SFG2398 REV GEF-Reduction and Phase-out of PFOS in Priority Sectors in China Environmental Auditing Report for Hubei Hengxin Chemical Co., Ltd Foreign Economic Cooperation Office, Ministry of Environmental Protection (FECO) Hubei Academy of Environmental Sciences (HAES) November, 2016 CONTENTS Chapter 1 Overview ...................................................................................................... 1 1. Introduction ................................................................................................................... 1 2. Auditing basis................................................................................................................. 1 3. Overview of Hubei Hengxin Chemical Co., Ltd.............................................................. 2 4. Main auditing content .................................................................................................... 4 5. Time period covered by audit ......................................................................................... 6 6. Applied standard............................................................................................................ 6 Chapter 2 Environmental sensitive areas & environmental functional zoning .................... 8 1. Environmental sensitive areas ........................................................................................ 8 2. Environmental functional zoning ..................................................................................10 3. General layout of the plant site .....................................................................................10 Chapter 3 Project overview ......................................................................................... 12 1. Project brief ..................................................................................................................12 2. Production process ........................................................................................................13 3. Raw materials and products..........................................................................................18 4. Main pollutant-producing sections & pollution treatment installations .........................19 Chapter 4 Contents of environmental audit ................................................................. 22 1. Implementation of “Three Simultaneous System” and EIA ..........................................22 2. Compliance of industrial policies ..................................................................................24 3. Implementation of emission declaration, emission permit and sewage charges payment ..........................................................................................................................................24 4. Specific pollutants and their emission & treatment ....................................................... 26 5. Control of total pollutant discharge...............................................................................33 6. Audit of Cleaner Production .........................................................................................34 7. Prevention and control of pollution from dangerous chemicals and registration of prohibited substances and new chemical substances .........................................................40 8. Disposal of hazardous wastes and general industrial solid wastes .................................41 9. Implementation of ecological protection measures (N/A) ..............................................43 10. Project impact on environmental sensitive areas including drinking water source protection area ..................................................................................................................43 11. Environmental safety hazards, emergency response plans and environmental accidents ..........................................................................................................................................44 12. Corporate environmental management .......................................................................49 13. Disclosure of environmental information..................................................................... 51 Chapter 6 Auditing Conclusion .................................................................................. 66 Chapter 7 Annexes ..................................................................................................... 68 1 Annex 1-1: Reply to EIR Form of the Organic Silicon and Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd. (2004) ................................................................................ 68 Annex 1-2: Reply to Retrospective Evaluation Report of the 30t/a Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd. (2008) ............................................................... 69 Annex 1-3: Opinions on Final Acceptance of the Organic Silicon and Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd. (2005) ................................................ 72 Annex 2-1: Cover of the Statistical Form for Declaration and Registration of Pollutant Discharge (2011) ....................................................................................................................... 73 Annex 2-2: Pollutant Discharge Permit of Hubei Province (2012-2015) .................................. 74 Annex 2-3: Pollutant Discharge Permit of Hubei Province (2015-2016) .................................. 75 Annex 3: Supervisory Monitoring Report (2015) ...................................................................... 76 Annex 4: Letter on Total Pollutant Discharge Control Indicators of Hubei Hengxin Chemical Co., Ltd. ..................................................................................................................................... 79 Annex 5: Operation Log of Environmental Protection Facilities............................................... 81 Annex 6-1: Hazardous Wastes Disposal Contract (2015) .......................................................... 82 Annex 6-3: Hazardous Wastes Manifest (2014) ........................................................................ 84 Annex 6-4: Hazardous Wastes Manifest of Hubei Province (2015) .......................................... 85 Annex 6-5: Register of Hazardous Wastes in Storage ................................................................ 86 Annex 6-6: Legal Person Certificate and Organization Code Certificate of Yichang Solid Wastes Disposal & Management Center (Yichang Hazardous Wastes Treatment Center) ........ 87 Annex 6-7: Practicing certificates of hazardous wastes transport staff ...................................... 88 Annex 6-8: Permit for Road Transport of Hazardous Wastes and Vehicle Registration Card ... 89 Annex 7-1: Environmental Hazard Prevention Measures and Emergency Response Plan ........ 90 Annex 7-2: Emergency Rescue Plan for Work Safety Accidents ............................................... 91 Annex 7-3: Implementation of Standardized Management of Hazardous Wastes ..................... 92 Annex 7-4: Cover of the Enterprise Work Safety Standardization Log II: Risk Management ... 93 Annex 8: Sign plate of wastewater discharge outlet .................................................................. 94 Annex 9: Sign-in Sheet of Discussion Meeting of Public Consultation of Hubei Hengxin Chemical Co., Ltd. ...................................................................................................................... 95 2 Chapter 1 Overview 1. Introduction To meet the requirements of the Stockholm Convention on POPs, the Foreign Economic Cooperation Office (FECO) and World Bank (WB) have developed the “GEF-funded Project for Reduction and Phase-out of PFOS (and its salts) in priority sectors in China". On June 4, 2015, the project obtained the approval from GEF. The PFOS project is to help China fulfill its mandatory obligation in phasing out of PFOS in exempted uses. It will also introduce BAT/BEP of acceptable uses in priority industries. The PFOS project plans to carry out demonstration, replacement, reduction/elimination activities in industries related to PFOS production and application such as hard chrome plating, decorative metal plating, pesticides and fire protection. The project is expected to reduce the production and use of 55-65 tons of PFOSF, and to enhance the ability to control environmental and health risks of chemicals, as well as to improve the supervisory capacity of relevant Chinese regulatory departments and agencies. Hubei Hengxin Chemical Co., Ltd (hereinafter referred to as “Hubei Hengxin") is China's largest manufacturer of PFOS. Therefore, it is under consideration as a demonstration enterprise for conversion of production to new non PFOS-based products under component 1 of the project, although participation of the enterprise is not confirmed at time of project approval, and details of possible investments are not known. In accordance with the requirements of PFOS project, it has carried out environmental audit, and will prepare an EIA as soon as details of the possible investments are known. The aim is to ensure the implementation of demonstration projects in China is in line with environmental regulations and WB's environmental policies. The Environmental Audit TOR was described in the PFOS Project Environment Management Framework (EMF) Annex II. As the largest producer of the PFOS in China, the Hubei Hengxin Co. Ltd has agreed to conduct an independent environmental audit. The audit aims to learn about the enterprise’s performance of environmental protection duties and the conformance of its environmental protection work with relevant laws and regulations. The enterprise must provide necessary supports to the consulting agency for the purpose of completing the audit. 2. Auditing basis The environment-audit is mainly based on the Environmental Management Framework and its Annex II – Environmental Auditing ToR. Relevant regulations and standards are as follows: 1. Solid Waste Pollution Prevention Law of PRC (Revised on April 24, 2015); 2. Environmental Impact Assessment Law of the People's Republic of China, 2003.9.1; 3. Law of PRC on Promotion of Cleaner Production, 2012.7.1; 4. Administrative Regulations on Collection and Use of Pollutant Discharge Fees, 2003.7.1; 5. Regulations on the Safety Control of Dangerous Chemicals (revised on Dec. 7, 2013). 6. Management Regulation on Hazardous Wastes Manifests; 1999.10.1; 1 7. Administration Measures for Operating Licenses of Hazardous Wastes (State Council Order No. 408), 2013.12.7; 8. The Catalogue for the Guidance on Adjustment of Industrial Structure (Revised edition, 2013), 2013.2.16. In this catalogue, the "newly-build PFOS production equipment are listed as "restricted"; correspondingly, development and application of alternative products and technologies in substitution of PFOS and its salts is listed as "encouraged"; while "coatings containing PFOS" are listed as "obsolete". 9. Administrative Measures for Environmental Monitoring, 2007.9.1; 10. Administrative Measures for Acceptance Inspection of Environmental Protection for Completed Construction Projects, 2010.12.21; 11. Guidelines for Drafting of Environmental Report (HJ617-2011). 3. Overview of Hubei Hengxin Chemical Co., Ltd Yingcheng Hengxin is a joint venture co-founded by Yingcheng Tianhong Chemical Co., Ltd. and Wuhan Defu Economic Development Co., Ltd in 2004. In the same year, the company initiated its production of organic silicon and organic fluorine products in Yingcheng Industrial Park, which is located in South of Changjing Bridge, Tiyu Road, Yingcheng City. In 2006, Yingcheng Hengxin Chemical Co., Ltd. is renamed Hubei Hengxin Chemical Co., Ltd after joining with Indonesia New Star Chemical Co., Ltd. Hubei Hengxin Chemical Co., Ltd is located in the provincial industrial park- Yingcheng Economic and Technological Development Zone. The company is a provincial high-tech enterprise specializing in development, production and marketing of perfluoroalkanes products. Its production capacity of organofluorine series is 30 t/a. Its products include perfluorinated alkyl sulfonic acid, perfluorinated alkyl carboxylic acid, perfluorinated tertiary amines and its derivatives. Its products are mainly used in areas such as oil exploration, firefighting, textile finishing, paper waterproofing, pharmaceuticals, pesticides, photographic film, electronics, electroplating, flame retardant, lithium battery production, and historic preservation and photoresist materials. Its products sell to countries like Europe, America, Japan, South Korea and Taiwan. In addition, Hubei Hengxin Chemical Co., Ltd covers an area of 19819.6m2, with a building area of 2657.9m2 and green area of 5820.0m2. There are 58 employees working for 278 days every year. The company adopts three-shift working system and every shift lasts 7.5 hours. Table 1 Basic status of the enterprise Company Hubei Hengxin Chemical Place of Yingcheng City, Hubei name Co., Ltd. incorporation Production Production capacity of PFOSF is 30 tons/year. capacity Legal Registered Gao Guobao 9 million RMB representative capital Organization As shown in Figure 2. chart 2 Perfluorinated alkyl sulfonic acid, perfluorinated alkyl carboxylic acid, Key products perfluorinated tertiary amines and its derivatives. Main production equipment are listed in Table 2: Table 2 List of production equipment No. Equipment name Model Amount Notes 1 Rectifier KHS4KA 6 units 2 Rectifier KHS3KA 8 units Used for electrolytic reaction, 3 Rectifier KHS6KA 1 unit located in Plant No.3 4 Rectifier ZDDKS3KA 8 units 5 Electrolytic tank 500L 23 units 6 Condenser 15 ㎡ 28 units Tail-gas purification 7 4 units tower Pumps for tail-gas 8 Circulating pump 4 units purification tower Used for 9 Freezer JVSLGF300 III 2 units sulfonation/chlorination/fluoridati on reaction, located at Plant No.2 10 Freezer JZS-KF125C 2 units Salt-cleaning water 11 IH10080160 11 units pump Horizontal 12 DZGI-0.7-A II 1 unit double-grate boiler 13 Measuring tank 1L 4 units Of which one is used for sulfonation reaction, one for 14 Reaction kettle 1000L 5 units acylation reaction, and one for drying. Of which two units are used for 15 Reaction kettle 500L 3 units fluorination reaction, one for acyl chloride reaction. A-series centrifugal 16 1 unit Used for desiccation after spray dryer sulfonation/chlorination/fluoridati Heat conduction oil on reaction, located at Plant No.2 17 3 sets tank Located in the boiler room. 18 Boiler 1t/h 1 unit Provides steam for bathe and production process 3 Figure 1 Plant photos 4. Main auditing content Based on the Environmental Management Framework of PFOS, environment-audit needs to be conducted against technically reformed enterprises. In accordance with environment-audit requirements specified in Annex 2 (of the Environmental Management Framework), main environment-audit contents are as follows: 1. Implementation of Three Simultaneous System and EIA; 2. Conformity with industrial policies; 3. Implementation of sewage discharge registration, waste discharge permit (if any); 4. Emission behavior of key pollutants and specific pollutants; 5. Stable operation of environmental protection facilities and automatic monitoring equipment (if any); 6. Implementation of Cleaner Production (if any); 7. Pollution control of hazardous chemicals and registration of prohibited substances and new chemicals (if any); 8. Disposal of hazardous wastes and general industrial solid wastes (if any); 9. Implementation of ecological protection measures (if any); 10. Impacts on environmental sensitive areas such as drinking water source (if any); 11. Environmental risks, contingency plans and environmental incidents (if any); 4 Institutional arrangement is shown as below: Figure 2 Organizational chart of Hubei Hengxin 5 5. Time period covered by the audit In accordance with the domestic environmental audit requirements of listed companies, the audit should cover the environ performance of the facility in the past 36 consecutive months. Since the environmental audit started in May 2016, it covers the performance of Hubei Hengxin Chemical Co., Ltd during the period of January 1, 2013 to December 31, 2015. 