Recently, the Bureau of Industry and Information Technology of Qiannan Prefecture, Guizhou Province, announced the announcement of the task of rectifying the feedback problem of the ecological environment warning film in the Yangtze River Economic Zone in 2023. The announcement said that the common problems of cement enterprises in the whole province were fed back. Involving Longli The main problem should be the new capacity in violation of regulations. Can it really be considered that the rectification has been completed? In August 2009, Guizhou Provincial Development and Reform Commission approved Qiannan Longli Hongshi Cement Co., Ltd. Phase II with a kiln diameter of 4.8 meters. with a capacity of 4000 tonnes/day " On September 26, 2009, the State Council approved the Circular of the National Development and Reform Commission and other departments on restraining overcapacity and redundant construction in some industries and guiding the healthy development of industries (Guo Fa [2009] No.38). In the Several Opinions on Cement: strictly control the new cement production capacity, implement the principle of eliminating backward production capacity in equal quantities, suspend the construction of cement projects that have not been started before September 30, 2009 and conduct a serious clean-up, and strictly prohibit the construction of projects that do not conform to the above principles. On November 10,
2009, the General Office of the National Development and Reform Commission issued the Notice on Relevant Issues Concerning the Clearance of Cement and Flat Glass Construction Projects. The Notice clearly States that the scope of cement cleaning is the projects under construction that have not been put into operation before September 30, 2009, and the projects that have been approved but not started. The contents of the clean-up are whether the projects under construction conform to the industrial policy, whether the examination and approval procedures are complete, and whether the construction contents are consistent with the declaration contents. Cement projects that have been approved but not started in all provinces, municipalities and autonomous regions shall not be allowed to start construction. Projects that are really necessary to be constructed must be demonstrated and approved by the Commission. On November 16,
2010, the Ministry of Industry and Information Technology issued the Access Conditions for Cement Industry (GY [2010] No.127). "Conditions" clearly States that new cement clinker production line projects must be strictly implemented in accordance with the principle of "equal or reduced elimination".
From the time node, the second line project, whether it has been started or not, should have passed the clean-up and eliminated the backward production capacity of 4000 tons per day. It has entered the stage of construction (or continuation). On October 6,
2013, the State Council issued the Guiding Opinions on Resolving the Serious Contradiction of Overcapacity (Guofa [2013] No.41). According to the list of cement clinker production lines published by the province, Line 2 was completed in December 2013. The project was an illegal project under construction referred to in the Opinion at that time. The document clearly States that for projects that are really necessary to be constructed, on the basis of meeting the requirements of layout planning and environmental carrying capacity, as well as the principle of equal or reduced replacement, the local government shall submit an application report to the Development and Reform Commission, the Ministry of Industry and Information Technology, and copy it to the Ministry of Land and Resources, the Ministry of Environmental Protection and other relevant functional departments. The National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Land and Resources, the Ministry of Environmental Protection and other functional departments shall issue confirmation opinions on the basis of the evaluation by the entrusted advisory bodies, and the relevant departments shall complete the relevant procedures in accordance with the law and regulations. All illegal projects under construction that have not been identified shall not be renewed, and shall be properly handled by the local government itself. The project was completed after the issuance of Document No.41, so the project should be recognized by the relevant ministries and commissions of the central government. At the time of confirmation, the project should have been basically completed soon, and the big kiln had already been in place. The approved kiln diameter was 4.8 meters, but it was built. 5. When dealing with the confirmation of illegal projects under construction, why was the kiln diameter? 5. If the environmental protection facilities have been completed and other environmental protection measures have been implemented in accordance with the requirements of the regulations, the application for trial production has been approved. After the application for trial production is approved by the competent administrative department of environmental protection, the construction unit may carry out trial production. The construction unit shall, within three months from the date of trial production, apply to the competent administrative department of environmental protection with the power of examination and approval for the acceptance of environmental protection for the completion of the construction project.
The main equipment and large kilns do not conform to the kiln diameter which is the main basis of environmental impact assessment. Why is the kiln diameter? 5. The Measures put forward the requirement of cement (clinker) capacity conversion for the first time. The corresponding capacity scale of Φ 4.8 m kiln is 5000 tons per day; Φ5. The Measures require the competent departments of industry and information technology at the provincial level to verify the capacity replacement plan in accordance with the relevant provisions of these Measures, to ensure that the elimination projects are real and the capacity is reasonable, and to specify the time limit for the elimination of replacement capacity.
