I. Company Overview

In 2004, Songtao Sanhe Manganese Industry Group Co., Ltd. completed and put into operation its first 20,000-ton-per-year electrolytic metallic manganese production line at Factory No. 1. In 2009, the company expanded and upgraded the facility, launching a second 30,000-ton-per-year electrolytic metallic manganese production line at Factory No. 2. 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 involved repurposing the existing capacities from the original Factory No. 1 (20,000 tons/year) and Factory No. 2 (30,000 tons/year), phasing out the older 20,000-ton-per-year line at Factory No. 1, and expanding and upgrading the 30,000-ton-per-year line at Factory No. 2. As part of this initiative, the entire 50,000-ton-per-year production line underwent a full-scale technological overhaul and was relocated to Factory No. 2. The project now comprises four separate electrolytic metallic manganese production lines, each with a capacity of 12,500 tons per year. Additionally, the manganese slag storage facility was repurposed from the infrastructure originally built to support Factory No. 2. The project covers a total area of 91,943 square meters, with a total investment of 213.955 million yuan. Environmental protection measures account for 17.4 million yuan of the total investment, representing 8.13% of the overall budget.

In 2021, in accordance with the "Better Complete Industrial Upgrading and Achieve Dual Reduction Goals" directive from the Electrolytic Manganese Innovation Alliance under the National Manganese Industry Technical Committee, our company accumulated a two-month production halt.

II. Status of Solid Waste and Hazardous Waste Management

1. In 2021, the cumulative stockpile of manganese slag entering the facility was 151,700 m³, with approximately 900,000 m³ currently stored.

2. In 2021, the laboratory generated 468.85 kg of waste liquid, which was properly stored in the warehouse. Additionally, 2.87717 kg of waste mineral oil was produced and also stored securely. Both the waste oil and laboratory waste liquid were handed over to a qualified organization for disposal before December 26, 2021.

3. In 2021, approximately 1,700 tons of anode slag were generated and sold to relevant ferroalloy plants for waste utilization.

III. Operation Status of Environmental Protection Equipment and Facilities:

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

2. The chemical pulping system is equipped with two sets of dust removal equipment, where collected dust is reused for pulp preparation. The well-prepared solution is then transported via pipelines, eliminating the risk of secondary contamination. Additionally, four acid mist treatment towers have been installed in the leaching process; after treatment meets the required standards, the discharged dust is released through a 15-meter-high exhaust stack, ensuring compliance with the Class II emission limits 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 in an elevated setup. The floor is treated with a "three-layer fabric and five layers of oil" method plus corrosion-resistant bricks to prevent leakage, with no damage or leakage observed. The workshop is equipped with silent axial-flow fans for air exchange and ventilation.

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

5. Production wastewater, leachate from the slag storage area, and collected early-stage rainwater—after treatment—are all reused in the production water system and solution systems.

6. Domestic wastewater is collected and treated separately before being discharged via the pipeline network to the Songtao Economic Development Zone Wastewater Treatment Plant for advanced processing.

IV. Pollution Prevention and Control Management Practices

1. An environmental management organization, the Safety & Environmental Protection Department, and a wastewater treatment station have been established, along with comprehensive environmental protection systems, job responsibilities, and operational procedures. The station is equipped with one station manager and 9 employees, capable of treating approximately 1,850 m³ of manganese-containing wastewater daily, as well as handling up to 500 m³ of ammonia-nitrogen-containing effluent. It features a wastewater treatment tank with a capacity of 620 cubic meters, a storage tank holding 600 cubic meters, and a filtration system with a total volume of 13 cubic meters. Additionally, the station is outfitted with two plate-and-frame filter presses and associated 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. Entrust a qualified third-party testing service organization to conduct regular quarterly monitoring of the company’s pollution sources, inlet and outlet points of culverts, water quality at monitoring wells, river cross-sections, and soil conditions. This includes equipment comparison tests and periodic sampling of river cross-sections to ensure effective prevention and management of pollutants. The initiative aims to achieve comprehensive environmental protection, management, remediation, and thorough identification of any gaps or deficiencies. In 2021, quarterly monitoring was completed and the results were published on the monitoring platform, with all tested parameters meeting the relevant national standards.

4. All departments and workshops involving water usage are equipped with water meters, and a dedicated person monitors daily the water consumption of each workshop. This data is then evaluated monthly against the established water-use assessment plan: rewards are given for conservation efforts, while penalties are imposed for exceeding the allocated limits.

5. Sulfuric acid tanks, nitric acid tanks, and ammonia solution tanks are equipped with containment berms that show no signs of damage or leakage. Eyewash stations and shower facilities are functioning properly.

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

7. The manganese slag storage facility and its associated safety and environmental protection systems are operating normally. Three groundwater quality monitoring wells are functioning as intended.

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

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

V. Environmental Emergency Response and Prevention Measures

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

2. Daily, dedicated personnel conduct safety and environmental inspections. Each month, proactive efforts are made to identify potential risks in emergency environmental incident management and to review risk-control measures for unexpected environmental events, with thorough record-keeping maintained.

3. The installed rainwater collection tank (2500 m³ capacity), along with its associated pump system (two sets of pumps), the emergency accident tank (1000 m³ capacity) equipped with another two pump sets, and the leachate boosting and reuse system featuring two pumps (one working, one standby) are all operating smoothly. This ensures that in case of an emergency, materials can be safely directed either to the centralized accident emergency tank or reused directly in production processes.

4. 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 strengthen daily maintenance management and maintain detailed operational logs for all equipment in the slag storage facility.

5. Strictly follow the requirements to prepare environmental emergency plans for the plant area and slag storage facility (prepared in September 2019 and already filed with the environmental authorities). In 2021, one emergency drill was conducted specifically for sudden environmental incidents at the slag storage facility, along with another drill focused on hazardous waste leakage accidents.

6. 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.

7. No environmental pollution incidents or complaints were reported in 2021.

Songtao Sanhe Manganese Industry Group Co., Ltd.

January 10, 2022