6. Applied standard In accordance with Notice of the General Office of the People's Government on forwarding the Functional Category of Surface Water Environment by Provincial Environment Protection Administration ([2000] No.10), and Letter on Environmental Impact Assessment Standards and Total Pollutant Discharge Control Indicators for Hubei Hengxin Chemical Co., Ltd. with a Capacity of 30t/an Organic Fluorine Products (No. 35 [2007] issued by EPA of Yingcheng City, the execution standards are as follows: Table 3 Emission standards and environmental quality standards Pollutant concentration limits Standard No. and CATEGORY CATEGORY name Value-getting Secondary Name time standard Annual average ≤0.06mg/m3 Sulfur dioxide Daily average ≤0.15g/m3 (SO2) 1-hour average ≤0.50mg/m3 Annual average ≤0.08mg/m3 GB3095-1996 NO2 Daily average ≤0.12mg/m3 Ambient Air Ambient air Category II Quality Standard and its amendments 1-hour average ≤0.24mg/m3 Annual average ≤0.20mg/m3 TSP Environmental Daily average ≤0.30mg/m3 quality standards Daily average ≤7mg/m3 Fluoride 1-hour average ≤20mg/m3 CODcr ≤20mg/L Chloride ≤250mg/L GB3838-2002 PH 6~9 Surface water Environmental Category Ⅲ environment Quality Standard for Surface Water NH3-N ≤1.0mg/L Fluoride ≤1.0mg/L Volatile phenol ≤0.005mg/L 6 Pollutant concentration limits Standard No. and CATEGORY CATEGORY name Value-getting Secondary Name time standard GB3096-93 Name Category II standard Standard of Acoustic Environmental Category II Equivalent Day and night ≤60dB (A) environment Noise of Urban sound Area level-Leq (A) Night ≤50dB (A) Concentration limit of hydrogen chloride at fugitive GB16297-1996 Hydrogen emission monitoring point: Integrated Emission Table 2 chloride, 0.20 9mg / m3; Standard for Air Category II hydrogen Concentration limit of Pollutants fluoride hydrogen fluoride at fugitive Waste gas emission monitoring point: 20ug / m3 GB13271-2014 Category-II Gas boiler: Soot & dust: 50 mg Emission Emission Standard area and Soot & dust, / m3, SO2: 100mg / m3; standards of Air Pollutants Category-II SO2, NOx NOx400mg/m3 for Boilers period GB8978-1996 PH, CODCr, PH: 6 ~ 9; CODCr: 100mg / L; Table 4 Integrated Water ammonia, ammonia: 15mg / L; Fluoride: Category I Discharge Standard fluoride 10mg/L Wastewater DB42 / 168-1999 Table 1 Chloride Discharge Category II in 300 mg/L for dry season, 400 Chloride Standards for River chemical mg/L for wet season in Hubei Province industry GB12348-90 Standard for Noise Continuous Day-time: 60dB (A); Acoustic noise at Boundary of Category III A-weighted Night-time: 55dB（A） Industrial sound level Enterprises 7 Chapter 2 Environmental sensitive areas & environmental functional zoning 1. Environmental sensitive areas Yingcheng City mainly has four rivers: Yunshui River, Zhang River, Dafushui River and Hanbei River. These rivers are tributary of Hanshui river system in Yangtze River. In 1959, Yunshui River is made as an independent river system straight into Yangtze River after its improvement. In 1969, the excavation of Hanbei River includes Dafushui River into the Hanbei River system. The length of Dafushui River in Yingcheng City is 65km. Its runoff area is 384km2 and foreign water volume is 3.112 billion. The number of brook more than 5km long is 14, totaling a length of 201km in Yingcheng City. In addition to Dafushui River, Yingcheng City also has Salt River and Laoxian River. Salt River is an agricultural irrigation canal. Due to heavy salt pollution, it is called Salt River. Salt River originates from Duangang Reservoir. It flows from north to south into Laoxian River and then flows into the Hanbei River. Laoxian River is a part of the Dafushui River (the section from Chengguan to the North of Hanbei River) before river migration. After the curving cut-off of Dafushui, the front end of Laoxian River has been silted up. Receiving domestic sewage from the urban region and salt chemical sewage with high degree of chloridion, Laoxian River has become a wastewater canal substantially. The reach from Ruanjiawan to Lvjiawan is about 7.8 km. Laoxian River flows into Dafushui through the right-angled stream artificially excavated in Yujia Floodgate, which is located downstream from central downtown region. Yujia Floodgate is open all the year round, as Laoxian River has been out of agricultural irrigation function. Currently, Yujia Floodgate has become the major sewage draining exit of Yingcheng City. The company locates at 1 Changjing Avenue in Yingcheng Industrial Park, adjacent to Yanshui River to the east with farmlands across the river, to Guangming Reclaimed Rubber Factory to the south, to Tiyuchang Road to the west with residential area across the road, and to Beimei Industrial Park to the north. Sewage water from this plant flows into Salt River and goes into Dafushui by going through Laoxian River, passing Hanbei River and finally flowing into the Yangtze River. 8 Figure3. Geographical location and surrounding of Hengxin Figure4. Urban region and drainage map of Yingcheng City where Hengxin is located (1) Environmental protection goals of surface water: Sewage water from this plant flows 9 into Salt River and goes into Dafushui by going through Laoxian River, passing Hanbei River and finally flowing into the Yangtze River. Therefore, quality of Salt River, which is the direct receptor of water discharged by this plant, shall meet the Category-III standard in GB3838-2002 Environmental Quality Standard for Surface Water; (2) Environmental protection goals of ambient air: The ambient air quality shall meet the requirement in GB3095-2012 Ambient Air Quality Standard and its Category-II standard of its amendments; (3) Environmental protection goals of acoustic environment: Acoustic environmental quality shall meet Category-II standards of GB3096-2008 Environmental Quality Standard for Noise. Environmental sensitive spots around the project site are shown in Table 4: Table 4 List of environmental sensitive spots around project site Items Sensitive Position Distance from Protection class Scale spots the enterprise boundary Ambient Resident W 50~100m About 10 air households, 40 GB3095-1996, people Resident SE 400~500m Category-II About 20 households, 80 people Surface Salt River E 10m GB3838-2002, water Category-III 2. Environmental functional zoning In accordance with Notice of the General Office of the People's Government on forwarding the Functional Category of Surface Water Environment by Provincial Environment Protection Administration ([2000] No.10), and Letter on Environmental Impact Assessment Standards and Total Pollutant Discharge Control Indicators for Hubei Hengxin Chemical Co., Ltd. with a Capacity of 30t/a Organic Fluorine Products (No. 35 [2007] issued by EPA of Yingcheng City, the environmental functional zoning of the project site are shown in Table 5: Table 5 Environmental function zoning of project site Environmental factors Regions and scopes Functional categories Ambient air Yingcheng Industrial Park Category-II area Surface water Dafushui River Category-III water Ambient noise Yingcheng Industrial Park Category-II area 3. General layout of the plant site The general layout of Hubei Hengxin is shown in Figure 5. 10 165500 24000 29000 19000 电 气 10000 原料棚 7000 体 职工宿舍 停 车场 盐 11000 44000 9000 35600 41600 10000 8700 办公楼 8100 8000 成品库 12000 10500 育 7000 4000 8000 6500 1300 4000 6000 8000 6500 184400 44000 水 10000 10000 1号 电 解 车间 2号 电 解 车间 52000 41600 35600 18000 绿化园区 52600 10000 磺化车间 冷冻车间 12000 49000 27000 7000 卫 生间 6000 10000 港 4000 6000 变 电房 锅 炉房 114000 30500 48000 光明橡胶厂 32800 水井 7 5 m m水 管 预设水管 2007.05.01 单位：毫米 Figure5 General Layout of Hubei Hengxin 11 Chapter 3 Project overview 1. Project brief The constructed projects are divided into main works, public works, environmental-protection works, and office and living facilities. See details in Table 6. Table 6 Composition of the company Project N Name of categorie Main contents o. workshop s 1 Main Productio 4 production shops works n shops 1 repair shop 1 warehouse 2 Public Supply 1 water supply pipe of Yingcheng City: Pipe diameter is works and DN108mm. 12 water supply pipes in the plant: pipe diameter is drainage DN57-108mm, and water pressure is 0.2Mpa. system The drainage system: a system diverting clean water from sewage water and a system diverting rainwater from sewage water. Quantity of domestic sewage is 2551 m3 /a; and quantity of industrial wastewater is 208 m3 / a. After treatment, the water will be discharged to Salt River, then flows into Dafushui River, and finally flows into the Yangtsze River through the Han River system. Circulatin Tap water is used for cooling and reflows during the distillation g water process. The volume of circulation water is 15 m3/h, and system cooling time is 7200 hours; the volume of circulation water in cooling unit is 250 m3/h, and usage time is 4800 hours; the volume of circulating water in vacuum pump is 3 m3/h, and usage time is 300 hours/year. Boiler A 1t / h boiler is adopted to provide steam, using natural gas as heating energy. system Power A 10kV power line of Yingcheng Electric Power Company is supply used. The supply capacity is 333 kVA, and power consumption system is 5.4 × 106kW·h/year. 3 Environ Exhaust The exhaust gas goes through a spray tower before fugitive mental-pr treatment emission. The hydrogen chloride and fluoride are tested out of otection system the plant boundary. The coal-fired boilers are changed into works gas-fired boiler. Tests of SO2, NOx and dust are conducted in the sampling port of chimney flue. Wastewate The washing wastewater is neutralized and deposited before r being discharged into sewage pipe network along with sanitary treatment waste. system Wastewater treatment plant of Yingcheng City: The handling capacity of this plant is designed to be 30000m3 per day. The sewage treatment equipment has maintained good performance since January, 2009, with an average daily sewage treatment capacity of 32100 m3. The oxidation ditch treatment 12 Project N Name of categorie Main contents o. workshop s process has been adopted in this project and the sewage water quality after the treatment reaches B-level discharge standard specified by Discharge Standard of Pollutants for Municipal Wastewater Treatment Plant (GB18918-2002). The pollutants discharge of this wastewater treatment plant during the audit period is within the limits. Solid The domestic waste of the plant shall be periodically handled waste by the sanitation department. The distillation residue treatment (rectification residue) and precipitate CaF2 shall be transferred to Yichang Hazardous Wastes Treatment Center (there is no qualified hazardous waste treatment center in Wuhan City). 4 Office Office Total construction area of office building is 504.2 ㎡ 5 Living Total construction area of the canteen is 201.6 ㎡ facilities 2. Production process Production process of PFOS: (1) Sulfonation: First, use a metering pump to put water into the sulfonation reactor. Then, use a vacuum pump to put bromooctane and sodium sulfite into to the sulfonation reactor. Meanwhile, add water and ethanol, and control the reaction temperature at about 80 ℃. Next, use a condenser for reflux condensation and stirring. The reaction time is 24 hours. After that, use distillation method to recycle the solvent. Then, collect the solvent into the gauging tank in 100℃. The distillation time is 6 hours. After reaction, the material in reactor shall be delivered to a dryer. The drying time is 14 hours and drying temperature is 120°C. The dried product-sulphonated salt mixture-shall be used for the next procedure-chlorination. The reactions in the reactor are as follows: C 8H17 Br＋Na2SO3 → C8H17SO3 Na ＋NaBr Bromooctane Sodium sulfite Octyl sodium sulfonate Natrium bromide The conversion rate of bromooctane is 98%. (2) Acyl chlorination： The phosphorus oxychloride and sulphonated salt mixture shall be put into the reactor by vacuum pump. The reaction temperature is about 75 ℃, and the reaction time is about 5 hours. Then, slowly add water to stir the reaction mixture for approximately 5 hours. After reaction, let stand for 3-4 hours for stratification. The lower part -wastewater-shall be discharged into sewage treatment station before final emission. The upper part shall be pumped into metering tank. The reactions in this reactor are as follows: 3C8H17SO3Na＋2POCl3 ＋3H2O→3C8H17SO2Cl＋3HCl＋Na2HPO4＋ NaH2PO4 Octyl sodium sulfonate Phosphorus oxychloride Water Octanesulfonyl chloride Hydrogen chloride Sodium hydrogen phosphate Sodium Dihydrogen Phosphate Conversion rate of C8H17SO3Na is 95%. (3) Fluorination: The potassium fluoride and octanesulfonyl chloride are put into the fluorination reactor by vacuum pump. The reaction temperature is about 80℃. The reaction time is 4-5 hours. Add gauged water to stir the reaction for 1 hour. Let stand for 13 4 hours for stratification. The lower part (wastewater) will be put into the sewage treatment station before emission. The upper product is pumped to a distillation kettle. The control temperature for heat transfer fluid is 120 ℃. The distillation time is 4 hours. The reactions in this reactor are as follows: C8 H17SO2 Cl＋KF→C8H17SO2F＋ KCl Octanesulfonyl chloride Potassium fluoride Potassium Fluoride Potassium chloride Conversion rate of octanesulfonyl chloride is 95%. (4) Electrolyzation: Use frozen brine to keep the electrolyzation temperature at -40 ℃. Put gauged hydrofluoric acid and nitrogen into the electrolytic tank. Use nitrogen gas as shield gas. Use rectifier to supply power for the polar plate of the electrolytic tank. Then, put gauged C8H17SO2F into the electrolytic tank. The electrolyzation time is about 48 hours. When current drops, the chemical C8H17SO2F need to be added to control the current. After electrolyzation, let stand for 1-2 hours. The crude product will flow into the trough under the impact of gravity. Iron plate will be used as negative pole, and nickel plate will be used as an positive electrode. The chemical reactions occurring during the electrolytic process are as follows: Octyl sulfonyl fluoride Hydrofluoric acid PFOSF C8H17SO2F +17.1HF→0.7C8F17SO2F+0.1C10F21SO2F+0.1C6F13SO2F+0.1C4F9SO2F +0.05C8F18 +17H2 ↑ Hydrogen Conversion rate of octyl sulfonyl fluoride is 97%. (5) Distillation: The receiving tank is filled with water to form a seal. The products will flow automatically to the receiving tank for cleaning. The water quantity for each batch of cleaning is 0.1 m3. The cleaning time is 12 hours. After cleaning, let stand for stratification. Put crude products into the heat-conduction oil tank for distillation. Control the temperature by heat-conduction oil tank. Under 100 ℃, get the front cut fraction. The duration is 4 hours; then rise to 110 ℃ to get the product. The duration is 2 hours. As required, the final product will be packaged into 25kg/barrel, 50 kg/barrel or 200 kg/barrel. The front cut fraction will undergo deep processing at room temperature. The front cut fraction from rectification will be put into a reactor, which is dedicated to deep processing. The admixture (by-product) obtained will be added with perfluoro surfactant to get the final product. The process is shown in Figure 3. The maximum production capacity per batch is 100kg. The production time for each batch is about 136 hours. The electrolysis can be carried out in three batches simultaneously. Hence, the production time can be guaranteed. 