ESMP 浙江 - EN - 0615

Ningbo Nenglin Fire-fighting Equipment Co., Ltd Harmless Disposal Activity of Reduction and Phase-out of PFOS in Priority Sectors in China   Environmental and Social Management Plan

June 15, 2023

 

 

 

 

 

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Content

1.        Introduction        

1.1        Background        

1.2        Methodology        

1.3        Report Structure        

2.        Applicable Environmental and Social Safeguard Policy        

3.        Site Introduction        

3.1        Collecting Company        

3.1.1        Project Location        

3.1.2        Project Buildings and Structures        

3.1.3        Production Process        

3.2        Disposal Company        

3.2.1        Project Location        

3.2.2        Project Buildings and Structures        

3.2.3        Technological Process        

4.        Project Baseline        

4.1        Collecting Company        

4.1.1        Environmental Baseline        

4.1.2        Socio-economic Baseline        

4.2        Disposal Company        

4.2.1        Environmental Baseline        

4.2.2        Socio-economic Baseline        

5.        Environmental and Social Audit        

5.1        Collecting Company        

5.1.1        Environmental Audit        

5.1.2        Occupational Health Audit        

5.1.3        Safety Audit        

5.1.4        Social Audit        

5.1.5        Management System        

5.1.6        Findings and Action Plan        

5.2        Disposal Company        

5.2.1        Environmental Audit        

5.2.2        Occupational Health Audit        

5.2.3        Safety Audit        

5.2.4        Social Audit        

5.2.5        Management System        

5.2.6        Findings and Action Plan        

6.        Project Activity Introduction        

6.1        Project Activity Content        

6.2        Project Schedule        

7.        Environmental And Social Impact Assessment of The Demonstration Project        

7.1        PFOS-containing Fire-fighting Foam Collecting        

7.2        PFOS-containing Fire-fighting Foam Disposal        

8.        Capacity Building        

8.1        Project Management Organization        

8.2        Job Contents        

9.        Stakeholder Engagement and Information Disclosure        

9.1        Objectives        

9.2        Stakeholders Engagement Process        

9.2.1        Collecting Company: NLFF        

9.2.2        Disposal Company: Guiling        

9.3        Stakeholders Consultation        

9.4        Public Engagement and Information Disclosure in the Next Phase        

9.5        Community Grievance Redressing Mechanism        

9.5.1        Collecting Company: NLFF        

9.5.2        Disposal Company: Guiling        

10.        Environmental And Social Management Plan        

11.        Environmental And Social Monitoring Plan        

12.        Cost Estimation        

Appendices        

APPENDIX A: List of Consulted Stakeholders        

APPENDIX B: Real Estate Certificate of NLFF        

APPENDIX C: Real Estate Certificate of Guiling        

APPENDIX D: List of Reviewed Documents of NLFF        

APPENDIX E: List of Reviewed Documents of Guiling        

APPENDIX F: Site Photo Log of NLFF        

APPENDIX G: Site Photo Log of Guiling        

 

Tables

Table 2‑1: E&S Safeguard Policies of the World Bank        

Table 2‑2: E&S Laws and Regulations        

Table 3‑1: Structures and Facilities within the Scope of this Demonstration Project        

Table 3‑2: Structures and Facilities within the Scope of the Demonstration Project        

Table 4‑1: Total Population and Population Density in 2022        

Table 4‑2: Comparison of GDP and Industrial Structure in 2022        

Table 4‑3: Total Population and Population Density in 2022        

Table 4‑4: Comparison of GDP and Industrial Structure in 2022        

Table 5‑1: Test Result and Frequency of Wastewater        

Table 5‑2: Test Result and Frequency of Air Emissions        

Table 5‑3: Noise Monitoring Result        

Table 5‑4: Solid Waste Type and Generation        

Table 5‑5: Existing Problems in NLFF and E&S Action Plan        

Table 5‑6: Hazardous Waste Disposal Amount        

Table 5‑7: Test Result and Frequency of Wastewater        

Table 5‑8: Test Result of Air Emissions        

Table 5‑9: Noise Monitoring Result        

Table 5‑10: Solid Waste Type and Generation        

Table 5‑11: Annual Monitoring Results of Groundwater        

Table 5‑12: E&S Issues        

Table 6‑1: Collecting Plan        

Table 6‑2: Project Schedule        

Table 7‑1: E&S Impact and Mitigation Measures in Collection Stage of PFOS-containing Fire-fighting Foam        

Table 7‑2: E&S Impact and Mitigation Measures in Disposal Stage of PFOS-containing Fire-fighting Foam        

Table 8‑1: Capacity Building and Training Plan        

Table 9‑1: Consultation Conclusion with Stakeholders        

Table 10‑1: ESMP of Collecting Company        

Table 10‑2: ESMP of Disposal Company        

Table 11‑1: E&S Monitoring Plan of NLFF        

Table 11‑2: E&S Monitoring Plan of Guiling        

Table 12‑1: Budget of the Demonstration Project        

 

 

 

FIgures

Figure 3‑1: Location of Collection Company and Disposal Company        

Figure 3‑2: Schematic Diagram of NLFF’s Surrounding Environment        

Figure 3‑3: Schematic Layout of the Facilities        

Figure 3‑4: Schematic Diagram of Guiling’s Surrounding Environment        

Figure 3‑5: Schematic Layout of the Facilities        

Figure 3‑6: Incineration Process Flow Chart of Guiling        

Figure 4‑1: Number of employees in Taizhou City in Recent Years (Unit: 10,000 people)        

Figure 4‑2: Number of Employees in Jiaxing City in Recent Years (Unit: 10,000 people)        

Figure 5‑1: Management System and Organization Chart        

Figure 5‑2: Management System and Organization Chart        

Figure 8‑1: Schematic Diagram of The System Structure of the Project Management Organization        

Figure 9‑1: On-site Interviews        

Figure 9‑2: PFOS Project Grievance Appeal Process Flow Chart        

 

 

 

Abbreviation
AQI	Air quality index
BOD	Biochemical oxygen demand
CEMS	Continuous Emissions Monitoring Systems
cod	Chemical oxygen demand
EEB	Ecology and Environment Bureau
EIA	Environmental impact assessment
E&S	Environmental and social
ESIA	Environmental and social impact assessment
ESMF	Environmental and social management framework
ESMP	Environmental and social management plan
ESS	Environmental and social standard
FECO	Foreign Environmental Cooperation Center
gef	Global Environmental Facility
NLFF	Ningbo Nenglin Fire-fighting Equipment Co., Ltd.
OHS	Occupational health and safety
Pdp	Pollution discharge permit
PFOS	Perfluorooctane Sulphonate
PFOSF	Perfluorooctane Sulfonyl Fluoride
WB	World Bank
WWTF	Wastewater treatment facility
wwtp	Wastewater treatment plant

 

 

1.       Introduction

1.1                       Background

In May 2009, the fourth meeting of the Conference of the Parties to the Stockholm Convention on Persistent Organic Pollutants (POPs) (hereinafter referred to as the POPs Convention) passed an amendment that nine new POPs including perfluorooctane sulphonate, and perfluorooctane sulfonyl fluoride (hereinafter referred to as PFOS group, PFOS/PFOSF) were added to the controlled list of the convention. On August 30, 2013, the Standing Committee of the National People's Congress reviewed and approved the amendment. On March 26, 2014, the amendment officially took effect in China. In order to implement the requirements of the POPs Convention and relevant amendments, and promote the phase-out and replacement of PFOS group in China, the Foreign Environmental Cooperation Center (FECO) of the China Ministry of Ecology and Environmental and the World Bank jointly developed the "Global Environmental Facility (GEF)-Reduction and phase-out of PFOS in priority sectors in China" (hereinafter referred to as the PFOS Project), which aims to help China fulfill its obligations related to PFOS group in the POPs Convention and realize the phase-out and replacement of priority sectors for specific exemptions, and introduce best available techniques/best environmental practices (BAT/BEP) applications, etc.

The fire suppression sector is one of priority sectors for the implementation of the PFOS Project in China, and various activities of the fire suppression sector sub-project under the PFOS project have been launched. The PFOS/PFOSF-containing fire-fighting foam (hereinafter referred to as PFOS-containing fire-fighting foam) contains only a small amount of PFOS group (approximately 0.1% - 0.8%). It could obtain high surface activity, high thermal stability and high chemical stability with the addition of a small amount of PFOS/PFOSF. In accordance with the requirements of Article 6 of the POPs Convention, PFOS-containing fire-fighting foam (products and articles that are about to become waste) should be collected, transported and stored in an environmentally sound manner. Therefore, this project designed demonstration activities for the environmentally sound disposal of PFOS-containing fire-fighting foam in the fire protection industry (hereinafter referred to as the demonstration activities), based on the four demonstration companies for the harmless disposal of PFOS-containing fire-fighting foam (hereinafter referred to as demonstration companies, located in Shanghai City, Zhejiang Province, Jiangsu Province and Henan Province) that have been selected by the project.

In May 2019, the Ninth Conference of the Parties to the POPs Convention deliberated and passed an amendment on PFOS-related compounds (hereinafter referred to as the 2019 Amendment), which adjusted the fire suppression foam from “acceptable purpose” to “specific exemption” and imposed restrictions on the conditions of use. The amendment has not yet come into force in China.  At the end of 2022, China included PFOS group as a new pollutant in the List of New Pollutants under Key Control (2023 Edition), and the requirements for PFOS control are: "The processing and use of PFOS substances is prohibited from March 1, 2023, but they are exempted from the production of fire-fighting foam before December 31, 2023; At the same time, it is stipulated that PFOS group that have been prohibited from use, or declared as waste by the owner, or collected or received by relevant departments that need to be destroyed, or categorized to be hazardous wastes according to the national hazardous waste directory or hazardous waste identification standards, shall be managed as hazardous wastes."

According to the related research and lab testing results, the PFOS content of PFOS-containing fire-fighting foam products of demonstration companies generally range from 1000 to 8,000 ppm (equivalent to 0.01%-0.08%), the PFOS. And based on the current series of legislations and standards, there is not yet possible to determine that PFOS-containing fire-fighting foamwastes are hazardous wastes. In accordance with the requirements of Article 6 of the POPs Convention, the parties shall take measures to conduct environmentally sound disposal of wastes whose PFOS group content exceeds the low concentration limit of paragraph 2 (C). Among them, the low concentration limit of PFOS group was set at 50 mg/kg (equivalent to 0.005%) by the POPs Convention in 2015, concentrations of PFOS group in the PFOS-containing fire-fighting foam products of demonstration companies were higher than the limit. Taking into account the current domestic management situation and the requirements of the POPs Convention, the demonstration activity intends to collect, transfer and store the fire-fighting foam as general goods, and then dispose of fire-fighting foam with PFOS content at above 50mg/kg with reference to hazardous waste for the disposal process, which is stricter than the requirements of national regulations, to improve the level of environmentally sound management in the disposal process.

In accordance with the General Technical Guidelines on the Environmentally Sound Management of Wastes Consisting of, Containing or Contaminated with Persistent Organic Pollutants (UNEP/CHW.16/INF/7) and the Technical Guidelines on the Environmentally Sound Management of Wastes Consisting of, Containing or Contaminated with PFOS/PFOSF, Perfluorooctanoic Acid (PFOA), its Salts and PFOA-Related Compounds, and Perfluorohexane Sulfonic Acid (PFHxS), its Salts and PFHxS Related Compounds (UNEP/CHW.16/INF/18), taking into account the results of the previous research of the project and the maturity of domestic hazardous waste disposal technologies, it is proposed to use high-temperature disposal technology (i.e. hazardous waste incineration or cement kiln co-disposal) to carry out final environmentally sound disposal of PFOS-containing fire-fighting foam in demonstration activity. High temperature disposal technology is one of the environmentally sound disposal technologies recognized by the technical guidelines of the POPs Convention, and it is also an internationally acceptable disposal technology that can destroy or irreversibly convert PFOS, and has formed technical cases and is included in the technical guidelines in the United States, European countries, Australia, etc. 

In order to promote the domestic management of PFOS-containing fire-fighting foam to meet the relevant requirements of the 2019 Amendment, FECO drafted “Global Environmental Facility (GEF)-Reduction and phase-out of PFOS in priority sectors in China: The technical suggestion and overall implementation plan for the environmentally sound disposal of PFOS-containing fire-fighting foam in the fire suppression sector” (2023.4.7), planned to carry out exploratory demonstration through this activity to push forward the domestic environmentally sound management of PFOS-containing fire suppression product waste. In the cities or provinces where the demonstration companies are located, the collection, transportation and storage of the PFOS-containing fire-fighting foam shall be carried out in accordance with the local management requirements, be disposed of with reference to the relevant management requirements and technical standards of hazardous waste disposal, adopting high-temperature disposal technology. The environmentally sound management of PFOS-containing fire-fighting foam shall be implemented and evaluated. Demonstration activities have been launched and will be implemented in four demonstration companies including Ningbo Nenglin Fire-fighting Equipment Co., Ltd (hereinafter referred to as NLFF). Since the demonstration companies have relatively complete information on the sales volume and users of PFOS-containing fire-fighting foam, they are suitable to undertake the tasks of collection and entrust the demonstration disposal companies. 

In this project, NLFF, as the collecting company, will collect about 80 tons of PFOS-containing fire-fighting foamfrom the client (such as the power plants and chemical plants, etc.) and entrust a disposal company for handling.

NLFF evaluated and compared the candidate list of qualified and capable hazardous waste disposal companies in Zhejiang Province, then compared and screened the disposal capacity and comprehensive strength of each company, with the assistance by the supervision agency, Zhejiang Ecological and Environmental Science Design and Research Institute. Finally, NLFF selected Zhejiang Guiling Environment Technology Co., Ltd. (hereinafter referred to as Guiling) as the disposal company of the project.

The environmental and social (E&S) compliance assessment are conducted for the existing facilities of both NLFF and Guiling, and the current E&S management systems of the two companies, as well as environmental and social impact assessment (ESIA) on the proposed environmentally sound disposal of PFOS-containing fire-fighting foam (the demonstration project).

In February 2023, Stantec Environmental Engineering (Shanghai) Co., Ltd. (Stantec) was commissioned by FECO to be responsible for preparing an ESMP for this demonstration project (the report).

1.2                       Methodology

The following methods were used by Stantec for this assignment:

·       Review of relevant documents, including (1) environmental impact assessment (EIA) document; (2) E&S management system documents (Yibin Branch continues to use the management procedures of the headquarters, and has not established management procedures at the branch level); (2) relevant social licensing documents (such as land acquisition impacts), and (4) other E&S related documents and records;

·       Online public information research;

·       On-site visits to the demonstration project and surrounding areas;

·       Project stakeholder consultation. A list of stakeholder consultation can be found in Appendix A.

1.3                       Report Structure

The remaining sections of this report are:

·       Section 2: Applicable Environmental and Social Standards;

·       Section 3: Project Introduction;

·       Section 4: Project Baseline;

·       Section 5: Environmental and Social Audit;

·       Section 6: Introduction of the Demonstration Project;

·       Section 7: E&S Impact Assessment of the Demonstration Project;

·       Section 8: Capacity Building;

·       Section 9: Stakeholder Engagement and Information Disclosure;

·       Section 10: Environmental and Social Management Plan;

·       Section 11: Environmental and Social Monitoring Plan;

·       Section 12: Cost Estimation;

·       Section 13: Appendices.

