I. Company Overview

In 2004, Songtao Sanhe Manganese Industry Group Co., Ltd. completed and put into operation the first production facility, featuring a 20,000-ton-per-year electrolytic metallic manganese production line. In 2009, the company expanded and upgraded the facility, launching the second production plant with a 30,000-ton-per-year capacity. In October 2015, the company initiated a comprehensive technical upgrade project for its 50,000-ton-per-year electrolytic metallic manganese production line. This project leveraged the existing capacities of the original first plant (20,000 tons/year) and the second plant (30,000 tons/year), phasing out the older 20,000-ton-per-year production line from the first plant while expanding and upgrading the second plant to accommodate an additional 30,000 tons/year. As a result, the entire 50,000-ton-per-year production line was thoroughly modernized and relocated to the second plant. Today, the company operates four separate electrolytic metallic manganese production lines, each with a capacity of 12,500 tons per year. The manganese slag storage facility continues to utilize the infrastructure originally built alongside the second production plant. The project covers a total area of 91,943 square meters, with a total investment of 213.955 million yuan. Of this, 17.4 million yuan has been allocated to environmental protection measures, accounting for 8.13% of the overall investment.

II. Status of Completed Procedures

1. The comprehensive upgrade and technical renovation project for the 50,000 t/a electrolytic metallic manganese production line was filed with the Industrial and Commerce Bureau of Songtao Miao Autonomous County (Document No. Songgongmao Planning [2015] No. 7, dated August 31, 2015). The project’s Environmental Impact Assessment Report was evaluated by the Guizhou Provincial Environmental Engineering Assessment Center and subsequently approved by the Guizhou Provincial Department of Ecology and Environment under Document No. Qianhuan Assessment [2015] No. 195 and Approval No. Qianhuan Review [2016] No. 23. Construction of the project commenced in October 2015, followed by a trial run on December 7, 2016. On August 17, 2017, the project successfully obtained the Environmental Protection Acceptance Filing for Completed Construction Projects (Filing No.: 520000-2017-114). Additionally, on September 7, 2018, the project passed the Clean Production Audit and received approval (Document No. Qianhuan Qingjie [2018] No. 124). In 2020, the clean production audit process was entrusted to the third-party agency, Guizhou Huarui Technology Co., Ltd., which prepared the relevant report.

2. Has obtained a pollution discharge permit (Certificate No.: 91520628755387186G002P)

3. Solid Waste Situation

1. In the first half of 2021, the accumulated stockpile of manganese slag reached 78,000 m³, with approximately 800,000 m³ currently stored.

2. The waste oil and laboratory waste liquids collected in 2020 have been handed over to qualified organizations for proper disposal. In the first half of 2021, the laboratory recorded an intake of 240.8 kg of waste liquids and 708.95 kg of waste mineral oil.

3. In the first half of 2021, 797 tons of anode slag were generated and are currently being sold to relevant ferroalloy plants for waste utilization.

IV. Operation Status of Environmental Protection Equipment and Facilities:

1. The ore stockpile area in the grinding workshop is equipped with a canopy, dust-control measures, and a mist-spraying system. Ore transportation is carried out via enclosed conveyor belts. The grinding process utilizes fully enclosed negative-pressure equipment, while dust generated by both the crushing system and the high-pressure roller mill are individually treated by two baghouse dust collectors. Additionally, a single-machine dust collector is installed atop each storage bin, ensuring that the overall dust collection efficiency meets or exceeds 99.5%.

2. The chemical pulping system is equipped with two sets of dust removal equipment, where the collected dust is reused for pulp preparation. The well-prepared solution is then transported via pipelines, effectively preventing secondary contamination. Additionally, four acid mist treatment towers have been installed in the leaching process; after treatment meets the required standards, the exhaust gases are released through a 15-meter-high stack, ensuring that the emitted dust complies with the Level 2 standards outlined in the "Comprehensive Emission Standard for Air Pollutants" [GB16297-1996]. Both the dust collection and acid mist treatment systems, as well as the acid mist towers, are operating smoothly. Furthermore, the chemical reaction tanks are fitted with containment dikes designed to prevent overflow of the chemical solution, and these dikes show no signs of damage or leakage.

3. The electrolysis workshop uses energy-saving and environmentally friendly high-molecular RPP electrolytic cells installed on elevated racks. The floor is treated with a "three fabrics and five oils" method plus corrosion-resistant bricks to prevent leakage, with no damage or leaks observed. The workshop is equipped with silent axial-flow fans for air exchange and ventilation.

4. The filtration workshop is equipped with high-efficiency filter presses, achieving a moisture content of approximately 24% in the filtered manganese slag. The filtered slag is then conveyed via conveyor belt to the slag storage area, ensuring compliance with environmental impact assessment requirements.

