall address the potential environmental impacts related to decommissioning, proper handling of dismantlement, and disposal of waste and hazardous material/waste.

Task 6: Making countermeasures and mitigatory measures for environmental protection

Mitigatory measures and countermeasures against BAT/BEP environmental impacts are made; review and validation are made from technological and economic perspectives.

Task 7: Making EMP for POPs controlThe EMP includes the following issues: institutional arrangement for POPs

control and management, environmental supervision and monitoring program, and trainings of related personnel in pollution control, monitoring technologies, equipment

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operation and maintenance, etc. The EMP shall also include occupational health and safety issues.

Task 8: Public consultationTwo rounds of public consultation as per OP4.01 and national regulations, i.e. (1)

TORs stage and (2) after draft EIA is available. People to be consulted: local affected communities/institutions/business, local governments, plant workers etc. Means of consultation: public meetings, individual interviews and questionnaire survey. Information disclosure: initial disclosure of project information and potential environmental issues, second disclosure of draft EIA/EMP reports.

It is important to record the details of these two rounds of consultation in the EIA report (the consultation process, i.e. date, locations, number/type of people participated, key issues raised and how these issues are addressed in EIA and the project design). The draft EIA shall be disclosed in publicly accessible places (e.g. local government and/or internet) with announcement published through local newspaper.Task 8: Providing a completed EIA report

The EIA report shall conform to OP/BP4.01 of the World Bank and the EIA technical guidelines of China and incorporate necessary descriptions, collection of fundamental data, and requisite drawings.

The final EIA report includes the following information as a minimum:

(a) Executive summary, briefing the major findings and recommended actions;

(b) The framework of policies, laws and administrative regulations, discussing the question as to under what framework of policies, laws and administrative regulations is the environmental assessment carried out; including both Chinese and World Bank EHS guidelines.

(c) Review of current plant operation, as mentioned in Task 1.(c) Alternative analysis

(c) Project introduction, stating in a clear and concise way the proposed project, its geological location, as well as ecological, social and temporal background, and usually including the map of project site and influence area;

(d) Baseline data, representing assessment study scope, related physical, ecological, social and economic conditions, and possible changes prior to the commencement of construction.

Meanwhile, consideration is also be given to the development projects either being constructed or proposed that are not directly linked to this project. The data shall relate to the project siting, design, operation or mitigation measures. In addition, the accuracy, reliability and source of data are also described in this section.

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(e) Environmental impacts and mitigatory measures, predicting and assessing the potential positive and negative impacts of the project in a quantified way if possible, making mitigatory measures against negative environmental impacts, indicating the residual negative impact after mitigation, and exploring the opportunities for better environmental protection. Decommissioning should also be part of it.

(f) Public involvement and information disclosure.

(g) EMP, including relief measures, monitoring and institution reinforcement, in compliance with annex C or Annex D of the World Bank document OP 4.01.

4 Qualification of the Implementing Agency

The BAT/BEP environmental impact assessment agency is qualified only when the following requirements are met.

— Accredited for environmental assessment by environmental management authority of China; highly experienced in the practice of environmental impact assessment;

— Having performed environmental impact assessment in relation to papermaking project in the last five years;

— Having successful experience in undertaking World Bank environmental assessment project;

— Having key assessors capable of good communication and writing skills in both Chinese and English.

5 Deliverables

An EIA report is submitted, together with necessary statements, fundamental data, and requisite drawings, in conformance with by OP/BP4.01 of the World Bank and the EIA technical guidelines of China.

The EIA report is subject to the technical review of environmental protection department and expert review of the World Bank.

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Annex 2 NWPM EMP TemplateThis template is applicable to environmental management plan for NWPM

construction, extension or transformation project.

1 Project Description and BackgroundThe NWPM construction, extension or transformation project is introduced in

words about its background, name, nature (newly constructed, expanded, renovated), location, investment, construction period, etc. Regional features, like the proximity to a conservation area or a place of historical or cultural interest, are also mentioned. The characteristics of land use (farmland, small factory, etc.) are also described (including the basic information, environmental conditions, etc. of the project site); the reason/purpose and role/function of the construction, expansion, transformation project are provided. It is well advised to attach a sheet of project summary.