 

 

 

2.       Applicable Environmental and Social Safeguard Policy

The applicable E&S safeguard policies of the World Bank are listed as following:

Table 2‑1: E&S Safeguard Policies of the World Bank

Safeguard Policy	Relevance of the Parent Project	Relevance of the Sub-Project (the Demonstration Project)	Note
Environmental Assessment  (OP/BP 4.01)	Triggered	Triggered	The project activities include raw material replacement, experiments, equipment replacement, product trial production and production activities, which will have an impact on the environment. The project will prepare this environmental management plan to control the environmental risks in the process of equipment removal.
Natural Habitats  (OP/BP 4.04)	Not Triggered	Not Triggered	Both parent project and the pilot project does not involve natural habitats and nature reserves at all levels, nor does it carry out construction in nature reserves.
Pest Management  (OP 4.09)	Triggered	Not Triggered	The parent project triggers the OP 4.09, according to the Environmental and Social Management Framework (ESMF). However, the pilot project does not involve the manufacture, use, purchase and treatment of pesticides, so the pilot project dose not trigger OP 4.09.
Indigenous People (OP 4.10)	Not Triggered	Not Triggered	The parent project doesn’t trigger the OP 4.10, according to the ESMF. This pilot project is not located in an ethnic minority settlement and does not trigger the WB's OP 4.10.
Physical Cultural Resources  (OP 4.11)	Not Triggered	Not Triggered	The parent project doesn’t trigger the OP 4.11, according to the ESMF. This pilot project does not involve material and cultural resources, and will not select sites that affect archaeological, paleontological and historical values to carry out activities.
Involuntary Resettlement  (OP/BP 4.12)	Triggered	Not Triggered	The parent project triggers the OP/BP 4.12, according to the ESMF. However, the construction of this pilot project does not involve land acquisition and demolition.
Forestry  (OP 4.36)	Not Triggered	Not Triggered	The parent project doesn’t trigger the OP 4.36, according to the ESMF. This pilot project does not involve commercial logging and does not involve virgin forest.
Safety of Dams  (OP/BP4.37)	Not Triggered	Not Triggered	Both parent project and the pilot project does not involve supporting the construction and rehabilitation of dams, nor will it rely on existing dams or dams under construction on the mission.
Projects on International Waterways (OP/BP7.50)	Not Triggered	Not Triggered	Both parent project and the pilot project does not involve international rivers.
Projects in Disputed Areas  (OP/BP7.60)	Not Triggered	Not Triggered	Both parent project and the pilot project does not involve disputed areas.
Access to Information	Triggered	Triggered	The World Bank (WB)'s Access to Information Policy is applicable to this project.

The report also refers the IFC EHS General Guidelines.

Table 2‑2 lists the domestic E&S laws and regulations applicable to this report.

Table 2‑2: E&S Laws and Regulations

Title	Date
General
Environmental Impact Assessment Law	2018
Environmental Protection Law	2015
Regulation on the Environmental Management of Construction Projects	2017
Inventory on Categorized Management of Environmental Impact Assessment of Construction Projects	2021
Notice on Further Strengthening the Management of Environmental Impact Assessment and Preventing Environmental Risks	2012
Notice on Printing and Distributing the List of Major Changes in Construction Projects of Some Industries in Environmental Impact Assessment Management	2015
Notice on Strengthening Risk Prevention and Strictly Managing Environmental Impact Assessment	2012
General Outline of Technical Guidelines for Environmental Impact Assessment of Construction Projects	2017
Air Pollution Prevention and Control
Atmospheric Pollution Prevention and Control Law	2018
Integrated Air Emission Standards (GB16297-1996)	1996
Notice of the Ministry of Ecology and Environment on the Issuance of the Sample Letter of Commitment of the Pollution Discharge License, the Application Form of the Pollution Discharge License and the Format of the Pollution Discharge License	2018
Integrated Emission Standard of Air Pollutants (DB 32/4041-2021)	1996
Standard for Pollution Control on Hazardous Waste Incineration (GB 1848-2020)	2020
Emission Standards for Odor Pollutants (GB 14554-93)	1994
Emission Standard of Cooking Fume (GB 18483-2001)	2001
Emission Standard of Air Pollution for Boiler (GB 13271-2014)	2014
Regulations for Atmospheric Pollution Prevention and Control of Zhejiang Province	2020
Water Pollution Prevention and Control
Environmental Quality Standards of Surface Water (GB 3838-2002)	2002
Water Law	2016
Water Pollution Prevention and Control Law	2017
Integrated Wastewater Discharge Standards (GB 8978-1996)	1996
The Reuse of Urban Recycling Water – Water Quality Standard for Industrial Uses (GB/T 19923-2005)	2005
Indirect Discharge for emission Limitation of Nitrogen and Phosphorus for Industrial Wastewater (DB 33/887-2013)	2013
Soil and Groundwater Pollution Prevention and Control
Standard for Groundwater Quality (GB/T 14848-2017)	2017
Standard for Soil Pollution Risk Control on Construction Land	2018
Noise Pollution Prevention and Control
Ambient Noise Pollution Prevention and Control Law	2018
Ambient Noise Emission Standard at the Boundary of Industrial Plants (GB 12349-2008)	2008
Emission Standard for Industrial Enterprises Noise at Boundary (GB 12348-2008)	2008
Solid Waste Pollution Prevention and Control
Solid Waste Pollution Prevention and Control Law	2020
Regulation on the Safety Management of Hazardous Chemicals	2013
Directory of National Hazardous Wastes (Version 2021)	2021
Measures on the Management of Waste Manifest for Hazardous Waste	1999
Standard for Pollution Control on Hazardous Waste Incineration (GB 1848-2020)	2021
Technical Specifications for Collection, Storage, Transportation of Hazardous Waste (HJ 2025-2012)	2013
Technical Specification for Centralized Incineration Facility (HJ/T 176-2005)	2005
Solid Waste Pollution Prevention and Control Regulations of Zhejiang Province	2023
Occupational Health
Occupational Health Law	2018
List of occupational hazard risk classification management of construction projects	2021
Provisions on the Administration of Occupational Health at Workplaces	2021
Technical Specifications for Occupational Health Surveillance (GBZ 188-2014)	2014
Safe Production
Safe Production Law	2021
Three Simultaneous Supervision Measures on Safety Installation for Construction Project	2015
Measures on the Management of Safety Accident Emergency Response Plan	2019
Fire Prevention Law	2021
Code of Design on Building Fire Protection and Prevention	2018
Labor Working Condition
Labor Law	2018
Labor Contract Law	2012
Laws and Regulations Related to PFOS
Announcement on Prohibiting the Production, Circulation, Use, Import and Export of Persistent Organic Pollutants such as Lindane	2019

 

 

 

3.       Site Introduction

3.1                       Collecting Company

NLFF is an enterprise specializing in the production and sales of fire-fighting agents, fire extinguishers, and other fire-fighting equipment. It is also a demonstration company in Yinzhou District, Ningbo City, Zhejiang Province under the Global Environment Facility PFOS Reduction and Phase-out Project. In this project, NLFF, as a collecting company, will collect about 80 tons of PFOS-containing fire-fighting foam from power plants, chemical plants, and other fire-fighting foam users, and entrust the disposal company for disposal. The disposal company Guiling is located in Gangqu District, Jiaxing City, Zhejiang Provence, approximately 107 km away from NLFF. The relative locations are shown in the figure below.

Figure 3‑1: Location of Collection Company and Disposal Company

3.1.1                      Project Location

NLFF is located at No. 10, Yunli Road, Yunlong Town, Yinzhou District, Ningbo City, Zhejiang Province. The geographical location is shown in Error! Reference source not found.. The area of NLFF belongs to the Yunlong Hengxi Industrial Area in Yinzhou, Ningbo City. The main industries are traditional manufacturing industries such as casting, electrical machinery, injection molding, packaging, and printing. The land used by NLFF does not involve legacy land acquisition and demolition issues, as detailed in the section on land use in the social audit section of 5.1.4.1.

NLFF is bordered by Ningbo Shengtong Metal Products Co., Ltd to the east., Ningbo Henglong Kitchen Equipment Co., Ltd. to the south, Yunlong Police Station across Longxia Road to the west, and Yunli Road to the north, across from which is Ningbo Xinma Electrical Appliance Co., Ltd.

Within 500 m of NLFF, there are mainly industrial parks, and a small number of residential areas, such as Wangjiaao Village, which is located 50 m to the west of NLFF, and Rong'an Jinyun Mansion, which is located 370 m to the north of NLFF. Wangshengyi Primary School is located 160 m to the northwest of NLFF. Yunlong Town Health Center is located 170 m to the southwest of NLFF. This demonstration project does not involve large-scale construction and production activities within the scope of NLFF, but only storage. All activities will be carried out in the workshop, and the influence on the surrounding environment is small. See the figure below for specific geographical location information.

Figure 3‑2: Schematic Diagram of NLFF’s Surrounding Environment

3.1.2                      Project Buildings and Structures

The project will not add new buildings or structures. It will rely on existing transferring and warehousing facilities, office areas, testing laboratories, power supply systems, water supply systems, and fire protection systems. The existing and involved buildings and structures are shown in the table below.

Table 3‑1: Structures and Facilities within the Scope of this Demonstration Project

 

The schematic layout of the above facilities is shown in the following figure.

Figure 3‑3: Schematic Layout of the Facilities

 

3.1.3                      Production Process

NLFF has one fire-fighting foam production line, one dry powder fire-fighting agent production line, and one dry powder fire extinguisher production line. Only the collection and storage of PFOS-containing fire-fighting foam were involved in this activity. The main components of the collected PFOS-containing fire-fighting foam are water, diethylene glycol butyl ether, fluorocarbon surfactant, hydrocarbon surfactant, stabilizer, solvent, etc., of which water accounts for 80%, the foam is not hazardous chemical or waste and belongs to inert liquid mixture. According to laboratory analysis and estimation, PFOS, as an additive of fluorocarbon surfactant, the content of which in the PFOS-containing fire-fighting foam ranges from about 1000ppm-8000ppm.

Since the current extinguishing foam storage tanks of the foam users may contain a mixture of PFOS-containing fire-fighting foam and PFOS-free fire-fighting foam, NLFF needs to sample and test the PFOS content in the tanks, and the extinguishing foam with test results of PFOS content greater than 50ppm will be collected.

NLFF will use its own vehicles to transfer PFOS-containing fire-fighting foam from the users; During the collection and transfer process, two NLFF operators will be staffed. The workers will transfer the fire-fighting foam from the storage tanks of the users to the totes through a pump, and then transport the totes to the storage warehouse in the NLFF plant area. The third-party supervision unit will conduct a secondary PFOS content test then before the disposal unit to receive the disposal. The temporary storage warehouse is equipped with emergency facilities for leakage prevention (impermeable floor, secondary cofferdam, emergency absorbing pads, emergency waste collection ditch and pallet, etc.).

 

 

3.2                       Disposal Company

Guiling is a disposal company for PFOS-containing fire-fighting foam. It was founded in September 2017 and holds a hazardous waste business license (No. 3300000270) issued by Jiaxing Ecological Environment Bureau (EEB), which is valid until January 2, 2028. The approved business methods include collecting, storage, and disposal. The approved business scale is 30,000 tons/year hazardous waste incineration. Its business license covers the collecting, transportation, treatment, and disposal of hazardous waste. The construction will start in November 2019 and will be completed and put into operation in early 2021. It plans to use the incineration process to conduct harmless disposal of PFOS-containing fire-fighting foam s. It has advanced environmental protection processes and equipment. As a demonstration base for the resource utilization and disposal of hazardous waste, Guiling has an incineration license of 30,000 tons/year.

3.2.1                      Project Location

Guiling Industrial Waste Recycling and Disposal Base is located at No.286 Washan Road, Gangqu District, Jiaxing City, China, with an area of 13,351 m². Guiling does not involve legacy land acquisition and demolition issues, as detailed in the section on land use in the social audit section of 5.2.4.1.

Guiling is bordered by Gewa Mountain Road to the east, across from which is Zhejiang Jiashang Stainless Steel Co., Ltd. Zhejiang Yitan New Material Technology Co., Ltd. is located on the south side of Guiling. Jiaxing Huawen Chemical Co., Ltd. is located on the west side of Guiling, and Chaihetan is located on the north side of Guiling. A river is located on the north side of Guiling, across from which is West Shichang Road, followed by, Jiaxing Haitai Chemical Logistics Integrated Service Co., Ltd. is located.

The area ranged within 500 m of Guiling is mainly covered by industrial parks, involving no residential area. See the figure below for specific geographical location information.

Figure 3‑4: Schematic Diagram of Guiling’s Surrounding Environment

3.2.2                      Project Buildings and Structures

The project will not add new buildings or structures, but will rely on the existing power supply system, water supply system, fire protection system, and hazardous waste storage and disposal engineering. The existing and involved buildings and structures are shown in the table below.

Table 3‑2: Structures and Facilities within the Scope of the Demonstration Project

 

The schematic layout of the above buildings and structures is shown in the following figure.

Figure 3‑5: Schematic Layout of the Facilities

3.2.3                      Technological Process

The incineration system process of the Project is as follows: Hazardous wastes are collected and transported into the plant through dedicated containers and vehicles, and hazardous wastes that need to be incinerated directly or after pre-treatment are transported into the incineration workshop are transferred using dedicated containers and vehicles. The rotary kiln is used for incineration, and the flue gas from the secondary combustion chamber is cooled by a waste heat boiler. Urea solution is injected into the first furnace of the waste heat boiler to remove nitrogen oxides from the flue gas, and a quench tower is used to quickly cool down the gas to prevent dioxins generation. After dry deacidification, the flue gas enters a baghouse for filtration. After dust removal, the flue gas enters a two-stage wet scrubber for further deacidification. After deacidification, the low-temperature wet flue gas is processed through wet electrostatic precipitator treatment, and finally emits from a 50 m high stack. The incineration process is shown in the following figure.

Figure 3‑6: Incineration Process Flow Chart of Guiling

This project only involves the incineration unit. Due to the low fluorine content of waste fire-fighting foam, it is considered that pretreatment is not necessary according to the assessment of Guiling, and it can be directly pumped into the rotary kiln for combustion.

 

 

 

4.       Project Baseline

4.1                      Collecting Company

The environmental and socio-economic baseline information of the project gives priority to using the baseline data around the collecting company. If there is no corresponding public information around the collecting company, the public information of the administrative division at the next higher level will be used as a reference, and so on. 

4.1.1                      Environmental Baseline

4.1.1.1                      Geography and Climate

NLFF is located at No.10, Yunli Road, Yunlong Town, Yinzhou District, in the southeast of the district, 12 km from the urban area of Ningbo. Yinzhou District is under the jurisdiction of Ningbo City, Zhejiang Province, and is one of its core urban areas. Located on the southern wing of the Yangtze River Delta, in the east of Zhejiang Province, along the central coast of Ningbo City, bordering Haishu District in the west, Jiangbei District and Zhenhai District in the north, Beilun District in the northeast, Fenghua District in the south, and Xiangshan County across Xiangshan Port in the southeast. The land area of the whole region is 1,380.54 km2.