5. Wastewater generated from production, leachate from the slag storage area, and initial rainwater are all recycled for use in the production water system and solution system. Domestic wastewater is collected, treated, and then discharged via the municipal network to the Songtao Economic Development Zone’s domestic wastewater treatment plant for further processing.

V. Operation Status of Pollution Control Equipment and Facilities

1. One wastewater treatment station, equipped with 1 station manager and 9 employees; it has a daily wastewater treatment capacity of approximately 1,200 m³. The station includes a wastewater treatment tank with a volume of 620 m³, a storage tank holding 600 m³, and a filtration system with a total filter volume of 13 m³, along with 2 plate-and-frame filter presses and supporting equipment.

2. One set of slag storage area online monitoring system and one set of plant-wide pollution source online monitoring system have been installed, with operations and maintenance managed by Guizhou Jinhong Environmental Technology Co., Ltd., ensuring smooth operation. Additionally, the installed video surveillance system is functioning properly.

3. One rainwater collection tank with a capacity of 2,500 cubic meters, one storage tank also with a capacity of 2,500 cubic meters, and two sets of pumps have been installed. Additionally, there is one emergency accident pool with a capacity of 1,000 m³ equipped with two pump sets. The two pumps used for leachate lifting and reuse—consisting of one operational unit and one backup—are functioning properly. This ensures that in case of an emergency, the pumped materials are directed to either the centralized accident emergency pool or reused in production processes.

4. Sulfuric acid tanks, nitric acid tanks, and ammonia solution tanks are equipped with containment berms, which show no signs of damage or leakage. Eye wash stations and shower facilities are functioning properly.

5. The leachate collection pool set up for the slag storage area, along with the emergency collection pools for sulfuric acid, ammonia solution, and rainwater, are all intact and show no signs of damage. Additionally, the associated valves, pumps, and pipelines are functioning properly, with no evidence of cracks, drips, or leaks observed.

6. The manganese slag storage facility and its associated safety and environmental protection systems are operating normally. Three groundwater quality monitoring wells have been properly set up and are functioning as intended.

7. The manganese sand filter system installed for the cooling tower and cooling circulating water is operating normally, with no splashing of cooling water during operation. Additionally, there are no signs of leakage in the cooling circulation water tank.

8. One ammonia-nitrogen treatment facility has been constructed, with a daily capacity of approximately 500 m³, and the facility is operating normally.

9. An emergency supplies warehouse has been established, managed by dedicated personnel, and equipped with appropriate emergency materials and vehicles tailored to various rescue scenarios, ensuring a reliable supply of resources in case of an accident.

6. Pollution Prevention and Environmental Emergency Response Measures

1. An environmental management organization, the Safety & Environmental Protection Department, and a wastewater treatment plant have been established, along with comprehensive environmental protection systems and clearly defined job responsibilities.

2. Entrust a qualified third-party testing organization to conduct regular quarterly monitoring of the company’s pollution sources, as well as water quality at the inlet and outlet points of culverts and monitoring wells, and along river cross-sections. Additionally, carry out periodic sampling and analysis of river cross-sections to ensure effective prevention and management of pollutants. This approach will help achieve comprehensive environmental protection, management, remediation, and identification of any gaps or deficiencies. Monitoring for the first and second quarters of 2021 has already been completed.

3. A dedicated person conducts daily safety and environmental inspections, while actively carrying out monthly checks for potential hazards in emergency environmental incident management and risk-prevention measures against sudden environmental events—and maintaining detailed records of these activities.

4. All departments and workshops involving water usage are equipped with water meters, and a dedicated person monitors the daily water consumption of each workshop. Monthly assessments are conducted based on the established water-use evaluation plan, rewarding employees for water conservation and penalizing those who exceed their allocated limits.

5. Establish comprehensive rules and procedures for managing the slag storage facility, develop a slag storage operation plan, set up a duty room, and assign dedicated personnel to oversee daily maintenance of all equipment in the facility, as well as maintain detailed operational logs and records.

6. Strictly follow the requirements to develop environmental emergency plans for the plant area and slag storage facility. The emergency plan prepared in September 2019 has already been filed with the environmental authorities. In the first half of 2021, a drill was conducted once to simulate an unexpected environmental incident at the slag storage facility.

7. During the flood season, dedicated personnel will conduct regular safety inspections and maintain on-duty presence at the slag storage area, hazardous chemical warehouse, and production facilities. This ensures that any potential hazards are promptly reported and addressed, while identified risks are handled without delay, safeguarding the company’s normal operations.

Songtao Sanhe Manganese Industry Group Co., Ltd.

July 15, 2021