Environmental and Social Management Plan for
Luoyang Langchao Fire Technology Co., Ltd.
Reduction and Phase-out of PFOS in Priority Sectors in
China
Environmental and Social Management Plan




  December 29, 2021
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




[Leave for Blank]
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




Contents
     1.     INTRODUCTION ....................................................................................................... 1
          1.1       BACKGROUND .............................................................................................................1
          1.2       METHODOLOGY ...........................................................................................................2
          1.3       REPORT STRUCTURE.....................................................................................................2
     2.     ENVIRONMENTAL AND SOCIAL SAFEGUARD POLICIES............................................... 4
     3.     SITE INTRODUCTION ................................................................................................ 8
          3.1       BASIC INFORMATION ...................................................................................................8
            3.1.1      Site Location .................................................................................................................................8
            3.1.2      Project Building Situation ..........................................................................................................10
            3.1.3      Site History ..................................................................................................................................11

          3.2       PROUCTION PROCESS ................................................................................................ 12
            3.2.1      Production Process Flow of Water-based Foam Fire Extinguishing Agent Products ......13
            3.2.2      Process Flow of Alcohol-resistant Foam Fire Extinguishing Agent ....................................13
            3.2.3      Raw Materials .............................................................................................................................15

     4.     PROJECT BACKGROUND ......................................................................................... 16
          4.1       ENVIRONMENTAL BASELINE ....................................................................................... 16
            4.1.1      Geography and Climate ............................................................................................................16
            4.1.2      Ambient Air Quality ....................................................................................................................16
            4.1.3      Surface Water Environmental Quality .....................................................................................17
            4.1.4      Groundwater Environmental Quality ........................................................................................18
            4.1.5      Acoustic Environmental Quality ...............................................................................................19

          4.2       ECOLOGICAL BASELINE ............................................................................................... 19
          4.3       SOCIOECONOMIC BASELINE ....................................................................................... 19
            4.3.1      Population ....................................................................................................................................19
            4.3.2      Economy and Income ................................................................................................................21
            4.3.3      Human Resource........................................................................................................................22

     5.     ENVIRONMENTAL AND SOCIAL AUDIT .................................................................... 24
          5.1       ENVIRONMENTAL AUDIT ............................................................................................ 24
          5.2       OCUPATIONAL HEALTH AND SAFETY AUDIT ................................................................ 29
          5.3       SAFETY AUDIT ............................................................................................................ 30
          5.4       SOCIAL AUDIT ............................................................................................................ 33
          5.5       MANAGEMENT SYSTEM AND MECHANISM ................................................................. 36
          5.6       FINDINGS AND CORRECTIVE PLAN .............................................................................. 40



                                                                                    i
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



     6.      PILOT PROJECT ACTIVITIES ..................................................................................... 43
     7.      MANAGEMENT ORGANIZATION SETTING ............................................................... 47
     8.      PILOT PROJECT E&S IMPACT ASSESSMENT .............................................................. 49
          8.1       ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT ................................................. 49
          8.2       ENVIRONMENTAL AND SOCIAL MONITORING PLAN .................................................... 59
          8.3       CAPACITY BUILDING ................................................................................................... 61
     9.      STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE ............................. 63
          9.1       OBJECTIVES................................................................................................................ 63
          9.2       ENGAGEMENT PROCESS AND FINDINGS ..................................................................... 63
          9.3       PUBLIC ENGAGEMENT AND INFORMATION DISCLOSURE IN THE NEXT PHASE .............. 66
          9.4       COMMUNITY GRIEVANCE REDRESSING MECHANISM .................................................. 66
          9.5       REPORTING MECHANISM ........................................................................................... 69
     10.        ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN .......................................... 70
     11.        COST ESTIMATION .............................................................................................. 78
     12.        ANNEX ............................................................................................................... 79
          Annex 1: List of Consulted Personnel ..................................................................................... 79
          Annex 2: Land Certificate....................................................................................................... 80
          Annex 3: Land Lease Agreement ............................................................................................ 81
          Annex 4: Drinking Water Quality Test Report ......................................................................... 83
          Annex 5: Letter of Commitment ............................................................................................ 86
          Annex 6: Document List......................................................................................................... 87
          Annex 7: Photolog ................................................................................................................. 88




                                                                           ii
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



TABLES
Table 3-1:Sensitive Points around the Project Area .............................................................. 9
Table 3-2: Relevant Buildings and Facilities within the pilot project area ..........................11
Table 3-3: Project History .......................................................................................................11
Table 3-4: List of Main Raw Materials ....................................................................................15
Table 4-1: Total Population and Population Density in 2019 ...............................................20
Table 4-2: Comparison of GDP and Industrial Structure in 2020 .........................................21
Table 5-1: Implementation Plan of Emergency Environmental Response Plan..................24
Table 5-2: Wastewater Testing Results .................................................................................25
Table 5-3:Exhaust Pollutant Organized Emission Test Results ..........................................26
Table 5-4: Exhaust Pollutant Unorganized Emission Test Results. ....................................26
Table 5-5: Noise Test Results ................................................................................................27
Table5-6:Implementation Plan of Occupational Health Status Evaluation and
        Occupational Hazard Factor Detection ...................................................................30
Table5-7:Emergency Implementation Plan of Production Safety ........................................31
Table5-8:Luoyang Langchao Fire Technology Corrective Plan for Fire Completion
        Acceptance ...............................................................................................................32
Table 5-9:Findings ..................................................................................................................40
Table 6-1:Diagram of Project Schedule .................................................................................43
Table 6-2:List of production facility to be updated ...............................................................45
Table 8-1:The Alternative Formula Identified in This Pilot Project ......................................49
Table 8-2:Potential E&S Impacts and Mitigation Measures in Alternative Formula
        R&D and Performance Testing Stage......................................................................51
Table 8-3:Potential E&S Impacts and Mitigation Measures During the Equipment
        Removal and Replacement ......................................................................................54
Table 8-4:E&S Monitoring Plan ..............................................................................................59
Table 8-5:Capacity Building and Training Plan.....................................................................61
Table 9-1:Consultation Conclusion with the Stakeholders ..................................................64
Table 9-2:Report Submission Plan ........................................................................................69
Table 10-1:Environmental and Social Management Plan .....................................................70
Table 11-1:Budget List of the Pilot Project ...........................................................................78




                                                                      i
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



FIGURES
Figure 3-1:The Project Location.............................................................................................. 8
Figure 3-2: Site Vicinity Map ................................................................................................... 9
Figure 3-3: Site Layout ...........................................................................................................10
Figure 3-4:Process Flow Chart...............................................................................................12
Figure 4-1: Social and Economic Overview in 2020 ............................................................22
Figure 4-22: Number of employees in Luoyang City in recent years (ten thousand
        people).......................................................................................................................23
Figure 5-1: Diagram of Main OHS Risks in the Process Flow of Yibin Branch ...................29
Figure 6-1:Diagram of the project technical route ................................................................44
Figure 7-1:Schematic Diagram of the System Structure of the Project Management
        Agencies ...................................................................................................................48
Figure 9-1:The First Round of Online Publicity Screenshots ..............................................66
Figure 9-2:Flow Chart of the GRM for PFOS Project ............................................................68




                                                                      ii
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



Abbreviations and Acronyms




 BAT                        Best Accessible Technology

 BEP                        Best Environmental Practice

 CCCF                       China Certification Center for Fire Product of the Ministry of Emergency
                            Management

 COD                        Chemical Oxygen Demand

 EIA                        Environmental Impact Assessment

 ESIA                       Environmental and Social Impact Assessment

 ESMP                       Environmental and Social Management Plan

 FECO                       the Foreign Environmental Cooperation Center

 GDP                        Gross Domestic Product

 GEF                        Global Environmental Facility

 GRM                        Grievance Redressing Mechanism

 PFOS                       Perfluorooctane Sulphonate

 PFOSF                      Perfluorooctane Sulfonyl Fluoride

 PPE                        Personal Protective Equipment

 OHS                        Occupational Health and Safety

 WB                         the World Bank




                                                                 iii
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




1.        INTRODUCTION
1.1       BACKGROUND
In August 2013, the Standing Committee of the National People's Congress approved the
Amendment to Annex A, Annex B and Annex C of the Stockholm Convention on Persistent
Organic Pollutants (hereinafter referred to as "the Stockholm Convention"), which lists nine new
Persistent Organic Pollutants, and the Amendment to Annex A, which lists endosulfan. On 25
March 2014, the Ministry of Ecology and Environment with other eleven ministries jointly issued
a notice banning the production, distribution, use, import and export of perfluorooctane sulphonate
and its salts (PFOS) and perfluorooctane sulfonyl fluoride (PFOSF), except for specific
exemptions and acceptable purposes. China shall phase out the use of six specific exempt uses
of PFOS by the end of the specific exemption period (25 March 2019) as required by the
amendment, and gradually implement best available techniques and best environmental practices
in the industries with the seven acceptable uses of PFOS, to gradually achieve the reduction and
phase-out of PFOS.
PFOS is stable in the environment, minimal volatility, neither hydrolytic nor photolytic nor
biodegradable under natural conditions. It is highly bio accumulative and ubiquitous worldwide.
PFOS is toxic to reproduction, mutagenicity, and development, and is a class of environmental
pollutants with systemic and multi-organ toxicity.
To reduce environmental pollution and fulfil national conventions, the Foreign Environmental
Cooperation Center (FECO) of the China Ministry of Ecology and Environment and the World
Bank (WB) have jointly developed the "Global Environmental Facility (GEF)-Reduction and
Phase-out of PFOS in Priority Sectors in China" since 2015. In 2021, FECO and WB decided to
conduct an environmental and social assessment of its PFOS-related production lines at Luoyang
Langchao Fire Technology Co., Ltd, (hereafter refers to Langchao Fire Technology) and to
promote and support the elimination of PFOS in production activities by offering grants.
Established in 1954, Luoyang Langchao Fire Technology Co., Ltd. switched its production to fire
extinguishing agents in 1970, The original name was "Luoyang Laocheng Fire Agent Factory"
located at No. 208, East Jiudu Road, Laocheng District, Luoyang City, Henan Province. In 1991,
it was renamed to "Luoyang Langchao Fire Agent Co., Ltd", and in 2011, it was renamed to
"Luoyang Langchao Fire Technology Co., Ltd." ("Langchao Fire Technology" or "Headquarters").
According to management personnel, the headquarters has no production activities, and only
retains some management and sales positions, which are responsible for branch management,
as well as marketing and business work.
According to the desktop survey and management personnel consultations, Langchao Fire
Technology involves a total of nine subsidiaries, namely the Yibin Branch, Luoyang Risheng Fire
Technology Co., Ltd, Henan Langchao Construction Engineering Co., Ltd, Luoyang Langchao
Industrial Developing Co., Ltd, Henan Langchao Safety Technology Co., Ltd, Hami Langchao Fire
Technology Co. Ltd., Henan Langchao Fire Engineering Co., Ltd., Henan Langchao Fire
Research Institute Co., Ltd., and Shanghai Hongqi Fire Technology Co., Ltd. Among them, the




                                                                 1
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



10 PFOS-related foam fire extinguishing agent production lines and public facilities of the Yibin
branch are involved in this proposed PFOS reduction and phase-out project (this pilot project).
Established in 2014, the Yibin Branch is called "Luoyang Langchao Fire Technology Co., Ltd Yibin
Branch", located in the southwest of Xihan Village, Zhuge Town, Yibin District, Luoyang City,
Henan Province, covering an area of 13,806 square meters (20.7 acres) in industrial land. The
Yibin branch is responsible for receiving orders from headquarters and producing and shipping.
The industry category belongs to specialized chemical product manufacturing. At present, the
main businesses include research and development of fire chemicals, sales and maintenance of
fire equipment, fire engineering and personal fire protection equipment. The designed production
capacity of foam fire extinguishing agent is 8,500 tons per year, and the actual production capacity
is about 5,000 tons per year.
This Environmental and Social Management Plan (ESMP) assessment was conducted only for
the existing PFOS-related foam fire extinguishing agent production lines and public facilities audit
of the Yibin Branch, and the existing environmental and social management system of the
headquarters and make the environmental and social impact assessment (ESIA) of this pilot
project. From July to August 2021, Stantec Environmental Engineering (Shanghai) Co., Ltd
(Stantec) was assigned to conduct the environmental and social assessment of this pilot project
and the ESMP (the "Report") was prepared accordingly.


1.2       METHODOLOGY
The following methods were used by Stantec for this assignment:
      •   Review of relevant documents, including (1) environmental impact assessment (EIA)
          document; (2) headquarters environmental and social management system documents
          (the Yibin Branch continued to use headquarters management procedures and branch-
          level management procedure was not established); (3) relevant social licensing
          documents (such as land acquisition impacts), and (4) other environmental and social-
          related documents and records;
      •   Online public information research;
      •   On-site visits to the pilot project and surrounding areas;
      •   Project stakeholder consultation. These stakeholders include Zhuge Town People’s
          Government, Zhuge Town Environmental Protection Office, Zhuge Town Land and
          Resources Office, Xihan Village Committee and affected lease holders in Xihan Village.
          A list of stakeholder consultation can be found in Appendix A.

1.3       REPORT STRUCTURE
The remaining sections of this report are:
      •   Section 2: Environmental and Social Safeguard Policy;
      •   Section 3: Site Introduction;



                                                                 2
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



     •    Section 4: Project Background;
     •    Section 5: Environmental and Social Audit;
     •    Section 6: Pilot Project Activities;
     •    Section 7: Management Organization Setting;
     •    Section 8: Pilot Project E&S Impact Assessment
     •    Section 9: Stakeholder Engagement and Information Disclosure;
     •    Section 10: Environmental and Social Management Plan;
     •    Section 11: Cost Estimation;
     •    Section 12: Annex.




                                                                 3
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



2.         ENVIRONMENTAL AND SOCIAL SAFEGUARD POLICIES
The applicable environmental and social safeguard policies of WB are listed as follows:
Table 2-1: Applicable Environmental and Social Safeguard Policies of the World Bank
                       Relevance
                                       Relevance of the
      Safeguard          of the
                                       Sub-Project (the                                    Note
        Policy          Parent
                                        Pilot Project)
                        Project
                                                              The project activities include raw material replacement,
                                                              experiments, equipment replacement, product trial
   Environmental
                                                              production and production activities, which will have an
    Assessment          Triggered           Triggered         impact on the environment. The project will prepare this
   (OP/BP 4.01)
                                                              environmental management plan to control the
                                                              environmental risks in the process of equipment removal.

                                                              Both parent project and the pilot project does not involve
  Natural Habitats         Not
                                         Not Triggered        natural habitats and nature reserves at all levels, nor does
   (OP/BP 4.04)         Triggered
                                                              it carry out construction in nature reserves.

                                                              The parent project triggers the OP 4.09, according to the
        Pest                                                  Environmental and Social Management Framework
     Management         Triggered        Not Triggered        (ESMF). However, the pilot project does not involve the
      (OP 4.09)                                               manufacture, use, purchase, and treatment of pesticides,
                                                              so the pilot project dose not trigger OP 4.09.

                                                              The parent project doesn’t trigger the OP 4.10, according
   Indigenous              Not
                                         Not Triggered        to the ESMF. This pilot project is not located in an ethnic
 People (OP 4.10)       Triggered
                                                              minority settlement and does not trigger the WB's OP 4.10.

                                                              The parent project doesn’t trigger the OP 4.11, according
 Physical Cultural                                            to the ESMF. This pilot project does not involve material
                           Not
 Resources (OP                           Not Triggered        and cultural resources, and will not select sites that affect
                        Triggered
      4.11)                                                   archaeological, paleontological, and historical values to
                                                              carry out activities.

      Involuntary                                             The parent project triggers the OP/BP 4.12, according to
     Resettlement       Triggered        Not Triggered        the ESMF. However, the construction of this pilot project
     (OP/BP 4.12)                                             does not involve land acquisition and demolition.

                                                              The parent project doesn’t trigger the OP 4.36, according
     Forestry (OP          Not
                                         Not Triggered        to the ESMF. This pilot project does not involve commercial
        4.36)           Triggered
                                                              logging and does not involve virgin forest.

                                                              Both parent project and the pilot project does not involve
  Safety of Dams           Not                                supporting the construction and rehabilitation of dams, nor
   (OP/BP4.37)          Triggered        Not Triggered        will it rely on existing dams or dams under construction on
                                                              the mission.

      Projects on
     International         Not                                Both parent project and the pilot project does not involve
      Waterways         Triggered        Not Triggered        international rivers.
     (OP/BP7.50)

    Projects in
                           Not                                Both parent project and the pilot project does not involve
  Disputed Areas                         Not Triggered
                        Triggered                             disputed areas.
   (OP/BP7.60)




                                                                 4
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



                       Relevance
                                       Relevance of the
     Safeguard           of the
                                       Sub-Project (the                                    Note
       Policy           Parent
                                        Pilot Project)
                        Project
   World Bank                                                 Both parent and the pilot project will carry out at least 2
 Policy on Access       Triggered           Triggered         rounds of information disclosure and public participation
  to Information                                              following the World Bank’s policies.




The WB General EHS Guideline has been referred.
Domestic environmental and social laws and regulations applicable to this report are listed in
Table 2 1.
Table 2 1: Environmental and Social Laws and Regulations.

                                                  Title                                                   Effective Date

  General

  Law on Environmental Impact Assessment                                                                        2018

  Law on Environmental Protection                                                                               2015

  Management Regulations for Environmental Protection for Construction Projects                                 2017

  Classification Method for Environmental Accident Risk of Enterprise                                           2018

  Notice of the State Council on Issuing the "Thirteenth Five-Year" Ecological Environment
  Protection Plan                                                                                               2016

  Notice of the State Council on Issuing the Three-Year Action Plan for Winning the Blue-Sky
  Defence War                                                                                                   2018

  Notice on Further Strengthening the Management of EIA and Preventing Environmental Risks                      2012

  Notice on Issuing the List of Significant Changes in Construction Projects of Some Industries
  in the Management of EIA                                                                                      2015

  Notice on the Issue the "Thirteenth Five-Year" EIA Reform Implementation Plan                                 2016

  Notice on Job Handover of EIA System and Pollution Discharge Permit System                                    2017

  Notice on Strengthening Risk Prevention and Strict EIA Management                                             2012

  Technical Guideline for Environmental Impact Assessment of Construction Project - General
  Program                                                                                                       2017

  Regulations of Henan Province on Environmental Protection of Construction Projects                            2016

  Notice of the Department of Housing and Urban-Rural Development of Henan Province on
  Issuing the Implementation Plan for the Prevention and Control of Air, Water, and Soil                        2020
  Pollution in Henan Province in 2020

  Air pollution control

  Integrated Emission Standards for Atmospheric Pollutants                                                      1996




                                                                 5
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



                                                  Title                                                   Effective Date

  Comprehensive Emission Standard of Air Pollutants                                                             2018

  Notice of the Ministry of Ecology and Environment on the Release of Sample Emission Permit
  Undertaking, Emission Permit Application Form and Emission Permit Format                                      2018

  Notice on the Issuance of the "Thirteenth Five-Year Plan" for the Prevention and Control of
  Volatile Organic Compounds Pollution                                                                          2017

  Emission Standards for Odorous Pollutants                                                                     1993

  Standard for Catering Service Air Pollutant Emission                                                          2018

  Pollution Control Standards for Hazardous Waste Incineration                                                  2001

  Emission Standards for Volatile Organic Compounds from Industrial Painting Processes                          2020

  Regulations of Henan Province on the Prevention and Control of Air Pollution                                  2018

  Regulations of Henan Province on Reducing Pollutant Discharge                                                 2014

  Regulations of Luoyang on the Prevention and Control of Air Pollution                                         2020

  Water resource protection

  Environmental Quality Standard for Surface Water                                                              2002

  Standard for Groundwater Quality                                                                              2017

  Law on Water                                                                                                  2016

  Law on Water Pollution Prevention and Control                                                                 2017

  Measures on Water Abstraction Permit Management                                                               2008

  Integrated Wastewater Discharge Standard                                                                      1996

  Technical Guidelines for Environmental Impact Assessment Groundwater Environment                              2016

  Urban Wastewater Recycling - Water Quality Standard for Industrial Use                                        2005

  Notice of the General Office of the People's Government of Henan Province on Issuing the
  Division of Centralized Drinking Water Source Protection in Towns and Villages in Henan                       2016
  Province

  Regulations of Henan Province on the Prevention and Control of Water Pollution                                2019

  Regulations of Luoyang City on the Protection of Drinking Water Sources in Luhun Reservoir                    2020

  Noise Emissions prevention

  Law on the Prevention and Control of Pollution of Environmental Noise                                         2018

  Emission Standard of Environment Noise for Boundary of Construction Site                                      2012

  Standard for Noise at the Boundary of Industrial Enterprises                                                  2008

  Waste Management and Disposal



                                                                 6
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



                                                  Title                                                   Effective Date

  Law on the Prevention and Control of Environmental Pollution by Solid Waste                                   2020

  Standard for Pollution Control on Industrial Solid Waste Storage                                              2013

  Standard for Pollution Control on Hazardous Waste Storage                                                     2013

  Standard for Pollution Control on the Hazardous Waste Landfill                                                2020

  National Catalogue of Hazardous Wastes                                                                        2021

  Management Regulation for Hazardous Waste Transfer Manifests                                                  1999

  Regulations of Henan Province on the Prevention and Control of Environmental Pollution by
  Solid Waste                                                                                                   2012

  Occupational Health

  Law on Occupational Disease Prevention and Control                                                            2018

  List of Occupational Disease Hazards Risk Categories for Construction Projects                                2021

  Regulations on the Management of Occupational Health in the Workplace                                         2021

  Technical Specification for Occupational Health Monitoring                                                    2014

  Safety

  Law on Production Safety                                                                                      2021

  Measures for Supervision and Management of "Three Simultaneous" Safety Facilities in
  Construction Projects                                                                                         2015

  Measures for the Management of Safety Production Emergency Plans                                              2019

  Law on Fire Protection                                                                                        2021

  Code for Fire Protection Design of Building                                                                   2018

  Code for Design of Extinguisher Distribution in Building                                                      2005

  Supervision and management regulations for firefighting products                                              2013

  Labor

  Labor Law                                                                                                     2018

  Labor Contract Law                                                                                            2012




                                                                 7
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



3.         SITE INTRODUCTION
3.1        BASIC INFORMATION
3.1.1 Site Location
The Yibin Branch is located at the southwest of Xihan Village, Zhuge Town, Yibin District, Luoyang
City, Henan Province (see Figure 3-1), covering an area of 13,806 square meters (approximately
20.7 mu). At present, the nature of the land belongs to rural collective construction land. Langchao
Fire Technology has signed a land lease agreement with Xihan Village and has obtained a land
use certificate for collective construction land (see chapter 5.4.1 for details of the land use).
Figure 3-1:The Project Location




The surrounding situation of the Yibin Branch is shown in Figure 3-2. As shown in the figure, the
surrounding conditions of the Yibin Branch are as follows:
       •    Western boundary: Duleyuan Hotel and Luoyang Qiangrong Glass Mirror Co., Ltd.;
       •    Eastern boundary: close to Luoyang Longmen Glass Group and Gulongxuan Hotel;
       •    North boundary: Gulong Road, 120m northeast of Gulong Road is Xihan Village;



                                                                 8
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



       •    South boundary: close to Luoyang Longmen Glass Group.