Yinzhou District has a subtropical monsoon climate with a mild and humid climate, with an average temperature of 16.20°C. It has frequent showers in summer, high air humidity, and high temperature; There is little rain in winter, and the climate is dry and cold; The rainfall in spring and autumn is balanced, with moderate heat and cold. In spring, there are many rainy days and scattered rainfall, while in autumn, there are many showers and typhoons, with concentrated rainfall and high intensity. The annual average rainfall is 1,450-1,800 mm. The dominant wind direction on the ground throughout the year is northwest wind, with southeast wind in summer (frequency 10%) and northwest wind in winter (frequency 10%). The main disastrous weather in the region is typhoon, rainstorm, drought, cold wave, frost, etc.

4.1.1.2                      Environmental Quality of Air

According to the functional zoning of atmospheric environment in Ningbo City, the area where the project is located belongs to Category II area. The area implements the Category II standard of the Ambient Air Quality Standard (GB 3095-2012). According to the Ningbo Ecological Environment Status Bulletin (2021), the annual average concentration of PM2.5 in the central urban area of Ningbo in 2021 was 21 μg/m3, a decrease of 8.7% compared to the same period of last year. The comprehensive index of ambient air quality was 3.25, a decrease of 0.06 compared to the same period of last year. The healthy rate of the air quality was 95.9%, up 3.0 percentage points compared to the same period of last year. The number of air quality compliance days is 350 and that of incompliance days is 15, with an incompliance rate of 4.1%. The incompliance pollutants were all ozone, with a decrease of 5 days compared to the same period of last year.

4.1.1.3                      Environmental Quality of Surface Water

According to Ningbo Ecological Environment Status Bulletin (2021), the overall water quality of the Yongjiang River system in 2021 was excellent, and the comprehensive assessment of the water quality in Yinzhou District was light pollution. There was no drinking water source in Yinzhou District.

The wastewater receiving water body of this project is the Yongjiang River, and it complies the Category IV standard according to Division Plan for Water Function and Water Environment Function Zones in Zhejiang Province (2015). The surface water within the scope of the project evaluation is a tributary of the Dahe River. According to Division Plan for Water Environment Function Zones in Zhejiang Province (2015), it can be found that the water body is Yongjiang 21, the water function zone is Yinzhou Agricultural Water Zone along the trunk river in the southeast of Yinzhou (code: G02121200503053), and the water environment function zone is agricultural water zone (code: 330212GA080203000350). According to the monitoring results of the water quality in 2019, the indicators of the Sanjiangkou and Zhangjianqiao sections of the water body meet the requirements of the "Surface Water Environmental Quality Standard" (GB3838-2002) Class III water quality standard.

4.1.1.4                      Environmental Quality of Groundwater

According to Ningbo Ecological Environment Status Bulletin (2021), there are a total of 6 national controlled groundwater quality monitoring points in Ningbo, of which 3 river valley pore phreatic water monitoring points have good water quality, all complying the Category III water quality standards; The water quality of the two confined water monitoring points in Layer II is poor, and they are all Category V water. Newly added national controlled groundwater pollution risk monitoring point (Ningbo Petrochemical Economic Development Zone) has water quality of Category V.

The groundwater environmental quality of the area where NLFF is located shall comply with the Category IV standard limits specified in Groundwater Quality Standard (GB/T14848-2017). According to the 2020 data of groundwater in Zhonghe Street, which is about ten kilometers to the North of the NLFF plant, all indicators reached Class III water quality standards.

4.1.1.5                      Environmental Quality of Noise

NLFF is located in the Category III acoustic environment functional area specified in Acoustic Environment Quality Standard (GB 3096-2008), and its plant boundary noise implementation standard is 65 dB(A) during the day and 55 dB(A) at night. Currently, according to the plant boundary noise detection report provided by NLFF, the daytime and night ambient noise background values of the project site comply with the requirements of the Category III area standard in the Environmental Quality Standard for Noise (GB 3096-2008).

4.1.1.6                      Ecological Environment

Currently, there are rivers, roads, enterprises, farmland, etc. distributed around the project site. Terrestrial animals are mainly common poultry and livestock, such as chickens, ducks, geese, etc. Natural fish in river channels and cultivated fish in ponds are all common local aquatic species, such as: black carp, grass carp, bream, crucian carp, carp, etc.; The vegetation is mainly crops such as vegetables and a small amount of seedlings. There are no protected animals and plants around the project.

4.1.2                      Socio-economic Baseline

4.1.2.1                      Population

Zhejiang Province is a provincial administrative region of the People's Republic of China, with the provincial capital of Hangzhou City, located in the Yangtze River Delta region. Zhejiang is one of the provinces with the smallest differences in economic development of its cities within China, and Hangzhou, Ningbo, Shaoxing, and Wenzhou cities are the four economic pillars of Zhejiang. Zhejiang is the only province where the income of residents in all districts and cities exceeding the national average. Zhejiang Province has a total area of 105,500 square kilometers, including 11 prefecture-level cities, 37 municipal districts, 20 county-level cities, and 33 counties (including one autonomous county). At the end of 2022, the permanent resident population of Zhejiang Province was 65.77 million.

Ningbo City is a prefecture level city under the jurisdiction of Zhejiang Province and an important port city along the southeast coast of China approved by the State Council. As of 2022, the city has jurisdiction over 6 districts and 2 counties, and manages 2 county-level cities, with a total area of 9,816 square kilometers. By the end of 2022, Ningbo had a permanent resident population of 9.62 million.

Yinzhou District, under the jurisdiction of Ningbo City, Zhejiang Province, is one of the central urban areas of Ningbo and the seat of the Ningbo Municipal Government. The total area is 814.2 square kilometers. In 2022, the total registered residence population of Yinzhou District will be 928,000.

According to the 2022 National Economic and Social Development Statistics Bulletin of the National Bureau of Statistics, the total population of China at the end of 2022 was 1,411.75 million. The total population of China, Zhejiang Province, Ningbo City, and Yinzhou District in 2022 is shown in Table 4‑1Error! Reference source not found..

Table 4‑1: Total Population and Population Density in 2022

Item	China	Zhejiang province	Ningbo city	Yinzhou district
Land area (square kilometers)	9,600,000	105,500	9,816	814.2
Total population (10,000 people)	140,211	6,577	961.8	-
Population density (person/km2)	148	623	979.8	-

Data source: 2022 China Statistical Yearbook; Statistical Bulletin on National Economic and Social Development of Zhejiang Province in 2022; Statistical Bulletin on National Economic and Social Development of Ningbo City in 2022; Statistical Bulletin on National Economic and Social Development of Yinzhou District, Ningbo City, 2022.

4.1.2.2                      Economy and Income

According to the "Statistical Bulletin of National Economic and Social Development of Zhejiang Province in 2022", the GDP of Zhejiang Province in 2022 was 7,771.5 billion CNY, an increase of 3.1% over the previous year. In terms of industries, the added value of the primary, secondary, and tertiary industries was 232.5 billion CNY, 332.5 billion CNY, and 4,218.5 billion CNY, respectively, an increase of 3.2%, 3.4%, and 2.8% compared to the previous year. The three industrial structures were 3.0:42.7:54.3. The per capita GDP was 118,496 CNY, an increase of 2.2% over the previous year. The per capita disposable income of all urban and rural residents was 60,302 CNY, 71,268 CNY, and 37,565 CNY, respectively, an increase of 4.8%, 4.1%, and 6.6% over the previous year. Overall, the level of economic development in Zhejiang Province is good; The per capita GDP and annual disposable income of Zhejiang Province are both higher than the national average.

According to the Statistical Bulletin of National Economic and Social Development of Ningbo City in 2022, Ningbo achieved a regional GDP of 157,043 billion CNY in the whole year, an increase of 3.5% over the previous year based on comparable prices. In terms of industries, the added value of the primary industry reached 38.2 billion CNY, an increase of 4.1%; The added value of the secondary industry reached 741.35 billion CNY, an increase of 3.2%; The added value of the tertiary industry was 79,088 billion CNY, an increase of 3.8%. The ratio of the three industries is 2.4:47.2:50.4. Based on the permanent population, the per capita GDP of the city is 163,911 CNY. In 2022, the per capita disposable income of residents in the city was 68,348 CNY, an increase of 4.5% over the previous year; Among them, the per capita disposable income of urban residents was 76,690 CNY, an increase of 3.8%, while the per capita disposable income of rural residents was 45,487 CNY, an increase of 5.9%. Overall, the economic development level of Ningbo City is good; Ningbo's per capita GDP and annual disposable income are both higher than the national and Zhejiang average levels.

According to the "2022 Statistical Bulletin of National Economic and Social Development of Yinzhou District, Ningbo City", in 2022, the total output value of the Yinzhou district (including the high-tech zone, the same below) was 273.48 billion CNY, a year-on-year increase of 3.0%. The added value of the primary industry was 3.07 billion CNY, an increase of 3.8%; the added value of the secondary industry was 75.12 billion CNY, an increase of 3.0%, including 60.63 billion CNY, an increase of 3.0%; the added value of the tertiary industry was 195.29 billion CNY, an increase of 3.0%. The tertiary industrial structure is 1.1:27.5:71.4. The annual per capita disposable income of all residents was 77,552 CNY, an increase of 5.3% over the previous year. Among them, the per capita disposable income of urban permanent residents was 84,630 CNY, an increase of 4.7%, while the per capita disposable income of rural permanent residents was 50,333 CNY, an increase of 6.9%. Overall, the economic development level of Yinzhou District is good; The annual per capita disposable income of Yinzhou District is higher than the average level of the country, Zhejiang Province, and Ningbo City.

In 2022, the per capita disposable income of Chinese residents was 36,883 CNY, an increase of 5.0% over the previous year. Among them, the per capita disposable income of urban residents was 49,283 CNY, an increase of 3.9% over the previous year; The per capita disposable income of rural residents was 20,133 CNY, an increase of 6.3% over the previous year. The comparison of GDP and industrial structure in 2022 is shown in Table 4‑2.

Table 4‑2: Comparison of GDP and Industrial Structure in 2022

Data source: 2022 China Statistical Yearbook; Statistical Bulletin on National Economic and Social Development of Zhejiang Province in 2022; Statistical Bulletin on National Economic and Social Development of Ningbo City in 2022; Statistical Bulletin on National Economic and Social Development of Yinzhou District, Ningbo City, 2022.

4.1.2.3                      Human Resources

Due to the provincial and municipal governments where the Collecting Company is located in were unable to publish the 2022 human resources data before the finalization of the report, the human resources section has adopted the 2021 human resources public data from the respective region.

According to the "Statistical Bulletin on the Development of Human Resources and Social Security in Zhejiang Province in 2021", in 2021, 1.22 million new urban jobs were created in Zhejiang Province, 471,700 unemployed people were re-employed, and 128,600 people with employment difficulties were helped to achieve re-employment. At the end of 2022, the registered urban unemployment rate was 2.61%, and the urban survey unemployment rate was 4.3%. The province issued 3.8 billion CNY of guaranteed loans to support 60,000 entrepreneurs. At the end of 2022, there were 2.25 million poverty relief workers from outside the province who were stably employed in Zhejiang.

In 2021, Zhejiang Province participated in 2.2 million person-times of professional and technical personnel knowledge update training, held 116 advanced training courses, and trained 20,000 high-level and urgently needed and backbone talents. Throughout the year, 2.6 million person-times of vocational skill training were conducted, 3,339 vocational skill level recognition and evaluation institutions were newly established, and 43,000 new apprentices were recruited and trained by enterprises.

According to the "Statistical Bulletin of National Economic and Social Development of Ningbo City in 2021", in 2021, the city added 344,000 urban employees, and 48,000 urban unemployed completed reemployments, including 26,000 people in difficulties. At the end of the year, the registered urban unemployment rate in the city was 2.31%. Throughout the year, 216000 new college students were employed in the city, an increase of 30.7% over the previous year.

In 2021, the total number of employees in Ningbo is about 6 million, with the largest number of employees in the secondary industry. In recent years, employment in the primary, secondary, and tertiary industries have shown a trend of increasing year by year (see Figure 4‑1).

Figure 4‑1: Number of employees in Taizhou City in Recent Years (Unit: 10,000 people)

Data source: 2021 Statistical Yearbook of Zhejiang Province.

4.2                      Disposal Company

The environmental and socio-economic background data of the Project shall preferably use the baseline data around the disposal company. If there is no corresponding public information around the disposal company, the public information of the administrative division at the next higher level shall be used as a reference, and so on. 

4.2.1                      Environmental Baseline

4.2.1.1                      Geography and Climate

The project is located in Jiaxing Gangqu District. Jiaxing Gangqu District is located in the northeast of Zhejiang Province, on the north shore of Hangzhou Bay. It is located in Pinghu County, Jiaxing City, 13.41 km away from Pinghu and 43 km away from Jiaxing. Backed by the beautiful and fertile Zhenjiahu Plain and adjacent to Shanghai Chemical Industry Park, the Gangqu District is the bridgehead linking Jiaxing City and Zhejiang Province to Shanghai, and the only sea outlet and foreign trade channel in northern Zhejiang.

Jiaxing is located in a subtropical monsoon climate region with four distinct seasons, with long winter and summer periods in the four seasons, and short spring and autumn periods. There are no significant regional differences. The frost-free period is long, and the sunshine is abundant. The annual rainfall is between 790 and 1,700 mm. The expected annual average temperature is 16.4°C, and the average relative humidity is 80%. The major disasters are storms, floods, low temperature and frost damage, followed by tornadoes and typhoons. The dominant wind direction throughout the year is east wind, with east and southeast winds dominating in spring and summer, and northwest winds dominating in autumn and winter. The annual average wind speed is 2.62 m/s, and the wind speed distribution in the southeast is greater than that in the west.

4.2.1.2                      Environmental Quality of Air

According to the Jiaxing Ecological Environment Status Bulletin, Jiaxing's former atmospheric functional areas, which include six districts, belong to Category II, and comply with the Category II standard of the Ambient Air Quality Standard (GB 3095-2012). In 2021, the urban ambient air quality in Pinghu City reached the secondary standard of PM2.5, with an annual average concentration of 21 μg/m3. The annual average ozone concentration is 146 μg/m3, healthy air quality rate 93.7%.

4.2.1.3                      Environmental Quality of Surface Water

The water near the area where Guiling is located is a Category III water quality functional area that complies the Category III water quality standard specified in the Environmental Quality Standard for Surface Water (GB 3838-2002). There is a Zhapu Pond near the plant area, which complies the standard except for the COD and TP indicators.

A wastewater treatment station is set up in the plant area of Guiling. Industrial wastewater and primary stormwater are treated and discharged into the municipal pipelines after compliance. Domestic wastewater is treated in the septic tank and discharged into the municipal pipelines after compliance. The treated wastewater is piped to the municipal wastewater treatment plant (WWTP) in Gangqu District for centralized treatment to meet the Class I Grade A standard in the Discharge Standard for Pollutants from Urban Wastewater Treatment Plants (GB 18918-2002) before being discharged into Hangzhou Bay, rather than directly into nearby surface water bodies. There is no impact on the surrounding surface water.

4.2.1.4                      Environmental Quality of Groundwater

According to the Jiaxing Ecological Environment Status Bulletin (2021), there were 3 Category IV and 2 Category V groundwater quality monitoring points in the national assessment of groundwater quality in five places in Jiaxing City. Compared with 2020, the overall quality of groundwater remained stable.