14 乙醇 Ethyl alcohol 溴辛烷 Sulfuration 磺化反应 reaction Bromooctane （24h, o 80 ℃）C） 亚硫酸钠 Sodium sulfite （24h，80 计量水 Water 乙醇回用 Recycling of ethyl alcohol 蒸馏 Distillation G1（无组织排 Fugitive discharge o （（ 6h ，100-120 6h, 100-120 ℃） C） 放） Drying 干燥（14h,120 o ℃） （14h, 120 C） G2 Fugitive discharge G2（无组织排放） Phosphorus 三氯氧磷 oxychloride Chloroformylation 喷淋塔洗涤 25% 盐 hydrochloric acid 25% 酰氯化反应 Scrubbing and Fresh water reaction 回收 of 酸 (Transference) 新鲜水 （10h，75o ℃） recycling （转移） （10h, 75 C） spray tower Stratification 下层废水 静止分层（3-4h) Lower W1 wastewater W1 （3-4h） Fluoridation 氟化反应 reaction Potassium fluoride 氟化钾 o （ 80 C （80℃，5-6h) 5-6h ） Fresh water 新鲜水 Stratification 静置分层（4h）(4h) 下层废水 Lower W2 wastewater W2 Distillation residue Distillation 蒸馏残渣 HW11 蒸馏（4h,120 ℃） HW11 （4h, 120 oC） G3 G3Fugitive （无组织排放） discharge 25% hydrofluoric acid 电解（ Electrolysis 喷淋塔洗涤 25%氢氟酸 (Transference) Hydrofluoric 氢氟酸 acid （50h, 50h,13- o Scrubbing and 回收 of （转移） 18℃） C） 13-18 recycling spray tower 水 Water 清洗（12h Washing ）） （12h 清洗废水 Washing wastewater Front cut fraction, for deep 前馏分，用 精馏（100- Processing 于深加工 Rectification 精馏残渣 Rectification residue 110℃） （100-110 o C） HW11 HW11 产品 Products Figure 6. Production process & products 15 Figure 7 No.1 workshop and hydrogen chloride absorption tower Figure 8 Electrolytic workshop 16 Figure 9 Condensing workshop and condensed water circulation system 17 Figure 10 Distillation workshop 3. Raw materials and products The project's product solutions are listed in Table 7. Hengxin’s output in 2015 exceeded the limit, i.e. 30t/a, specified in the Reply of EIA. So, Hengxin shall control its output below the limit or apply to local EPB for reconstruction or expansion, depending on market needs and its own productivity. Table 7 List of product solutions No. Product name Annual output Executive 2013 2014 2015 standard 1 PFOSF 25920kg 23262kg 36428kg Q/YH01-2005 4 products of 4086kg 3148kg 3172kg fluorocarbon The raw/auxiliary materials and storage methods are shown in Table 8: Table 8 List of raw/auxiliary materials Materials Usage (t/a) Consumption quota (kg Remarks (origin, ingredients, storage / tonne of product) methods, etc.) 18 Materials Usage (t/a) Consumption quota (kg Remarks (origin, ingredients, storage / tonne of product) methods, etc.) Bromoocta 17.1 570 ≥98%, outsourcing, iron drum-200kg ne / barrel Sodium 11.2 374 ≥98%, outsourcing, bagged-25kg / sulfite bag Nitrogen 0.24 8 ≥98%, outsourcing, bottled-340kg / bottle Hydrofluori 32.7 1090 ≥99.5%, outsourcing, in HF storage c acid tank placed in ambient temperature Phosphorus 8.6 287 ≥98.5%, outsourcing, plastic oxychloride barrel-200kg / barrel Potassium 4.6 153.3 ≥96%, outsourcing, bagged-25kg / hydroxide bag Ethanol 1.9 300 ≥99%, outsourcing, in sealed plastic bucket, placed in shade to avoid direct sunlight. Water 21456 325.3 Running water 6 5 Electricity 5.4×10 kw·h 1.8×10 Supplied by Yingcheng Power Supply Company 4. Main pollutant-producing sections & pollution treatment According to final acceptance inspection report of environmental protection monitoring station of Yingcheng City (HY[2005] No.B01) and Retrospective Evaluation Report of the 30t/an Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd and the replies (X.H.H [2008] No.19), the practical implementation of pollution treatment measures for the project are shown in Table 9. Table 9 Major pollution sources and implementation of pollution prevention measures Pollution Actual Treatment measures sources implementation Audit comments proposed in EIA and effects Industrial Industrial wastewater Constructed, and The design of process is wastewater will be used as water recycling has reasonable, and water circulating water of the been achieved. recycling can be achieved. chiller after neutralization Washing By adding Ca (OH) 2 Constructed, and The design of process is wastewater and flocculants, up-to-standard reasonable, and up-to-standard wastewater will be used discharge has been discharge can be achieved. for washing, after which achieved. the water will enter into the municipal pipe network Domestic A biological treatment Not constructed yet, As the survival of biological 19 sewage system will be adopted and the water flows bacteria will be affected by for treatment of into the municipal hydrogen fluoride, which domestic sewage. pipe network makes it inappropriate to directly. construct biological wastewater treatment system. What’s more, the company’s scale is small and the discharge of sewage has met with the standard. Rain water Sewage pipes to Separation of rain & The separation of rain from separate rain & polluted polluted water has wastewater is well done. water will be been achieved. constructed. Hydrogen Use spray tower to wash Constructed, the The treatment process is chloride before emission. hydrogen chloride reasonable and can achieve waste gas recycling efficiency compliance with standard on is greater than 99% discharge of the hydrogen chloride in waste gas. Hydrogen Use three-layer spray Constructed, the The treatment process is fluoride tower to wash before treatment efficiency reasonable, the discharge of waste gas emission. is greater than 99% the hydrogen fluoride in waste gas can meet standard. Exhaust Switch to gas-fired Constructed, and The treatment process is gas of the boiler by using natural up-to-standard reasonable, the boiler gas as fuel discharge has been up-to-standard discharge of achieved. NOx, SO2 and smoke in waste gas can be achieved Factory (1) The boiler will be Soundproofing doors boundary installed in a private and windows are not As founded during the site noise boiler room. (2) installed and inspection, acoustic noise Low-noise cooling low-acoustic noise produced by cooler units is tower will be used. (3) cooling tower has high and it is recommended to Soundproofing doors not been adopted. construct soundproofing doors and windows will be Acoustic noises and windows or to use used. (4) Doors and produced may go low-noise cooling towers in windows will be closed beyond the limit accordance with the original during production at when production is environmental assessment night. arranged in the requirements. night. Distillation After acid chloride Distillation residues The storage yard of hazardous residues reaction, the front cut are temporarily wastes is not installed in a fraction in distillation stacked at the standardized way. For will be transferred; after storage yard of example, impervious electrolysis process, the hazardous wastes. separated regions are not front cut fraction in arranged in the storage yard, distillation will undergo hazardous wastes are not deep processing for sale. strictly separated from other wastes, warning marks and graphical signs for environmental protection are not made in accordance with GB15562.2. There are high 20 risks associated with the storage yard and the enterprise needs to enhance standardized management accordingly. CaF2 For road filling of the CaF2 residues are The treatment is in accordance plant site hazardous wastes with the regulation, and could and transferred to not cause the harm of waste. Yichang hazardous wastes treatment center for treatment and there are no signs of landfilling. Household Gathered and delivered Taken, and details of The treatment is in accordance refuse to the Yingcheng this waste yard can with the regulation and is household refuse be found in Table Reasonable and economical. treatment plant by the 2.1. environmental protection agency uniformly Fire A 250m³-emergency fire Recycling water The design is reasonable, and pond needs to be pond is also used as can be capable of meeting installed. emergency fire with the water needs of fire pond; fire hydrants protection are installed at doors of every workshop and buildings, the pond is 1000m3 Invalidation Emergency fire pond The original The design is capable of of (with the size of 22 m3 emergency fire pond handling the emergency in wastewater at least) needs to be enlarged to 250m3 cases of failure of wastewater treatment arranged. pond in wastewater treatment station. Standards station treatment station, required are met with. with pipes connected with sulfonation and electrolysis workshops. Plant To plant trees and Water demand for greening grasses afforestation is huge (8730m3 Actions Taken per year) and one alternative option is to implement greening management by using scientific technologies to save water. 21 Chapter 4 Contents of environmental audit 1. Implementation of “Three Simultaneous System” and EIA Yingcheng Hengxin Chemical Co., Ltd. is a joint venture co-founded by Yingcheng Tianhong Chemical Co., Ltd. and Wuhan Defu Economic Development Co., Ltd in 2004. In the same year, the company initiated its production of organic silicon and organic fluorine products in Yingcheng Industrial Park, which is located in South of Changjing Bridge, Tiyu Road, Yingcheng City. In April 2004, Yingcheng Hengxin Chemical Co., Ltd. entrusted Wuhan Environmental Protection Science Research Institute to prepare the Environmental Impact Statement for Organic Silicon and Organic Fluorine Products Project of Yingcheng Hengxin Chemical Co., Ltd. In the same year, the environmental protection agency approved the statement. In July 2005, the project passed final acceptance. The company did not install silicone manufacturing equipment. The main products of the company are organofluorine series. Its annual production capacity of PFOSF is 30 tons. In September 2007, the company commissioned Hubei Junbang Environmental Technology Ltd to prepare Retrospective Evaluation Report of the 30t/an Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd (See Annex 1-1). In March 2008, the report got the approval of Yingcheng Environmental Protection Agency (See Annex 2-3:X.H.H [2008] No.19) (See Annex 1-3). In March, 2009, the company passed the environmental protection acceptance check (See Annex 2-5: X.H.H [2009] No.34 (See Annex 1-5). See Table 10 for implementation of three simultaneous system and EIA Following the review comments for environmental acceptance check of the 30t/an Organic Fluorine Products Project, the project conducted the following work: (1) Standardized the eco-label at the sewage outfall; (2) Monitored the water pH; entrusted Yingcheng monitoring station to carry out the supervisory monitoring twice a year. The monitoring indicators meet the standards. However, the output of PFOSF at Hubei Hengxin in 2015 exceeds 30 tons, which is the approval limit for EIA. 22 Table 10 Environmental approval documents Environmental protection Start/end EIA EIA Company acceptance check No. Location Project name Nature Project content time of document name Approval Approval Approval Approval Approval Approval construction type Unit date No. Unit date No. Environmental Yingchen Scale of Yingcheng impact statement for g Hubei production: Municipal Yingche silicone products and Municipal H.Y. Hengxin New-b fluorine-20 Report Environme 1 ng City, organic fluorine 2003 to 2005 Environm 2004.2 Replied 2005.7 [2005] Chemical uilt ton/year, form ntal Hubei project of Hubei ental No. B01 Co., Ltd. silicon-250 ton/ Protection Hengxing Chemical Protection year Bureau Co., Ltd. Bureau Retrospective evaluation report for Hubei Yingche 30 t/an Recon X.H.H X.H.H Hengxin Xiaogan Xiaogan 2 ng City, organofluorine structi 30 t/a PFOSF 2003 to 2005 Report 2008.3 [2008] 2009.3 [2009] Chemical EPA EPA Hubei project of Hubei on No. 19 No. 34 Co., Ltd. Hengxin Chemical Co., Ltd 23 2. Compliance of industrial policies In the construction period ** of production line, the products of this project is listed as "permit category', in accordance with Decision of State Council on Releasing Interim Provisions for Promoting Industrial Restructuring (G.F [2005] No. 40) and Guidance Directory for Adjustment of Industrial Structures-2011(amended in 2013). However, the Standing Committee of the National People's Congress approved the “Amendment of Annex A, Annex B and Annex C Associated with 9 Kinds of POPs Stated in Stockholm Convention and Notice on Entry into Force of Amendments to Annex A Associated with Newly-Added Endosulfan” (Notice of the Ministry of Environmental Protection, No.21, March 25, 2014.) The amendment came into force on March 26, 2014. On March 25, 2019, the specific exemption will expire. China should phase-out 6 kinds of PFOS of specific exemptions before the end of specific exemption date. Besides, China should gradually develop BAT/BEP for 7 kinds of PFOS in PFOS industries of acceptable uses. Therefore, the products in this project are required to be phased-out in a specified time limit. 3. Implementation of emission declaration, emission permit and sewage charges payment 3.1 Implementation of emission declaration Documents for emission declaration of Hubei Hengxin Chemical Co., Ltd. are complete. The sampling is shown in Annex 2-1. 3.2 Implementation of emission permits The term of validity for emission permit (see Annex 2-2, Annex 2-3 and Annex 2-4) is April 16, 2012-April 15, 2015, April 16, 2015-April 15, 2016 and April 16, 2016--April 15, 2017. The implementation of emission permit is shown in Table 11. However, in the emission permit, there are no control requirements for emission of specific pollutants. Table 11 Implementation of emission permits Year 2013 2014 2015 License name Emission permit of Hubei Province License No. K.Y.0900007 Issued by: Yingcheng Municipal Environmental Protection Bureau and status Contents License quantity, t/a 0.5 0.5 0.5 SO2 Emission quantity, t/a 0.144 0.144 0.144 24 Year 2013 2014 2015 License quantity - 0.356 0.356 0.356 emission quantity, t/a License quantity, t/a 1.42 1.42 1.42 NOx Emission quantity, t/a 0.828 0.828 0.828 License quantity - 0.592 0.592 0.592 emission quantity, t/a License quantity, t/a 0.19 0.19 0.19 Dust Emissions, t/a 0.0216 0.0216 0.0216 License quantity - 0.1684 0.1684 0.1684 emission quantity, t/a License quantity, t/a 0.12 0.12 0.12 CO Emissions, t/a 0.11 0.11 0.11 D License quantity - 0.01 0.01 0.01 emission quantity, t/a License quantity, t/a 0.04 0.04 0.04 Am mon Emission quantity, t/a 0.008 0.008 0.010 ia License quantity - 0.032 0.032 0.03 emission quantity, t/a 3.3 Implementation of sewage charges payment In accordance with payment notices and payment invoices of Hubei Hengxin issued by Yingcheng Environmental Protection Agency, the company's timely payment of sewage charges is in full amount during the production period. Table 12 Payment of sewage charges Payment notice Paid Collection agencies of Year contributi Amount sewage charges Time interval Code on (yuan) payable H.J.F.H.Z Yingcheng Municipal January to 2013 [2013] No. 20000 20000 Environmental December 322 Protection Bureau Invoices found, Yingcheng Municipal January to 2014 payment - 20000 Environmental December notice not Protection Bureau found H.J.F.H.Z Yingcheng Municipal January to [2015] No. 10000 10000 Environmental June 315 Protection Bureau 2015 H.J.F.H.Z Yingcheng Municipal July to [2015] No. 10000 10000 Environmental December 343 Protection Bureau 25 4. Specific pollutants and their emission & treatment 4.1 Pollutant sources and pollution treatment According to final acceptance report of Yingcheng Environmental Monitor Station (HY[2005] No.B01) and Retrospective Evaluation Report of the 30t/a Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd and its relevant approval (X.H.H [2008] No.19), the practical implementation of pollution treatment measures for the project are shown in Table 9 (Annex 5- Operation Log of Sewage Treatment Station), including discharge standards, up-to-standard discharge assessment and analysis of key pollutants. 