Figure 3-2: Site Vicinity Map




See Table 3-1 for the environmental sensitive points within 500 meters of the Yibin Branch (the
conventional distance of China's environmental impact assessment).
Table 3-1:Sensitive Points around the Project Area

                                                                                                             Closest
      No.            Protection Target                    Type                     Direction
                                                                                                           Distance(m)

                                                        Dining
       1               Duleyuan hotel                                            West�?north                    Nearby
                                                    accommodation

                                                        Dining
       2              Gulongxuan hotel                                                East                     Nearby
                                                    accommodation

       3                Xihan village                    Village                   Northeast                   120 m

       4                  Pei village                    Village                   Northwest                   300 m

                                                  Agricultural irrigation
       5                Yidong canal                                                 North                      50 m
                                                          canal




                                                                   9
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



3.1.2 Project Building Situation
The Yibin Branch factory area is composed of production workshops, finished product
warehouses, packaging barrel warehouses, office buildings, dormitories, laboratories, etc. The
whole plant of the Yibin Branch is arranged with the office area on the north side of the plant area,
the production area on the south side of the plant area, the finished product warehouse, and the
packaging barrel warehouse at the southeast corner of the plant area, and the dormitory on the
east side of the plant area. The southwest area adjacent to the warehouse of waste drums and
bags is the auxiliary facilities area, where a sewage treatment station is mainly installed. The
layout of the Yibin Branch factory area is shown in Figure 3-3.


Figure 3-3: Site Layout




The pilot project is to implement the Stockholm Convention in China, carry out the Best Accessible
Technology/Best Environmental Practice (BAT/BEP), and promote the reduction and phase-out
of PFOS in the fire industry eventually. The goal of this pilot project is to develop PFOS-free foam
extinguishing agent, and to trial-produce and test PFOS-free foam fire extinguishing products,
and gradually achieve the replacement of PFOS-containing fire extinguishing products. The main
tasks of the pilot project consist of:


                                                                 10
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



       •    Research and development of the PFOS-free foam fire extinguishing agents.
       •    Replacement of production equipment and trial production.
       •    Quality control of the trail production.
       •    Testing and evaluation by third parties.
       •    Fire extinguishing experiments.
       •    Replacement of the PFOS-containing foam fire extinguishing products.
       •    Promotion of PFOS-free products.
       •    Closure of the pilot project.


See Table 3-2 for details of this pilot project and related buildings and facilities:
Table 3-2: Relevant Buildings and Facilities within the pilot project area
 No.                             Building                                      Structure                   Area (m2)
           Synthetic foam project production and raw material,
  1                                                                          Steel structure                 1,350
                        finished product workshop

  2                    Finished product warehouse                          Brick and concrete               835.36

  3                     Packing barrel warehouse                           Brick and concrete               1,023.8

  4                             Laboratory                                 Brick and concrete                 400

  5                           Sewage station                               Brick and concrete                 300



This pilot project does not involve large-scale construction activities, only the replacement of
production and testing equipment, and all activities are carried out within the building, which has
a small impact on the surrounding environment. The project area is mainly for synthetic foam
project production and raw materials, finished product workshops, and laboratories. The project
affected area includes all the above-mentioned buildings.


3.1.3 Site History
The historical situation of Langchao Fire Technology is shown in Table 3-3.
Table 3-3: Project History
       Year                                                           Activities

                     Luoyang Laocheng Fire Agent Factory was established, located at No. 208, East Jiudu Road,
       1954
                     Laocheng District, Luoyang City

       1970          Converted to fire extinguishing agent

       1991          Renamed to “Luoyang Langchao Fire-fighting Agent Co., Ltd."

                     The production department moved to its current address, which was on the southwest side of
                     Xihan Village, Zhuge Town, Yibin District, Luoyang City, covering an area of 20.7 acres and
       2010
                     obtaining a collective land use certificate. The address in the Laocheng District was only reserved
                     for the management department, and no production was carried out.



                                                                 11
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



       Year                                                           Activities

       2011          Renamed to “Luoyang Langchao Fire Technology Co., Ltd."

                     "Luoyang Langchao Fire Technology Co., Ltd. Yibin Branch" was established at the same address
       2014          in Xihan Village, Zhuge Town. Yibin branch is mainly responsible for production, and Langchao
                     Fire Technology Co., Ltd. is mainly responsible for management and business sales.




3.2       PROUCTION PROCESS
The Yibin Branch has 10 foam fire extinguishing agent production lines, designed to produce
8,500 tons of compound and sub-packed foam fire extinguishing agents per year. The current
actual production capacity is about 5,000 tons per year. The Yibin Branch currently produces six
types of foam fire extinguishing agents, namely aqueous film-forming foam fire extinguishing
agent (designed production capacity is 1500 tons/year, actual production capacity is about 880
tons/year), and medium double foam fire extinguishing agent (designed production capacity is
1,500 tons/year, actual production capacity is about 880 tons/year), high-expansion foam fire
extinguishing agent (designed production capacity is 1,500 tons/year, actual production capacity
is about 880 tons/year), anti-solvent aqueous film-forming foam fire extinguishing agent (designed
production capacity is 1,500 tons/year, actual production capacity is about 880 tons/year),
alcohol-resistant foam fire extinguishing agent (designed production capacity is 1,000 tons/year,
actual production capacity is about 600 tons/year) and alcohol-resistant fluoroprotein foam fire
extinguishing agent (designed production capacity is 1,500 tons/year, actual production capacity
is about 880 tons/year ), two of the foam fire extinguishing agents (water film-forming foam fire
extinguishing agent and solvent-resistant aqueous film-forming foam fire extinguishing agent)
contain PFOS in the production raw materials. Although the remaining four foam fire extinguishing
agents do not contain PFOS in the raw materials, they may still contain trace amounts of PFOS
in their final products because they share the production line with PFOS-containing products.
The production process of the above six foam fire extinguishing agents is the same except for the
difference in the feeding and mixing section. The production process is a simple mixing and sub-
packaging of multiple raw materials, the whole process is only physical without chemical reaction
and all production processes are normal temperature and pressure. The process flow chart is
shown in Figure 3-4. The project currently employs 67 people and implements a one-shift system
with 8 hours of work per shift and 300 days of work per year.
Figure 3-4:Process Flow Chart




In the existing project, the production raw material containing PFOS is the firefighting additive
F1212 (a fluorocarbon surfactant), which is used in the mixing process. The addition ratio varies



                                                                 12
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



according to different foam fire extinguishing agent models, ranging from 1% to 5 %. Fluorocarbon
surfactants have been used for a long time, the product quality is stable, and have the effect of
reducing the surface tension of the liquid and the film formation, and the fire extinguishing
performance are stable, and it is the main material that must be added to the foam fire
extinguishing agent at this stage. The main purpose of this pilot project is to replace the fire-
fighting aid F1212.


3.2.1 Production Process Flow of Water-based Foam Fire Extinguishing Agent
      Products
The production process flow of Water-based Foam Fire Extinguishing Agent Products is as
follows:
     •     Main product types: aqueous film-forming foam fire extinguishing agent, medium
           expansion foam fire extinguishing agent, high expansion foam fire extinguishing agent
     •     Use high-quality raw materials: water, sodium lauryl sulfate, urea, foaming agent,
           antifreeze, fluorocarbon surfactant, etc. All raw materials of the Yibin Branch are
           purchased from outside, and all kinds of raw materials must be inspected when entering
           the factory, only after passing the inspection can materials be put into storage for later
           use.
     •     Mixing: add water, antifreeze, stabilizer, flame retardant, blowing agent, solvent, and
           fluorocarbon surfactant into the mixing tank orderly, and control the stirring speed to 90
           rpm and the temperature to room temperature, so that the components are fully dissolved
           and reacted, and then mixing and stirring for 4 hours.
     •     Finished product: after mixing and stirring for 4 hours, take samples for inspection,
           weigh, and pack after passing and put the product into storage according to the
           requirements of the factory inspection procedures.
     •     Packaging, marking, transportation and storage requirements: products that pass
           the inspection are packaged in anticorrosive iron or plastic barrels, the name, model,
           mixing ratio, weight, production number, production date, trademark, manufacturer, and
           simple storage requirements of the water-based fire extinguishing agent must be clearly
           marked on the packaging barrel. The products should not be mixed with other types of
           fire extinguishing agents, alcohols, acids, and bases impurities, so as not to affect product
           quality, and should be stored in a cool and ventilated place, the storage temperature
           should be less than 45 ℃, the storage period is two years.

3.2.2 Process Flow of Alcohol-resistant Foam Fire Extinguishing Agent
The process flow of Alcohol-resistant Foam Fire Extinguishing Agent is as follows:
•   Main product type: soluble-resistant aqueous film-forming foam fire extinguishing agent,
    alcohol-resistant foam fire extinguishing agent, alcohol-resistant fluoroprotein foam fire
    extinguishing agent
•   Use high-quality raw materials: xanthan gum, fluorocarbon surfactants, foaming agents,
    ethylene glycol, urea, etc. All raw materials of the Yibin Branch are purchased from outside,



                                                                 13
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



    and all kinds of raw materials must be inspected when entering the factory, only after passing
    the inspection can materials be put into storage for later use.
•   Mixing: before production, add the measured water into the reaction tank, then slowly put the
    xanthan gum into the reaction tank, turn on the mixer while adding the xanthan gum, turn off
    the mixer after stirring for 2 hours, and soak for 12-24 hours. Accurately measure various raw
    materials according to the weight percentage specified in the process formula. When the
    xanthan gum solution has no lumps, add sodium lauryl sulfate, urea, foaming agent, and
    ethylene glycol into the reaction tank and stir for about 4 hours so that the components are
    fully dissolved.
•   Finished product: put the prepared foam liquid into the defoaming tank for defoaming. After
    defoaming, take a sample for inspection. The inspection standard shall be inspected
    according to the requirements of the factory inspection regulations. After the index is qualified,
    it will be packed into barrels and put into storage.
•   Packaging, marking, transportation and storage requirements: products that pass the
    inspection are packaged in anticorrosive iron or plastic barrels, the name, model, mixing ratio,
    weight, production number, production date, trademark, manufacturer, and simple storage
    requirements of the water-based fire extinguishing agent must be clearly marked on the
    packaging barrel. The products should not be mixed with other types of fire extinguishing
    agents, alcohols, acids, and bases impurities, so as not to affect product quality, and should
    be stored in a cool and ventilated place, the storage temperature should be less than 45 ℃,
    the storage period is two years.




                                                                 14
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



3.2.3 Raw Materials
All raw materials of the Yibin Branch are purchased. The materials involved are shown in Table
3-4.
Table 3-4: List of Main Raw Materials
                                             Annual
  No.           Raw Materials                                  Chemical Properties         Main Chemical Composition
                                           Consumption
                                                                                               8~10 glycosidic alcohol,
   1         Foaming agent F801               120 tons           General chemicals
                                                                                                   ethylene glycol

           Fluorocarbon surfactant
                                                                                           Perfluoroalkyl acrylate polymer
   2         (firefighting additive           18 tons            General chemicals
                                                                                              (PFOS), ethylene glycol
                     F1212)

                Additive F301N                                                               Glucose, cellulose, sodium
   3                                          240 tons           General chemicals
                 (antifreeze)                                                                        benzoate

   4       Sodium dodecyl sulphate            36 tons            General chemicals            Sodium dodecyl sulphate

   5            EDTA-2 sodium                 24 tons            General chemicals                 EDTA-2 sodium

                                                                                             D glucopyranose, oligomer,
   6        Fchj-50 foaming agent             180 tons           General chemicals
                                                                                                decyl octyl glycoside

   7                  Urea                    240 tons           General chemicals                       Urea

                                                                                           Alkenyl sulfonate, hydroxyalkyl
   8                  AOS                     60 tons            General chemicals
                                                                                              sulfonate, desulphonated

   9           Anionic surfactant             120 tons           General chemicals          Fatty alcohol sodium sulphate

   10             Dodecanal                   1.2 tons           General chemicals                    Dodecanal

   11      Foaming agent APG0810              120 tons           General chemicals                 Alkyl Glycoside

                                                                                              Perfluoroalkyl quaternary
   12       Fire-fighting aid YF-138          12 tons            General chemicals
                                                                                                 ammonium iodide

   13            Xanthan gum                   6 tons            General chemicals                  Xanthan gum

            Diethylene glycol butyl
   14                                         36 tons            General chemicals          Diethylene glycol butyl ether
                    ether

   15       Foaming agent KLH-30              12 tons            General chemicals            Cocamidopropyl Betaine

   16           Ethylene glycol               120 tons           General chemicals                  Ethylene glycol

   17              Hoof shell                 360 tons           General chemicals                         /

   18               gasoline                   600 L           Hazardous chemicals                         /

   19             Isopropanol                  600 L           Hazardous chemicals                   Isopropanol




                                                                 15
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



4.        PROJECT BACKGROUND
The environmental and socio-economic background data of this project use the background data
of the Yibin District as priority. If there is no corresponding public information in Yibin District, the
public information of Luoyang City, the upper-level administrative division of Yibin District, will be
used as a reference. If there is no corresponding public information in Luoyang City, the public
data of the higher administrative division of Henan Province shall be consulted.

4.1       ENVIRONMENTAL BASELINE
4.1.1 Geography and Climate
Luoyang City is located in the western part of Henan Province, between 111°08’~112°59’ east
longitude and 33°35'~35°05' north latitude. It borders Zhengzhou in the east, Sanmen Gorges in
the west, the Yellow River and Jiaozuo in the north and Pingding Mountain and Nanyang in the
south. Yibin District is located between 112°29'~112°39 east longitude and 34°30'~34°40 north
latitude, south of Luoyang City and southwest of Yanshi City, the planning area borders Guanlin
Town and Longmen Town, Luolong District, Luoyang City in the west, Wan'an Mountain and
Pengpo Town, Yichuan County in the south, and Yi River in the north. Yibin branch is located on
the southwest side of Xihan Village, Zhuge Town, Yibin District, Luoyang City.
Luoyang City has a warm temperate continental monsoon climate, and the seasonal changes of
atmospheric circulation are obvious. The winter is controlled by the polar airflow, and the weather
is cold and dry; the summer is affected by the North Pacific subtropical high pressure, the weather
is hot and rainy, with an average annual temperature of 14.7℃; the average annual precipitation
is 585.2mm, but the distribution during the year is extremely uneven. The precipitation in June to
September is about It accounts for 63.5% of the whole year; the annual average relative humidity
is 66%; the most frequent wind direction is northeast.
4.1.2 Ambient Air Quality
According to the Environmental Quality Bulletin of Luoyang City in 2020, the urban ambient air of
Luoyang City in fine particulate matter (PM2.5), respirable particulate matter (PM10), sulfur
dioxide, nitrogen dioxide, carbon monoxide 95th percentile concentration and ozone 90th
percentile concentrations have all decreased significantly, and the number of good days has
increased significantly. The annual average concentration of fine particulate matter (PM2.5) is 51
μg/m3, sulfur dioxide (SO2) is 8 μg/m3, nitrogen dioxide (NO2) is 34 μg/m3, carbon monoxide (CO-
95) is 1.3 mg/m3, and ozone (O3H8-90) is 166 μg/m3.
In 2020, the comprehensive index of ambient air quality in Luoyang City was 5.10, which is a
decrease of 0.99 compared with 2019, and the air quality has improved. In 2020, the annual
average concentration of sulfur dioxide (SO2) reached the national first-level standard limit of
ambient air quality (20 μg/m3); the annual average concentration of nitrogen dioxide (NO2) met
the national second-level standard limit of ambient air quality (40 μg/m3); the concentration of
carbon monoxide (CO-95) reached the national secondary standard limit of ambient air quality (4
mg/m3); the concentration of ozone (O3H8-90) exceeded the national secondary standard limit of
ambient air quality (160 μg/m3) 0.04 times; the annual average concentration of inhaled particulate



                                                                 16
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



matter (PM10) exceeded the national secondary standard limit of ambient air quality (70 μg/m3)
by 0.23 times; the annual average concentration of fine particulate matter (PM2.5) exceeded the
national secondary standard limit of ambient air quality (35 μg/m3) 0.46 times. Fine particulate
matter (PM2.5) is still the main air pollutant in Luoyang City.


4.1.3 Surface Water Environmental Quality
According to the Environmental Quality Bulletin of Luoyang City in 2020, there were 12 surface
water monitoring sections in 6 major monitoring rivers under the jurisdiction of the city, and the
total length of the monitored river sections was 671.2 kilometers. The water quality of Yi River,
Luo River and Ru River was excellent, the water quality of Yiluo River was good, and the water
quality of Jian River and Chan River was mildly polluted. Compared with 2019, the water quality
of the six rivers has not changed significantly, the water quality of the Yi River has improved, and
the water quality of the Chan River has slightly decreased. During the "Thirteenth Five-Year Plan"
period, the overall water quality of rivers in Luoyang City has improved, the comprehensive
pollution index was on a downward trend, the overall water quality of Yi River and Luo River has
improved from good to excellent in 2017, and seven surface water state and provincial control
monitoring sections have reached three types of water quality one year ahead of schedule,
including five sections of two types of water quality and above, accounting for 71.4%.
In 2020, the comprehensive water quality class of the 8 centralized underground drinking water
sources of the Luonan water source mixed water, Li Lou water source mixed water, Zhangzhuang
water source mixed water, Xiachi groundwater well group, Linjian groundwater well group,
Wangfuzhuang groundwater well group, Jili District groundwater well group and Dongjiao
groundwater well group were all in the third class. Among them, Luonan water source mixed water
quality was the second class, the rate of compliance was 100%.
The surface water in Yibin District is mainly Yi River, which belongs to the Yellow River basin and
the Yiluo River system, there are also a number of irrigation canals, such as the Dongyi Canal,
Yidong Canal, Mati Well Branch Canal, Caishigang Branch Canal, etc., with the irrigation area of
nearly 40km2, there is also a small first-class Jiuliugou Reservoir, covers an area of 50 acres,
reservoir capacity of 2.26 million m3, irrigation area of 2,100 mu; small second-class Zhuge
Reservoir.
The water body function plan of Yi River in Luoyang City is Class III. Yidong canal is a local
agricultural irrigation canal, and water is diverted from the Yi River during the agricultural irrigation
period, and there is no water diversion during the monitoring period of the Yibin Branch.
Taohuadian reservoir is the largest reservoir in Luoyang City, Yanshi City, it is located at the east
of Taohuadian Village, Gaolong Town, 15 kilometers south of Yanshi City, and is located at the
junction of Majianhe and Liujian River, a tributary of the Yi River, and is at the junction of Fengshi,
Gaolong and Guxian towns. The reservoir mainly consists of dam, main and secondary spillways,
two water transmission caverns in the east and west, with a total control basin area of 230 km2, a
total reservoir capacity of 18.72 million m3, a normal reservoir capacity of 8.86 million m3, a rainfall
collection area of 183 km3, and an elevation of 135m. Taohuadian Reservoir has played an
important role in flood control, irrigation, and industrial water supply since its completion.



                                                                 17
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



The wastewater of the Yibin Branch is treated by the wastewater treatment facilities in the factory
and discharged into the Yidong Canal, which eventually flows into the Taohuadian Reservoir.


4.1.4 Groundwater Environmental Quality
In 2020, 11 groundwater quality monitoring wells in Luoyang City had a comprehensive water
quality of Class II, Class III and Class IV, and the groundwater quality was divided into three
classes: excellent, good, and poor. Among them: 1 well reached the second-class excellent level,
accounting for 9.09% of the total number of monitored wells; 9 wells reached the third-class good
level, accounting for 81.8% of the total number of monitored wells; 1 well reached the fourth-class
poor level, accounting for 9.09% of the total number of monitored wells.
The comprehensive groundwater score in 2020 was 2.18. Compared with 2019 (2.19), it was
slightly lower, and the water quality remained unchanged at good; the geometric mean of
bacteriological factors was 2.00, which was the same as 2019 (2.00) and remained at Class I.
During the "13th Five-Year Plan" period, the groundwater quality of each well location changed
significantly. Among them, the water quality of Zhangzhuang monitoring wells changed from good
in 2016 to excellent in 2020; the water quality of monitoring wells of Linjian water source,
Wangfuzhuang water source, Lilou water source, Dongjiao water source, Towing Factory and
Foreign Language College changed from poor in 2016 to good in 2020.
The groundwater in Luoyang City is mainly distributed in the plain area at the edge of Yanluo
Depression Basin and the plain area of Luo River and Jian River valley, and the lithology of aquifer
in these areas belongs to the sand and gravel layer formed by alluvium of Quaternary Upper
Pleistocene to Holocene, and the protection conditions of its air pocket are not uniform, among
which in the river floodplain is unfavorable to the protection of groundwater pollution because of
the thin thickness of air pocket, lithology particle group and good permeability.
At present, water for industrial production and residential use in Luoyang City mainly comes from
groundwater, and there are three underground drinking water source pressure stations and nine
concentrated groundwater sources. The Yibin Branch is located in the southwest of Xihan Village,
Zhuge Town, Yibin District, Luoyang City, and the water of the Yibin Branch is supplied by its own
well within the factory. According to the latest water quality monitoring on privately owned wells
in 2021, the water quality of the well meets the national standard for drinking water. Detailed
testing report are available in Annex 4. It is 21km from Wangfuzhuang water source, 16km from
Wulibao water source, 13.5km from Zhangzhuang water source, 10km from Luonan water source,
16km from Linjian water source, 13km from Xiachi water source, 19km from Houli Village water
source, 13km from Lilou water source, and 14km from Dongjiao water source. Reportedly the
Yibin Branch is not within the protection scope of the groundwater source and the centralized
water supply plant in Luoyang area. The drainage from the Yibin Branch meets the first-grade
standard of Table 4 of the "Comprehensive Sewage Discharge Standard" (GB8978-1996) and is
discharged into Yidong Canal, which eventually flows into Taohuadian Reservoir and does not
affect the groundwater source.