From the time node, although the document was issued, the project has been completed. Project completion acceptance is to check whether the construction content conforms to the approved content and verify whether the kiln diameter is 4. If the acceptance time is after the promulgation of the Measures, the competent department has an inescapable responsibility. It is necessary to look back, how can completion and acceptance of the project make the construction content of the kiln diameter 5.6 meters pass? 650,000 tons, cement output is 1,659,900 tons, and the output is controlled within the approved capacity range; the comprehensive energy consumption per unit product of clinker is 100.89 Kgce/t, and the energy consumption per unit product of cement is 82.
The cement overcapacity in Guizhou Province is relatively serious, and the kiln shutdown time is too long due to peak staggering. According to the Notice on Staggered Peak Production of Cement Industry in 2024 issued jointly by the Provincial Department of Industry and Information Technology and the Department of Ecology and Environment, all new dry cement clinker production lines in the province are required to carry out staggered peak production, with 180 days for each line, including no less than 60 days in the first quarter, no less than 30 days in the second quarter and no less than 30 days in the third quarter. Not less than 60 days in the fourth quarter. According to this plan, the annual operation time of the cement clinker production line is 185 days. The annual clinker output of 4000 tons/day production line should be 740000 tons, even if it can be overproduced by 10%, it is less than 820000 tons. How is the conclusion drawn that the output is controlled within the approved capacity (1.24 million tons *)? Is it with another 4000 tons/day production line in the factory area to stop one and open one? According to the announcement, the Reply of the Department of Raw Materials Industry of the Ministry of Industry and Information Technology on Issues Related to Replacement of Cement Production Capacity (GYH (2023) No.407) ensures that the actual output is not greater than approved production capacity, implements the control requirements of clinker and cement output, and ensures that the actual output of clinker and cement in the second production line is not more than 1.24 million tons.
5. On October 17, 2024, the Ministry of Industry and Information Technology issued the Measures for the Implementation of Capacity Replacement in the Cement and Glass Industry (2024 version) (Ministry of Industry and Information Technology [2024] No.206). In explaining why the capacity conversion table was cancelled and how to determine the capacity data after the cancellation, the competent authorities said that the main consideration of the cancellation of the capacity conversion table of the approved capacity scale in the Implementation Measures was that with the continuous progress of production technology and equipment level, the capacity approved solely on the basis of the diameter of cement rotary kilns could no longer reflect the actual production capacity. The Implementation Measures make it clear that the production capacity is determined strictly according to the project filing (approval) documents, and the annual production capacity days are calculated according to 300 days. In order to promote the unification of the registered production capacity and the actual production capacity, for the compliance production lines whose actual production capacity is greater than registered production capacity, the difference in production capacity can be supplemented and the relevant procedures such as filing, environmental assessment and energy assessment can be improved in accordance with these Measures. It is stipulated that the capacity of cement clinker production line used for replacement of new projects can not be split and transferred, and that the capacity of cement clinker production line used for technical transformation or completion of completed projects can not be split and transferred more than two projects.
In the Implementation Measures (2024 edition), the actual capacity refers to the capacity that the production line can achieve in actual production. In the previous implementation method, the actual production capacity is calculated and determined according to the kiln (outside) diameter and the cement clinker production capacity conversion table. Φ5. Although the one-to-one correspondence between kiln diameter and capacity has been cancelled, it can not be too disjointed, and the corresponding actual capacity is still lower than capacity that can be achieved in actual production.
Not long ago, Guizhou Province announced a replacement plan for the supplementary capacity of the 6833t/d cement clinker production line project completed in May 2011. The plan shows that the specifications, models and quantities of the main equipment are Φ5.4/5. The re-filed capacity is 6833t/d. It is only 80% of the 8500t/d calculated according to the previous capacity conversion table. This is also a big step towards the unification of record capacity and actual capacity.
At present, there is no measure to make up the difference capacity in the rectification of the project, that is, the approved capacity is only 50% of the 8000t/d calculated according to the previous capacity conversion table. Of course, it is the right of enterprises to organize production according to approved production capacity. The supervision department also inspects according to the approved production capacity. Moreover, the actual situation is that when the production line is produced according to the approved capacity, the energy efficiency can also reach the limit stipulated by the national standard, but after all, it is a big horse pulling a small car, and the matching of the process is obviously unreasonable.
The Energy Conservation Law stipulates that energy-using units shall, in accordance with the principle of rational use of energy, strengthen energy conservation management, formulate and implement energy conservation plans and technical measures to reduce energy consumption. Therefore, how can project achieve the unity of record capacity and actual capacity? How to achieve the best energy efficiency of the production line?
To sum up, the responsibility for the feedback of the ecological environment warning film in the Yangtze River Economic Zone in 2023 has not been traced clearly, not to mention that it can play a warning role, and the rectification task has not taken into account the requirement of the unification of the record capacity and the actual capacity.
