The land for Puyang WtE project was acquired from the waste management industrial park and the project site is in the industrial park, adjacent to an existing MSW landfill. Given the location in an established industrial park, there are neither related impacts nor clearly established risks or likelihood that impacts will occur with respect to PS5: Land Acquisition and Involuntary Resettlement, PS6: Conservation and Sustainable Management of Living Resources, PS: 7 Indigenous Peoples, and PS8: Cultural Heritage.

 The proposed Puyang WtE project is located in an existing waste management industry park. The WtE facility will be designed according to European Union (EU) standards. The predicted air emissions and stormwater discharged will meet both local regulatory requirements and World Bank Group (WBG) EHS Guidelines. The contaminated water from the process areas and leachate from waste storage will be treated and recycled as production water. Waste will be transported using the existing transportation route for the industry park, which have been approved by the authorities.

Mitigation measures for the potential E&S impacts have been identified in the design and in the relevant E&S assessments prepared by the company. The potential adverse E&S impacts of this project for both construction and operations phases are considered few in number, of limited significance and readily mitigated through the company’s existing robust systems and procedures and the pollution prevention and control measures included in the design. This is therefore a Category B project according to IFC’s Policy on Environmental and Social Sustainability.                                                  

    Environmental and Social Assessment and Management System

BGE hires external experts to conduct E&S assessments for its projects according to Chinese laws/regulations and its own technical standards. Once such E&S assessment reports are finalized, the company discloses these reports locally as part of its ongoing stakeholder engagement, in compliance with the legal requirements. An environmental and social impact assessment (ESIA) was prepared for Puyang WtE project according to Chinese regulatory requirements. The ESIA generally meets IFC Performance Standards and WBG EHS Guideline requirements. The ESIA is disclosed together with this ESRS.

The company has established a robust corporate E&S management system that applies to all its subsidiaries. BGE corporate operations are certified by ISO 14001 (environment) and OHSAS 18001 (occupational health/safety) standards. There are detailed environmental, occupational health/safety (OHS) and process safety requirements engrained in the company’s EHS management programs. As part of this IFC investment, compliance with applicable IFC Performance Standards and relevant and applicable WBG EHS Guidelines will be included in the project-specific E&S policy and E&S management plan (ESMP) and relevant procedures to be developed for Puyang WtE and the company will align a relevant procedure for the screening and assessment of E&S risks and impacts for future projects to IFC’s Performance Standards requirements (ESAP 1).

Policy

BGE’s E&S policy reflects its commitments to sustainable development and corporate social responsibility. Its environmental policy states that BGE is to contribute to the society by creating a sustainable safe environment (http://www.bgechina.cn/index.php?c=CorporateCulture&item=12). Its policy promotes creative technologies to provide the leading environmental services. BGE’s E&S policy is implemented though the company’s environmental, OHS, and process safety procedures, which include well-designed key performance indicators (KPI) to evaluate and improve E&S performances.

Identification of Risks and Impacts

Environmental and social risks for any new projects are initially identified and mitigated during preparation phases through BGE’s internal procedures of E&S risk identification and assessment. As indicated above, the procedures will be aligned to IFC’s Performance Standards requirements. During operations, EHS risks are identified through formalized auditing programs, periodical inspections, and spot checks. IFC’s review found that audits/inspections/checks are adequately documented with corrective actions to mitigate the EHS impacts.

Management Programs 

Management teams at the subsidiary level are responsible for educating, training and motivating employees to understand and comply with company’s EHS standards and performance procedures which have been set up to monitor and support the works throughout BGE. BGE’s EHS management system is well developed and includes detailed technical standards, standard operating procedures (SOPs) and work instructions, internal codes for EHS performance, and an extensive inspection/audit program. Corporate management holds biweekly EHS meetings and each subsidiary is required to submit monthly EHS performance reports. As indicated under ESAP 1, the company will develop and implement a project-specific ESMP and relevant procedures for Puyang WtE.