                                                                 18
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



4.1.5 Acoustic Environmental Quality
In 2020, the urban area of Luoyang City had a total of 262 noise monitoring points on an 800-
meter×800-meter grid, covering an area of 168 square kilometers. The average equivalent sound
level of daytime ambient noise in the urban area was 51.9 dB, and the regional acoustic
environment noise was Class 2, with an overall evaluation of good. Compared with 2019, it
decreased by 0.9 dB, and the acoustic environment quality did not change. The area of urban
areas exposed to daytime noise between 50.1 and 55.0 dB and with good environmental quality
accounted for 62%, with an affected population of about 1.312 million people; the area exposed
to less than 50.0 dB accounted for 22%, with an affected population of about 206,000 people; the
area exposed between 55.1 and 60.0 dB accounted for 16%, with an affected population of about
414,000 people. Domestic noise and traffic noise are still the main noise sources.


4.2       ECOLOGICAL BASELINE
Luoyang City is rich in wildlife resources. There are more than 290 species of terrestrial
vertebrates, including 8 species of amphibians, 22 species of reptiles, more than 120 species of
birds, and 42 species of mammals, including salamanders, red-bellied sapsuckers, Sumerian
antelopes, money leopards and other national and provincial key animals. There are about 144
families of trees, shrubs, native plants, edible mushrooms, etc. There are more than 2,100 species
of plants, including more than 10 species of Lianxiang trees, ginkgo, pearl ginseng, etc. that are
protected at the national level, and nearly 30 species of Bashan fir, hemlock, etc. that are
protected at the provincial level.
The Yibin Branch is located in the southwest of Yibin District, and the plant resources are mainly
artificially cultivated food crops, cash crops and vegetables, and the animals are mainly artificially
raised domestic animals. According to the survey, there are no rare plant and animal species in
the evaluation area.


4.3       SOCIOECONOMIC BASELINE
4.3.1 Population
Henan Province is located in the central-eastern part of China and the middle and lower reaches
of the Yellow River, bordered by Anhui and Shandong Province to the east, Hebei and Shanxi
Province to the north, Shaanxi Province to the west and Hubei Province to the south. As of 2021,
the province has 17 prefecture-level cities and one province-administered county-level city, with
a total area of 167,000 square kilometers, accounting for 1.73% of the country's total area. Henan
Province is one of the most populous provinces in China, with a total population of 109.52 million
at the end of 2019 and a population density of 661 people per square kilometer. The resident
population is 96.4 million, including 51.29 million urban residents, with an urbanization rate of
53.21%.
Luoyang City, a prefecture-level city in Henan Province, is the deputy center city of the Central
Plains City Cluster. Luoyang City has a total area of 15,230 square kilometers, including 2,229


                                                                 19
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



square kilometers of urban area, located in the west of Henan Province, with a length of about
179 kilometers from east to west and a width of about 168 kilometers from north to south. As of
March 2021, Luoyang City had 7 counties and 7 districts under its jurisdiction. At the end of 2019,
Luoyang City had a total population of 7,170,200 people, with a population density of 470.79
people/km2. As of November 2020, the city's resident population was 7,056,699, of which the
urban population was 4,585,300, accounting for 64.98%. Luoyang City is a multi-ethnic place.
There are 45 ethnic components in the city, among which the Han population accounts for about
98.8% of the total population of the city, and other ethnic minorities account for about 1.2% of the
total population of the city. The distribution of ethnic minorities in Luoyang City is characterized
by large dispersion and small clustering, and there are 1 urban ethnic district, 2 ethnic townships
(towns) and 24 ethnic villages in the city.
Yibin Economic Development Zone (demonstration zone) is located in the southeast of Luoyang
City, north to the Luo River, south to the foothills of Wanan Mountain, west to the Erguang
Expressway, east to the west border of Yanshigaolong. It has a total area of 280 square
kilometers, of which, the central urban area is 52 square kilometers. It has jurisdiction of 5 towns
including Zhuge Town, Licun Town, Pangcun Town, Dianzhuang Town, and Koudian Town, with
a total of 106 communities. In the 2020 national seventh census, the total population was 360,000,
permanent population was 274,700, permanent population urbanization rate was 64.5%. There
are a total of 262 permanent ethnic minorities in the region, among which 66 are the Hui ethnic
minorities, accounting for 25.2%.
According to the results of the main data of the seventh national census published by the National
Bureau of Statistics in May 2021, the total population of the country was 141.78 million. According
to the results of the main data of the seventh national census in Henan Province, the permanent
population of the province was 99,365,519, and the total population of the province was not
published. According to the results of the seventh national census of Luoyang City, the permanent
population of the city was 7,056,699, and the total population data of Luoyang City was not
published. Therefore, it was not possible to obtain the total population data of Henan Province
and Luoyang City in 2020. According to the 2020 China Statistical Yearbook and the 2020 Henan
Provincial Statistical Yearbook, the total population of China, Henan Province, and Luoyang City
in 2019 is shown in Table 4-1.


Table 4-1: Total Population and Population Density in 2019
            Subject                       China             Henan Province            Luoyang City             Yibin District
   Area (square kilometres)             9,600,000                167,000                  15,230                     280

   Population (ten thousand
                                         140,005                 10,952                   717.02                      32
            people)

      Population density
                                          145.8                    655                    470.79                   1,285.7
  (person/square kilometres)
Data sources: 2020 China Statistical Yearbook, 2020 Henan Provincial Statistical Yearbook, 2019 National Economic and Social
Development Statistical Bulletin of Luoyang City, Yibin District Government Website(http://www.hnlykfq.gov.cn/jingkaiqujieshao.html)




                                                                   20
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



4.3.2 Economy and Income
GDP Per Capita
Henan Province is a large economic province in China. According to the Statistical Bulletin of
National Economic and Social Development of Henan Province in 2020, the annual gross
domestic product of the province was CNY 5,499,707 billion, ranking 5th among 31
provinces/autonomous regions/municipalities directly under the central government; the
permanent population of Henan Province was 96.4 million, and the per capita gross regional
product was CNY 57,051.
During the "Thirteenth Five-Year Plan" period, Luoyang's total economic output has exceeded
CNY 400 billion and CNY 500 billion, reaching CNY 512.84 billion in 2020, with a year-on-year
increase of 3%, the total amount was ranked 45th among cities above prefecture-level, the growth
rate of economic indicators continued to be higher than the national average level of the whole
province, and ranked first in the province. The permanent population of Luoyang City is CNY
7,056,699, and the per capita GDP of Luoyang City is CNY 72,674.
A comparison of gross domestic product (GDP) and industrial structure in 2020 is shown in Table
4-2.
Table 4-2: Comparison of GDP and Industrial Structure in 2020
                       Subject                                    China               Henan Province          Luoyang City

                  GDP (billion CNY)                             1,015,986                 54,997.07               5,128.4

               GDP per capita (CNY)                              72,447                    57,051                   72,674

       GDP growth rate (compared to 2018)                         2.3%                      1.3%                     3%

         Proportion of primary industry (%)                       7.7%                      9.7%                     5%

       Proportion of secondary industry (%)                       37.8%                     41.6%                    45%

         Proportion of tertiary industry (%)                      54.5%                     48.7%                    50%

Data source: 2020 National Economic and Social Development Statistical Bulletin of the People's Republic of China, 2020 National
Economic and Social Development Statistical Bulletin of Henan Province, 2020 National Economic and Social Development Statistical
Bulletin of Luoyang City.



Disposable Income Per Capita
In 2020, the per capita disposable income of residents in Henan Province was 24,810.10 yuan,
of which, the per capita disposable income of urban residents was CNY 34,750.34 and the per
capita disposable income of rural residents was CNY 16,107.93.
In 2020, the per capita disposable income of residents in Luoyang City was CNY 28,096, with an
increase of 3.7%. Among them, the per capita disposable income of urban residents was CNY
39,287, with an increase of 1.7%; the per capita disposable income of rural residents was CNY
15,902, with an increase of 6.2%.



                                                                  21
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



Overall, the economic development level of Luoyang City is relatively low, and the average annual
disposable income of urban and rural residents is lower than the national as well as the average
level of Henan Province (see Figure 4-1). Overall, the economic development level of Luoyang
City is relatively low, and the average annual disposable income of urban and rural residents is
lower than the national as well as the average level of Henan Province (see Figure 4-1).
Figure 4-1: Social and Economic Overview in 2020

         72447        72674
                57051
                                                                       43834
                                                                                39287
                                       32189                              34750.34
                                                 28096
                                           24810.1                                                   17131     15902
                                                                                                         16107.93



      GDP per capita (RMB)             Annual disposable               Annual per capita             Annual per capita
                                   income per capita (RMB)          disposable income of           disposable income of
                                                                   urban residents (RMB)           rural residents (RMB)

                                         China       Henan Province          Luoyang City


Data source: 2020 National Economic and Social Development Statistical Bulletin of the People's Republic of China, 2020 National
Economic and Social Development Statistical Bulletin of Henan Province, 2020 National Economic and Social Development Statistical
Bulletin of Luoyang City.



4.3.3 Human Resource
In 2019, the number of working populations in Luoyang City was about 4,217,500, of which the
number of employees in the primary industry was the largest. In recent years, the number of
employees in the secondary industry has been decreasing year by year, and the number of
employees in the tertiary industry has been increasing year by year (see Figure 4 2).
In 2019, the number of working populations in Luoyang City was about 4,217,500, of which the
number of employees in the primary industry was the largest. In recent years, the number of
employees in the secondary industry has been decreasing year by year, and the number of
employees in the tertiary industry has been increasing year by year (see Figure 4 2).




                                                                  22
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




Figure 4-22: Number of employees in Luoyang City in recent years (ten thousand people)

   2019             117.39                      123.74                             180.62
   2018                   153.92                         131.53                             163.17
   2017                   152.61                         140.06                              161.46
   2016                   160.84                            135.43                          150.21
   2015                   157.59                          134.99                         143.23
   2014                   149.51                         139.38                        136.44

          0          50        100        150         200         250        300       350           400      450   500

              Number of employees in Primary industry                  Number of employees in Secondary industry
              Number of employees in Tertiary industry



Data source: 2015 - 2020 Henan Province Statistical Yearbook




                                                                  23
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



5.        ENVIRONMENTAL AND SOCIAL AUDIT
5.1       ENVIRONMENTAL AUDIT
The overall plant and production line of the Yibin Branch has obtained the approval of the
environmental assessment report form issued by the Bureau of Land and Environmental
Protection of the Management Committee of Luoyang City-Rural Integration Demonstration Zone
on February 3, 2016, and completed the completion of environmental protection acceptance and
obtained the certificate in March 2016, and the environmental emergency plan was prepared by
Yibin Branch in March of the same year. According to the requirements of relevant regulations,
Yibin Branch should refer to the "Management Measures for the Record of Emergency
Environmental Incident Preparedness Plans of Enterprises and Institutions" (2015) and conduct
a retrospective assessment of the environmental emergency preparedness plan at least once
every three years. The enterprise has signed a contract with a third-party agency on December
6, 2021, for the preparation of a new emergency response plan for environmental incidents, the
implementation plan is shown in Table 5-1 below.

Table 5-1: Implementation Plan of Emergency Environmental Response Plan
               Contents                    Planned Completion Date                                Notes
     The third party completes the
      preparation of emergency                      March 2022
     environmental incident plans

                                                                              The frequency of drills is based on the text
  Conduct an environmental training                                          of the emergency plan, and the training time
                                                     April 2022
        and emergency drill                                                    is consistent with the next year's training
                                                                                                  plan



The Yibin Branch obtained a water abstraction license in April 2019, valid until March 2022; and
conducted a fixed source discharge registration in May 2020, valid until May 2025. The above
administrative licenses cover all existing production activities of Luoyang Langchao Technology
Yibin Branch.


Water Supply and Sewage Disposal
The water used by the Yibin Branch includes water for production, domestic use and drinking
water for employees. The water used for production, living and canteen at the Yibin Branch is
supplied by the well water in the plant, and the annual water intake is 20,000 cubic meters.
Employees use bottled water for drinking.

The wastewater generated by the Yibin Branch mainly includes wastewater from washing the
outer surface of newly purchased drums, wastewater from the workshop floor and laboratory, and
domestic sewage. Among them, the wastewater from workshop floor and laboratory, and
domestic sewage are treated by "A2 /O + secondary sedimentation tank + filtration" process in the
wastewater treatment station in the factory, and the wastewater from washing the outer surface



                                                                  24
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



of newly purchased drums contains only trace suspended matter and COD, which can be
discharged into Yidong canal after mixing with the effluent from the wastewater treatment station,
and then enter Taohuadian reservoir. The total discharge volume of production wastewater from
the Yibin Branch is 615 cubic meters per year. According to the test results of wastewater from
Henan Moore Testing Co., Ltd. on April 14, 2021 (see Table 5-2), the effluent quality meets the
requirements of the Class I standard in Table 4 of the Comprehensive Wastewater Discharge
Standard (GB8978-1996).
The wastewater generated by the Yibin Branch mainly includes wastewater from washing the
outer surface of newly purchased drums, wastewater from the workshop floor and laboratory, and
domestic sewage. Among them, the wastewater from workshop floor and laboratory, and
domestic sewage are treated by "A2 /O + secondary sedimentation tank + filtration" process in the
wastewater treatment station in the factory, and the wastewater from washing the outer surface
of newly purchased drums contains only trace suspended matter and COD, which can be
discharged into Yidong canal after mixing with the effluent from the wastewater treatment station,
and then enter Taohuadian reservoir. The total discharge volume of production wastewater from
the Yibin Branch is 615 cubic meters per year. According to the test results of wastewater from
Henan Moore Testing Co., Ltd. on April 14, 2021 (see Table 5-2), the effluent quality meets the
requirements of the Class I standard in Table 4 of the Comprehensive Wastewater Discharge
Standard (GB8978-1996).

Table 5-2: Wastewater Testing Results
    Test                                                                           GB8978 Table 4
                     Date                  Item                  Value                                       Compliance
    point                                                                          Class I standard
                                     Flow Rat (m3/h)              0.92                      /                       √

                                            pH                    7.51                    6~9                       √

                                        SS (mg/L)                     8                    70                       √

 Discharge                             COD (mg/L)                  13                     100                       √
                   2021.4.9
   Outlet
                                      NH3-N (mg/L)               0.117                     15                       √

                                    Petroleum (mg/L)             0.06L*                     5                       √

                                                               Colorless,                                           √
                                   Appearance (mg/L)                                        /
                                                             slightly turbid

*: / means not detected.



In addition, according to the EIA and its approval, the discharge index of wastewater pollutants
from the Yibin Branch is 0.034 tons per year of chemical oxygen demand and 0.004 tons per year
of NH3-N. The design capacity of wastewater treatment station is 5 cubic meters per day, and the
actual pollutant discharge of the enterprise can meet this discharge indicator according to the
wastewater testing concentration.



Air Emission



                                                                 25
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



The main sources of organized air emissions from the Yibin Branch are workshop exhaust (dust
and ammonia) and canteen oil smoke. The production waste gas treatment process of the Yibin
Branch uses air collector and water adsorption facilities and is discharged through a 15-meter
exhaust pipe. Canteen fumes are treated by high-efficiency fume removal devices and then
discharged through a 15-meter-high exhaust pipe. According to the test results of organized
emissions from Henan Moore Testing Co., Ltd. on April 14, 2021 (see Table 5-3), the dust
monitoring results meet the requirements of the secondary standard of Table 2 of the
Comprehensive Emission Standard for Air Pollutants (GB16297-1996), and the ammonia meets
the requirements of Table 2 of the Emission Standard for Odor Pollutants (GB14554-1993).

Table 5-3:Exhaust Pollutant Organized Emission Test Results

                                                      Test Result                        Standard

   Test                   Emission        Emission                              Emission
               Date                                                                                             Compliance
   point                  Pollutant      Concentrati          Emission         Concentratio        Emission
                                            on                Rate(kg/h)            n              Rate(kg/h)
                                          (mg/m3)                                (mg/m3)

 Exhaust                 Particulates           2.1           4.09×10-3            120                3.5           √
               2021.
 Emission
                4.9                                                                                   4.9           √
   Port                   Ammonia               0.81          1.54×10-3             /




The sources of unorganized air emissions from the Yibin Branch are mainly dust and ammonia
from the production workshop. According to the test results of unorganized emission of exhaust
gas by Henan Moore Testing Co., Ltd. on April 14, 2021 (see Table 5-4), the unorganized
emission of dust meets the requirements of the unorganized emission limit value of Table 2 of the
Comprehensive Emission Standard for Air Pollutants (GB16297-1996), and the unorganized
emission of ammonia meets the requirements of the Emission Standard for Odor Pollutants
(GB14554-1993) Table 1 in Class II standard requirements.

The sources of unorganized air emissions from the Yibin Branch are mainly dust and ammonia
from the production workshop. According to the test results of unorganized emission of exhaust
gas by Henan Moore Testing Co., Ltd. on April 14, 2021 (see Table 5-4), the unorganized
emission of dust meets the requirements of the unorganized emission limit value of Table 2 of the
Comprehensive Emission Standard for Air Pollutants (GB16297-1996), and the unorganized
emission of ammonia meets the requirements of the Emission Standard for Odor Pollutants
(GB14554-1993) Table 1 in Class II standard requirements.

Table 5-4: Exhaust Pollutant Unorganized Emission Test Results.

                                                  Particulates (mg/m3)                             Ammonia(mg/m3)
  Test point            Date
                                      Results      Standard         Compliance           Results     Standard   Compliance

 Downwind1#                             0.217                              √              0.08                      √
                       2021.4.9
                                                        1.0                                             2.0
 Downwind2#        (09:00-10:00)        0.250                              √              0.10                      √




                                                                    26
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



                                                 Particulates (mg/m3)                          Ammonia(mg/m3)
  Test point            Date
                                     Results      Standard       Compliance          Results     Standard      Compliance

 Downwind3#                           0.200                            √               0.09                          √

 Downwind4#                           0.251                            √               0.11                          √




Noise Emission
The noise source of the Yibin Branch is mainly the equipment noise in the production process.
According to the noise monitoring results of Henan Moore Testing Co., Ltd. on April 14, 2021 (see
Table 5-5). As the south plant boundary is adjacent to Luoyang Group Longmen Glass Co., Ltd.,
the noise monitoring value may be influenced by the noise from other plants, so the noise from
the south plant boundary is not monitored. The north plant boundary is adjacent to S320, and the
noise monitoring results meet the 4a class standard (i.e., 70dB during daytime and 55dB during
nighttime) of the Environmental Noise Emission Standard for Industrial Boundary (GB12348-
2008); the east plant boundary is adjacent to Duleyuan Hotel and Luoyang Qiangrong Glass
Mirror Co., Ltd., and the west plant boundary is adjacent to Luoyang Longmen Glass Group and
Gulongxuan Hotel. The reason may be due to the existence of municipal road renovation on the
west and east side of the front of the Yibin Branch, from day to night, which may have a certain
impact on the boundary noise of the Yibin Branch. According to the monitoring report of 2019
before the renovation of municipal roads, it can be seen that the noise monitoring of the factory
boundary of the Yibin Branch can meet the environmental impact report form approval of the "
Emission Standard for Industrial Enterprises Noise at Boundary" (GB12348-2008) category 1
standard (i.e. 55dB during the day and 45dB at night), the current situation of the enterprise is the
same as the production situation in 2019 , thus judging that the noise in 2021 Monitoring exceeds
the standard for the reason of municipal road renovation, and the Yibin Branch production has
nothing to do with.

Table 5-5: Noise Test Results
                                                 Daytime Leq [dB(A)]                         Nighttime Leq [dB(A)]
     Test point            Date
                                         Noise                                       Noise
                                                     Standard     Compliance                     Standard      Compliance
                                         Value                                       Value
   North Boundary                         57.3           70              √            47.7           55              √

   East Boundary         2021.4.9         54.1           55              √            46.6           45              ×

   West Boundary                          55.8           55              ×             47            45              ×

   North Boundary                         58.2           70              √            47.7           55              √

   East Boundary         2019.3.25        53.3           55              √            44.3           45              √

   West Boundary                          52.7           55              √            44.7           45              √




                                                                 27
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



Chemical Management
The chemicals used in the production of the Yibin Branch include sodium dodecyl sulfate, urea,
foaming agents (F801, Fchj-50, APG0810, KLH-30), fire-fighting auxiliary F1212, fire-fighting
auxiliary YF-138, anionic surfactants, xanthan gum, diethylene glycol butyl ether, ethylene glycol,
etc. In addition, a small amount of gasoline and isopropyl alcohol will be used in the fire-fighting
test. Except for gasoline and isopropyl alcohol, all other chemicals are not hazardous chemicals.
Hazardous chemicals are stored separately from other chemicals in designated chemical
warehouses at the Yibin Branch and are equipped with warning signs and fire-fighting equipment.
There are designated management personnel to conduct regular inspections of the chemical
warehouse. The safety information sheet of chemical substances has been posted and the
secondary containers have been set up, therefore, the chemical storage of the Project meets the
requirements of relevant regulations.



Solid Waste Disposal
The solid waste generated by the Yibin Branch mainly includes waste drums and bags, sediment
from the circulation pool outside the flushing drums, sludge from the sewage treatment station
and domestic waste, shown as follows:

The volume of waste packaging drums and bags is 7.1 tons per year, which is collected and
handed over to the raw material manufacturer for recycling; the empty drums of gasoline and
isopropyl alcohol are reused; the volume of dust and other sediment generated by the circulation
pool outside the flushing drums is 0.8 kg per year, which is collected and transported to the Zhuge
Town Refuse Transfer Station by the Xihan Village Committee; the volume of sludge generated
by the sewage treatment station is 1.5 tons per year, which is collected and transported to the
Zhuge Town Refuse Transfer Station by the Xihan Village Committee. The sludge generated from
the sewage treatment station is 1.5 tons per year, which is collected and transported to the Zhuge
Town Refuse Transfer Station by the Xihan Village Committee; the domestic garbage is collected
and transported to the Zhuge Town Refuse Transfer Station by the Xihan Village Committee.


Ecological Impact
The Yibin Branch is located in the southwest of Yibin District, and the plant resources are mainly
artificially cultivated food crops, cash crops and vegetables, and the animals are mainly artificially
raised domestic animals. According to the survey, there are no cherished plant and animal
species in the evaluation area. Therefore, the potential impact of this pilot project on the local
ecosystem is small.

According to the online information search and interviews with on-site management personnel,
the Yibin Branch has not received any complaints from the surrounding residents during its
operation period and has not received any punishment from local government departments. The
feedback obtained from the interview with the relevant personnel of Zhuge Town Environmental
Protection Office on July 23 was consistent with this.



                                                                 28
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



5.2       OCCUPATIONAL HEALTH AND SAFETY AUDIT
The existing occupational health and safety (OHS) risk identified of the factory is summarized in
Figure 5-1. The occupational health risk identified is described in 5.2 of this chapter, and the
occupational safety risk identified will be described in 5.3 of the next chapter.

