Environmental Assessment Report - World Bank · Changshu 3F Zhonghao New Chemical Materials Co., Ltd (hereinafter called ‘Changshu 3F Zhonghao’) established in 2001 is a subsidiary

Environmental Assessment Report

HFC-23 Emissions Reduction

at Changshu 3F Zhonghao New Chemical Materials Company

November 18, 2005

China Green Enterprise Limited

Chinese Research Academy Of Environmental Sciences

E1244v. 2

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

i

Table of Contents

1 Introduction ....................................................................................................................... 1

2 Project Settings .................................................................................................................. 3

2.1 Information about the Company .................................................................................. 3

2.2 Information about the Site and Its Surroundings ......................................................... 4

2.3 Environmental Characteristics ..................................................................................... 9

2.3.1 Geology and Topography .................................................................................. 9

2.3.2 Climate and Ambient Air Quality...................................................................... 9

2.3.3 Hydrogeology and Ambient Water Quality..................................................... 10

2.3.4 Noise Levels .................................................................................................... 11

2.3.5 Soil .................................................................................................................. 12

2.3.6 Other Environmental Characteristics .............................................................. 12

3 Descriptions of the HCFC-22 Production and HFC-23 Destruction Processes......... 13

3.1 Description of the HCFC-22 Process ......................................................................... 14

3.1.1 HCFC-22 Process at Lines A and B ................................................................ 14

3.1.2 Source, Treatment, and Discharge of Pollutants ............................................. 17

3.2 Description of the HFC-23 Process............................................................................ 19

3.2.1 Basic Information............................................................................................ 19

3.2.2 HFC-23 Emissions Reduction Process............................................................ 19

3.2.3 Operation and Maintenance Schedule............................................................. 22

3.2.4 Investment Cost............................................................................................... 23

4 Regulatory and Institutional Framework ..................................................................... 24

4.1 Regulatory Framework............................................................................................... 24

4.1.1 Relevant Laws, Regulations, and Technical Guidelines of China .................. 24

4.1.2 Relevant Legal Requirements and Regulations for the Jiangsu Province....... 25

4.1.3 Relevant Technical Documents for Changshu ................................................ 26

4.1.4 Relevant Provisions of the World Bank .......................................................... 26

4.1.5 Applicable Environmental Discharge and Ambient Quality Standards .......... 27

4.1.6 Applicable Standards Related to the Design and Operation of Hazardous

Waste Facilities............................................................................................... 32

ii

4.2 Institutional Framework ............................................................................................. 34

4.2.1 Foreign Economic Cooperation Office, State Environmental Protection

Administration (SEPA/FECO) ....................................................................... 34

4.2.2 Jiangsu Environmental Protection Bureau ...................................................... 34

4.2.3 Suzhou Environmental Protection Bureau ...................................................... 34

5 Environmental Discharges from the HFC-23 Reduction Process and Mitigation

Measures......................................................................................................................... 36

5.1 Environmental Discharges from the HFC-23 Reduction Process .............................. 36

5.1.1 Construction Phase.......................................................................................... 36

5.1.2 Operational Phase............................................................................................ 37

5.2 Mitigation Measures................................................................................................... 40

5.2.1 Construction Phase.......................................................................................... 40

5.2.2 Operational Phase............................................................................................ 41

6 Impacts of Discharges on Receptors.............................................................................. 44

6.1 Construction Phase..................................................................................................... 44

6.2 Operational Phase....................................................................................................... 45

6.2.1 Air Impact Assessment .................................................................................... 45

6.2.2 Wastewater Impact Assessment....................................................................... 57

6.2.3 Groundwater Impact Assessment .................................................................... 57

6.2.4 Solid Waste Impact Assessment ...................................................................... 57

6.2.5 Noise Impact Assessment................................................................................ 57

6.2.6 Social Impacts ................................................................................................. 59

7 Evaluation of Alternatives .............................................................................................. 61

7.1 Evaluation of Alternative Process Options for HFC-23 Emissions Reduction.......... 61

7.2 Evaluation of Alternatives for Emission Controls of Air Pollutants under Upset

Process Conditions ..................................................................................................... 62

7.3 Evaluation of Alternatives for the Wastewater and Sludge Discharges ..................... 65

8 Process Safety and Emergency Measures ..................................................................... 69

8.1 Process Safety ............................................................................................................ 69

8.2 Prevention and Control of Air Emissions of Pollutants ............................................. 73

8.3 Spill Prevention, Containment, and Countermeasures............................................... 74

8.4 Personnel Protection................................................................................................... 74

8.5 Emergency Preparedness and Countermeasures ........................................................ 74

9 Environmental Management Plan ................................................................................. 76

iii

9.1 Environmental Management ...................................................................................... 76

9.2 Environmental Monitoring Plan................................................................................. 78

10 Public Consultation ......................................................................................................... 82

10.1 Public Consultation for ToR of the EA .................................................................... 82

10.1.1 Information of Public Consultation for ToR of the EA................................. 82

10.1.2 Results of the Public Consultation for ToR of the EA .................................. 84

10.2 Public Consultation for the Draft EA....................................................................... 86

10.2.1 Information of Public Consultation for the Draft EA ................................... 86

10.2.2 Results of the Public Consultation for the Draft EA..................................... 88

Annex 1 ToR for Environmental Assessment of HFC-23 Emissions Reduction at

Changshu 3F Zhonghao ...................................................................................... 90

Annex 2 Distribution Map of Monitoring Points (Air and Surface Water) and

Ambient River System ........................................................................................ 94

Annex 3 Descriptions of the Relevant Chinese Regulations............................................ 95

Annex 4 HFC-23 Generated from the HCFC-22 Process................................................ 96

Annex 5 Material Balances for the HFC-23 Emissions Reduction Process ................... 97

Annex 6 Official Letter about the Conduct of Public Consultation on the ToR of the

EA ....................................................................................................................... 102

Annex 7 Records of the Consultation Meeting on the ToR of the EA .......................... 104

Annex 8 Official Letter about the Conduct of Public Consultation on the Draft EA. 109

Annex 9 Records of the Consultation Meeting on the Draft EA....................................111

Annex 10 Certificate of Land Use Right: Line A of the HCFC-22 Process.................. 117

Annex 11 Certificate of Land Use Right: Line B of the HCFC-22 Process.................. 118

Annex 12 List of EA Preparers ........................................................................................ 119

iv

List of Tables

Table 2-1 Chemical Products and Intermediates Produced by Changshu 3F Zhonghao and Changshu 3F Fluorochemical .................................................................. 3

Table 2-2 Changshu 3F Zhonghao’s Assets, Revenues, and Profits (million US$) ........ 3

Table 2-3 Parameters of Multi-year Weather Condition of the Plant Site....................... 9

Table 2-4 Ambient Air Quality Monitoring Results...................................................... 10

Table 2-5 Monitoring Results of Surface Water Quality (Unit: mg/l, except pH) ..... 10

Table 2-6 Monitoring Results of Ground Water Quality............................................... 11

Table 2-7 Monitoring Results of Acoustical Quality (Unit: dB(A)) .......................... 11

Table 2-8 Monitoring Results of Soil Quality (Unit: mg/kg)..................................... 12

Table 3-1 Design Parameters of HFC-23 Incinerator.................................................... 22

Table 3-2 Consumption of Main Raw and Auxiliary Materials and Energy................. 22

Table 4-1 Applicable Air Emissions Standards ............................................................. 27

Table 4-2 The Receptors for Air Emissions from the Project ....................................... 28

Table 4-3 Applicable Air Quality Standards ................................................................. 29

Table 4-4 Applicable Wastewater Discharge Standards................................................ 29

Table 4-5 The Receptors of Wastewater Discharge from the Project............................ 30

Table 4-6 Applicable Water Quality Standards ............................................................. 30

Table 4-7 Applicable Quality Standard for Ground Water............................................ 30

Table 4-8 Applicable Noise Emission Standards .......................................................... 31

Table 4-9 Applicable Quality Standard for Noise ......................................................... 31

Table 4-10 Applicable Quality Standard for Soil .......................................................... 32

Table 4-11 Technical Specifications of Incinerators ..................................................... 32

Table 5-1 Noise Source Strength of the Construction Equipment ................................ 37

Table 5-2 Material Balances of HFC-23 Process (Unit: tpy) ..................................... 38

Table 5-3 Environmental Discharges from HFC-23 Process ........................................ 40

Table 5-4 Levels of Noise Emissions from Major Process ........................................... 40

Table 5-5 Noise Pollution Mitigation Measures and Their Effectiveness..................... 43

Table 6-1 Impacts of Discharges on Receptors during Construction Phase.................. 44

Table 6-2 Compliance Status of Construction Equipment Noise.................................. 44

Table 6-3 Characteristics of the Air Dispersion Models ............................................... 45

Table 6-4 Parameters of Waste Gas Pollution Source ................................................... 48

Table 6-5 Average Weather Parameters of Different Stability Conditions.................... 48

v

Table 6-6 Meteorologic Conditions on Representative Days........................................ 49

Table 6-7 Maximum Ground-Level Concentration (1-hr avg.) and Distance during Windy Conditions......................................................................................... 50

Table 6-8 Maximum Concentration (1-hr avg.) at the Receptors during Windy Conditions (µg/m3) ....................................................................................... 51

Table 6-9 Maximum Ground-Level Concentration (1-hr avg.) and Distance during Stagnant Atmospheric Conditions ................................................................ 52

Table 6-10 Daily Average Concentration at the Receptors on Representative Days (µg /m3) ............................................................................................................... 54

Table 6-11 Information of the Noise Sources................................................................ 58

Table 6-12 Noise Simulation Results at Changshu 3F Zhonghao’s Boundary in Daytime (Unit: dB(A)) ................................................................................. 59

Table 6-13 Noise Simulation Results at Changshu 3F Zhonghao’s Boundary at Night (Unit: dB(A))................................................................................................ 59

Table 7-1 Comparison of the Options for HFC-23 Emissions Reduction..................... 61

Table 7-2 Comparison of the Options for Emission Controls of Air Pollutants............ 64

Table 7-3 Cost Comparison of the Options for Emission Controls of Air Pollutants ... 64

Table 7-4 Comparison of the Options for Wastewater and Sludge Discharges............. 67

Table 7-5 Cost Analysis of Option 2 ............................................................................. 67

Table 8-1 Process Hazard Analysis ............................................................................... 71

Table 9-1 Staff Training Plan for HFC-23 Emissions Reduction Project ..................... 78

Table 9-2 Pollutants Discharge Monitoring Plan for the Operational Phase ................ 79

Table 9-3 Ambient Quality Monitoring Plan for the Pilot Testing and Operational Phase............................................................................................................. 80

Table 9-4 Analytical Methods for Pollutant Parameters ............................................... 81

Table 10-1 Questionnaire for the ToR of the EA .......................................................... 83

Table 10-2 Information of the Residents Involved in This Investigation...................... 84

Table 10-3 Statistic Results of All Questionnaires ........................................................ 85

Table 10-4 Questionnaire for the Draft EA................................................................... 87

Table 10-5 Information of the Residents Involved in This Investigation...................... 88

Table 10-6 Statistic Results of All Questionnaires ........................................................ 89

vi

List of Figures

Figure 2-1 The Geographic Position Map of Changshu 3F Zhonghao New Chemical

Materials Co., Ltd. in China.......................................................................... 5

Figure 2-2 The Geographical Position Map of the Proposed Project in Changshu City 6

Figure 2-3 The Surroundings of the Proposed Project .................................................... 7

Figure 2-4 The Site Plan for Changshu 3F Zhonghao’s Production Facilities................ 8

Figure 3-1 The Plain Layout of Changshu 3F Zhonghao.............................................. 14

Figure 3-2 Treatment of Process Wastewaters at Changshu 3F Zhonghao................... 18

Figure 3-3 Flow Diagram of HFC-23 Emissions Reduction Process ........................... 20

Figure 6-1 Contour Map of 1-day Average Concentration of Fluoride on

Representative Days................................................................................... 55

Figure 6-2 Contour Map of 2-day Average Concentration of Fluoride on

Representative Days................................................................................... 55

Figure 6-3 Contour Map of 1-day Average Concentration of HCl on Representative

Days............................................................................................................ 56

Figure 6-4 Contour Map of 2-day Average Concentration of HCl on Representative

Days............................................................................................................ 56

Figure 7-1 Process Flow Diagram of a Parallel Gas Cleanup System.......................... 63

Figure 7-2 Process Flow Diagram for the HFC-23 Project with Gas Storage Tanks.... 64

Figure 7-3 Process Flow Diagram of the Newly-Built Special WWTP........................ 66

Figure 9-1 Organization of Environmental Management for the Proposed Project...... 76

vii

List of Abbreviations

AHF Anhydrous Hydrogen Fluoride CDM Cleaning Development Mechanism CFCs Chloroflurocarbons Changshu 3F Zhonghao Changshu 3F Zhonghao New Chemical Materials

Company EA Environmental Assessment EIA Environmental Impact Assessment EMP Environmental Management Plan EPB Environmental Protection Bureau FCIP Jiangsu Hi-tech Fluorochemical Industrial Park GHG Green House Gas GWP Global Warming Potential HCFC-21 Fluorodichloromethane(or CHCl2F) HCFC-22 Chlorodifluoromethane (or CHClF2) HCFCs Hydrochlorofluorocarbons HFC-23 Trifluromethane (or CHF3) HFC-32 Difluoromethane (or CH2F2) HFCs Hydrofluorocarbons IPCC Intergovernmental Panel on Climate Change LNG Liquefied Natural Gas OP/BP/GP Operational Policy / Bank Procedure / Good Practices PDD Project Design Documents RMB Official Currency of People's Republic of China SEPA State Environmental Protection Administration SEPA/FECO Foreign Economic Cooperation Office, State

Environmental Protection Administration ToR Terms of Reference TWP The Third Water Plant of Changshu City UNEP United Nations Environment Programme WWTP Wastewater Treatment Plant

HFC-23 Emissions Reduction Project at Changshu 3F Zhonghao New Chemical Materials Company

China Green Enterprise Limited 1

1 Introduction

Changshu 3F Zhonghao New Chemical Materials Co., Ltd (hereinafter called ‘Changshu 3F Zhonghao’) established in 2001 is a subsidiary company of Shanghai 3F New Chemical Materials Co., Ltd., located in Jiangsu Hi-tech Fluorochemical Industrial Park. Changshu Refrigerants Factory founded in 1975 is the predecessor of Changshu 3F, and Changshu 3F Fluorochemical Industry Co., Ltd established in 1993 is the successor. Changshu 3F is a large-scale chemical enterprise with three chlorodifluoromethane (HCFC-22) production facilities and one CH2F2 (HFC-32) production facilities, which mainly produce series of fluoro-refrigerant. It has passed environmental management system certification and ISO9000 certification, awarded ‘advanced enterprise of protecting ozone layer’ by the State Environmental Protection Administration (SEPA), and been one of key enterprises in organic fluoric industry at national level.

Hydrochlorofluorocarbons (HCFCs) are controlled substances under the Montreal Protocol, and should be completely phased out before 2040 in the developing countries. However, domestic demand in China for HCFC-22 will be expanded in a certain period with accelerated phase-out of chloroflurocarbons (CFCs). Meanwhile, the organic fluorine products in China are expected to increase at an annual rate of 12%. This will also promote the development of HCFC-22 production. Therefore, it can be foreseen that the trifluromethane (HFC-23 or CHF3) emission will also be continuously increased. HFC-23 has a low toxicity but with a large Global Warming Potential (GWP =11,700 in the IPCC 2nd Assessment Report). Emissions of hydrofluorocarbons (HFCs) are controlled under the Kyoto Protocol. So far, there is no regulation at the national or local level to restrict the emissions of HFC-23 in China. It is unlikely that China would impose any limits on its HFC-23 emissions in the near future. Therefore, almost all the HFC-23 in China is directly released to the atmosphere uncontrolled. Changshu 3F Zhonghao voluntarily implements this Cleaning Development Mechanism (CDM) project to install a HFC-23 destruction system at its currently operating HCFC-22 production facilities. The system can collect and destroy HFC-23 and other by-products generated during HCFC 22 production. Therefore, the implementation of this project can reduce HFC-23 emissions from Changshu 3F Zhonghao, which would contribute to the mitigation of global warming. Meanwhile, the project will also contribute to create direct and indirect employment at the local level.

Pursuant to the related provisions in the Environmental Protection Law of the People's Republic of China, the Law of the People's Republic of China on the Environmental Impact Assessment, the Regulations on Environmental Management of Construction Project (Decree No.253 of the State Council) as well as Operational Directives of World Bank [4.01], Changshu 3F Zhonghao entrusted China Green Enterprise Limited to conduct an Environmental Assessment (EA) for ‘HFC-23 Emissions Reduction at Changshu 3F



Zhonghao New Chemical Materials Co., Ltd.’. EA for this project should not only conform to China’s EA requirements, but also meet with World Bank’s (WB) EA requirements. This EA follows the consultant Terms of Reference (ToR, see Annex 1) prepared by the World Bank, and agreed among Changshu 3F Zhonghao, the EA consultants and SEPA.

This project is classified by the World Bank as a Category A project for EA purposes. Therefore, this EA has been prepared to meet the World Bank’s and China’s EA requirements. The objectives of the EA are to:

Identify current status of the environmental quality and socio-economic characteristics of the project’s surrounding areas;

Identify pollutant types, sources and discharge points to the environment; and

through engineering analysis, analyze the feasibility of measures to prevent or control pollution;

Predict and analyze the extent of the impacts of the pollutants discharges from the

project to the surrounding areas;

During the process of implementing EIA, we received valuable guidance from WB, Jiangsu Environmental Protection Bureau, Suzhou Environmental Protection Bureau and Changshu Environmental Protection Bureau, as well as strong support and concerted cooperation from Changshu 3F Zhonghao. We should like to thank them for their great efforts in this project



2 Project Settings

2.1 Information about the Company

Changshu 3F Zhonghao New Chemical Materials Company Ltd. and Chanshu 3F Fluoorochemical Industry Company Ltd. are joint stock (private) companies involved in the research, development and manufacture of fluorine-containing polymers and chemicals, and freon and halon substitutes. In 1993, Shanghai 3F, which was established in 1975, invested in Changshu Refrigeration Company, with the subsequent change of the name of latter company to Changshu 3F Fluorochemical Industry Company. Changshu 3F Zhonghao was established in October 2001. The chemical products and intermediates currently produced by Changshu 3F Zhonghao are shown in Table 2-1.

Table 2-1 Chemical Products and Intermediates Produced by Changshu 3F Zhonghao and Changshu 3F Fluorochemical

Chemical Products Chemical Intermediates Changshu 3F Zhonghao HCFC-142b

HFC-32 HFC-125 HCFC-22 C-318 HFC-227ea

Anhydrous hydrogen fluoride (AHF) HFC-152a TFE TFP

Changshu 3F Fluorochemical HCFC-141b CFC-113a HFC-143a

CFC-113 CTFE

Since early 2000s, Changshu 3F Zhonghao has expanded in terms of assets, revenues, profits (Table 2). About 60 percent of the company’s production is exported: 27 percent to the United States, 9 percent to Europe, 9 percent to the Middle East, 6 percent to Japan, 6 percent to Southeast Asia, and 3 percent to South America.

Table 2-2 Changshu 3F Zhonghao’s Assets, Revenues, and Profits (million US$)

Years Assets Revenues Profit 2005 92 122 20 2004 85 95 13 2003 55 46 5.6 2002 13 23 1.4 2001 7.3 1.8 /



2.2 Information about the Site and Its Surroundings

The company’s headquarters and Changshu 3F Zhonghao (including its HCFC-22 production facilities) are located 20 km north of Changshu City in the Jiangsu Province1 within the Jiangsu Hi-Tech Fluorochemical Industrial Park, and Changshu 3F Fluorochemical is located 5 km west of this Industrial Park (Figures 2-1 and 2-2). The number of employees at Changshu 3F Zhonghao was 800 in 2004 and is 916 in 2005.

The Industrial Park, which covers an area of 5.2 km2, was established by the Government in October 1999 on a reclaimed land from the former bed of the Yangtze River. The surroundings of Changshu 3F Zhonghao’s production site are shown in Figure 2-3.Currently, the industrial park includes 10 companies, all of which are fluorochemical companies. Changshu 3F Zhonghao has 443 mu (229,000 m2) of land reported to have been legally acquired without getting involved in any resettlement issues at the Industrial Park. In addition, four other companies at the Industrial Park are of large size: (i) Atofina (Changshu) Fluorochemical Company Ltd.; (ii) DuPont Fluorochemical Company, (iii) Changshu 3F Chemical Industry Company Ltd., and iv) Daikin Fluorochemical Company. The Industrial Park is easily accessible from the Riverside Expressway (i.e. Class 1 Highway) in the south. There are no residences in the industrial park, except for a dormitory which houses the employees and their families who come to the Changshu 3F Zhonghao site for a short-period of training and accommodation for night-shift workers.

The site plan for CHangshu 3F Zhonghao is shown in Figure 2-4. A cooling water pond in the south-central part within the Changshu 3F Zhonghao site, adjacent to its southern border, feeds into a circulating cooling water canal that goes along the southwestern, western, and northwestern boundaries of the plant site. The immediate land uses around the plant site are as follows:

• North: Reclaimed land with no current use, except for a coal ash disposal site. There is a plan to convert this area for industrial use.

• East: Fushan Pond and then land reserved for Changshu 3F Zonghao and Dupont. • South: Changfu Road, Fushan Pond and then Atofina (Changshu) Fluorochemical

Company Ltd. Residential areas near Changshu 3F Zhonghao’s site are Fushan Town (with a population of 3,000-4,000, 2 km south of the Industrial Park), Dengshi (with a population of 1,200, 3.7 km southeast of the project site), and Wangshi Town (with a population of 21,000, 5.7 km southeast of the Industrial Park). The nearest school (the Fushan Center Elementary School) and hospital (Fushan Hospital) are both 4 km to the west of the Industrial Park. There are no minorities or historical relics around the Industrial Park. There are no critical natural habitats close to the plant site. 1 Changshu City is approximately 90 km northwest of Shanghai.



