Comprehensive Renovation Project for the Coke Oven System of Baoshan Iron and Steel Co., Ltd

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Environmental Impact Assessment for the Comprehensive Upgrade Project of Baoshan Iron and Steel Co., Ltd.’s Coke Ovens. Issued by: Shanghai Institute of Environmental Sciences. Date of issuance: August 3, 2009. Relevant link: First public announcement of the environmental impact assessment. 1.1 Background of the project construction: Baoshan Iron and Steel Co., Ltd. currently has 12 coke ovens, all located in the coking plant of its subsidiary. These ovens were built in three phases, with 4 coke ovens each having 50 chambers and a diameter of 6 meters in each phase; this results in a total of 6 production units. The designed annual capacity for producing coke is 5.18 million tons, while the actual annual output is 5.33 million tons, meaning an excess production of 150,000 tons per year. Additionally, by-products such as coke oven gas and tar are produced as well. 　　The first-phase coke ovens have exceeded their designed service life, while the second-phase coke ovens suffer from inherent deficiencies due to poor quality of refractory materials and inadequate oven drying processes; both phases of these coke ovens are now in a state of severe wear and degradation. Based on the design life of the coke ovens, as well as considering the actual operating conditions of these ovens and the time required for overhauls, in order to ensure their reliable and stable operation, two large-scale rotating coke ovens with 7m carbonization chambers and 55 tuyeres will be built within the existing plant area. These ovens will replace the old set of two coke ovens with 6m carbonization chambers and 50 tuyeres from the first phase of Baosteel Co., Ltd. (Ovens 1A and 1B). 　　The newly built rotating coke oven will have an annual coke production capacity of 1.35 million tons. Once it is put into operation, the production at the two old coke ovens will be stopped immediately for major repairs. The remaining 10 existing coke ovens in the coking plant will operate at a reduced capacity, with a production volume of 4.18 million tons per year; thus, the total annual coke production of the entire plant remains at 5.33 million tons, remaining unchanged before and after the technical upgrades. Project construction can, without altering the existing coke production capacity, sequentially carry out major overhauls of the 12 existing coke ovens on site, thereby achieving energy savings and emission reductions in coke production through technological upgrades. 　　1.2 Project Overview The site for the construction of this project’s revolving coke ovens is located in the northwest corner of Baosteel’s coking plant. The construction will be carried out using the land that results from the demolition of the original No. 2 and No. 3 heavy oil storage tanks and other facilities, as well as after partial rerouting of the river used to protect the plant. This project can make full use of existing railways, roads, and transportation equipment, as well as existing utilities such as power supply, water, steam, and nitrogen, thereby saving a significant amount in infrastructure investment and land use. 　　During the construction of the replacement coke ovens, the old coke ovens (1A and 1B) continued to operate. Once the replacement coke ovens were completed and put into operation in December 2011, the two old coke ovens were shut down, with the shutdown taking place in January 2012. 　　The total investment for the project is 1,823.2 million RMB, of which 171.2 million RMB is allocated to environmental protection measures, accounting for approximately 9.4% of the total project investment. The area designated for engineering purposes is approximately 112,000 m², of which 22,400 m² is covered with greenery, giving a green coverage rate of 20%. 　　The project involves the construction of 2 carbonization chambers with a capacity of 7m each, as well as large-scale regenerative coke ovens with 55 chambers; the annual coke production capacity is 1.35 million tons, while the amount of by-product waste gas generated is 608060×103 m³ per year. The construction scope includes new construction projects, replacement projects, utilization of existing facilities projects, and supporting projects. The new construction project consists of a 2×55-chamber 7m coke oven system, which includes a coal preparation workshop (expanded), a coking workshop, a coke screening system, as well as production auxiliary facilities ； The alternative project involves replacing a set of 2×50-hole 6m old coke ovens (1A, 1B) from Baosteel’s Phase I facility ； The asset utilization project aims to make full use of Baosteel’s existing external supporting utilities ； The supporting projects are approved separately to meet the construction requirements of this project, and are not included within the scope of this environmental impact assessment. 　　