Cement and Glass Industry (2024 edition) clearly States that the amount of capacity used for replacement shall be determined strictly in accordance with the capacity specified in the project filing (approval) documents. In the subsequent interpretation of the policy, it was said that in order to promote the unification of the registered capacity and the actual capacity, for the compliance production lines whose actual capacity is greater than registered capacity, the difference in capacity can be made up in accordance with these measures and the relevant procedures such as filing, environmental assessment and energy assessment can be improved. It is stipulated that the capacity of cement clinker production line used for technical transformation or completion of completed projects can not be transferred more than two projects.
For the cement clinker production line, the first priority is the capacity replacement plan. How does the situation that the actual production capacity is greater than record production capacity occur? In explaining why the capacity conversion table was cancelled, he said that with the continuous progress of production technology and equipment level, the capacity approved solely on the basis of the diameter of cement rotary kiln could not reflect the actual production capacity. There is no mention of "in view of the existence of the phenomenon of" approving small and building large "in the construction of cement clinker projects" mentioned in previous measures.
In the process of "criticizing small and building big", part of it is due to various reasons (known from top to bottom), and the range of "small" is limited. Part of it is a solid "small building", "small" range is too large.
If it does not involve reconstruction and expansion, the continuous progress of production technology and equipment level will limit the increase of production capacity. After all, the feasibility study of the project has been carefully done by the design Institute, which has a detailed discussion on the project construction content, scale and output scheme, project construction conditions, resource and environment guarantee, project construction technology scheme, equipment scheme, production and operation scheme, safety guarantee scheme, etc. After the project is put into production, it is probable that the production line will exceed the original design capacity, but the normal design redundancy should not be taken into account.
If the supplementary capacity of the production line greatly exceeds the capacity of the record (including approval), it seems pale to say that the level of production technology and equipment has improved. Or the project filing is to "approve the small and build the big", and the production capacity to be supplemented is too large; or with the mentality that the production capacity index can not be "wasted", the more is the better, and the new filing capacity is too large.
According to the capacity conversion of the previous replacement method, the corresponding capacity scale of Φ4.8 m kiln is 5000 t/d. Due to various reasons, many projects have reduced the registered production capacity to below 5000 t/d (one point). It is the way for normal production and operation of the production line to supplement or skip or skip to 5000 t/d this time, and relevant procedures such as filing, environmental assessment and energy assessment shall be improved after the balance capacity is supplemented according to the requirements of the Replacement Measures. Without any "operation"
on the grounds of supplement, the capacity scale of Φ4.8 m kiln is raised like a "satellite", 6000 t/d, 6500 t/d, and even 7000 t/d. Even if 4500 t/d is not intentionally lowered at the time of filing, the increase in production capacity is as high as 40%. The effect of expanding production capacity is better than that of general projects. With
such a high capacity scale, the construction content, scale and output scheme, project construction conditions, resource and environment guarantee, project construction technology scheme, equipment scheme, production and operation scheme and safety guarantee scheme in the feasibility study of the original project can be said to have changed beyond recognition.
Such a large-scale and output change can no longer be limited to the addition, subtraction, multiplication and division of the project capacity replacement scheme, the listing of equations, and the implementation of the relevant procedures for major changes such as environmental assessment and energy assessment, but should be compared with the reconstruction project, referring to the "Reference Outline for the Preparation of Feasibility Study Report of Enterprise Investment Projects" issued by the National Development and Reform Commission (2023 edition). The design consulting unit is requested to conduct a feasibility study again on the project construction conditions, resource and environment guarantee, project construction technology scheme, equipment scheme, production and operation scheme, safety guarantee scheme, etc., and make conclusions and suggestions.
If you still pay for it, it is like investing in the production line of purchasing capacity indicators, which costs a lot of money according to the market situation. The project investment and financing and financial plan should also be supplemented. Make investment estimation, profitability analysis, financing plan, debt repayment ability analysis and financial sustainability analysis. At present, in particular, we should take into account the fact that the supply of cement continues to exceed demand and the utilization rate of production capacity can not be raised, so we should not follow the trend and make prudent decisions. The original feasibility study report should be a fraudulent unqualified report
for the project of "approving small projects to build large ones". In the process of promoting the unification of record capacity and actual capacity, the past mistakes should be corrected and the feasibility study should be carried out again.
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