Schedule 2-1 Project Summary

Project Basic project information Works of the project Construction period

2 Major Environmental Impacts and Mitigatory MeasuresSchedule 2-2 Summary of Major Environmental Impacts and Mitigatory Measures

Project phase

Scope of impact Potential impactsProposed mitigatory measures

Remarks

Construction period

Land requisition and utilization

General construction problems

Air quality control

Water quality control

Noise control

Solid waste management

Ecological protection

Public health

Construction safety

Operation period

Water quality control Description focuses on dioxin release

Air quality control

Noise control

Solid waste management

Ecological protection

Risk management

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Note: 1. The above table is only for reference. Please revise or supplement it according to the particulars of each project.

2. It is recommended to make a separate schedule in addition to the above table to detail the mitigation measures against dioxin impact upon the water quality.

3. The third column of the above table may contain brief description of related major environmental problems; it is advisable to provide written notes to this column, mainly explaining the management and the implementation methods of key issues.

3 Institutional Arrangement3.1 Environmental Management and Monitoring Agencies

Information is provided on the environmental consultant agency during the construction period and on environmental management body during the operation period of the NWPM construction, expansion or transformation project, covering mainly the organizational structure, post, number of employees, etc. Schedule 2-3 and Schedule 2-4 may be supplemented or revised to suit the specific situation of each project.

The environmental monitoring agencies responsible for water quality, air quality, noise, etc. are specified.

Related environmental management body and personnel arrangement are elaborated. (The attachment of an organization structure diagram is recommendable)

Schedule 2-3 Sample of Environmental Supervisor Arrangement during the Construction Period

Post Scope of work Staff requirement Number of staff

Team leader

Ambient air supervisor

Noise supervisor

Wastewater and solid waste supervisor

Complaint hotline staff

Schedule 2-4 Sample of Environmental Management Body during the Operation Period

Department Scope of work Staff requirement Number of staff

Environmental management div.

Environmental monitoring department

Environmental technology department

3.2 Duties and Authorities of Environmental Management

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The specific duties and powers of personnel in relation to environmental management during the construction and operation period are summarized in writing.

During the construction period, the persons recommended for coverage are the project owner, the contractor, the consultant engineer, the external environmental consultants, the environmental monitoring agency, the World Bank, etc.; and the areas involved may include: 1) environmental protection and management on site, 2) the quarters and occupational hygiene management of construction staff, 3) safety management, 4) social management. During the operation period, the persons recommended for coverage are the project owner, the environmental protection bureau, the World Bank, etc.; and the areas involved may include: 1) environmental protection and management during the operation period, 2) the occupational health and safety, 3) safety management, 4) social management.

4 Environmental Supervision and Monitoring Program4.1 Environmental Supervision Program

A feasible and well-targeted environmental supervision program is suggested so that supervision and pollution control can be implemented to processes where environmental impacts may occur during the construction and the operation period.

4.2 Environmental Monitoring ObjectiveThe environmental monitoring objectives during the construction or the

operation period of a newly designed, expanded or innovated NWMP project are expounded.

4.3 Environmental Monitoring ProgramThe environmental monitoring program separately addresses different situations

during the construction period and the operation period of a newly designed, expanded or innovated NWMP project, covering monitoring period, items, factors, points, frequency, etc. Schedule 2-5 Sample of Environmental Monitoring Program during the Construction (Operation) Period may serve as a reference for making a specific environmental monitoring program.

Schedule 2-5 Sample of Environmental Monitoring Program during the Construction (Operation) Period

Monitoring elements

Monitoring factor

Monitoring point

location

Monitoring frequency

Applicable Standards

Monitoring agency

Water environment and wastewater

Air and waste gas

Acoustic environment

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5 TrainingStaff training programs and budgets are described in detail, covering trainees,

number of persons, expenses, etc. Schedule2-6 is a sample training program.

Schedule 2-6 Environmental Personnel Training Program

Project phase Trainee Number of personsExpense

(RMB 10,000)

Construction period

Before the operation of the project

Total

6 EMP Budget

Schedule 2-7 EMP Budget for Construction Period

DescriptionBudget for

construction period (RMB)

Source of funds

Operation of environmental management body (including wages, overheads, transport costs, etc.)