Figure 5-1: Diagram of Main OHS Risks in the Process Flow of Yibin Branch




As shown in the figure above, the health hazards of operation period mainly include:

Noise hazard, which is from the operation of pumps, mixing tanks and other equipment. In the
selection of pumps, mixing tanks and other equipment, Yibin Branch selected the model with low
noise, and installed damping pads for relevant equipment. The damping pads are square cement
damping foundation. In addition, the equipment with high noise has been centrally arranged in
the production area to reduce the impact of noise on the non-production area.

Chemical hazards, which are from chemicals used in the production of fire extinguishing agent
and chemicals in case of leakage. At present, all chemicals used in the production process of
Yibin Branch are general chemicals and do not involve hazardous chemicals. All chemicals are
stored in the designated area, and the chemicals are well packaged. When in use, chemicals are
transported to the mixing tank through pumps and closed pipelines to minimize the direct contact
of operators with chemicals. Yibin Branch provides employees with personal protective equipment
(PPE) such as protective masks and gloves.

In view of the above occupational hazards, Yibin Branch has planned to entrust a qualified third-
party agency to carry out occupational hazard status evaluation and occupational disease factor
detection. The Yibin Branch has committed to completing the above work by April 2022,


                                                                 29
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



completing the declaration of occupational hazards according to the report conclusions, and
organizing employees exposed to occupational hazards to have occupational health examination.
According to the current laws and regulations, occupational hazard status evaluation report is
only prepared for checking and there is no need to keep records. At present, the declaration of
occupational hazard items shall be completed through the nationally unified online declaration
system (except Shanghai). In addition, the existing employee training plan of the Yibin Branch
does not include the topic of occupational hazard protection, and no special occupational health
training has been carried out. Yibin Branch will arrange an employee occupational health
examination and organize an employee occupational health knowledge training two months after
the declaration of occupational hazard factors. The specific schedule is shown in Table 5-6.

Table5-6:Implementation Plan of Occupational Health Status Evaluation and
Occupational Hazard Factor Detection

                      Details                            Completed by                             Notes

 Sign occupational health status evaluation and
  occupational disease factor detection service         December 2021
           contract with a third party

  The third party completes the current situation
                                                         February 2022
                 evaluation report

    Complete the declaration of occupational
                                                         February 2022
                hazard factors

    Conduct an employee occupational health
                                                           April 2022
                 examination

    Conduct an employee occupational health                                    The training time shall be consistent with
                                                           April 2022
                   training                                                           the training plan next year



5.3       SAFETY AUDIT
The production of the Yibin Branch does not involve highly toxic chemicals, highly toxic
substances, precursor, and explosive chemicals, nor dangerous chemical reactions. There is no
major hazard source of dangerous chemicals, and the company obtained the safety production
standardization Certificate in May 2021. The main hazardous and harmful factors during operation
include:

Mechanical injury: There are many rotating facilities (pumps, agitators, etc.) in the production area.
If the safety protection facilities of the above mechanical transmission parts are not well prepared,
there is a risk of mechanical injury such as winding, extrusion and cutting at the rotating parts
such as couplings. In addition, the above mechanical equipment may throw out parts that are not
firmly fixed during operation (workpiece), hitting the human body, thus posing a threat to personal
safety.

Electric shock: The equipment in the production area is electrically driven, which may cause
electric shock accidents due to electric leakage of equipment, non-standard operation of staff and




                                                                 30
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



other reasons. When a human body is shocked, accidents due to nerve paralysis are likely to
occur such as falling.

Falling from height: There is a working platform in the production area, which is equipped with
protective fence and escalator. If the protective fence and escalator are loose and broken, workers
may fall from height during platform operation or patrol inspection.

Fire accident: A small amount of gasoline and isopropanol will be used as fuel during fire
extinguishing test. If the container storing the chemical is damaged and cause leakage, a fire
accident may occur when the fuel meets fire source or heat source.

According to management personnel, during the operation of the Yibin Branch, the production
specialist carries out safety patrol every day, and the production department carries out self-
assessment of safety production every month. Since the operation of the Yibin Branch, no
industrial injury or accident has occurred. In December 2020, the Yibin Branch entrusted a
qualified third-party company to carry out the lightning protection device testing. The grounding
resistance of all lightning protection devices in the plant meets the requirements of laws and
regulations.

According to Article 32 of China Work Safety Law, the Yibin Branch does not belong to the mining,
metal smelting construction project, also the site does not involve in the production, storage,
loading and unloading of dangerous goods, so there is no need to carry out safety pre-evaluation,
acceptance evaluation and status evaluation.

The safety management personnel of the Yibin Branch have obtained the training certificate of
safety production and management as required. According to the on-site audit and management
consultations, the Yibin Branch uses a special equipment (forklift). However, the use registration
certificate and regular inspection report of the forklift are not provided for review, and the forklift
operator has not provided the special equipment operation certificate. At present, the company is
reapplying for the use registration certificate of the forklift, the regular inspection report of the
forklift and the special equipment operation certificate for the forklift operator. It is expected that
all licenses required, and forklift inspection will be completed within 4 months.

The Yibin Branch prepared the emergency plan for safety accidents in July 2016. According to
the consultation with Luoyang Emergency Management Bureau of Henan Province (Tel: 0379-
63917639), the Yibin Branch needs to evaluate the emergency plan every three years according
to the requirements of The Measures for Emergency Management Plan for Safety Accidents
(2019). At present, the enterprise has started the review of the emergency plan for production
safety, and the specific implementation plan is shown in Table 5-7.

Table5-7:Emergency Implementation Plan of Production Safety

                     Details                         Completion time                              Notes

   Sign a service contract with a third-party
   regarding production safety emergency              December 2021
                     plan

  The third party completes the emergency              February 2022                    Review every three years




                                                                 31
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



                     Details                            Completion time                            Notes
                       plan

        Complete the registration with the
                                                         February 2022
           government department

                                                                                The drilling frequency and requirements
  Conduct a safety training and emergency
                                                          March 2022            shall be consistent with the emergency
                     drill
                                                                                                   plan



The Yibin Branch has planned to apply the reissuance of the fire completion acceptance, and the
enterprise promises to obtain the acceptance certificate in September 2022. The specific
implementation schedule is shown in Table 5-8
Table5-8:Luoyang Langchao Fire Technology Corrective Plan for Fire Completion
Acceptance

                                                         Completion       Planned Completion
  No.                  Work Required                                                                           Notes
                                                          Standard               Time

              Apply for reissuance of planning            Receipt of
   1                                                                           April 2022
               permit and construction permit              permits

           Apply for reissuance of the approval of       Receipt of
   2                                                                           May 2022
                 the commencement report                 documents

               Apply for reissuance of Review
                                                         Receipt of
   3         opinions on fire protection design of                             May 2022
                                                         documents
                     construction project

                                                                                                       Have the drawings
                                                                                                       stamp, designer's
             Apply for reissuance of completion           Receipt of                                    signature stamp,
   4                                                                           May 2022
                    acceptance drawings                   drawings                                       drawing review
                                                                                                      qualification seal and
                                                                                                       completion stamp

             Apply for reissuance of the project          Receipt of
   5                                                                           June 2022
               completion acceptance report                report

                                                                                                     Business license and
            Sign a contract with a third-party fire       Contract
   6                                                                           July 2022             qualification certificate
                  facility testing institution             signed
                                                                                                      of testing institution.

            Qualification certificate of firefighting     Receipt of
   7                                                                           July 2022
                     facilities Inspection                certificate

             Supplement the quality certificate of        Receipt of
   8                                                                           July 2022
                      fire products                       certificate

                                                           Accepted
              Fill in the application form for fire
                                                             and                                     Receiving the notice of
   9        protection acceptance of construction                             August 2022
                                                          feedbacks                                     site acceptance
                             project
                                                            given

                                                         Completion      August 2022 (Subject to           Qualification or
  10                   Site acceptance                       of            government’s time)               rectification
                                                         acceptance                                        acceptance or




                                                                  32
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



                                                       Completion        Planned Completion
  No.                 Work Required                                                                           Notes
                                                        Standard                Time

                                                                           September 2022
               Liaise with the issuance of fire         Receipt of
  11                                                                         (Subject to
               completion acceptance report              report
                                                                          government’s time)



The on-site emergency facilities of Yibin Branch include fire extinguishers, fire hydrants,
emergency lights, emergency indication signs and emergency evacuation diagrams. During the
on-site audit, Yibin Branch provides 2021 annual training plan regarding management, laws, and
regulations, ISO9001 system and safety production. According to the consultations with
management personnel, Yibin Branch has not carried out drills for firefighting, flood control and
other special emergency plan. As mentioned above, the enterprise plans to carry out relevant
drills before March 2022 according to the drill plan of environmental and safety emergencies.


5.4       SOCIAL AUDIT
Project Land Use
The Yibin Branch covers an area of 13,806 square meters (about 20.7 mu). According to the site
management, the project land is the collective construction land rented from Xihan village, Zhuge
town. On April 28, 2010, Langchao Fire Technology obtained the collective land use certificate
(See Annex 2).

According to the consultation with Mr. Li of Zhuge Town Land Office, before Langchao Fire
Technology built facilities on the leased land, Xihan village committee had gone through the
procedures for the conversion of collective agricultural land to construction land. Langchao Fire
Technology signed a construction land lease agreement with Xihan village committee and
obtained a collective land use certificate, which met the requirements of local land planning and
relevant laws and regulations.

In October 2009, Langchao Fire Technology and Xihan village committee signed a collective
construction land-use right lease agreement (hereinafter referred to as the "agreement", see
Annex 3 for details). The agreement stipulates that the lease term of the land-use right is from
October 30, 2009 to October 30, 2029, and the rent is paid annually according to the grain market
price, that is, the annual output of the land is 1,000 kg/mu/year of wheat and corn respectively,
and the grain price is subject to the statistics of the market price of wheat and corn published by
the local price bureau at the end of August each year. The rent shall be paid in advance before
use annually. The rent of the current year shall be paid from the date of signing the contract, and
the rent of the next year shall be paid before October 30 of each year.

According to Mr. Song, member of Xihan village Party committee, before 2009, all the land leased
by Langchao Fire Technology was contracted by households, involving three villagers' groups,
namely the group 1, group 2, and group 10. The annual land rent was paid to the land contractors,
and the village group did not retain it. In October 2020, the land rent for the next year (i.e., from



                                                                 33
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



November 1, 2020, to October 30, 2021) has been distributed to the villagers. Mr. Song said that
due to the lack of documentation caused by several relocations of the village committee office,
the register of lease holders, rent distribution records and procedures for transferring agricultural
land to construction land have not been obtained during this survey.

According to the random consultations with the lease holders, the land rent in 2020 and before
having been paid to the households, and the land rent in 2020 is about 2,200 yuan/mu. The
villagers consulted said that they did not earn much from farming (the net profit of farming was
about 500 yuan/mu). The villagers were willing to lease the land to obtain the land rent. The
villagers thought that the rent exceeded the income brought by land loss, and the villagers were
satisfied.


Workforce and Working Conditions
In accordance with the national and provincial regulations on labor, Langchao Fire Technology
has developed procedures for labor management, including recruitment management, personnel
management, promotion management, attendance systems, performance management and
remuneration system.

Based on management consultation and document review, a total of 67 employees were
employed for the Project, including 52 from Langchao Fire Technology (responsible for
management and operations, and not responsible for production), 5 from the Yibin branch, and
10 temporary workers, as shown below.

Langchao Fire Technology: 7 staff in the General Manager Office, 13 staff in the Administration
Department, 3 staff in the Supply Department, 2 staff in the Technology Department, 6 staff in the
Development Department, 1 staff in the Production Department, 14 staff in the Sales Department
and 6 staff in the Finance Department. There are 30 male employees and 22 female employees
in Langchao Fire Technology. The 22 female employees are all engaged in light manual jobs,
such as sales, housekeeping, accounting, technical quality inspectors, cleaning, clerks, and office
management. All 52 workers have signed labor contracts. Langchao Fire Technology has 1 ethnic
minority employee, Man ethnic, who has been working with the company for six years and has no
special habit in diet. The youngest employee is 22 years old and works as a support worker in the
Engineering Management Centre.

Yibin branch: 1 production manager, 1 office staff, 1 sale and 2 production workers. Two of the
five employees at the Yibin branch are female, working in sales and in office. The youngest of the
employees is 32 years old and works in sales. 5 workers are all Han ethnic, and all have signed
labor contracts.

10 temporary workers: 7 are males and 3 are females. The youngest is 34 years old and as a
production worker. All employees are Han ethnic.

According to the management consultation and document review, there are 13 production
workers (including 3 formal employees and 10 temporary workers) in the Project. The working
hours of production workers are from 8:00 to 12:00 and 14:00 to 18:00. During the time of audit,



                                                                 34
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



randomly selected labor contracts, personal files, attendance sheets, salary records and social
insurance were provided for review. As confirmed during the audit, the Project has signed labor
contracts with 10 temporary workers, and the Project had purchased accident insurance for these
10 workers. According to the production workers' attendance sheet and salary records from April
to June 2021, it was found that there was overtime and continuous work for the production workers.
The production workers were paid on a daily salary at CNY 100 or 110 per day.

During this audit, no juvenile worker, child worker, gender discrimination, harassment and forced
labor were identified through document review and onsite consultations. However, the Project did
not develop written social responsibility management procedures in place for anti-discrimination,
anti-harassment, prohibition of child labor, and prohibition of forced labor. According to
management consultations, male and female employees are treated equally in terms of wages,
training, promotion, and career development. In addition, employees of both Langchao Fire
Technology and Yibin Branch are entitled to benefits under the Labor Law. The specific benefits
enjoyed by female employees are as follows.

•    Females are entitled to maternity leave in accordance with the law. Physical work
     arrangements will be avoided during pregnancy and job transfers will be made if necessary;
•    During breastfeeding period, female is entitled to one hour of breastfeeding leave in
     accordance with the law;
•    The Project and the dormitory building have separate toilets for females;
•    On the Women's Day (8th March), Langchao Fire Technology and Yibin Branch gives gifts to
     female workers (mainly daily necessities, tissues, shampoo, etc.).


The Yinbin Branch has a self-operated canteen, located on the 1st floor of the office building,
which provides lunch for staff at a price of CNY 2. A valid canteen operator's health certificate and
catering service license were provided for review. The staff of the Yibin Branch are mainly local
workers. The Yibin Branch has built its own three-story dormitory building for employees to take
their lunch break, with 6 rooms on each floor and 4-8 people living in each dormitory. Separate
dormitories and toilets are provided for male and female workers respectively. The dormitory
security is managed by the Project. According to on-site observations, the dormitories are clean
and well equipped with fire-fighting equipment (e.g., evacuation signs, evacuation lights and fire
extinguishers).


Ethnic Minorities
The Project is in Yibin District, Luoyang City, Henan Province. According to the on-site and village
committee consultations, Xihan Village is not an area inhabited by ethnic minorities and the
project does not involve ethnic minorities, therefore the pilot project does not involve any impact
on ethnic minorities.


Grievance Redressing Mechanism



                                                                 35
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



Langchao Fire Technology has established an internal grievance redressing mechanism (GRM).
Employees are free to submit their grievances with the Administration Department. If the
Administration Department cannot deal with it, the grievance will be reported to the General
Manager Office, which will make the final decision. The Administration Department is responsible
for keeping a record of grievances from each employee. Upon receiving a grievance, a reply as
to whether it is accepted or not shall be made within three working days. Grievance without
objective factual basis and based on subjective assumptions will not be accepted. Within 5
working days after receiving the grievance, the Administration Department must review the
grievance and communicate with the appellant. If it is not possible to resolve, it will be reported to
the General Manager Office for further processing. Employees of the Administration Department
who have grievances can directly report to the General Manager Office. Based on management
consultations, employees currently report grievance to and receive verbal feedback from their
leaders. No records of grievances are kept.

According to management consultations, the Yibin Branch uses internal GRM of Langchao Fire
Technology and has not established an internal GRM.

Langchao Fire Technology has not established a (external) community GRM and has not
disclosed a community GRM to the surrounding communities. Based on management
consultations. No grievance has been received by the surrounding communities for Langchao
Fire Technology. A community GRM has been established during this assignment with the
support from Stantec. (See Chapter 9.4 for details)

5.5       MANAGEMENT SYSTEM AND MECHANISM
Based on the company and project assessment, the E&S issues arising from Yibin Branch are
under the jurisdiction of Luoyang Zhuge Town Environmental Protection Office, Zhuge Town
Emergency Management Office, and Zhuge Town Health Center. The E&S management
procedures are developed and supervised by the Production Department in the Corporate, while
the Yibin Branch followed the E&S management procedures in the Corporate and did not have
separate E&S management procedures at project level. The Production Department of Langchao
Fire Technology is responsible for the overall safety related work of the Yibin Branch. The
Administration Department of Langchao Fire Technology is responsible for the overall
environmental and health related work of the Yibin Branch. The organizational structure of the
Langchao Fire Technology is shown in Figure 5-1.




                                                                 36
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



Figure 5-1 The Organizational Structure of the Langchao Fire Technology




Based on document review and management consultations, Langchao Fire Technology 's existing
E&S management procedures include:

•    Internal audit procedures
•    Management review control procedures
•    Environmental factor identification and evaluation control procedures
•    Occupational health and safety management procedures
•    Hazard identification and evaluation control procedures
•    Pollutant control procedures
•    Energy resource management procedures
•    Procedures for the identification of regulatory and requirements
•    Information exchange and communication control procedures
•    Management of change procedures
•    Contractor management procedures
•    Environmental/occupational health/safety incident investigation and non-compliance control
     procedure
•    Personnel management procedures
•    Payroll and attendance management procedures
•    Training management system


Langchao Fire Technology has conducted EHS inspections as follows:

•    The Production Department conducts weekly safety meetings and monthly internal EHS
     reviews, and develops reviewing reports and non-compliance corrective plan, if any, in
     accordance with non-compliance control procedures.
•    The Production Department conducts regular training for production staff on environment,
     occupational health, and safety in accordance with the annual training plan.
•    The Production Department updates internal management procedures annually in
     accordance with changes in national EHS-related laws and regulations.


                                                                 37
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



•    Langchao Fire Technology conducts regular audits of the ISO9001, ISO14001 and ISO18001
     systems.


Langchao Fire Technology follows the emergency system and organization in the emergency plan
for work safety and environmental emergencies prepared in 2016 for the current emergency
management. The emergency management organization is shown in Figure 5-2:

Figure 5-2: Emergency Response Management Organization




The emergency response steps of Langchao Fire Technology are summarized as follows:

Response Level
Langchao Fire Technology divides the emergency response into level I and level II according to
the nature, severity, controllability and impact range of possible work safety accidents and
disasters. According to the specific situation of the accident, the emergency rescue headquarters
shall determine and start the corresponding level of emergency rescue plan.

Level II emergency response (minor accident): For accidents that can be handled by the company,
the company should start the emergency plan, eliminate potential safety hazards, control the site
and report to the Emergency Rescue Office of Yibin District.

Level I emergency response (general accident): For accidents that cannot be handled by the
company or ma cause casualties and need the assistance of external rescue forces, the company
will report to the Yibin District Emergency Rescue Office. Upon approval, the relevant
departments of the Yibin District will start the emergency plan at the district level.


Response Procedure
1)   In case of fire, mechanical injury, electric shock and other emergencies, the personnel on
     duty shall immediately handle the situation on site and call the police, and explain the accident
     situation, current emergency treatment situation and assistance to be provided to the principal
     responsible person.


                                                                 38
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



2)   The principal responsible person shall determine the response level according to the severity
     of the accident, immediately report the accident to the emergency rescue headquarters, and
     dial 119 to request external assistance.
3)   After reporting to the police, the personnel on duty shall ask relevant personnel to meet the
     119 vehicles at the intersection and guiding them to the accident scene.
4)   After receiving the alarm call, the emergency headquarters shall immediately notify personnel
     of its own department and the accident rescue team to arrive at the site and practise the
     corresponding emergency plan.


Emergency Response Measures
In case of an accident, the emergency headquarters shall command all personnel for rescue who
can participate and use various emergency equipment in the plant. During rescue, attention
should be paid to analyzing the on-site accident situation and protecting the personal safety of
rescuers. After rescue, the accident site shall be cleaned up and the cause of the accident shall
be investigated.

The company has developed corresponding on-site disposal plans for several types of accidents
that may occur and cause great impact (fire and explosion, electric shock, falling, mechanical
injury and lifting injury). The above types of accidents shall be redressed according to the on-site
disposal plan.


Response Closure
When the accident is under control, the environmental pollution and hazards are eliminated, and
the evidence is collected, the principal commander shall issue the order to relieve the
emergency rescue, and the safety department shall notify the accident site to remove the alarm
and dismiss the personnel on guard. When the evacuation of surrounding communities and
organizations is involved, the principal commander shall notify the managers of surrounding
organizations or the community leaders to shut the alarm.

After the emergency, the accident shall be summarized, the notes on duty and other data shall
be summarized and filed. Then the reporting materials shall be drafted and reported to relevant
local government departments in accordance with relevant regulations.




                                                                 39
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



5.6       FINDINGS AND CORRECTIVE PLAN
During the assessment, the main E&S issues of Langchao Fire Technology and the Yibin Branch are shown in Table 5-9. Langchao
Fire Technology has developed a commitment plan (See Annex 5) for this purpose and promised to carry out follow-up corrective work
according to the following plan.
Table 5-9:Findings

                                                                                                 Responsible        Suggested    Completion
  No         Focus                   Issues                          Suggestions                                                                   Compliance status
                                                                                                    party             time        indicator

                                                                                                                                                  The Yibin Branch has
                                                                                                                                                  provided    the    fire
                           The Yibin Branch did not       Langchao Fire Technology should
                                                                                                                                                  completion
                           subject to application         contact the local Housing and
                                                                                                                                Fire protection   acceptance work plan
                           processes      of     fire     Urban-Rural Construction Bureau          Langchao
                                                                                                                                completion        and committed to
   1      EHS permit       protection     completion      to   prepare     fire  protection          Fire           9 Months
                                                                                                                                acceptance        implement             it
                           acceptance in accordance       completion            acceptance        Technology
                                                                                                                                documents         according to the plan.
                           with the requirements of       documents in accordance with
                                                                                                                                                  It is expected to be
                           laws and regulations.          relevant requirements.
                                                                                                                                                  completed by the end
                                                                                                                                                  of September 2022.

