The sponsor has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the World Bank Group (WBG)/IFC environment and social safeguard policies and the environmental, health and safety guidelines. Information about how these potential impacts will be addressed by the Sponsor is summarized in the paragraphs that follow. Further information is provided in the attached Corrective Action Plan (CAP), which is agreed upon by IFC and the Sponsor and will address the compliance gaps with IFC’s requirements.
- Land and Natural Environment:
The project area is a dry semi-desert barren land with limited farming and grazing. The project site is flat with a dry river bed to the east of the site. There are no protected or endangered species in or near the project site. The annual average precipitation in Dalate Qi is approximately 310 mm with an annual average evaporation rate of 2,130 mm. The groundwater level is approximately 8 meter below ground level, and the groundwater flows to the north. Xinao also purchased 3 hectares of low land, approximately 5 km southeast of the proposed project site, to be used for coal ash/slag temporary storage and landfill site. The landfill site is dry semi-desert salina land with no farming, grazing, or residential homes at the site or in the surrounding area.
- Environment and Social Impact Assessment:
Xinao has prepared an Environment Impact Assessment (EIA) and Safety Impact Assessment (SIA), respectively, which have been approved by the regulatory agencies. Xinao also contracted independent consultants to prepare a supplemental Environmental and Social Impact Assessment (ESIA) to meet the WBG/IFC’s requirements. In addition to the issues discussed in the EIA and SIA, the ESIA also covers alternative analysis, cumulative impact analysis, economic/social impact analysis, etc, and proposes mitigation measures for these impacts.
- Environmental, Health, and Safety Management System:
The construction committee is managing environmental, health, and safety (EHS) issues during the construction phase. The Sponsor will set up an EHS department, reporting to the general manager, and an EHS management system before the construction phase is finished. The proposed EHS department will lead the corporate EHS management, including the EHS monitoring for the overall operation processes. The Sponsor has decided to apply for ISO 14001 after the operations become stable.
- Water Source and Wastewater Treatment:
The water source for both operation and sanitary purposes will be from Yellow River. The local government is responsible for building the water pipeline to the property line of the project company. The total water consumption is approximately 900 m3/d. There will be an onsite water treatment plant for both process and drinking water. The wastewater from both process and sanitary usages will be pre-treated at the onsite wastewater treatment plant. Part of the effluent from the onsite wastewater treatment plant will be further treated and recycled and the remaining effluent will be discharged to the proposed municipal wastewater treatment plant (MWWTP) which is scheduled for operation in October, 2006. The MWWTP has the capacity of 20,000 m3/d and is designed to treat both industrial and sanitary wastewater. According to the ESIA, the effluent from the onsite wastewater treatment plant will meet the influent requirements of the MWWTP. The wastewater from the construction phase will be treated at the onsite septic tank and discharged to the storm channel. According to the CAP, the Project Company will send the wastewater from the constructions to the MWWTP once it is put into operation.
- Air Emissions and Ambient Air Quality:
The major air emission pollutants from the processes are SO2, NOx, and particulate matter (PM), which will meet both local regulatory requirements and WBG/IFC guideline limits according the ESIA prediction. Air quality at the project site meets local regulatory requirements and WBG/IFC guideline limits for ambient air, with the exception of PM due to the semi-desert environment. In addition, the dust from the coal ash/slag storage and landfill site will increase the ambient PM level in the nearby area on windy days. The project company will develop an effective dust control plan for the landfill to minimize impacts to the surrounding environment before operations begin in accordance with the CAP.
Based on a comparison of the life cycle assessment of coal burned for cooking purposes and coal transformed to DME and then burned, the CO2 generated by this project will be reduced by approximately 40%. The CO2 reduction to the atmosphere could be further increased up to approximately 70% if there are means to capture and store the approximately 150 tons/hr excess of CO2 generated through CO2 Capturing and Storage (CCS). Xinao is assessing possibilities to address the CCS aspects of the project.
- Workplace and Ambient Noise Levels:
The ESIA estimates the workplace noise levels will be approximately 85 – 95 dB(A) after the noise control. The project company will take additional applicable methods to further reduce the workplace noise levels to 85 dB(A) or less during the detailed engineering design and operations and provide appropriate personal protection equipment (PPE) to the operators in accordance with the CAP. The ESIA predicts the ambient noise levels will be less than 65 dB(A), which meets local regulatory requirements and the WBG/IFC guideline limits.