4.2 Discharge monitoring According to the routine monitoring data got by Yingcheng Environmental Protection Monitoring Station (for sampling, see Annex 3), the emission behavior of Hubei Hengxin within the audit period is shown in Table 13. Judging from the statistical results in Table 13, the emission behavior of major pollutants during the verification period meets the emission standards. But: (1) The company's monitoring frequency of pollutants is only two times, failing to reach 4 as required in EIA (Retrospective Evaluation Report of the 30t/an Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd); (2) The indicator of fluoride in wastewater has not been got due to lack of monitoring capacity of Yingcheng Environmental Monitor Station; (3) The monitoring of indicators for plant-boundary fugitive emissions-hydrogen chloride and hydrogen fluoride gas-has not been carried out as required by EIA; (4) The number of monitoring sites for plant-boundary noise did not reach 8 as required by EIA; The specific pollutants for Hubei Hengxin Chemical Co., Ltd refer to perfluorinated compounds-PFOS and PFOA, in accordance with Reply on Entrusted Monitoring of Specific Pollutants of Hubei Hengxin Chemical Co., Ltd. Perfluorinated compounds are listed items in Amendments of 9 kinds of POPs in Stockholm Convention. The Stockholm Convention comes into force in August 30, 2013. However, there are no national environmental quality standards, emission standards and technical specification for testing for such specific pollutants. Due to this reason, this specific pollutant was not monitored. 26 Table 13 Summary of emission behavior of key pollutants Audit item: Hubei Hengxin Pollutant No. of emission Limit of emission Emission Year Pollutants Monitoring values Source sources standards executed standards behavior Emission behavior of water pollutant CODcr 100mg/L 212-51.6 Pass GB8978-1996 Fluoride 10mg/L - - Integrated Water Main outfall Discharge Standard- 2013 Yingcheng Environmental PH 6~9 7.62-6.84 Pass (namely, Category I Protection Monitoring Station (No.: 2013 sewage NH3-N 15mg/L 6.8-1.2 Pass Y.H.J.Z (2013) No. WY2013-017, treatment Y.H.J.Z (2013) No. WY2013-070, plant's outfall) DB42 / 168-1999 two monitoring reports) Chloride Discharge 300 mg/L for dry Chloride Standards for River season; 400 mg/L 71.46 (1 time) Pass in Hubei for wet season Province-Category II CODcr 100mg/L 68.4-93.4 达标 GB8978-1996 Fluoride Integrated 10mg/L - - Wastewater 2014 Yingcheng Environmental Main outfall pH Discharge 6~9 6.88-7.07 达标 Protection Monitoring Station (namely, Standard-Category I ( No.: Y.H.J.Z (2014) 2014 sewage NH3-N 15mg/L 0.2-0.7 达标 WY2014-020, Y.H.J.Z (2014) No. treatment DB42 / 168-1999 WY2014-059, two monitoring plant's outfall) Chloride Discharge 300 mg/L for dry reports) Chloride Standards for River season; 400 mg/L 79.97-95.72 Pass in Hubei for wet season Province-Category II Emission 2014 Main outlet 45 m3/d quantity 27 Audit item: Hubei Hengxin Pollutant No. of emission Limit of emission Emission Year Pollutants Monitoring values Source sources standards executed standards behavior CODcr 100mg/L 12.0~87.4 Pass 2015 Yingcheng Environmental GB8978-1996 Fluoride 10mg/L - - Protection Monitoring Station (No.: Integrated Water Y.H.J.Z (2015) No. WY2015-054, Main outfall Discharge Standard- pH 6~9 6.86~6.87 Pass Y.H.J.Z (2015) No. WY2015-019, (namely, Category I two monitoring reports) 2015 sewage NH3-N 15mg/L 3.1~4.4 Pass treatment plant's outfall) DB42 / 168-1999 Chloride Discharge 300 mg/L for dry Chloride Standards for River season; 400 mg/L - - Unmonitored in Hubei for wet season Province-Category II Emission behavior of air pollutant Plant Concentration boundary's limit of fugitive Hydrogen fugitive emission in - - Unmonitored chloride emissions- GB16297-1996 monitoring point: No.1 plant Integrated Emission 0.20 mg / m3; Plant Standard for Air Concentration boundary's Pollutants limit of fugitive Hydrogen emission in fugitive - - Unmonitored 2013 fluoride emissions- monitoring point: No.2 plant 20 µg / m3; GB13271-2014 Coal: 200mg / m3; Dust 10.1-10.6 Pass 2013 Yingcheng Environmental Emission Standard of gas: 50 mg / m3 Boiler's Protection Monitoring Station (No.: Air Pollutants for exhaust Y.H.J.Z (2013) No. WY2013-017, Boilers-Class II funnel Y.H.J.Z (2013) No. WY2013-070, NOx districts and II time 400 mg / m3 116-121 Pass two monitoring reports) interval 28 Audit item: Hubei Hengxin Pollutant No. of emission Limit of emission Emission Year Pollutants Monitoring values Source sources standards executed standards behavior Coal: 900mg / m3; SO2 2 Pass gas: 100 mg / m3 Plant Concentration boundary's limit of fugitive Hydrogen fugitive emission in - - Unmonitored chloride emissions- GB16297-1996 monitoring point: No.1 plant Integrated Emission 0.20 mg / m3; Plant Standard for Air Concentration boundary's Pollutants limit of fugitive Hydrogen fugitive emission in - - Unmonitored 2014 fluoride emissions- monitoring point: No.2 plant 20 µg / m3; GB13271-2014 Coal: 200mg / m3; Dust 5-8 Pass 2014 Yingcheng Environmental Emission Standard of gas: 50 mg / m3 Boiler's Protection Monitoring Station (No.: Air Pollutants for exhaust NOx 400 mg / m3 98-112 Pass Y.H.J.Z (2014) No. WY2014-020, Boilers-Class II funnel Y.H.J.Z (2014) No. WY2014-059, districts and II time Coal: 900mg / m3; SO2 18-37 Pass two monitoring reports) interval gas: 100 mg / m3 Plant Concentration boundary's limit of fugitive Hydrogen fugitive emission in - - Unmonitored chloride GB16297-1996 emissions- monitoring point: No.1 plant Integrated Emission 0.20 mg / m3; Standard for Air Plant Concentration 2015 Pollutants boundary's limit of fugitive Hydrogen fugitive emission in - - Unmonitored fluoride emissions- monitoring point: No.2 plant 20 µg / m3; Boiler's GB13271-2014 Coal: 200mg / m3; 2015 Yingcheng Environmental Dust 6-11 Pass exhaust Emission Standard of gas: 50 mg / m3 Protection Monitoring Station (No.: 29 Audit item: Hubei Hengxin Pollutant No. of emission Limit of emission Emission Year Pollutants Monitoring values Source sources standards executed standards behavior funnel NOx Air Pollutants for 400 mg / m3 101-121 Pass Y.H.J.Z (2015) No. WY2015-054, Boilers-Class II Y.H.J.Z (2015) No. WY2015-019, districts and II time Coal: 900mg / m3; two monitoring reports) SO2 1-68 Pass interval gas: 100 mg / m3 Behavior of plant-boundary noise Monitoring Monitoring No. of noise Noise standard Year Monitoring values Behavior Monitoring Report No. points project standards executed limits Set 8 GB12348-90 Day-time: 1#48.1； 2013 Yingcheng Environmental monitoring Standard for Noise at 2#43.6；3#52.2；4#49.1 Continuous Day-time: 65dB Protection Monitoring Station (No.: sites at 1m Boundary of (A); Night-time: 2013 A-weighted Pass Y.H.J.Z (2013) No. WY2013-017, away from the Industrial Night-time: 1#42.3； sound level 55dB（A） Y.H.J.Z (2013) No. WY2013-070, plant Enterprises-Category 2#40.2；3#46.1；4#44.1 two monitoring reports) boundary III Set 8 GB12348-90 Day-time: 1#51.4-63.4； 2#48.2-51.4； 2014 Yingcheng Environmental monitoring Standard for Noise at Continuous Day-time: 65dB Protection Monitoring Station (No.: sites at 1m Boundary of 3#53.1-49.6； 4#60.2-47.7 2014 A-weighted (A); Night-time: Pass Y.H.J.Z (2014) No. WY2014-020, away from the sound level Industrial 55dB（A） Night-time: 1#46.3-50.2； Y.H.J.Z (2014) No. WY2014-059, plant Enterprises-Category 2#43.3-47.4； two monitoring reports) boundary III 3#48.7-47.2； 4#49.9-42.2 Set 8 GB12348-90 Day-time: 1#52.2-54.3； 2#55.1-63.4； 2015 Yingcheng Environmental monitoring Standard for Noise at Continuous Day-time: 65dB Protection Monitoring Station (No.: sites at 1m Boundary of 3#62.2-50.3； 4#48.9-51.5 2015 A-weighted (A); Night-time: Pass Y.H.J.Z (2015) No. WY2015-054, away from the sound level Industrial 55dB（A） Night-time: 1#43.6-47.7； Y.H.J.Z (2015) No. WY2015-019, plant Enterprises-Category 2#47.0-51.4； two monitoring reports) boundary III 3#47.8-53.0； 4#45.6-46.6 Given the foregoing deficiencies, in order to understand whether discharges of the plant in 2016 has met with the control indicators, Hubei Academy of Environmental Sciences conducted supplementary monitoring tests on wastewater and noise indicators and PONY was commissioned for monitoring and testing air indicators (see Table 14 ), showing up-to-standard results in each indicator. 30 Table 14 Supplementary monitoring on pollutant discharge Audit item: Hubei Hengxin Pollutant No. of emission Limit of emission Emission Year Pollutants Monitoring values Source sources standards executed standards behavior Emission behavior of water pollutant CODcr 100mg/L 48-72 Pass GB8978-1996 Fluoride 10mg/L 7.00 Pass Integrated Water Main outfall Discharge Standard- pH 6~9 6.03-7.42 Pass (namely, Category I Monitored by Hubei Academy of May, 2016 sewage NH3-N 15mg/L 0.48-0.534 Pass Environmental Science treatment plant's outfall) DB42 / 168-1999 Chloride Discharge 300 mg/L for dry Chloride Standards for River season; 400 mg/L 154-283 Pass in Hubei for wet season Province-Category II Emission behavior of air pollutant Plant Concentration Pass Monitored by a commissioned boundary's limit of fugitive company—PONY (an Hydrogen fugitive emission in 0.017-0.028 environmental monitoring agency chloride emissions- GB16297-1996 monitoring point: recognized by environmental No.1 plant Integrated Emission 0.20 mg / m3; protection bureaus of Beijing, May, 2016 Plant Standard for Air Concentration Pass Dalian and Shenzhen. PONY is boundary's Pollutants limit of fugitive also on the list of socialized Hydrogen fugitive emission in - environmental monitoring agencies fluoride emissions- monitoring point: recognized by Hebei and Shandong No.2 plant 20 mg / m3; Province. In addition, PONY is 31 Audit item: Hubei Hengxin Pollutant No. of emission Limit of emission Emission Year Pollutants Monitoring values Source sources standards executed standards behavior 10.4-11.8 also recognized by environmental Coal: 200mg / m3; protection bureaus of Jiangsu and Dust Pass gas: 50 mg / m3 Guizhou Province as an environmental monitoring agency GB13271-2014 45-49 for oil and gas recovery Boiler's NOx Emission Standard of 400 mg / m3 Pass management projects. PONY is Air Pollutants for exhaust capable of providing professional Boilers-Class II funnel Coal: 900mg / m3; 6 water quality testing services. ) SO2 districts and II time Pass gas: 100 mg / m3 interval NOx 400 mg / m3 101-121 Pass 3 Coal: 900mg / m ; SO2 1-68 Pass gas: 100 mg / m3 Behavior of plant-boundary noise Monitoring Monitoring No. of noise Noise standard Year Monitoring values Behavior Monitoring Report No. points project standards executed limits Set 8 GB12348-2008 monitoring Standard for Noise at Day-time: 1#53.6； Continuous sites at 1m Boundary of Day-time: 65dB 2#52.7；3#51.9； 4#52.1； Monitored by Hubei Academy of May, 2016 A-weighted Pass away from the sound level Industrial (A); 5#57.9；6#55.7； 7#51.3； Environmental Science plant Enterprises-Category 4#57.7 boundary III 32 5. Control of total pollutant discharge According to the Letter on Environmental Impact Assessment Standards and Total Pollutant Discharge Control Indicators for the 30t/an Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd. (No. 35 [2007] of Yingcheng Municipal Environmental Protection Bureau) (Annex 4), the control indicators of total pollutant discharge are specified as shown in the table 15 below: Table 15 Control indicators of total pollutant discharge Types Control Expected Recommended control indicators of total factors total pollutant pollutant discharge and calculation method discharge Recommended Calculation method values Control CODcr 0.12 0.12 According to actual indicators of discharge volume total pollutant Ammonia 0.04 0.04 According to actual discharge in the nitrogen discharge volume 11th five-year Soot & dust 0.096 1.9 According to actual plan discharge volume by coal-fired boiler SO2 0.08 6.4 According to actual discharge volume by coal-fired boiler, given sulfur content is 0.8% Industrial 0 0 On the condition of solid wastes disposing of all solid wastes legally Specific Chloride 0.13 0.13 According to actual pollutants discharge volume Actual information about total pollutant discharge of the company is shown in the table 16 below. Table 16 Statistics of total discharge of pollutants in the project Type of Pollutant Total pollutant Specific pollutants Self-reduction pollutants production discharge Total discharge (unit: 10,000 0.2579 0 0.2579 m3/a) Wastewater CODcr (t/a) 0.642 0 0.642 NH3-H (t/a) 0.08 0 0.08 Chloride (t/a) 0.0302 0 0.0302 33 Fluoride (t/a) 0.009 0.008 0.001 Hydrogen 3030 2999.7 30.3 Industrial chloride (kg/a) production Hydrogen Exhaust gas 6540 6474.6 65.4 fluoride (kg/a) Soot & dust (t/a) 0.096 0 0.096 Boiler SO2 (t/a) 0.08 0 0.08 Hazardous wastes (t/a) 8 8 0 General industrial solid wastes Solid wastes 1.1 1.1 0 (t/a) Household refuse (t/a) 17 17 0 From the data in Table 16, it can be found that the total discharge of CODcr and ammonia nitrogen largely exceeds the limits. However, indicated from the data in Table 13-14, the concentration of CODcr and ammonia nitrogen in discharged wastewater does not exceed the limits. Basing on the audited water balance data of cleaner production, the reason behind the conflicting results may lie in concentration dilution due to overuse of domestic water and afforestation water of the enterprise (for details please refer to the audit of Cleaner Production). 6. Audit of Cleaner Production The project aims to promote cleaner production and Best Available Techniques / Best Environmental Practices (BAT/BEP) through demonstration and popularization. However, audit of cleaner production, which is usually based on material balance, especially water balance, has not been conducted currently. Thus, water balance analysis is conducted as the first move in the preparation stage. The water balance in production process is shown in Table 17 and Figure 11 and other water consumptions of this enterprise are listed in Table 18. Table17. Water balance in PFOSF production (Unit: t/a) Workshop Input Output Section Material name Amount Output name Amount Disposal Remanent To the next Fresh water 120 6 water reaction 1. Sulfonation Uncontrolled Vapour 114 discharge Water Remanent To the next step of introduced for 6 94.5 water stratification 2. Acylating sulfonation chlorination Fresh water 90 Water for To the intermediate -1.5 reactions product Water introduced for Lower layer 25 % HCl are 3. Stratification 94.5 103 acylating wastewater transferred chlorination 34 Workshop Input Output Section Material name Amount Output name Amount Disposal Fresh water Remanent To the next for spray 13 water 4.5 reaction washing Water Remanent To the next step of introduced for 4.5 water 94.5 4. Fluorination stratification stratification Fresh water 90 Mixing and transportation out Water Lower layer of wastewater introduced for 94.5 87 wastewater containing bromine fluorination 5. Stratification and wastewater containing HCl Vapour 3 Fugitive discharge Remanent To the next 4.5 water reaction Water Scrubbing 25 % HF are introduced for 4.5 26 wastewater transferred stratification Fresh water Washing Water treatment 6. Electrolysis 30 33 for cleaning wastewater station Fresh water Remanent Rectification for spray 26 1.5 water process washing Water Rectification Hazardous wastes 7.Rectification introduced for 1.5 1.5 residues transference electrolysis Total fresh Including annual water consumption of 300 tons for production, 30 tons water washing water, 13 tons HCl scrubbing water and 26 tons of HF scrubbing consumption in water, amounting to369 tons fresh water consumption per year in the production whole production process. process Notes: Water amount consumed in form of vapour include step1 and 5, amounting to 107 tons per year and water consumption for washing is 33 tons per year, using calcium hydroxide for wastewater neutralization sedimentation. Calcium fluoride generated in this process is to be delivered to hazardous wastes center for treatment. 