Figure 2-1 The Geographic Position Map of Changshu 3F Zhonghao New Chemical Materials Co., Ltd. in China



Figure 2-2 The Geographical Position Map of the Proposed Project in Changshu City



Note: FCIP means “Jiangsu Hi-tech Fluorochemical Industrial Park”.

Figure 2-3 The Surroundings of the Proposed Project



Gate Maintenance Workshop,Hardware Bin

The Proposed Project

N

Noise Monitoring Point

Refrigeration Room

Recirculated Water

Pumping Station

Refrigeration W

orkshop

Living Area

Power Station

Office B

uilding

Operating R

oom

Subpackage Station

Calcium Bicarbonate

Warehouse Bicarbonateion Storehouse

Mountain Meal Storehouse

Storehouse

Fushan Pond

Chang Fu Road

Scale

Car Shed

HCFC-22 Line B

Control Room

Sewage Tank

Store BinAHF Generative Device

Control R

oom

Mountain Meal Storehouse Store Bin

Recycled Water System

Raw Material Breaking

Air CollectorAcetylene Generating

Compression

Switch Station

Air Collector

Store Tanks Area

10000t HFC-152a

Refrigeration Workshop

HFC-152A Device

(10KV Switching Room)

Refrigeration-15c

HFP F125 TFE

Control Room

Control Room

F142b Device

River

Office Building

Dining Hall

Dormitory

R227 Workshop

Control Room

R125 Workshop

Refrigeration Room

Laboratory

Car Shed

Boiler H

ouse

Stack

RiverPure Water Station

10t/hr Boiler

1860M2 Mountain Meal Bin

Storage Bin

Transformation Station

Refrigeration Workshop

Master-control Room

AHF Main Building

AHF Generative Device

AHF Generative Device

Storage Bin

Recycled Water Pump House

Transformation Station

Incinerator Station

HCFC-22 Line A

Figure 2-4 The Site Plan for Changshu 3F Zhonghao’s Production Facilities



2.3 Environmental Characteristics

2.3.1 Geology and Topography

Geology: According to geological data, the line from Changhu River to Xuliujing is divided into four layers of which the first layer is mild clay and interbedded thin-layer silty sand of 16 cm depth, and the surface layer is muddy mild clay of about 2m depth, the second layer is light loam of 6cm depth; the third layer is powdered fine sand of 1.9cm; the fourth layer is mild clay and clay. The compression deformation performance of the first, second and fourth layer is poor.

Topography: Changshu is featured by cross water network and a flat topography with a slight decline from northwest to southeast. The areas along Yangtze River belong to river plain if divided in terms of tiny topographical structure。Generally, the elevation there is 4.5-5.5m, and local regions 6m, and bank along river 6.5-7.5m.

2.3.2 Climate and Ambient Air Quality

2.3.2.1 Climate

Changshu 3F Zhonghao is located in subtropical southern humid climate with prevailing monsoon wind and flush rainfall. According to the statistics of multi-year weather information, the main parameters of weather condition are identified in Table 2-3 below.

Table 2-3 Parameters of Multi-year Weather Condition of the Plant Site

Items Spring Summer Autumn Winter Average Average 14.8 27.9 17.4 2.8 15.5 Maximum Temperature

19.8 31.8 22.1 6.9 19.8 Temperature (oC)

Minimum Temperature

10.6 4.7 13.7 -0.3 12

Pressure (hpa) Average 1014.8 1003.8 1019.7 1026.3 1016.4 Relative humidity (%) Average 75 82 77 75 77 Precipitation(mm) Average 85.3 161.7 57.7 34.6 1062.3 2.3.2.2 Ambient Air Quality

The results from the Environmental Protection Bureau (EPB) Report of Oct, 2005 (sampling date: Oct.18-22, 2005) show compliance with the Chinese ambient quality standards for all monitored pollutants (Table 2-4, Annex 2)



Table 2-4 Ambient Air Quality Monitoring Results

Monitoring Results (1-hr avg.)

Pollutants Dengshi (1#) Fushan (2#) Wangshi (3#) Plant Site (4#)

Ambient Air

Standard

(1-hr avg.)

(see notes)

Status

Fluoride (µg/m3) 2-4 3-6 2-5 4-6 20 In compliance

HCl (mg/m3) 0.010-0.014 0.014-0.019 0.006-0.014 0.018-0.027 0.05 In compliance

Cl2 (mg/m3) 0.015-0.021 0.025-0.031 0.009-0.015 0.029-0.037 0.1 In compliance

Notes: 1. The standard for fluoride is Category 2 of Ambient Air Quality Standard (GB 3095-1996) (Annex 3);

2. The standards for HCl and Cl2 are from Table 1 of Hygienic Standards for the Design of Industrial Enterprises

(TJ 36-79): Maximum allowable concentrations of harmful substance in ambient air of residential district.

2.3.3 Hydrogeology and Ambient Water Quality

2.3.3.1 Surface Water

Nearby surface water

The closest surface water is the Fushan Pond, which is parallel to the southern and eastern boundaries of the Changshu 3F Zhonghao site at a distance of approximately 30 meters. Yangtze River is 4 km north of the site. Cuipu Pond lies in the southeast of the plant site at a distance of approximately 2.5 km. Wangyu River also lies in the southeast of the plant site but at a distance of approximately 4.3 km. All the above mentioned surface waters eventually flow to the Yangtze River (Annex 2).

Ambient water quality

According to the Changshu EPB Report of Oct. 2004, all monitored pollutants in Wangyu River (nearby the estuary to Yangtze River) and the intake area of the Third Water Plant (TWP) of Changshu City were in compliance with the surface water quality standards (Table 2-5, Annex 2).

Table 2-5 Monitoring Results of Surface Water Quality (Unit: mg/l, except pH)

Sampling Location DO Fluoride NH3-N Volatile

Phenol BOD5 CODcr

Wangyu River Estuary 8.5 0.32 0.29 0.000 1.2 12

Standard of Wangyu River Estuary (see notes) ≤5 ≤1.0 ≤1.0 ≤0.005 ≤4 ≤20

TWP Intake Area 8.3 0.36 0.12 0.000 / /

Standard of Intake Area of the TWP (see notes) ≤6 ≤1.0 ≤0.5 ≤0.002 ≤3 ≤15

Note: 1. Standard for Wangyu river estuary is Category Ⅲ of Environmental Quality Standards for Surface Water

(GB3838-2002) (Annex 3);

2. Standard for intake area of the TWP is Category Ⅱ of Environmental Quality Standards for Surface Water

(GB3838-2002) (Annex 3).



2.3.3.2 Groundwater

The shallow groundwater is 1-3 meters below the ground level and has a depth of approximately 6 meters. According to the Changshu EPB’s Report, all monitored pollutants in shallow groundwater were compliance with Category Ⅲ of Groundwater Quality Standard (Table 2-6).

Table 2-6 Monitoring Results of Ground Water Quality

Sampling Location Monitored Pollutants

(mg/l)

Standard (mg/l) (see notes) North of Dengshi

(mg/l) Northeast of Fushan

Town (mg/l) North of Fushan

Town (mg/l) Sulfate ≤250 92.5 161.0 101.0

Chloride ≤250 44.7 66.4 54.6

Hg ≤0.001 0.00002 0.00002 0.00002

As ≤0.05 0.000 0.000 0.000

Cd ≤0.01 0.000 0.000 0.000

Cr ≤0.05 0.000 0.000 0.000

Fluoride ≤1.0 0.25 0.18 0.36 Note: The standard is Category Ⅲ of Environmental Quality Standards for Ground Water (GB/T 14848-1993) (Annex 3).

2.3.4 Noise Levels

Noise levels around Changshu 3F Zhonghao boundary was monitored for two days (one during the daytime and the other at night) by Changshu EPB (Figure 2-4) on November 25, and May 10, 2005. The results in Table 2-7 show compliance with the applicable noise quality standards.

Table 2-7 Monitoring Results of Acoustical Quality (Unit: dB(A))

Monitoring Code Daytime Status Night Status

Z1 58.5 In compliance 45.7 In compliance






Standard (see note) 65 55 Note: The standard is Category 3 of Standard of Environmental Noise of Urban Area (GB3096-93) (Annex 3).



2.3.5 Soil

The type of soil around the project site is characterized to be mostly sandy. Soil quality was monitored by Changshu EPB (Table 2-8). The results show compliance with the Category 2 of the soil quality standard, even Category 1.

Table 2-8 Monitoring Results of Soil Quality (Unit: mg/kg)

Note: The applicable standard is Category 2 of Environmental Quality Standard for Soils (GB 15618-1995) (Annex 3);

2.3.6 Other Environmental Characteristics

Since the project is located in the Changshu International Fluorochemical Industrial Park, its surroundings are manufacturing enterprises of fluor-based chemicals, and there are no permanent residents. The production area has not been subject to any flooding, earthquakes, or typhoons. Based on statistics, Fushan has been subject to 1.5 typhoons and one hail annually, but these have not been violent to cause any damage on Changshu 3F Zhonghao’s installations or operations.

Pollutants

Monitored

East of

Cuipu Pond

North of

Dengshi

East of

Fushan Pond

South of

Cuipu Pond

North of

Fushan Pond

Standard:

Category 2

Standard:

Category 1

Total Arsenic 8.9 9.2 8.8 9.5 8.4 25 15

Total Mercury 0.1 0.1 0.1 0.1 0.1 0.5 0.15

Total Chrome 58.2 62.3 64.6 63.8 58.4 300 90

Total Lead 20 18 16 16 19 300 35

Total Cadmium 0.2 0.2 0.2 0.2 0.2 0.3 0.2

Total Copper 29 30 30 33 34 100 35



3 Descriptions of the HCFC-22 Production and HFC-23 Destruction

Processes

HFC-23 is generated as a waste gas from the HCFC-22 production process. Changshu 3F Zhonghao has the following Lines for HCFC-22:

Line A, with capacity of 20,000 tpy, which use liquid-phase reactions in the reactor, was commissioned in 2000 and it’s the focus of this EA report.

Line B, with capacity of 20,000 tpy, was commissioned in 2001 and it’s the

focus of this EA report too.

The New Line, with capacity of 10,000 tpy, as it was constructed after December 31, 2001, will be outside the scope of the China: HFC-23 Emissions Reduction as per the requirements of the Kyoto Protocol and, therefore, is not considered under this EA report.

Only Lines A and B, which were commissioned before December 31, 2001, qualify with the Kyoto Protocol requirements for HFC-23 emissions reduction and are, therefore, the main focus of this due diligence environmental assessment.

Therefore, although the HFC-23 emissions from Lines A and B (with a total capacity of 40,000 tpy) will be controlled under the China: HFC-23 Emissions Reduction Project, the HFC-23 emissions from the New Line (with a capacity of 10,000 tpy) will be emitted to the atmosphere uncontrolled to contribute to global warming. HFC-23 emissions from Lines A and B will be directed to the HFC-23 emissions reduction facility. This section of the EA briefly describes first the HCFC-22 process which generates the HFC-23 gases, and then gives detailed information about the main focus of this investment project, which is the reduction of the HFC-23 emissions.



Gas-holder Tank

Recirculated Water

Refrigeration Room

PondF22

Refrigeration

F22/F32 Facilities

Control Room

Circulating Water System

Carbide Crushing

F22 Cylinder A

rea

Acetylene

Generating

Mountain Meal Storehouse

AHF

F22 Cylinder Packing Space

Switch Station

F125aRefrigeration Workshop

F125a

Generator Set

Substation

Refrigeration Room

HFPF125 TFE

Control Room

Production Department

Noise Sources

Line BLine A

The Proposed Project

N

Refrigeration

Workshop

Office B

uilding

Power Station

Living Area

Calcium Bicarbonate

Subpackage Station

Operating Room

Storehouse

Figure 3-1 The Plain Layout of Changshu 3F Zhonghao

3.1 Description of the HCFC-22 Process

The production facilities, liquid raw materials, products, and by-products of Lines A and B are located at the same lot. The activities in the immediately adjacent areas to Lines A and B are as follows (Figure 3-1). Line A:

North: AHF production facility West: Refrigeration workshop South: Steel products storage and small cylinder package storage East: Cylinder storage

Line B: North: Filling areas West: Internal circulation South: Old office building East: Refrigeration workshop

3.1.1 HCFC-22 Process at Lines A and B

HCFC-22 is produced from a series of liquid-phase reactions that involve anhydrous



hydrogen fluoride (AHF) and chloroform (CHCl3) in the presence of the antimony pentachloride (SbCl5) catalyst. The subsequent steps in the HCFC-22 production process involve separation of the product HCFC-22 from reaction by-products and feed chemicals. In the reactor, the following reactions take place:

HF + SbCl5 → SbCl4F + HCl (3-1)

CHCl3 + SbCl4F → SbCl5 + CHCl2F (= HCFC-21) (3-2)

CHCl2F + SbCl4F → SbCl5 + CHClF2 (=HCFC-22) (3-3)

CHClF2 + SbCl4F → SbCl5 + CHF3 (=HFC-23) (3-4)

Where, reactions (3-2) and (3-4) are side reactions producing the Fluorodichloromethane (HCFC-21) intermediate and the HFC-23 waste. During its use in the reactor, pentavalent antimony (Sb+5) is also reduced to trivalent antimony (Sb+3). The catalyst is activated by introducing chlorine into the reactor (i.e. chlorine addition oxidizes Sb+3 to Sb+5).

3.1.1.1 Line A

Line A is located at the southeastern part of Changshu 3F Zhonghao’s site. The activities in the neighboring areas of Line A are as follows:

• North: AHF production facility.2 • West: Chiller3 • East: Coal boiler and then the coal storage area • South: Warehouse for steel materials and an office building.

AHF and chloroform (CHCl3) are reacted in a steam-jacketed reactor in the presence of antimony pentachloride (SbCl5) catalyst. The reaction products include HCFC-22, HCl, intermediate HCFC-21, and by-product HFC-23. These reaction products and unreacted AHF and chloroform are fed to a reflux column on top of the reactor’s vapor line to separate most of the unreacted AHF and chloroform and intermediate HCFC-21 from HCl, HCFC-22, HCF-23; sending the former three components back to the reactor. The heavier components in the vapor line from the reflux column are condensed in a condenser and the condensate is returned to the reflux column.

The gas stream from the condenser contains mostly HCFC-22, HFC-23, and HCl, and some

2 AHF production facility is not within the boundary of this due diligence environmental assessment because only 20

percent of the produced AHF is used as a feed chemical to the HCFC-22 production lines, whereas 80 percent of AHF is used as a feed chemical to other processes.

3 The chiller is not within the boundary of this due diligence environmental assessment because the cold water is not exclusively used for the HCFC-22 production lines.



residual HF, chloroform, and HCFC-21. The acid gases (mostly HCl and some HF, which contain the following organic impurities: HCFC-21, HCFC-22, and chloroform) are removed by water scrubbing (in two water scrubbers in series) and sold as by-product HCl (containing some HF and minor quantities of organics). The gas stream from the second water scrubber enters a caustic scrubber, where HF and the remaining HCl and minor quantities of HCFC-21, HCFC-22, and chloroform are removed with caustic (NaOH); and sent to the wastewater pretreatment plant.

The gas stream from the caustic scrubber is collected in an intermediate storage tank, and the condensing compounds are removed by phase separation and sent to the wastewater pretreatment plant.

The gas stream containing HCFC-22, HCFC-21, and HFC-23 are first cooled and then compressed. Any compressor oil that may entrain the gas stream is removed by an oil separator. Two condensers in series then separate the condensate (mostly HCFC-22 and HCFC-21, and minor quantities of HFC-23) from the non-condensable gases (mostly HFC-23 and minor quantities of HCFC-22). The non-condensable HFC-23 –rich gas is discharged to the atmosphere, and the condensate is collected in an intermediate storage tank. HFC-23 from the condensate is removed in a stripping column and sent to the gas storage tank, whereas the remaining gases are distilled to separate HCFC-21 from HCFC-22. HCFC-21 is recycled to the reactor, whereas the HCFC-22 is dried in a molecular sieve, weighed, and transferred to the HCFC-22 storage tank for shipment as product.

3.1.1.2 Line B

Line B shares the same lot with HFC-32 production. Line B is located to the west (but not immediate west) of Line A and to the east of the inner side of the circulating cooling water pond. The activities in the neighboring areas of Line B are as follows:

• North: o of the HCFC-22 loading area: F-152a production facility

• West: o of the HCFC-22 production area: Cooling water pond o of the HCFC-22 loading area: a vacant lot (this lot is conceived as an

option for the HFC-23 emissions reduction investment), and to its north the HFPF-125 TFE production facility

• South: o of the HCFC-22 production area: Old administration building and yard

(this site is also conceived as an option for the HFC-23 emissions reduction investment)

• East:



o of the HCFC-22 production area: Chiller4 o of the HCFC-22 loading area: Acetylene generation facility, stone crusher,

and water recycling facility. As in Line A, most of HCFC-21 and unreacted HF and CHCl3 (chloroform) are removed in the reflux column and condenser, and recycled to the reactor. The non-condensable chemicals from the condenser are introduced to a distillation column under pressure where HCl and HFC-23 are removed from the top as gas; and chloroform, HF, HCFC-21, and HCFC-22 are removed from the bottom as liquid. The gas stream from the condenser of the distillation column are scrubbed with water in two scrubbers in series to remove hydrochloric acid (HCl) - with some residual hydrofluoric acid (HF) - which is sold as a by-product. The gases from the second scrubber, containing mostly HFC-23 and some HCFC-22, are discharged to atmosphere.

The liquid stream from the distillation column is washed with water and decanted to remove 12% HF + 3% HCl mixture as a lighter phase, which is sold as a by-product. The heavier phase containing HCFC-21, HCFC-22 and some residual HF and HCl is washed with sodium carbonate and decanted to remove the residual fluorides and chlorides, which are sent to wastewater pretreatment. The heavier phase containing HCFC-21 and HCFC-22 are sent to an intermediate storage tank, and then to a distillation column, where HCFC-21 is removed from the bottom and recycled to the reactor, and HCFC-22 is removed from the top. HCFC-22 is dried by molecular sieves prior to transfer to the HCFC-22 weighing and product storage tank.

3.1.2 Source, Treatment, and Discharge of Pollutants

(1) Wastewater discharge from the HCFC-22 Process

The wastewater from the HCFC-22 process is mainly from the caustic scrubbing tower and the separator with daily discharge amount of 24m3/d and annual discharge amount of 7,920 m3/a. This process wastewater is transported through pipeline to Changshu 3F Zhonghao’s wastewater treatment station for treatment. After treated, the pH is 6-9, and discharge concentrations of COD and fluoride are less than 100 mg/l and 10mg/l respectively, which comply with Class I in Table 4 of Integrated Wastewater Discharge Standard (GB8978-1996) (Annex 3). The annual maximum discharge amount of fluoride and COD is less than 0.079 tons and 0.792 tons.

The process diagram of Changshu 3F Zhonghao’s wastewater treatment plant (WWTP) is given in Figure 3-2.

4 The chiller is not within the boundary of this due diligence environmental assessment because the cold water is not exclusively used for the HCFC-22 production lines.



Figure 3-2 Treatment of Process Wastewaters at Changshu 3F Zhonghao

(2) Waste Gas

The air emissions from the HCFC-22 production occur from the following sources:

• Condenser (Line A) and the tail gas absorption tower (Line B). This emission contains HFC-23, HCFC-22, HF, and HCl.

Aeration, neutralization,regulating tank

Coagulation Reactor

Sedimentation Tank

Biochemical Process

Secondarysedimentation Tank

Coagulation Reactor

Final sedimentationTank

Clear water collectingTank

Discharge to pipeline ofthe industrial park

Process wastewaters

Air

Sludge

Sludge

Sludge

Sludge

Air

Aluminum chloride polyacrylamide

Calcium hydroxide, Aluminum Polymer

Calcium hydroxide, Aluminum Polymer



• Storage tanks for HF and HCl. • Incinerators burning the distillation bottom residues. This emission contains HCl,

fluoride, smoke dust, SO2, CO and dioxins. According to the monitoring report on concentration outside of boundary, No. (2005) 115 provided by Changshu Environmental Monitoring Central Station, fugitive emission concentration of fluoride and HCl outside of boundary are 2.11-4.01 µg/m3and 0.008-0.023 mg/m3 respectively, which comply with Category II in Table 2 of Integrated Emission Standard of Air Pollutants (GB16297-1996) (Annex 3).

3.2 Description of the HFC-23 Process

3.2.1 Basic Information

The HFC-23 emissions from Lines A and B of Changshu 3F Zhonghao’s HCFC-22 Process will be destroyed through use of the incineration technology. The proposed project will be located within the present production areas of Changshu 3F Zhonghao. Therefore, no new land acquisition or resettlement is involved. The surroundings around the project site are as follows (see Figure 2-3):

North: HFP F125 TEF facility; West: TFP R227 facility; South: Circulating cooling water pond; East: THCFC-22 Storage Tank area.

