Recently, the Department of Ecology and Environment of Shandong Province issued the "Central Eco-environmental Protection Supervision of Mass Letters and Visits Reporting and Border Supervision and Reform (the sixteenth, seventeenth and eighteenth batches)", announcing the overproduction of several cement enterprises, a total of 17 cement enterprises were named. Among them, the cement enterprises with the largest overproduction have a production capacity of 4000 tons per day, with an average daily output of about 8000 tons in 2025 and an overproduction rate of 100%. After the disclosure of the overproduction situation of the cement industry
in Shandong Province, it quickly aroused widespread concern in the industry. In view of the core issues of general concern in the industry, the author collates relevant information for the reference of the industry:
1. Will overproduction increase the total amount of pollutants, energy consumption and carbon emissions?
In recent years, the domestic cement industry has continued to deepen the treatment of pollutants, and many enterprises have achieved ultra-low emission transformation. In the field of energy consumption management and control, with the systematic promotion of energy-saving technology transformation, the comprehensive energy consumption index of clinker production has been significantly optimized.
However, from the perspective of total carbon emissions, its correlation with overproduction is actually weak. As a rigid demand product, the total market volume of cement exists objectively, and the production adjustment of an enterprise will not change the overall demand pattern-the reduction or shutdown of production can not eliminate the demand, and the market vacancy will soon be filled by other subjects. Based on the characteristics of cement production process, as long as production is maintained, carbon dioxide emissions are inevitable, and this attribute does not change with the fluctuation of production capacity of a single enterprise.
Therefore, there is not a simple linear positive correlation between total pollutant emissions, total energy consumption, total carbon emissions and clinker production, and overproduction behavior may not directly lead to the synchronous rise of the above three indicators.
However, it should be noted that the expansion of production line scale through technical transformation can be completely in accordance with the national capacity replacement policy and environmental protection policy, the replacement of the replacement and the environmental assessment of the environmental assessment. Neither want to implement capacity replacement, nor want to re-EIA, blindly striving to reduce unit consumption through overproduction is the negation of the concept of enterprise innovation and development, which runs counter to the direction of national policy guidance.
2. How much overproduction of clinker production line needs to be re-evaluated?
In January 2018, the Ministry of Ecology and Environment issued the Notice on the Issuance of the List of Major Changes in Construction Projects in Fourteen Industries, such as Pulp and Paper, attached to the List of Major Changes in Cement Construction Projects (Trial Implementation). The list of major changes in cement construction projects (for trial implementation) is applicable to cement manufacturing (including supporting mines and co-processing) and the construction of independent grinding stations. The first provision is that the production capacity of cement clinker shall be increased by 10% or more, and the mining capacity of supporting mines or the production capacity of cement grinding shall be increased by 30% or more. Article 24 of
the Environmental Impact Assessment Law clearly States that if the nature, scale, location, production process or measures to prevent pollution and ecological damage of a construction project have changed significantly after the approval of the environmental impact assessment document of the construction project, the construction unit shall re-submit the environmental impact assessment document of the construction project for approval.
In short, production lines with clinker overproduction of 10% or more are major changes in scale and need to re-submit EIA documents for approval! What
cement enterprises should do is to produce in strict accordance with the approved production capacity, and to re-submit the EIA documents in time if there is an overproduction of 10% or more. Of course, we should not forget that part of the overproduction capacity needs to go through the procedures of capacity replacement and replace the corresponding capacity, otherwise it is also illegal!
3. How to punish cement enterprises for overproduction? The basis and methods of punishment for overproduction of
cement enterprises are mainly as follows:
① According to the Measures for Administrative Penalties for Illegal Acts in Production Safety, if a production and business operation entity carries out production beyond the approved production capacity and intensity, it shall be given a warning and may be fined not less than 10,000 yuan but not more than 30,000 yuan. The principal person in charge and other relevant personnel shall be fined not less than 1000 yuan but not more than 10000 yuan.
② According to the Law of the People's Republic of China on Environmental Impact Assessment and the Interim Regulations on the Management of Carbon Emission Trading, if the output of clinker exceeds 110% of the registered production capacity, the enterprise may be fined according to law, and the relevant responsible persons shall be given administrative sanctions; If the clinker production data is falsified, it will directly violate the Provisional Regulations on the Management of Carbon Emission Trading, and the enterprises, legal representatives and relevant responsible persons involved may be fined, and their carbon emission quotas for the next year shall be reduced by 50% -100%, and those with serious circumstances shall be ordered to stop production for rectification.
③ According to the Regulations on the Administration of Pollutant Discharge Permits, if a pollutant discharge unit discharges pollutants in excess of the permitted discharge concentration and quantity, the competent department of ecological environment shall order it to make corrections or restrict production or stop production for rectification, and impose a fine of not less than 200,000 yuan but not more than 1 million yuan; If the circumstances are serious, the pollutant discharge permit shall be revoked, and with the approval of the people's government with the power of approval, it shall be ordered to suspend business or close down.
In addition, local governments will also issue relevant policies to regulate the production behavior of cement enterprises according to local conditions. For overproduction enterprises, local governments may take measures including but not limited to ordering rectification, interview warning and restricting power supply. For enterprises with bad circumstances and repeated prohibition, joint punishment will be imposed on the main body of the enterprise, the legal representative and the person directly responsible in strict accordance with the law and regulations.
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