35 120 Water Sulfuration reaction （24h, 80 oC） Distillation （6h, 100-120 oC） Drying Vapour 114 （14h, 120 oC） Recycling scrubbing water Water remained 6 13 90 Chloroformylation Fresh water Scrubbing and reaction recycling of （10h, 75 oC） spray tower Reaction consumption 1.5 Water-94.5 Water 90 Water 13 Water 103 25% Stratification Lower wastewater W1 hydrochloric （3-4h） acid Water remained 4.5 (Transference) 90 Fresh water Fluoridation reaction （80 oC 5-6h） Wastewater Water94.5 containing nickel 87 generated and Water87 Stratification Lower wastewater W2 mixed with HCI （4h） wastewater， Water7.5 Water3 transferred to Distillation Distillation residue HW11 Wuhan Mingxiu （4h, 120 C） o Recycling scrubbing water 26 26 25% hydrofluoric Hydrofluoric acid Scrubbing and recycling acid Electrolysis of spray tower (Transference) （50h, 13-18 oC） Water Washing （12h） Washing wastewater Front cut fraction, for deep Rectification residue Processing Rectification HW11 （100-110 oC） Products Figure11. Water balance of PFOSF (Unit: t/a) 36 Table17. Annual water consumption of Hubei Hengxin (Unit: t/a) Water supply（m3/a） Water consumption（m3/a） Water Water Sewag Clean consumption Total Circula Transfere Fresh consumption e water department water ting nce into water in form of dischar discharge supply water [1] others [1] vapour ge Circulating 108000 105840 2160 1080 0 0 1080 cooling water Circulating water for 720000 717840 2160 2160 0 0 0 refrigerator Production water supply 300 0 300 117[4] 180[5] 3[2] 0 [3] Cleaning water 30 0 30 0 30[2] 0 [3] HCl absorbing 13 0 13 0 13 0 0 water [3] HF absorbing 26 0 26 0 26 0 0 water[3] Water for 8730 0 8730 8730 0 0 0 afforestation Domestic 3001 0 3001 450 0 2551 0 water Water for 1800 1795 5 5 0 0 0 vacuum pump Boiler water 5100 0 5100 4600 0 0 500 Total 847000 825475 21525 17142 219 2584 1580 Notes: [1] Tonnage of water consumption in form of vapour and clean water drainage are estimates. [2] Total wastewater drainage is 33 tons per year, including 30-ton washing wastewater and 3-ton industrial wastewater. [3] Industrial water consumption includes water used for production, cleaning, HCl and HF absorption, of which details are listed in Table 17. [4] 114 tons dry vapour for sulfonation per year and 3 tons dry vapour for fluorination per year are included in water consumption in terms of vapour (1). [5] Consumption of water transferred into other forms includes 87-ton wastewater containing bromine generated out of stratification during the fluorination process per year. This wastewater is mixed with HCl wastewater generated from acylating chlorination before being transferred out. In addition, 90-ton water consumed in stratification during acylating chlorination per year and 3-ton water consumed in washing process per year, during which waste hydrochloric acids are generated, are also included. As shown in Table 18, total annual water consumption of this enterprise is 84700 tons, including 825475 tons recirculating water per year. It can be found that the consumption of fresh water is 21525 tons per year. Audit analysis is as follows: 37 (1) Circulating water consumption is 829800 tons per year, including 1800-ton water for vacuum pump per year, 720000-ton circulating water for refrigerator per year and 108000-ton circulating cooling water per year. 4325 tons of fresh water needs to be replenished annually as circulating water, with a water recycling efficiency of 99.5 % which is very close to 100 % water recycling efficiency standard of cleaner production. In the meantime, 21,525 tons fresh water are required annually, including 369 tons fresh water consumed during the whole production process, 3001 tons domestic water, 8730 tons water for afforestation and 5100 tons water for boiler. (2) 3001-ton domestic water and 8730-ton water for afforestation are consumed annually in form of fresh water, accounting for 54.5% of the total annual fresh water consumption. It can be found that the water consumption volume is too large. a) According to the standards set forth in the Code for Urban Water Supply Engineering Planning GB 50282-98 (Table 2.2.3-4), water consumption standard for afforestation is 1000~3000 tons/km2/d. With green space of 5820.0m2 and working hours of 278 days in Hengxin, the annual water limit for afforestation is in the range between 1617.96 tons and 4853.88 tons. Accordingly, water for afforestation in Hengxin obviously exceeds the standard of GB 50282-98 by 2-5 times. b) According to the standards set forth in the Code for Urban Water Supply Engineering Planning GB 50282-98 (Table 2.2.4, the districts in small cities), domestic water consumption is 190-350 L per people per day. Basing on the reality that there are 78 employees working 278 days per year in Hengxin, standardized annual domestic water consumption is 4119.96-7589.4 tons per year. Thus, domestic water consumption of this plant is within the limits. c) Basing on the facts above, on one hand, a scientific water-saving method can be adopted in landscape administration to keep water consumption for afforestation within limits. On the other hand, afforestation water of the enterprise needs to be managed strictly to deal with the problem that the total discharge volume of CODcr and ammonia nitrogen has exceeded the control indicator. With regard to the controversial result that the discharge concentration of CODcr and ammonia nitrogen has not exceeded the limits, the reason may lie in the dilution effects generated by huge afforestation water consumption. To cope with this challenge, the enterprise may take measure to regulate the irrigation period, volume and coverage of afforestation and check the condition of water pipes of afforestation regularly to avoid water wastes. In addition, rain water and domestic wastewater can be collected to be used for afforestation since the annual precipitation in local place is high. (3) 5100 tons of water is consumed annually for boilers, including 4600 tons of water being discharged into the air in form of vapour. However, boilers of this enterprise are in small sizes and used in a discontinuous mode. Heat and pressure of vapour decrease after going through the reducing valve and the reaction of heat exchange, result in difficulty of being used in electricity generation. Water consumption in form 38 of vapour in sulfonation process is also tremendous, with an annual volume of 114 tons. Thus, it is recommended to take effective measures to make use of heat energy of vapour for the heating of this enterprise to reduce direct loss of water in form of vapour and thus to achieve the objective of water saving. (4) Water consumptions for hydrogen chloride and hydrogen fluoride absorption are 103 tons and 26 tons per year respectively, generating acid solution in high concentration. Besides, 87 tons of wastewater containing bromine per year generated in fluorination process is to be mixed with HCl wastewater. Acid solution abovementioned can be sold to other companies as useful chemical materials to realize cleaner production. (5) The volume of wastewater generated is not large, consuming 30 tons washing water per year. (6) Water used in the whole production process of this enterprise annually is 369 tons (including waste scrubbing water) and 1 ton products consume 12.3 tons water. Water consumption details of each production process are listed in Table 11 and Figure 11. There are 8 domestic enterprises providing products similar to Hengxin Chemical Co., Ltd. As the largest enterprise with most product categories and the highest production value among PFOS/PFOSF producers, there is no statistical data concerning the average unit water consumption of Hengxin Chemical Co., Ltd, making it impossible to make horizontal comparisons. 39 7. Prevention and control of dangerous chemicals and registration of prohibited substances and new chemicals According to the Classification and Labels of Dangerous Chemical Substances Commonly Used (GTB13690), the chemical raw & auxiliary materials and intermediate products used in production by the company contain flammable liquids, flammable gases, non-flammable gases, flammable objects when wet, spontaneous combustible articles (corrosives) and poisonous substances. These are potential hazards in this project. The risks of the goods and materials used in this project are identified according to the Catalog of Hazardous Chemicals (2002), the Directory of Highly Toxic Chemicals and relevant references. Raw & auxiliary materials, intermediate products and byproducts used or produced in this project are shown in Table 19. Among the raw & auxiliary materials, intermediate products and dangerous chemicals involved in the proposed project, there are 8 dangerous chemicals and 1 highly toxic chemical. More details are provided in Table 18. Table 19 List of Major Dangerous Chemicals Used Highly toxic No. Goods & materials Usage Dangerous chemicals or not? chemicals or not? Yes, among Class 3.2: 1 Bromooctane Raw material No Flammable Liquids (flash) 2 Sodium sulfite Raw material No No Phosphorus Yes, among Class 8.1: 3 Raw material Yes oxychloride Acidic Corrosives Yes, among Class 6.1: Toxic 4 Potassium fluoride Raw material No Substances Sodium octyl Intermediate 5 No No sulfonate products Chlorine octyl Intermediate 6 No No chloride products Yes, among Class 2.1: 7 Hydrogen Exhaust gas No\ Flammable Gases Recycled Yes, among Class 8.1: 8 Hydrogen fluoride No product Acidic Corrosives Raw materials Yes, among Class 8.1: 9 Hydrofluoric acid No and byproducts Acidic Corrosives Perfluoroalkanesulf 10 Product No No onyl Fluorides Product in Yes, among Class 8.1: 11 Hydrogen bromide No accident Acidic Corrosives Yes, among Class 8.1: 12 Hydrogen chloride Byproducts No Acidic Corrosives 40 Although warehousing of toxic chemicals is managed by the company, some toxic or hazardous raw materials and some polluted packaging containers are stored in open warehouse. Warehouse of raw & auxiliary materials does not match the requirements, there is no leakage alarm system, no isolation facilities and no fire/explosion prevention measures at storage site, classified storage and management of dangerous chemicals is not provided, and no qualified organization is entrusted to handle and transport toxic chemicals. In addition, the company formulated emergency response plan in case of accidents and major hazards and there are records of emergency rescue drills, but these were not reported to competent authority for the record and the frequency of drills does not meet the requirements. Therefore, this enterprise needs to formulate and supervise the implementation of Environmental Management Plan. Figure 12 Photos of raw materials storage site 8. Disposal of hazardous wastes and industrial solid wastes Solid wastes generated by the project contain household refuses, CaF2 residues and distillation residues which includes those produced after fluorination and those produced after electrolysis. Household refuses are collected uniformly by the sanitation department and disposed by Yingcheng refuse treatment station for landfilling. Distillation residues and CaF2 residues are transported to Yichang Hazardous Wastes Treatment Center. However, a large amount of calcium fluoride sludge is stacked in the waste water processing station in this plant, failing to meet with relevant standards. 41 Recycling and disposal of industrial and dangerous wastes are listed in Table 20. Refer to Annexes 6-1 to 6-4 for waste disposal contracts and documents, Annex 7-5 for extracts of Register of Hazardous Wastes in Storage, and Annexes 6-6 to 6-8 for qualifications for disposal of hazardous chemicals. In addition, the company has improved the hazardous wastes management system and measures (see Annex 7-3). Table 20 Comprehensive utilization and disposal of industrial solid wastes and hazardous wastes Output utilizati disposal Titles Year (t/a) on(t/a) (t/a) Recycling implementation 2013 5 5 Cut fraction is transferred after the acylating chlorination and before the distillation process; 2014 2.8 2.8 front cut fraction generated out of the Distill distillation before the electrolysis process are ation sold as byproducts after deep processing. residue 2015 12 12 Currently, the said front cut fraction is transferred to Yichang concentrated hazardous wastes treatment center after being stacked in the yard of hazardous wastes temporarily 2013 1 1 Basing on the requirements specified by the environmental protection agency, CaF2 residues 2014 0.7 0.7 with category code of HW49 are transferred to the Yichang concentrated hazardous wastes treatment center for treatment and there are no CaF2 signs of landfilling. Besides, there are still 40 2015 1.2 1.2 tons of CaF2 having not been transferred due to the denial of Yichang concentrated hazardous wastes treatment center. Currently, Yingcheng environmental protection agency is trying to find a solution for this problem. Recycl 2013 25 25 Some potassium hydroxide and potassium ed HF fluoride are used by this enterprise and some 2014 28 28 （25% are neutralized by lime into calcium fluoride acid 2015 32 32 wastes. Remaining waste acids are transferred water） to Wuhan Mingxiufeng Limited Company Recycl 2013 180 180 Waste acids are transferred to Wuhan ed HCl 2014 Mingxiufeng Limited Liability Company (there 198 198 is barely any charge for this basing on the （25% feedback of this enterprise and thus water acid 2015 228 228 consumption of hydrogen chloride and water） hydrogen fluoride acid are estimates). House 2013 15 15 Collected uniformly by the sanitation hold 2014 14 14 department and disposed by Yingcheng refuse refuse 2015 17 17 treatment station for treatment regularly. At present, the company has some problems in the aspect of industrial solid wastes and hazardous wastes, e.g. improper storage of settling CaF2 sludge for wastewater treatment, which doesn’t meet the requirements for disposal of hazardous wastes. 42 Figure 13 Photos of hazardous wastes storage site 9. Implementation of ecological protection measures When implementing environmental protection audits against enterprises (relevant to energy, mineral resources mining, forestry-paper integration etc.), the implementation of ecological protection measures needs to be specified. Hubei Hengxin Chemical Co., Ltd. is located in the industrial park of Yingcheng City, without involvement of exploitation and destruction of the ecological environment. Therefore, there is no need to audit the implementation of ecological protection measures. 