HFC-23 is an inevitable waste gas from the HCFC 22 process. The HCFC-22 process typically produces HFC-23 quantities at levels of 3-4% of HCFC 22 production. According to the historical monitoring data of Changshu 3F Zhonghao (Annex 4), the contents of HFC-23 were always above 3% of HCFC-22 and less than 4% of HCFC-22 production. In order to destroy HFC-23 completely, the generation rate (HFC-23 and HCFC-22) of 4% is used in the EA. As Changshu 3F Zhonghao’s total production capacity of HCFC-22 from both Plants A and B is 40,000 tpy, the capacity of the HFC-23 emissions reduction facility is taken to be: 40,000 × 0.04 = 1,600 tpy. Therefore, the designed capacity of the HFC-23 incinerator is taken to be 1,600 tpy. 3.2.2 HFC-23 Emissions Reduction Process

3.2.2.1 Process Description

The destruction process is based on incineration of HFC-23 gases followed by water quenching, water and alkali scrubbing of HF and HCl from the flue gases, and treatment of washed gases with calcium hydroxide (Ca(OH)2) to precipitate calcium fluoride (CaF2) (Figure 3-3).



Inci

nera

torIntermediate

Storage Tank

32

Stream(Evaporation loss)

WaterWater

Alk

ali S

crub

bing

Wat

er S

crub

bing

WastewaterⅢWastewaterⅡ

Que

nch

HFC-23 Waste Gas from the HCFC-22 Process

Air

Steam

LNG

1

2

3

4

5 9 13

6 816

11 15

10 14

NaOH, Water

17Air Emission to Atmosphere

18

Neutralization

19Ca(OH) FeCl20

Filter Press

Sludge for Road Construction

23

pH AdjustmentHCl

25

Treated Wastewater Discharge

21Polymer(PAM)

22

12

7

WastewaterⅠ

24

Gas Cleanup System

WWTPSettling Tank

Precipitate

Filtrate

Filte

r Cak

e

Cle

ared

Wat

er

Emergency Gas Storage Tank



Figure 3-3 Flow Diagram of HFC-23 Emissions Reduction Process

The waste gas stream from Lines A and B of Changshu 3F Zhonghao’s HCFC-22 Plant, mostly containing HFC-23, is stored in an intermediate storage tank that provides a buffer storage capacity before being admitted to the HFC-23 Emissions Reduction Process.5 The HFC-23 gas from the intermediate storage tank is transferred by pipeline to the incinerator for destruction. Liquefied natural gas (LNG) is combusted with air in the incinerator to produce the heat necessary for the destruction of the waste gas, yielding CO2 and H2O. Steam, as an additional source of hydrogen, is also introduced to the incinerator to ensure complete conversion of halogens to hydrogen halides. The HFC-23 gas stream is destroyed in the incinerator to yield CO2 and HF. In addition, HCFC-22, which is also present in the waste gas stream, is destroyed to yield CO2, HF, HCl. The reactions in the incinerator proceed as follows:

CHF3 (= HFC-23) + H2O + 1/2 O2 → CO2 + 3HF (3-5)

5 In case of an emergency shut down of the HFC-23 Emissions Reduction Process, this intermediate storage tank will also

provide a storage capacity for the HFC-23 waste gas from the HCFC-22 Process



CHClF2 (=HCFC-22) + H2O + 1/2 O2 → CO2 + 2HF + HCl (3-6)

CH4 + 2O2 → CO2 + 2H2O (3-7)

The temperature in the incinerator is kept at 1,200oC to ensure the destruction of the HFC-23/HCFC-22 and minimize the formation of unwanted combustion waste gases such as dioxins and furans. (Throughout this document, “dioxins” will henceforth be used as a general descriptor of dioxins and furans species).

The flue gases are then fed to the quench tower, where they are rapidly cooled down with water to close to ambient temperature. Quenching is conducted in quench tower through direct contact of the flue gases with water in a “shower mode” instead of indirect cooling in a “heat exchanger mode”, which is commonly used in China. The selection of the direct contact design (through improved heat exchange and thus rapid cooling) is aimed at elimination of dioxin formation.

The cooled gas passes through a two-stage scrubber, the first one operating with water, and the other one with an alkali (NaOH) solution. In these operations, HF and HCl are dissolved in the quench water and water and alkali scrubbers. The gas from the alkali scrubber is emitted to the atmosphere through a stack.

The wastewaters from the quench tower and scrubber tower are sent to a special WWTP for this project. Treatment of HFC-23 Emissions Reduction Process’ wastewaters at this special WWTP is shown to be more feasible than treatment at Changshu 3F Zhonghao’s WWTP for the entire facility (see Section 7.3 on the Evaluation of Alternatives for the Wastewater and Sludge Discharges).

In this special WWTP, wastewaters from the HFC-23 Emissions Reduction Process are neutralized by Ca(OH)2 according to the following reactions:

2HF + Ca(OH)2 → CaF2↓ + 2H2O (3-8)

2HCl + Ca(OH)2 → CaCl2 + 2H2O (3-9)

The reaction products are directed to a settling/precipitation tank, where the CaF2 precipitate is allowed to settle. The precipitate (mainly CaF2) from the bottom of the settling tank is sent to a filter press for dewatering to approximately 65 percent moisture. The filter cake is sent off site for road construction (see Section 7.3 on the Evaluation of Alternatives for the Wastewater and Sludge Discharges), and the filtrate is recycled to the neutralization tank. The cleared water from the top of the thickener is pH adjusted with HCl in a tank, and the treated wastewater is discharged from the process.



3.2.2.2 Technological Design Parameters of HFC-23 Incinerator

The technological design parameters of the HFC-23 incinerator are given in Table 3-1.

Table 3-1 Design Parameters of HFC-23 Incinerator

Items Incinerator

Capacity (kg/h)

Incineration Temperature

(oC)

Residence Time of Gas (s)

Combustion Efficiency

(％)

Removal Percentage of Oxidation (％)

Oxygen Content of

the Flue Gases (dry basis) (％)

Parameter 151.5 ≥1200 ≥2.0 ≥99.9 99.99 6-10 3.2.2.3 Raw Materials, Auxiliary Materials and Energy Consumption

Project’s consumption of raw materials, auxiliary materials and energy is given in Table 3-2 below.

Table 3-2 Consumption of Main Raw and Auxiliary Materials and Energy

Items Name Use Consumption Source

Sodium Hydroxide

Used in alkali absorption tower as absorbent material for HFC-23 flue gases

160 tpy Purchased from outside supplier or manufacturer

Calcium Hydroxide

Used in neutralization tank of the WWTP of this project as neutralizer for the wastewater

2,785 tpy Purchased from outside supplier or manufacturer

Steam Used in the HFC-23 incinerator as one of the reactants

439 tpy Changshu 3F Zhonghao’s boiler house

Raw and Auxiliary Materials

Fresh water

Used in quench tower for water cooling; Used in water scrubbing tower and alkali scrubbing tower for the waste gas treatment

89,760 tpy Water supply networks of the industrial park

LNG Fuel for the HFC-23 incinerator

850 tpy Purchased from outside supplier or manufacturer Energy

Power Facilities’ power 500,000 kwh Changshu electric network

3.2.3 Operation and Maintenance Schedule

The operating schedule is just like the HCFC-22 project. The project will operate 330 days



per year and 24 hours per day. The other 30 days are for the maintenance of HFC-23 incineration facilities at the same time as the maintenance for the HCFC-22 Line A and B. The labor requirement during operation of this project will be about 40 persons for all three shifts, who are newly hired from the local residents. 3.2.4 Investment Cost

The total investment of this project is estimated to be about RMB 59 million ($ 7.4 million). About RMB 57 million ($ 7.1 million) of this amount is for investment in fixed assets and RMB 2 million ($ 0.3 million) for working capital.



4 Regulatory and Institutional Framework

4.1 Regulatory Framework

4.1.1 Relevant Laws, Regulations, and Technical Guidelines of China

(1) Environmental Protection Law of the People's Republic of China, issued on Dec. 26, 1989;

(2) Law of the People's Republic of China on the Environmental Impact Assessment, issued on Sept.1, 2003;

(3) Law of the People's Republic of China on the Promotion of Cleaner Production, issued on Jan. 1, 2003;

(4) Law of the People's Republic of China on the Prevention and Control of Atmospheric Pollution, amended on Apr. 29, 2000;

(5) Law of the People's Republic of China on the Prevention and Control of Environmental Pollution by Solid Waste, issued on Apr. 1, 1996;

(6) Law of the People's Republic of China on Prevention and Control of Water Pollution, issued on May, 15, 1996;

(7) Law of the People's Republic of China on Prevention and Control of Pollution from Environmental Noise, issued on Mar. 1, 1997;

(8) Regulations on Environmental Management of Construction Project, No.253 Decree issued by the State Council on Nov. 29, 1998;

(9) Interim Regulations on the Prevention of Water Pollution in the Huai River Valley, No.183 Decree issued by the State Council on Aug. 8, 1995;

(10) Interim Measures on the Administration of Key Water Pollutants Discharge Permit in Huai River Basin and Tai Lake Basin, No. [2001]11 Decree issued by the State Environmental Protection Administration (SEPA) on Oct. 1, 2001;

(11) The Tenth Five-Year Plan for Industrial Water Saving issued on Oct. 12, 2001;

(12) Pollution Prevention and Control Technology of Hazardous Wastes, No.[2001] 199 issued by SEPA, the former State Economic and Trade Commission (SETC), and the Ministry of Science and Technology (MOST) on Dec.17, 2001;



(13) Ordinance of hazardous chemicals safe management, issued by the State Council in 2002;

(14) National Catalogue of Hazardous Wastes, No. [1998]89 issued by SEPA;

(15) Official Reply on "the Tenth Five-year Plan" of the National Environmental Protection by the State Council, No. [2001] 69 issued by the State Council;

(16) Technical Guidelines for EIA: General Principals (HJ/T2.1-93);

(17) Technical Guidelines for EIA: Atmosphere Environment (HJ/T2.2-93);

(18) Technical Guidelines for EIA: Surface water Environment (HJ/T2.3-93);

(19) Technical Guidelines for EIA: Noise Environment (HJ/T2.4-1995) ;

(20) Circular on Strengthening coordination and cooperation of industrial policies and Credit Policies to Control Relevant Problems of Credit Risk, No.[2004]746 issued by the National Development and Reform Commission;

(21) Directive on banning redundant construction in specific industrial and commercial investment areas (First Batch), No. [1999] 14 Decree issued by SETC;

(22) The Catalogue of Phasing out Out-of-Date Production Capacities, Techniques and Products (First Batch, Second Batch), No. 6 &16 Decrees issued by SETC；

(23) The Catalogue of Phasing out Out-of-Date Production Capacities, Techniques and Products (Third Batch), No. 32 Decree issued by SETC.

4.1.2 Relevant Legal Requirements and Regulations for the Jiangsu Province

(1) Provisions about Ordinance of Environmental Management for Construction Project, No. [98] 1 issued by Jiangsu Environmental Protection Committee;

(2) Circular on Criterion of Environmental Management for Construction Project of Jiangsu Province, No.[2002]46 issued by Jiangsu Environmental Protection Committee on May 7th, 2002;

(3) Proposals on Strengthening Environmental Management for Construction Project, No.(97)105 issued by Jiangsu Provincial Government on July 17th, 1997;

(4) Interim Provisions on Total Amount Control for Pollutants Discharge of Jiangsu Province, No. [1993]38 issued by Jiangsu Provincial Government;



(5) Circular on Printing and distributing Measures on Standardizing Pollutants Discharge Outlets, No. [97]122 issued by Jiangsu Environmental Protection Committee;

(6) Proposals on Implementing the Exchange and Transfer of Hazardous Wastes, No. [1998]122 issued by Jiangsu Environmental Protection Committee in Oct. 1998;

(7) Official Reply on Jiangsu Surface Water Environmental Function Zoning, No. [2003] 29 issued by Jiangsu Provincial Government on Mar. 18th, 2003;

(8) Function Zoning of Jiangsu Atmospheric Environmental Capacity, issued by Jiangsu Environmental Protection Bureau in September, 1998.

4.1.3 Relevant Technical Documents for Changshu

(1) Changshu’s Urban General Planning (2000-2050)

(2) Changshu’s Urban Environmental Protection Programme, issued by the Changshu Environmental Protection Bureau;

(3) Provisions for the Administration of the Prevention and Control of Pollution in Protected Areas for Drinking Water Sources of Changshu Third Water Supply Plant, issued by Changshu Municipal

Government;

(4) Jiangsu Changshu International Fluorine Chemical & Industrial Park General Planning;

(5) Environmental Impact Assessment Report and Environmental Protection Programme of Jiangsu Changshu International Fluorine Chemical & Industrial Park;

(6) Report on Changshu Environmental Pollution Sources and Pollutants Discharge Status, formulated by Changshu Environmental Supervision Branch Team;

(7) Other basic information provided by Changshu 3F Zhonghao New Chemical Materials Co., Ltd

4.1.4 Relevant Provisions of the World Bank

(1) OP/BP 4.01 of World Bank and its annex (Environmental Assessment) in January 1999;

(2) OP/(Environmental Assessment) of World Bank in January 1999;

(3) GP4.01 of World Bank and its annex (Environmental Assessment) in January 1999;

(4) Environmental Impact Assessment Sourcebook (Volume 1-3) of World Bank;



(5) OP/BP4.04 (Natural Habitat) of World Bank in September 1995;

(6) GP4.07 (Water Resources Management) of World Bank in December, 2000;

(7) GP14.70 of World Bank (Involving Non-Governmental Organizations in Bank-Supported Activities in January 1999.

4.1.5 Applicable Environmental Discharge and Ambient Quality Standards

4.1.5.1 Air

For the air emission standards from the proposed HFC-23 incineration facility, the Chinese standard GB 14848-2001 (Pollution Control Standard for Hazardous Waste Incineration) was taken as the basis, with the exception of the dioxin emission standard. The European Union’s more stringent discharge standard for dioxin was taken as the basis for this project. The applicable air emission standards are presented in Table 4-1.

Table 4-1 Applicable Air Emissions Standards

Sources of air

Emissions Pollutants Standard

Reference for

Standard Analytical Method

Reference for

Analytical

Method

Smoke

opacity Lingesman Class � Lingesman method GB/T 5468-91

HCl 100 mg/m3

Mercury sulfhydryl

spectrosphotometry

Silver nitrate volumetry

HJ/T 27-1999

HF 9.0 mg/m3

Filter Sampling and

Fluorine Ion-selective

Electrode Method

(3)

Soot 100 mg/m3 Gravimetry GB/T

16157-1996

SO2 400 mg/m3

Formaldehyde

Absoring-Pararosaniline

Spectrophotometry

(3)

NOx (as

NO2) 500 mg/m3

N-(1-naphthyl) Ethylene

Diamine Dihydrochloride

Spectrophotometry

HJ/T 43-1999

CO 100 mg/m3 Non-disperisive Infrared

Spectrometry HJ/T 44-1999

Sb 4.0 mg/m3

Pollution Control

Standard for

Hazardous Wastes

Incineration (GB

18484-2001)

5-Br-PADAP

Spectrophotometry (3)

HFC-23

incinerator(1)

Dioxins(2) 0.1 TEQ ng/m3 European Union Gas Chromatography/Mass

Spectrometry (4)



100 mg/m3

1.4kg/h (stack

height :30m)

Mercury sulfhydryl

spectrosphotometry


HJ/T 27-1999

HCl Fugitive emission

concentration outside

of boundary: 0.20

mg/m3

Mercury sulfhydryl

spectrosphotometry


HJ/T 27-1999

9 mg/m3

0.59kg/h (stack

height : 30m)

Filter Sampling and


Electrode Method

(3)

HCFC-22

production

Fluoride Fugitive emission

concentration outside

of boundary:20µg/m3

Class II in Table 2

of GB16297-1996

Filter Sampling and


Electrode Method

(3)

Notes: (1) The capacity of the incinerator: ≤300 kg/h.

Use 11% O2 (dry air) as conversion reference in the calculation. The conversion formula is: C = 10/(21-Os)×cs

Where: c: Converted concentration of the measured pollutant at standard condition (mg/m3); Os: Oxygen

concentration of exhaust gases (%); cs: Concentration of the measured pollutant at standard condition (mg/m3).

Stack height: ≥25 m.

(2) TEQ is defined as: TEQ=Σ(concentration of dioxin congeners × TEF), where TEF is the “toxic equivalent

concentration”, defined as the “relative potency of different dioxin congeners compared to TCDD

(2,3,7,8-tetrachlorodibenzo-p-dioxin)”.

(3) Monitoring and Analysis Methods for Air and Exhaust Gases, Beijing: China Environmental Science Press,

1990.

(4) Analysis and Assessment Manual for Solid Wastes, Beijing: China Environmental Science Press, 1990. PP

332-359.

The nearest receptors for air emissions from the project site is the Fushan town (Table 4-2 and Figure 2-3).The applicable air quality standard for the project’s receptor is the Chinese regulation GB 3095-1996 for Class II Ambient Air Quality Standard (Table 4-3).

Table 4-2 The Receptors for Air Emissions from the Project

Receptors Population Distance from the

Project Site (m)

Orientation Relative

to the Project Site

Reference for

Applicable Standard

Fushan Town 3,000-4,000 2,000 SW

Dengshi 1,200 3,700 SE

Wangshi Town 21,000 5,700 SE

Class II of Ambient Air

Quality Standard

(GB3095-1996)

(Annex 3)



Table 4-3 Applicable Air Quality Standards

Pollutants Standard Reference for Applicable Standard ≤20 µg/m3 (hourly average)

Fluoride ≤7 µg/m3 (daily average)

Class ⅡAmbient air quality standard (GB 3095-1996)

≤50 µg/m3 (1-hr avg.) HCl

≤15 µg/m3 (Daily avg.)

Hygienic standards for the Design of Industrial Enterprises (TJ36-1979) (see note)

Note: The standard for hydrogen chloride is from Table 1 of Hygienic Standards for the Design of Industrial Enterprises

(TJ 36-79): Maximum allowable concentrations of harmful substance in ambient air of residential district.

4.1.5.2 Wastewater

For the wastewater discharge standards from the proposed HFC-23 incineration facility, the Chinese standard GB 8978-1996 (Integrated Wastewater Discharge Standard) was taken as the basis (Table 4-4).

Table 4-4 Applicable Wastewater Discharge Standards

Source of Wastewater Discharge

Pollutants Standard Reference for

Standard Analytical Method

Reference for Analytical

Method

pH 6-9 pH value-Glass electrode method

GB 6920-86

COD 100 mg/l K2Cr2O7 method GB 11914-89 SS 70 mg/l Gravimetric method GB11901-89

HFC-23 incinerator

Fluoride 10 mg/l

Class 1 in Table 4 of Integrated

Wastewater Discharge

Standard (GB 8978-1996)

Ion selective electrode method

GB 7484-87

Stormwater is discharged to Fushan pond which will finally flue into the Yangtze River. The discharge standard and the water quality standard for Fushan pond is given in Table 4-5. Wastewater discharge form this project after treatment will be discharged to the wastewater piping network of the Industrial Park for pumping to the Yangtze River. The nearest receptors for wastewater discharge from the project site are shown in Table 4-5. (Table 4-5 and Figure 2-3).The applicable water quality standard for the project’s receptors is the Chinese regulation GB 3838-2002 for Class III Ambient Water Quality Standard (Table 4-6).



Table 4-5 The Receptors of Wastewater Discharge from the Project

Receptor Distance to the Project Site (m)

Orientation Relative to the Project Site

Reference for Applicable Standard

Fushan Pond 30 Southeast Class III of Environmental Quality Standards for Surface Water (GB3838-2002) (Annex 3)

Yangtze River 4,000 North Class II of Environmental Quality Standards for Surface Water (GB3838-2002) (Annex 3)

Table 4-6 Applicable Water Quality Standards

Standard (mg/l) Pollutants

Category III Category II

Reference for Applicable Standard

COD ≤20 ≤15 BOD5 ≤4 ≤3 Ammonia nitrogen

≤1.0 ≤0.5

Fluorid ≤1.0 ≤1.0 DO ≤5 ≤6 Volatile hydroxybenzene

≤0.005 ≤0.002

Chloride ≤250 Petroleum ≤0.05 ≤0.05

Environmental Quality Standards for Surface Water (GB3838-2002) (Annex 3)

4.1.5.3 Groundwater

Class III of Quality Standard for Ground Water (GB/T14848-1993) is applied for groundwater environment assessment (Table 4-7).

Table 4-7 Applicable Quality Standard for Ground Water

Receptor Items Unit Standard Reference for

Applicable Standard Sulphate mg/l ≤250 Chloride mg/l ≤250 Fluoride (as F-) mg/l ≤1.0

Hg mg/l ≤0.001 As mg/l ≤0.05 Cd mg/l ≤0.01

Plants area as well as surroundings

Cr mg/l ≤0.05

Class III of Quality Standard for Ground Water (GB/T14848-1993) (Annex 3)



4.1.5.4 Noise

For the noise emission standards from the proposed project, the Chinese standard GB12523-90 (Noise Limits for Construction Site) and GB12348-90 (Standard of Noise at Boundary of Industrial Enterprises) was taken as the basis for construction phase and operational phase respectively (Table 4-8).

Table 4-8 Applicable Noise Emission Standards

Phase Source of Noise

Emission Standard

Reference for

Standard

Reference for

Analytical Method

Cubic meter

of earth and

stone digging

Bulldozer, grab,

loader

Day: 75 dB(A)

Night: 55dB(A)

Pilling various pile

driver

Day: 85 dB(A)

Night:No

constructing

Structural

engineering

concrete pug

mill, Concrete

vibrating stick,

electricity saw

Day: 70 dB(A)

Night: 55dB(A)

Construction

Phase

Fitment

engineering Crane,elevator

Day: 65 dB(A)

Night: 55dB(A)

Noise Limits for

Construction Site

(GB12523-90)

GB 12524

Operational Phase HFC-23

incinerator

Day: 65 dB(A)

Night: 55dB(A)

Class III of Standard of

Noise at Boundary of

Industrial Enterprises

(GB12348-90) (Annex

3)

GB 12349

Class III of Standard of Environmental Noise of Urban Area (GB3096-93) is applied for acoustic environment quality assessment (Table 4-9).