Technical feasibility and E&S performances are critical components for due diligence of merge and acquisition (M&A). As indicated in ESAP 2, BGE will establish a formal due diligence procedure of M&A to consistently evaluate E&S performances and risks, including historical contamination, according to the good international industry practices (GIIP) and consistent with IFC’s Performance Standards.

Organizational Capacity and Competency

At the corporate level, BGE has an EHS department with a manager reporting to chief executive offer. The EHS department is responsible for ensuring subsidiaries to comply with the corporate EHS policy and to implement the required management programs. At each operation or construction site, there is a dedicated EHS team to manage the daily EHS operations according to corporate policies, programs, and site-specific EHS procedures. Site EHS managers report to site general managers with dotted reporting lines to the corporate EHS manager. The Puyang WtE project will have its own EHS management team, including a community liaison officer, as per company’s approach described in the Stakeholder Engagement section below. 

Emergency Preparedness and Response

BGE corporate has an emergency response (ER) policy with biannual site-wide ER drills, and at least once coordinated with local fire brigades and hospitals. Each site has its own specialized ER scenarios, which are drilled individually at different processes. At the sites visited, there were sufficient firefighting equipment and sufficient water/foam fire suppression systems onsite, which appeared to be properly maintained. Toxic gas sensors and automatic fire detectors were found to be installed at all critical locations visited with connection to central operation room. Automatic sprinkler systems were installed for all fuel storage tanks. The company reports that all operation sites have similar ER equipment.

Monitoring and Review

BGE has instituted comprehensive EHS monitoring programs at its facilities. The KPIs include point source emissions, fugitive emissions, effluents, fence line air quality, ambient air quality, noise levels, waste handlings/disposals, groundwater monitoring, lost time injury, work permit review, among others.  The Puyang WtE project will develop and implement its own monitoring program.  The monitoring program will be compliant with IFC’s Performance Standards and relevant and applicable WBG EHS Guidelines, and it will include, among others, a community grievance mechanism and relevant social performance KPIs.

Besides monthly review of the KPIs, BGE’s corporate EHS department organizes biannual internal EHS audits for all operation sites and critical construction sites. Engineers from EHS department also conduct routine inspections and spot checks. All these reviews are recorded for mitigation implementation review. For critical operational phases (e.g. project start-up, important maintenance), corporate EHS engineers stay onsite to monitor these operations. 

As part of this project and in line with ESAP 3, BGE will develop a time-bound implementation plan for an intranet-based EHS performance database and a real-time electronic operational control system with audio/video monitoring for all operational sites and critical construction sites. The database and monitoring system will be managed by the corporate EHS department, which enables corporate management to have access to real-time EHS performances through data sharing and audio/video monitoring at each operation site and critical construction site.  The Puyang WtE operations will be covered by the monitoring system.

   During operations, Puyang WtE project will employ approximately 100 workers, including fulltime direct employees and contracted workers. As part of this project, the construction contractor will mobilize construction workers for construction and commissioning. The construction workforce needs are still to be finalized by the company.

Human Resources Policies and Procedures

BGE has a corporate human resources (HR) management team and corporate HR policy that specifies the terms of employment and working conditions. These include procedures related to recruitment, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and termination, vacation, other leave, respectful workplace, and retirement. The company provides HR policy training that is part of the new employee induction, and all employees have access to this policy. The HR issues are managed at each site separately. Specific policy provisions and procedures on gender-based violence and harassment were not available during the appraisal. BGE’s HR management will incorporate prevention of gender-based violence and harassment in the HR policy (ESAP 5). All suitable HR policies apply to contractor workers, including construction contractor workers.