10. Project impact on environmental sensitive areas including drinking water source protection area Yingcheng city has abundant water resources including rivers, ports, reservoirs (mainly in the southwest), lakes (mainly in the south) and ponds, and most of its 43 terrain is made up of plain, hillock and water. The water area amounts to 118km 2, accounting for 10.7% of the city's total area. Surface water mainly comes from the runoff water formed from foreign water and rainwater and the lakes. In the territory of this city, there are four major rivers, namely Yun River, Zhang River, Dafu River and Hanbei River, all of which flowed into Han River, a tributary of Yangtze River. In 1959, Yun River was rectified and became a direct feeder to Yangtze River without flowing through Han River. After Hanbei River was excavated in 1969, Dafu River began to flow into Hanbei River, finally to Han River. Dafu River has a length of 65km in the territory of this city, it collects water from an area of 384km 2 surrounding it, and its water capacity in the territory of this city amounts to 3.112 billion m3. Yingcheng city also has 14 streams longer than 5km, with a total length of 201km.There were 21 lakes in the southeast of this city, covering an area of about 285,000mu (190km2), of which three large lakes named Dongxicha, Longsai and Laoguan cover an area of 64,500mu (43km2). There are no large lakes in urban area and there are a dozen of small ponds in the industrial park. In this city, there are 2 medium-sized reservoirs, 17 small-sized class-I reservoirs and 69 small-sized class-II reservoirs, with total water capacity of 137.525 million m3, collecting rainwater from an area of 498.76km2 surrounding them, having a channel density of 0.29km/km2. In normal conditions, Yingcheng city has a water production of 483 million m3, the annual precipitation amounts to 1.197 billion m3, total surface runoff water amounts to 383 million m3, all rivers and canals have a total length of 589km, water storage and diversion amounts to 78.6 million km2. Shenggang River has its source in Sanlianwan, Jingshan County, flows into Yanghe Town of Yingcheng City, then goes through Zhaojiayan (Yanghe Town), Duangang, Moyushan (Chengbei subdistrict), Changhu (Chengzhong subdistrict), Liuyang (Silipeng subdistrict) and Chenta (the Development Zone), then feeds into Laoxian River at Xiangshuiqiao, divides in two after that, one flowing into Dafu River through Henghe sluice and the other flowing into Jiahe canal through Yujia sluice and finally into Hanbei River. Salt River is a section of Shenggang River, from the original railway bridge to the new railway bridge with a total length of 2km. It is named for the fact that it is heavily polluted by salt & chemical industry. In addition, Hubei Hengxin Chemical Co., Ltd. is located in Guanghui Village, Silipeng District. Underground water within this region is low in flow velocity and takes calcium magnesium carbonate as its chemical type, being non-erosive to concrete. The calcium fluoride sludge has been disposed and transferred as hazardous wastes in 2013, which is appropriate and will not pollute underground water. 11. Environmental safety hazards, emergency response plans 11.1 Environmental safety hazards In chemical production, many of raw materials, intermediate products and finished products are flammable, explosive or toxic substances. Chemical industry is highly susceptible to serious accidents. So, it's very important to identify the fire and explosion hazards in chemical production process. Among raw materials used, the bromooctane is a flammable substance (flashpoint 44 23°C) in intermediate flashpoint group. It is very reactive and may easily react with air, causing fires and explosions. Other raw materials are incombustible or nonflammable substances. In addition, hydrofluoric acid and phosphorus oxychloride are acidic corrosives. Phosphorus oxychloride decomposes rapidly when meeting water to produce a great quantity of heat and dense smoke, which may cause explosion, and it also decomposes when meeting water vapor to release phosphoric acid, hydrogen chloride and other irritant gases which cause human poisoning. Hydrofluoric acid is a corrosive substance presenting strong acidic property, which reacts with most of metals to produce hydrogen, an explosive gas, forms explosive mixture when mixed with air, explodes when exposed to heat or meeting open flame, and burns immediately when meeting H blowing agent. Hydrofluoric acid is very corrosive and may damage human skin, equipment and buildings. Table 21 List of Major Dangerous Chemicals Used Highly toxic Quantity in Goods & Dangerous chemicals Storage No. Usage chemicals or storage materials or not? method not? (t/a) Yes, among Class Raw 1 Bromooctane 3.2: Flammable No 8 Iron bucket material Liquids (flash) Yes, among Class Phosphorus Raw Plastic 2 8.1: Acidic Yes 50 oxychloride material bucket Corrosives Potassium Raw Yes, among Class 3 No 2 Steel jar fluoride material 6.1: Toxic Substances Yes, among Class Hydrogen Recycled 4 8.1: Acidic No 100 Plastic Bag fluoride product Corrosives Figure 14 Photo of emergency pond 45 Consequently, safe production awareness must be raised and fire and explosion prevention and control must be strengthened to lower and eliminate the risks of fire and explosion. Currently, the company has developed emergency response plan to take the measures in the plan in case of an accident to effectively reduce the impact on surrounding environment. However, the company shall add more risk prevention measures. Please refer to the Environmental Management Plan for details. 11.2 Emergency response plan The company has developed emergency response plans for environmental accidents (see Annex 7-1 to Annex 7-4), including Environmental Hazard Prevention Measures and Emergency Response Plan, Emergency Rescue Plan for Work Safety Accidents, Implementation of Standardized Management of Hazardous Wastes, Enterprise Work Safety Standardization Log I: Persons-in-charge and Responsibilities, Enterprise Work Safety Standardization Log II: Risk Management, Enterprise Work Safety Standardization Log III: Laws, Regulations and Management Provisions, Enterprise Work Safety Standardization Log IV: Safety Training and Education, Enterprise Work Safety Standardization Log V: Production Equipment, Enterprise Work Safety Standardization Log VI: Work Safety, Standardization Log VII: Product Safety and Hazard Announcement, Standardization Log VIII: Occupational Hazards, Log IX: Accidents and Emergency Responses, Log X: Inspections and Performance Appraisal. Up to now, there is no significant environmental risk accident occurring to this enterprise. Implementations of measures of environmental risks are listed in the table. This report here presents a few review comments on these plans: (1) The emergency response plans developed by the company only specify the measures to be taken in case of leakage of dangerous chemicals, but not include the accidents that may occur during production and the measures to be taken; (2) The emergency response plans developed by the company only stipulates the rescue measures to be taken in case of an accident, but not include preventive measures during storage and transportation of dangerous chemicals. (3) The emergency response plans developed by the company fail to well define what should be done and by whom when an accident occurs. (4) More emergency drills shall be carried out and the drill information shall be submitted to relevant departments for the record (Annex 7-5: Photos of emergency drills), including information of occurrence of significant environmental risk accidents such as fire in warehouse etc. 11.3 Environmental accidents and the handling information We conducted a site survey and found that the company received no administrative penalties for environmental affairs, had no major or extraordinarily serious environmental pollution accident, received no environmental appeals by letter or visit, and had no other acts in violation of environmental protection laws and regulations in the proposed period. 46 Table 22 Environmental hazard and prevention measures sources Enviro risks Recommended measures of EIA Actual implementation Audit opinions Productio Fires and Implementations of automatic Implemented Reasonable n explosions of control, monitoring alarm and equipment interlock protection of accidents in process system need to be enhanced. Sophisticated DCS controlling DCS controlling system DCS controlling system needs to be implemented. system and interlock protection has not been system need to be implemented in implemented the safety control system, including the function of alarming, stops of vehicle and accident handling. Emergency An emergency pond of 250m³ needs Constructed Reasonable measures of fires to be installed for fire protection. and explosions of equipment Leakage of Preservation and maintenance need Implemented Registration of periodical check of leakage has not been reaction solution to be made for system equipment done, which needs to be improved. in equipment and sealed units. Leakage of HF Two-circuit design needs to be Two-circuit system has Two-circuit system needs to be developed to avoid HF gas in equipment adopted to avoid risks of HF leakage not been constructed. leakage. caused by unexpected brakes of vehicles. Management Operational regulations, on-the-job Implemented Standardization of management needs to be enhanced and negligence training and professional education risk management records need to be kept. need to enhanced and regulated strictly. Storage Fire and explosion Different dangerous chemicals need Interval distance of Restricted by the limited plant area, Hengxin is incapable of caused by to be separately stored with an dangerous chemicals is maintaining an interval distance of 50m. Risks exist in the inappropriate interval distance of over 50 m. shorter than 50m. storage of dangerous chemicals and cofferdfeel needs to be design of Cofferdfeel needs to be set up Cofferdfeel is not installed. chemical independently, too. available. 47 sources Enviro risks Recommended measures of EIA Actual implementation Audit opinions warehouse Fire and explosion Complete fire protection system Fire protection system is Warehouse classification needs to be done as required, caused by needs to be set up and periodical set up while check corresponding check frequency needs to be determined and inappropriate check of chemical warehouse needs records are not preserved check records need to be preserved. management of to be made. standardly. warehouse equipment Oil spillage None Requirements in audit Fire dike needs to be installed, drain valves and pipes be opinions need to be settled strictly as required by the design regulations. supplemented. Materials for purpose of preventing oil penetration and diffusion need to be paved on the surface of oil depot. Fire and explosion Kept in a shady, cool and ventilated Chemicals are stored in a Storage volume under high temperatures needs to be caused by lack of place, far away from fire and heat shady, cool and controlled at reasonable level to keep high temperature risks proper fire sources sources. Temperature of warehouse ventilated place. within limit, as the temperature of Hubei Province in management shall not exceed 30 degree centig. Summer is usually over 30 degrees centigrade. measures for fire An emergency pond of 250m³ needs Constructed Reasonable and explosion of to be installed for fire protection. warehouse Transport Transportation of dangerous Adopted Risk prevention manuals for the storage and transportation ation chemicals is in the charge of need to be supplemented, enhanced and regulated. The suppliers and associated risks and packaging of chemicals since the beginning of shipment accidents are born by suppliers or needs to be complete and the loading operation needs to be transportation companies. stable and safe. Emergency leakage treatment equipment needs to be available for vehicles during the transportation. Vehicles need to follow regulated routes and shall not stay in residential and populated regions. Wastewat Invalidity of An emergency pond of at least 22 m³ Constructed Reasonable er wastewater needs to be installed treatment treatment stations 48 12. Corporate environmental management In respect of corporate environmental management, Hubei Hengxin Chemical Co., Ltd. adopts general manager responsibility system and sets the Safety and Environmental Protection Department which will take charge of all environmental work, including environmental impact assessment of construction projects and the acceptance inspection of supporting environmental protection facilities (designed, constructed and put into operation simultaneously with the construction project), operation of environmental protection facilities, environmental monitoring, handling of environmental pollution accidents, and assisting local environmental protection authority in environmental law enforcement. According to our site survey, Hubei Hengxin Chemical Co., Ltd. has established a sound environmental management system and a sound environmental filing system, as shown in Table 23 and Table 24. The company's environmental management organization is shown in Figure 15. Table 23 Environmental Management System Environmenta Environmental Company Environmental Environmental l management management Name management personnel monitoring station department regulations General manager:1, Supervisory Safety and deputy manager for monitoring by Hubei Hengxin Environmental environmental protection: Yingcheng Chemical Co., No Protection 1, Safety and Municipal Ltd. Department Environmental Protection Environmental Department staff: 3 Monitoring Center Table 24 List of Environmental Files of Hubei Hengxin Chemical Co., Ltd. No. Title Date Remarks The EIR Form (environmental impact report form) and its reply as well as the reply 1 concerning acceptance inspection for organic 2004.2 H.Y. [2015] No. B01 silicon and organic fluorine products project of Hubei Hengxin Chemical Co., Ltd. The retrospective evaluation report and its reply as well as the reply concerning acceptance X.H.H. [2008] No.19 2 inspection for the 30t/an Organic Fluorine 2008.3 X.H.H. [2009] No. 34 Products Project of Hubei Hengxin Chemical Co., Ltd. Pollutant Discharge Permit for the period from Yingcheng Municipal 2012.4, 3 April 16, 2012 - April 15, 2015 and for the Environmental Protection 2015.4 period from April 16, 2015 to April 15, 2016 Bureau Yingcheng Municipal Payment notice and invoices for pollutant 4 2013-2015 Environmental Protection discharge Bureau Monthly pollutant discharge declaration form of Hubei Hengxin Chemical 5 2011 Shenzhen Gelinmei Company Co., Ltd. Yingcheng Municipal 6 6 monitoring reports 2013-2015 Environmental Monitoring 49 No. Title Date Remarks Station Environmental Hazard Prevention Measures and Hubei Hengxin Chemical 7 2011 Emergency Response Plan Co., Ltd. Implementation of Standardized Management of Hubei Hengxin Chemical 8 2015 Hazardous Wastes Co., Ltd. Emergency Rescue Plan for Work Safety Hubei Hengxin Chemical 9 2011 Accidents Co., Ltd. 10 Enterprise Work Safety Standardization Log Hubei Hengxin Chemical 10 2011 Books Co., Ltd. 11 Dangerous Goods Transportation Contract 12 Industrial Wastes Disposal Contract Permit for collecting hazardous wastes of Hubei 13 province Yingcheng Municipal Environmental Protection Top environmental Bureau management Departments and General Manager divisions to carry out environmental protection measures Other deputy managers Deputy manager in charge of environmental protection Functional departments Safety & Environmental and divisions Protection Department Monitoring and review Workshops Monitoring Monitoring and review Information feedback Posts Figure 15 Organization Chart of Hubei Hengxin Chemical Co., Ltd. 50 13. Disclosure of environmental information In accordance with Measures for Administration of Environmental Information Disclosure, Hubei Hengxin Chemical Co., Ltd. has the obligation of disclosing the environmental information. Disclosure of environmental information of Hubei Hengxin upon investigation is shown in Table 25, Figure 16-17. And disclosure of environmental information before PFOS project was not done. Therefore, the company is obliged to disclose environmental information according to the regulations in the future and perform its obligations and liabilities for environmental protection. Table 25 Disclosure of environmental information of Hubei Hengxin Disclosure Media Information disclosed Website Annex time Announcement on Annex 9-1 Environmental Auditing http://www.mepf Report of Hubei eco.org.cn/dtxx/t Governmenta Hengxin Chemical Co., June 30, 2016 zgg/201606/t201 l website Ltd. - GEF-funded 60630_68020.ht Project for Phase-out