Table 4-9 Applicable Quality Standard for Noise

Receptor Standard Reference for Applicable Standard

Plant boundary Day: 65dB(A) Night: 55dB(A)

Class III of Standard of Environmental Noise of Urban Area (GB3096-93)

(Annex 3)

4.1.5.5 Soil

Class II of Quality Standard for Soil (GB 15618-1995) is applied for soil environment assessment (Table 4-10).



Table 4-10 Applicable Quality Standard for Soil

Pollutants Unit Standard Total Arsenic mg/kg 25 Total Mercury mg/kg 0.5 Total Chrome mg/kg 300 Total plumbum mg/kg 300 Total Cadmium mg/kg 0.3 Total Cuprum mg/kg 100

4.1.6 Applicable Standards Related to the Design and Operation of Hazardous Waste Facilities

4.1.6.1 Incineration of Hazardous Wastes

Referring to Pollution Control Standard for Hazardous Wastes Incineration (GB 18484-2001), the technical specifications of incinerators is stipulated in Table 4-11:

Table 4-11 Technical Specifications of Incinerators

Waste Categories

Temperature (oC)

Gas Retention Time (s)

Combustion Efficiency (%)

DRE(%) Calcination Reduction Rate (%)

Hazardous ≥1100 ≥2.0 ≥99.9 ≥99.99 ≤5 Notes: 1. Combustion Efficiency (CE) = 100% × [CO2]/([CO2] + [CO]). Where, [CO2] and [CO] refer to the concentration

of carbon dioxide and carbon monoxide in exhaust gases, respectively.

2. Calcination Reduction Rate is calculated with the following formula: P = 100% × (A-B)/A. Where, P refers to

calcination reduction rate, %; A refers to mass of desiccated incineration residue at room temperature, g; B

refers to mass of incineration residue, at room temperature after three-hour calcinations at 600 oC (± 25 oC), g.

The oxygen content of incinerators’ exhaust gases should be between 6% and

10% (dry gases).

The operation of incinerators must be maintained at a negative pressure to prevent exhaust of hazardous gases.

Incinerators must install the tail gas treatment system, alarm system, and

emergent treatment apparatus. 4.1.6.2 Storage of Hazardous Wastes

Referring to Standard for Pollution Control on Hazardous Waste Storage (GB 18597-2001), applicable requirements for this project are:



(1) General Requirements

All hazardous waste generators and operators should construct special hazardous waste storage facilities, or rebuild existing constructions as hazardous waste storage facilities.

Those hazardous wastes that are explosive, flammable or discharging toxic gases

at normal temperature and pressure must be pretreated, and must be stored after stabilized. Otherwise, the hazardous wastes should be stored as explosive or flammable hazardous substances.

Those solid hazardous wastes that will not decompose or volatilize at normal

temperature and pressure can be stacked separately in storage facilities.

It is prohibited to store incompatible (react with each other) hazardous wastes in the same container.

Those hazardous wastes that cannot be stored in a normal container can be

stored in non-leaking rubber bags.

Containers storing liquid or semi-solid hazardous wastes must have a space of more than 100 mm between liquid surface and the container top.

(2) Design principles of hazardous waste storage facilities (Warehouse Type)

The floor and curbs should be made of solid and leak-proof materials. All construction materials must be compatible with stored hazardous wastes.

The facilities must have spill collection facilities, air vents, and gas purifying

equipment.

The facilities must install safety lighting facilities and observation windows.

Containers with liquid or semi-solid hazardous wastes must be placed on the anti-corrosive and hardened floor. The floor surface should have no cracks.

Curbs should be designed to contain spills. The holding capacity between floor

surface and crub should exceed the maximum storage capacity of the largest container or more than 1/5 of the total storage capacity.

Incompatible hazardous wastes must be stored separately, and segregated by a

partition room. (3) Safety protection of hazardous waste storage facilities



Hazardous waste storage facilities must install warning signs.

Hazardous waste storage facilities should install fence walls or other protection fence.

Hazardous waste storage facilities should have communication equipment,

lighting facilities, safety protection garments and tools, and emergency protection facilities.

Leakages from hazardous waste storage facilities must be treated as hazardous

wastes. 4.2 Institutional Framework

4.2.1 Foreign Economic Cooperation Office, State Environmental Protection Administration (SEPA/FECO)

SEPA/FECO is the sponsor and organizer of this project and it is responsible for the consultancy service of this project, which includes: communicate the World Bank and Changshu 3F Zhonghao effectively in time, compile the Project Design Document (PDD), other procedure and etc..

4.2.2 Jiangsu Environmental Protection Bureau

To carrying out supervision and management to the project, to instruct Suzhou and Changshu EPB carry out all of the relevant regulations, and to check the performance of the project periodically and the pollutant control during construction phase and operational phase.

4.2.3 Suzhou Environmental Protection Bureau

Accepting the guidance of Jiangsu EPB, Suzhou EPB is responsible for the environmental management and environmental monitoring during both construction phase and operational phase.

During construction phase: Supervising the implement of environmental management plan (EMP) of Changshu 3F Zhonghao; Supervising the carrying out of the relevant environmental regulation and standard; Responsible for the inspection and management of the construction and operation of the environmental protection facilities; Monitoring the dust and noise during the construction period regularly; Solving any problem in time.

During operation phase: Carrying out the environmental protection laws, regulations and standards; Assisting Changshu 3F Zhonghao in formulating and carrying out the environmental protection rules and regulations; Through monitoring and investigation,



determining the environment quality objective; Organizing the training and examining of Changshu 3F Zhonghao’s environmental protection personnel; Carrying out the technological exchange of environmental protection.



5 Environmental Discharges from the HFC-23 Reduction Process and

Mitigation Measures

5.1 Environmental Discharges from the HFC-23 Reduction Process

5.1.1 Construction Phase

The project activities during the construction phase include ground leveling, pile foundation work, construction of factory building and workshop, industrial equipment installation. Construction is expected to be conducted by 40-50 workers for a period of 6-8 months. The main pollutants discharged to the environment are domestic sewage generated by construction workers, construction wastewater, dust, solid wastes as well as air emissions and noise emissions from the construction equipment. These pollutants will have some impacts on the ambient environment.

(1) Air emissions

Air emissions include construction dust and exhaust gas from construction vehicles.

Dust: Dust will be produced during construction from leveling ground, transporting earth, loading, unloading and transporting construction materials and compounding concrete cement mortar. Dust will also be generated in windy conditions. Without any mitigation measures, dust concentrations in nearby construction areas may reach 1.5-30 mg/m3. This will have some impacts on the construction workers’ health because the dust can settle in alveolar pulmonum and then affect blood-supply function of the workers.

Exhaust gas: Main pollutants from the construction vehicle exhaust are NOX,

CO, and hydrocarbons. (2) Wastewater discharges

The wastewater during the construction phase mainly includes construction wastewater and sewage generated by construction workers.

The construction wastewater mainly consist of washing water of construction machinery and the water used to washing ground during civil works. The wash water may contain petroleum.

As mentioned above, the construction is expected to be conducted by 40-50

workers for a period of 6-8 months. Sewage from construction workers mainly consist of pollutant such as COD, BOD, oils, TP, and TN.



(3) Solid waste discharges

The solid wastes mainly include domestic refuse generated by constructor and construction rubbish generated during the construction period. Construction waste is mainly from excavating earth and other wastes generated during construction, such as concrete, tile, lime, sand and stone.

(4) Noise emissions

Noise is generated mainly from construction equipment and loading/unloading operations.

According to the type of the construction activities and the geological conditions of the project site, the machinery and equipment to be used during the construction phase will mainly include pile driver, agitator, bulldozer, excavator, milling and planning machine and transportation vehicle (self-discharging truck). The noise intensity varies according to different construction time and work condition of machinery, which is difficult to be quantified. The Noise Source Strength of the Construction Equipment is shown in Table 5-1.

Table 5-1 Noise Source Strength of the Construction Equipment

Construction Equipment Distance of Monitoring

Point from Noise Source, (m)

Actual Measurement Value (dB)

Self-discharging truck 15 88 Scraper 15 88

Bulldozer 15 87 Grab 15 91

Air Pick 15 88 Clay Rabbling 7.5 81

Shaker 7.5 81 5.1.2 Operational Phase

Material balance calculations were conducted to estimate the raw material usage and pollutant discharge rates from the HFC-23 emissions reduction process.

The results of material balance calculations are shown in Table 5-2.



Table 5-2 Material Balances of HFC-23 Process (Unit: tpy)

Stream Numbers (See Figure 3-3) 1 2 3 4 5 6 7 8 9 10 11 12

HFC-23 1,600 HCFC22 132.4

HCl 55.9 27.9 27.9 16.8 HF 1,433 716 716 645

Steam 439 LNG 850 Air 27,433 23,645 23,645

Water 1,913 21,450 14,453 8,910 1,913 66,000 56,100 9,900 CO2 3,411 3,411

NaOH Ca(OH)2

FeCl3 Polymer

CaF2 CaCl2 NaCl NaF

Sludge (dry)



Table 5-2 Material Balances of HFC-23 Process (Continued) (Unit: tpy)

Stream Numbers (See Figure 3-3)

13 14 15 16 17 18 19 20 21 22 23 24 25 HFC-23 HCFC22

HCl 11.2 2 44.7 225.3 HF 71.6 0.2 1,361

Steam LNG Air 23,645 23,645

Water 3,960 2,709 1,320 73,261 5,319 69,189 69,300 CO2 3,411 3,411

NaOH 160 7.1 7.1 150 Ca(OH)2 2,785 90

FeCl3 69 69 Polymer 34.7 34.7

CaF2 2,417 1.35 1.35 CaCl2 68 203 NaCl 14.7 14.7 14.7 234 NaF 150 109

Sludge (dry) 2,753 Note: See Annex 5 for the detail analysis process of material balances.



According to the results of material balances in Table 5-2, environmental discharges by this project are listed in Table 5-3.

Table 5-3 Environmental Discharges from HFC-23 Process

Items Pollutants Concentration Discharge rate Receptors Fluoride ≤9.0 mg/m3 ≤0.2 t/a HCl ≤100 mg/m3 ≤2 t/a Air Emission Dioxins ≤0.1 TEQ ng/m3 ≤2 mg/a

Ambient air

Wastewater Fluoride ≤10 mg/l ≤0.7 t/a Wangyu River Sludge CaF2 / 8072 t/a Road Construction Noise Shown below The major noise sources in this project include the air blower for the incinerator, the draft fan for the flue gas treatment system and various water pumps. The levels of noise emissions from the equipment are shown in Table 5-4.

Table 5-4 Levels of Noise Emissions from Major Process

Main Equipment Equipment Quantity Source Strength dB(A)

Air blower for the incinerator 2 95

Draft fan for the flue gas treatment system 1 90

Various water pumps 4 80

5.2 Mitigation Measures

5.2.1 Construction Phase

(1) Air emissions

Regular sprinkling of water in the construction area to reduce dust emissions. The transportation vehicle in the construction area will have a speed less than 40

km/h to reduce dust emissions from the land. To mitigate impacts of the construction dust on surroundings, the construction

areas will be enclosed with fences with a height of at least 1.8m. (2) Wastewater discharges

Sewage: After collection, sewage will be discharged to the sewage network for treatment at the municipality’s WWTP.

Construction wastewater: The construction wastewater will be sent to the WWTP of Changshu 3F Zhonghao for treatment.



(3) Solid waste discharges

The domestic refuse in residential region will be bagged, cleaned by sanitation workers to designated piling points every day.

The construction unit will avoid the loss of construction materials in transportation, loading and unloading and construction as possible as it can. The construction waste will be stored in approved piling points and cleaned timely for terra and rolled-earth fill or transported to municipal landfill plant.

(4) Noise emissions

The following measures will be taken to mitigate noise pollution during construction phase:

Making the construction scheme reasonably to avoid using heavy-noise equipment at night.

Using low-noise equipment as much as possible. Enclosing a barrier for heavy-noise equipment (e.g. a compressor). Sound insulation with soundproof facilities. Frequent maintenance of the construction equipment. Using ear plugs near heavy-noise equipment.

5.2.2 Operational Phase

5.2.2.1 Air Pollution Mitigation Measures

The following measures will be taken to mitigate air pollution from this project:

(1) The incinerator will be operated at a negative pressure as stipulated in the Chinese regulation GB 18484/2001 (Pollution Control Standard for Hazardous Wastes Incineration). Operation at negative pressure will prevent discharge of any emissions from the incinerator.

(2) The flue gases from the incinerator will be treated. The treatment will include: (i) water quenching, (ii) water scrubbing, and (iii) alkali scrubbing. The technology for this treatment is available in China and abroad. This technology will be able to reduce the pollutant concentrations in the incineration flue gases to meet the following standards in the Chinese regulation GB 18484-2001. As can be seen below, the standards in GB 18484 are comparable to the UNEP Guidelines. For dioxins emissions, the UNEP Guideline of 0.1 TEQ ng/m3 will be used instead of the Chinese standard of 0.5 TEQ ng/m3.



Monitoring Results Parameters GB 18484-2001 UNEP Guideline at INEOS Fluor HF 9 mg/m3 5 mg/m3 0.5 mg/m3 HCl 100 mg/m3 100 mg/m3 3 mg/m3 PM 20 mg/m3 50 mg/m3 15 mg/m3 CO 100 mg/m3 80 mg/m3 3 mg/m3 Dioxins 0.5 TEO ng/m3 0.1 TEQ ng/m3 0.0006 TEQ ng/m3

The proposed technology was used at INEOS Fluor, Japan. As can be seen from the monitoring results given above, this technology was found to be effective at INEOS Fluor in reducing the pollutant concentrations to levels that are much lower than those required by GB 18484 or UNEP Guideline.

(3) The incineration gases form the above-mentioned treatment will be emitted to the atmosphere through two stacks (for Line A, 31m; for Line B, 36m), which meets the 25-meter stack height requirement stipulated in GB 18484. This stack height is adequate to provide good dispersion of pollutants to meet the ambient quality standards (see Section 6.2.1.1 for dispersion modeling results).

5.2.2.2 Water Pollution Mitigation Measures

The wastewater generated by this project will be treated by a special WWTP (Section 7-3). The following measures will be taken to mitigate water pollution from this project:

(1) All of the wastewater form HFC-23 reduction process is directed into the WWTP of the project where it will be treated for fluoride removal. This treatment is necessary because the fluoride concentration from the HFC-23 process (18.57 g/l) dose not meet the Chinese discharge standard of 10 mg/l (GB8978-1996). The treatment will include precipitation of fluoride with calcium hydroxide, settling and dewatering of the sludge. The treated wastewater will be able to meet the discharge standard of 10 mg/l.

(2) The filtrate from the filter-pressing of the sludge will be directed back to the neutralization pond where it will be treated again through the WWTP.

(3) The fluoride concentration in the effluent from the WWTP will comply with the wastewater discharge standard for fluoride (10 mg/l) for Category 1 of Integrated Wastewater Discharge Standard (GB 8978-1996) (Annex 3).

5.2.2.3 Sludge Management Mitigation Measures

The solid wastes generated in this project are mainly sludge from the WWTP. The following measures will be taken to mitigate sludge pollution from this project:

The sludge from the WWTP will be dewatered by a filter press to produce a filter cake with



approximately 65 percent moisture. The filter cake consists of mainly CaF2 which is not classified as hazardous waste. The filter cake will be stored temporally for using as road construction.

5.2.2.4 Noise Pollution Mitigation Measures

Mitigation measures for noise pollution from this project will include: selecting low-noise equipment, sound insulation of the plant building, and damping of vibration to foundation. This results in a noise reduction of 30-45 dB(A), and makes the noise at the boundary of this project meet with the requirements of Standard of Noise at Boundary of Industrial Enterprises. The mitigation measures and their effectiveness are shown in Table 5-5.

Table 5-5 Noise Pollution Mitigation Measures and Their Effectiveness

Main Equipment Mitigation Measures Sound Level after

the Mitigation Measures (dB(A))

Standard(dB(A))

Air blower of the incinerator

Damping of vibration to foundation, sound insulation with soundproof room, furnishing muffler

Draft fan of waste gas treatment facilities

Sound insulation with soundproof room, damping of vibration to foundation, furnishing muffler

Various water pumps

Damping of vibration to foundation, sound insulation with soundproof cover

≤26

(see Tables 6-12, 6-13)

Day: 65 Night: 55



6 Impacts of Discharges on Receptors

6.1 Construction Phase

The construction of this project will bring some impacts on surroundings. See Table 6-1 for details:

Table 6-1 Impacts of Discharges on Receptors during Construction Phase

Environmental Discharges

Receptors Impacts after Taking of the

Mitigation Measures

Air emissions The office building area and other plants of Changshu 3F Zhonghao

Negligible

Wastewater discharges The surface water Negligible Solid waste discharges The plant area Negligible

Noise emissions The office building area and other plants in Changshu 3F Zhonghao

Shown below

Analysis of impacts of noise emissions:

Table 6-2 Compliance Status of Construction Equipment Noise

Standard Distance Scope in Compliance (m) Construction Equipment

Day Night Day Night Self-discharging truck 65 55 ＞212 ＞670

Scraper 75 55 ＞67 ＞670 Bulldozer 75 55 ＞60 ＞600

Grab 75 55 ＞95 ＞950 Air Pick 75 55 ＞67 ＞670

Clay Rabbling 70 55 ＞27 ＞150 Shaker 70 55 ＞27 ＞150

The table above shows that construction noise affects a small area but for heavy-noise equipment the distance in compliance will be 600-700m at night. As a result, the noise in construction phase will have impacts on construction worker and the employees in Changshu 3F Zhonghao. The construction activities will have a negligible impact on the nearby plants outside because of the big distance. So the construction unit must conduct their construction activities with necessary mitigation measures to meet the noise standards. Heavy-noise generating equipment (such as self-discharging truck, scraper and grab) should not be used at night.



6.2 Operational Phase

6.2.1 Air Impact Assessment

As the main objective of this project, the HFC-23 emissions from Changshu 3F Zhonghao would reduce global warming. Assuming that the HFC-23 emissions are about 4% of the HCFC-22 production, the HFC-23 emissions reduction benefits may reach 1,600 tpy at Changshu 3F Zhonghao. Given that the global warming potential of HFC-23 is 11,700, this corresponds to an equivalent of 18.72 million tons of CO2 emissions reduction.

But regarding the possible air pollution brought by this project, detail analysis is presented as following.

6.2.1.1 Selection of Air Dispersion Model

At present, the major air dispersion models include Gaussian model, SCREEN3, PLUME5 and CTDMPLUS. The characteristics of these models are listed in Table 6-3.

Table 6-3 Characteristics of the Air Dispersion Models

Terrain Land Use Pollutant Source Configuration Time

Items Flat

Com-

plex Urban Rural

Gas-

eous

Parti-

culate Point

Elevated

Point

Multiple

Point

Short-term

Exposure

Long-term

Exposure

Gaussian Y Y Y Y Y Y Y Y Y Y N

SCREEN3 Y Y Y Y Y Y Y Y N Y N

PLUME5 Y Y Y Y Y N Y Y Y Y Y

CTDMPLUS N Y N Y Y Y Y Y Y Y N

Note: “Y” means “suitable for use”; “N” means “not suitable for use”.

The Gaussian model is often used as a kind of air dispersion model on industrial air emission. It can be used to analyze the concentration distribution of air pollution upon several kinds of scenarios. Gaussian model is characterized as “preferred models” in Technical Guidelines for Environmental Impact Assessment-Atmospheric Environment (HJ/T2.2-93) by SEPA because it meets certain minimum technical criteria, have undergone field testing and have had extensive peer review. And there is a documented experience base in China for Gaussian model which will add more credibility to the analysis or eliminate the need for model validation. So, Gaussian model is selected to analysis the air impact assessment in this report.

6.2.1.2 Description of the Selected Model

Here shows the detail information of Gaussian model:



(1) Air dispersion model during windy conditions

Under this condition, air dispersion model is based on the following formulas:

FyUQc

yzy

⋅

σ−

σσπ= 2

2

2exp

2 (6-1)

( ) ( )∑

σ+

−+

σ−

−= 2

2

2

2

22exp

22exp

zz

HenhHenhF (6-2)

HHsHe ∆+= (6-3)

Where,

c: Ground-level concentration of any downwind point, mg/m3;

Q: Emission rate, mg/s;

y: Crosswind distance, m;

σy: Lateral dispersion parameter, m;

σz: Vertical dispersion parameter, m;

U: Stack height wind speed, m/s;

h: The thickness of mixed layer, m;

He: Effective Stack Height, m;

Hs: Stack height, m;

∆H: Plume rise, m.

(2) Air dispersion model on stagnant atmospheric conditions

Under this condition, air dispersion model is based on the following formulas:

( )( )

GQYXCL ⋅=ηγπ 02

2322, (6-4)

⋅++= 2

202

201222

eHYXγγ

η (6-5)

( ){ }sseeG sU Φ⋅⋅+⋅= − 22 2201

2

21 πγ (6-6)

( ) ∫∞−

−=Φs

t dtes 22

21π

(6-7)



ηγ 01

UXs = (6-8)

Where,

cL: Ground-level concentration of any downwind point on stagnant atmospheric conditions, mg/m3;

X: Horizon distance, m;

Y: Crosswind distance, m;

γ01: Regression coefficient of lateral dispersion parameter;

γ02: Regression coefficient of vertical dispersion parameter;

t: Time for air dispersion, s;

Q, U, He: The same definitions as above.