1.3 Situation of nearby sensitive targets The project is located within the large manufacturing complex of Baosteel in Baoshan District, Shanghai, and is close to the Yangtze River ； The atmospheric assessment area for this project is a circular zone with a diameter of 7.2 km centered on the project site; the atmospheric environmental protection distance required for coke ovens is 1000 m. The atmospheric assessment area for environmental risks is a circular zone with a diameter of 10 km centered on the project site, while the range affected severely by risk incidents (i.e., the safety distance) is 280 m. 　　The specific sensitive targets within the scope of the project evaluation are listed in Table 1-4 of the general introduction section of the report. The main sensitive targets in this scope are the town area of Yuepu Town, Shengqiao Community, and other scattered villages; the nearest sensitive target is located 1.8 km away from the project site. It can be seen that there are no sensitive targets within the atmospheric environmental protection distance and safety distance required for the project, thus meeting the requirements for such distances. 　　1.4 Clean Production Analysis This project is a comprehensive upgrade and renovation of coke ovens; the ovens used are of the 7m carbonization chamber type, and facilities for dry quenching of coke, coal charging, and coke pushing along with dust removal systems are also installed as part of this project. These measures meet the requirements specified in the \"Access Conditions for the Coke Industry\" and the \"Clean Production Standards for the Coke-Baking Industry\". 　　The evaluation compares and analyzes it with the \"Clean Production Standards for the Coking Industry\" from five aspects: production process and equipment requirements, resource and energy utilization indicators, product indicators, pollutant generation indicators, and environmental management requirement indicators. Apart from a few cases where the data met the secondary standards, the vast majority satisfied the requirements of the primary standards. Compared with domestic advanced coke ovens, this project as a whole reaches the domestic advanced level. 　　The project adheres to the principles of clean production, controlling the generation and emission of pollutants at the source of the manufacturing process, and strengthening environmental management ； Advanced and reliable treatment technologies are employed for the pollutants emitted, ensuring that all emissions meet the specified standards ； After the renovation, both energy consumption and pollutant emissions were reduced to a certain extent ； The project meets the relevant requirements of the \"Guidelines for Developing a Circular Economy and Protecting the Environment in the Steel Industry\" in terms of energy recovery, water resource recycling, and solid waste recycling ； The project effectively implements the spirit of the Shanghai Energy Conservation and Emission Reduction Implementation Plan. Therefore, this evaluation concludes that the current coke oven renovation project meets the requirements of clean production and can reach an advanced level of clean production in China. 　　1.5 Environmental Protection Measures and Emission Compliance 　　1.5.1 Waste Gas Treatment Measures 　　(1) Dust Treatment Measures for Coal Preparation Processes 　　Pulse bag filters are installed at locations where dust is generated, such as the coal secondary crushing rooms, coal humidification facilities, coal loading ports in coal towers, and coal transfer stations, to treat the coal dust-containing waste gas. The efficiency of these dust removal systems exceeds 99.5%, and after being purified to meet regulatory standards, the waste gas is released into the atmosphere through exhaust stacks. 　　(2) Waste gas treatment measures for the coal loading system The exhaust gas from the coal loading system is of intermittent nature; therefore, a surface dust removal system is installed, which consists of both mobile and fixed components. The mobile device is installed on the coal loading vehicle, while the fixed device is placed on the ground. When loading coal into the coke oven, the high-pressure ammonia water system in the rising pipe of the coke oven is activated first, creating a certain negative pressure within the rising pipe; this allows some of the dust generated during coal loading to be drawn into the exhaust collection pipe. The dust that escapes through the coal loading holes is absorbed by the mobile cover and then sent via pipes to the dust removal system on the ground for purification. Once it meets the required standards, it is released into the atmosphere through exhaust stacks. 　　(3) Flue gases from coke oven heating and combustion The fuel used for coke oven heating is a mixture of coke oven gas and blast furnace gas, with the main pollutants in the flue gases being SO2, NOX, and a small amount of particulate matter. The project adopts high chimneys for compliant emissions, with a chimney height of 145m. 　　