of ml PFOS-related Industries in China Announcement on Annex 9-2 Environmental Auditing Report of Hubei http://www.fluori Enterprise Hengxin Chemical Co., June 30, 2016 de-cn.com/news_ website Ltd. of GEF-funded detail/id/14.html Project for Phase-out of PFOS-related Industries in China Environmental http://www.hbaes Annex 9-3 Website of Management .com/newsView. Hubei Framework of do;jsessionid=FB Academy of July 1, 2016 GEF-funded Project for 9C63C6334B02F Environment Phase-out of ECAD386B09D al Science PFOS-related Industries DE9658?infoId= in China 2010 Announcement on Annex 9-4 Website of Environmental http://report.hbep Department Management b.gov.cn:8080/pu of Framework of b/root8/tjgzs/gtf Environment July 4, 2016 GEF-funded Project for wgl/201607/t201 al Protection Phase-out of 60704_96104.ht of Hubei PFOS-related Industries ml Province in China Environmental Auditing Annex 9-5 Yingcheng Report of Hubei http://www.hbyc Municipal Hengxin Chemical Co., August 3, epb.gov.cn/html/ Environment Ltd. of GEF-funded 2016 2016/0803/891.ht al Protection Project for Phase-out of ml Bureau PFOS-related Industries in China 51 Figure 16 Web Page Screenshot of Information Publicity of Yingcheng Environmental Protection Bureau Figure 18 Photo of the meeting of Hubei Hengxin Chemical Co., Ltd. 52 Web Page Screenshot of Environmental Information Publicity of Hubei Hengxin Chemical Co., Ltd. Meanwhile, public consultation with the in-service employees and residents of the surrounding areas has been implemented through discussion meeting and questionnaire during the disclosure period. On the one hand, a discussion meeting on the project was held in the meeting room of Hubei Hengxin Chemical Co., Ltd. on August 10, 2016 and 35 people (refer to figure 16 and for details on attendants, refer to attachment 10-1) have participated in the meeting. The meeting procedures are as follows: General Manager of Hubei Hengxin Chemical Co., Ltd., Li Shutao, first made brief introduction; then Doctor Li Yu from Hubei Academy of Environmental Science explained the PFOS project and the environmental issues that may occur in the implementation of the project by Hubei Hengxin, distributed questionnaire and solicited opinions from the attendants. On the other hand, questionnaires were distributed to the residents of the surrounding areas and altogether 86 questionnaires were returned. The introduction to the project and main contents of the questionnaires are shown in annex 10-2. The feedback is shown as follows: 53 Figure 17 Web page screenshot of Environmental Information Publicity of Hubei Hengxin Chemical Co., Ltd from Foreign Economic Cooperation Office of Ministry of Environment (1) Discussion meeting At the discussion meeting, the attendants mainly asked about what the persistent organic pollutant is, the impact on PFOS phase-out exerted by production change and whether the living of the residents will be affected, and hoped that Hubei Hengxin Chemical Co., Ltd. will strength the safety management. (2) Summary of the questionnaire (86) By issuing the questionnaires of Hubei Hengxin Chemical Co., Ltd., A total of issuing questionnaires is 86, and the answer summary is shown in Figure 19 and Table 26. Meanwhile, the people education degree, age, occupation and gender distribution of the questionnaire is shown in table 27. 54 Table 26 The Summary of the questionnaire Questions Answer 1 Answer 2 Answer 3 Answer 4 Answer 5 Do you know 20 people 25 answered 41 answered about persistent answered know a little no（48%） organic pollutants yes（23%） （29%） PFOS Do you know 49 people 19 answered 18 answered about Hubei answered know a little no（21%） Hengxin yes（57%） （22%） Chemical Co., Ltd. Are you content 28 people 44 answered 14 answered with the answered basically not quite environment of yes（33%） content content your current （51%） （16%） residents What, do you 6 people 1 thought it 25 thought 10 thought other 44 think, are the thought it is is gas it is noise it is chose principal waste water pollution pollution deterioration “know environmental pollution （1%） （29%） of little about problems （70%） ecological it”（51%） environment （12%） What is the 40 people 37 answered other 9 did degree of impact answered no impact not select on environment fair（47%） （43%） any option of the （10%） surrounding areas exerted by Hubei Hengxin Chemical Co., Ltd. What, do you 5 people 1 answered 10 answered 18 answered 52 think, are the answered waste water noise noise expressed environmental waste gas pollution pollution pollution “know impact after pollution （1%） （12%） （21%） little about Hubei Hengxin （6%） it”（60%） Chemical Co, Ltd. carry out PFOS phase-out through production change Whether, do you 5 people 15 people 66 answered think, the PFOS answered answered “no impact” phase-out by “have “the impact （77%） Hubei Hengxin relatively degree is Chemical Co., greater fair”（17%） Ltd. will impacts” influence your （6%） working and life What, do you 10 answered 11 answered 2 answered 63 answered think, are the “positive “tolerable “intolerable “no impact” 55 Questions Answer 1 Answer 2 Answer 3 Answer 4 Answer 5 impacts on local impact” adverse adverse （73%） economic and （12%） impact” impact” social （13%） （2%） development exerted by PFOS phase-out by Hubei Hengxin Chemical Co., Ltd. What, do you 16 answered 10 answered 2 answered 58 answered think, are the “positive “tolerable “intolerable “no impact” impacts on your impact” adverse adverse （67%） working, life and （19%） impact” impact” economic income （12%） （2%） exerted by PFOS phase-out by Hubei Hengxin Chemical Co., Ltd. What is your 18 28 5 expressed other 35 attitude towards expressed expressed “disagree” expressed PFOS phase-out “in favor of “acceptable” （6%） “indifferent by Hubei it”（21%） （33%） to it” （41%） Hengxin Chemical Co., Ltd. What are your no answer opinions and was gained suggestions on （100%） PFOS phase-out by Hubei Hengxin Chemical Co., Ltd. Table 27 The education degree, age, occupation and gender distribution characteristics of the participants of public consultation Senior Technical Primary Junior high Junior Universit high secondary school school college y school school Education 4（7%） 58（67%） 9（10%） 8（9%） 3（3%） 4（5%） degree 20-30 30-40 40-50 50-60 60-70 Age 3（3%） 19（22%） 35（41%） 21（24%） 8（9%） financial Farmer Worker Teacher affairs Occupation 49（57%） 31（36%） 4（5%） 2（2%） Male Female Gender 50（58%） 36（42%） 56 In conclusion, the results of public consultation show that 79% of the participants have some knowledge of Hubei Hengxin Chemical Co., Ltd., 84% of them are basically content with the surrounding environment. As for PFOS phase-out, 94% of the participants think it exerts not so much impacts on their working and life and less than 6% of them disagree with PFOS phase-out. Therefore, most of the public have no objection to PFOS phase-out of Hubei Hengxin Chemical Co., Ltd. Figure 19 Questionnaire of Public Consultation of Hubei Hengxin Chemical Co., Ltd. （Figure 19-1） 57 Figure 19 Questionnaire of Public Consultation of Hubei Hengxin Chemical Co., Ltd. （Figure 19-2） 58 Chapter 5 Environmental management plan Upon audit, Hubei Hengxin Chemical Co., Ltd. is found to have many problems. Here are some improvement suggestions, namely environmental management plan. Hubei Hengxin Chemical Co., Ltd. should implement this plan to make it comply with relevant standard and environmental protection requirements. 1．Setup of environmental management organization In accordance with actual conditions of the company, safety and environmental protection department is to be set. The department is responsible for safety and environmental protection of the whole company under leadership of the company leaders. The management organs are shown in figure 15. The specific duties of environmental management organs of the departments and units to carry out environmental protection measures are: 1) Setting up sound environmental protection rules and regulations and clearly defining the accountability and awarding and punishment methods. 2) Determining the environmental management goal, such as, emission or discharge of gas, water and noise as per standard, realization of greening indicators and timely treatment of solid wastes and so on. 3) Setting up environmental protection files, such as environmental impact assessment report, environmental protection project acceptance report, pollutant source monitoring report, records of environmental protection equipment and the operation and other environmental statistics and so on. 4) Collecting and managing relevant pollutants discharge standard, environmental protection rules and regulations, technical data on environmental protection and implementing the environmental protection regulations and standards. 5) Well implementing “simultaneous design, construction and operation” of environmental protection with the construction project; supervising and evaluating the environmental protection work of various departments during the operation period of the project. 6) Prevention and control of gas, waste water and solid wastes pollution is one of important aspects of environmental protection and the normal operation of pollution prevention facilities should be guaranteed through environmental management measures. Managing all of the environmental protection facilities and main equipment in a coordinated way and realizing the simultaneous operation and repair of the environmental protection facilities and main equipment; when failure of the environmental protection facilities occur, the environmental management organ should immediately take joint measures with various departments to prevent and control the pollution. 7) Understanding the pollutants discharge of the whole site, setting up pollutant sources files and carrying out environmental protection statistics and well controlling the total discharge of pollutants. 8) Responsible for treatment of general pollution accidents. 59 9) Setting up and implementing ISO14001 environmental management system when the conditions permit. 10) Performing the obligation of disclosure of enterprise environmental information according to requirements. 2．Mitigation measures Aiming at the evaluated adverse environmental impacts, the specific and operable mitigation measures (refer to Table 26) on operation period of Hubei Hengxin Chemical Co., Ltd. are brought up in accordance with relevant domestic regulations, norms and management measures and experiences of previous similar projects and with reference to the Environmental, Health, and Safety Guidelines (EHS Guidelines). The implementer is the company and the supervisor is the local PMO. The budget should be determined with reference to the production change plan of Hubei Hengxin Chemical Co., Ltd. and the cost should be borne by the company and GEF. 3. Monitoring plan The exhaust gas monitoring sites, indicators and frequency are shown in Table 26. Table 26 Exhaust gas monitoring plan Monitoring Monitoring Pollution Monitoring No. Monitoring sites Workshop indicators frequency sources agency Exhaust Plant boundary First Monitor gas of acyl 1 (Fugitive emissions HCl workshop once every chloride monitoring site) Yingcheng quarter, process s Environme Plant boundary and each Exhaust Second ntal 2 (Fugitive emissions HF sample gas of workshop Monitoring monitoring site) should be electrolysis Center no less than Exhaust Boiler Dust, SO2, 3 No.3 exhaust funnel 3 feet gas of room NOx boiler The waste water monitoring sites, indicators and frequency are shown in Table 27. 60 Table 26 Environmental problems, risks and mitigation measures Environmental Problems and risks Mitigation/prevention and control measures medium Strengthen management over harmful raw and auxiliary materials, poisonous chemicals and dangerous wastes, store and manage the dangerous chemicals in a classified way, entrust the departments with qualification to load, unload and transport the poisonous chemicals, install leakage alarming device and Non-standardized storage of isolation devices in the storing site, take explosion and fire prevention measures, set up sound management industrial solid wastes and system and facilities and implement the management measures. dangerous wastes Set up impermeable isolated areas in the storing site, strictly separate the dangerous wastes from other solid wastes; implement classified storage of other solid wastes and prohibit mixing with dangerous wastes and domestic wastes. Set alarm signs and environmental protection image icons according to GB15562.2. To prevent entry of runoff into the storing site and avoid increase of leachate, diversion devices should be set Leakage and soaking of solid around the storing site and leachate catchment and drainage facilities and leakage blocking and sealing skirt wastes should be designed. Solid wastes The caught leachate and leakage should be discharged upon treatment of the sewage treatment station. The ground and skirt should be made of solid and anti-leakage materials. Hidden dangers in transportation Entrust the departments with qualification toe load, unload and transport, formulate the emergency plan of of solid and dangerous wastes of risk prevention in the transportation process. the company Calcium fluoride sludge is dangerous inorganic fluoride wastes. In accordance with requirements of the environmental protection bureau, HW49 (category code of CaF2) are transferred to Yichang Hazardous Waste Disposal Center for treatment and should not be buried. In addition, about 40 tons calcium fluoride Treatment of CaF2 are still in the plant and was not transferred, because Yichang Hazardous Waste Disposal Center can’t accept any more. Currently, Yingcheng Municipal Environmental Protection Bureau is finding solutions. Meanwhile, the temporary storage site of calcium fluoride should be standardized and cofferdam should be set to avoid its contact with concentrated acid. 61 Environmental Problems and risks Mitigation/prevention and control measures medium The company uses fresh water of 8730 m3/a for greening and fresh water of 3001 m3/a for living. The total consumption accounts for 54.5% of the total fresh water consumption. Therefore, scientific water saving methods can be used for greening. In addition, the total emission of CODcr and ammonia nitrogen exceeds Discharge of domestic sewer the standard but the concentration does not exceed the standard. This may be caused by dilution of hugely consumed water. Therefore, water consumption for greening and living should be strictly managed to realize water saving. When the domestic sewer treatment device fails, the domestic sewer and waste water from production Waste water should be temporarily stored in the reservoir and then be treated by the sewage treatment devices after the devices have been repaired. Such water should not be directly discharged outside and the maximum Treatment of production waste discharge of such water of the company is specified to be about 11m3/d. Now, 250m3 emergency treatment water and the emergency pool has been built to cope with the situation of failure of sewage treatment station. treatment Set up sound reactor emergency facilities and improve the inlet of HF emergency pool. Close all drainage outlets when accidents happen and all waste water is guided to the emergency pool or sewage treatment station and discharge to the outside is strictly banned. Emission of hydrogen fluoride Spray tower washing has been used to recycle the hydrogen chloride and chlorine hydride and the emission Gas and chlorine hydride and so on has met the standard. Emission of gas of the boiler Natural gas has been used as fuel of the boiler and emission of SO2, NOx and soot has been effectively room controlled. The emission has met the standard. Install sound-insulation doors and windows or use low-noise cooling towers according to the original Noise Noise of the freezer environmental impact assessment requirements. Close doors and windows during the night production. Fire and explosion in the Strengthen the application of automatic control, monitoring alarm and chain protection of accidents of the production process process system. The safety control system should have improved DCS control system and safety interlock system, including Accident alarming, parking and accident treatment functions. Set 250m³ emergency pool for fire-fighting. Leakage in the production Maintain the system equipment and sealing units. process Design dual-loop to avoid HF leakage caused by sudden stop. Fire, explosion or leakage in the Store the dangerous chemicals in different areas and the area spacing should be longer than 50m. Those storage process areas should be isolated with cofferdam respectively. 