The environmental quality of groundwater in the area where the Guiling is located shall comply with the Category III standard limits specified in the Environmental Quality Standard for Groundwater (GB/T 14848-2017). Due to historical reasons, some groundwater monitoring factors in this plot fail to meet the requirements of this standard. 

 

4.2.1.5                      Environmental Quality of Noise

According to the Jiaxing Ecological Environment Status Bulletin (2021), the average equivalent sound level range of environmental noise in six urban areas of Jiaxing City in 2021 was 52.7-55.0 dB(A). Compared to 2020, Pinghu City, where Guiling is located, the ambient noise has increased and remains around 53 dB(A). Among various noise sources that affect the urban acoustic environment, domestic noise sources and traffic noise sources are the main noise sources, accounting for 48.6% and 35.4%, respectively.

Guiling is located in the Category III acoustic environment functional area specified in the Environmental Quality Standard for Noise (GB 3096-2008). The plant boundary noise implementation standard is 65 dB(A) during the day and 55 dB(A) at night. Currently, according to the plant boundary noise report provided by Guiling, the daytime and night environmental noise background values of the project site comply with the requirements of Category III area standards in the Environmental Quality Standard for Noise (GB 3096-2008).

4.2.1.6                      Ecological Environment

Part of the land parcel in Jiaxing Gangqu District where Guiling is located belongs to the enclosed land (wasteland) along the beach, mainly composed of reeds and weeds, and basically belongs to natural vegetation (secondary vegetation), with relatively simple species. Another part is farmland, mainly planted with crops such as rice and vegetables. Vegetation resources are mainly planted crops. Artificial vegetation is generally divided into farmland, forest, and water. Only coastal mudflat, low hills and Yiliang land still retain some natural vegetation. Currently, there are more than 1,000 kinds of wild plants, including 213 species of 41 under national protection.

There are 1,661 species of wild animals in 6 major categories in the area, including 9 species under national secondary protection. Wild animals and plants are mainly concentrated in scenic areas such as Jiulong Mountain, but there are no large wild mammals.

In addition, there is no significant ecological damage or soil erosion in Jiaxing Gangqu District, and the overall ecological environment is relatively good.

4.2.2                      Socio-economic Baseline

4.2.2.1                      Population

Zhejiang Province is a provincial administrative region of the People's Republic of China, with the provincial capital of Hangzhou City, located in the Yangtze River Delta region. Zhejiang is one of the provinces with the smallest differences in economic development of its cities within China, and Hangzhou, Ningbo, Shaoxing, and Wenzhou cities are the four economic pillars of Zhejiang. Zhejiang is the only province where the income of residents in all districts and cities exceeding the national average. Zhejiang Province has a total area of 105,500 square kilometers, including 11 prefecture-level cities, 37 municipal districts, 20 county-level cities, and 33 counties (including one autonomous county). At the end of 2022, the permanent resident population of Zhejiang Province was 65.77 million.

Jiaxing City, a prefecture level city under the jurisdiction of Zhejiang Province, is approved by the State Council as a tourist city in China with the characteristics of a water town in the south of the Yangtze River. Jiaxing City is located in the northeast of Zhejiang Province, in the hinterland of the Hangjiahu Plain in the Yangtze River Delta, bordering Shanghai in the east, Suzhou in the north, and Hangzhou in the south. The city has 2 districts, 2 counties, and 3 county-level cities under its jurisdiction. The land area is 3,915 square kilometers, and the sea area is 4,650 square kilometers. By the end of 2022, the city's permanent resident population was 5.55 million.

Pinghu City, a county-level city under the jurisdiction of Zhejiang Province, is managed by Jiaxing City. It is located in the north of Zhejiang Province, at the eastern end of the Hangjiahu Plain, with a total area of 554.4 square kilometers. Pinghu City governs 3 streets and 6 towns.

According to the 2022 National Economic and Social Development Statistics Bulletin of the National Bureau of Statistics, the total population of the country at the end of 2022 was 1,411.75 million. The total population of China, Zhejiang Province, Jiaxing City, and Pinghu City in 2022 is shown in Table 4‑3.

Table 4‑3: Total Population and Population Density in 2022

Item	China	Zhejiang province	Jiaxing city	Pinghu city
Land area (square kilometers)	9,600,000	105,500	3,915	554.4
Total population (10,000 people)	140,211	6,577	555.10	-
Population density (person/km2)	148	623	1,417	-

Data source: 2022 China Statistical Yearbook; Statistical Bulletin on National Economic and Social Development of Zhejiang Province in 2022; Jiaxing National Economic and Social Development Statistical Bulletin in 2022.

 

4.2.2.2                      Economy and Income

According to the "Statistical Bulletin of National Economic and Social Development of Zhejiang Province in 2022", the GDP of Zhejiang Province in 2022 was 7,771.5 billion CNY, an increase of 3.1% over the previous year. In terms of industries, the added value of the primary, secondary, and tertiary industries was 232.5 billion CNY, 332.5 billion CNY, and 4,218.5 billion CNY, respectively, an increase of 3.2%, 3.4%, and 2.8% compared to the previous year. The three industrial structures were 3.0:42.7:54.3. The per capita GDP was 118,496 CNY, an increase of 2.2% over the previous year. The per capita disposable income of all urban and rural residents was 60,302 CNY, 71,268 CNY, and 37,565 CNY, respectively, an increase of 4.8%, 4.1%, and 6.6% over the previous year. Overall, the level of economic development in Zhejiang Province is good; The per capita GDP and annual disposable income of Zhejiang Province are both higher than the national average.

According to the "Statistical Bulletin of National Economic and Social Development of Jiaxing City in 2022", Jiaxing’s GDP in 2022 was 673.945 billion CNY, an increase of 2.5% over the previous year based on comparable prices. In terms of industries, the added value of the primary industry was 14.401 billion CNY, an increase of 2.4%; The added value of the secondary industry was 371.961 billion CNY, up 2.9%; The added value of the tertiary industry was 287.6 billion CNY, an increase of 2.0%. Based on the permanent resident population, the city's per capita GDP in 2022 was 121,794 CNY, an increase of 1.2% over the previous year. Overall, Jiaxing has a good level of economic development; Jiaxing's per capita GDP and annual disposable income are both higher than the national and Zhejiang average levels.

In 2022, the per capita disposable income of average Chinese residents was 36,883 CNY, an increase of 5.0% over the previous year. Among them, the per capita disposable income of urban residents was 49,283 CNY, an increase of 3.9% over the previous year; The per capita disposable income of rural residents was 20,133 CNY, an increase of 6.3% over the previous year.

The comparison of GDP and industrial structure in 2022 is shown in Table 4‑4.

Table 4‑4: Comparison of GDP and Industrial Structure in 2022

Data source: 2022 China Statistical Yearbook; Statistical Bulletin on National Economic and Social Development of Zhejiang Province in 2022; Jiaxing National Economic and Social Development Statistical Bulletin in 2022.

4.2.2.3                      Human Resources

Due to the provincial and municipal governments where the Disposal Company is located in were unable to publish the 2022 human resources data before the finalization of the report, the human resources section has adopted the 2021 human resources public data from the respective region.

According to the "Statistical Bulletin on the Development of Human Resources and Social Security in Zhejiang Province in 2021", in 2021, 1.22 million new urban jobs were created in Zhejiang Province, 471,700 unemployed people were re-employed, and 128,600 people with employment difficulties were helped to achieve re-employment. At the end of 2022, the registered urban unemployment rate was 2.61%, and the urban survey unemployment rate was 4.3%. The province issued 3.8 billion CNY of guaranteed loans to support 60,000 entrepreneurs. At the end of 2022, there were 2.25 million poverty relief workers from outside the province who were stably employed in Zhejiang.

In 2021, Zhejiang Province participated in 2.2 million person-times of professional and technical personnel knowledge update training, held 116 advanced training courses, and trained 20,000 high-level and urgently needed and backbone talents. Throughout the year, 2.6 million person-times of vocational skill training were conducted, 3,339 vocational skill level recognition and evaluation institutions were newly established, and 43,000 new apprentices were recruited and trained by enterprises.

According to the "Statistical Bulletin of National Economic and Social Development of Jiaxing City in 2021", in 2021, there were 188,800 new urban employment in Jiaxing City, with a registered urban unemployment rate of 1.82%. The city has completed 107,630 farmer trainings, including 8260 rural practical talent trainings, added 1,014 high-quality farmers, and developed 1,114 newly cultivated agricultural entrepreneurs.

In 2021, Jiaxing City recorded 3.3 million employees, with the largest number of employees in the secondary industry. In recent years, employment in the primary, secondary, and tertiary industries have shown a trend of increasing year by year (see Figure 4‑2Error! Reference source not found.).

Figure 4‑2: Number of Employees in Jiaxing City in Recent Years (Unit: 10,000 people)

Data source: 2021 Statistical Yearbook of Zhejiang Province.

 

5.       Environmental and Social Audit

5.1                      Collecting Company

5.1.1                      Environmental Audit

5.1.1.1                      Environmental Permit 

The EIA form of NLFF's "Project with Annual Production of 20,000 tons of Dry Powder Extinguishing Agent and 2,000 tons of foam Extinguishing Foam" was approved by Ningbo EEB in September 2021 (YHJ [2021] No. 122). NLFF registered its pollution discharge permit(PDP).on May 12, 2020, with the registration number of 91330212144565561C001X.

The risk assessment report and emergency response plan for environmental emergencies of NLFF was filed in October 2021 (filing number: 330212-2021-077-L). Its environmental emergency plan was carried out from the aspects of plan system, organizational structure and responsibilities, surveillance and early warning, information reporting, emergency monitoring, emergency response, emergency disposal, emergency termination, post incident management, safeguard measures, drills, etc.

The company currently operates within the scope of the existing EIA, environmental emergency plan, and PDP.

5.1.1.2                      Wastewater

NLFF uses water for production, quality inspection, product development, and daily activities The water is supplied by the municipal water supply network. The wastewater from foam production, quality inspection and R&D is reused in production; Domestic wastewater enters the municipal wastewater pipeline after pre-treatment in a septic tank. The external drainage capacity is about 2,400 tons/year.

The wastewater from the project mainly includes domestic wastewater from employees and a small amount of laboratory cleaning wastewater. The discharge amount of domestic wastewater is 2,400 tons/year, which is discharged into the septic tank and then discharged into the Xinzhou WWTP.

According to the test report by Ningbo Yonglan Testing Co., Ltd. in August 2022 (sampling time in August 2022), the water quality at the general outlet of the wastewater treatment station in the current plant area meets the requirements of the Class III standard in Table 4 of the Comprehensive Wastewater Discharge Standard (GB8978-1996) and the Discharge for Emission Limitation of Nitrogen and Phosphorus for Industrial Wastewater (DB 33/887-2013), Table 1 of the indirect emission limit of water pollution from industrial enterprises. The test results are detailed in the following table.

Table 5‑1: Test Result and Frequency of Wastewater

5.1.1.3                      Air Emission

NLFF has 20 air emission outlets (DA001-DA020), of which this project only involves the air emission from the kitchen and boiler house, and the corresponding exhaust discharge No. in test report is YQ5 and YQ11.

According to the test report issued by Ningbo Yonglan Testing Co., Ltd. in August 2022 (sampling time in August 2022), the air emissions from kitchen and boilers met the limit requirements in Table 3 of the " Emission Standard of Cooking Fume" (Trial) (GB18483-2001) and "Emission Standard of Air Pollution for Boiler " (GB13271-2014).

Table 5‑2: Test Result and Frequency of Air Emissions

Pollution type	Discharge No.	Discharge port name	Pollutant	Result		Standard		Monitoring frequency	Compliance
				Emission concentration （mg/m3）	Emission rate （kg/h）	Emission concentration （mg/Nm3）	Emission rate （kg/h）
Organized emissions	YQ5	Kitchen	Cooking Fume	1.28	-	2.0	-	Once/half a year	Yes
	YQ11	Boiler air emission outlet	Particulate matter	<20	-	20	-	Once/year	Yes
			Sulfur dioxide	<3	-	50	-	Once/year	Yes
			Nitrogen oxide	25 - 29	-	150	-	Once/year	Yes

This project does not involve production air emissions, but only the kitchen and boiler air emissions generated by the daily activity of employees.

 

5.1.1.4                      Noise

The noise sources of NLFF are mainly fans, pumps, air compressors, etc.; The noise sources were arranged in the plant as far away as possible from the plant boundary. According to the test report issued by Ningbo Yonglan Testing Co., Ltd. in August 2022 (sampling time in August 2022), the noise levels at the plant boundary meet the Class 3 standard limit specified in the Emission Standard for Industrial Enterprises Noise at Boundary (GB12348-2008), and the noise at sensitive points on the west side of the plant boundary meets the Class 2 standard specified in the Environmental Quality Standard for Noise (GB3096-2008). The test results of noise levels at boundaries are shown in the table below.

Table 5‑3: Noise Monitoring Result

5.1.1.5                      Solid Waste

The main type of hazardous waste of NLFF is waste gloves, which are stored in a hazardous waste warehouse and entrusted to Ningbo Longxin Environmental Technology Co., Ltd. for disposal. Ningbo Longxin Environmental Technology Co., Ltd. holds a hazardous waste business license. General industrial waste mainly consists of waste packaging materials, which is stored in the general solid waste temporary storage area, and is entrusted to Ningbo Longxin Environmental Technology Co., Ltd. for disposal. Domestic waste is disposed of by the sanitation department.

The types, amount, and disposal companies of outsourced solid wastes in the plant are shown in the following table:

Table 5‑4: Solid Waste Type and Generation

No.	Name	Type	Generation amount (t/a)	Disposal company
1	Waste gloves	Hazardous waste	0.05	Ningbo Longxin Environmental Technology Co., Ltd
2	Waste packaging	General industrial waste	40	Ningbo Longxin Environmental Technology Co., Ltd
3	Domestic waste	Domestic waste	24	Municipal sanitation department

The solid wastes involved in this project are the packaging totes containing PFOS-containing fire-fighting foam, which are planned to be incinerated together by the hazardous waste disposal company. The project is expected to generate domestic waste from employees. The totes containing PFOS-containing fire-fighting foam shall be disposed by the disposal company of the demonstration project together.

5.1.1.6                      Emergency Management

The plant has developed comprehensive environmental management plans, special emergency plans, and on-site disposal plans for possible environmental risks, and has provided corresponding measures (leakage prevention measures, such as collecting trenches, and impervious floors) according to the plans; Anti seepage measures such as yellow sand and absorbent pads.

The plant has set up an emergency response team. Each department conducts drills every year according to the plan. Within past three years, the plant has not experienced any emergency environmental accidents such as fire or leakage.

This project mainly involves the transportation and transfer process and leakage prevention in the storage area. The potential environmental risk of collecting company of this project is the leakage of PFOS-containing fire-fighting foam during the collecting and temporary storage process, once a leakage occurs, NLFF can respond according to the special emergency measures for leakage in the plan: 1) cut off the pollution source and close the rainwater valve as soon as possible; 2) emergency handling personnel shall wear face shields, wear chemical protective clothing, avoid directly contacting the leakage, and stop leakage under the safety condition; 3) temporary storage warehouse is equipped with secondary cofferdam and connected to emergency tank; 4) temporary storage warehouse is equipped with anti-leakage tray to collect leaked materials, and the on-site personnel will transfer the totes to a safe area if leakage occurs, and load the collected leakage collected from the tray into the hazardous waste package, if the liquid leaks to the ground, activated carbon, linoleum or rags, etc. will be used to clean up the ground, and the collected leakage and contaminated emergency supplies will be handed over to the hazardous waste treatment unit for disposal. 5) conduct leakage emergency training for transportation staff in advance, if the liquid leaks to the ground during transportation, use activated carbon, linoleum or rags to clean the ground, and collect the leakage and emergency supplies contaminated with the leakage to the hazardous waste treatment unit for disposal.