Water quality monitoring

Lab analysis

Wage of sampling personnel

Total cost of water analysis

Air quality and noise monitoring

Lab analysis

Wage of sampling personnel

Total cost of air quality and noise monitoring

Other monitoring expenditures

Consultant engineer budget (including wages, overheads, transport costs and other expenses of environmental

monitoring)

Operation of environmental protection facilities

Training budget

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DescriptionBudget for

construction period (RMB)

Source of funds

Total EMP budget -

Schedule 2-8 EMP Budget for Operation Period

Description Budget for Operation period (RMB)

Source of funds

Operation of environmental management body (including wages, overheads, transport costs, etc.)

Water quality monitoring

Lab analysis

Wage of sampling personnel

Total cost of water analysis

Air quality and noise monitoring

Lab analysis

Wage of sampling personnel

Total cost of air quality and noise monitoring

Other monitoring expenditures

Operation of environmental protection facilities

Training budget

Total EMP budget -

Note: Possible sources of fund are: the project management fund, construction management and consultation fund, or technical assistance fund.

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Annex 3 Genetic Mitigation and Management Measures against Environmental Impacts of BAT/BEP Plan

In 2007, IFC of the World Bank Group issued Environment, Health and Safety Guideline Pulp and Paper Mills for papermaking industry. This guideline deals with the information related to pulping and papermaking facilities, including chemical pulping and mechanical pulping using wood as raw material, pulping using recycled fiber as raw material, and pulping using non-wood materials like bagasse, rice straw, and reed as raw material. This guideline gives elaborate technical guidance to the influence & management, indices & monitoring of papermaking industry from the aspect of environmental and employee health and safety.

This guide also provides general requirement for wastewater treatment and control method of most papermaking processes. When making several supplementary methods aimed at wastewater management in kraft and sulfite pulp mills, this guideline offers some suggestions on the control of dioxins (see Box Annex-3).

Box Annex-3 Environmental management for PCDDs in wastewater given in Environment, Health and Safety Guideline Pulp and Paper Mills

— PCDDs in Wastewater

Bleaching section wastewater may include polychlorinated dibenzo-p-dioxins (PCDD) and polychlorinated dibenzo-furans (PCDF), commonly known as dioxins and furans. When elemental chlorine free (ECF) or totally chlorine free (TCF) bleaching technique is used, the concentration of dioxins and furans in the wastewater is lower than the monitoring standard value.

— Control and Management of Dioxins in Wastewater

● The following methods may be employed during non-wood pulp bleaching process to reduce or avoid the formation of 2,3,7,8-TCDD:

● Using elemental chlorine free or totally chlorine free bleaching instead of elemental chlorine bleaching;

● Reducing elemental chlorine consumption by reducing multiple use of chlorine or by increasing chlorine dioxide substitute for molecular chlorine;

● Minimizing the quantity of dioxins introduced into the bleaching process by using precursor-free additive and complete cleaning;

● Removing the nodes wherever possible;

● Stopping using polychlorophenol-tainted materials in pulping process.

— Wastewater Treatment

Sludge produced during wastewater treatment shall be managed as waste or by-product.

● Preliminary mechanical treatment: suspended solids in wastewater are usually removed

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in a mechanical clarification tank or sedimentation tank. Chemical flocculation is sometimes used as an auxiliary means to remove suspended solids;

● Secondary treatment: pulp and paper mills with a relative higher release of organic pollutants mostly use biological treatment technologies to remove toxic compounds like resin acids and chlorine organic substances from the wastewater. Actual applications include several biological treatment technologies of different types and configuration. The most popular systems include active sludge treatment method, oxidation pond treatment method, various biofilteration methods employed concurrently with other methods, anaerobic treatment used before anaerobic biological treatment during preliminary treatment stage, and a comprehensive use of different methods when a hi-efficiency treatment is needed.

Source: Environment, Health and Safety Guidelines Pulp and Paper Mills, 2007 by International Finance Corporation

Where occupational health and safety are concerned, this guideline contains eight aspects, including chemical hazard, physical hazard, wood dust, etc. To avoid chemical hazard, the guideline recommends the following methods to prevent, control and minimize the potential impact of chemical substances upon worker health and safety: Mechanized pulping and papermaking shall be preferred whenever feasible so that the workers can complete operations in a control room away from potential chemicals and other health and safety hazards; an effective process control also helps reduce the use of bleaching agent and other chemicals to a minimum; avoid using elemental chlorine bleaching whenever possible.

The annex includes brief description of basic pulping and papermaking and different pulping processes and wastewater management guideline; the management guideline parameters include AOX, a routine factor for wastewater monitoring in pulping and papermaking, but there are no parameters on dioxin.