(4) Waste gas treatment measures for the coke pushing system The exhaust gas from the coke pushing system is of intermittent nature; therefore, a surface-based dust removal system is installed. This system uses suction cups to draw the gas in through pipes, sends it to the surface dust removal system for purification, and then releases it into the atmosphere via exhaust stacks after it meets the required standards. 　　(5) Dry quenching coke dust removal system: The high-temperature flue gas generated at the top of the coke tanks and at the exhaust openings of the circulation fans is captured by suction hoods. First, the temperature of this flue gas is reduced using coolers; thereafter, it mixes with the low-temperature dust-laden air from the coke discharge ports, the conveyor belts at those ports, and the new coke transfer station. The resulting mixture then enters a pulse bag filter for purification, with a dust removal efficiency of 99.5%. The purified gas is subsequently discharged into the atmosphere through fans and silencers. 　　(6) Dust removal system for the screening and storage of coke: Pulse bag filters are installed at locations where dust is generated, such as the coke storage area in front of the furnace, the coke screening facilities, and the coke transfer stations, to treat the coke dust-containing exhaust gases. The efficiency of these dust removal systems exceeds 99.5%, and after being purified to meet the required standards, the exhaust gases are released into the atmosphere through exhaust stacks. 　　The emission concentrations and rates of the main process exhaust gases mentioned above meet the requirements of the secondary standards specified in the \"Comprehensive Emission Standards for Air Pollutants\" (GB16297－1996) ； Among them, the emissions of H2S and NH3 meet the requirements of the \"Emission Standards for Odorous Pollutants\" (GB14554-93) ； The airborne pollutants emitted in an uncontrolled manner from the coke oven body meet the requirements of the secondary emission standards for newly built mechanized coke ovens as specified in the \"Emission Standards for Air Pollutants from Coke Ovens\" (GB16171-1996). 　　1.5.2 Wastewater treatment measures The wastewater generated during the production process mainly includes: condensate water from gas pipelines, water used for gas sealing, floor washing water produced in the coal preparation workshop and coking screening section, washing water from various floors, and wastewater from dry quenching processes. 　　The wastewater from dry quenching of coke is clean water with only a high salt content and no other pollutants; it can be discharged directly into Baosteel’s protective river. Other production wastewater is sent to the phenol-cyanide wastewater treatment plant of the chemical company for treatment. After treatment, the discharge parameters will meet the requirements of the second-level standards set out in the \"Comprehensive Wastewater Discharge Standards\" (DB 31/199-2009), and the treated water will be discharged into Baosteel’s protective river in compliance with these standards. 　　1.5.3 Solid waste treatment measures The coal dust collected by the coal loading and preparation dust removal systems amounts to approximately 4,544.65 tons per year, which is returned to the process system for reuse ； The coke dust collected by the coking and coke treatment dust removal systems amounts to approximately 1683**4 tons per year, while the coke dust collected by the dry quenching coke dust removal system amounts to about 18,895.31 tons per year. After being humidified, this dust is transported back to the sintering system using tank trucks for reuse. 　　Therefore, the treatment and disposal plan for the project’s solid waste is feasible, with a treatment rate of 100%, which meets the solid waste control requirements set by environmental regulations. 　　1.5.4 Noise control measures 　　While meeting the requirements of process design, low-noise equipment should be preferred for various pumps, air compressors, gas blowers, dust removal fans, and other similar devices. These devices should be placed in enclosed areas to reduce noise transmission, and sound-absorbing or sound-insulating building materials should be used to prevent noise from spreading. Mufflers are installed at the outlets of each dust removal fan, air compressor, and air blower ； Sound insulation measures have been taken at the coke discharge device, circulation fans, circulation gas pipes, and other similar locations. 　　In the overall plant layout design, the terrain, the directionality of sound sources, and the level of noise in the workshops are taken fully into account. By utilizing structures, buildings, and green plants to shield and absorb noise, a rational layout is established to reduce the impact of noise. 　　After the above measures are taken, the intensity of environmental noise in this project will be significantly reduced, and the noise generated by high-noise equipment will be under control, resulting in minimal impact on the noise level at the factory boundaries. 　　