                                                                                                                                                  The Yibin Branch has
                                                                                                                                                  commissioned a third
                                                                                                                                                  party to prepare the
                                                          Langchao Fire Technology should                                                         environmental
                                                          contact    local     EEB       and                                                      emergency plan. The
                                                                                                                                safety
                           The Yibin Branch did           Emergency Response Bureau to                                                            retrospective
                                                                                                                                emergency
                           review the production          prepare safety emergency plan                                                           evaluation of the work
          Emergency                                                                                Langchao                     plan and the
                           safety emergency plan          and      the        environmental                                                       safety     emergency
   2       plan and                                                                                  Fire           3 Months    environmental
                           and the environmental          emergency plans every three                                                             plan is also under
             drills                                                                               Technology                    emergency
                           emergency plans every          years and register them in                                                              planning.       It   is
                                                                                                                                plans and drill
                           three years                    government           departments.                                                       expected that both
                                                                                                                                records
                                                          Conduct relevant drills every year                                                      plans      will     be
                                                          and keep drill records                                                                  completed           by
                                                                                                                                                  February 2022. A drill
                                                                                                                                                  will be followed the
                                                                                                                                                  plans.




                                                                                         40
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



                                                                                                    Responsible     Suggested    Completion
  No         Focus                   Issues                           Suggestions                                                                   Compliance status
                                                                                                       party          time        indicator

                                                                                                                                                   The Yibin Branch has
                                                                                                                                                   planned                 to
                                                                                                                                                   commission a third
                                                           Langchao Fire Technology shall
                           The Yibin Branch has not                                                                             Assessment of      party to carry out
                                                           entrust a qualified third party to
                           carried out identification of                                                                        occupational       occupational health
                                                           carry     out   identification  of
                           occupational           health                                                                        hazard status,     status evaluation and
                                                           occupational health hazards and
                           hazards and detection of                                                                             detection    of    occupational hazard
                                                           detection of occupational disease
                           occupational         disease                                              Langchao                   occupational       factor        detection
          Occupational                                     hazards. According to the
   3                       hazards, and has not                                                        Fire         4 Months    hazard factors     services, which is
            Health                                         identified occupational hazard
                           provided       occupational                                              Technology                  and                expected      to       be
                                                           factors, regular occupational
                           health examination for                                                                               occupational       completed by March
                                                           health examination shall be
                           employees exposed to                                                                                 health             2022.                The
                                                           conducted      for       employees
                           occupational         disease                                                                         examination of     occupational hazard
                                                           exposed to occupational hazard
                           hazards                                                                                              employees.         declaration           and
                                                           factors.
                                                                                                                                                   occupational health
                                                                                                                                                   examination will be
                                                                                                                                                   carried out after it.

                           The Yibin branch uses one
                           special           equipment     Langchao Fire Technology should
                           (forklift). However, the        contact     the      local    Quality                                Forklift           The enterprise is re-
                           registration certificate and    Supervision Bureau and apply for                                     registration       applying the forklift
                           periodic inspection report      a registration certificate for the                                   certificate,       certificate,    special
                           of the forklift were not        use of forklifts. And entrust a           Langchao                   monitoring         equipment operation
            Special
   4                       provided for review, and        qualified third-party to conduct            Fire          4months    report,            certificate and regular
           Operation
                           the forklift operator did not   regular forklift monitoring. In          Technology                  operation          inspection of forklift. It
                           provide        a      special   addition,       Langchao          Fire                               certificates for   is expected to be
                           equipment         operator's    Technology should apply for                                          special            completed within four
                           certificate.                    special equipment operation                                          equipment          months.
                                                           certificates for forklift operators.

                           The training plan for
                           Langchao Fire Technology        Langchao Fire Technology should                                                         Relevant    contents
                                                                                                     Langchao
                           did       not     include       strengthen the environmental and                                     Relevant           have been included in
   5        Training                                                                                   Fire          1 month
                           environmental         and       occupational    health   related                                     procedures and     the 2022 training
                                                                                                    Technology
                           occupational       health       training.                                                            training records   schedule
                           related topics




                                                                                           41
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



                                                                                                 Responsible        Suggested    Completion
  No         Focus                   Issues                          Suggestions                                                                   Compliance status
                                                                                                    party             time        indicator

                                                                                                                                                  A list of households
                                                                                                                                                  affected by land lease
                                                                                                                                                  and a distribution
                                                                                                                                                  record of land rent in
                           According        to     the
                                                                                                                                                  2021      have     been
                           consultations with the
                                                                                                                                                  provided. Due to the
                           village         committee,
                                                                                                                                List of land      lack of data storage of
                           Langchao Fire Technology
                                                                                                                                tenants,          the village committee,
                           rents the land of Group 1,     Langchao Fire Technology should
                                                                                                                                records of rent   the procedures for
                           Group 2, and Group 10 of       contact Xihan Village Committee
                                                                                                                                payments and      agricultural        land
                           Xihan village, and the rent    to obtain list of land tenants,          Langchao
                                                                                                                                documents for     conversion cannot be
   6      Land Lease       is paid every year.            records of rent payments and               Fire            1 month
                                                                                                                                the conversion    provided. Based on
                           However, no list of land       documents for the conversion of         Technology
                                                                                                                                of agricultural   the review of the
                           tenants, records of rent       agricultural land to construction
                                                                                                                                land         to   provided data and the
                           payments and procedures        land and keep relevant records
                                                                                                                                construction      confirmation of the
                           for the conversion of
                                                                                                                                land              land leased farmers
                           agricultural     land     to
                                                                                                                                                  that their actual rights
                           construction land were
                                                                                                                                                  and interests are
                           available for review.
                                                                                                                                                  protected. Therefore,
                                                                                                                                                  this case is deemed
                                                                                                                                                  compliant            and
                                                                                                                                                  acceptable.

                           Langchao Fire Technology
                           has      established   an
                           internal GRM; However,         Langchao Fire Technology should
                                                                                                                                Written
                           no written record of the       further improve the employee
                                                                                                                                documents of      The Yibin Branch has
                           opinions of employees,         GRM and keep records for the             Langchao
          Grievance                                                                                                             GRM       and     established        a
   7                       feedback and handling          results of grievance handling. In          Fire            1 Month
          Mechanism                                                                                                             written           community GRM and
                           results are available;         addition, a community GRM               Technology
                                                                                                                                grievance         become compliant.
                                                          should be established and
                           Langchao Fire Technology                                                                             records
                                                          recorded.
                           has not established a
                           community GRM.




                                                                                         42
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




6.            PILOT PROJECT ACTIVITIES
Langchao Fire Technology submitted The Implementation Plan and Work Plan of Demonstration
Activities of Foam Fire Extinguishing Agent Production Enterprises in Fire Industry to the Centre
for Foreign Cooperation and Exchanges of the Ministry of Ecology and Environment (FECO) in
June 2021. According to the declaration, the objectives of the pilot project are:
•      Develop new foam fire extinguishing agent formulation contains no PFOS;
•      Trial produce foam fire extinguishing agent contains no PFOS;
•      Test and evaluate the reliability of the trial product's performance;
•      Achieve that the company's products of foam extinguishing agents containing PFOS are
       completely discontinued.
According to the declaration, the pilot project includes the following tasks:

•      Task 1: New formulation design;
•      Task 2: Production equipment replacement and trial production;
•      Task 3: Quality control of trial production;
•      Task 4: Entrust a third party to conduct test and evaluation;
•      Task 5: Carry out physical fire experiment;
•      Task 6: Stop producing products containing PFOS;
•      Task 7: New product publicity and promotion;
•      Task 8: Summary of demonstration activities.
The pilot project is planned to be completed within one year. The preliminary schedule is shown
in Table 6-1:
Table 6-1:Diagram of Project Schedule

    Activities   Jan.    Feb.     Mar.      Apr.     May      Jun.      Jul.    Aug.     Sept.     Oct.      Nov.   Dec.

     Task 1

     Task 2

     Task 3

     Task 4

     Task 5

     Task 6

     Task 7

     Task 8




                                                                 43
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



The proposed technical route for the pilot project is shown as Figure 6-1:
Figure 6-1:Diagram of the project technical route




According to the consultations with management personnel, the pilot project is mainly to replace
some product formulas and optimize and replace the original devices and equipment according
to the selected alternative formula. The project activities involved in the pilot project mainly include:
Laboratory development of alternative product formulation

•    The following 5 types of representative foam fire extinguishing agent products will be
     developed to replace the original PFOS foam extinguishing agent products (water-soluble
     film forming foam extinguishing agent and water film foam extinguishing agent). The product
     model is 3% (AFFF, -20 ℃) - seawater resistant, 6% (AFFF, -10 ℃) - seawater resistant, 6%
     (AFFF, -20 ℃) - seawater resistant, 3% (AFFF/AR, -30 ℃) - seawater resistant, And 6%
     (AFFF / AR, - 20 ℃) - seawater resistant. Stop producing the two products containing PFOS
     and retain the other four existing products.

•    Select surfactants that do not contain PFOS are selected to mix with other surfactants and
     auxiliaries to prepare PFOS free foam stock products. At present, the raw materials to be


                                                                 44
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



     selected include ethylene glycol, anionic surfactant, diethylene glycol butyl ether, foaming
     agent 1, foaming agent 2, foaming agent 3 and antifreeze.
Optimization and renovation of equipment and facilities

•    The PFOS residues from the inner walls of original foam extinguishing agent production
     equipment (including reactor, stirred tank, pipe and valve, etc.) are not easy to be cleaned.
     Therefore, if not replaced, the test effects for PFOS-free products will be directly affected.

•    Considering that products with and without PFOS share the same production line in the
     current production process of the Yibin Branch, the pilot project will update and replace the
     production equipment containing PFOS residues in 10 production lines, and add new
     production equipment (See Table 6-2), adjust the production process, optimize the process
     equipment, and adopt special water supply device and intelligent control system to ensure
     the preciseness and accuracy of trial production results. The company will also add purified
     water treatment equipment, online production monitoring equipment, intelligent feeding
     device and other equipment, and upgrade the old production equipment such as production
     mixing tank, reactor, pipeline and electric control valve so that the new production equipment
     will not be polluted by the original production equipment, nor the production process be
     affected by the production of the original foam extinguishing agent nor the new production
     equipment contains PFOS substance. The existing ten production lines of the Yibin Branch
     will be adjusted according to the above methods.
Table 6-2:List of production facility to be updated


         No              Name of Facility             Type of update               Quantity            Specifications


                         Mixing tank device             Replacement                                     3 m3, 2 m3, 1
          1                                                                           12
                                                                                                            m3

          2                  Dump tank                  Replacement                    6                     5 m3

          3             Water storage tank              Replacement                    2                     8 m3

          4                 Dump pump                   Replacement                   10                       /

          5                Solenoid valve               Replacement                   40                       /

          6                Electric valve               Replacement                   40                       /

          7                     Pipes                   Replacement                 3000m                      /

          8               Master computer               Replacement                    1                       /

          9               Metering device               Replacement                    5                 Weighbridge

                      Purified water treatment          Replacement                                            /
          10                                                                           1
                             equipment

          11         Automatic feeding device           Newly added                    6                       /

                      PFOS / PFOA detection             Newly added                                            /
          12                                                                           1
                           equipment




                                                                 45
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



Product test and evaluation

•   After the preliminary tests of the five new trial products are qualified and the technical
    performance meets the standard requirements, the nationally qualified testing institution, will
    carry out the testing and evaluation on each model of the trial products once, ensuring to meet
    relevant standards.
•   The reliability of alternative PFOS-free technology is evaluated against the performance of
    original foam extinguishing agent containing PFOS, including solidification point, accelerated
    aging, precipitate, specific fluidity, pH value, surface tension, interfacial tension, corrosion,
    foaming times, liquid drainage time and fire extinguishing performance.
•   The evaluation tests of safety and environmental performance such as toxicity test,
    biodegradation experiment, etc. are carried out for the PFOS-free foam fire extinguishing
    agent which has been verified of its fire extinguishing reliability.


Replacement of PFOS-Containing Foam Fire Extinguishing Products

•   The five types of PFOS-free foam fire extinguishing agents will be submitted to China
    Certification Center for Fire Products of the Ministry of Emergency Management (CCCF), a
    national qualified third-party testing institution, for testing, including the fire-fighting
    experiments under physical fire scenarios, to verify the reliability of the new products. Then
    obtain the testing report and voluntary certificate of the new products from the CCCF. It shall
    be noted that the CCCF will be responsible for the fire-fighting experiments under physical fire
    scenarios, the Yibin Branch will not be involved in the experiments except providing PFOS-
    free foam fire extinguishing products and obtaining the report after the experiments.
•   After passing the testing, the PFOS-free foam fire extinguishing agents will be put into mass
    production to replace the PFOS-containing products completely.


Advertising and Promotion

•   The PFOS-free foam fire extinguishing products will be promoted through the company’s
    website, social media (e.g., WeChat), and displayed prominently on the homepage of the
    website. Knowledge about PFOS and Stockholm Convention will also be introduced at the
    website’s Industry News.
•   Fire Company, a professional app developed by Langchao Fire Technology, connects the
    upstream and downstream of the industry, which can be used for promotions.
•   Promotions can also be given at the exhibitions, relevant fire-fighting meetings organized by
    associations and government if Langchao Fire Technology attends.




                                                                 46
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



7.        MANAGEMENT ORGANIZATION SETTING
 Many participants are involved in the implementation of this pilot project. To achieve the smooth
 progress of this pilot project and ensure that the project complies with the WB’s environmental
 and social standards and China’s regulatory and policy requirements, the pilot project plans to
 set up a project management mechanism consisting of the following parties.

 FECO: It is the overall project management institute of this pilot project and is generally
 responsible for the implementation of the project to meet the requirements of WB’s standards
 and Chinese regulations and policies.

 Local functional departments (Zhuge Town People's Government, Zhuge Town Environmental
 Protection Office, Zhuge Town Land Office, Zhuge Town Emergency Management Office, Zhuge
 Town Health Center, etc.): Responsible for the daily management and supervision of WFS.

 The Yibin Branch: It is the main body of implementation of this pilot project, responsible for
 formulating and organizing the implementation of PFOS reduction and elimination project plans,
 performing duties according to the ESMP. It also takes the main responsibility for emergency
 management, waste disposal, monitoring and reporting, etc. The Yibin Branch entrusts the
 construction vendors for specific implementation of relevant construction content, entrusts
 Xinxiang Dong Fang Tong Ye Co. Ltd. (i.e., raw material vendor) for recycling and reusing, and
 entrusts independent monitoring vendors to monitor and issue reports. The Yibin Branch will set
 up a special project team, with the general manager responsible for project management and
 external liaison. The project team has four teams for formula development, manufacturing,
 testing and evaluation, and project promotion, responsible for specific implementation.

 Equipment suppliers, construction contractors, testing vendors, waste disposal vendors: They
 are responsible for providing production equipment, testing equipment and materials according
 to the project implementation plan of the Yibin Branch, and carrying out corresponding equipment
 removal, cleaning, installation, testing, waste disposal, etc.

 Consulting agencies (Henan University of Science and Technology, Tianjin Fire Research
 Institute, Stantec Co., Ltd., etc.): They are responsible for the whole process of project
 implementation, providing technical, environmental, and social management consulting services
 for the Yibin Branch.

 The system structure of the project management agencies of this pilot project is shown in Figure
 7-1.




                                                                 47
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



Figure 7-1:Schematic Diagram of the System Structure of the Project Management
             Agencies




                                                                 48
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



8.        PILOT PROJECT E&S IMPACT ASSESSMENT
In accordance with the project activities described in Section 7, this section assesses the
environmental and social impacts involved in the pilot project activities.

8.1       ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT
This pilot project activities which may involve environmental and social impacts are: (1) PFOS
alternative formula research and development, (2) product performance test (3) the removal of
production equipment and production equipment replacement, (4) pilot project trial production.
This pilot project production line will continue using the workshop of existing foam extinguishing
agent project, which does not involve new plant or new land, and does not increase or decrease
staff strength. The potential environment, occupational health, and safety (OHS) risks involved in
different stages of the pilot project are described in the following paragraphs.

PFOS alternative products formula research and development and product performance
test stage
The alternative formula identified in this pilot project include Ethylene glycol, diethylene glycol
butyl ether, foaming agent 1 (environmentally friendly foaming agent), foaming agent 2 (anionic
surfactant), foaming agent F801N, antifreeze F301N. The safety information data for these six
chemicals are shown in Table 8-1, and the six chemicals are general chemicals, of which ethylene
glycol, diethylene glycol butyl ether, foaming agent 2 (anionic surfactant), foaming agent F801N
and antifreeze F301N are consistent with the raw materials currently used by the Yibin Branch.
However, the drug ratio in the alternative product formulation will be different to some extent.
Foaming agent 1 (environmentally friendly foaming agent) is a new chemical, which is used to
replace the currently used fire-extinguishing assistant F1212 containing PFOS.
Table 8-1:The Alternative Formula Identified in This Pilot Project
                                                                                                                  Annual
  Chemical                              Physical/Che                                            Chemical
                    Composition                                Environmental/Hazards                            Consumptio
   name                                 mical Hazards                                             Type
                                                                                                                  n (Ton)
                                                             Not listed as persistent,
                                        Irritating to skin   bioaccumulative or toxic.
  Diethylene                                and eyes,        Avoid pouring into any sewer,
                  Diethylene glycol                                                              General
  glycol butyl                           potential harm      ground, or into any body of                            12
                  monobutyl ether                                                               Chemicals
     ether                               in contact with     water. All disposal operations
                                                skin         must comply with local
                                                             regulations.

   Ethylene                             Swallowing can                                           General
                   Ethylene glycol                                          /                                       60
    glycol                                be harmful                                            Chemicals

  Foaming                                                    This     product   is   90%
   agent 2           Sodium alkyl       Irritating to skin   biodegradable and can be            General
                                                                                                                    72
  (Anionic           sulfate, H2O            and eyes        treated by incineration in a       Chemicals
 Surfactants)                                                locally approved manner

   Foaming         Glucose pyran,
    agent 1        oligomer, decyl                                                               General
 (environment                                   /                           /                                       60
                   octyl glycoside,                                                             Chemicals
  ally friendly          H2O
    foaming



                                                                 49
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China


                                                                                                                  Annual
  Chemical                              Physical/Che                                            Chemical
                    Composition                                Environmental/Hazards                            Consumptio
   name                                 mical Hazards                                             Type
                                                                                                                  n (Ton)
    agents)

                     Vernoside,           Irritating to
   Foaming                                                  This product is not toxic and        General
                   ethylene glycol,     eyes, nose, and                                                             60
 agent F801N                                                biodegradable.                      Chemicals
                         H2O                  throat

                      Glucose,
  Antifreeze          cellulose,                                                                 General
                                                                                                                    60
   F301N               sodium                                                                   Chemicals
                      benzoate



For the research and development of PFOS phase-out products, it is necessary to carry out the
corresponding product formulation test in the laboratory, and conduct preliminary selection by the
performance of foaming, liquid analysis, aging, freezing, and melting according to the relevant
requirements of national standard GB15308-2006. The initially selected products will be tested in
small fire extinguishing experiments. Small fire extinguishing experiments will be carried out in
the special fire scene setting area. New formula will be applied to fight the simulated fire to verify
the fire-fighting effects. The simulated fire will be extinguished with new formula products to verify
the effectiveness of the product. If the experimental results meet the technical requirements, a
trial production of no less than 1000kg will be conducted, and the product will be sent to a qualified
third party for testing as per GB14308-2006 requirements. The main environmental impact in this
process is that the experimental wastewater produced by formula preparation and container
cleaning, and each time of the fire extinguishing test will produce about 20 liters of wastewater.
The specific number of tests cannot be determined yet. The main pollutants in the experimental
wastewater are surfactant. Because the product experiment of this pilot project and of existing
project are basically the same, which produces no new pollutants, the laboratory wastewater and
fire extinguishing experimental wastewater can be discharged to the wastewater treatment station
of the plant, and then discharged through "A2/O + secondary sedimentation tank + filtration�? to
Yidong Canal and further to Taohuadian Reservoir.

After passing the third-party testing and evaluation accordance with GB15308, CCCF will carry
out fire extinguishing testing for different models of trial products in the physical fire scenes to
further verify the fire extinguishing effect and performance of the products. CCCF is a professional
agency authorized and approved by the China National Certification and Accreditation
Administration Commission to take the following responsibilities: (1) implementation of the
compulsory or voluntary certification of fire products, and technical appraisal of fire products in
China; (2) development and implementation of fire protection product conformity assessment
standards, implementation rules and technical guidelines; (3) Implementation of international
mutual recognition of fire protection product conformity assessment in accordance with the laws
and regulations, management of the expert group of China's compulsory fire protection product
certification, participating in various sub-technical committees of the national fire protection
standardization technical committee; and (4) providing quality information of fire protection
product certification and technical appraisal for the fire protection departments, product quality
supervision, inspection and quarantine departments, and the general public.




                                                                 50
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



According to the project implementation plan, the physical fire scene fire extinguishing testing is
carried out by Fire Product Conformity Assessment Center. The Yibin Branch is only responsible
for providing foam fire extinguishing agent and is not engaged in the specific experimental process,
the testing results can be obtained after testing. Its environmental and social impact assessment
is therefore not within the scope of this report.

During the research and development of PFOS alternative product formulation and product
performance testing, the main occupational health risks are related to the chemicals used during
the R&D and testing process, as well as gasoline and isopropanol used as fuel for fire
extinguishing experiments. Except for foaming agent 1 (environmentally friendly foaming agent),
the remaining chemicals were consistent with those used in the existing production process of
the Yibin Branch.

Foaming agent 1 (environmentally friendly foaming agent) is a general chemical. According to its
MSDS, it will not cause physical/chemical hazards to human body and environment. Therefore,
the occupational health risk in the production process of the pilot project products is lower than
that in the current project. Therefore, it can be managed in accordance with the current
occupational health risk control system of the Yibin Branch. All employees shall be equipped with
protective masks, protective glasses, protective gloves, work clothes and other PPE. In addition,
the work site shall also be equipped with emergency spray and eye washing facilities.

In this stage, the main safety risks are electric shock, mechanical injuries, and fire accidents,
which are the same as in the existing production process of the Yibin Branch. Therefore,
according to the existing safety management system, it can be controlled through strengthening
the safety training and daily supervision of employees, improving the awareness of PPE wearing,
increasing the daily inspection frequency of fire facilities and other aspects of the work.

According to the physicochemical properties and degree of environmental hazard of these
chemicals in the alternative formula, the environmental and social impacts and mitigation
measures in this stage are summarized in Table 8-2.