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Table annex-3 Recommended genetic mitigation and management measures against environmental impacts of BAT/BEP Plans

Environmental mitigation and management measures

Environmental benefitsResponsible

party

TCF bleaching processes are adopted, where O2, O3, H2O2

and enzyme bleaches are usedBleaches free of chlorine element may preclude the condition for dioxin generation.

Enterprise

ECF bleaching process is applied, where ClO2 is used instead of Cl2

Consumption of Cl2 is reduced, so is the generation of POPs. Enterprise

Process is improved by adding O2, H2O2, enzyme, etc. to minimize the use of chlorine bleaching agent

Consumption of Cl2 is reduced, so is the generation of POPs. Enterprise

The vacuum level of the drum washer is enhanced, the drop legs and sprayers are properly located and the sprinkling water is increased to make the pulp cleaner.

The organic substance content in the pre-bleaching aqueous phase is reduced to prevent the generation of hazardous organic pollutants in the bleaching process.

Enterprise

Facilities like screw presses are used additionally to promote the extraction of black liquor.

COD, BOD, SS and other pollutants are significantly removed from the middle-stage water, resulting in smaller risk of hazardous organic pollutant generation in the bleaching process.

Enterprise

Anthraquinone or polysulfides are added during the digestion process.

The digestion efficiency is improved and the pollutants in the wastewater are reduced.

Enterprise

Modified continuous cooking technologies (MCC, EMCC and isothermal cooking) are adopted.

The digestion efficiency is improved and the pollutants in the wastewater are reduced.

Enterprise

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Environmental mitigation and management measures

Environmental benefitsResponsible

party

Refined batch cooking process (RDH, Super Batch) and rapid displacement heating (RDH) technology are adopted.

The digestion efficiency is improved and the pollutants in the wastewater are reduced.

Enterprise

Raw materials tainted by cholorophenol are disused. Dioxin pollution caused by raw materials is avoided. Enterprise

Defoamers containing DBD and DBF are not used. Generation of dioxins is avoided. Enterprise

Sludge treatment and management is intensified. The risk of POPs concentration and leakage is reduced. Enterprise

The environmental monitoring program is implemented to regularly monitor the release of dioxins and other major pollutants of concern.

The enterprise is timely informed of the pollutant emission, leading to a timely adjustment of production and an effective monitoring of emission.

Enterprise, environmental management

authority

Environmental protection indoctrinationEnvironmental protection indoctrination program may be launched to raise the environmental awareness among enterprises and residents and to call for cleaner production of enterprises.

Environmental management

authority

Environmental information disclosureEnvironmental information is disclosed to facilitate the understanding of and supervision by the stakeholders.

Enterprise

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Acknowledgement

This research is conducted under the project of "Dixon Release Reduction of Non-Wood Pulp and Papermaking Industry in China" jointly launched by Foreign Economic Cooperation Office (FECO) under the Ministry of Environmental Protection of PR. China and the World Bank. It was commenced from October, 2009 and had been accomplished by the end of December.

For the smooth completion of this research, we first extend our thanks to the FECO under the Ministry of Environmental Protection of PR. China, which provided lots of favorable conditions for this research, especially in the exchange with other subject researches and in field visits to demonstration enterprises. Our thanks also go to the sister units, including Tsinghua University, Environmental Protection Research Institute of Light Industry, Research Center for Eco-Environmental Science under Chinese Academy of Sciences, and Dalian Institute of Chemical Physics under Chinese Academy of Sciences, for their supply of a large amount of fundamental data and background information to this research, especially for their support and assistant in papermaking processes and BAT/BEP analysis. Besides, we are deeply indebted to the experts participating in our discussions, including Sun Xuecheng (senior engineer), Wu Changmin (teacher), Zhang Anlong (professor), Feng Wenying (senior engineer), Cheng Yanjun (the institute director), Song Yun (chief engineer), Sun Xiaofeng (senior engineer), Li Xiaopeng (engineer), Huang Jun (associate professor), Zheng Huiting (Ph.D), Li Caibin (senior engineer), Zheng Minghui (professor), Liu Wenbin (researcher), Ni Yuwen (associate researcher), Zhai Huamin (professor), and Liu Ji (senior engineer), for their valuable advice on the enhancement of project implementation and research report.

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