When the transport vehicle pumps out the PFOS-containing fire-fighting foam, it is equipped with a stainless-steel chassis. However, during a site visit, it was found that the impervious cofferdam in the storage area was damaged and needed to be repaired. The cofferdam will be repaired and the emergency plan described above will be implemented to effectively manage the emergency environmental risks of the project.

5.1.2                      Occupational Health Audit

5.1.2.1                      Occupational Health Permit

In April 2022, NLFF commissioned Zhejiang Zhongyi Testing and Research Institute Co., Ltd. to prepare the "Assessment Report on the Status Quo of Occupational Disease Hazards". The conclusion is that NLFF has followed the requirements of relevant national laws, regulations, and standards on occupational health management in the production process, and has taken effective occupational hazard protection measures for production facilities and processes that may cause occupational hazards as required, basically in line with the "Law of the People's Republic of China on the Prevention and Control of Occupational Diseases" and other relevant laws, regulations, standards, and specifications. The occupational disease prevention measures taken have achieved desired protective effect.

According to the "Notes on Issues Related to the ‘Three Simultaneities’ Supervision and Management Measures for Occupational Disease Prevention Facilities in Construction Projects" issued by the Emergency Management Department, "before the implementation of Order No. 90 on May 1, 2017, employers that had started operation and not carried out the ‘Three Simultaneities’ of occupational disease prevention facilities in accordance with the law should be ordered by the safety regulatory department to complete the detection and evaluation of occupational hazards in the workplace within a specified time limit after inspection and discover, enterprises had occupational hazards detected in the workplace shall receive penalty in accordance with relevant provisions of occupational disease prevention laws, regulations, and rules."

NLFF had not carried out the "Three Simultaneities" work for occupational disease prevention facilities, and started operation before the implementation of the “‘Three Simultaneities’ Supervision and Management Measures for Occupational Disease Prevention Facilities in Construction Projects" on May 1, 2017. It has regularly conducted occupational hazards testing, and the latest testing was completed by Zhejiang Institute of Chinese Medicine Testing and Research Co., Ltd. on November 4, 2022. There were no violences where the concentration or intensity of occupational hazards in the workplace exceeds the national occupational health standards.

According to the content of the occupational hazards detection report and on-site interviews, NLFF has not yet completed the 2022 occupational hazard declaration, and it is recommended that NLFF should complete the declaration as soon as possible.

5.1.2.2                      Occupational Hazard and Protection

During the operation of NLFF, the occupational hazards at the work site include:

Noise hazard: Noise hazards come from the operation of equipment such as pumps and mixing tanks. NLFF has installed vibration damping equipment, and concentrated equipment that generates high noise in the production area to reduce the impact of noise on non-production areas. NLFF also equipped employees with earplugs.

Chemical hazard: Chemical hazards come from chemicals used in the production of fire-fighting agents. Chemicals are stored in designated areas with complete external packaging. NLFF provides employees with personal protective equipment (PPE) such as protective masks, safety glasses, protective gloves, and work clothes. In addition, the work site is also equipped with emergency shower and eye wash facilities.

High temperature hazard: High temperature hazards come from boilers. NLFF maintained good natural ventilation in all workshops, and added exhaust fans to enhance air circulation in some workshops during the hot summer season even they don’t have heat sources.

The project only involves noise hazard, and NLFF has provided ear plugs and other PPE.

5.1.2.3                      Occupational Health Surveillance

NLFF has developed a corresponding occupational health monitoring management system and established occupational health files for workers in accordance with the requirements of the Technical Code for Occupational Health Monitoring (GBZ 188-2014).

In 2022, employers conducted pre job and during job occupational health checks. The project will involve two warehouse keepers and one loading worker, all of whom have undergone on-the-job occupational health checks and the conclusions indicated no abnormalities.

5.1.2.4                      Detection of Occupational Hazard in Workplace

According to the "Catalogue of Classified Management of Occupational hazards and Risks in Construction Projects" (GWBZJ Fa [2001] No. 5), NLFF belongs to enterprise category with "serious occupational disease hazards". According to Article 20 of the "Regulations on the Administration of Occupational Health in the Workplace" (effective as of February 1, 2021), employers with serious occupational hazards should entrust occupational health technical service institutions with corresponding qualifications to conduct at least one occupational hazards test a year and at least one occupational hazard status evaluation every three years. NLFF conducts occupational hazard testing every year. In November 2022, it entrusted Zhejiang Zhongyi Testing and Research Institute Co., Ltd. to conduct occupational hazard testing, and the concentration or intensity of occupational hazards did not exceed the national occupational health standards.

5.1.2.5                      Occupational Health Training and Emergency Management

NLFF has formulated the "Occupational Health Education and Training System". The company conducts unified safety production education (including occupational health related content) for employees before boarding. After taking up their posts, each department conducts regular safety and health education and emergency training, and the office regularly organizes training and relevant assessment.

NLFF has developed an emergency rescue plan, including special plans for heat stroke and chemical leakage, and has established an emergency rescue team to quickly respond to acute occupational hazards. One portable spray eyewash is set in the foam workshop, with a service range of 15m. Cofferdam is set at the semi-finished product storage tank of foam workshop, and the volume of cofferdam is larger than the storage capacity of single storage tank. In addition, each workshop is equipped with a first aid kit.

5.1.3                      Safety Audit

5.1.3.1                      Safety Permit

The production process of NLFF uses hazardous chemicals. According to the "Implementation Measures for Safety Licensing of Hazardous Chemical Construction Projects" and the "Three Simultaneities" Supervision and Management Measures for Safety Facilities of Construction Projects, the "Three Simultaneities" work for safety facilities should be carried out, and the safety status evaluation should be conducted every three years. Due to the fact that the Science and Technology Industrial Park in Xinghua Economic Development Zone where NLFF is located does not belong to a chemical industry park, according to the consultation opinion of the Yinzhou District Emergency Response Bureau, the safety "Three Simultaneities" report cannot be filed, so it is sufficient to conduct a safety status quo assessment in accordance with the Regulations on the Safety Management of Hazardous Chemicals.

In July 2020, NLFF commissioned Ningbo Qianye Safety Technology Co., Ltd. to prepare the Special Safety Assessment Report for Hazardous Chemical Storage and Use Sites. The issue of combustible gas detector and alarm devices mentioned therein had been rectified. The various rectification measures proposed in the evaluation report had been effectively implemented. On the premise of strictly complying with the existing safety management system and safety operation procedures, and ensuring the integrity and effectiveness of safety facilities, the risks in the storage and use sites of hazardous chemicals are basically controllable.

NLFF had prepared and released an emergency plan for production safety accidents (the latest version of the emergency plan was released in December 2020), and organized relevant training and drills.

The building is equipped with fire hydrants, mobile fire extinguishers, emergency lighting, emergency indication signs, and emergency evacuation plans. NLFF is responsible for entrusting a qualified third-party organization to carry out annual testing of lightning protection devices. The test results in 2021 all meet the relevant requirements of laws and regulations, but it is recommended to conduct an annual inspection. In April 2022, an emergency drill for natural gas leakage was held.

5.1.3.2                      Analysis of and Protection from Safety Hazards

The production of NLFF does not involve highly toxic chemicals, highly toxic substances, easily toxic and explosive chemicals, does not involve hazardous chemical reactions, and there are no major hazards of hazardous chemicals. The main hazardous and harmful factors existing during operation include mechanical injury, fire accidents, explosions (boiler explosions), burns, object strikes, high temperatures, poisoning, asphyxia, electric shock, and falling from height.

According to the on-site audit, the safety protection measures currently implemented by the company are relatively consistent with those in the completion acceptance report of safety facilities. The company has implemented certain safety protection measures in terms of construction, process equipment, and devices. The plant layout is reasonable, special equipment is regularly tested, and special operators employed are certified. The equipped fire-fighting facilities and equipment are placed in an obvious and accessible location, with clear space around, complying with relevant requirements.

This project only involves the transportation and storage of PFOS-containing fire-fighting foam, and the relevant hazards are from the loading, unloading and transportation of forklifts in the plant, and from the vehicle transportation outside the plant. For lifting hazards, the existing protective measures include regular inspection of forklifts, the establishment of safe operating procedures for forklifts, and the holding of certificates for personnel on duty,

According to the Acceptance of Fire Protection Design of Building Engineering issued by the Fire Protection Department of Yinzhou Branch of Ningbo Municipal Public Security Bureau on February 12, 2007 (YGXYZ (2007) No. 045), the fire protection acceptance of building engineering of NLFF is qualified.

5.1.3.3                      Safety Management

The safety management personnel of NLFF have participated in safety knowledge training courses for safety management personnel as required. Welders, high-voltage electricians, forklift drivers, and boiler operators all hold operating certificates for special equipment; There have been no industrial injuries or accidents during operation so far.

NLFF has prepared emergency plans for production safety accidents, emergency plan training, and drill plans, and conducted safety emergency drills for different types of accidents, keeping training and drill records.

Up to now, NLFF has not experienced any industrial injury or accident.

NLFF has entrusted Jiangsu Huayun Lightning Protection Testing Co., Ltd. to test the lightning protection facilities of various buildings and structures in the plant area. Currently, it holds the "Lightning Protection Device Test Report", the number of which is JSHY112022HN092, and the validity period is until May 31, 2023.

5.1.4                      Social Audit

5.1.4.1                      Project Land Use

NLFF is located at No. 10, Yunli Road, Yunlong Town, Yinzhou District, Ningbo City. According to the land use certificate and the building ownership certificate (see Appendix B) of NLFF, NLFF owns the use right and building ownership of the state-owned construction land within the red line of the current plant area. The operation of the existing project does not involve temporary land use or land acquisition, more than 15 years have passed since the original land was acquired, and the managers consulted indicated that they were unable to obtain land acquisition information. In the past five years, NLFF has received no complaints about land issues. There are no legacy issues related to land acquisition, land use restrictions and involuntary resettlement.

5.1.4.2                      Labor and Working Conditions

According to interviews and document reviews, there are 54 employees in NLFF which contains 14 female employes, including 3 in the Administration Department, 3 in the Finance Department, 8 in the Marketing Department, 27 in the Production Department, 8 in the Quality and Technology Department, and 5 in the Office Department.

The working hours of production workers are 7:30~11:00, 12:00~16:30 (spring and summer seasons), 8:00~11:00, 11:30~16:30 (autumn and winter seasons), and the working hours are clearly listed in the Employee Handbook. According to document review and interviews, NLFF does not advocate overtime work and takes regular holidays during holidays; Overtime rarely occurs during normal times. If overtime occurs, employees will be arranged to take compensatory leave, which does not involve paying overtime wages. NLFF’s working hours meet the requirements of the national labor law.

All employees are recruited on the market in accordance with the relevant requirements of the national labor law, and all have directly signed labor contracts with NLFF. No forced labor or child labor issues were found in the audit. The project will not cause job adjustments or layoffs for employees, and the salaries of employees involved in the project can be paid in full and on time, which is higher than the minimum wage standard of Ningbo City updated in 2021 (2,280 CNY).

All employees enjoy the benefits stipulated in the national labor law. The benefits enjoyed by female employees also include female employees are entitled to maternity leave in accordance with the law; Women's Day welfare; During pregnancy, physical labor will be avoided and if necessary, positions will be transferred.

NLFF does not provide dormitories; NLFF has a canteen for employees, where employees are provided with meal allowance for meal expenditures.

5.1.4.3                      Impact on Surrounding Communities

Within 500 m around NLFF, there are two residential areas, one school, and one hospital. The nearest residential area is about 50 m away from the site, the nearest school is about 160 m from the site, and the nearest hospital is about 170 m aways from the site, please refer to chapter 3.1.1 for the map of the geographical region.

The impact of the existing projects of NLFF on the surrounding communities is mainly caused by occupational hazards such as water pollutants, air emissions, solid waste, noise, and dust generated during the operation process, as well as the operation of raw and auxiliary materials and product transportation vehicles. NLFF has taken measures to reduce the impact on residents in surrounding communities by strictly following prevention and control measures required by environmental assessment, controlling noise sources and transportation vehicles, and reasonably operating to reduce dust emission. Due to the small E&S impact of NLFF on the outside world, its impact on surrounding communities is very limited.

According to consultations with management personnel and document review, the environmental and social management plan of NLFF’s Phase I project was publicly disclosed three times on the company's official website and factory bulletin board in December 2021 and January 2022 (two disclosures in January 2022), respectively. During the public disclosure period, no feedback was received from the public or surrounding communities. NLFF’s environmental assessment was disclosed through the national construction project environmental information platform on May 2022, during the disclosure period, no feedback was received from the public or surrounding communities. NLFF has not disclosed the route of transportation, it is suggested to disclose the route of transport vehicles externally through WeChat official account, bulletin boards or other channels.

5.1.4.4                      Ethnic Minorities

NLFF is located in Yunlong Town, Yinzhou District, Ningbo City, Zhejiang Province, and does not belong to ethnic minority residential areas. The project land does not involve ethnic minorities, so the project does not involve the impact on ethnic minorities.

5.1.4.5                      Grievance Redress Mechanism

(1)       Employee Grievance Redress Mechanism

NLFF has established an internal grievance mechanism and established a labor union. The employee grievance channels are divided into the following three types:

a.       Employees are free to file grievance with the labor union;

b.       Employees are free to file grievance to the General Manager's mailbox;

c.       Employees are free to file grievance with their immediate leaders.

After receiving the grievance, a reply on whether to accept it will be made within 5 working days. The labor union or the General Manager's Office shall review the grievance within 5 working days after receiving it, and coordinate and communicate with the complainant and the leader in charge on the grievance handling opinions. If coordination is not possible, it is recommended that employees take judicial procedures. According to consultations with management and employees, employees have expressed awareness of the employee grievance mechanism, and all grievances are made orally by employees to their immediate leaders. Due to all orally appealed grievances include daily work issues such as compensatory leave, the immediate leader is able to resolve daily work issues on the spot, so there is no written appeal record involved. NLFF has not encountered any non-daily work appeal issues, where NLFF has not established an employee grievance record form.

(2)       Community Grievance Redress Mechanism

According to interviews with management personnel, NLFF established a community grievance mechanism procedure in December 2021 and kept a written record of possible grievances. In order to promptly understand and address the impact of the project on employees of affected enterprises (hereinafter collectively referred to as "affected persons") and other stakeholders, and ensure the needs of affected groups for information disclosure and the widest possible public participation (not limited to surrounding communities), NLFF has established a multi-level grievance channel, as follows:

NLFF has appointed a coordinator (Mr. Yu Li) to receive community grievance, investigate and resolve all external grievances arising from or related to project activities. The community grievance redress mechanism has been disclosed to the surrounding communities through the company bulletin board. The contact information for community grievances is as follows:

Social coordinator: Mr. Yu Li Phone: 13566628922 Email: qc@nenglin.com Address: No.10, Yunli Road, Yunlong Town, Yinzhou District, Ningbo City, Zhejiang Province

The Social Coordinator will collect and record all grievance through the Grievance Registration Form and will record them in the grievance database. The grievance appeal process includes the following steps:

·       Stage 1: Affected people/communities can submit their grievances and complaints to the coordinator of their enterprise through oral or written appeals. Enterprises related to the affected person/community must maintain a written record of oral complaints and provide a clear response within two weeks.