Table 8-2:Potential E&S Impacts and Mitigation Measures in Alternative Formula R&D
           and Performance Testing Stage

     Factor                        Impact                                               Mitigation
                                                             •    The laboratory wastewater is discharged to the
                    •    The cleaning wastewater and              wastewater treatment station at the plant, and then
                         the fire extinguishing test              discharged to Yidong Canal and further to Taohuadian
                         wastewater produced during               Reservoir once the treatment meets the standard. The
  Wastewater             the experiment is basically              water quality of the outlet of the wastewater treatment
                         consistent        with     the           station in the plant shall meet the standards of Table 4
                         conventional experiment of the           of Comprehensive Sewage Discharge Standard
                         existing project.                        (GB8978-1996).
                    •    The chemicals used for the •             Evaluate the corrosiveness, toxicity, flammability, and
  Storage and            experiment are generally same            reactivity of the newly introduced chemicals according
  handling of            as those used for conventional           to the chemical safety instructions.
   chemicals             experiment of the existing •             Provide chemical safety information sheet in the
                         project, except for the FPOS-            chemical use area or storage area.
                         free fluorosurfactant.



                                                                 51
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



     Factor                        Impact                                               Mitigation
                                                             •    Provide training and appropriate PPE to employees
                                                                  who may expose to the chemicals.
                    •    Waste chemicals and materials
                         generated      during      the •         Hire local qualified vendors for the waste transportation
   Solid waste           experiment are generally same            and disposal. These vendors need to be qualified by
                         as those generated during the            local government agencies, with valid certificates.
                         current experiment.
                                                        •         Before starting the research and development test,
                                                                  evaluate the occupational hazard of the proposed new
                                                                  fluorine surfactant, give priority to the chemicals with
                                                                  less human health risk, and take appropriate
                                                                  occupational hazard protection measures (e. g.: PPE,
  Occupational      •    Occupational health hazards of           ventilation facilities, etc.) according to the assessment
    health               staff exposure to chemicals.             results.
                                                             •    Train employees on occupational hazard protection to
                                                                  understand occupational disease hazard, protective
                                                                  measures, and emergency disposal measures. Provide
                                                                  applicable PPE to staff. Organize the employees to
                                                                  participate in the occupational health checks.
                                                             •    According to the existing safety management system,
                                                                  strengthen the safety training and daily supervision of
                                                                  the staff.
                                                             •    Help employees improve the awareness of wearing
     Safety         •    Electric shock, mechanical               PPE and provide applicable PPE to employees
                         damage, fire risk.                       regularly according to the identified safety risks.
                                                             •    Conduct regular inspection on the existing firefighting
                                                                  facilities (fire hydrants, mobile fire extinguishers, etc.) to
                                                                  ensure their effectiveness.
                    •    Formula development process
                         may have effects on the
                         occupational health and safety
                         of workers;
                    •    project does not add new land,
                         and it will produce no land
      Social             impact;                          •       Strictly implement the above requirements for OHS.
                    •    The project is located in the
                         industrial park, and there is no
                         obvious social sensitivity point
                         around it, and there is no
                         impact      on    the    nearby
                         community.




Removal and replacement of the production equipment and facilities stage
According to the project implementation plan and consultation with management personnel, the
Yibin Branch has ten foam extinguishing production lines at present. This pilot project plans to
adopt the unified replacement of raw materials, facilities, and equipment, which does not involve
large-scale construction activities, and does not involve large-scale entry of construction
personnel. Accordingly, the pilot project is expected to have little impact on the surrounding
communities. The equipment list for removal and replacement is shown in Table 6-2 in Section 6
of this report.




                                                                 52
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



The pilot project will have environmental impacts such as wastewater, solid wastes, and noise
during this stage.
In terms of wastewater, the cleaning wastewater produced during this stage is about 5.6 tons; the
domestic wastewater production of the construction personnel is about 45 liters/day. The
equipment cleaning wastewater and domestic wastewater will be collected and discharged into
wastewater treatment station at the plant through the "A2/O + secondary sedimentation tank +
filtration" process, then will be discharged into the Yidong Canal and further to Taohuadian
Reservoir, the effluent quality of the plant wastewater treatment station shall meet the
requirements of Class I standards in Table 4 of the Comprehensive Sewage Discharge Standard
(GB8978-1996).

The main pollutants produced are waste equipment and household wastes of construction
personnel, which are general solid wastes. The waste equipment generated is about 25-30 tons,
and the household waste of the construction personnel is about 1 kg/day. The waste equipment
can be treated by a qualified solid waste recycling and disposal as the recyclable industrial solid
wastes or other types of solid wastes. The household garbage, after collection, is uniformly
transported by the village committee of Xihan village, Zhuge Town to the garbage transfer station
of Zhuge Town for treatment.

Noise is mainly the construction noise generated during equipment removal and traffic noise
generated during equipment transportation. The pilot project shall focus on reducing the noise
impact generated during equipment removal on construction personnel and surrounding
communities and avoid construction at night. The traffic noise generated during equipment
transportation can be controlled through slow driving within the plant area and the sensitive points
at the factory entrance.

The equipment removal and replacement stage are the stage with highest risk of the health and
safety in this pilot project, and the construction contractor shall follow the relevant requirements
of the construction and removal of the General Environment, Health and Safety Guidelines of the
WB.

The main occupational health risks at this stage are the dust, residual chemicals, and noise
generated during the removal process. Workers may have health problems from exposure to the
hazard factors mentioned above. Therefore, full-time, or part-time occupational health
administrators must be designated responsible for occupational health management in the
construction stage. Construction personnel shall be trained on occupational health related topics
regularly. In the removal of equipment and replacement, workers shall wear corresponding PPE,
such as protective masks, protective glasses, and protective gloves according to the hazard
factors. In addition, the work site shall also be equipped with emergency spray and eye washing
facilities.

The main safety hazard at this stage include fire, lifting injury, mechanical injury, electric shock,
falling and object strike, vehicle injury, etc. Therefore, full-time, or part-time safety administrators
must be designated responsible for site safety management in the construction stage. They shall
conduct safety training to the construction personnel regularly, standardize the operation process
of the construction personnel, and control the time of continuous work. For high-risk operations


                                                                 53
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



such as fire, climbing and hoisting, the operation permit system shall be implemented, and
appropriate hazard prevention measures shall be taken. Strengthen the supervision of the
construction personnel correctly wearing PPE, enhance the maintenance of equipment and tools,
to ensure that they are in a good working condition.

Environmental risk and environmental emergency response: In the process of equipment removal
and cleaning, there is a risk of hazardous waste/chemical leakage. Due to the small content of
hazardous waste and chemicals involved, the probability of this risk is low. It is recommended
that the residue in the equipment should be cleaned to no residues before the equipment is
removed, and the relevant residues and waste solvents and wastewater should be properly
disposed of; flames is prohibited during this stage. In case of spill events, only trained personnel
with appropriate PPE can handle and clean the spilled hazardous wastes/hazardous chemicals.
Untrained personnel shall keep a safe distance from the spill site. The transportation of hazardous
wastes/chemicals must be carried out by qualified vendors, and the transportation routes shall
avoid sensitive points such as water sources. If the spilled hazardous wastes/chemicals are highly
toxic and highly volatile, emergency evacuation and rescue measures shall be arranged
immediately. Places contaminated by hazardous wastes/chemicals shall be cleaned up in time,
and the wastes generated in the cleaning process shall be treated as hazardous wastes.

The pilot project only involves updating the original production equipment polluted by PFOS to
the same production equipment without PFOS. The replaced equipment functions and models
are basically the same, and the production, operation and inspection processes remain
unchanged. Therefore, the environmental and social impacts of equipment removal and
replacement mainly exists in the stage of equipment removal and installation. During the
production and operation, there will be no additional environmental, occupational health, safety,
and social impacts on the pilot project. The potential environmental and social impacts and
mitigation measures during the removal and replacement of the equipment in the pilot project are
shown in Table 8-3.


Table 8-3:Potential E&S Impacts and Mitigation Measures During the Equipment Removal
           and Replacement

     Factor                    Impact                                               Mitigation

                   •    The           wastewater
                        containing          PFOS •         The equipment cleaning wastewater and domestic wastewater
                        pollutants generated by            shall be collected and discharged into wastewater treatment
                        the equipment cleaning             station at the plant. After meeting the standard, it will then be
                        process is about 5.6               discharged into Yidong Canal and further to Taohuadian
  Wastewater            tons;                              Reservoir. The outlet water quality of the plant wastewater
                   •    Domestic      wastewater           treatment station shall meet the requirements of Class I
                        generated      by      the         standards in Table 4 of the Comprehensive Sewage Discharge
                        construction personnel is          Standard (GB8978-1996).
                        about 45 liters / person /
                        day.
                                                   •       After collection, the domestic waste will be uniformly
                   •    Domestic            waste          transported by the village committee of Xihan Village, Zhuge
   Solid waste          generated      by      the         Town to the waste transfer station of Zhuge Town for
                        construction personnel is          treatment. The waste equipment can be treated by a qualified
                        about 0.5 tons;                    solid waste recycling and disposal as the recyclable industrial



                                                                 54
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



     Factor                    Impact                                               Mitigation
                   •    Waste materials and                solid waste or other types of solid waste according to the actual
                        equipment, about 6 tons.           situation.
                                                      •    The pilot project shall explore more environment friendly and
                                                           less impact approaches for scheme design and technology,
                   •    The          maximum               especially the construction process that may produce noise.
                        construction    noise              Relevant engineering measures shall be further discussed to
      Noise             generated      during              reduce the noise impact on construction personnel.
                        equipment removal is •             Avoid construction at night.
                        about 80 db.          •            The equipment transportation vehicles shall drive slowly
                                                           through the plant area and the sensitive points at the factory
                                                           entrance.
                                                      •    The pilot project shall establish and improve the occupational
                                                           health protection mechanism and designate full-time or part-
                                                           time occupational health administrators to be responsible for
                   •    Construction workers are           the occupational health management in the construction
  Occupational          exposed to occupational            stage. Train the construction personnel on occupational
    health              health hazards caused              health-related topics regularly and keep the training records.
                        by    dust,   chemicals, •         The pilot project shall help construction personnel strengthen
                        noise, etc.                        the awareness of wearing PPE and distribute PPE to the
                                                           construction personnel of different types of work according to
                                                           the occupational hazard factors identified.
                                                      •    The pilot project shall establish and improve the production
                                                           safety mechanism. The production department shall conduct
                   •    Potential safety risk
                                                           production safety related theme training for the construction
                        factors such as fire,
                                                           personnel and keep the training records.
                        lifting injury, mechanical
                        injury, electric shock, •          Standardize the operation process of construction personnel,
                        falling from height and            control continuous working hours (e. g. implement rotation
     Safety             object strike, and vehicle         working system, arrange rest time and extension time).
                        injury, collapse, noise •          Work permit system shall be implemented for high-risk
                        and vibration, dust, and           operations (fire, climbing, hoisting, etc.).
                        poor operation, etc. •             Strengthen the supervision on the wearing of PPE, and
                        during the construction            regularly maintain the equipment and tools to ensure that they
                        process                            are in good working condition.

                                                      •    Before disassembly of equipment, the residue in the
                                                           equipment must be cleaned, cleaned without residue before
                                                           the equipment is removed, and the relevant residues and
                                                           waste solvents, wastewater shall be properly disposed of.
                                                      •    Ensure that the cleaning site is impermeable, and that all
                                                           wastewater is collected.
                                                      •    Flames is prohibited during this stage.
                                                      •    Only trained personnel with appropriate PPE can handle and
 Environmental                                             clean the leaked hazardous wastes/hazardous chemicals.
   risks and       •    Leakage of chemicals or            Untrained personnel shall keep a safe distance from the
 environmental          hazardous waste during             leaking site.
  emergency             cleaning equipment      •          The transportation of hazardous wastes/chemicals must be
   response                                                carried out by qualified agency, and the transportation routes
                                                           shall avoid sensitive points such as water sources. If the
                                                           leaked hazardous wastes/chemicals are highly toxic and
                                                           highly volatile, emergency evacuation and rescue measures
                                                           shall be arranged immediately. Places contaminated by
                                                           hazardous wastes/chemicals shall be cleaned up in time, and
                                                           the waste generated in the cleaning process shall be treated
                                                           as hazardous waste.




                                                                 55
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



     Factor                    Impact                                               Mitigation
                                                      •    Conduct regular monitoring of environmental impact, ensure
                                                           that noise, exhaust gas and other pollutants meet the
                                                           standards, and proactively disclose environmental impact
                                                           monitoring results to the community.
                                                   •       Establish and implement an effective community GRM, and
                   •    Social        disturbance          take the initiative to address complaints from community,
                        caused by transport                respond to complaints from the community, and provide timely
     Social             vehicles            during         feedback to the complainants on the results of the processing,
                        construction;                      properly resolve residents' complaints and maintain
                   •    Noise impact during                appropriate records.
                        construction               •       The speed of material transportation vehicles shall be limited,
                                                           and the transportation vehicles must take sealing measures.
                                                           The materials during transportation shall not leak, scatter, or
                                                           fly along the way, so as to reduce the impact of transportation
                                                           dust on surrounding residents.



Production and operation stage
According to the managers consultation, this pilot project only involves replacing the original
production equipment contaminated by PFOS material with the same type of equipment excluding
PFOS. The replaced equipment functions and models are basically unchanged in production,
operation, and inspection process. Therefore, the environmental and social impacts of this pilot
project mainly exist during the equipment removal and installation stage. The production and
operation process will not produce more environmental, OHS and social impact than the existing
production activities. Environmental and social management and mitigation measures can be
implemented in accordance with existing management systems.

According to the current operation analysis of the Yibin Branch, the possible environmental impact
in the trial operation of the pilot project is exhaust gas, wastewater, noise, and solid wastes, etc.

The main sources of exhaust gas are workshop exhaust gas (dust and ammonia) and canteen oil
fume. The production waste gas is treated through gas collecting hood and water adsorption
facilities before it is discharged through 15m exhaust funnel. Canteen oil fume is discharged
through 15 m exhaust funnel after being treated by high-efficiency oil fume removal device. Dust
emission shall meet the requirements of Class II standard in Table 2 of Comprehensive Emission
Standard of Air Pollutants (GB16297-1996). Ammonia emission meets the requirements of Table
2 in Emission Standard of Odor Pollutants (GB14554-1993).

Wastewater mainly includes wastewater for cleaning the outer surface of newly purchased
packaging barrels, workshop floor and laboratory wastewater, and domestic sewage. Among
them, the workshop floor and laboratory wastewater and domestic sewage are treated by the
sewage treatment station in the plant through the "A2/O + secondary sedimentation tank +
filtration" process. The wastewater for cleaning the outer surface of the newly purchased
packaging barrel contains only trace of suspended solids and COD. It is collected and mixed with
the effluent from the sewage treatment station. After reaching the standard, it is discharged into
Yidong Canal and further into Taohuadian Reservoir. The effluent quality shall meet the
requirements of Class I standard in Table 4 of Integrated Wastewater Discharge Standard
(GB8978-1996).


                                                                 56
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



The noise of the operation stage is mainly generated by mixer, filling machine, vacuum pump, air
compressor and other noisy equipment. As the equipment of the pilot project are basically same
as WFS existing production project, there is no additional noise equipment, thus the noise impact
is basically same as the current situation. It is suggested that employees strictly follow the
equipment operation manual to avoid additional mechanical noise caused by mechanical failure.
The enterprise will carry out noise monitoring at factory boundaries regularly to ensure that the
noise monitoring results of north boundary meets the Class 4a standards (namely, 70dB in the
daytime and 55dB at night) of Environmental Noise Emission Standard of Industrial Enterprises
(GB 12348-2008); and the noise monitoring results of boundaries of east, south, and west meet
the Class 3 standard of Environmental Noise Emission Standard of Industrial Enterprises (GB
12348-2008).

The solid wastes generated during the operation stage is mainly waste packaging buckets, waste
packaging bags and household wastes. The waste packaging barrels and bags produced are
about 7.1 tons per year, which will be collected and handed over to raw material manufacturers
for recycling. The empty barrels of gasoline and isopropanol are reused; The amount of dust and
other sediment generated from the circulating water tank for washing the outsides of packaging
buckets is about 0.8 kg per year. After collection, it is uniformly transported by the village
committee of Xihan Village, Zhuge Town to the waste transfer station of Zhuge Town for treatment.
The sludge produced by the sewage treatment station is about 1.5 tons per year. After collection,
it is uniformly transported by the village committee of Xihan Village, Zhuge Town to the waste
transfer station of Zhuge Town for treatment. After collection, the domestic garbage will be
uniformly transported by the village committee of Xihan Village, Zhuge Town to the garbage
transfer station of Zhuge Town for treatment.

During the trial operation of the pilot project, occupational hazard factors on the work site include
noise and chemicals. Since low noise equipment has been considered in the equipment selection,
and noise reduction and isolation measures are planned during the installation process, the noise
level during the operation of the pilot project is expected to be similar to the current noise level.
Yibin Branch has equipped its employees with PPE as protective masks, protective gloves etc. It
is suggested to provide protective glasses. The site workers can further reduce the impact of
workplace noise impact by wearing earplugs. In terms of chemicals, the chemicals for the
production are general chemicals, and the production processes will be conducted in airtight
containers and pipelines, therefore the risks of site workers in direct contact with chemicals are
relatively low. The enterprise will test the occupational hazard factors once a year, organize
regular occupational health examination for employees, and conduct a retrospective evaluation
of occupational diseases every three years

The main safety risks in this stage of pilot project include mechanical injury, electric shock, falling
and fire accidents, which are the same as the existing project safety risks, so they can be
controlled in accordance with the existing safety management system. During the pilot project trial
operation stage, it is recommended to strengthen the training of site workers, enhance the
maintenance of equipment and tools, to ensure that they are in good working condition. The site
workers shall carry out safety self-inspection before starting the daily production and organize a
comprehensive safety inspection every month to ensure timely detection of potential safety issues
and complete rectification. Update the emergency plan for production safety accidents timely,


                                                                 57
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



provide emergency rescue materials (such as fire sand, oil absorption cotton, fire extinguishers,
etc.), and organize relevant drills.

The environmental emergencies during the trial operation of the pilot project may be the chemical
spills. The emergency method is basically the same as that in the equipment removal and cleaning
stage. In case of spill, only those who wear appropriate protective clothing and equipment and
have received training can deal with and clean the spilled hazardous wastes/chemicals. Untrained
personnel shall keep a safe distance from the spill site. The transportation of hazardous
wastes/chemicals must be carried out by qualified agencies, and the transportation route shall
avoid sensitive points such as water sources. If the spilled hazardous wastes/chemicals are highly
toxic and highly volatile, emergency evacuation and rescue measures will be arranged
immediately. The places polluted by hazardous wastes/chemicals will be cleaned in time, and the
wastes generated in the cleaning process will be disposed of as hazardous wastes

The environmental emergencies during the pilot operation of this pilot project may be the chemical
spills, and the emergency response method is basically the same as the equipment removal and
cleaning stage. Once the spill occurs, only trained personnel with appropriate PPE can handle
and clean the spilled hazardous wastes/hazardous chemicals. Untrained personnel shall keep a
safe distance from the spill site. The transportation of hazardous wastes/chemicals must be
carried out by qualified vendors, and the transportation routes shall avoid sensitive points such
as water sources. If the leaked hazardous wastes/chemicals are highly toxic and highly volatile,
emergency evacuation and rescue measures shall be arranged immediately. Places
contaminated by hazardous wastes/chemicals shall be cleaned up in time, and the waste
generated in the cleaning process shall be treated as hazardous waste.




                                                                 58
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



8.2       ENVIRONMENTAL AND SOCIAL MONITORING PLAN
According to the environmental and social impact analysis of the pilot project in Section 8.1, the
corresponding environmental and social monitoring plans for the pilot project are shown in
Table 8-4.