Working Conditions and Term of Employment

All workers are on BGE’s payroll except small numbers of contracted workers for non-core business processes (e.g. cleaning). Under the employment terms that strictly follow the national labor law, workers are employed on fixed term contracts which are renewable subject to satisfactory performance and availability of work. Overtime works are compensated as 1.5 times of base salary during workdays and 2 – 3 times during holidays. All employees have access to the insurance and pension funds as required by labor law. For employees of other contractors who may work at BGE sites, BGE requires the contractors to fully comply with national labor laws and HR conducts periodic inspections.

Workers’ Organization

A worker union with elected union leaders is set up at BGE, as required by the All China Federation of Trade Unions (ACFTU). BGE management is committed to keeping the union independent from management and allows collective bargaining.

Non-discrimination and Equal Opportunity

The HR policy specifies non-discrimination and equal opportunity and hiring and promotion are merit-based. When candidates have equal qualifications, preferences of hiring are given to local community members and females. Currently, approximately 20% of employees are female. BGE plans to recruit more female employees as part of the Puyang WtE project and other projects and to increase the percentage of female employees.

Retrenchment

No retrenchment is expected at any of the company’s sites in the foreseeable future.

Grievance Mechanism

The company has a formalized grievance mechanism which is introduced to each employee at induction, which also applies to onsite contractor workers. The employees can report their grievances to either HR managers or union labor leaders. All the grievances and the actions undertaken by the company to close the grievances are recorded and available to management. As part of the procedure, the HR managers/union leaders are required to report to the senior management if they could not solve the grievance. Workers can report their grievances by email to HR management and suggestion boxes are available for anonymous grievances.

Protecting the Work Force

BGE complies with national law and does not hire workers below the age of 18 years.  HR department checks birth and school certificates during the hiring process. No forced labor practices are used by BGE. BGE has a strict labor audit program to ensure no child or forced labor is used by its suppliers and the occupational health/safety performances of the major suppliers meets local regulatory requirements.

Occupational Health and Safety

BGE has routine OHS training programs, including new employee trainings and annual refreshers. Based on records reviewed and information provided to IFC, there have been no fatal or serious accidents in the company’s operational history; however, OHS management lacks performance statistics throughout construction sites and operational sites. IFC site visits found that personal protective equipment was adequate for all functions, and was strictly enforced, including for contracted workers. Based on the records provided by the company on performances of other WtE sites and the design criteria, it is expected that air quality and noise levels at workplaces across Puyang WtE site will meet both local regulatory requirements and GIIP. In any case, workplace environment will be monitored, and compliance reported to IFC.

As part of this investment, BGE will improve OHS management through statistics of recordable accidents. As indicated in ESAP 6, BGE will start tracking all recordable accidents across its operation and construction sites. To ensure OHS management of construction contractors in compliance with IFC requirements, and as indicated in ESAP 7, BGE will develop an OHS management plan for construction contractors and the plan will be implemented at the Puyang WtE site.

Supply Chain

The MSWs for Puyang WtE project will be directly supplied by Puyang Municipal Government. Risks associated with the company’ supply chain are unlikely.

   Resource Efficiency

Municipal solid waste is the main raw material of this project, with a design consumption rate of 1,000 ton per day. Electricity will be generated onsite. The sanitary water will be supplied by the municipal government, while the process water will be the treated wastewater from the municipal wastewater treatment plant nearby.

Energy and water efficiency are considered in the design of Puyang WtE project, including high energy efficiency equipment selection, design for waste energy recycle, cooling water treatment/recycle, wastewater treatment/recycle, among others. As a result, the water consumption rate is 2.3 m3/ton waste, which is significantly lower than the Chinese guideline benchmark of 3.2-4.6 m3/ton waste. 

GHG Emissions

The operation of Puyang WtE project will generate 338,000 tons of equivalent CO2, mainly from MSW incineration and leachate treatment.

Pollution Prevention

Puyang WtE project ESIA indicates that the current soil, groundwater, and ambient air quality at the project site meet all local regulatory requirements.