(3) The maximum ground-level concentration and the distance

The maximum ground-level concentration and the distance is based on the following formulas:

( )1

2

2PHUe

Qxce

mm ⋅⋅⋅π⋅=

(6-9)

α

α−

α

α−

α

α+

αα−

⋅⋅

αα

+

γ⋅γ=

2

1

2

12

1

21

121

11

21

2

1

211

1

2

eH

P

e

(6-10) ( )( )22 21

2

1

1

2

1α−α

αα

+

γ

= em

Hx (6-11)

Where,

Cm: Maximum ground-level concentration, mg/m3;

xm: Horizon distance from the flue gas emission source to the maximum ground-level concentration point, m;

γ1: Regression coefficient of lateral dispersion parameter;

γ2: Regression coefficient of vertical dispersion parameter;

α1: Regression index of lateral dispersion parameter;

α2: Regression index of vertical dispersion parameter;

Q, U, He: The same definitions as above.

(4) Daily average concentration

The daily average concentration is based on the following formulas:



( ) ( )∑

=

=N

ihd YXC

NYXC

1,1,

(6-12)

Where,

Cd: Daily average concentration, mg/m3;

Ch: 1-hr avg. concentration, mg/m3;

N: Number of hours;

X, Y: The same definitions as above.

6.2.1.3 Input Data

(1) Parameters of Waste Gas Pollution Source are presented in Table 6-4.

Table 6-4 Parameters of Waste Gas Pollution Source

Stack Pollutant Discharge Rate (mg/s) Items

Flue gas flowrate (m3/h)

Height (m)

Diameter (m)

HCl Fluoride Dioxins

Normal Process Conditions 70 6.3 7.0×10-8

Upset Process Conditions 2525 25 0.6

1,955 47,635 7.0×10-6

Note: Under upset process conditions, assume all of the HCl and HF generated in the incinerator emit into the

atmosphere directly without treatment. According to Column 5 in Table 5-2 (Referring to Node 5 in Figure 3-3

which present all of the waste gas generated from HFC-23 incinerator) we can see, the emissions of HCl and HF

are 55.9 tpy and 1,433 tpy respectively. After conversion, the emission of Fluoride (based on F) is 1361.35 tpy.

So, the emission rate of HCl and Fluoride is 1,955 mg/s and 47,635 mg/s respectively.

(2) Meteorologic parameters on windy time are presented in Table 6-5.

Table 6-5 Average Weather Parameters of Different Stability Conditions

Atmospheric Stability Type A-B Type C Type D Type E-F Thickness of Mixed Layer (m) 1250 900 550 250 Power Index of Wind Profile 0.07 0.10 0.15 0.25

Temperature Lapse Rate 1.8 1.6 1.0 -1.6 Ground Wind Speed (m/s) 2.5

Predominant Wind Direction NNE



(3) Meteorologic parameters on representative days are presented in Table 6-6.

Table 6-6 Meteorologic Conditions on Representative Days

Representative Day 1 Representative Day 2 Wind

Direction Wind Speed (m/s)

Atmospheric Stability

Wind Direction

Wind Speed (m/s) Atmospheric

Stability ENE 2.0 D NWW 2.0 D

E 2.2 D NW 2.2 E ENE 2.2 E NW 2.5 D ENE 2.5 C NWW 3.0 D ENE 2.0 B N 3.3 D ENE 2.3 D NNW 3.0 D

E 2.2 D NW 2.5 B NE 2.0 D N 2.2 B

6.2.1.4 Simulation Results

Air dispersion modeling of HCl, HF, and dioxin emissions from the HFC-23 process was conducted for: (i) windy conditions, (ii) stagnant atmospheric conditions, and (iii) representative days. The cases evaluated under windy conditions and stagnant atmospheric conditions include: (i) Normal process conditions, and (ii) Upset process conditions. Under upset process conditions, it is assumed that all of the HCl and HF generated in the incinerator would discharge into the atmosphere directly without any treatment. The concentration of dioxins in the gas emission is assumed to be 10 TEQ ng/m3 under upset process conditions (Based on a national survey of emissions from incinerators, the discharge concentration of dioxins from underdesigned incinerators can exceed the standard by 100 times).

(1) Simulation results for windy conditions

Maximum ground-level concentration (1-hr avg.) and distance The maximum ground-level concentrations (1-hr avg.) of the pollutants and the distance from the flue gas emission source are calculated (Table 6-7), using equations 6-9, 6-10, and 6-11; and the input data given in Tables 6-4 and 6-5.



Table 6-7 Maximum Ground-Level Concentration (1-hr avg.) and Distance during Windy Conditions

Atmospheric Stability Process

Conditions

Concentration (1-hr avg.) and

Distance Type B Type C Type D Type E

Standard

(1-hr avg.)

(see notes)

HCl (µg/m3) 4.2 3.94 3.38 1.55 50

Fluoride (µg/m3) 0.366 0.354 0.304 0.14 20 Normal

Conditions Cmax

Dioxins (ng/m3) 4.07×10-7 3.94×10-7 3.38×10-7 1.55×10-7 /

HCl (µg/m3) 117 110 94 43 50

Fluoride (µg /m3) 2,770 2,680 2,300 1,060 20 Upset

Conditions Cmax

Dioxins (TEQ ng/m3) 4.07×10-5 3.94×10-5 3.38×10-5 1.55×10-5 /

Xmax(m) 180 282 379 929 /

Notes: 1. “Cmax” means the maximum ground-level concentration;

2. “Xmax” means the horizon distance from the flue gas emission source to the maximum ground-level

concentration point;

3. The standard for fluoride is Category 2 of Ambient Air Quality Standard (GB 3095-1996) (Annex 3);

4. The standard for HCl is from Table 1 of Hygienic Standards for the Design of Industrial Enterprises (TJ 36-79):

Maximum allowable concentrations of harmful substance in ambient air of residential district.

Table 6-7 shows the following results:

Normal process conditions: The distance of the maximum ground-level concentration (1-hr avg.) of HCl, fluoride and dioxins - which are emitted by the incinerator of this project against the predominant wind direction is 180 meters (180 meters south-south-west of the project site). This occurs under atmospheric stability Type B. The receptor at this point is the Land Reserved for FCIP Phase II (See Figure 2-3). The maximum ground-level concentration (1-hr avg.) of HCl is 4.2 µg/m3, only 8.4% of the environmental standard; and of fluoride is 0.366 µg/m3, only 1.8% of the standard; and of dioxins is 4.07×10-7 TEQ ng/m3. So the pollutants emitted by this project will have a negligible impact on the receptors.

Upset process conditions: The distance of the maximum ground-level concentration (1-hr avg.) of HCl, fluoride and dioxins which are emitted by the incinerator of this project against the predominant wind direction is 180 meters (180 meters south-south-west of the project site). This occurs under atmospheric stability Type B. The receptor at this point is the Land Reserved for FCIP Phase II (See Figure 2-3). The maximum ground-level concentration (1-hr avg.) of HCl is 117 µg/m3, 2 times the HCl environmental standard; and of fluoride is 2,770 µg/m3, 139 times the standard; and of dioxins is 4.07×10-5 TEQ ng/m3. So the fluoride emitted by this project under upset process conditions and with atmospheric stability Type B will have a major impact on the receptor. In addition, HCl emitted by this project will also have a negative impact on the receptor.

Under atmospheric stability Types C, D, and E, the fluoride concentrations also greatly



exceed the fluoride ambient quality standard; and under atmospheric stability Types C and D, the HCl concentrations also a little exceed the HCl ambient quality standard. In addition, dioxin concentrations in the range of 1.55×10-5 to 3.94×10-5 TEQ ng/m3 are predicted.

Under atmospheric stability Type C, the ambient fluoride concentration exceeds the standard by 134 times at a point 282 meters south-south-west of the project site, where the ambient HCl concentration exceeds the standard by 2 times. The receptor at this point is the Land Reserved for FCIP Phase II. Under atmospheric stability Type D, the ambient fluoride concentration exceeds the standard by 115 times at a point 379 meters south-south-west of the project site, where the ambient HCl concentration exceeds the standard by less than 2 times. The receptor at this point is the Land Reserved for FCIP Phase II. Under atmospheric stability Type E, the ambient fluoride concentration exceeds the standard by 53 times at a point 929 meters south-south-west of the project site. The receptor at this point is the Land Reserved for FCIP Phase II. There are no agricultural lands or crops involved (See Figure 2-3).

Maximum ground-level concentration (1-hr avg.) at the receptors The maximum pollutant concentrations (1-hr avg.) at the Receptors are calculated (Table 6-8), using equations 6-5, 6-6, 6-7 and 6-8 and the input data given in Table 6-4 and 6-5.

Table 6-8 Maximum Concentration (1-hr avg.) at the Receptors during Windy Conditions (µg/m3)

Receptors Dengshi Fushan Town Wangshi Town

Unfavorable wind direction NW NE NW

Standard

(1-hr avg.)

(see notes)

Normal Conditions 0.44 1.56 0.22 HCl

Upset Conditions 12.29 43.57 6.14 50

Normal Conditions 0.04 0.14 0.02 Fluoride

Upset Conditions 302.4 3024.4 151.2 20





Normal process conditions: The ambient air quality standards for HCl and fluoride will be met at all receptors, including Dengshi, Fushan Town, and Wangshi Town. The maximum HCl concentration is predicted for Fushan Town (1.56 µg/m3), which is approximately 3% of the ambient standard. The maximum fluoride concentration is predicted for Fushan Town (0.14 µg/m3), which is less than 1% of the ambient standard. That is, the flue gas emitted by this project will have a negligible impact on the receptors under normal process conditions.



Upset process conditions: The ambient HCl concentrations at all receptors will meet the ambient quality standard of 50 µg/m3. However, at Dengshi, Fushan Town, and Wangshi Town, the ambient HF concentrations at these receptors will be greatly exceeded under upset process conditions. At Dengshi, the ambient concentration of HF discharged by this project is predicted to be 302.4 µg/m3, more than 15 times the ambient standard. At Fushan Town, the ambient concentration of HF is predicted to be 3,024 µg/m3, approximately 150 times the ambient standard. And at Wangshi Town, the ambient concentration of HF is predicted to be 151.2 µg/m3, more than 7 times the ambient standard. That is, the fluoride emitted by this project under upset process conditions will have a major impact on the receptors.

(2) Simulation results for stagnant atmospheric conditions

Maximum ground-level concentration (1-hr avg.) and distance The maximum ground-level concentrations (1-hr avg.) of the pollutants and the distance from the flue gas emission source are calculated (Table 6-9), using equations 6-9, 6-10, and 6-11, and the input data given in Table 6-4.

Table 6-9 Maximum Ground-Level Concentration (1-hr avg.) and Distance during Stagnant Atmospheric Conditions

Atmospheric Stability Process

Conditions

Concentration (1-hr avg.) and

Distance Type B Type C Type D Type E

Standard

(1-hr avg.)

(see notes)

HCl (µg/m3) 11.06 9.78 7.53 0.64 50

Fluoride (µg/m3) 0.994 0.88 0.68 0.057 20 Normal

Conditions Cmax

Dioxins (ng/m3) 1.1×10-6 9.76×10-7 7.52×10-7 6.37×10-8 /

HCl (µg/m3) 309 273 210 18 50

Fluoride (µg /m3) 7,520 6,650 5,140 430 20 Upset

Conditions Cmax

Dioxins (TEQ ng/m3) 1.1×10-4 9.76×10-5 7.52×10-5 6.37×10-6 /

Xmax(m) 33 81 145 756 /

Notes: 1. “Cmax” means the maximum ground-level concentration;

2. “X max” means the horizon distance from the flue gas emission source to the maximum ground-level

concentration point;

3. The standard for fluoride is Category 2 of Ambient Air Quality Standard (GB 3095-1996) (Annex 3);




Normal process conditions: The distance of the maximum ground-level concentration (1-hr avg.) of HCl, fluoride and dioxins which are emitted by the incinerator of this project against the predominant wind direction is 33 meters (33 meters south-south-west of the project site). This occurs under atmospheric stability Type B. The receptor at this point is the pond within the Changshu 3F Zhonghao facility (See Figure 2-3). The maximum



ground-level concentration (1-hr avg.) of HCl is 11.06 µg/m3, only 22% of the environmental standard; and of fluoride is 0.994 µg/m3, only 5% of the standard; and of dioxins is 1.1×10-6 TEQ ng/m3. So the pollutants emitted by this project will have a negligible impact on the environment.

Upset process conditions: The distance of the maximum ground-level concentration (1-hr avg.) of HCl, fluoride and dioxins emitted by the incinerator of this project against the predominant wind direction is 33 meters (33 meters south-south-west of the project site). This occurs under atmospheric stability Type B. The receptor at this point is the pond within the Changshu 3F Zhonghao facility (See Figure 2-3). The maximum ground-level concentration (1-hr avg.) of HCl is 309 µg/m3, 6 times the environmental standard; and of fluoride is 7,520 µg/m3, 376 times the standard; and of dioxins is 1.1×10-4 TEQ ng/m3. So the fluoride emitted by this project under upset process conditions will have a major adverse impact on the receptor. In addition, HCl emitted by this project will result in ambient HCl concentration that is 6.2 times the standard, and will also have a negative impact on the receptor.

In addition, under atmospheric stability Types C, D, and E, the fluoride concentrations also greatly exceed the fluoride ambient quality standard; and under atmospheric stability Types C and D, the HCl concentrations also exceed the HCl ambient quality standard. In addition, dioxin concentrations in the range of 6.37×10-6 to 9.76×10-5 TEQ ng/m3 are predicted.

Under atmospheric stability Type C, the ambient fluoride concentration exceeds the standard 333 times, and the ambient HCl concentration exceeds the standard by more than 5 times at a point 81 meters south-south-west of the project site, where the receptor at this point is the Fushan Pond. Under atmospheric stability Type D, the ambient fluoride concentration exceeds the standard 257 times and the ambient HCl concentration exceeds the standard less than 4 times at a point 145 meters south-south-west of the project site, where.the receptor at this point is the Land Reserved for FCIP Phase II. Under atmospheric stability Type E, the ambient fluoride concentration exceeds the standard 22 times at a point 756 meters south-south-west of the project site, where the receptor at this point is the Land Reserved for FCIP Phase II. There are no agricultural lands or crops involved (See Figure 2-3).

(3) Simulation results for representative days

The daily average concentrations at the receptors are calculated (Table 6-10, Figure 6-1, Figure 6-2), using equation 6-12 and the input data given in Tables 6-4 and 6-6.



Table 6-10 Daily Average Concentration at the Receptors on Representative Days (µg /m3)

Receptors Dengshi Fushan Town Wangshi Town

Standard

(1-hr avg.)

(see notes)

Representative Day 1 0 0.0174 0 HCl

Representative Day 2 0.0039 0 0.002 15

Representative Day 1 0 0.193 0 Fluoride

Representative Day 2 0.043 0 0.022 7




From Table 6-10, Figure 6-1 and Figure 6-2 we can see that the daily average concentrations of HCl and fluoride on the receptors by the proposed project are much lower than the standards. That is, the flue gas emitted by this project will have a negligible impact on the receptors (including Dengshi, Fushan Town, and Wangshi Town).

(4) Conclusion

Only under upset process conditions, fluoride emitted by this project is predicted to result in fluoride concentrations that will greatly exceed the 1-hour ambient quality standard. In addition, only under upset process conditions with atmospheric stability Type B, C, and D, HCl emitted by this project is predicted to result in a maximum ground-level concentration (1-hr avg.) that is several times over the standard.

Any negative impacts on the receptors during the upset process conditions will be prevented through implementation of the project’s emergency procedures. These procedures will involve closing the discharge to the stack and purging all flue gases from the HFC-23 Process to the emergency gas storage tank of the HFC-23 Emissions Reduction Process (please see Figures 3-3 and 7.2). The emergency procedures also call for the use of the intermediate storage tank to store the HFC-23 waste gas from the HCFC-22 Process (please see Section 7.2 Evaluation of Alternatives for Emission Controls of Air Pollutants under Upset Process Conditions).



Figure 6-1 Contour Map of 1-day Average Concentration of Fluoride on Representative Days

Figure 6-2 Contour Map of 2-day Average Concentration of Fluoride on Representative Days



Figure 6-3 Contour Map of 1-day Average Concentration of HCl on Representative Days

Figure 6-4 Contour Map of 2-day Average Concentration of HCl on Representative Days



6.2.2 Wastewater Impact Assessment

Treated wastewater from this project will be discharged to the wastewater piping network of the Industrial Park for pumping to the Yangtze River. After treatment at Changshu 3F Zhanghao’s WWTP, the wastewater will be compliance with the applicable standard6. So it will have a negligible impact on the surface water, which has a huge absorption capacity.

6.2.3 Groundwater Impact Assessment

The possible pollution sources to groundwater by the HFC-23 Emissions Reduction Project include:

Chemical and wastewater spillage from tanks Spillage during loading and other transfer operations (e.g. pipeline transfer) Wastewater leakage from the pipeline and WWTP Sludge spillage in WWTP

To prevent or reduce adverse impacts to groundwater, the following measures will be taken:

Impermeable floor: concrete will be used in the production areas to prevent the infiltration of chemical or wastewater spillage into the ground.

Containment around tanks: to collect the chemical and wastewater spill from the tanks in production area.

Preventive maintenance: to reduce the chemical and wastewater spill in advance. Frequent inspections: to avoid unforeseen spill or infiltration as much as

possible. With the above measures, adverse impacts on the groundwater by this project will be eliminated.

6.2.4 Solid Waste Impact Assessment

Sludge generated in WWTP of this project will be the main solid wastes during the operational phase. See Section 5.1.2 and Section 5.2.2.2 for detail information about sludge discharges and mitigation measures. By taking these mitigation measures, there will have negligible impact on surroundings by the HFC-23 Emissions Reduction Project.

6.2.5 Noise Impact Assessment

(1) Prediction model

6 Fluoride standard: 10mg/l. Category 1 of Integrated Wastewater Discharge Standard (GB 8978-1996) (Annex 3).



The “Technical Guidelines for EIA: Noise Environment (HJ/T2.4-1995)” is used to predict the noise impacts of this project. The model is based on noise attenuation from a point source according to the following formula:

( ) ( ) LrrrLrL ∆−

−=

00 lg20

(6-13)

Where,

L: Noise level contributed by the point source at any point, dB(A);

r, r0: Distance from the point source, m;

∆L: Noise attenuation by sound barrier, shelter, air absorbing and the ground, dB(A).

The model predicts noise superposition according to the following formula:

= ∑

=

n

i

LiL1

1.010lg10 (6-14)

Where,

L: Noise level after superposition, dB(A);

Li: Noise level at the predict point contributed by the sound source i, dB(A);

(2) Input data

The input data used in this model include the noise levels (before and after mitigation measure) and the distance of the noise sources to Changshu 3F Zhonghao’s boundaries (Table 6-11).

Table 6-11 Information of the Noise Sources

Distance to Changshu 3F Zhonghao’s Boundary (m)

Noise Sources Noise Level

(dB(A))

Noise Level of the Noise Source after the Mitigation Measures

(dB(A)) East South West North

Air blower for the incinerator 95 60 88 55 120 100

Draft fan for waste gas treatment facilities 90 60 80 50 128 105

Various water pumps 80 60 85 52 123 103 (3) Simulation results

The noise levels at Changshu 3F Zhonghao’s boundaries by the HFC-23 Emissions



Reduction Project are calculated using the input data given in Table 6-11 and formula 6-13, 6-14. The results are presented in Tables 6-12 and 6-13 for daytime and night time, respectively.

Table 6-12 Noise Simulation Results at Changshu 3F Zhonghao’s Boundary in Daytime (Unit: dB(A))

Monitoring Codes

Location of Monitored

Points

Present Noise Level

Contribution Forecast

Noise Level Standard (see notes)

Status

Z1 South border 58.5 26 58.5 In compliance Z2 South border 59.2 25 59.2 In compliance Z3 East border 57.8 21.9 57.8 In compliance Z4 East border 58.3 21 58.3 In compliance Z5 West border 56.6 18.4 56.6 In compliance Z6 North border 57.4 20 57.4

65

In compliance Notes: 1. Column “Contribution” means “Noise level contributed by this project”.

2. The standard is Standard of Noise at Boundary of Industrial Enterprises (GB 12348-90) (Annex 3).

Table 6-13 Noise Simulation Results at Changshu 3F Zhonghao’s Boundary at Night (Unit: dB(A))

Monitoring Codes

Location of Monitored

Points

Present Noise Level

Contribution Forecast

Noise Level Standard (see notes)

Status

Z1 South border 45.7 26 45.7 In compliance Z2 South border 45.7 25 47.5 In compliance Z3 East border 46.2 21.9 46.2 In compliance Z4 East border 47.9 21 47.9 In compliance Z5 West border 46.1 18.4 46.1 In compliance Z6 North border 46.5 20 46.5

55

In compliance Notes: 1. Column “Contribution” means “Noise level contributed by this project”.

2. The standard is Standard of Noise at Boundary of Industrial Enterprises (GB 12348-90) (Annex 3).

The results in Table 6-12 and Table 6-13 show compliance with the applicable noise quality standards. Therefore, the HFC-23 Emissions Reduction Project will have negligible noise impacts on its surroundings.

6.2.6 Social Impacts

The social impacts of this project to the local people and Changshu 3F Zhonghao include:

(1) Implementation of this project will bring employment opportunities to 40-50 workers during the construction phase and to 40 workers during the operational phase.



(2) Since benefited from this project, Changshu 3F Zhonghao may invest on the local environmental protection activities and economic development, by which the living levels of the local people will be considerably promoted.

(3) After implementation of this project, Changshu 3F Zhonghao will get a certain sum of money. It is beneficial for the Changshu 3F Zhonghao’s sustainable development. But it will be disallowed that Changshu 3F Zhonghao expand its HCFC-22 production with this money to emit more HFC-23 to the environment.

(4) Implementation of this project will improve Changshu 3F Zhonghao’s reputation and make the enterprise more famous in China and even in the world. It can help the enterprise to enhance its competitiveness in its field.