Table 8-4:E&S Monitoring Plan
                                                                                                             Required
   Project      Monitorin         Monitoring            Characteristic             Applicable
                                                                                                            monitoring
    stage        g factor          contents              pollutants                Standard
                                                                                                            frequency
                                                                                   Integrated
  Formula                      Water quality at      Flow rate, pH, COD,           wastewater
                Wastewat
   R&D                        the main sewage        BOD5, NH3-N, SS,          discharge standard       Once at mid-stage
                   er
   stage                      outlet of the plant          TP, TN             (1996) Table 4 Class
                                                                                   I Standard

                                                                                   Integrated
                               Water quality at      Flow rate, pH, COD,           wastewater                Once at
                Wastewat
                              the main sewage        BOD5, NH3-N, SS,          discharge standard        construction peak
                   er
                              outlet of the plant          TP, TN             (1996) Table 4 Class             time
                                                                                   I Standard

                                                                               Emission Standard
 Equipmen                                                                         for Industrial
  t removal                                               Equivalent           Enterprise Noise at           Once at
      and         Noise        Boundary noise          continuous noise             Boundary             construction peak
 replaceme                                                   value              (GB12348-2008)                 time
   nt stage                                                                      Class 3 and 4a
                                                                                    Standard

                                                       Whether waste            Pollution Control
                                    waste
                                                       equipment and              Standards for            Once at the
                  Solid           equipment,
                                                      domestic garbage          Hazardous Waste         construction period
                  waste            domestic
                                                       are treated with        Storage (GB18597-               ends
                                   garbage
                                                         compliance                   2001)

                                                                                    Integrated
                               Water quality at      Flow rate, pH, COD,           wastewater
                wastewate
                              the main sewage        BOD5, NH3-N, SS,          discharge standard       Once at mid-stage
                    r
                              outlet of the plant          TP, TN             (1996) Table 3 Class
                                                                                   III Standard

                                                                               Emission Standard
                                                                                  for Industrial
                                                          Equivalent           Enterprise Noise at
   Project        Noise        Boundary noise          continuous noise             Boundary            Once at mid-stage
     trial                                                   value              (GB12348-2008)
  operation                                                                      Class 3 and 4a
    stage                                                                           Standard

                                                       Whether waste            Pollution Control
                              Waste packaging         packaging bucket            Standards for
                  Solid
                              bucket, domestic          and domestic            Hazardous Waste         Once at mid-stage
                  waste
                                  garbage            garbage are treated       Storage (GB18597-
                                                       with compliance                2001)

                Occupatio                            8h equivalent sound         Occupational
                               Workplace noise                                  Contact Limit for       Once at mid-stage
                nal health                                  level
                                                                                  Workplace



                                                                 59
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China


                                                                                                             Required
   Project      Monitorin         Monitoring            Characteristic             Applicable
                                                                                                            monitoring
    stage        g factor          contents              pollutants                Standard
                                                                                                            frequency
                                                                              Hazardous Factors -
                                                                                Part 2 Physical
                                                                               Factors (GBZ 2.2-
                                                                                     2007)

                                                                               Integrated emission
                                                                                  standard of air
                                  Organized                                      pollutants (1996)
                                                       Dust, Ammonia                                        Once a year
                                  discharge                                     Emission standard
                                                                               for odour pollutants
                                                                                     (1993)
                 Exhaust
                  Gas
                                                                               Integrated emission
                                                                                  standard of air
                                Non-organized                                    pollutants (1996)
                                                       Dust, Ammonia                                        Once a year
                                  discharge                                    Emission standard
                                                                               for door pollutants
                                                                                     (1993)

                                                                                    Integrated
                               Water quality at      Flow rate, pH, COD,           wastewater
                Wastewat
                              the main sewage        BOD5, NH3-N, SS,          discharge standard           Once a year
                   er
                              outlet of the plant          TP, TN             (1996) Table 3 Class
   Project                                                                         III Standard
   official
  operation                                                                    Emission Standard
   phase                                                                          for Industrial
                                                          Equivalent
                                                                               Enterprise Noise at
                  Noise        Boundary noise          continuous noise                                     Once a year
                                                                                    Boundary
                                                            value@
                                                                                (GB12348-2008)
                                                                               Class III Standard

                                                       Whether waste            Pollution Control
                               waste packaging        packaging bucket            Standards for
                  Solid
                               bucket, domestic         and domestic            Hazardous Waste             Once a year
                  waste
                                   garbage           garbage are treated       Storage (GB18597-
                                                       with compliance                2001)

                                                                                 Occupational
                                                                                Contact Limit for
                                                                                  Workplace
                Occupatio                            8h equivalent sound
                               Workplace noise                                Hazardous Factors -           Once a year
                nal health                                  level
                                                                                Part 2 Physical
                                                                               Factors (GBZ 2.2-
                                                                                     2007)

                Communit          Number of
                                                                                                          Once every half
                    y             community                   N/A                  World Bank
                                                                                                              year
 The whole      grievance         grievances
  life cycle
                   Staff       Number of staff                                                            Once every half
                                                              N/A                  World Bank
                grievance       grievances                                                                    year




                                                                 60
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



8.3         CAPACITY BUILDING
During the project manager consultation, Stantec has found that Langchao Fire Technology does
not know enough about the relevant environmental and social requirements, especially the
requirements of the safeguard policy of the WB. In the execution of the project, the ability of the
project implementation agency and the construction contractor shall be improved to ensure the
effective implementation of the ESMP, so it is necessary to strengthen the capacity building of
the organization in the process of the pilot project.
The annual training plan to be established in this pilot project is based on the domestic laws and
regulations on the environment, OHS and social management, as well as the relevant policy
requirements of the FECO and the WB. The main contents of the technical training shall include:
•     • Environmental protection laws and regulations and social laws, regulations and policies
      related to the pilot project;
•     • ESIA procedures;
•     • Potential environment problems caused by the pilot project
•     • Safeguard policy of the WB.
•     • Convention of Stockholm


Key personnel to be trained for this pilot project shall include Langchao Fire Technology
Administrative Department, Production Department, Technology Department, and other
departments responsible for managing the environmental and social impact of the Yibin Branch.
In addition, all employees, temporary workers, contractors, construction personnel and
maintenance personnel of the Yibin Branch will also be trained. It is shown in Table 8-5 of the
capacity building and training plan of this pilot project.
Table 8-5:Capacity Building and Training Plan
                                                                                                 Number of          Days of
        Topic            Training Target                   Training Contents
                                                                                                  Trainees          Training

                          Langchao Fire        •   Related E&S regulations
    Requirements        Technology, Yibin      •   E&S policy and plan
     of policy, law,    Branch, temporary      •   World Bank Safeguards                          About 75             1
    and regulation.    workers, contractors,   •   E&S management framework
                          suppliers etc.       •   Stockholm Convention

    Environmental
                          Langchao Fire
     Impacts and
                        Technology, Yibin      • Langchao Fire Technology              E&S
        Social                                                                                    About 67             1
                        Branch, temporary        management procedure
     Assessment
                             workers
      Procedure
                                               • E&S management requirements during
    Implementation
                          Langchao Fire          construction
    of environment
                        Technology, Yibin      • Internal monitoring, external monitoring,
       and social                                                                                 About 70             1
                        Branch, temporary        and internal auditing
     management
         plan
                       workers, contractors    • Implementation of E&S management
                                                 plan
                                               • Emergency      response      plan    and
     Emergency            Langchao Fire          measures                                         About 70             1



                                                                 61
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



                                                                                                 Number of          Days of
       Topic            Training Target                    Training Contents
                                                                                                  Trainees          Training
    Response           Technology, Yibin
    Measures           Branch, temporary
                      workers, contractors




                                                                 62
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




9.        STAKEHOLDER ENGAGEMENT AND INFORMATION
          DISCLOSURE
9.1       OBJECTIVES
Public consultation and information disclosure is a two-way communication between the project
party and the public, an important mechanism for reducing the risk and social impact of the project,
and an important way of project information transparency and public engagement. Objectives of
public engagement and information disclosure include:
•    Identifying stakeholders and establishing and maintaining constructive contact with them.
•    Assessing the Project related benefits and supports provided by stakeholders and considering
     stakeholders’ views on the Project design and environmental and social management.
•    Providing an effective and inclusive means of engagement that fully involves all parties
     affected by the Project in the discussion of issues that may affect them throughout the project
     cycle
•    Ensuring that appropriate project information on environmental and social risks and impacts
     is disclosed to stakeholders in a timely, understandable, and appropriate manner.


9.2       ENGAGEMENT PROCESS AND FINDINGS
Based on the nature of the project, findings of field work, and interviews with relevant agencies,
the stakeholders identified in the pilot project include: the project owner (Langchao Fire
Technology), the project office (FECO), the relevant government agencies (including Zhuge Town
People's Government, Zhuge Town Environmental Protection Office, and Zhuge Town Land
Office), the project workers, contractors, Xihan Village committee and the affected land
leaseholders, etc.
The stakeholder engagement process conducted during this environmental and social survey was
mainly summarized as follows:
•    Consulting with relevant management personnel of Langchao Fire Technology to understand
     the Project background, scale, impact situation, labour management, etc.
•    Visiting government departments, including Zhuge Town People's Government,
     Environmental Protection Office, Land Office, to understand the current environmental status
     of the Project, environmental regulations requirements, frequency of environmental
     supervision and environmental complaints, and to understand the land use planning and
     relevant policies on the Project.
•    Consulting the Project workers to understand labour working conditions, welfare benefits,
     labour management, etc.
•    Visiting the Xihan Village Committee and consulting village officials to understand the basic
     situation of the village, the impact of the project's land leases, the type of leased lands, rental
     payment standards, land rental distribution, etc.


                                                                 63
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



•       Randomly consulting affected land leaseholders to understand the impact of the project, rent
        payment, satisfaction with the project, as well as opinions and suggestions.
•       Visiting surrounding hotels to understand the environmental and social impact of the project
        on surrounding hotels
•       FECO follows up the environmental and social audit with the enterprise, discusses the
        rectification plan with the enterprise management level, and monitors information disclosure,
        public engagement, and grievance.


Based on the consultation with stakeholders, the main findings reported by stakeholders during
this environmental and social survey are shown in Table 9-1. Comments and suggestions from
various stakeholders have been incorporated into the environmental and social management
plan.


Table 9-1:Consultation Conclusion with the Stakeholders
                                             Operation
    No.           Stakeholders                                    Consulted comments and advice                         Solution
                                               time
                                                           • Langchao Fire Technology is a famous local
                            Zhuge Town                       enterprise which is regarded as a star
    1                        People’s          2021.7        enterprise and has built a good relationship           /
                            Government                       with the local government and surrounding
                                                             communities.
                                                           • It is confirmed that the EIA report completed
                                                             in 2014 by Langchao Fire Technology has
                                                             obtained corresponding approval and
                                                             acceptance of environmental protection
                                                             completion;
                                                           • As confirmed with Zhuge Township EPB,
                            Zhuge Town                       since the Project only involves in changing of
                           Environmental                     one raw material, there is no need to conduct
    2                                          2021.7                                                               /
                             Protection                      a new EIA or EIA update;
                               Office                      • The      Environmental     Protection   Office
             Relevant
                                                             regulates the environmental impact of
           governmental
                                                             companies through daily irregular inspections;
           departments
                                                           • The environmental protection bureau never
                                                             receives any environmental grievance from
                                                             the surrounding communities on the facilities
                                                             of Langchao Fire Technology.
                                                           • Before 2009, the land used for the project was
                                                             mainly agricultural land. Before Langchao Fire
                                                             Technology leased the land, the local village
                                                             committee had gone through the formalities of
                                                             converting agricultural land.
                            Zhuge Town
    3                                          2021.7      • Langchao Fire Technology has signed lease              /
                            Land Office
                                                             agreement with Xihan Village and have
                                                             obtained the collective land use right
                                                             certificate, which is in accordance with the
                                                             requirement of local land use plan and
                                                             regulations.




                                                                 64
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



                                             Operation
 No.              Stakeholders                                    Consulted comments and advice                         Solution
                                               time
                                                           • Langchao Fire Technology have not signed
                                                             labour contract with 10 temporary workers;
                                                           • According to records of salary and                     The enterprise
                                                             attendance, situations of overtime and                 has resigned
            Project workers (currently
   4                                           2021.7        continuous work are observed;                          contracts with
                    employed)
                                                           • Langchao Fire Technology has established               temporary
                                                             internal GRM but did not form written records          workers.
                                                             of workers’ comments and reflections and the
                                                             handling results.
                                                           • Langchao Fire Technology has signed land
                                                             lease agreement with Xihan Village
                                                             Committee and pays the rent according to the
                                                             agreement annually. Currently, the rent for the
   5        Xihan Village Committee            2021.7                                                               /
                                                             next year has been paid in October of 2020.
                                                           • The village committee distributes the rent to
                                                             the corresponding affected farmers without
                                                             withdrawal and retaining.
                                                           • Affected lease holders receive the rent every
                                                             year. The rent paid in October of 2020 has
                                                             been distributed to them;
            Affected lease holders of
   6                                           2021.7      • The affected lease holders express that the            /
                  Xihan Village
                                                             income from lease rent is higher than that of
                                                             farming and are satisfied with leasing their
                                                             land.
                                                           • The operation of the existing project facilities
                                                             has no impact on the surrounding hotels.
                                                             Duleyuan Hotel has been running for more
                                                             than ten years and are not affected by the
   7         The surrounding hotels            2021.7        environmental impact brought by Langchao               /
                                                             Fire Technology;
                                                           • Duleyuan Hotel has been running in good
                                                             condition and maintain a good neighbourhood
                                                             relationship with Langchao Fire Technology.
                                                           • Langchao Fire Technology has done the first-
                                                             round publicity of its ESMP on its website
           The first-round publicity and                     (http://www.lylangchao.com/) in 12.15, 2020.
   8                                           2021.12                                                              /
          feedback collection of ESMP                        The publicity picture is illustrated in in Figure
                                                             9-1. No feedback is received during the
                                                             publicity period.




                                                                 65
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



Figure 9-1:The First Round of Online Publicity Screenshots




9.3       PUBLIC ENGAGEMENT AND INFORMATION DISCLOSURE IN
          THE NEXT PHASE
The plan for the next phase public engagement and information disclosure is as follows:
•   Paying the rent for leased land on time and keeping records;
•   Building community GRM, disclosing it to the communities, and keeping records;
•   Disclosing the project to the surrounding communities to understand their attitude and
    comments on the project, and keeping records;
•   Langchao Fire Technology plans to establish the second-round publicity of the environmental
    and social management plan on the company’s website and the notice boards in the factory
    after the approval of the WB.


9.4       COMMUNITY GRIEVANCE REDRESSING MECHANISM
Grievance mechanism: During the preparation and operation of the project, the Yibin Branch
established a multi-level grievance channel to timely understand and resolve the impacts and
problems of the project to the affected company’s employees (referred as “the affected parties�?)
and other stakeholders, and to ensure the affected party’s requirement for information disclosure
and wide public engagement (not limited to the surrounding communities). The details are as
follows:




                                                                 66
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



The Yibin Branch plans to assign a coordinator (Ms Li) from the development stage of the project,
who will be responsible for receiving grievances onsite, via disclosed telephone number/WeChat
account/website/onsite information board, investigating and addressing all external grievances
arising from or related to the project activities.
The coordinator will collect and record all grievance through registration form and keep records
in grievance database. The grievance procedures include the following steps, and the flow chart
of grievance is illustrated in Figure 9-2:
•   The first stage: The affected person/community may address their grievances and complaints
    to the coordinator of their enterprises either orally or in written forms. Their enterprises shall
    keep a written record for the oral grievances and provide a clear reply within two weeks.
•   The second stage: If the affected people/community are unsatisfied with the decision of stage
    1, they can submit their grievances to FECO. During the operation of the project, the GRM at
    the level of the enterprises and the local project office is the main channel for resolving the
    project grievances. The national project office shall make joint efforts with the local project
    offices/engaged enterprises and the affected people/communities, to seek solutions for
    problems under the circumstances that the local project office/enterprises cannot resolve or
    there is no project-level GRM.
•   The third stage: If the affected people/communities are still unsatisfied with the above
    decision, they can appeal to administrative bodies with jurisdiction level by level for arbitration,
    in accordance with “Administrative Procedure Law of the People’s Republic of China�?, after
    receiving the grievance handling decision.
•   The fourth stage: If the affected parties are still not satisfied with the arbitration decision, they
    may, after receiving the arbitration decision, bring a suit to the civil court in accordance with
    the Civil Procedure Law.




                                                                 67
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



Figure 9-2:Flow Chart of the GRM for PFOS Project




                                                                 68
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



The contact details for the community grievance of this pilot project are as follows:

 Implementation unit contact: Zhuqing Li
 Cell phone: 15036375530
 E-mail: 155281909@qq.com
 Address: Luoyang Langchao Fire Technology Co. Ltd., 250 m from the crossing of Gulong
 Road and Erguang Highway, Luolong District, Luoyang City, Henan Province


For anonymous grievances, we should attach the equal importance as other grievances, keeping
confidentiality of the information of the appellant, and put forward solutions to the grievances. The
grievance shall be handled with records within 7 days. FECO will track the GRM and keep records.


9.5       REPORTING MECHANISM
The Project shall submit reports on the implementation of ESMP. Table 9-2 indicates the report
submission plan of the project.
Table 9-2:Report Submission Plan
   Report         Preparation                                                                                  Time or
                                            Contents                      Acceptance agency
    type            agency                                                                                   frequency

   Internal                         Project activity progress,                                                1 time (at
                  Construction                                           Implementation agency
  monitoring                          problem rectification                                                 completion of
                 unit/contractor                                       (Langchao Fire Technology)
    report                          progress, file record, etc.                                             construction)

                  Pilot project     Project activity progress,                                            1 time (during the
   Internal
                   group of           problem rectification              Implementation agency            project operation
  monitoring
                 Langchao Fire      progress, file record, etc.        (Langchao Fire Technology)              period)
    report
                  Technology

   External                         Environmental and social                                                2 times (one
  monitoring                         performance, problem                                                 during the middle
                                                                         Implementation agency
    report         External          rectification progress,                                               of construction
                                                                       (Langchao Fire Technology);
    during       monitoring unit    implementation of social                                              period, one at the
                                                                                 FECO
 construction                          and environmental                                                    completion of
    period                           management plan, etc                                                   construction)

   External                         Environmental and social                                               1 time (three
  monitoring                          performance, problem                                                months after the
                                                                         Implementation agency
    report         External           rectification progress,                                              completion of
                                                                       (Langchao Fire Technology);
    during       monitoring unit    implementation of ESMP,                                                construction)
                                                                                 FECO
  operation                                      etc
    period




                                                                  69
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




10.       ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN
According to the section 5 (E&S status survey) and the section 8 (E&S impact assessment on pilot project), the ESMP for this pilot
project is designed as follows (Table 10-1).
Table 10-1:Environmental and Social Management Plan
                                                                                                                                                          Cost
          Potential Issues                               Management Requirements                              Responsibility        Supervisor
                                                                                                                                                        Estimate
                                       • Langchao Fire Technology shall contact the local Housing
                                         and Urban-Rural Development Bureau and prepare
                                         corresponding fire protection completion acceptance                     The Yibin     FECO (project office),
                                         documents according to relevant regulations.                             Branch,      Luoyang Housing and
                    EHS approval                                                                                                                           /
                                       • The Yibin Branch has issued fire completion acceptance work           Langchao Fire       Urban-Rural
                                         schedule and has promised to perform according to the                  Technology     Development Bureau
                                         schedule. The completion acceptance is planned to be done
                                         by the end of September of 2022.
                                       • Langchao Fire Technology shall contact the local Ecological
                                         and Environmental Bureau and prepare emergency plans of
                                         environmental and production safety events for government
                                         departments for reference according to relevant regulations.                          FECO (project office),
                                         It is also necessary to conduct relevant drills annually and                              Zhuge Town
                                                                                                                 The Yibin
                                         keep the drill records.                                                                  Environmental
                   Emergency plan                                                                                 Branch,
  The existing                         • The Yibin Branch has entrusted a third-party organization to                            Protection Office,        /
                      and drill                                                                                Langchao Fire
    project                              prepare emergency plans for environmental emergencies.                                Luoyang Work Safety
                                                                                                                Technology
  rectification                          The retrospective evaluation of work safety emergency plan                              Supervision and
    period                               is also included in the plan, and it is expected to complete the                      Administration Bureau
                                         preparation of the plan text in February 2022. After the
                                         preparation of the two plans, a drill will be arranged
                                         respectively.
                                       • Langchao Fire Technology shall entrust a qualified third-party
                    Occupational         institute to carry out the identification of occupational health
                         health:         hazard factors and the detection of occupational disease
                    Occupational-        hazard factors. Regular occupational health examination
                                                                                                                 The Yibin
                        disease-         should be conducted for employees exposed to the                                      FECO (project office),
                                                                                                                  Branch,
                   inductive factor      occupational-disease-inductive factors according to the                                Luoyang Municipal          /
                                                                                                               Langchao Fire
                      testing and        identified factors.                                                                    Health Commission
                                                                                                                Technology
                     occupational      • The Yibin Branch has planned to entrust a third-party institute
                         health          to carry out an occupational health status evaluation and a
                     examination         detection of occupational-disease-inductive factors, which
                                         are expected to be completed by March 2022. Occupational




                                                                                         70
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China


                                                                                                                                                            Cost
          Potential Issues                               Management Requirements                              Responsibility         Supervisor
                                                                                                                                                          Estimate
                                         hazard declaration and occupational health examination will
                                         be carried out after completion of the evaluation.
                                       • Langchao Fire Technology shall contact the local Quality
                                         Supervision Bureau and apply for registration certificate for
                                         forklift truck according to relevant requirements. A qualified
                                         third-party institute shall also be entrusted to conduct regular
                                                                                                                 The Yibin
                                         forklift testing. In addition, Langchao Fire Technology shall
                       Special                                                                                    Branch,
                                         obtain special equipment operating license for forklift                                FECO (project office)         /
                      operations                                                                               Langchao Fire
                                         operators.
                                                                                                                Technology
                                       • The enterprise is reapplying for forklift license, special
                                         equipment operation license and entrusting regular
                                         inspection of forklift. It is expected to be completed in four
                                         months.
                     Environment:
                                       • The laboratory wastewater is collected and discharged to the
                      the cleaning
                                         wastewater treatment station in the factory. After reaching the
                   wastewater and                                                                                The Yibin
                                         standard, it is discharged into Yidong Canal and then into
                     experimental                                                                                 Branch,                                   CNY
                                         Taohuadian reservoir. The effluent water quality of the
                       wastewater                                                                              Langchao Fire                             10,000/time
                                         treatment station shall meet the requirements of table 4 in the
                   produced during                                                                              Technology
                                         Comprehensive Sewage Discharge Standard (GB8978-
                    the experiment
                                         1996)
                        process
                                       • Assessment of the occupational health risk shall be done on                            FECO (project office),
                                         the environmentally friendly foaming agent before the start of                              Zhuge Town
                    Occupational         the research and development test, and take appropriate                                    Environmental
 Development
                      health and         occupational hazard prevention measures (e.g., PPE,                                      Protection Office,
   stage of
                        safety:          ventilation facilities, etc.) based on the assessment results.          The Yibin      Human Resources and
  substitute
                    occupational       • A qualified occupational health technological service institute          Branch,       Social Security Bureau
  foam fire                                                                                                                                              CNY 50,000
                   health hazard of                                                                            Langchao Fire       of Yibin District,
 extinguisher                            should be entrusted to conduct regular test for occupational
                     the workers         disease hazardous factors at workplaces.                               Technology      Luoyang City, Luoyang
                      exposed to       • Training related to occupational disease hazards prevention                              Municipal Health
                      chemicals          shall be conducted to employees to inform them of                                           Commission
                                         occupational hazards, protective measures, and emergency
                                         measures.
                                       • Enhancement is done on the safety training and daily
                    Safety: risk of
                                         supervision of employees according to the existing safety               The Yibin
                   electrical shock
                                         management system.                                                       Branch,
                   and mechanical                                                                                                                             /
                                       • Enhancement shall be done on the awareness of PPE                     Langchao Fire
                     injury during
                                         wearing, and regular supply of PPE should be guaranteed for            Technology
                    development.
                                         employees according to identified safety risks.
  Equipment         Environment:       • The cleaning wastewater and domestic wastewater are                        The Yibin   FECO (project office),        /
   cleaning,         wastewater          processed by the wastewater treatment station in the factory,               Branch,       Zhuge Town



                                                                                         71
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China


                                                                                                                                                          Cost
          Potential Issues                               Management Requirements                              Responsibility        Supervisor
                                                                                                                                                        Estimate
  dismantling,        generated           and then discharged into Yidong Canal, and then into                 Langchao Fire       Environmental
   installation    during cleaning,       Taohuadian Reservoir. The effluent quality should meet the            Technology,      Protection Office,
      stage        dismantling and        requirements of table 4 in the comprehensive Sewage                    Contractor    Human Resources and
                    installation of       Discharge Standard (GB8978-1996).                                                    Social Security Bureau
                      equipment                                                                                                   of Yibin District,
                       (cleaning                                                                                               Luoyang City, Luoyang
                     wastewater,                                                                                                 Municipal Health
                       domestic                                                                                                     Commission
                     wastewater)
                                       • This pilot project should explore more environmentally
                    Environment:         friendly and less influential methods in terms of scheme
                   noise generated       design and technology, especially in the process construction
                   during cleaning,      which may produce noise. Relevant engineering measures
                                                                                                                                                            /
                   dismantling and       should be further discussed to mitigate the impact of the
                    installation of      project on the surrounding communities.
                      equipment        • Night construction should be avoided.
                                       • Transporting vehicles should run at a low speed.
                    Environment:
                     solid wastes
                      generated        • After collection, the household garbage will be transported to
                   during cleaning,      the garbage transfer station of Zhuge Town by the village
                   dismantling and       Committee of Xihan Village.
                    installation of    • The dismantled and cleaned equipment can be entrusted to                                                       CNY 5,000
                      equipment          a qualified solid waste recycling and disposal company
                      (municipal         according to the recyclable industrial solid wastes or other
                     wastes and          types according to the actual situation.
                         waste
                     equipment)
                                       • The Yibin Branch or Langchao Fire Technology shall sign
                                         EHS agreements with construction contractor, equipment
                    Occupational
                                         suppliers, etc., and clarify the responsibility and duty of both
                        health:
                                         sides.
                     occupational
                                       • The pilot project shall designate a full-time or part-time
                   health hazards
                                         occupational health manager to be responsible for
                    caused by the
                                         occupational health management during the construction                                                             /
                     exposure of
                                         phase. Regular training on occupational health related topics
                     construction
                                         for construction personnel.
                   workers to dust,
                      chemicals,       • The pilot project should strengthen the awareness of the
                      noise, etc.        construction personnel to wear personal articles and
                                         distribute PPE to the construction personnel of different work
                                         types according to the identified occupational hazard factors.