·       Stage 2: If the affected person/community is not satisfied with the decision made in Stage 1, they can file grievance to FECO. During the implementation of the project, the grievance appeal mechanism at the level of the enterprise and local project office is the main channel for resolving the appeal of the project. FECO will make every effort to work with local project offices/participating enterprises and affected people/communities to seek assistance in resolving issues that cannot be resolved at the local project office/enterprise level or that do not have a project level grievance mechanism.

·       Stage 3: If the affected person/community is still not satisfied with the above project level decision, they can, after receiving the decision, appeal to the administrative authority with jurisdiction level by level for arbitration in accordance with the National Administrative Procedure Law.

·       Stage 4: If the affected person is still dissatisfied with the arbitration decision, after receiving the arbitration decision, he/she can bring a lawsuit to a civil court in accordance with the Civil Procedure Law.

For anonymous grievance, the same importance should be attached to other grievances. Meanwhile, the complainant's information should be kept confidential, and solutions should be proposed to the grievances. The grievances should be handled and recorded within 7 days. In addition to the above complaint channels, neighboring residents can call 12345 citizen hotlines for complaints. FECO will track the grievance mechanism and keep records. According to interviews with management personnel and grievance record document reviews, the surrounding communities have not filed grievances against NLFF.

5.1.4.6 Emergency management

According to consultations with management personnel and document reviews, NLFF has not developed a social risk emergency management mechanism. It is recommended that the company to establish a social risk emergency management mechanism and establish an emergency work leadership command center, establish an efficient information network, strengthen monitoring of unstable social factors, and conduct a comprehensive evaluation and prediction of information that may lead to large-scale group events, especially early warning information. The social risk emergency management mechanism should enable the company to achieve early detection, early reporting, early control, and early resolution of any potential social risks. Sound mechanisms should be developed for investigating and mediating conflicts and disputes, increase efforts to investigate conflicts and disputes that may trigger group incidents, identify potential issues that may trigger group incidents, and actively work with relevant government departments to resolve conflicts, and promptly report relevant information and work situations. It is recommended that the company to add the following content to its existing social management mechanisms to form a comprehensive social risk emergency management mechanism:

·       Establish a communication mechanism with surrounding community management committees;

·       Establish communication mechanisms with relevant local security government departments;

·       Develop an internal handling process to address social risks;

·       Develop an early warning plan to address social risks, such as conducting relevant visits, investigations, and summarizing issues reported by the public in response to emerging social risk information.

5.1.5                      Management System

NLFF has passed the certification of BSI ISO9001 quality management system, ISO14001 environmental management system, and ISO45001 occupational health and safety (OHS) management system. The environmental protection, safety, occupational health, and social management system of NLFF relies on the existing management framework, as shown in the following figure.

Figure 5‑1: Management System and Organization Chart

The Q/A Department of NLFF is responsible for formulating the company's environmental protection, safety, occupational health and social management system, assisting in the application of relevant permits, staying in touch with relevant government departments, and responsible for the routine work of environmental safety and occupational health throughout the plant, inspecting and maintaining relevant facilities and equipment. The Q/A Department also conducts regular compliance audits, inspects the implementation of environmental, safety, occupational health and risk management, identifies problems and solutions, and keeps achieving improvement, cooperates with other department in the formulation and implementation of risk management procedures, and regularly provides publicity, education, and job training to relevant employees and contractors.

NLFF has developed an environmental, occupational health, safety production, and social management system, as follows:

·       Decomposition of management policies, objectives, and indicators

·       Job Requirements for Personnel

·       Safety production responsibility system

·       Management system for industrial accidents

·       Fire safety management system

·       Management Measures for Use of Safety Signs

·       Environmental management system

·       Environmental Protection System of Finance Department

·       Printing management system

·       Related party management system

·       Labor protection and protective equipment management system

·       Management Measures for the Protection of Female Employee

·       Management Measures for Employee Health Examination

·       Management Measures for Waste Disposal

·       Regulations on Waste Classification Management

·       Control Measures for Energy Conservation and Consumption Reduction

·       Management Measures for Noise Emission Control

·       Warehouse Management Regulations

·       Chemical and oil product management system

·       Code of practice for safe use of electricity

 

 

 

 

5.1.6                      Findings and Action Plan

During this audit, the main E&S problems identified by NLFF are shown in table below.

Table 5‑5: Existing Problems in NLFF and E&S Action Plan

No.	Focus	Problem points	Proposal	person in charge	Suggested completion time	Completion index	Compliance status
1	Occupational Health	The occupational hazard declaration for 2022 has not been made.	NLFF should complete the annual occupational hazard declaration as soon as possible	NLFF	4 months	Declaration Record of Occupational Disease Hazards	-
2	Environment	The cofferdam in the temporary storage area for PFOS-containing fire-fighting foam is damaged, unable to prevent seepage and leakage.	NLFF will repair the cofferdam structure before the collecting activities begin	NLFF	1 month	Repair the cofferdam	-
3	Safety	The latest annual inspection of lightning protection devices was conducted in 2021.	Annual inspection of lightning protection devices	NLFF	6 months	Complete the annual lightning protection inspection report	-
4	Labor	NLFF did not establish employee grievance record form.	NLFF to establish an employee grievance record form.	NLFF	1 month	Form a written employee grievance record form.	Rectification is planned to be completed by July 2023.
5	Surrounding communities	NLFF did not publicly disclose the transportation vehicle routes to the surrounding communities	NLFF to disclose the routes of transportation vehicles to surrounding communities through local road bureaus, WeChat official account tweets, bulletin boards and other forms.	NLFF	3 months	Form a written record of transportation vehicles for public disclosure.	Rectification is planned to be completed by September 2023.
6	Emergency management	NLFF did not establish relevant social risk emergency management mechanisms.	NLFF should develop a social risk emergency management mechanism, and provide introduction and training to relevant departments.	NLFF	3 months	Establish written mechanism for emergency management mechanism for social risks and conduct trainings on relevant internal departments.	Rectification is planned to be completed by September 2023.

 

 

 

5.2                      Disposal Company

5.2.1                      Environmental Audit

5.2.1.1                      Environmental Permit

EIA Approval

Guiling was established in September 2017 and is located at 286 Washan Road, Jiaxing Gangqu District, covering an area of 13,351 meters², It is mainly engaged in the disposal of hazardous wastes and the production and utilization of renewable resources. Its business license covers the collecting, transportation, treatment, and disposal of hazardous wastes, as well as environmental engineering and related technical services.

The environmental assessment of the Guiling Special Waste Comprehensive Treatment Center Project (incineration part) was approved by Jiaxing EEB in November 2019 (JGHJ [2019] No. 11), which approved the incineration of 30,000 t/a of hazardous waste. Currently, the operation content of Guiling is consistent with the approved content, without significant changes.

Hazardous Waste Business License

Guiling currently holds a hazardous waste business license issued by Jiaxing EEB. The license number is 3300000270 and is valid from January 3, 2023, to January 2, 2028. The approved business methods include collecting, storage, and disposal. The approved business scale is 30,000 tons/year of hazardous waste incineration. Currently, the Guiling business mode, the type and scale of waste disposed meet the requirements of the hazardous waste business license. The approved hazardous waste categories and other specific contents are shown in the table below.

Table 5‑6: Hazardous Waste Disposal Amount

 

Pollution discharge permit

Guiling currently holds a PDP issued by Jiaxing EEB. The license number is 91330400MA2B81592M001V and is valid from December 16, 2020, to December 15, 2023.

At present, Guiling has a total of 4 air emission stacks, including 2 wastewater outlets, including 1 general plant wastewater outlet and 1 heavy metal wastewater outlet. The safety and environmental protection department of the plant entrusts a third party to conduct annual/monthly/quarterly self-monitoring according to the requirements of the pollution discharge license, and the monitoring content covers wastewater, air emission, noise, groundwater, and soil. The plant maintains monitoring records and environmental management accounts, and regularly prepares quarterly and annual performance reports. Through interviews with Sun Weiqiang, the director of the EHS department, spot checks on relevant monitoring reports and hazardous waste transfer manifest (see 5.2.1.2-5.2.1.6 for specific content), and reviews of the 2022 annual implementation report, it was found that the Guiling pollution management situation meets the requirements of the pollution discharge license.

5.2.1.2                      Wastewater

Currently, there are two wastewater discharge outlets (discharge outlet No. DW001 and No. DW002). The incineration process is adopted for disposal in this project. The incineration wastewater mainly comes from the flue gas treatment process, including the drainage from the acid scrubber and the neutralization. This project involves the testing of PFOS-containing fire-fighting foam, which generates laboratory cleaning wastewater. The wastewater is firstly discharged into the heavy metal wastewater treatment system (discharge outlet No. DW001), and then discharged into the municipal wastewater pipeline through the general plant discharge outlet (discharge outlet No. DW002). The workers' domestic wastewater generated in this project is treated in a septic tank and then discharged into the municipal wastewater pipeline through the general discharge outlet of the plant (discharge outlet No. DW002).

DW003 and DW006 are equipped with continuous emissions monitoring systems (CEMS). The wastewater monitoring report (a wastewater monitoring report from Ningbo Huace Testing Technology Co., Ltd. in September 2022) and the CEMS data during the on-site visit indicate that the discharge concentrations of DW001 and DW002 (1) pollutants meet the requirements of the Class III standard in the Integrated Wastewater Discharge Standard GB 8978-1996, and the Indirect Discharge for Emission Limitation of Nitrogen and Phosphorus for Industrial Wastewater (DB 33/887-2013) Table 1, (2) The frequency of self-monitoring meets the requirements of environmental assessment and PDPs. See table below for details.

Table 5‑7: Test Result and Frequency of Wastewater

Discharge No.	Discharge port name	Pollutant	Result	Standard	Monitoring frequency	Compliance
			Emission concentration （mg/L）	Emission concentration （mg/L）
DW002	Heavy metal wastewater outlet	Total arsenic	0.0002	0.5	Once/quarter	yes
		Total Lead	<0.1	1.0	Once/quarter	yes
		Total mercury	<0.00004	0.005	Once/quarter	yes
		Total cadmium	<0.05	0.1	Once/quarter	yes
		Hexavalent chromium	<0.004	0.5	Once/quarter	yes
		Total chromium	0.0028	1.5	Once/quarter	yes
DW001	General wastewater outlet	Fluoride (calculated as F -)	13.0	20	Once/quarter	yes
		Suspended solids	8	400	Once/quarter	yes
		Petroleum	0.26	20	Once/quarter	yes
		Total nitrogen (in N)	37.1	70	Once/quarter	yes
		BOD5	30.8	300	Once/month	yes
		Adsorbable organic halides	1.43	8	Once/quarter	yes
		Ammonia nitrogen (NH3-N)	<37.1	45	Once/quarter	yes
		Total phosphorus (calculated as P)	0.22	8	Once/quarter	yes
		COD	49.41	500	Continuous	yes
		Ammonia nitrogen	9.53	45	Continuous	yes

5.2.1.3                      Air Emission

At present, there are 4 air emission stacks at Guiling. This project uses the incineration equipment located in the incineration workshop for disposal, which has one incineration line. The flue gas from the incineration line is discharged to the atmosphere through a 50 m stack after passing through the air emissions treatment device (the name of the discharge outlet is 1 # incineration stack, and the number of the stack is DA001). The incineration workshop is equipped with CEMS for air emission monitoring, which can automatically monitor hydrogen chloride, sulfur dioxide, nitrogen oxides, fume, and carbon monoxide contents. In addition to the air emissions outlet of the incineration workshop, this project also involves a laboratory air emissions outlet (DA004).

The monitoring report on air emission (three air emission testing reports from Ningbo Huace Testing Technology Co., Ltd. from October 2022 to November 2022), the public data from the self-monitoring information disclosure platform of the pollution discharging unit in Zhejiang Province, and the CEMS data during the on-site visit indicate that there are organizational air emission outlets (outlet numbers DA001, DA002) and fugitive air emission (plant boundary air emission) in the (1) Emission Standard for Odor Pollutants GB14554, "Pollution Control Standard for Hazardous Waste Incineration GB 18484-2001", "Integrated Emission Standard for Air Pollutants GB 16297-1996"; (2) The frequency of self-monitoring meets the requirements of environmental assessment and PDPs. See the table below for details.

Table 5‑: Test Result of Air Emissions 

Pollution type	Discharge No.	Discharge port name	Pollutant	Result		Standard		Monitoring frequency	Compliance
				Emission concentration （mg/m3）	Discharge rate （kg/h）	Emission concentration （mg/Nm3）	Emission rate （kg/h）
Organized emissions	DA001	1 # incineration air emissions discharge outlet	Ringelmann scale (dimensionless)	<1	N/A	Level 1	N/A	Once/half a year	Yes
			Arsenic compounds	1.0×10-3 – 1.8×10-3	2.3×10-5 – 4.55×10-5	0.5	N/A	Once/month	Yes
			Cadmium compounds	ND	N/A	0.05	N/A	Once/month	Yes
			Chromium compounds	4.5×10-3 - 2.81×10-2	1.11×10-4 – 7.25×10-4	0.5	N/A	Once/month	Yes
			Lead compounds	ND	N/A	0.5	N/A	Once/month	Yes
			Mercury compounds	4.0×10-3 – 9.2×10-3	9.78×10-5 – 2.28×10-4	0.05	N/A	Once/month	Yes
			Thallium compounds	ND	-	0.05	N/A	Once/month	Yes
			nitrogen oxide	151.78	N/A	300	N/A	Continuous	Yes
			Carbon monoxide	3.26	N/A	100	N/A	Continuous	Yes
			Hydrogen fluoride	0.66	-	4.0	N/A	Once/half a year	Yes
			Hydrogen chloride	0.0	N/A	60	N/A	Continuous	Yes
			Sulfur dioxide	0.0	N/A	100	N/A	Continuous	Yes
			Particulate matter	1.531	-	30	N/A	Continuous	Yes
			Dioxins (ng-TEQ/m3)	ND	-	0.5	N/A	Once/half a year	Yes
			Tin, antimony, copper, manganese, nickel, cobalt, and their compounds	0.014 – 0.055	4.70×10-4 – 1.92×10-3	10	N/A	Once/month	Yes
	DA004	4 # exhaust port	Volatile Organic Compounds	0.1	-	70	N/A	Once/quarter	Yes
			Hydrogen chloride	ND	-	10	N/A	Once/quarter	Yes
Fugitive	Plant boundaries	/	Hydrogen chloride	0.06	-	0.15	N/A	Once/quarter	Yes
			Particulate matter	0.248	-	0.5	N/A	Once/quarter	Yes
			Volatile Organic Compounds	0.48	-	4.0	N/A	Once/quarter	Yes
			Odor concentration (dimensionless)	ND	-	20	N/A	Once/quarter	Yes
			Fluoride	0.0013	-	0.02	N/A	Once/quarter	Yes
			Hydrogen sulfide	0.005	-	0.06	N/A	Once/quarter	Yes
			Ammonia	0.03	-	1.5	N/A	Once/quarter	Yes

 

5.2.1.4                      Noise

Noise mainly comes from production equipment including pumps, fans, air compressors, cooling towers, etc. The plant has taken a series of noise reduction measures, including the selection of low noise equipment, sound insulation, vibration reduction, etc.