1.6 Environmental Impact Assessment 　　1.6.1 Air Environmental Impact Assessment 　　(1) During the trial operation of the rotating coke oven, while the coke oven to be replaced was still in use, with an alternating period of about 2 months: Under normal operating conditions, based on the hourly, daily, and annual weather data for Baoshan District in 2008, the ground-level hourly concentrations, daily average concentrations, and annual average concentrations of PM10, NO2, SO2, H2S, NH3, benzene, BaP, and total non-methane hydrocarbons all met the concentration limits set by environmental air quality standards. The maximum hourly, daily average, and annual average ground concentration values of various pollutants within the evaluation range were all recorded at the location of Baosteel’s coke oven facility. 　　Under abnormal operating conditions, under hourly meteorological conditions throughout the year, the maximum hourly ground-level concentration of SO2 for environmental air quality protection objectives ranges from 0.088 to 1.667 mg/m³, while the maximum hourly ground-level concentration of PM10 ranges from 0.121 to 2.123 mg/m³. At sensitive locations, these values exceed the hourly concentration limits set by environmental air quality standards, or the equivalent converted hourly concentrations (0.45 mg/m³ for PM10). 　　After being combined with the current background values, the concentrations of H2S and PM10 will exceed the limits set by environmental air quality standards, which is mainly due to the excessive levels of the current background values. The combined effects of other pollutants all meet the corresponding environmental air quality standard limits. 　　(2) Once the new coke ovens in this project are completed and put into operation, the two existing old coke ovens will cease to operate. At the same time, the operating load of the other coke ovens will decrease, resulting in a reduction in pollutant emissions. Taking into account the combined effects of the old and new coke ovens, and after combining them with the current baseline values, the concentrations of various pollutants at sensitive sites meet the corresponding environmental standards, thereby improving the local air quality. 　　(3) The main source of unorganized emissions for this project is the coke oven itself. The calculated environmental protection distances for various pollutants show that the greatest distance required for BaP is 700 meters. Meanwhile, in accordance with the provisions of the \"Standards for Health Protection Distances in Coking Plants\" (GB 11661-89), for newly built coking plants as well as projects for their expansion or renovation, with an average annual wind speed of 2–4 m/s, the health protection distance is set at 1000 meters. In accordance with the principle of strict environmental protection, the atmospheric environmental protection distance required for the coke ovens in this project is 1000 meters. There are no sensitive facilities such as residential areas, schools, or hospitals within a 1000-meter radius around the project site, thus meeting the requirements for this protection distance. 　　(4) Recommendation: After the completion of this project, efforts should be made to shorten the alternating operation time between the old and new coke ovens, to shut down the old coke ovens as soon as possible, and at the same time to reduce the operating load on the other coke ovens in order to cut down pollutant emissions. 　　After the new coke oven comes online, every effort should be made to prevent abnormal emissions, ensuring that the impact of this coke oven project on sensitive areas is minimized. 　　1.6.2 Environmental Impact Analysis of Water 　　(1) The wastewater discharged from the proposed project mainly consists of production wastewater and cleaning wastewater; the total amount of wastewater discharged is 177,127 m³/year ； Compared with the current situation, once the proposed project is in normal operation and the coke production volume remains unchanged, the amounts of wastewater generated and major pollutants emitted will be reduced by 13,100 m³/year, CODcr by 3.77 tons/year, SS by 0.73 tons/year, volatile phenols by 0.04 tons/year, and petroleum compounds by 0.88 tons/year, which will contribute to the improvement of the regional water quality. 　　(2) The 20 m3/h of wastewater temporarily generated during the 2-month trial operation of the proposed project will be sent to the existing phenol-cyanide wastewater treatment plant of the chemical company for treatment. The design treatment capacity of the phenol-cyanide wastewater treatment plant at the chemical company is 258 m3/h; there is currently a remaining capacity of 58 m3/h, which is sufficient to handle the additional 20 m3/h of wastewater that will be generated during the trial operation phase of this project. The impact of the temporarily added small amount of treated, up-to-standard effluent discharge on the water quality of Baosteel’s protective river is minimal. 　　