7 Evaluation of Alternatives

HFC-23 has a low toxicity. As HFC-23 has a large GWP (11,700), its emissions are controlled under the Kyoto Protocol. Implementation of this project at Changshu 3F Zhanghao would achieve Green House Gas (GHG) emission reductions by 18.7 million tpy CO2 equivalent (which would contribute to the mitigation of global warming), while promoting sustainable development and technical benefits to China.

To determine the optimum schemes to implement the HFC-23 Emissions Reduction Project, the following alternatives are evaluated in this section: (i) process options for HFC-23 emissions reduction, (ii) emission controls of air pollutants, and (iii) wastewater treatment and sludge management.

7.1 Evaluation of Alternative Process Options for HFC-23 Emissions Reduction

Four options are evaluated for the HFC-23 emissions reduction process:

Option 1: Without the project option;

Option 2: Incineration;

Option 3: Process optimization;

Option 4: Process optimization combined with incineration.

Comparison of the four options above is given in Table 7-1.

Table 7-1 Comparison of the Options for HFC-23 Emissions Reduction

Option 1 Option 2 Option 3 Option 4 Items

Without the Project Incineration Process Optimization Option 2 + Option 3

Treatment effect none good ordinary better

Investment none RMB 38.9 million less high

Operating cost none higher less high

Process flow none complex simple complex

Operation, management

and maintenance none complex simple complex

Raw materials

consumption none higher less high

Pollutants amount none high less high

As shown in Table 7-1, Option 4 is the optimum solution given the current conditions,



which would be first process optimization until the breakeven point is reached and then incineration of the HFC-23 that cannot be avoided by process optimization. The reason is that it is not possible to reduce the HFC-23 concentration to 0 level only by process optimization. However, although it is possible to reduce the HFC-23 concentration to 0 level by incineration, this technology is expensive in terms of capital and operating costs. So, a recommended solution would be to use process optimization to a technically feasible point where the cost of process optimization breaks even against the cost of incineration, and then switch to the incineration technology to get the HFC-23 emissions to nearly 0 level. It should be noted that process optimization would be much more attractive than incineration at higher ratios of HFC-23 waste gas-to-HCFC-22 production. In addition, the costs of process optimization and incineration technology both involve costs associated with technology transfer.

7.2 Evaluation of Alternatives for Emission Controls of Air Pollutants under Upset Process Conditions

Section 6 predicted that only under upset process conditions, fluoride emitted by this project would result in ambient fluoride concentrations that will greatly exceed the 1-hour ambient quality standard. In addition, Section 6 predicted that only under upset process conditions and atmospheric stability Type B, C, and D, HCl emitted by this project is predicted to result in a maximum ground-level concentration (1-hr avg.) that several times over the standard.

To mitigate the negative impacts on receptors, the following two options are evaluated and compared with the base-case Option 1 (no controls on gas emissions): Option 2 (installation of a parallel gas cleanup system) and Option 3 (installation of gas storage tanks).

(1) Option 1: No control of gaseous emissions

This option assumes: (i) failure of the incinerator or the gas cleanup system, and (ii) direct air emissions of the flue gases to the atmosphere without any treatment. As summarized above and further discussed in Section 6, these emissions would result in ambient fluoride concentrations above the ambient quality standard. In addition, under stagnant atmospheric conditions with atmospheric stability Type B, C, and D, ambient HCl concentrations would be over the ambient standard. As a result, negative impacts would be expected on the receptors (including Fushan Town, Dengshi, and Wangshi Town).

(2) Option 2: Installation of a parallel gas cleanup system

This option assumes: (i) failure of the incinerator or the gas cleanup system (#1), and (ii) installation of an identical, parallel (i.e. standby) gas cleanup system (#2) to treat the flue gases in case of the failure of the incinerator or the original gas cleanup system. Under this option, the flue gases are diverted from the original gas cleanup system (#1) to an identical, parallel gas cleanup system (#2) without any emission of pollutants to the atmosphere, thus avoiding any negative impacts on the receptors (see Figure7-1). In the



meantime, the original cleanup system would be inspected and repaired for service.

Figure 7-1 Process Flow Diagram of a Parallel Gas Cleanup System

(3) Option 3: Installation of gas storage tanks

This option assumes: (i) failure of the incinerator or the gas cleanup system, (ii) installation of an emergency gas storage tank which is acid-proof to provide a storage capacity that would collect all the gases within the system, which would otherwise be emitted to the atmosphere, (iii) installation of a intermediate storage tank to store the HFC-23 waste gas from the HCFC-22 Process. Under this option, emergency procedures would involve closing the discharge to the stack and purging all flue gases from the HFC-23 Process to the emergency gas storage tank, thus avoiding any adverse impacts on the receptors. The emergency procedures also call for the use of the intermediate storage tank to store the HFC-23 waste gas from the HCFC-22 Process, thus avoiding emission of this global warming gas to the atmosphere.

The intermediate storage tank is devised to have a capacity of 240 m3 to store the HFC-23 waste gas from the HCFC-22 Process at a maximum of 41 atm, for a period of 6 days. And the emergency gas storage tank is devised to have a capacity of 10 m3 to store the gases within the system at a maximum of 41 atm. After the defective equipment is repaired, then stored gases from the two storage tanks would be directed to the incinerator of the HFC-23 Emissions Reduction Project.


HFC

-23

Inci

nera

tor

#1 Gas Cleanup System

#2 Gas Cleanup System

WWTP

Air Emissions

Air Emissions Wastewater Discharge



Figure 7-2 Process Flow Diagram for the HFC-23 Project with Gas Storage Tanks

Comparison of the three options above is described in Table 7-2 and the cost details are presented in Table 7-3.

Table 7-2 Comparison of the Options for Emission Controls of Air Pollutants

Option 1 Option 2 Option 3

Item No gaseous Emissions Controls

Parallel Gas Cleanup System

Gas Storage Tanks

Compliance with the air emission standards

No Yes Yes

Availability of land No Big Less

Costs 0 RMB 5.18 million yuan /a

(see Table 7-3)

RMB 4.69 million yuan /a

(see Table 7-3)

Table 7-3 Cost Comparison of the Options for Emission Controls of Air Pollutants

Option 2 Option 3

Type Item Parallel Gas Cleanup System

(RMB million yuan)

Gas Storage Tanks

(RMB million yuan)

Incinerator 24.30 24.30

Gas Cleanup System 9.72 4.86

Monitoring Instrument 3.24 3.24

DCS 2.43 2.43

Stack 0.80 0.80

Pump and Pipe 0.20 0.20

Storage Tanks / 0.96

Equipment Cost

Filter Press 0.10 0.10


HFC

-23

Inci

nera

tor

Gas Cleanup System

WWTP

Intermediate Storage Tank

Emergency Gas Storage Tank

Air Emissions

Wastewater Discharge



Total Equipment Cost 40.79 36.89

Installation Cost (6% of Total Equipment Cost) 2.43 2.21

Installed Equipment Cost 43.22 39.10

Equipment Depreciation Cost (10 years) RMB 4.32 million yuan /a RMB 3.91 million yuan /a

Equipment Maintenance Cost

(2% of Installed Equipment Cost) RMB 0.86 million yuan /a RMB 0.78 million yuan /a

Total Costs RMB 5.18 million yuan /a RMB 4.69 million yuan /a

As shown in Table 7-2, Option 1 does not comply with the air emission standards, so it is infeasible. Option 2 would need more land area than Option 3. In addition, the total annualized cost of Option 3 would be less than Option 2. As a result, Option 3 (installation of gas storage tanks) is recommended instead of Option 2 (installation of a parallel gas cleanup system).

7.3 Evaluation of Alternatives for the Wastewater and Sludge Discharges

The wastewater generated by this project is estimated to be approximately 73,300 m3/a (Annex 5). Three options are evaluated for the wastewater and sludge discharges: Option 1-no wastewater controls, Option 2-use of a newly-built special WWTP, and Option 3-use of the entire facility’s WWTP.

(1) Option 1: No wastewater controls

Under this option, the wastewater generated by this project is discharged directly (i.e. without any treatment) to the ambient surface water. Since the pollutant concentration in the wastewater from the gas cleanup system is very high (e.g. pH≤4, and fluoride concentration is 18.6 g/l)(Annex 5), it will greatly exceed the applicable wastewater discharge standard (the standard for pH is 6-9, and for fluoride is 10 mg/l) (GB 8978-1996, Table 4-4). Therefore, Option 1 is no longer considered.

(2) Option 2: Use of a newly-built special WWTP

In the special WWTP (Figure 7-3), the wastewater from the gas cleanup system is neutralized with Ca (OH)2 to form the CaF2 precipitate, which is settled in the settling/precipitation tank. The cleared water from the settling/precipitation tank is pH adjusted with HCl to a pH of 6-9 before discharge to the wastewater piping network of the Industrial Park, where it is pumped for final discharge to the Yangtze River. The wastewater discharge monitoring data of INEOS Fluor (Japan) Limited – which adopts the same kind of HFC-23 incinerator and gas cleanup systems – shows that the fluoride concentration in the treated wastewater discharge from Changshu 3F Zhonghao is less than 1.0 mg/l, which also complies with the requirements of 10 mg/l for fluoride in Category I in Table 4 of Integrated Waste Discharge Standard (GB8978-1996) (Annex 3).



The settled CaF2 solids from the settling/precipitation tank are removed and then dewatered by a filter press to approximately 65 percent moisture. The filter cake is sent off site. The filtrate is directed back to the neutralization tank for treatment.

Figure 7-3 Process Flow Diagram of the Newly-Built Special WWTP

The sludge generated in this process (mainly CaF2) is non-hazardous. It can be transported off-site for road construction, landfilling, filling of low lying area, or cement kiln.

When used in a cement kiln, fluoride emissions would likely occur at high temperatures. As the cement kiln would not be equipped with any gas washing equipment, these fluoride emissions would be discharged directly to the atmosphere, possibly causing adverse impacts on the receptors. Therefore, sludge incineration in a cement kiln is no longer considered.

There is no low lying area nearby Changshu 3F Zhonghao site where the sludge

can be used. Therefore, filling of low lying areas is no longer considered.

Between the options for road construction and landfilling, road construction is more attractive since it involves reuse of the sludge as a raw material at no cost (except for the transportation cost) whereas landfilling involves disposal (and transportation) at some cost.

Therefore, use of the sludge for road construction is selected under Option 2.

(3) Option 3: Use of the entire facility’s WWTP

Option 3 focuses on using of the entire facility’s WWTP to treat the wastewater generated by the proposed project. Currently, as Changshu 3F Zhonghao’s entire WWTP is operating at 80% of its design capacity (360 t/d), there is a surplus capacity of 72 t/d. As this excess capacity is much less than the the flow rate of wastewater that requires treatment from the proposed project (222 t/d), Option 3 is no longer considered.

Treated Wastewater

Discharge

Wastewater from Gas

Cleanup System

Neutralization

Tank

Settling

Tank

pH

Adjustment

Filter

Press

Sludge Disposal

Precipitate

Cleared Water

Filtrate

Filter Cake



Comparison of the above-mentioned three options is presented in Table 7-4, and the cost details are given in Table 7-5.

Table 7-4 Comparison of the Options for Wastewater and Sludge Discharges

Option 1 Option 2 Item No Wastewater

Controls Use of a Newly-Built WWTP

Compliance with the wastewater discharge standards

No Yes

Availability of land No Yes Costs 0 RMB 1.77 million yuan/a (see Table 7-5)

Table 7-5 Cost Analysis of Option 2

Option 2

Type Item Use of a Newly-Built WWTP

(RMB million yuan)

Operating room

Equipment room 0.20

Neutralization tank 1.60

Sludge tank 0.20

Buildings

Total Buildings Cost 2.00

Buildings Depreciation Cost (20 years) RMB 0.10 million yuan/a

NaOH RMB 0.64 million yuan /a

Ca(OH)2 RMB 0.84 million yuan /a

Polymer (PAM) RMB 0.19 million yuan /a

Chemicals

(see notes)

Total Chemicals Cost RMB 1.67 million yuan /a

Sludge Disposal Cost Road construction

0

Landfilling

RMB 30 yuan/t

Total cost: RMB 0.24 million

yuan/a

Total Costs RMB 1.77 million yuan/a RMB 2.01 million yuan/a

Note: According to Changshu 3F Zhonghao, the unit price (A) of NaOH, Ca(OH)2, and PAM are RMB 4000 yuan/t, 300

yuan/t, and 1800 yuan/t, respectively; and the consumptions (B) of these chemicals are 160 tpy, 2785 tpy, and 104

tpy respectively (Annex 5). So, the costs of them (C) are RMB 0.64 million yuan/a, 0.84 million yuan/a, and 0.19

million yuan/a (C=A×B).

As shown in Table 7-4, as Option 1 does not comply with the wastewater discharge, it is not feasible. As there is not enough treatment capacity at the existing WWTP for the Changshu 3F Zhanghao facility for the wastewater generated by the proposed project, Option 3 is not feasible either. As a result, Option 2 (construction of a special WWTP) is recommended as the only feasible option although it requires some land, which is available at the Changshu



3F Zhanghao facility. Within Option 2, use of the non-hazardous sludge for road construction is recommended for resource recovery and cost reasons. Option 2 with its non-hazardous sludge used for road construction would cost RMB 1.8 million yuan/a.

If the expansion of the treatment capacity of the entire WWTP is considered in the subsequent months before the implementation of HFC-23 Emissions Reduction Project, a further evaluation of alternatives for the wastewater treatment and sludge management would be recommended.



8 Process Safety and Emergency Measures

8.1 Process Safety

The most critical process steps, in terms of safety-related risks, within this CDM project are production, storage and transportation.

(1) The safety risks associated with the production process would be related to mainly failures in the incinerator and/or gas cleanup systems. If these equipment/systems can’t work properly, concentrations of the air pollutants (HF, HCl, and dioxins) in the air emissions from the HFC-23 destruction Process would exceed their applicable discharge standards. Main equipment failures and associated consequence are as follows:

Dioxins would form if the temperature in the incinerator is lower than 1200oC and retention time is less than 2 seconds. Dioxins would then be emitted to the environment.

Failures in the quench tower might result in the formation of dioxins, which would be emitted to the environment.

Failures in the water scrubber or alkali scrubber would result in HCl and HF concentrations in the emissions above the applicable emission standards.

(2) The safety risks associated with the storage and transportation processes include inadvertent environmental discharges of some input materials to the HFC-23 Emissions Reduction Process. These input materials include LNG and NaOH. LNG leaks to the environment may occur during accidents of tanker trucks or during storage or handling within the HFC-23 Emissions Reduction Process, and with fire or explosion, resulting in human injury or death, as well as material damage. NaOH spills also may result from accidents during transportation, storage or handling (e.g. transfer of NaOH from the tanker truck to the storage tank, or from the storage tank to the process). The impacts from NaOH spills vary from mild irritation to serious damage of the upper respiratory tract (resulting in sneezing, sore throat, or runny nose) in case of inhalation; irritation, severe burns, or scarring in case in case of skin contact; irritation of eyes, impairment of vision, or even blindness in case of eye, contact; and burns of mouth throat, and stomach, and even scarring of tissue and death in case of ingestion.

Because such accidents pose major risks to human health and the environment, SEPA, in its document of No.[1990] 057 requires that an environmental impact assessment be conducted to assess the significant environmental accident potential associated with some processes. The process hazard analysis is a rigorous, comprehensive, and systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. This assessment includes an identification of potential sources of accidental releases, identification of any previous release within the facility with catastrophic consequences in the workplace, estimation of workplace effects of a range of releases, and



estimation of the health and safety effects of such a range on employees, and countermeasures in response to prevent and control accidents. A simplified process hazard analysis for the HFC-23 Emissions Reduction Process is given in Table 8-1 and detailed countermeasures are described in the following sections.



Table 8-1 Process Hazard Analysis

Process Type Sources of Accident Hazards Probability

Out of compliance with the associated air emissions standards

Equipment failure in the incinerator and/or the flue gas cleanup system.

(1) Failure to maintain the temperature in the incinerator less than 1200oC and the retention time in the combustion chamber less than 2 seconds, resulting in formation of dioxins and emissions at concentrations above the dioxins guideline/standard;

(2) Failures the in quench tower, resulting in the formation of dioxins and emissions at concentrations above the dioxins guideline/standard;

(3) Failures in the water scrubber or caustic scrubber, resulting in the HCl and HF emissions at concentrations above the HCl and HF standards.

(1) HCl and HF emissions may result in HCl and HF concentrations at ground level (e.g. fluoride concentrations as high as 7.5 mg/m3 at 33 meters from the source, as shown in Table 6-9) that are hazardous to human health, with irritation to the eyes and respiratory tract, coughing, burning of the throat

(2) HCl and HF generate acid mist to corrode metallic equipment;

(3) The air pollutants (HCl, HF and dioxin) emitted under upset process conditions are predicted to have adverse impacts on the local receptors. Under upset process conditions, concentrations of these air pollutants at Fushan Town, Dengshi, and Wangshi Town would exceed the associated air quality standards (see Section 6). The maximum concentration of dioxins under upset process conditions may reach 10 TEQng/m3, 100 times above the UNEP discharge guideline.

Low

Production

Spill

Breakage of transportation pipeline (1) Leaked LNG explodes when exposed to heat sources and naked flame; (2) Caustic alkali causes serious burns to workers when spilled.

Low

Storage Leak/Spill Rupture of or leak from storage tanks The spilled LNG explodes when exposed to heat sources and Low



Process Type Sources of Accident Hazards Probability (cylinders) or valves of LNG naked flame.

Rupture of or spill from caustic storage tanks and valves, under upset process conditions, failure in safety valve and monitoring system

Skin contact of spilled caustic causes serious skin burns to the workers.

Low

Fire, explosion The natural gas leak is exposed to air, naked flame, static electricity, friction, or heat

The LNG leak explodes when exposed to heat sources (such as naked flame).

Low

Spill

Vehicle accidents, rupture of the vehicle tank

(1) The spilled LNG explodes when exposed to heat sources (such as naked flame); (2) Spilled caustic alkali causes serious burns to the personnel at the accident site with skin contact.

Low

Transportation

Fire, explosion The spilled natural gas is exposed to air, naked flame, static electricity, friction, and hit

Ditto Low



8.2 Prevention and Control of Air Emissions of Pollutants

Good system design is used as the first measure to prevent and control of air emissions of pollutants:

It has been shown in Section 6 that air emissions of pollutants under upset conditions of the HFC-23 Emissions Reduction Process would result in ground-level pollutant concentrations that would pose risks to human health and the environment. To mitigate these adverse impacts, under upset conditions, the process design will include an Emergency Gas Storage Tank that will collect the purged gases from the HFC-23 Emissions Reduction Process, which would otherwise be emitted to the environment through the stack. In addition, the emergency procedures call for the use of the Intermediate Storage Tank (between the HCFC-22 Process and the HFC-23 Emissions Reduction Process) to store the HFC-23 waste gas from the HCFC-22 Process, thus avoiding emission of this global warming gas to the atmosphere. Collection of the purged gases from the HFC-23 Emissions Reduction Process will be achieved by shifting the gas flow to the Emergency Gas Storage Tank through pipeline transfer. After the malfunctioning equipment is repaired, the gases from the two Gas Storage Tanks will be directed to the incinerator. In summary, the proposed design eliminates the exposure of potential receptors to the hazardous pollutants from the HFC-23 Emissions Reduction Process under upset process conditions and, in the meantime, collection of the global warming HFC-23 gases;

A flame detector will be installed on the incinerator to control the air inlet valve and ensure combustion safety;

An explosion relief valve will be installed on the incinerator to automatically open the emergency discharge valve and achieve chain control for combustor and air inlet electromagnetic valve, prevent damage of equipment and ensure combustion safety;

A fan will be installed to purge the gases within the incinerator before start-up (this would purge any flammable gas);

A temperature monitoring equipment and an automatic control system of combustion, with manometers and thermometers at principal pipes, will be installed to maintain the operating pressure of the incinerator and keep the temperature in the incinerator at 1200oC;

An automatic fume detector will be installed to facilitate timely monitoring of the flue gas; and



8.3 Spill Prevention, Containment, and Countermeasures

Spill- or leak-related risks can be mitigated through system design, with a spill or leak detection and alarm system of hazardous raw materials to inform any leaks or spills. In addition to collect any leak from the caustic storage tank, a concrete base and a concrete dike around storage tank around the caustic alkali will be provided for containment of the spill. The dike height will ensure collection of at least 100% of the entire content of the storage tank.

8.4 Personnel Protection

In the project area, the Changshu 3F Zhonghao employees will wear personal protection equipment, which are kept at workers’ change rooms. Under normal operating conditions, all workers will wear hard hats and work clothes; and in case of climbing, workers will wear safety belts. In response to emergencies such as caustic spills or HCl or HF emissions, a half-face respirator will be worn for up to 10 times the exposure limit. In addition, acid-resistant protective clothing (such as neoprene, PVC, or PE booths, gloves, and apron) will be worn for skin protection. 8.5 Emergency Preparedness and Countermeasures

The HFC-23 Emissions Reduction Process will be operated strictly within the technical parameters of the process to avoid any emergencies. The system design, employee training, and coordination with the relevant institutions (such as the nearest firehouse and hospital) will be key in preventing or countermeasuring emergencies.

Changshu 3F Zhonghao will prepare an Emergency Response Plan based on the emergency response plan for the HCFC-22 Plant. This Plan is expected to include:

Company introduction Identification, characteristics and impacts of hazardous materials Safety, firefighting, and personal protection equipment distribution Emergency response organization staff and responsibilities Alarm and communication Inspection of high risk areas and responsibilities Emergency response for accidents Personnel evacuation Levels of emergency response and termination Training and drills Emergency response plan management

Firefighting equipment, such as fire extinguishers (foam and power types), fire hoses, hatches, are available within every building. Changshu city has a fire department, which is 17 km away from the plant site. The fire department has fire trucks and firemen to respond



to major emergencies.