The noise monitoring report (the monitoring report of Ningbo Huace Testing Technology Co., Ltd. in October 2022) indicates that the noise at the plant boundary complied with the Emission Standard for Industrial Enterprises Noise at Boundary (GB 12348-2008). The plant conducts monitoring four times a year, and the testing frequency meets the environmental assessment requirements.

Table 5‑9: Noise Monitoring Result

Location	Daytime Leq [dB (A)]			Nighttime Leq [dB (A)]
	Level	Standard	Compliance	Level	Standard	Compliance
East boundary	61	65	Yes	52	55	Yes
South boundary	64	65	Yes	54	55	Yes
West boundary	63	65	Yes	53	55	Yes
North boundary	59	65	Yes	52	55	Yes

 

5.2.1.5                      Solid Waste

The solid wastes generated during the operation of the plant mainly include slag, fly ash, waste refractory materials, waste packaging barrels and totes, waste packaging materials, and oil filter elements. They are entrusted to qualified companies outside the site for disposal, with a disposal rate of 100%; And other industrial wastes, including sludge, waste activated carbon, waste mineral oil, lab waste, and waste cloth bags, are sent to the incinerator for incineration and disposal; Domestic waste is collected and disposed of by a municipal sanitation institute.

The hazardous wastes generated during the operation of the plant are classified and stored in the No. 2 Hazardous Waste Temporary Storage Warehouse (Class C), and the domestic waste is temporarily stored in the domestic waste cans in the plant . The temporary storage area for self-produced hazardous wastes in a Class C warehouse is provided with a trench to collect the leaked liquid. The ground and bottom of the drainage ditch are made of impervious and corrosion-resistant hardened ground. The temporary storage room is designed to be closed and equipped with air inlets. The air emission is discharged at high altitude after spraying, washing, demisting, and activated carbon adsorption treatment. The temporary storage room is equipped with a water barrier and warning signs at the entrance. The design of temporary storage and construction of hazardous waste meets the "Standard for Pollution Control of Hazardous Waste Storage GB 18597-2001".

The types, amount, and disposal companies of solid wastes to be disposed of by the plant in 2022 are shown in the following table:

Table 5‑: Solid Waste Type and Generation

No.	Name	Type	Generation in 2022 (t)	Disposal company
1	Slag	Hazardous waste	5,518	Hangzhou Fuyang Shenneng Solid Waste Environmental Recycling Co., Ltd Lanxi Zili Technology Environmental Protection Co., Ltd Zhejiang Huiheyuan Environmental Technology Co., Ltd Zhejiang Feile Environmental Protection Technology Co., Ltd Wenzhou Environmental Development Co., Ltd Zhejiang Runhong Environmental Technology Co., Ltd
2	Fly ash	Hazardous waste	927	Hangzhou Fuyang Shenneng Solid Waste Environmental Recycling Co., Ltd Lanxi Zili Technology Environmental Protection Co., Ltd Zhejiang Teli Renewable Resources Co., Ltd Zhejiang Feile Environmental Protection Technology Co., Ltd
3	Waste packaging drum	Hazardous waste	1212	Zhejiang Yongli Environmental Technology Co., Ltd Shaoxing Yaoda Renewable Resources Utilization Co., Ltd Zhejiang Black Cat God Environmental Technology Co., Ltd Wenzhou Zhuoce Renewable Resources Utilization Co., Ltd. (only handling waste iron barrels)
4	Waste refractory material	Hazardous waste	105	Zhejiang Feile Environmental Protection Technology Co., Ltd Wenzhou Environmental Development Co., Ltd
5	sludge	Hazardous waste	14	Guiling
6	Waste activated carbon	Hazardous waste	10	Guiling
7	Waste mineral oil	Hazardous waste	0.5	Huzhou Jinjie Vein Technology Co., Ltd
8	Analysis and inspection of waste	Hazardous waste	0.1	Guiling
9	Waste packaging	General industrial waste	-	Haining Jiazhou Environmental Protection Technology Co., Ltd Zhejiang Runmiao Renewable Resources Co., Ltd
10	Domestic waste	Domestic waste	-	Environmental sanitation department

5.2.1.6                      Soil and Groundwater

The soil and groundwater monitoring report (the monitoring report of Ningbo Huace Testing Technology Co., Ltd. in September 2022) indicates that a total of 2 soil and 3 groundwater monitoring sites have been set up throughout the plant, and a total of 2 soil samples and 3 groundwater samples have been collected. The laboratory analysis results show that the soil monitoring factors (including mercury, cadmium, lead, arsenic, chromium (hexavalent), copper nickel complies with the Standard for Soil Pollution Risk Control on Construction Land (Trial) (GB 36600-2018); Groundwater monitoring factors (including pH, total dissolved solids, chloride, nitrate nitrogen, fluoride, nitrite nitrogen, ammonia nitrogen, chromium (hexavalent), mercury, cadmium, nickel, lead, arsenic, copper, and zinc) comply with Category III of the Groundwater Quality Standard (GBT14848-2017).

According to the groundwater survey conducted by the plant area of Ningbo Huace Testing Technology Co., Ltd. entrusted by Guiling in September 2022, the key pollutant concentrations of background groundwater in the plant area of Guiling comply with Category III of GB/T14848-2017 "Quality Standards for Groundwater", and the specific results are shown in the table below.

Table 5‑: Annual Monitoring Results of Groundwater

Detection  point	Detection time	Pollutant	Unit	Results (Max)	GB/T14848-2017 Class III Standard	Compliance
Three points in the plant area	2022.11.4 ~2022.11.9	pH	-	7.4 – 7.7	6.2 – 8.5	Yes
		Total dissolved solids	mg/L	256	1000	Yes
		chloride	mg/L	0.52	250	Yes
		Nitrate nitrogen	mg/L	2.46	20	Yes
		Nitrite nitrogen	mg/L	0.104	1.0	Yes
		Ammonia nitrogen	mg/L	0.374	0.5	Yes
		Chromium (hexavalent)	mg/L	0.021	0.05	Yes
		Mercury	mg/L	<0.00004	0.001	Yes
		Cadmium	mg/L	<0.00005	0.005	Yes
		Nickel	mg/L	<0.007	0.02	Yes
		Lead	mg/L	0.0193	0.20	Yes
		Arsenic	mg/L	0.0026	0.05	Yes
		Copper	mg/L	<0.04	1	Yes
		Zinc	mg/L	0.036	1	Yes

5.2.1.7                      Emergency Management

The plant has developed comprehensive environmental plans, special emergency plans, and on-site disposal plans for possible environmental risks, and filed with the Emergency Management Bureau of Jiaxing Gangqu District (Comprehensive Bonded Zone) in June 2021 (filing number: 3304522021014).

The plant has provided corresponding measures according to the plan (leakage prevention measures, such as collecting trenches, collecting cofferdams, and impervious floors); Fire and explosion prevention measures, such as fire extinguishers, fire hydrants, fire alarms, and gas detectors; seepage prevent measures such as yellow sand and absorbent pads); Emergency measures, such as chemical protective clothing and gas masks.

The potential environmental risk of the disposal company of this project is PFOS-containing fire-fighting foam leakage during transportation and disposal, once a leakage occurs, Guiling can react in accordance with the special emergency measures for leakage in the plan: 1) Cut off the pollution source and close the rainwater valve as soon as possible; 2) Emergency response personnel shall wear face shields, chemical protective clothing, shall not directly contact the leakage, and stop the leakage under the condition of ensuring safety; 3) The hazardous waste warehouse and feeder are equipped with drainage ditches, which are connected to the emergency tank in the plant to ensure that the leaked waste liquid is not directly discharged into the environment; 4) Conduct leakage emergency training for transportation staff in advance, if the liquid leaks to the ground during transportation, use activated carbon, linoleum or rags to clean the ground, and the collected leakage and emergency supplies contaminated with leakage are handed over to the hazardous waste treatment unit for disposal; 5) Transportation vehicles and plant areas are equipped with sufficient emergency materials (such as protective clothing, protective gloves, protective masks, linoleum, activated carbon, rags, sandbags, etc.)

The plant has set up an emergency management team, and each department conducts regular drills every year according to the plan requirements. Within past three years, the plant has not experienced any emergency environmental accidents such as fire and leakage.

5.2.2                      Occupational Health Audit

5.2.2.1                      Occupational Health Permit

In June 2019, Zhejiang Jiaxing Hebang Safety Technology Co., Ltd. was entrusted by Guiling to prepare the "Pre-Assessment Report on Occupational hazards of the Guiling Special Waste Comprehensive Treatment Center Project (Incineration Part) of Zhejiang Guiling Technology Co., Ltd.".

After completing the construction and installation of relevant occupational disease prevention facilities for the project, Guiling commissioned Zhejiang Jiaxing Hebang Safety Technology Co., Ltd. in March 2021 to prepare the "Occupational hazard Control Effect Evaluation Report for the Project of Guiling Special Waste Comprehensive Treatment Center (Incineration Section) of Zhejiang Guiling Technology Co., Ltd.". The report conclusion shows that the existing occupational hazard prevention measures are in place and meet the requirements. According to the conclusion of the hazard factor testing report on December 2, 2022, the occupational hazards of all posts in Guiling did not exceed the standard.

Guiling has established an occupational hazard declaration system, stipulating that the occupational health management organization is responsible for reporting or changing to the occupational health management department. In 2022, it conducted an occupational hazards declaration with the registration number of 330482002022240338.

Based on the above information, this audit did not identify any noncompliance issues related to occupational health permitting with Guiling.

5.2.2.2                      Occupational Hazard and Protection

The main occupational hazards of Guiling during production and operation include chemical factors in warehouses, incineration workshops, and wastewater treatment stations (hazard sources: natural gas, sodium hydroxide, sulfuric acid, dioxins, toluene, xylene, methanol, ethyl acetate, fluoride, nitrogen oxides, ammonia, carbon monoxide, carbon dioxide, toxic and hazardous waste, etc.) Hazardous factors such as dust (hazard sources: activated carbon, hazardous waste, incineration fly ash, and slag), noise (hazard sources: noise generated by fans, pumps, and air compressors on the incineration line in the incineration workshop), and high temperature (hazard sources: incinerators and waste heat boilers) in the incineration workshop. Workers may have health problems due to exposure to the above hazardous factors during daily operations.

The occupational disease prevention measures taken by Guiling include:

Dust and toxic matter prevention measures: (1) Mechanization and automation shall be adopted for operation processes and equipment that generate dust and toxic matter to avoid direct worker operation. For example, both the flue gas system and the flue gas treatment system in the incineration workshop are sealed, and a combination of mechanization and automation is used to avoid direct contact between operators; (2) The equipment and pipelines shall be provided with effective airtight measures, and ventilation and purification measures shall be taken in combination with the operation process. For example, the equipment and pipelines in the incineration workshop are sealed, and the feeding port is equipped with mechanical ventilation. The air emissions generated by the reaction kettle is discharged through the closed pipeline and purified. (3) Provide emergency facilities in workplaces that may contain or produce dust and toxins. For example, eyewash and emergency evacuation channels are provided for positions where chemicals are used in incineration workshops and wastewater treatment stations. (4) Employees wear PPE such as breathing masks.

High temperature prevention measures: (1) High temperature equipment and pipelines such as incinerators and waste heat boilers are provided with thermal insulation protection layers to prevent personnel from contacting high-temperature exposed parts. (2) The incineration workshop is mainly equipped with natural ventilation and exhaust facilities to reduce high-temperature hazards. (3) There is an employee lounge in the plant area, which is away from heat sources. (4) When the highest temperature of the day is ≥ 35 degrees Celsius, use fans to cool down the air and reduce the time for high-temperature operations.

Noise reduction measures: (1) Select equipment with low noise. (2) Install vibration damping pads between noise equipment such as air compressors and fans and the foundation to reduce the noise intensity generated during equipment operation. (3) Noise generating workshops and non-noise-generating workshops are arranged separately. (4) Employees wear PPE such as earplugs.

Based on the above information, this audit did not identify any non-compliance issues related to occupational hazards and protection in Guiling.

5.2.2.3                      Occupational Health Surveillance

Guiling has developed an occupational health surveillance management system that requires all employees engaged in operations that are exposed to occupational hazards to participate in occupational health check before, during, and after work. It has established occupational health surveillance files for all employees engaged in operations that are exposed to occupational disease hazards. In 2022, all in-service employees underwent an annual occupational health check, and four employees were found to have occupational contraindications, including noise occupational contraindications and methanol occupational contraindications. Currently, the worker has been transferred to a department that is not exposed to occupational hazards. In addition, the conclusion of the health check report is normal.

Based on the above information, this audit did not identify any non-scrubber issues related to occupational health monitoring in Guiling.

5.2.2.4                      Detection of Occupational Hazard in Workplace

The occupational hazard risks of Guiling belong to the category of "serious". Guiling has developed a plan for the detection and evaluation of occupational hazards in the workplace, commissioned a third-party organization to carry out occupational hazard detection every year, and conducted an occupational hazard status evaluation every three years. According to the "Detection Report on Occupational hazards of Zhejiang Guiling" prepared by Jiaxing Hebang Safety Technology Co., Ltd. in August 2022, chemical factors (such as toluene, xylene, methanol, ethyl acetate, fluoride, nitrogen oxides, ammonia, carbon monoxide, carbon dioxide, toxic and hazardous waste, etc.), power frequency electric fields, high temperatures The detection results of the concentration or intensity of occupational hazards such as noise do not exceed the applicable national occupational health standards.

Based on the above information, this audit did not identify any non-compliance issues related to workplace occupational hazard testing in Guiling.

5.2.2.5                      Occupational Health Training and Emergency Management

The existing environmental health and safety training plan for Guiling has already covered occupational health related content. According to the randomly selected 2022 training records, Guiling has regularly organized employees to participate in training and conducted assessments in accordance with the training plan.

The existing safety emergency plans and emergency plans for unexpected environmental events of Guiling have already covered the content of occupational hazard emergency management. Guiling has established an emergency rescue team in accordance with the requirements of relevant emergency plans. In areas where acute occupational hazards may occur (such as chemical storage areas), emergency rescue equipment and materials such as spray facilities, eye washers, first aid kits, etc. have been equipped. In addition, Guiling has developed an emergency plan drill plan. According to the 2022 emergency drill records checked, Guiling regularly conducted drills according to the plan, and conducted drill summaries and evaluations.

Based on the above information, this audit did not identify any non-compliance issues related to occupational health training and emergency management related to Guiling.

5.2.3                      Safety Audit

5.2.3.1                      Safety Permit

In July 2019, Guiling organized the preparation of the "Safety Pre-Assessment Report for the Guiling Special Waste Comprehensive Treatment Center Project." and obtained an approval. After the completion of the project construction, Guiling organized the preparation of the Safety Acceptance Evaluation Report for the Guiling Special Waste Comprehensive Treatment Center Project in February 2022, and completed the safety acceptance procedures required by laws and regulations. In addition, according to regulatory requirements, Guiling requires a safety evaluation of the company's safety operation conditions every three years.