1.6.3 Acoustic Environmental Impact Assessment 　　(1) Under normal conditions during the trial operation phase of the proposed project, the combined effect of the noise generated by the project’s equipment and the background noise results in the noise levels at the east and north boundaries of Baosteel remaining roughly the same as they are currently. That is, the daytime noise levels at these boundaries still meet the Class 3 standards specified in the \"Emission Standards for Environmental Noise at Industrial Enterprise Boundaries (GB12348-2008)\". At night, however, the noise levels exceed the allowed limits due to the influence of ship traffic on the Yangtze River and road traffic; as a result, the combined noise level also exceeds the limits. Nevertheless, the additional noise impact caused by the project’s equipment on the nighttime noise levels at the north and east boundaries is relatively small, at 0.1 dB(A) and 0.7 dB(A) respectively. Outside the northern and eastern boundaries of Baosteel Co., Ltd. are the Yangtze River and Baosteel’s protective river, respectively; there are no environmentally sensitive sites, so the noise generated by the project’s equipment has a minimal impact on the environment. 　　(2) Once this project is completed and put into operation, the two old coke ovens, 1A and 1B, will be shut down for major repairs; at that time, the noise generated by the plant’s equipment as a whole will not have any additional impact on the eastern and northern boundaries of Baosteel Corporation. 　　(3) Since this project is located far away from the factory boundaries surrounding Baosteel, it has little impact on the acoustic environment at those boundaries during both day and night, and it will not change the existing level of the acoustic environment. The project site is surrounded by Baogang Steel Plant areas, with the nearest residents located 1.8 km away; therefore, there will be no noise disturbance to the local residents. It is also recommended that the coking branch plant strengthen noise control measures on a regular basis, particularly in terms of the maintenance of equipment that generates noise, to ensure that no abnormal operations occur. 　　1.7 Environmental Risk Analysis This project is a comprehensive upgrade and renovation of Baosteel’s coke oven system. The gas involved in the production process is flammable, explosive, and toxic; various internal and external factors can lead to hazardous accidents, with material leaks being the main cause of environmental pollution as well as fire and explosion incidents. 　　After identification, carbon monoxide and hydrogen sulfide were determined as the evaluation factors, while the blast furnace gas transmission pipelines and the coke oven off-gas transmission pipelines were identified as major sources of project risks. The project’s environmental risk assessment is conducted at the primary level, with the scope of atmospheric risk assessment covering areas within 5 kilometers of major hazard source points. 　　According to the analysis, the main source of accidents in the project comes from the gas transmission pipelines. Predictions of the affected area show that following a leak in the blast furnace gas transmission pipeline, the impact of CO is most severe under conditions of low wind speeds and the worst possible stability of atmospheric conditions; the concentration level at which death can occur is 180 m, the distance over which there is a severe impact is 270 m, the distance over which there is a moderate impact is 400 m, and the distance over which there is a mild impact is 520 m ； Following a leak in the coke oven off-gas transmission pipeline, the impact of H2S is most severe under conditions of low wind speed and poor F stability; the lethal concentration range is 200 m, the distance at which severe effects occur is 280 m, the distance for moderate effects is 700 m, and the distance for mild effects is 1700 m. The main impact area of the project risk incidents is within the Baogang Steel Plant site; the nearest sensitive targets are located 1,800 meters away, and there are no residential areas within the area of severe impact. Therefore, the risk level is acceptable. The impact of CO from the leakage incident on residential areas outside the plant area is mainly an excessive level of environmental air quality over a short period of time ； The impact of H2S from the leakage incident on residential areas outside the plant area is mainly characterized by a strong, unpleasant odor and temporary exceedances of environmental air quality standards. At a distance of 5 km within the scope of the risk assessment, the concentration of H2S was 0.05 mg/m3, which exceeds the olfactory threshold for H2S of 0.035 mg/m3; hence, the impact range is relatively large. 　　Overall, leaks and explosions of materials at the project site can have an impact on the surrounding environment and local population. Therefore, the project has implemented a series of risk prevention measures to reduce the likelihood of such incidents occurring and to mitigate their effects. 　　1.8 Pollutant Emissions of the Project and Changes Before and After the Renovation The changes in pollutant emissions before and after the project’s renovation are detailed in Table 17-1. As can be seen from the table, all pollutants have decreased to varying degrees after the reform of the coke oven. Table 17-1 Summary Table of Total Wastewater Discharge from the Coke Oven System Before and After Renovation