62 Environmental Problems and risks Mitigation/prevention and control measures medium Store in the cool warehouse with good ventilation, be far away from fire and heat source, the temperature in the warehouse should be not higher than 30℃. Set up sound fire-fighting system; grade the warehouse in accordance with regulations; and determine the check frequency and keep the check records in accordance with the grading requirements. Set up fire-fighting dike, install drain valve and drainage pipeline strictly in accordance with the design standard; pave oil penetration and diffusion proof materials on the ground of oil depot. Fire, explosion and or leakage in Transportation of dangerous chemicals of the project will be undertaken by the supplier and the supplier or the transportation process the transportation company should be responsible for the risks and accidents in the transportation process. It is required to supplement the risk prevention manuals for the storage and transportation process, strengthen management on storage and transportation of chemicals and standardize the transportation process: the package should be complete and the loading should be proper at the time of departure; the transportation vehicle should be equipped with emergency leakage treatment equipment, should avoid sunshine, rain and high temperature during the transportation and the transportation vehicle should run according to the given route and not stop at the residential areas and densely populated areas. Problems in emergency Equip communication equipment, lighting facilities and safety wears and tools and set emergency protection management facilities. Set up check and maintenance system, regularly check and maintain the water retaining wall and water diversion channels and so on, timely take necessary measures to ensure normal operation if damages or Environmental abnormalities are found; record the type and quantities of solid wastes transported to the site and other management relevant data in details and keep them for long term for inquiry at any time. The person in charge and duty division at the time of accidents should be clearly defined in the emergency plan. Have more emergency rescue training and report it to the relevant department for record. 63 Table 27 Waste water monitoring plan Monitoring Monitoring Monitoring Pollution Monitoring agency sites indicators frequency sources Self monitoring: Monitor twice every Monitoring should be Flow, pH, day for once every 8 carried out by the CODcr, ammonia hours and each sample Company’s monitoring nitrogen, fluoride should be no less than station; General 3 discharge Sewage, Yingcheng outlet of cleaning Environmental waste water Third-party waste Flow, pH, Monitoring Station treatment monitoring: Monitor water CODcr, ammonia (Provincial station once every quarter, nitrogen, Environment and each sample chloridate, Monitoring Station should be no less than fluoride should be entrusted for 3 the qualifications it does not have) General Third-party discharge PFOS content monitoring: Monitor Cleaning Hubei Provincial outlet of (characteristic once every year, and waste Environment waste water pollutants) each sample should be water Monitoring Station treatment no less than 3 station Noise monitoring: (1) Monitoring sites: eight monitoring sites should be arranged at 1m from the plant boundary; (2) Monitoring project: noise between day and night (equivalent continuous A sound level) in plant boundary; (3) Monitoring frequency: monitoring once every quarter; (4) Monitoring agency: Yingcheng Environmental Monitoring Station. 4. Capacity building and training program The capacity building and training program of the project are shown in Table 28. Table 28 Capacity building and training program of the project Implementation No. Name of activity Specific actions frequency of plan Check the staff’s post capacity; strengthen Provide training fees for the professional training of environmental Strengthening of professional training in management staff and understand 1 the staff’s post environmental environmental management knowledge in capacity management, and order to improve the quality of arrange once a year environmental protection work Publicity of laws Publicizing laws and regulations related to and regulations safety and environment on office staff 2 Once every half year related to safety according to the company system and environment requirements and job needs 3 Professional Environmental monitoring personnel Provide training fees for 64 Implementation No. Name of activity Specific actions frequency of plan training on should have a certificate, and be professional training in environmental responsible for the provided environmental environmental monitoring monitoring data, be familiar with the management, and personnel production process, and continuously arrange once a year improve their professional quality. Noise monitoring equipment, acidimeter, flow meter, COD rapid detector, ultraviolet specrophotometer, analytical balance, Construction of 4 ammonia meter and on-line monitoring Financed purchase laboratory devices should be provided according to the daily monitoring of the waste water in the sewage treatment station in plant area 5. Supervision and reporting system According to China's relevant environmental regulations and World Bank’s policy requirements, the subproject (that is, the Employer) shall be responsible for the preparation of "Evaluation and Monitoring Report on the Implementation of Environmental Management Plan" (usually twice a year). The purpose is to ensure that the related requirements and measures of environmental management plan are implemented, identify problems in time, analyze and summarize, in order to control adverse environmental impacts in the project follow-up work. The main contents of environmental management plan should include: (1) Implementation of environmental management plan: main content of construction at this phase; training in environmental management at this stage; implementation of mitigation measures; problems and causes; corrective measures of the next step; (2) Environmental monitoring results: give a brief explanation to the data, explain the problems and dissatisfaction phenomenon, analyze its causes, and recommend corrective measures; resident complaints and solution should be included when necessary; (3) Environmental management: standardized situation of emissions; collection of effluent fees; construction of environmental protection facilities; summary of experience, problem analysis and conclusion. Working proposals and plans for the next half year. 65 Chapter 6 Audit Conclusion The cleaning wastewater generated by Hubei Hengxin Chemical Co., Ltd. are discharged through the general discharge outlet of wastewater treatment plant after being neutralized, flocculated and settled. The production wastewater should be utilized through selling by way of chemical raw materials, and sewage should be discharged together with treated cleaning wastewater to the municipal pipe network and treated together in Yingcheng wastewater treatment plant: (1) The concentrations of main indicators such as fluoride, chloride, CODcr, ammonia nitrogen and pH in treated wastewater can meet the primary standard in Integrated Wastewater Discharge Standard (GB8978-1996) and the emission concentration required by the secondary standard of the maximum acceptable emission of chemical industry in Discharge Standard of Chlorides for the Fuhe River Basin in Hubei Province (DB42/168-1999); (2) however, the total emissions of CODcr and ammonia nitrogen exceed the requirements of EIA, and the plant uses too much domestic water and green water, which should be improved in the project implementation period. Some amount of HF gas escapes while hydrogen gas is released in electrolysis process. HF gas is condensed in condenser. The gases not condensed in condenser will flow into tail-gas washing tower through buffer tank and are purified in washing tower. HF gas will be washed with water by two-stage spraying system, with purification efficiency above 99%. After HF concentration becomes within 20-25%, HF gas is sent to tail-gas collecting tank and then transferred to Wuhan Mingxiufeng Chemical Co., Ltd. as by-product. The unabsorbed HF gas is discharged in uncontrollable manner, but within the limits for uncontrolled discharge monitoring points in Table 2 of Integrated Emission Standard of Air Pollutants (GB16297-1996). Similarly, the HCl gas produced in the acylating chlorination process is also recycled and treated through absorption by spray tower, and HCl acid waste water is sold to Wuhan Mingxiufeng Chemical Co., Ltd. as raw material, achieving the effect of pollutants recycling and the HCl indicator in gas of the plant is discharged up to the standard. What’s more, in order to reduce the SO2, NOx and dust emissions in the boiler, Hubei Hengxin Chemical Co., Ltd. has transformed the boiler into boiler using natural gas in accordance with the requirements of the EIA, achieving the stable and standardized discharge of the three indicators. Solid wastes generated by the Company contain household refuses, CaF2 residues and distillation residues which includes those produced after fluorination and those produced after electrolysis. Among them, (1) household refuses are collected and disposed of by sanitation department in Yingcheng Household Refuses Treatment Plant; (2) distillation residues are transported to Yichang Hazardous Wastes Treatment Center, which complies with the requirements of EIA; (3) The Company transfers all the CaF2 residues with category code HW49 to Yichang Hazardous Wastes Treatment Center for disposal in accordance with the requirements of the Environmental Protection Bureau, and landfill phenomenon does not exist. In addition, there are still about 40 tons of calcium fluoride in the plant area. Since Yichang Hazardous Wastes Treatment Center no longer accepts the transfer, the EPB of Yingcheng is assisting in looking for solutions. 66 As a chemical enterprise, the greatest environmental risk of the Company is from the disposal and storage methods of industrial solid waste and hazardous waste. There are great potential risk and many areas for improvement, for example: the storage method of industrial solid waste and hazardous waste of the plant is not standardized, and there’s leakage, wetting and soaking of solid waste. The environmental management on harmful raw materials, toxic chemicals and hazardous wastes should be strengthened. The hazardous chemicals should be classified for storage and management. The toxic chemicals should be handled and transported by qualified units. Leakage alarm devices and explosion-proof and fire-proof facilities should be installed. Relevant management system and facilities should be established and perfected. Management measures should be implemented. The detailed suggestions are shown in Table 28. The noise of the Company is mainly generated from refrigeration units. Although the monitoring results show that the plant boundary noise indicators reach the standard, after the site investigation, it’s considered that soundproof windows and doors or low-noise refrigeration units still should be set up in accordance with the EIA requirements and doors and windows should be closed when working at night. The Company needs to improve environmental management and strengthen risk awareness: (1) determine the responsible person and division of labor of environmental management; (2) formulate a more comprehensive emergency plan, and enhance emergency drills of the Company, which should be recorded by the Municipal Environmental Protection Bureau; (3) establish an inspection and maintenance system, and carry out regular inspection and maintenance on facilities such as retaining wall and diversion channel. When damage or abnormity is found, necessary measures should be taken to ensure the normal operation; the type and quantity of solid waste and other related information should be recorded in detail and kept for a long term for easy reference; (4) disclose environmental information in accordance with the requirements of the EIA. In summary, no environmental safety accident occurred, and the Company had no illegal act violating environmental protection laws, and no complaint against the Company was received from startup of the project to this day. During the verification period, the Company does well in exhaust gas treatment, qualified pollutant emission concentration indicators in recent years and environmental management. But the Company still has many deficiencies, especially with regard to the potential risk of storage method of its industrial solid waste and hazardous waste, which should be improved under the premise of strictly implementing the environmental protection and pollution control measures, and actively cooperating and promising to implement the relevant environmental requirements. 67 Chapter 7 Annexes Annex 1-1: Reply to EIR Form of the Organic Silicon and Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd. (2004) 68 Annex 1-2: Reply to Retrospective Evaluation Report of the 30t/a Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd. (2008) 69 70 71 Annex 1-3: Opinions on Final Acceptance of the Organic Silicon and Organic Fluorine Products Project of Hubei Hengxin Chemical Co., Ltd. (2005) 72 Annex 2-1: Cover of the Statistical Form for Declaration and Registration of Pollutant Discharge (2011) 73 Annex 2-2: Pollutant Discharge Permit of Hubei Province (2012-2015) 74 Annex 2-3: Pollutant Discharge Permit of Hubei Province (2015-2016) 75 Annex 3: Supervisory Monitoring Report (2015) 76 77 78 Annex 4: Letter on Total Pollutant Discharge Control Indicators of Hubei Hengxin Chemical Co., Ltd. 79 80 Annex 5: Operation Log of Environmental Protection Facilities 81 Annex 6-1: Hazardous Wastes Disposal Contract (2015) 82 83 Annex 6-3: Hazardous Wastes Manifest (2014) 84 Annex 6-4: Hazardous Wastes Manifest of Hubei Province (2015) 85 Annex 6-5: Register of Hazardous Wastes in Storage 86 Annex 6-6: Legal Person Certificate and Organization Code Certificate of Yichang Solid Wastes Disposal & Management Center (Yichang Hazardous Wastes Treatment Center) 87 Annex 6-7: Practicing certificates of hazardous wastes transport staff 88 Annex 6-8: Permit for Road Transport of Hazardous Wastes and Vehicle Registration Card 89 Annex 7-1: Environmental Hazard Prevention Measures and Emergency Response Plan 90 Annex 7-2: Emergency Rescue Plan for Work Safety Accidents 91 Annex 7-3: Implementation of Standardized Management of Hazardous Wastes 92 Annex 7-4: Cover of the Enterprise Work Safety Standardization Log II: Risk Management 93 Annex 8: Sign plate of wastewater discharge outlet 94 Annex 9: Sign-in Sheet of Discussion Meeting of Public Consultation of Hubei Hengxin Chemical Co., Ltd. 95 96