Since Guiling is mainly engaged in the comprehensive treatment of hazardous wastes, industrial hazardous wastes, and waste packaging materials, and involves the production and operation of hazardous chemicals, it is necessary to apply for a safety production license according to regulatory requirements. The current Zhejiang hazardous waste business license for Guiling is valid on January 2, 2028, meeting regulatory requirements.

In March 2021, Guiling obtained the opinion on fire control acceptance of construction projects issued by Jiaxing City Construction and Transportation Bureau. The project was comprehensively evaluated as qualified through fire control acceptance, meeting regulatory requirements.

5.2.3.2                      Analysis of and Protection from Safety Hazards

The main safety hazards during the operation process of Guiling are fire, explosion (boiler explosion), mechanical injury, scalding, object strike, falling from height, and other non-mechanical hazardous and harmful factors, such as electrical hazards (electric shock), high temperature, poisoning, suffocation, etc.

The safety protection measures taken for Guiling include: (1) various fire protection facilities (fire hydrants, mobile fire extinguishers, etc.), lightning protection facilities, and fire alarm systems are provided, and safety emergency lights should be installed at main passages. (2) The incineration system is equipped with an independent emergency shutdown system. (3) The metal shells of electrical equipment should be grounded or grounded for protection, and metal objects such as the steel structure, exhaust pipe, exhaust pipe, and iron railing in the plant area should be connected by equipotential bonding. Explosion-proof equipment and combustible gas alarm devices are used in areas with explosion risks. (4) The exposed transmission or moving parts of various mechanical equipment shall be equipped with protective covers to avoid mechanical injury accidents. (5) The operating platform in the plant area is provided with safety guardrails and handrails. (6) High temperature equipment and pipelines such as incinerators and waste heat boilers are provided with thermal insulation layers. (7) Obvious safety signs shall be installed in places with potential safety accidents in the workshop.

For example, in the incineration area, there are the following safety facilities: (1) The collecting device is equipped with liquid level detection and alarm; (2) The transmission device of the pump is equipped with protective shields, the building is equipped with lightning protection facilities, and the floor is provided with anti-corrosion and leakage prevention facilities; (3) Explosion-proof electrical equipment and explosion-proof tools are used; (4) Fire hydrants, spray eye washers, and emergency plugging equipment are provided on site Configure anti-corrosion labor protection equipment and hand-held toxic gas alarm; (5) Safety warning signs are set at the site; (6) Insulation layers for pipelines and reactors are set to prevent scalding (7) DCS control system are used for protective power and emergency shutdown device.

5.2.3.3                      Safety Management

The administrative management mode of Guiling is the general manager responsibility system, and the permanent safety management department is the Safety and Environment Department. The Safety and Environmental Protection Department of Guiling Company has 6 safety management personnel, all of whom hold certificates of safety production management personnel for hazardous chemicals within the validity period. Guiling has established a safety production management system and safety operation procedures for each post, and safety management personnel have participated in training as required.

Special operation personnel (such as welders, high-voltage electricians, forklift drivers, and boiler operators) all hold special equipment certificates; There have been no industrial injuries or accidents during operation so far. Entrust a qualified third-party organization to conduct annual testing and maintenance of fire-fighting facilities.

Guiling has established a safety production responsibility system for all employees, and has designated a complete safety management system and safety operation procedures for each position based on the company's situation, which comply with the relevant requirements of the Safety Production Law.

Guiling has prepared special emergency plans for personal injury accidents, fire and explosion accidents, special equipment accidents, typhoon and flood prevention, chemical information leakage, and production safety accidents, all in line with the national " Guidelines for Enterprises to Develop Emergency Response Plan for Work Place Accidents " (GB/T29639-2020) and relevant standards, and submitted application form for the filing of emergency plans for safety accidents in production and business units in June 2021. Obtained the filing certificate from the Emergency Management Bureau of Jiaxing Gangqu District with the filing number of 3304522021013, and the validity period is until June 2024. At the same time, Guiling has developed emergency plan training and drill plans, and conducted safety emergency drills for different types of accidents, keeping training and drill records.

Guiling has entrusted Jiangsu Huayun Lightning Protection Testing Co., Ltd. to test the lightning protection facilities of various buildings and structures in the plant area. Currently, it holds the "Lightning Protection Facility Test Report", with the test report number of JSHY112022HN092-6. The semi-annual inspection has been completed in time.

In February 2023, Guiling entrusted Zhejiang Fang'an Engineering Testing Co., Ltd. to conduct regular inspections of the fire-fighting facilities within the entire plant area, and the inspection results showed they were qualified. The inspection report number was ZJJ202302NO.01497, and the validity period was until February 2024.

Guiling has entrusted multiple qualified companies to regularly verify all special equipment (forklifts, pressure vessels, cranes, elevators, boilers, and pressure pipes) in the plant area, and issued verification certificates. The conclusions indicate the equipment were all qualified, and the verification reports are within the validity period.

5.2.4                      Social Audit

5.2.4.1                      Project Land Use

Guiling is located at 286 Washan Road, Gangqu District, Jiaxing City. Guiling covers an area of 13351 square meters. In 2019, it obtained the real estate certificate issued by Pinghu Municipal Bureau of Land and Resources with the number of (2019) 0006553, and is valid until February 18, 2069, see Appendix C. According to the consultation with the park management committee, the Gangqu District was originally a wasteland when land acquisition was implemented between 1993 and 1994. Due to three decades have passed, the status of land acquisition and resettlement could not be traced. Guiling has not received any complaints against land legacy issues in the past 4 years, and the Gangqu District management committee has not received any land-related complaints in the past 10 years. There are no legacy issues regarding land acquisition, land use restrictions and involuntary resettlement.

5.2.4.2                      Labor and Working Conditions

According to interviews and document reviews between management personnel and production workers, as of January 31, 2023, Guiling had a total of 112 employees; Among them, there are 7 people in the General Manager's Office, 6 in the Safety and Environment Department, 4 in the Finance Department, 2 in the Procurement Department, 27 in the Incineration Production Department, 1 in the HR Department, 16 in the Planning Department, 14 in the Technology Department, 1 in the Personnel Department, 12 in the Equipment Department, 17 in the Marketing Department, 2 in the Project Department, and 3 in the Administration Department. All employees are direct employees with Guiling and have signed labor contracts. One employee of Guiling is from a minority ethnic group. The employee is of Hui ethnic group, 31 years old, and a worker of the production department. There is no significant difference in the worker’s eating habits other than not eating pork from the Han ethnic group, and there is no special custom. The youngest employee from Guiling is 20 years old.

According to interviews and document reviews between management personnel and production workers, the working hours of Guiling management personnel are: 8:30-11:30, 12:30-17:00, working 5 days a week and taking 2 days off; There are 24 production workers in three groups and two shifts (that is, production workers are divided into three groups, with more than 8 people in each group, and a two-shift work system is implemented). The day shift work hours are 8:30-20:30, and the night shift work hours are 20:30-8:30. Guiling adopts a comprehensive working hour system. Generally, overtime pay is calculated at 150% of the normal salary, and on weekends, it is calculated at 200% of the normal salary. However, at present, the company has not obtained a comprehensive working hour system approval approved by the local government.

During this audit, production workers of Guiling were interviewed and their labor contracts, personal files, attendance records, salary payment records, and social insurance purchase vouchers were randomly audited. According to the minimum wage standard updated in 2021 in Jiaxing City, which is 2,070 CNY/month, the salaries of Guiling employees significantly exceed this standard (the total salary of frontline employees is 5,500-6,000 CNY/month). In addition to the basic salary, Guiling has a monthly full attendance bonus of 200 CNY and a monthly high-temperature subsidy of 300 CNY from June to September. In addition to salary, Guiling also provides holiday gifts, transportation subsidies, housing subsidies for employees from other places, and other benefits to its employees.

During this audit, through document review and on-site interviews, it was found that child labor, underage employees, gender discrimination, harassment, and forced labor were not present. Guiling has established clear written social responsibility management procedures for anti-discrimination, anti-harassment, and prohibition of forced labor. According to management personnel and production worker interviews, both female and male employees receive equal treatment in terms of salary, training, promotion, and career development. In addition, Guiling employees enjoy the benefits stipulated in the national labor law. The specific benefits enjoyed by female employees are as follows:

·       Enjoy maternity leave in accordance with the law, avoid arranging physical labor during pregnancy, and transfer positions if necessary;

·       On International Women's Day on March 8th, there is a half day holiday and small gifts are given;

·       Enjoy employee health checks and include female specific health checks.

In the plant area of Guiling, there is a staff restaurant (without a kitchen, with external delivery) to facilitate the dining of employees, providing free breakfast, lunch, and evening meals for workers, and providing free midnight snack for night shift workers. According to interviews between management personnel and production workers, most Guiling workers are local residents, and most of them reside in their local homes. There are no dormitories in the plant area. Guiling provides employees with free public rental housing outside the plant area. The public rental housing is 6-7 kilometers away from the plant area. Most employees travel by electric scooters, and the daily commuting time is 15 minutes per trip.

5.2.4.3                      Impact on Surrounding Communities

The area where Guiling is located is the Gangqu District of Jiaxing City, surrounded by other factories, and there are no community residents within 500 m of the site. According to the field audit, there are no environmentally sensitive points within 500 m of the Guiling. Therefore, the impact of Guiling operations on surrounding communities is very limited.

Guiling’s environmental protection acceptance monitoring report was disclosed on the public information platform of Zhejiang Qiushi Environmental Monitoring Co., Ltd. in July 2021, where no feedback was received from the public or surrounding communities during the disclosure period. According to the interview with management personnel, the transportation vehicle route was not disclosed by Guiling. It is suggested that Guiling to disclose the transportation route through public channels such as WeChat official account, bulletin boards, etc.

5.2.4.4                      Ethnic Minorities

Guiling is located in Jiaxing Gangqu District. According to on-site audits and interviews with management personnel, this area is not inhabited by ethnic minorities, and the project land does not involve ethnic minorities. Therefore, this demonstration project does not involve the impact on ethnic minorities.

5.2.4.5                      Grievance Redress Mechanism

(1)        Employee Grievance Redress Mechanism

Guiling has established an employee (internal) grievance mechanism, and employee grievance channels are divided into the following four types:

a.       Employees are free to file grievances with the leaders in charge. If the leader in charge is unable to coordinate, it shall be reported to the HR manager, who shall make decisions. If the HR manager is unable to coordinate, it will be reported to the general manager, who will make the final decision;

b.       Guiling has established a labor union, and employees are free to file grievances to the labor union;

c.       Employees are free to file grievances to the company's suggestion box. The suggestion box is located at the door of the company and is opened once a half month;

d.       Employees are free to file grievances with the HR Manager of the company.

Upon receipt of a grievance, it is necessary to quickly review the grievance and coordinate and communicate with the complainant and the leader in charge on the grievance handling opinions. According to interviews with managers and production workers, if necessary, employees verbally complain to their leaders, and their leaders would then handle their comments, feedback, and concerns on-the-spot, therefore, no written grievance record is required. If no internal coordination within the company is not possible, it is recommended that employees go through judicial procedures. According to the interview, there are currently no cases where employees have filed grievances. Guiling has provided a sample employee grievance record form. If an employee grievance occurs, the grievance will be recorded.

(2)       Community Grievance Redress Mechanism

Guiling has not established a community (external) grievance mechanism. According to interviews with management personnel, the surrounding communities have not complained about Guiling. Guiling was assisted to establish a community grievance mechanism (see Chapter 9 for details).

5.1.4.6 Emergency management

According to consultations with management personnel and document reviews, Guiling has not developed a social risk emergency management mechanism. It is recommended that the company to establish a social risk emergency management mechanism and establish an emergency work leadership command center, establish an efficient information network, strengthen monitoring of unstable social factors, and conduct a comprehensive evaluation and prediction of information that may lead to large-scale group events, especially early warning information. The social risk emergency management mechanism should enable the company to achieve early detection, early reporting, early control, and early resolution of any potential social risks. Sound mechanisms should be developed for investigating and mediating conflicts and disputes, increase efforts to investigate conflicts and disputes that may trigger group incidents, identify potential issues that may trigger group incidents, and actively work with relevant government departments to resolve conflicts, and promptly report relevant information and work situations. It is recommended that the company to add the following content to its existing social management mechanisms to form a comprehensive social risk emergency management mechanism:

·       Establish a communication mechanism with surrounding community management committees;

·       Establish communication mechanisms with relevant local security government departments;

·       Develop an internal handling process to address social risks;

·       Develop an early warning plan to address social risks, such as conducting relevant visits, investigations, and summarizing issues reported by the public in response to emerging social risk information.

5.2.5                      Management System

Guiling has established an internal environment, occupational health, safety operation, and social management system in accordance with relevant Chinese laws and regulations. The current management structure of Guiling is shown in the figure below. The Safety and Environment Department, Administration and HR and General Manager’s Office take responsibility for daily E&S management.

Figure 5‑2: Management System and Organization Chart

The main departments responsible for E&S management are listed as follows:

Safety and Environment Department

The company has established a Safety and Environment Department to take charge of the company's environmental management work, with a total of 6 people, including 1 full-time environmental management personnel, equipped with environmental management personnel and monitoring personnel with professional knowledge and skills, as well as various monitoring and analysis instruments. The main responsibilities are: 1) to implement the Environmental Protection Law of the People's Republic of China and relevant laws and regulations at the beginning, formulate environmental management rules and regulations in accordance with national environmental policies, environmental standards, and environmental monitoring requirements, and supervise the implementation; 2) Master the technical measures for pollution control, equipment operation and maintenance, stay updated with the condition of comprehensive utilization of waste, and establish pollution control management files; 3) Check the operation of the company's environmental protection equipment, lead and organize the company's environmental monitoring work, develop emergency prevention measures, promptly take measures and monitor pollution in case of abnormal pollution, analyse and summarize experiences and lessons, and eliminate pollution accidents. 4) Develop emission indicators for various pollutants in the production process and operational indicators for environmental protection facilities and conduct regular assessment; 5) Promote the application of advanced environmental protection technology and equipment, organize professional technical training on environmental protection of the company, promote and improve the environmental protection awareness of all personnel on site. 6) Supervise the installation and commissioning of environmental protection equipment of the company, stick to the principle of "Three Simultaneities", and ensure that the design, construction, and operation of environmental protection facilities are carried out simultaneously with the main works.

Administrative and HR

The relevant responsibilities of the Administration and HR department in E&S management include labor management, including improving the human resources management systems, implementing compensation system, handling employee relations, managing the registration of employee files (including occupational health files), and arranging employee accommodation.

General Manager's Office

The relevant responsibilities of General Manager's Office in E&S management are to handle external grievance reception and coordinate the handling of work.

Guiling has developed a series of E&S management systems, covering subjects such as risk identification, risk mitigation measures formulation and implementation, and emergency response. The main E&S management systems include:

·       Safety operation regulations

·       Safety management system

·       Emergency rescue plan

·       On-duty system

·       File management system

·       Manifest Management System

·       Vehicle equipment maintenance and repair system

·       Management system of overall safety production responsibility system

·       Three Simultaneous Management System

·       Contractor Safety and Environmental Management Procedure

·       Anti-discrimination and anti-harassment procedure document

·       Regulations on Prohibition of Forced Labor

·       Employee handbook