Fushan Hospital locates 4 km away form the Changshu 3F Zhonghao site, in which workers injured by accident would be treated in time.

The critical process-related equipment will be maintained and inspected regularly to detect potentials for accidents and prevent spill of raw materials and air pollutants contained in flue gas during operation.



9 Environmental Management Plan

Changshu 3F Zhonghao’s environmental mission is to achieve a harmony between chemical production and environment by preventing and controlling pollutant discharges from the company with continuous technical innovation. Compliance with environmental standards and minimizing the associated environmental impacts are essential in meeting this mission.

9.1 Environmental Management

The organizational structure of environment management for the HFC-23 Emissions Reduction Project at Changshu 3F Zhonghao is shown in Figure 9-1.

Figure 9-1 Organization of Environmental Management for the Proposed Project

The Environment Management Unit under the HFC-23 Emissions Reduction Process Supervisor will be responsible for planning and carrying out the environmental activities both during the construction and operational phases of the project. This Unit will consist of three employees.

During the construction phase, the Environmental Management Unit will be responsible for:

Assisting Safety & Environment Department for the preparation of the environment management plans specific to the HFC-23 Emissions Reduction Project construction activities, as obtained from the Construction Department

Identifying risk areas at the construction site Monitoring air, wastewater, solid waste discharges, and noise levels. The

General Manager

Plant ManagerSafety and

Environment Manager

Other Plant Manager HCFC-22 & HFC-32 Plant Manager

Other Department Manager

HCFC-22 Plant Supervisor

HFC-23 Emissions Reduction Process Supervisor

Environment Management Unit

HFC-32 Plant Supervisor



monitoring environmental discharges may include collection and analysis of samples. Noise level monitoring will be done at the plant boundary.

Ensuring implementation of mitigation measures Preparing monthly monitoring and environmental supervision reports, and

disseminating to the HFC-23 Emissions Process Supervisor and the Safety & Environment Department

Participating in accident investigations Recordkeeping of environmental and safety information (e.g. accidents) Supporting the Safety & Environment Department to address public grievances Preparing an Emergency Response Plan for the HFC-23 Emissions Reduction

Process Coordinating with the Safety & Environment Department for the training of the

HFC-23 Emissions Process. During the operational phase, the Environmental Management Unit will be responsible for:

Collecting samples for air, wastewater, sludge discharges and noise emissions from the HFC-23 Emissions Reduction Project, as specified in Table 9-2

Collection of ambient samples for air, wastewater, groundwater, and noise levels, as specified in Table 9-3

Handling of these samples (e.g. preservation and delivery to the laboratory) Ensuring analyses of these samples in the laboratory, as specified in Table 9-4 Preparing monthly environmental monitoring reports, and disseminating to the

HFC-23 Emissions Process Supervisor and the Safety & Environment Department

Recordkeeping environmental information (e.g. spills, leaks, accidents) Participation in accident investigations Supporting the Safety & Environment Department in addressing public

grievances Supporting the Safety & Environment Department in updating the emergency

response plan for the HFC-23 Emissions Process Coordinating with the Safety & Environment Department for the training of staff

of the HFC-23 Emissions Process. Safety & Environment Department will support Environment Management Unit in the following areas:

Preparation of the Emergency Response Plan during the construction phase and updating of the plan during the operational phase

Preparation of staff training plans and arrangements (contracting of training companies)

Reviewing the environmental reports received from the Environment Management Unit

Disseminating the environmental (quarterly) reports to the local EPB, SEPA, and



the World Bank Posting of the quarterly environmental monitoring information in Changshu 3F

Zhonghao’s WebSite Participation in accident investigations Addressing public grievances Compiling material safety data sheets for the chemicals handled in the HFC-23

Emissions Reduction Process Recordkeeping of environmental and safety information (e.g. spills, accidents).

Staff training will facilitate smooth and effective implementation of the HFC-23 Emissions Reduction Project both during its construction and operational phases. The staff training plan of this Project is presented in Table 9-1.

Table 9-1 Staff Training Plan for HFC-23 Emissions Reduction Project

Training Topics (see note) Project Period Staff

No. of

Persons Time

Training

Cost

(RMB) 1 2 3 4

Project manager 1 15,000 √ √ √

Environment

supervision staff 3 60,000 √ √ √ √

Construction

phase Contract units of the

construction work 1

2006

15,000 √ √ √

Operational

phase

Environment

supervision staff 3 2006 60,000 √ √ √ √

HFC-23

Emissions

Reduction

Project

Total / 7 / 150,000 / / / /

Note: Training Topics- 1. Environmental laws/regulations applicable to the project, 2. Environmental monitoring, 3.

Pollution control, 4. Emergency response

9.2 Environmental Monitoring Plan

(1) Environmental Discharge Monitoring

Environmental discharge monitoring will be carried out during project construction and operational phases. The Environment Management Unit will prepare the discharge monitoring plan for the construction phase prior to the initiation of the construction based on discussions with the Construction Unit. For the operational phase, the discharge monitoring plan shown in Table 9-2 will be used.



Table 9-2 Pollutants Discharge Monitoring Plan for the Operational Phase

System Location Parameters Frequency Combustion chamber Temperature Continuously The inlet of the combustion chamber

Flow rate Continuously Incinerator

The exit of the combustion chamber

Flow rate Continuously

Flow rate, temperature, smoke opacity, smoke dust, fluoride, HCl, SO2, NOX, CO, O2

Continuously

Heavy metals (only Sb and other heavy metals contained in the catalyst)

1 time/month (see notes)

Alkali Scrubbing

Tower Stack

Dioxins 1 time/month

Discharge outlet pH, fluoride, COD, SS, flow rate Continuously WWTP

Sludge storage site Leachate 2 times/month (see notes)

Notes: 1. Sludge leachate tests will be conducted during the first 3 months. If found to be non-hazardous, then no more

leachate testing will be conducted.

2. All heavy metals will be analyzed during the first 3 months, and then a reduced list of heavy metals (those that

are detected in the first 3 months) will be developed for the subsequent months.

(2) Ambient Quality Monitoring

Ambient quality monitoring will be carried out during project construction and operational phases. The Environment Management Unit will prepare the ambient quality monitoring plan for the construction phase prior to the initiation of the construction based on discussions with the Construction Unit. For the operational phase, the ambient quality monitoring plan shown in Table 9-3 will be used.



Table 9-3 Ambient Quality Monitoring Plan for the Pilot Testing and Operational Phase

Monitoring Frequency

Pollutants Pilot Testing

(for 7 days) Operation

Sampling

Frequency

Monitoring

Time

Number

of

Points

Monitoring

Location

Noise Leq (A) 1 time/week 2 times/year 24 h/d 24 h/d 4 Surrounding

project site

Daily average

concentration

Fluoride,

HCl 1 time/week 4 times/year 3 d/time 12 h/d 1

Hourly

average

concentration

Fluoride,

HCl 1 time/week 4 times/year 4 times/d 45 min/time 1

Ambient Air

Dioxins 2 time/year / / 1

Fushan Town

Surface Water pH, COD, Fluoride,

Discharge rate 1 time/month

2 consecutive

days 1 time/d 1

Wangyu

River

Esturary

Groundwater

pH, Permanganate index,

Fluoride, Chloride, Total

hardness

1 time/year 2 consecutive

days 1 time/d 1

Water well in

Fushan Town

The analytical methods for pollutant parameters are listed in Table 9-4.



Table 9-4 Analytical Methods for Pollutant Parameters

Media Pollutant Parameters Analytical Method Reference for Analytical Methods

Smoke dust Gravimetry GB/T 16157-1996

SO2 Formaldehyde Absoring-Pararosaniline

Spectrophotometry (1)

Fluoride Filter Sampling and Fluorine

Ion-selective Electrode Method (1)

HCl Mercury sulfhydryl spectrosphotometry

Silver nitrate volumetry HJ/T 27-1999

CO Non-disperisive Infrared Spectrometry HJ/T 44-1999

Dioxins Gas Chromatography/Mass

Spectrometry (2)

Smoke opacity Lingesman method GB/T 5468-91

Flue gas

Ambient Air

NOX (as NO2) N-(1-naphthyl) Ethylene Diamine

Dihydrochloride Spectrophotometry HJ/T 43-1999

pH pH value-Glass electrode method GB 6920-86 Fluoride Ion selective electrode method GB 7484-87

COD K2Cr2O7 method GB 11914-89 SS Gravimetric method GB11901-89

Chloride AgNO3 titration GB/T 11896-89

Permanganate index Titration GB/T 5750-85

Wastewater

Surface water

Groundwater

Total hardness Titration /

Notes: (1) Monitoring and Analysis Methods for Air and Exhaust Gases, Beijing: China Environmental Science Press,

1990.

(2) Analysis and Assessment Manual for Solid Wastes, Beijing: China Environmental Science Press, 1990. PP

332-359.

(3) Reporting of the Monitoring Data

A comprehensive monthly environmental monitoring report will be prepared by the Environment Management Unit and submitted to the HFC-23 Emissions Reduction Process Supervisor and the Safety & Environment Manager. The HCFC-22 & HFC-32 Plant Manager and the Changshu 3F Zhonghao Plant Manager will receive the environmental monthly reports through the HFC-23 Emissions Reduction Process Supervisor and the Safety & Environment Manager, respectively. The Safety & Environment Manager will submit quarterly environmental monitoring reports to the local EPB, SEPA, and the World Bank. Changshu 3F Zhonghao will also prepare an integrated annual report based on quarterly report and submit it to EPB, SEPA, and the World Bank. The Safety & Environment Manager will also post the quarterly environmental monitoring information in Changshu 3F Zhonghao’s WebSite.



10 Public Consultation

HFC-23 Emissions Reduction Project of Changshu 3F Zhonghao will have some impacts on the local public. So it has drawn extensive attention from the affected people, NGOs, local governments and academic institutions. According to OP/BP 4.01 of World Bank and its annex (Environmental Assessment), Environmental Protection Law of the People’s Republic of China and Law of the People's Republic of China on the Environmental Impact Assessment, public consultation for this project has been conducted by the environmental assessment team in order to receive views of the local public which will be incorporated into the ToR and EA.

The public consultation of this project has been conducted twice, which mainly include consultation meeting and questionnaire investigation. The first meeting and questionnaire investigation was held to discuss the ToR of the EA and the second one to discuss the findings of the draft EA. The informed views of the consulted people have been incorporated into the ToR and EA.

10.1 Public Consultation for ToR of the EA

10.1.1 Information of Public Consultation for ToR of the EA

(1) Consultation meeting

The consultation meeting for ToR of the EA was held on Sep 2, 2005 (Annex 6). In this meeting, the representatives from Xinhua Chemical Plant, Xinte Chemical Co. Ltd, Changshu Yitong Polyurethane Limited, Haiyu Town government of Changshu, the Labor Union of Haiyu town, Fushan Center Primary School of Changshu, Fushan Hospital and 7 residential representatives (from Fushan town, Dengshi, and Wangshi town) were invited to discuss the ToR of the EA together. The project information was explained to the consulted people whose views on the project were then be recorded in the meeting.

(2) Questionnaire investigation

Along with the consultation meeting, questionnaire investigation was conducted within the project’s area of influence. Table 10-1 shows the questionnaire for ToR of the EA.



Table 10-1 Questionnaire for the ToR of the EA

Name Sex

Occupation Age

Education Nationality

Address

Work place

How long have you lived

in this area □ under10 years; □ under 20 years; □ under 30 years; □ over 30 years

Information of

person

investigated

Distance from your living

place to this project □ within 500m; □ within 1000m; □ within 2000m; □ over 2000m

1. Are you satisfy with the local environment? □Yes □No □Not clear

2. How do you think about the importance of

this project?

□Very important □Important □Unimportant

□Do not know

3. Do you agree with the construction of this

project? □Yes □No □Do not care

4.Do you think the site selection of this project

is reasonable? □Yes □No □Do not care

5.What do you think will be the main

environmental impacts brought by this project?

□Air pollution □Water pollution

□Noise pollution

6. How do you think the impact on the local

ecological environment by this project? □Positive impact □Negative impact □No impact

7. How do you think the impact on the ambient

environment by this project? □Positive impact □Negative impact □No impact

8. Do you think this project’s advantages are

bigger than its disadvantages? □Yes □No □The same □Not clear

Attitude on the

project


economy by this project? □Positive impact □Negative impact □No impact

Do you have any suggestion for this project?

Suggestions

and

Requirements How do you think about the ToR of EA? Do you have any suggestions and requirements?

30 people from Fushan Town, Wangshi Town, and Dengshi were involved in this investigation and the detail information is listed in Table 10-2.



Table 10-2 Information of the Residents Involved in This Investigation

Item Type No. of Persons Percentage (% )

Below 18 2 6.7 18-35 13 43.3 36-55 12 40

Age

Over 55 3 10 Worker 13 43.3 Technician 5 16.7 Clerk 5 16.7

Occupation

Other 7 23.3 Male 18 60

Sex Female 12 40 Under middle school 7 23.3 Middle school 17 56.7 Education

Junior college and above 6 20 10.1.2 Results of the Public Consultation for ToR of the EA


In general, all of the affected people indicated on the consultation meeting that they agree with the ToR of EA. At the same time, they hoped the draft EA be finished as soon as possible. See Annex 7 for the detail record of consultation meeting on ToR of the EA.


The statistic results of all of the 30 questionnaires are shown in Table 10-3.



Table 10-3 Statistic Results of All Questionnaires

No. Questions Views No. of

Persons Percentage (%)

Yes 30 100 1 Are you satisfy with the local environment?

No 0 0

Very important 19 63.3

Important 11 36.7

Not important 0 0 2

How do you think about the importance of this

project?

Do not know 0 0

Yes 30 100

No 0 0 3 Do you agree with the construction of this project?

Do not care 0 0

Yes 30 100

No 0 0 4 Do your think the site selection of this project is

reasonable? Do not care 0 0

Air pollution 0 0

Water pollution 0 0 5 What do you think will be the main environmental

impacts brought by this project? Noise pollution 0 0

Positive impact 30 100

Negative impact 0 0 6 How do you think the impact on the local

ecological environment by this project? No impact 0 0

Positive impact 30 100

Negative impact 0 0 7 How do you think the impact on the ambient

environment by this project? No impact 0 0

Yes 30 100

No 0 0

The same 0 0 8

Do you think this project’s advantages are bigger

than its disadvantages?

Not clear 0 0

Positive impact 28 93.3

Negative impact 1 3.3 9 How do you think the impact on the local economy

by this project? No impact 1 3.3

As can see from the above table, 100% of the people involved in this questionnaire investigation support the construction of the project. And they all agree with the site selection. They think this project will promote the social development with no negative impact on the local environment.

(3) Results

As a whole, the representatives of the affected people who were involved in the public consultation on ToR of the EA indicated that they support the construction of HFC-23 Emissions Reduction Project in Changshu 3F Zhonghao. The most important environmental problem they worried about is the impact on them by air emission of this project. In



addition, they pay a lot of attention on the working opportunities brought by this project.

10.2 Public Consultation for the Draft EA

10.2.1 Information of Public Consultation for the Draft EA


The consultation meeting for the draft EA was held on Sep.26, 2005 (Annex 8). In this meeting, the representatives from Xinhua Chemical Plant, Xinte Chemical Co. Ltd, Changshu Yitong Polyurethane Limited, Haiyu Town government of Changshu, the Labor Union of Haiyu town, Fushan Center Primary School of Changshu, Fushan Hospital and 8 residential representatives (from Fushan town, Dengshi, and Wangshi town) were invited to discuss the ToR of the EA together. The findings of the draft EA was explained to the consulted people whose views on the project and mitigation measures were then be recorded in the meeting.


Along with the consultation meeting, questionnaire investigation was conducted within the project’s impact area of influence. Table 10-4 shows the questionnaire for the draft EA.



Table 10-4 Questionnaire for the Draft EA

Name Sex

Occupation Age

Education Nationality

Address

Work place

How long have you lived

in this area □ under10 years; □ under 20 years; □ under 30 years; □ over 30 years

Information of

person

investigated

Distance from your living

place to this project □ within 500m; □ within 1000m; □ within 2000m; □ over 2000m

1. Are you satisfy with the local environment? □Yes □No □Not clear

2. How do you think about the importance of

this project?

□Very important □Important □Unimportant

□Do not know

3. Do you agree with the construction of this

project? □Yes □No □Do not care

4.Do you think the site selection of this project

is reasonable? □Yes □No □Do not care

5.What do you think will be the main

environmental impacts brought by this project?

□Air pollution □Water pollution

□Noise pollution


ecological environment by this project? □Positive impact □Negative impact □No impact

7. How do you think the impact on the ambient

environment by this project? □Positive impact □Negative impact □No impact

8. Are you satisfied with the mitigation

measures mentioned in the draft EA? □Yes □No □Not clear

Attitude on the

project


economy by this project? □Positive impact □Negative impact □No impact

Do you have any suggestion for this project?

Suggestions

and

Requirements How do you think about the draft EA? What else mitigation measures do you think should be taken?

30 people from Fushan Town, Wangshi Town, and Dengshi were involved in this investigation and the detail information is listed in Table 10-5.



Table 10-5 Information of the Residents Involved in This Investigation

Item Type No. of Persons Percentage (% )

Below 18 1 3.3 18-35 15 50 36-55 10 33.3

Age

Over 55 4 13.3 Worker 12 40 Technician 6 20 Clerk 4 13.3

Occupation

Other 8 26.7 Male 16 53.3

Sex Female 14 46.7 Under middle school 6 20 Middle school 16 53.3 Education

Junior college and above 8 26.7 10.2.2 Results of the Public Consultation for the Draft EA


In general, all of the affected people indicated on the consultation meeting that they agree with the draft EA. At the same time, they put forward more mitigation measures on environmental discharges of the project. See Annex 9 for the detail record of consultation meeting on the draft EA.


The statistic results of all of the 30 questionnaires are shown in Table 10-6.



Table 10-6 Statistic Results of All Questionnaires

No. Questions Views No. of

Persons Percentage (%)

Yes 30 100 1 Are you satisfy with the local environment?

No 0 0

Very important 16 53.3

Important 14 46.7

Not important 0 0 2

How do you think about the importance of this

project?

Do not know 0 0

Yes 30 100

No 0 0 3 Do you agree with the construction of this project?

Do not care 0 0

Yes 30 100

No 0 0 4 Do your think the site selection of this project is

reasonable? Do not care 0 0

Air pollution 0 0

Water pollution 0 0 5 What do you think will be the main environmental

impacts brought by this project? Noise pollution 0 0


Negative impact 0 0 6 How do you think the impact on the local

ecological environment by this project? No impact 4 13.3


Negative impact 0 0 7 How do you think the impact on the ambient

environment by this project? No impact 2 6.7

Yes 30 100

No 0 0

No idea 0 0 8

Are you satisfied with the mitigation measures

mentioned in the draft EA?

Not clear 0 0


Negative impact 0 0 9 How do you think the impact on the local economy

by this project? No impact 1 3.3

As can see from the above table, 100% of the people involved in this questionnaire investigation support the construction of the project. And they all agree with the mitigation measures mentioned in the draft EA. They think this project will promote the social development with no negative impact on the local environment.

(3) Results

As a whole, the representatives of the affected people who were involved in the public consultation on the draft EA indicated that they support the construction of HFC-23 Emissions Reduction Project in Changshu 3F Zhonghao. In addition, they put forward more mitigation measures on environmental discharges of the project.



Annex 1 ToR for Environmental Assessment of HFC-23 Emissions

Reduction at Changshu 3F Zhonghao

EXECUTIVE SUMMARY 1. INFORMATION 2. PROJECT SETTING

- Information about the company - Information about the HCFC-22 process and HFC-23 emissions - Project setting

o Description of the site (with site map and layout of the company site, showing the HCFC-22 and HFC-23 process areas)

o Landscape and activities in the surrounding areas o Climate (temperature, rainfall, wind direction) and ambient air quality o Geology and hydrogeology (including soil quality, depth of the

groundwater table, groundwater flow direction, and groundwater quality) o Noise levels (within the process area, at the boundary, at the receptors) o Nearby human settlements o Nearby infrastructure (roads/highways, hospitals, fire stations) o Nearby surface waters, water use, and ambient water quality o Nearby critical habitats

3. DESCRIPTION OF THE HFC-23 REDUCTION PROCESS

This will include a description of the proposed HFC-23 emissions reduction process (with process flow diagram), including raw materials handling/storage, process steps, products/by-products, and auxiliary facilities for steam, electricity, water. As coordinated operation of the HFC-23 emissions reduction process with the HCFC-22 production process is required, the following points will be covered: (i) the basis for the selection of the HFC-23 emissions reduction process capacity, (ii) batch versus continuous (e.g. 24 hours/day) mode of operation of certain equipment of the HFC-23 emissions reduction process, and (iii) the scheduled maintenance period for the HCFC-22 production and HFC-23 emissions reduction processes. In addition, the key design and operating parameters of major equipment for the HFC-23 emissions reduction process will be specified (e.g. minimum operating temperature, residence time and excess oxygen in case of the incineration technology).

4. REGULATORY AND INSTITUTIONAL FRAMEWORK - Applicable legislation. Examples include:



o Air pollution legislation (technology requirements, air emissions, ambient air quality)

o Water pollution legislation (for surface and ground water protection: technology requirements, wastewater discharges, ambient water quality)

o Industrial solid/hazardous waste legislation (storage, treatment/destruction(such as incineration)/disposal(land disposal) requirements)

o Noise pollution o Occupational health and safety

- Regulatory agencies and their respective roles in this project (permitting by the agency, reporting of monitoring data by the company, monitoring by the agency, enforcement by the agency):

o State environmental agency o Provincial environmental agency o Local environmental agency

5. ENVIRONMENTAL DISCHARGES FROM THE HFC-23 REDUCTION PROCESS

AND MITIGATION MEASURES (during the construction phase and operational phase) Please specify the discharge rates, discharge conditions, pollutant concentrations; and treatment operations. If landfilling of solid/hazardous waste discharges is involved, please also provide a description of the landfill site, design and operating parameters of the landfill, and how the waste is to be transported to the landfill.