(t/a) | Pollution Source | Pollutant | Emission Amount in Existing Coke Oven System | Emission Amount under This Project | Reduction Amount through “Replacing Old with New” | Total Emission Amount after Construction | Overall Increase/Decrease | Overall Reduction Rate

| Waste Gas | Volume of Waste Gas (10^4 m³/a) | 564,800 | 882,867 | 011,754 | 705,301 | 208 | -346,800 | 6.14% |
| Soot and Dust | 1,733.71 | 124.65 | 388.19 | 1592.05 | -141.66 | 8.17% |
| SO2 | 1,086.63 | 169.63 | 251.50 | 1,004.76 | -81.87 | **3%** |
| NOx | 2,763.59 | 484.85 | 636.99 | 2,611.45 | -152.14 | 5.5% |
| H2S | 14.30 | 2.16 | 4.31 | 12.15 | -2.15 | 15.0% |
| NH3 | 1,050.09 | 16.13 | 2**493.68 | -11.41 | 10.8% |
| BSO4 | 1.35 | 8.51 | 10.56 | 39.3 | -2.05 | 5.0% |
| BaP | 0.03 | 20.00 | 51 | 0.009 | 0.0281 | -0.003 | 912.2% |
| Benzene | 29.41 | 16.08 | 7.62 | 27.87 | -1.54 | 5.2% |
| Non-methane Hydrocarbons | 122.60 | 26.64 | 31.21 | 118.03 | -4.57 | 3.7% |

| Waste Water | Volume of Waste Water (10^4 m³/a) | 228.05 | 17.71 | 19.01 | 209.05 | -1.31 | 0.6% |
| SS | 72.45 | 11.35 | 12.08 | 71.73 | -0.73 | 1.0% |
| CODcr | 128.85 | 17.71 | 21.48 | 125.09 | -3.77 | 2.9% |
| Volatile Phenols | 0.44 | 70.03 | 0.07 | 0.40 | -0.04 | 8.9% |
| Petroleum Products | 5.38 | 0.02 | 0.90 | 4.50 | -0.88 | 16.3% |

1.9 The project meets the requirements for total emission control.
The total emission targets for pollutants from the coking plant have not been allocated separately; they are included within Baosteel’s overall emission control targets. After the reform of the project’s coke ovens, the reduction in SO2 emissions was 81.87 t/a, while the reduction in CODcr emissions was 3.77 t/a. After the renovation, the total SO2 emissions of Baosteel’s branch were 4,950.90 tons per year, which is lower than the target amount of 6,000 tons per year set for this branch ； The total CODcr emission is 358.91 t/a, which is lower than the target amount of 900 t/a set for Baosteel’s branch. Therefore, the pollutant emissions for this item meet the total emission control requirements set by Shanghai and Baosteel Co., Ltd. Table 17-2 Total emissions of pollutants from Baoshan Steel’s branch plants (t/a)
Pollutant | Total target value | Original emission volume | Change after renovation | Emission volume after renovation
SO2 | 60005032.77 | –81.87 | 4950.90
COD | 900362.68 | –3.77 | 358.91

1.10 Summary conclusions of the report
This project involves the production of coke and coke oven gas for steelmaking using coal as raw material. It falls under the category of projects involving the deep processing and comprehensive utilization of coal tar. It is one of the industries encouraged by China for development ； The project construction is in line with ** and Shanghai’s industrial policies, the entry requirements for the coking industry, as well as Baoshan District’s overall regional development plan ； Before and after the technical upgrades, Baosteel’s total coke production capacity remains unchanged; the newly built rotating coke ovens enable the sequential overhaul of the existing 12 coke ovens in their original locations, and technological upgrades help achieve energy savings and emission reductions in coke production ； The project involves replacing a set of 2×50-hole 6m old coke ovens in Baosteel’s first phase with a new 2×55-hole 7m coke oven system. The production process is more advanced, meeting the requirements set out in the \"Clean Production Standards for the Coke Industry\" and the \"Guidelines for Environmental Protection in the Development of a Circular Economy in the Steel Industry\", and it satisfies the demands related to clean production as well as energy conservation and emission reduction ； The project has implemented various targeted pollution control measures to ensure that pollutants are discharged at levels that meet the required standards, thereby minimizing their impact on environmental quality and preventing any deterioration in the regional environmental quality ； After the renovation, pollutant emissions were reduced, achieving an increase in production while simultaneously reducing pollution ； The pollutant emissions from the project meet the total emission control requirements set by Shanghai and Baosteel Co., Ltd. 　　The majority of the public supports the construction of this project. Meanwhile, the developer has pledged to strictly abide by environmental protection laws and regulations, as well as to comply with the requirements related to environmental protection measures, ensuring the proper operation of environmental control facilities. The results of the environmental risk assessment show that there are no residents within the affected area by potential risk incidents, and the risk level is acceptable. 　　Therefore, from the perspective of environmental protection, it is feasible to carry out the renovation and construction of this project within the existing coking plant area of Baoshan Iron and Steel Co., Ltd., provided that all the environmental protection measures outlined in this report are implemented.