The main process buildings will have negative pressure with air curtains at waste truck entrance to avoid fugitive emissions and odors. The waste storage bay in the process building will be lined with impermeable layers to prevent leaks. All the fermentation emissions and odor chemicals will be sent to the incinerator. The ESIA predicts the ambient air quality ground level concentrations at the plant border for particulate matters (PM10 and PM2.5), hydrogen sulfide (H2S), ammonia (NH3), and odor will meet local regulatory requirements. 

The adopted technology will ensure that the combustion temperature maintains at 850ºC for at least two seconds. Large water-cooling walls will be used to avoid dioxins/furans reformation. The flue gases will be treated by scrubbers and the treatment system will also have an additional stage of activated carbon absorption, which will be operated in case of need, if levels are exceeded after scrubbers and before emission to the atmosphere. The air emissions from the plant will meet both local regulatory requirements and WBG EHS Guideline limits for all relevant pollutants, including dioxins/furans, SOx, NOx, PM, and hydrogen chloride (HCl).

As per local requirements, the initial 5 cm or 15 min flush of rainwater will be collected and conveyed to treatment and all sanitary wastewater will be treated, and the effluent will be used for onsite dust control or greenbelt. Any contaminated water from the process areas and leachate from waste storage will be treated through physical/chemical treatment and reverse osmosis. The treated effluents will be sent back as fresh production water. The cooling water will be discharged to municipal sewer system for further treatment at the municipal wastewater treatment plant. The only discharged water is clean rainwater after 15 min rain, which, as per the ESIA, will be fully compliant with local regulatory requirements and applicable and relevant WBG General EHS Guidelines.  In any case, the facility will have a retention pond designed to collect the first flush of rainwater from the garbage truck transportation road and an online monitoring alarm which will be able to divert any potential contaminated rainwater to the leachate regulating pond designed to hold up to 6,000m3 of water.

Onsite sanitary waste, wastewater treatment sludge, and used activated carbons from the deodorization system will be sent to the incinerator. Incineration slags are industrial solid wastes and will be sold for recycle at brick manufacturers. The fly ash from scrubber is a hazardous waste, which will be solidified onsite with heavy metal chelators and cements. The solidified fly ash will be subject to toxicity characteristic leaching procedure (TCLP), and if the test will confirm non-hazardous waste characteristics, the solidified fly ash will be disposed at a dedicated cell of the adjacent MSW landfill. If the solidified fly ash will not pass TCLP, it will be are disposal of at licensed hazardous waste treatment facilities, together with other hazardous wastes (e.g. used activated carbons from the flue purification system). The used catalysts will be sent back to the manufacturers for regeneration/disposal.

Online monitoring will be installed for incineration emissions and rainwater discharged, including PM, NOx, SOx, pH, TSS, etc. Any non-compliant condition will trigger a corrective procedure. The local environmental protection bureau will also receive real-time readings for the emission and effluent qualities. The company will develop and implement an environmental monitoring program which will be fully compliant with national requirements and IFC’s requirements.                                                

   Community Health and Safety

As indicated above, the nearest community is approximately 700 meters from the site. The distance is larger than the local regulatory requirement of 300 meters. As presented in the ESIA, the modelling of fugitive emissions of PM, H2S, and NH3 showed that impact levels will all be contained within the plant site. Stack emission modelling showed that the project contribution in terms of ambient air quality impacts will be limited and will result in ambient air quality levels for all relevant pollutants within the national standards and applicable WHO values, including for the worst-case operational scenarios associated with the addition of the maximum ground level concentrations modeled to the maximum baseline levels.

The modelling carried out for noise levels also showed that the project noise impacts will be limited and noise levels at the nearest residential receptors will be lower than local regulatory requirements. The groundwater contaminant plume modelling for the credible worst-case scenario for the leakage of MSW and leachate storages showed that contaminant plume can be contained within the site and local groundwater resources, including local water wells and surface water recharge, will not be affected. The company will monitor environmental conditions at the locations of maximum impact and at the locations of the nearest receptors and will ensure there will not be any risk to community health, due to the WtE operations.