- Air emissions - Wastewater discharges - Solid/Hazardous waste discharges - Noise emissions

6. IMPACTS OF DISCHARGES ON RECEPTORS (during the construction phase and

operational phase) - Air emissions (air emission impacts will be determined through air dispersion

modeling, with the careful selection of the most appropriate air dispersion model for the topographical conditions and other input information (such as meteorological conditions and the receptors). Air dispersion modeling will include air emissions of pollutants discharged from both the HFC-23 emissions reduction process as well as the HCFC-22 manufacturing or its related processes (for example, if applicable, air emissions from “on-site” incineration of the HCFC-22 manufacturing process distillation bottoms (i.e. residues) or other wastes (such as oils) will be included in the air dispersion modeling).

- Wastewater discharges (water dispersion modeling for critical pollutants will be conducted)

- Solid/Hazardous waste discharges - Noise emissions



- Social impacts (e.g. employment opportunities during construction and operation of the HFC-23 emissions reduction facility, positive impacts on the reputation of the companies)

7. EVALUATION OF ALTERNATIVES

Alternative options will be evaluated and a recommendation will be provided for the HFC-23 emissions reduction process as well as environmental control measures.

- Evaluation of alternative process options for HFC-23 emissions reduction. At a minimum, the following options will be considered: (i) without the project option, (ii) incineration, (iii) process optimization, and (iv) process optimization combined with incineration.

- Evaluation of alternatives for emission controls of air pollutants (e.g. dioxins) during steady-state as well as non-steady-state (i.e. during process start-up, process shut-down, and upset process conditions). At a minimum, the following options will be considered: (i) no gaseous emissions controls, (ii) installation of a duplicate (i.e. parallel) gas cleanup system, and (iii) installation of storage capacity to capture the pollutants which would otherwise be emitted to the atmosphere.

- Evaluation of alternatives for the wastewater discharges. At a minimum, the following options will be considered: (i) no wastewater controls (i.e. direct discharge to the surface water), (ii) use of a dedicated wastewater treatment system for the HFC-23 emissions reduction plant with the discharge of the treated waters to the surface water, (iii) use of a dedicated wastewater treatment system for the HFC-23 emissions reduction plant with the discharge of the treated waters to the entire facility’s wastewater treatment plant, and (iv) discharge to the entire facility’s wastewater treatment plant. For options (ii) and (iii), alternative process schemes (e.g. type of dewatering equipment) and/or treatment chemicals (e.g. NaOH, KOH) will be evaluated. For options (iii) and (iv), the impact of HFC-23 treated waters/untreated wastewaters on the design and operating conditions of the entire facility’s wastewater treatment plant will be evaluated.

- Evaluation of alternatives for solid waste discharges. Hazardousness or non-hazardousness of the wastewater treatment sludge will be discussed. At a minimum, the following options will be considered if the sludge is determined to be non-hazardous: (i) use as input material to the cement kiln, (ii) use as input material for road construction, and (iii) landfilling.

8. PROCESS SAFETY AND EMERGENCY MEASURES (during the construction phase

and operational phase) - Process safety - Spill prevention, containment, and countermeasures - Personnel protection



- Emergency preparedness and countermeasures (preparation of an emergency plan, countermeasures in case of case of fire, explosion, personal injury)

9. ENVIRONMENTAL MANAGEMENT PLAN (during the construction phase and

operational phase) - Environmental monitoring plan (identification of specific monitoring points,

monitoring parameters, frequency of monitoring, methods of monitoring, analytical methods, data reporting). The environmental monitoring and reporting responsibilities by the company will be specified.

a) Air emissions and ambient air quality b) Wastewater discharges and ambient water quality c) Industrial solid/hazardous wastes (and groundwater quality) d) Noise

- Environmental management (organization chart showing the environmental unit in corporate management, roles and responsibilities, staffing, staff training plan).

10. RESETTLEMENT ACTION PLAN

The resettlement action plan will be prepared if there is any planned land acquisition by the company for any operation related to the HFC-23 emissions reduction investments (for example, for building the HFC-23 process, for building/expanding a wastewater treatment plant, or for building/expanding a landfill to be acquired by the company). The resettlement plan is required for “new” land acquisition by the company (i.e. a resettlement plan is not required if the company decides to establish the HFC-23 emissions reduction investments on a land already owned by the company)

11. PUBLIC CONSULTATION Public consultation will be conducted with project stakeholders to cover the project’s area of influence. Each HCFC-22 manufacturing company investing in a HFC-23 reduction scheme will hold consultation meetings within their enterprise and also within the project’s area of influence to explain the project information and receive views of the affected people (directly or through the local community leaders or citizen representatives), NGOs, local governments, and academic institutions. The first meeting will be held to discuss the ToR of the EA and the second one to discuss the findings of the draft EA. Records of public meetings will be held. Informed views of the consulted people will be incorporated into the ToR of the EA and the draft EA.

APPENDICES - List of EA Preparers. - Records of consultation meetings.



Annex 2 Distribution Map of Monitoring Points (Air and Surface Water) and Ambient River System



Annex 3 Descriptions of the Relevant Chinese Regulations

Type Serial Number Title of the Standard Category Descriptions

GB 3095-1996 Ambient Air Quality Standard Category 2 Implemented in Type 2 region which is defined as residential area, mixed region of commercial and

traffic and residential area, cultural area, industrial area, and rural area.

Category � Class A water source protection area for centralized drinking water supply, habitats of rare aquatic

species, spawning grounds of fish and shrimps, and feeding grounds of infant fish. GB 3838-2002

Environmental Quality Standards

for Surface Water Category �

Class B water source protection area for centralized drinking water supply, winter habitats or

migrating paths of fish and shrimps, aquiculture and other fishing areas, and swimming areas.

GB/T 14848-93 Quality Standard for Ground Water Category � In accord with human health baseline, mainly serves the purpose of centralized drinking water

supply, industrial and agricultural water supply.

GB 3096-1993 Standard of Environmental Noise of

Urban Area Category 3 Suitable for industrial area.

Category 1 To protect the natural ecosystem and maintain the background environmental quality of soils.

Chinese

Ambient

Quality

Standards

GB15618-1995 Environmental Quality Standard for

Soils Category 2 To ensure agricultural activities and safegard the human health

GB 16297-1996 Integrated Emission Standard of Air

Pollutants Category 2 Implemented on the pollutant sources in Type 2 region (GB 3095-1996).

GB 8978-1996 Integrated Wastewater Discharge

Standard Category 1

Implemented on wastewater which is discharged into water area classified as Category � (GB

3838-2002) or sea area classified as Category 2 (GB 3097-1997)7.

Chinese

Discharge

Standards

GB 12348-90 Standard of Noise at Boundary of

Industrial Enterprises Category � Suitable for industrial area.

7 GB 3097-1997: Sea Water Quality Standard. Category 2 in GB 3097-1997 is suitable for aquaculture area, bathing beach sea area, sport area or recreation area on the sea where human contact

the sea water directly, and industrial water using area which is relevant directly to human diet.



Annex 4 HFC-23 Generated from the HCFC-22 Process



Annex 5 Material Balances for the HFC-23 Emissions Reduction Process

1. Reaction Equation

(1) Reaction in the incinerator

Oxidation of HFC-23

HFCOOOHHFCCHF 3)23( 2221

23 +→++=

Molecular Weight (MW) 70 18 16 44 60

Reacted Amount (RA) (tpy) 1200 308.6 274.3 754.3 1028.57

Oxidation of HCFC-22

HClHFCOOOHHCFCCHClF ++→++= 2)22( 2221

22

MW 86.5 18 16 44 40 36.5

RA (tpy) 24.5 5.1 4.53 12.46 11.33 10.34

Oxidation of LNG

OHCOOCH 2224 22 +→+

MW 16 64 44 36

RA (tpy) 600 2400 1650 1350

(2) Reaction in the Alkali Scrubbing Tower

Neutralization of HF

HF + NaOH → NaF + H2O

MW 20 40 42 18

RA (tpy) 51.86 103.72 108.9 46.7

Neutralization of HCl

HCl + NaOH → NaCl + H2O

MW 36.5 40 58.5 18

RA (tpy) 0.268 0.62 0.91 0.28



(3) Reaction in theWWTP

Neutralization of HF

2HF + Ca(OH)2 → CaF2 + 2H2O

MW 40 74 78 36

RA (tpy) 987.91 1827.63 1926.42 889.1

Neutralization of HCl

HCl + Ca(OH)2 → CaCl2 + 2H2O

MW 73 74 111 36

RA (tpy) 8.272 8.39 12.58 4.01

Reaction of NaF

2NaF + Ca(OH)2 → CaF2 + 2NaOH

MW 84 74 78 80

RA (tpy) 108.9 96 101.1 103.7

(4) pH Adjustment

Ca(OH)2 + 2HCl → CaCl2 + 2H2O

MW 74 73 111 36

RA (tpy) 68 67.1 102 33

NaOH + HCl → NaCl + H2O

MW 40 36.5 58.5 18

RA (tpy) 109.34 99.78 160 49.2



2. Material Balances Process

Stream # Description Bases/Assumptions/Calculations

1 Flue gas to

incinerator

① Composition: Based on information from Changshu 3F Zhonghao

HFC-23 Line A: 80％ Line B: 89%

HCFC-22 Line A: 10％ Line B: 3.6%

Other Line A: 10％ Line B: 7.4%

② Flow of chemicals: HFC-23 1600 tpy; HCFC-22 132.36 tpy

2 Air input

① Amount of O2 needed for incineration of HFC-23: 1600 × 16/70 ＝ 365.7 tpy

② Amount of O2 needed for incineration of HCFC-22: 132.36 × 16/86.5 ＝22.48 tpy

� Amount of O2 needed for burning of LNG: 850 × 64/16 ＝ 3400 tpy

� Total O2 needed: 365.7 + 22.48 + 3400＝3788.18 tpy

⑤ Amount of air needed: 3788.18/0.21=18038.95 tpy

⑥ Excessive air: 9394 tpy

⑦ Total air needed: 18038.95 + 9394=27432.95

3 Steam input

① Amount of steam needed for incineration of HFC-23: 1600×18/70＝411.43 tpy

�Amount of steam needed for incineration of HCFC-22: 132.36×18/86.5＝27.54 tpy

� Total steam needed: 411.43+27.54＝438.97 tpy

4 LNG 850 tpy, according to Changshu 3F Zhonghao

5 Waste gas from the

incinerator

� HF generated

HF generated from incineration of HFC-23: 1600×60/70＝1371.43tpy

HF generated from incineration of HCFC-22: 132.36×40/86.5＝61.21 tpy

Total HF generated: 1371.43 + 61.21=1432.64 tpy

� HCl generated: 132.36×36.5/86.5＝55.85 tpy

� CO2 generated

CO2 generated from incineration of HFC-23: 1600×44/70＝1005.7 tpy

CO2 generated from incineration of HCFC-22: 132.36×44/86.5＝67.33 tpy

CO2 generated from burning of LNG: 850×44/16＝2337.5 tpy

Total CO2 generated: 1005.7 + 67.33 + 2337.5＝3410.53 tpy

� H2O generated from burning of LNG: 850×36/16＝1912.5 tpy

� Surplus air: 27432.95－3788.18＝23644.77 tpy

6 Water input of the

Quench Tower 21450 tpy, according to Changshu 3F Zhonghao

7 Wastewater from

the Quench Tower

① Wastewater discharged from the Quench Tower: 21450+1912.5-8910=14452.5 tpy

② Content of HF in wastewater (ratio of absorption: 50%): 716.32 tpy

③ Content of HCl in wastewater (ratio of absorption: 50%): 27.925 tpy

8 Evaporation loss from

Quench Tower 8910 tpy, according to Changshu 3F Zhonghao

9 Waste gas from the

Quench Tower

� HF: 1432.64－716.32＝716.32 tpy

� HCl: 55.85－27.925＝27.925 tpy

� CO2: 3410.53 tpy

� Surplus air: 23644.77 tpy

10 Water input of the

Water Scrubbing 66000 tpy, according to Changshu 3F Zhonghao



Tower

11

Wastewater from

the Water

Scrubbing Tower

� Water discharge from the water scrubbing tower: 66000-9900＝56100 tpy

� Content of HF in the wastewater: 716.32×90%＝644.688 tpy

� Content of HCl in the wastewater: 27.925×60％＝16.755 tpy

12

Evaporation loss

from the Water

Scrubbing Tower

9900 tpy, according to Changshu 3F Zhonghao

13

Waste gas from the

Water Scrubbing

Tower

� Surplus air: 23644.77 tpy

� HF: 1432.64-716.32-644.688＝71.64 tpy

� HCl: 55.85-27.925-16.755＝11.17 tpy

� CO2: 3410.53 tpy

14

Water input and

NaOH input of the

Alkali Scrubbing

Tower

� Water input: 3960 tpy, according to Changshu 3F Zhonghao

� Amount of NaOH:

HF treatment needed: (71.64－0.9)×40/20＝142.9 tpy

HCl treatment needed: (11.17－2)×40/36.5＝10.05 tpy

Total needed: 142.9 + 10.05＝152.95 tpy

Using amount: 160 tpy

Surplus amount: 160－152.95＝7.05 tpy

15

Wastewater from

the Alkali

Scrubbing Tower

� Wastewater discharge:

Wastewater discharge after evaporation loss: 2640 tpy

H2O generated by neutralization of HF: (71.64－0.19)×18/20＝64.31 tpy

H2O generated by neutralization of HCl: (11.17－2)×18/36.5＝4.52 tpy

Total wastewater discharge: 2640 + 64.31 + 4.52 ＝2708.83 tpy

� Discharge amount of NaF: (71.64－0.19)×42/20＝150 tpy

� Discharge amount of NaCl: (11.17－2)×58.5/36.5＝14.7 tpy

16

Evaporation loss

from the Alkali

Scrubbing Tower

1320 tpy, according to Changshu 3F Zhonghao

17 Air emission to

the Atmosphere

HF: 0.19 tpy (F: 0.18 tpy); HCl: 2 tpy

Air: 23644.77 tpy; CO2: 3410.53 tpy

18 The whole

wastewater

� Wastewater discharge: 73261.33 tpy

� Content of HF in wastewater: 1361 tpy

� Content of HCl in wastewater: 44.68 tpy

� Discharge amount of NaF: 150 tpy

� Discharge amount of NaCl: 14.7 tpy

� Discharge amount of NaOH: 7.05 tpy

19

Ca(OH)2 input of

the Neutralization

Tank

� HF treatment needed: 1361×74/40＝2517.85 tpy

� HCl treatment needed: 44.68×74/73＝45.29 tpy

� NaF treatment needed: 150×74/84＝132.14 tpy

� Total needed: 2517.85 + 45.29 + 132.14＝2695.28 tpy

� Using amount: 2785 tpy

� Surplus amount: 2785－2695.28＝89.72 tpy

20 FeCl3 input of the

Neutralization In general, it is expected to be 1‰ of the wastewater: 69.3 tpy



Tank

21

Polymer input of

the Neutralization

Tank

In general, it is expected to be 0.5‰ of the wastewater: 34.65 tpy

22 Sludge Discharge

� Amount of CaF2:

CaF2 generated from neutralization of HF: 1361×74/40＝2517.85 tpy

CaF2 generated from reaction of NaF and Ca(OH)2: 150×78/84＝132.14 tpy

� Total dry sludge:

(Amount of CaF2+FeCl3+Polymer) – (Amount of CaF2 in wastewater):

2517.8 + 132.14 + 69.3 + 34.65 －1.35＝2752.54 tpy

③ Total sludge: Dry sludge + Water with the sludge: 2752.54 + 5319.37 = 8071.91 tpy

23 Wastewater from

the Settling Tank


Wastewater inflow: 73261.33 tpy

Wastewater with sludge: 5319.37 tpy

H2O generated from neutralization of HF: 1361×36/40＝1224.9 tpy

H2O generated from neutralization of HCl: 44.68×36/73＝22.03 tpy

Total wastewater discharge: 73261.33 + 1224.9 + 22.03－5319.37＝69188.89 tpy

� Content of CaCl2 in wastewater: 44.68×111/73＝67.94 tpy

� Content of NaOH in wastewater:

NaOH generated: 150×74/84＝142.86 tpy

NaOH from alkali washing tower: 7.05 tpy

Total NaOH: 142.86 + 7.05＝149.91 tpy

④ Content of Ca(OH)2: 89.72 tpy (surplus)

⑤ Content of NaCl: 14.7 tpy

⑥ Content of CaF2: 1.35 tpy (F: 0.693 tpy)

24

HCl acid input of

the pH Adjustment

Tank

� HCl needed for neutralization of surplus Ca(OH)2: 89.72×73/74＝88.51 tpy

� HCl needed for neutralization of surplus NaOH: 149.91×36.5/40＝136.8 tpy

� Total HCl need: 88.51 + 136.8＝225.31 tpy

25

Treated

Wastewater

Discharge


Wastewater inflow of neutralization tank: 69188.89 tpy

Water generated from neutralization of surplus Ca(OH)2: 89.72×36/74＝43.65 tpy

Water generated from neutralization of surplus NaOH: 149.91×18/40＝67.46 tpy

Total wastewater discharge: 69188.89 + 43.65 + 67.46=69300 tpy

� NaCl2 discharge:

NaCl2 from neutralization tank: 14.7 tpy

NaCl2 generated in the pH adjustment tank: 149.91×58.5/40＝219.24 tpy

Total NaCl2 discharge: 219.24 + 14.7＝233.94 tpy

� CaCl2 discharge:

CaCl2 from neutralization tank: 67.94 tpy

CaCl2 generated in the pH adjustment tank: 89.72×111/74＝134.58 tpy

Total CaCl2 discharge: 134.58 + 67.94＝202.52 tpy

� Content of CaF2: 1.35 tpy (F: 0.693 tpy)



Annex 6 Official Letter about the Conduct of Public Consultation on the

ToR of the EA

关于开展第一次公众调查的函

常熟三爱富中昊化工新材料有限公司：

HCFC-22尾气焚烧项目的环境影响评价工作已经展开，环评大纲已经编制完成，依

据世界银行OP4.01及附件、《中华人民共和国环境保护法》和《中华人民共和国环境影

响评价法》的规定，为体现项目的公开、公正原则，拟开展第一次公众调查，征询意见，

为项目决策和管理提供依据。

本次公众调查的目的：针对环评大纲，厂址周围受项目直接或间接影响的人群和单

位了解项目建设情况和可能带来的环境影响，并提出相应意见和措施。

调查方法：发放公众调查表和召开听证座谈会相结合的方式

被调查者范围：厂址周围受项目直接或间接影响的人群和单位，包括直接受影响的

人群、受影响团体的公共代表、其他感兴趣的团体。

有关内容：本项目属废气治理项目，必然有利于减轻全球气候变化的压力，有利于

我国乃至全世界的环境气候改善。但在项目建设以及运营时期，都会对各子项目周边地

区造成环境影响，直接涉及工程附近居民的切身利益，通过公众参与的方式让各工程附

近社团、公众了解项目建设情况和可能带来的环境影响，积极为项目建设献计献策，同

时反馈各种意见和建议，使工程对环境影响减少到最低限度。

因此，要让被调查者知道本项目的优缺点，项目焚烧完后可能产生HF、HCl二噁英

等物质，以及相应处理办法和对环境的影响情况。



请尽快组织相关人员开展此次公众调查工作，并对公众调查结果进行汇总递交给

我公司。

顺祝商琪！

中绿实业有限公司

二〇〇五年八月二十四日



Annex 7 Records of the Consultation Meeting on the ToR of the EA











Annex 8 Official Letter about the Conduct of Public Consultation on the

Draft EA

关于开展第二次公众调查的函

常熟三爱富中昊化工新材料有限公司：

在参考了第一次公众调查反馈意见和建议的基础上，我们完成了HCFC-22尾气焚烧

项目的环境影响评价报告初稿。依据世界银行OP4.01及附件、《中华人民共和国环境保

护法》和《中华人民共和国环境影响评价法》的规定，为体现项目的公开、公正原则，

拟开展第二次公众调查，征询意见，为项目决策和管理提供依据。

本次公众调查的目的：针对环境影响评价报告（初稿），厂址周围受项目直接或间

接影响的人群和单位了解项目建设情况中可能带来的环境影响，及采取的相应措施，同

时反馈各种意见和建议，完善设计方案，使工程对环境影响减少到最低限度。

调查方法：发放公众调查表和召开听证座谈会相结合的方式

被调查者范围：厂址周围受项目直接或间接影响的人群和单位，包括直接受影响的

人群、受影响团体的公共代表、其他感兴趣的团体。

有关内容：要让被调查者知道清楚本项目的优缺点，项目焚烧完后产生HF、HCl、

二噁英等物质的排放量、排放浓度和采用相应措施进行处理后对环境的影响情况，尤其

是在不利条件下产生的HF、HCl、二噁英等物质对各敏感点的影响。

请尽快组织相关人员开展此次公众调查工作，并对公众调查结果进行汇总递交给

我公司。



此致！

顺祝商琪！

中绿实业有限公司

二〇〇五年九月二十一日



Annex 9 Records of the Consultation Meeting on the Draft EA













Annex 10 Certificate of Land Use Right: Line A of the HCFC-22 Process



Annex 11 Certificate of Land Use Right: Line B of the HCFC-22 Process



Annex 12 List of EA Preparers

Mr. Zhu Pei

Mr. Jin Ping

Mr. Wang Xiaoguang

Mr. Jia Chao

Mr. Zhang Huiyong

Mr. Lu Fuyuan

Mr. Huang Binghe