                                                                                         72
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China


                                                                                                                                                Cost
          Potential Issues                                 Management Requirements                              Responsibility   Supervisor
                                                                                                                                              Estimate
                                         • The Yibin Branch or Langchao Fire Technology shall sign
                                           EHS agreements with construction contractor, equipment
                                           suppliers, etc., and clarify the responsibility and duty of both
                                           sides.
                                         • The pilot project shall establish and improve the safety
                                           production mechanism, and the production department shall
                                           carry out safety production related subject training for
                                           construction personnel and keep training records.
                                         • The operation process of the construction personnel shall be
                                           regulated, the continuous working time shall be controlled
                                           (such as implementing the rotation system, arranging rest
                   Safety: potential       time, and stretching time).
                        safety risk      • Good field cleaning mechanism shall be conducted. Wastes
                    factors during         and leakage shall be cleaned regularly. Dust reduction
                     construction          measures during construction are recommended.
                     such as fire,       • Warning signs should be posted at construction sites where
                      lifting injury,      there are risks of fire, electric shock, falling, and mechanical
                      mechanical           injury.
                    injury, electric     • The pilot project should strengthen the awareness of the
                                                                                                                                              CNY 5,000
                     shock, falling        construction personnel to wear personal equipment,
                       and object          distribute PPE to the construction personnel of different types
                    strike, fall/slip,     according to the identified safety hazard factors, and ensure
                    vehicle injury,        the correct use of construction personnel.
                   collapse, noise       • Work permit management procedures shall be implemented
                    and vibration,         for high-risk work, such as fire work and climbing work.
                    dust, and poor       • Regular inspection and maintenance of mechanical
                        operation          equipment, working vehicles, etc., should be conducted to
                                           ensure that only equipment or vehicles (e.g., forklifts and
                                           lifting equipment) that meet the requirements of regulations
                                           are used, and operators have relevant licenses (e.g., special
                                           equipment operator's license).
                                         • Planning and zoning of vehicle traffic, mechanical operations,
                                           walking areas, controlling vehicle traffic through one-way
                                           traffic rules, setting speed limits, and directing traffic on site
                                           by trained signalmen (wearing conspicuous vests or coats).
                                         • It is necessary to formulate emergency plans, organize
                                           emergency teams, equip them with emergency supplies, and
                                           carry out training and drills
                                         • Regular monitoring on environmental impacts should be done
                   Social: Impacts         to ensure the discharge of noise, waste gas, etc. meet the
                   of pollutants on                                                                                                               /
                                           standard. Monitoring results of environmental impacts shall
                   the surrounding         be disclosed to the public.



                                                                                          73
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China


                                                                                                                                                           Cost
          Potential Issues                               Management Requirements                               Responsibility        Supervisor
                                                                                                                                                         Estimate
                     communities       • It is necessary to implement and operate an effective
                                         community GRM and actively disclose the project GRM to the
                                         community. Grievance redressing and its results should be
                                         reflected to appellant in time. Records should be kept of every
                                         grievance redressing.
                                       • The speed of the transport vehicles in the factory shall be
                                         limited, and the transport vehicles shall be sealed. The
                                         materials shall not leak, scatter, or fly in the air along the way,
                                         so as to reduce the impact of transportation dust on the
                                         surrounding communities.
                   Environmental
                   risk: there are • Before dismantling, the residue in the equipment shall be
                   risks including   cleaned, and the equipment shall be dismantled after no
                      leakage of     residue is cleaned, and the relevant residue, waste solvent
                     wastewater      and wastewater shall be properly disposed of; Dismantling
                      containing     activities shall be carried out by professional personnel                                                              /
                        residual     wearing protective clothing and equipment.
                   chemicals and   • Ensuring that anti-seepage measures of the cleaning site are
                  PFOS during the    implemented, and all the cleaning wastewater is collected.
                       cleaning    • Fire is prohibited during the equipment dismantling.
                       process.
                                       • Only trained personnel wearing appropriate protective                   The Yibin
                                                                                                                                FECO (project office),
                                         clothing and equipment should handle and clean spilled                   Branch,
                                                                                                                                    Zhuge Town
                                         chemicals. Untrained personnel should keep a safe distance            Langchao Fire
                                                                                                                                   Environmental
                                         from the spill site                                                    Technology,
                      Emergency        • The transport of spilled chemicals shall be carried out by                               Protection Office
                                                                                                                 Contractor
                   response: there       qualified agencies, and the transport route shall avoid
                      are risks of       sensitive points such as water sources. If the spilled
                       chemical          hazardous waste/chemicals are highly toxic and volatile,
                     leakage and         emergency evacuation and rescue measures should be                                                                 /
                    inappropriate        arranged immediately. Areas contaminated by hazardous
                    operation can        wastes/chemicals should be cleaned up in a timely manner
                   cause poisoning       and the waste generated in the cleaning process should be
                       or injury.        disposed of as hazardous wastes.
                                       • If any person is injured, the injured person should be treated
                                         on the spot in accordance with the corresponding chemical
                                         first aid method, and then sent to the hospital for further
                                         treatment.
   Operation        Environmental                                                                                   The Yibin   FECO (project office),      /




                                                                                         74
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China


                                                                                                                                                           Cost
          Potential Issues                               Management Requirements                              Responsibility        Supervisor
                                                                                                                                                         Estimate
  stage of the      management         • The pilot project shall maintain and improve the existing                Branch,          Zhuge Town
  pilot project                          environmental protection mechanism and designate a full-              Langchao Fire      Environmental            CNY
                                         time or part-time environmental administrator to be                    Technology          protection          10,000/time
                                         responsible for the environmental management of the pilot
                                         project. Regular training should be carried out on
                                         environment-related topics for all staff and keep training
                                         records.
                                       • In this pilot project, a qualified third-party testing institution
                                         shall be entrusted to conduct regular testing of the total outlet
                                         of wastewater produced in the factory area, and the effluent
                                         quality shall meet the requirements of the first class in Table
                                         4 of the Comprehensive Sewage Discharge Standard
                                         (GB8978-1996).
                                       • The organized and unorganized waste gases of the pilot
                                         project shall be regularly tested by qualified third-party testing
                                         institutions, and the pollutants shall meet the requirements of
                                         the comprehensive emission standard of air pollutants (1996)
                                         and the emission standard of malodorous pollutants (1993).
                                       • This pilot project shall further strengthen the noise control on                                                  CNY
                                         the east and west sides of the factory boundary, and a                                                         10,000/time
                                         qualified third-party testing institution shall be commissioned
                                         to conduct regular testing, and the noise results shall meet
                                         the requirements of the environmental noise emission
                                         Standard (2008) for the industrial enterprise factory
                                         boundary.
                                       • Solid wastes generated in the pilot project include waste
                                         packaging barrels and bags, sediments generated from the
                                         circulating pool outside the washing packaging barrels,
                                         sewage treatment station sludge, household garbage, and
                                         hazardous waste. General solid wastes should be entrusted
                                         to a qualified third-party organization for collection and
                                         treatment. The third-party company qualified for hazardous
                                         waste disposal shall be entrusted to carry out outbound
                                         transportation and treatment of hazardous wastes.
                                       • The pilot project shall maintain and improve the existing
                      Health:            occupational health management mechanism and designate                  The Yibin
                    exposure of                                                                                                FECO (project office),
                                         full-time or part-time occupational health managers to be                Branch,
                     workers to                                                                                                 Luoyang Municipal            /
                                         responsible for the occupational health management of the             Langchao Fire
                    occupational                                                                                                Health Commission
                                         pilot project. Conduct regular training on occupational health         Technology
                   health hazards        related topics for all staff and keep training records.




                                                                                         75
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China


                                                                                                                                                           Cost
          Potential Issues                               Management Requirements                              Responsibility        Supervisor
                                                                                                                                                         Estimate
                   from noise and      • The pilot project should entrust the qualified occupational
                                                                                                                                                           CNY
                      chemicals.         health technical service organization to carry out the
                                                                                                                                                        10,000/time
                                         detection of occupational-disease-inductive factors.
                                       • The pilot project should entrust qualified organizations to
                                         provide regular occupational health examination for
                                                                                                                                                             /
                                         employees exposed to occupational hazards. Complete the
                                         declaration of occupational hazards.
                                       • The pilot project should strengthen the awareness of
                                         employees' wearing of personal articles, issue PPE to
                                         employees of different jobs on a regular basis according to
                                                                                                                                                        CNY 10,000
                                         the identified occupational-disease-inductive factors, and
                                         post warning labels of occupational-disease-inductive factors
                                         in the workshop.
                         Safety:
                      mechanical                                                                                               FECO (project office),
                    injury, electric   • Safe production management mechanism should be furtherly                              Luoyang Housing and
                                                                                                                 The Yibin
                    shock, falling,      improved and regular training of safe production should be                                Urban-Rural
                                                                                                                  Branch,
                    fire, and other      carried out for all employees.                                                        Development Bureau,      CNY 50,000
                                                                                                               Langchao Fire
                       safety risk     • Emergency plan for production safety accidents should be                              Luoyang Work Safety
                                                                                                                Technology
                     factors in the      updated and regular training and drills shall be organized.                             Supervision and
                       production                                                                                              Administration Bureau
                        process.

                                       • The pilot project should meet the national regulations and
                                         laws and sign labour contracts with temporary workers within
                                                                                                                 The Yibin
                                         one month from the start of working.
                    Recruitment                                                                                   Branch,
                                       • Grievance mechanism for the employees (including                                                                    /
                    management                                                                                 Langchao Fire
                                         contracted workers and temporary workers) of the pilot
                                                                                                                Technology
                                         project. Comments, feedbacks, and worries raised by
                                         employees shall be redressed and recorded in written forms.                           FECO (project office),
                                                                                                                               Human Resources and
                                       • The pilot project shall keep tracking the rent payment status                         Social Security Bureau
                                                                                                                                                             /
                                         of land lease and keep records.                                                          of Yibin District,
                                       • The pilot project should establish a social management                                    Luoyang City
                                         mechanism and designate full-time or part-time community                The Yibin
                      Social             liaison officers to be responsible for community                         Branch,                                    /
                    management           communication and management of Langchao Fire                         Langchao Fire
                                         Technology.                                                            Technology
                                       • The pilot project should establish and implement an effective
                                         community GRM and take the initiative to disclose it, deal with                                                     /
                                         the complaints raised by the community, and feedback the



                                                                                         76
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China


                                                                                                                                                          Cost
          Potential Issues                                Management Requirements                              Responsibility      Supervisor
                                                                                                                                                        Estimate
                                           results to the complainants in time, so as to properly solve the
                                           complaints of the communities.
                                       •   The pilot project plans to carry out two rounds of publicities of
                                           ESMP on the company’s website and notice board within                                                            /
                                           plant area, respectively, in December 2021.
                                       •   The pilot project shall carry out regular monitoring on
                                                                                                                                                           see
                                           environmental impacts to ensure discharge of pollutants such
                                                                                                                                                      environmental
                                           as noise, exhaust gas, etc. meet the standard. The
                                                                                                                                                      management
                                           environmental impact monitoring results shall be disclosed to
                                                                                                                                                           part
                                           the communities to resolve their worries.
                                       •   Only trained personnel wearing appropriate protective
                                           clothing and equipment should handle and clean chemical
                     Emergency
                                           spills. Untrained personnel should keep a safe distance from
                   reaction: There
                                           the spill site.
                     are risks of
                                       •   The transport of spilled chemicals shall be carried out by
                      chemical
                                           qualified units, and the transport route shall avoid sensitive
                   leakage in trial                                                                              The Yibin
                                           points such as water sources. If the spilled hazardous
                    operation and                                                                                 Branch,        FECO (the project
                                           waste/chemicals are highly toxic and volatile, emergency
                        formal                                                                                 Langchao Fire    office), Zhuge Town
                                           evacuation and rescue measures should be arranged                                                                /
                     production                                                                                 Technology,        Environmental
                                           immediately.      Areas      contaminated      by      hazardous
                      operation,                                                                               Waste disposal     Protection Office
                                           wastes/chemicals should be cleaned up in a timely manner
                      improper                                                                                      unit
                                           and the waste generated in the cleaning process should be
                    operation will
                                           disposed of as hazardous wastes.
                        lead to
                    poisoning and      •   If there are employee injuries, on-site treatment should be
                         injury.           conducted following the first aid approaches of the
                                           corresponding chemicals. The injured employees should be
                                           sent to hospital for further treatment after the first aid.




                                                                                          77
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




11.       COST ESTIMATION
The cost of implementing the ESMP mainly includes the cost of wastewater treatment, equipment
updating and debugging, training, preparing risk assessment and monitoring of the ESMP
implementation. Tasks 4, 5, 6 and 7 do not involve the cost related to the ESMP. Table 11-1
shows the details of cost estimation.

Table 11-1:E&S Budget of the Project

       Task                                  Subject                                           Sum (CNY)

      Task 1                 Laboratory wastewater treatment fee                                  20,000

                                   Wastewater treatment fee                                       30,000
      Task 2
                                 Waste equipment disposal fee                                     10,000

                              PFOS/PFOA testing equipment fee                                   1,200,000

                                  Other testing equipment fee                                    634,700

      Task 3                            Stuff training fee                                        10,000

                                   Solid wastes disposal fee                                      20,000

                                   Wastewater treatment fee                                      100,000

                           E&S management and monitoring report
                                                                                                 150,000
                                      preparation

      Task 8              ESMP implementation fee (including GRM
                                                                                                 160,000
                                   implementation fee)

                                       ESMP preparation                                          100,000

                                    Total                                                       2,434,700




                                                                 78
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



12.       ANNEX
     Annex 1: List of Consulted Personnel
On July 23, 2021, Stantec interviewed and consulted relevant stakeholders for the purpose of
completing the environmental and social assessment. Please refer to the list below. Stantec is
grateful for the cooperation of these consulted people during the consultation:

    No.                    Name                                  Department                              Position

     1                     Mr. He                        Langchao Fire Technology                       the Minister

     2                     Ms. Li                        Langchao Fire Technology                       the Director

     3                   Ms. Zhang                       Langchao Fire Technology                      HR manager

     4                   Mr. Zhang                               Zhuge Town                           Deputy mayor

     5                   Mr. Zhang                       Zhuge Town (Land Office))                      the Director

                                                        Zhuge Town (Environmental
     6                    Mr. Zhao                                                                      the Director
                                                            Protection Office)

                                                                                                  community committee
     7                    Mr. Song                              Xihan Village
                                                                                                       member

     8                    Mr. Han                               Xihan Village                       villager of group 2

     9                    Ms. Han                               Xihan Village                       villager of group 1




                                                                 79
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



     Annex 2: Land Certificate




                                                                 80
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



     Annex 3: Land Lease Agreement




Note: The annual rent of CNY 1533.78 /mu in this agreement is only the land rent of the year (2009).
According to the confirmation of the person in charge of Langchao Fire Technology and the cadres of Xihan
Village Committee, the land rent standard of each year thereafter is calculated according to the grain yield
and the grain price, that is, the yield is 1000 kg of wheat and corn, respectively. Grain prices are subject to
that announced by the local price bureau at the end of every August.




                                                                 81
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




                                                                 82
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



     Annex 4: Drinking Water Quality Test Report

                                                                                         Referred Standard Limits
Detection         Testin
                                           Items                      Results            of Drinking Water Hygiene
  point           g Time
                                                                                          Standard (GB5749-2006)

                                             pH                           7.9                           6.5~8.5


                                  Total bacteria (CFU/ml)             Not tested                     100CFU/mL


                                Total coliform (MPN/100ml)            Not tested                Should not be tested


                                    E. Coli (MPN/100ml)               Not tested                Should not be tested


                                 Thermotolerant coliforms
                                                                      Not tested                Should not be tested
                                      (MPN/100ml)

                                          As (µg/L)                      <1.0                          0.01 µg/L


                                        Cr VI (mg/L)                    <0.004                         0.05 µg/L


                                          Pb (µg/L)                      <2.5                          0.01 µg/L


  Drinking        2021.12.               Hg (µg /L)                      <0.1                         0.001 µg/L
  water in          16
  factory
  kitchen          (08:00)                Se (µg/L)                      <0.4                          0.01 µg/L

                                       Cyanide (mg/L)                   <0.002                        0.05 mg/L

                                       Flouride (mg/L)                  <0.006                         1.0 mg/L


                                      Chloride (mg/L)                    2.42                          250 mg/L


                                         Chroma (º)                       <5                              15 º


                                       Turbidity (NTU)                   <0.5                           1 NTU


                                            Odour                        None                          No odour


                                      Visible objectives                 None                            None


                                          Cd (µg/L)                      <0.5                         0.005 µg/L


                                          Al (µg/L)                       <40                          0.2 µg/L




                                                                 83
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




                                                                                         Referred Standard Limits
Detection         Testin
                                           Items                      Results            of Drinking Water Hygiene
  point           g Time
                                                                                          Standard (GB5749-2006)


                                          Fe (µg/L)                      <4.5                          0.3 µg/L


                                          Mn (µg/L)                       2.8                          0.1 µg/L


                                          Cu (µg/L)                       <5                           1.0 µg/L


                                          Zn (mg/L)                      <0.05                         1.0 mg/L


                                         Na (mg/L)                       11.0                          200 mg/L


                                      Sulphate (mg/L)                   <0.018                         250 mg/L


                                         TDS (mg/L)                       105                         1000 mg/L


                                 Anionic surfactant (mg/L)              <0.050                         0.3 mg/L


                                  Oxygen demand (mg/L)                   0.58                           3 mg/L


                                   Volatile phenol (mg/L)              <0.0003                        0.002 mg/L


                                       NO3-N (mg/L)                      2.50                          10 mg/L


                                   Total hardness (mg/L)                 65.0                          450 mg/L


                                        CHCl3 (µg/L)                     <1.4                          0.06 µg/L


                                         CCl4 (µg/L)                     <1.5                         0.002 µg/L


                                   Total α radiation (Bg/L)             <0.043                         0.5 Bg/L


                                   Total β radiation (Bg/L)             <0.015                          1 Bg/L




                                                                 84
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




                                                                                         Referred Standard Limits
Detection         Testin
                                           Items                      Results            of Drinking Water Hygiene
  point           g Time
                                                                                          Standard (GB5749-2006)


                                       NH4-N (mg/L)                      0.104                         0.5 mg/L


                                       Bromate (µg/L)                    <5.0                          0.01 µg/L


                                   Formaldehyde (mg/L)                   <0.05                         0.9 mg/L




                                                                 85
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



     Annex 5: Letter of Commitment




                                                                 86
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China



        Annex 6: Document List
 No.                                                           Document
          EIA report and its approval, Luoyang Urban and Rural Integration Demonstration Zone Management
   1
          Committee, Bureau of Land and Environmental Protection, Feb. 3, 2016

   2      Sewage discharge registration form and its receipt, valid until May 6, 2025

   3      Water withdrawal permit, Luoyang Water Conservancy Bureau, April 2, 2019

   4      Collective land use certificate, Yanshi Bureau of Land and Resources, April 28, 2010

   5      Safety production standardization certificate, valid until May, 2024

          Emergency plan for production safety accidents and its record form, Luoyang Yibin District Management
   6
          Committee, July 18, 2016

   7      Emergency plan for environmental protection, March 10, 2016

   8      Environmental and social management procedure document

   9      System management organization chart

  10      2 labor contracts, 2 samples of personnel file, 2 samples of social security certificate

   11     Official employees’ roster

  12      Temporary workers roster

  13      Production worker attendance records, April-July 2021, Aug.-Oct. 2021

  14      Production worker wage records, April-June 2021, Aug.-Oct. 2021

  15      Training schedule and relevant training records of 2021

  16      Partial chemical inspection report

  17      Management mechanism of wastewater treatment station

  18      Waste packaging drum recycling agreement, valid until Dec. 13, 2022

  19      Waste packing drum register book

  20      1 electrician certificate

  21      Safety management personnel training certificate, Aug. 13, 2020

  22      Annual lightning protection device test report of 2020, Dec. 4, 2020,

  23      Export records of epidemic prevention and control materials, Feb.-May, 2021

  24      Labor protection articles distribution record

  25      List of raw materials

  26      Fire safety daily checklist, Dec. 3, 2021

  27      Enterprise safety inspection self-check form, Dec. 3, 2021

  28      Production, safety meeting record registration form

  29      Safety, production, management training record, 2020

  30      Environmental monitoring report, April 14, 2021, April 1, 2019




                                                                 87
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




     Annex 7: Photolog




 Picture 1: Factory brand                                       Picture 2: Foam extinguishing agent production
                                                                workshop




 Picture 3: Raw material warehouse                              Picture 4: Packaging drum warehouse




 Picture 5: Laboratory                                          Picture 6: Fire extinguishing agent test area




                                                                 88
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




 Picture 7: Waste packaging drums temporary                     Picture 8: Hazardous wastes warehouse
 storage area




 Picture 9: Production workshop exhaust gas                     Picture 10: Wastewater treatment facility
 exhaust cylinder




 Picture 11: Canteen                                            Picture 12: Canteen fume exhaust cylinder




                                                                 89
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




 Picture 13: Dormitory                                          Picture 14: Consultation with Xihan Village
                                                                Committee




 Picture 15: Consultation with Zhuge Town                       Picture 16: Consultation with Xihan Villagers
 Government and environmental protection bureau




 Picture 17: North side of the factory                          Picture 18: East side of the factory




                                                                 90
Luoyang Langchao Fire Technology Co., Ltd -Project of Reduction and Phaseout of PFOS in Priority Sectors in China




 Picture 19: South side of the factory                          Picture 20: West side of the factory




                                                                 91