- Solid and Hazardous Waste Management:
The domestic solid wastes generated onsite will be sent to the municipal landfill. The major industrial solid waste generated from operation is approximately 200,000 tons coal ash/slag per annum. The project company has signed an agreement with a local cement company to send the coal ash/slag for cement manufacturing. For temporary storage and final disposal of coal ash/slag, if the demand decreases, The project company will build a coal ash/slag landfill near the manufacturing site. The proposed landfill has a composite liner system with HDPE as the impermeable layer, leachate collection system, and three groundwater monitoring wells. The permeability coefficient of the liner system is less than 1(10-7 cm/s. According to the CAP, the project company will also consider a leachate treatment system during the detailed design phase.
The major hazardous wastes generated are used catalysts, various fuel oils, waste petroleum products, etc. The used catalysts will be recycled by the manufacturers. The fuel oils will be recycled in the gasification process. The other hazardous wastes will be sent out to a licensed hazardous waste handling company for recycle/disposal. According to the CAP, the Project Company will sign a service contract with a licensed qualified hazardous waste handling company before operations begin.
- Hazardous Materials and Operation Hazard:
The final products of this project, methanol and DME, and other intermediate products/by-products, including H2, CO, and H2S, are all hazardous materials. The ESIA evaluates the operational safety of the project site and proposes primary mitigation methods to manage potential impacts. The project company will conduct a hazard & operability (HAZOP) study during the detailed design phase and conduct regular compliance audits to verify that the mitigation measures are being implemented during operations in accordance with the CAP.
- Occupational Health and Safety:
The ESIA evaluates the occupational health and safety (OHS) situations for each process. The proposed EHS department will lead the drafting and implementation of internal safety rules and processes. It will also be in charge of the OHS compliance with various government requirements. According to CAP, the project company will conduct an industrial hygiene assessment to identify the potential occupational issues and provide prevention methods before operations commence. The project company is also committed to providing adequate Personal Protective Equipment (PPE) for its contractors and employees during construction and operations.
- Fire Prevention and Emergency Response:
Due to the hazardous nature of the operations, there is a possibility of fire, explosion, and/or a chemical release during operations. The closest fire department is 8 km away and it is possible for their fire trucks to be on site in approximately 10 to 15 minutes after notification. There will be a fire-fighting water storage tank with capacity for 2-hours of firefighting on-site. Accord to the CAP, the project company will ensure that an automatic monitoring/alarm system is included in the detailed design of the facility. The project company will also involve, which includes coordinating and training, the local fire brigade and nearby communities in its emergency response drills in accordance with the CAP.
- Coal Mines and Related Safety:
The project company will consume approximately 1.2 million tons of coal per year. The coal will be sourced from local coal mines in Erdos City, which account for 1/6 of all coal reserves in China. The coal mines in Erdos are relative new and safety records are better compared with coal mines in other areas of China. There is a Coal Mining Safety Bureau (CMSB) in Erdos City, which conducts scheduled and random safety inspections. According to the CAP, the project company will only acquire coal from mines with a minimum annual output of one million tons and that have annual safety certificates from CMSB. If the coal is transported to the site by road, the project company will only contract the transportation to large trucking companies with satisfactory maintenance and safety records in accordance with the CAP.
- Land acquisition and project affected people:
The project has acquired approximately 1 km2 of land which is mainly dry, semi-desert, barren land with only a small portion of it used for agricultural purposes (4 hectares). The land acquisition process commenced in April 2004. One household was physically relocated while three households lost part of their agricultural land. Monetary compensation at a regulated rate was disbursed to the project affected households and the Project Company has committed to providing details in the CAP as to how they will ensure that the affected households will be able to improve or at least to restore their livelihoods to the pre-project level. As part of the EIA and SIA process, the project company conducted public consultation.
- Proposed DME Manufacturing Plants:
The project company plans to build up to four satellite DME manufacturing plants near the consumption markets, using the methanol from the Erdos site as the raw material. The project company may utilize Xinao Group’s LPG distribution facilities sites or purchase lands for the proposed satellite DME manufacturing sites. The project company will prepare ESIA’s for each site. According to the CAP, the project company will inform IFC before the construction of each satellite plant and has also committed to be compliant with applicable WBG/IFC’s safeguard policies and guidelines.