The MSW generated by the municipality, currently transported to the landfill, will be diverted to WtE site, and the solidified fly ash will be sent to the adjacent landfill. There will not be any expected incremental MSW transportation due to the implementation of this project. All the MSW will be transported in stored in the closed cargo boxes of the trucks. All trucks are equipped with GPS and in-cabin audio/video monitoring system. The trucks are only allowed on approved routes within defined speed limits. The municipal waste control center monitors the waste truck speeds and routes. All the trucks will be washed before leaving Puyang WtE site.  The normal operations at Puyang WtE project will have limited risks to community health and safety, which will be fully mitigated by implementation of the mitigation measures.

Emergency Preparedness and Response

Puyang WtE project will prepare ER plans in close coordination with the local authorities, and conduct routine drills for firefighting and potential accidental events as per BGE’s practice at all its projects. Alarms will be added to the online monitoring system to alert the operation personnel about potential faulty or incorrect operations and other emergencies. For credible scenarios of potential faulty or incorrect operations or during maintenance shutdown, activated carbons, which are installed at the emission scrubbers, will be used to control and minimize both stack and fugitive emissions. The project design indicates the maximum time to bring faulty or incorrect operations back to normal, for credible scenarios, is one hour. The stack/fugitive emission modelling developed for those scenarios as part of the ESIA show no impacts to receptors outside of industrial zone if normal operations are re-established within one hour.

Security Personnel

BGE will hire a private service provider for Puyang WtE site security that will conduct routine ID check at the gates and security monitoring. There will not be armed security at the site.                                                

  Stakeholder Mapping / Analysis / Engagement

For all its operations, BGE develops and maintains stakeholder mapping and analysis results. The communities near BGE’s operational and construction sites are key stakeholders. Each site has a dedicated community liaison officer or a community liaison team depending on the potential impacts to communities. The liaison officers hold regular meetings with community leaders and visit the communities as per a schedule defined by the relevant corporate procedure.

As part of its corporate social responsibility, BGE has created funds for elementary/middle school educations to support students, with special consideration of the most vulnerable and disadvantaged families. BGE Environmental Scholarships are awarded for outstanding college students in prestigious universities to attract students in the environmental fields.

Consultation and Grievance Mechanisms

The leaders of the communities located within the area of influence of each BGE’s operation have access to the company through the BGE liaison officers and site managers, which enable effective handling and response in case of any concern. Formal community grievance mechanisms are established at each site and will be available at the Puyang WtE site for the construction and the operations phase. The grievance mechanism is a living management tool which is adapted to different project phases and tasks.

Information Disclosure and Ongoing Reporting to Affected Communities

As indicated above, all BGE projects have ESIAs, which are conducted by external consultants. Public consultations are the key part of ESIA processes and comply with local regulations. All the ESIAs are disclosed to the local communities once they are approved. For all operation sites, an electronic board outside of site gates display real-time online monitoring data. For construction sites, the company provides, outside the gates, updates on the latest monitoring data for fugitive emissions and effluents. BGE publish annual corporate Social Responsibility Reports on its website to summarize its sustainability initiatives. As part of the project in line with ESAP 4, the company will ensure that its annual Social Responsibility Reports include key E&S performance data across BGE’s main operation/construction business.

  BGE will disclose this document in the local prevailing language at http://www.bgechina.cn For inquiries or concerns about the environmental and social impacts of this project please contact:

Contact Person:  Xu Chaojiang

Company Name: Beijing Geoenviron Engineering & Technology, Inc

Address:  No. 13 Building-1-4 Floor 101, Courtyard 9, Dijin Road, Haidian District, Beijing

Email:    xuchaojiang@bgechina.cn

Phone:    +86-10-62490098

Facsimile:   +86-10-88233169