Interpretation of the "Principles for the Examination and Approval of Environmental Impact Assessment Documents for Electrolytic Aluminum Construction Projects (2024 Edition)".

The electrolytic aluminum industry is the basic industry of China's national economy, and it is also a high-energy-consuming and high-emission industry, and it is a serious overcapacity industry in the "Guiding Opinions of the State Council on Resolving the Contradiction of Serious Overcapacity" (Guo Fa [2013] No. 41), and in the past five years, the electrolytic aluminum production capacity has been transferred from the key areas of air pollution prevention and control to Inner Mongolia, Yunnan, Sichuan and other energy-rich areas. In order to further improve the management efficiency of electrolytic aluminum construction projects, unify the management scale, strengthen source prevention and control, and promote the synergy of pollution reduction and carbon reduction in heavily polluting industries, the Ministry of Ecology and Environment recently issued the "Principles for the Examination and Approval of Environmental Impact Assessment Documents for Electrolytic Aluminum Construction Projects (2024 Edition)" (hereinafter referred to as the "Approval Principles"), which is the first time that the principles for the examination and approval of environmental impact assessment documents for electrolytic aluminum construction projects have been formulated. It is of great significance to promote the synergy of pollution reduction and carbon reduction in the industry.

The first is to clarify the scope of application. Based on the "Catalogue of Classified Management of Environmental Impact Assessment of Construction Projects (2021 Edition)", the scope of application is given for the approval of the environmental impact assessment documents of construction projects of "electrolytic aluminum in 321 commonly used non-ferrous metal smelting" and "carbon anode/cathode for aluminum in graphite and other non-metallic mineral products manufacturing 309", and the scope of application is connected with the environmental rating management directory. The purpose of the construction of the carbon project for aluminum is to serve the electrolytic aluminum industry, and the implementation of the "Aluminum Industry Pollutant Emission Standard" (GB 25465), so it is clearly included in the scope of application.

The second is to reiterate the requirements of industrial policy. The "Guiding Opinions of the State Council on Resolving the Contradiction of Serious Overcapacity" (Guo Fa [2013] No. 41) clearly requires that relevant departments and institutions shall not handle the environmental impact assessment and approval of new capacity projects in industries with serious overcapacity, and the "Implementation Plan for Carbon Peaking in the Industrial Sector" and the "Implementation Plan for Carbon Peaking in the Non-ferrous Metals Industry" both require adhering to the constraints on the total production capacity of electrolytic aluminum, strictly implementing the capacity replacement method, and studying the differentiated electrolytic aluminum production capacity reduction and replacement policy. The 2023 Central Economic Work Conference also pointed out that overcapacity in some industries is a difficulty and challenge that needs to be overcome. Therefore, the "Examination and Approval Principles" proposes that "projects involving the increase of electrolytic aluminum production capacity shall complete capacity replacement according to the requirements of the national industry management department". In November 2021, the "Opinions of the Central Committee of the Communist Party of China and the State Council on Deepening the Battle of Pollution Prevention and Control" put forward requirements such as "resolutely curbing the blind development of high-energy-consuming and high-emission projects" and "strictly prohibiting new steel, coking, cement clinker, flat glass, electrolytic aluminum, alumina, and coal chemical production capacity in key areas".

The third is to clarify the site selection requirements. The "Regulations on the Administration of Environmental Protection of Construction Projects" stipulates that "if the regional environmental quality does not meet the national or local environmental quality standards, and the measures to be taken by the construction project cannot meet the management requirements of the regional environmental quality improvement objectives, the administrative department of environmental protection shall make a decision not to approve the environmental impact report and the environmental impact report form", combined with the possible environmental impact of fluoride in electrolytic aluminum construction projects, in order to protect the continuous improvement of the ecological environment quality of China's high-fluoride areas, the "Examination and Approval Principles" are clear" Strictly restrict the construction and expansion of new and expanded electrolytic aluminum and carbon projects for aluminum with residues in areas where ambient air, surface water, groundwater, and soil fluoride exceed the standard".

Fourth, strengthen pollution prevention and control measures. First of all, in terms of waste gas prevention and control, Article 7 of the Law on the Prevention and Control of Air Pollutants clearly stipulates that "enterprises, institutions and other producers and operators shall take effective measures to prevent and reduce air pollution", but some existing electrolytic aluminum enterprises have not built desulfurization facilities, and the sulfur dioxide emission intensity of the electrolytic aluminum industry in non-key areas is significantly higher than that in key areas, and the construction requirements of desulfurization facilities should be put forward for new electrolytic aluminum projects. According to the "Comprehensive Treatment Plan for Air Pollution in Industrial Furnaces and Kilns", the "Approval Principles" put forward that "electrolytic flue gas should be equipped with high-efficiency desulfurization facilities such as limestone-gypsum method", and clarified the pollution control measures for unorganized waste gas in the process of residual cooling, electrolyte cleaning, and electrolyzer roasting start-up; Since the carbon project for aluminum involves raw asphalt, the "Approval Principles" put forward the requirements for the collection and treatment of volatile organic compounds, and clarified that "the control of fugitive emissions of volatile organic compounds in the plant shall meet the requirements of the "Fugitive Emission Control Standard for Volatile Organic Compounds" (GB 37822)"; The production and emission of pollutants such as particulate matter in the process of aluminum ash heat recovery is obvious, and the "Approval Principles" proposes that "aluminum ash heat recovery involving aluminum should be equipped with high-efficiency flue gas collection systems and dust removal facilities". Secondly, it emphasizes the requirements of the industry's initial rainwater collection and treatment standards, and clearly builds the initial rainwater tank in accordance with the relevant requirements of the "Code for Environmental Protection Engineering Design of Non-ferrous Metals Industry" (GB 50988). Finally, the principle of solid waste reduction, recycling, and harmlessness should be strengthened, and the requirements for the treatment and disposal of overhaul slag, aluminum ash slag, carbon slag, waste tar, and residual anode should be clarified. For example, the implementation of the implementation of the entry standards for overhaul slag should be pretreated before entering the flexible landfill in the industry, and the "Approval Principles" proposes that "stable pretreatment facilities must be built to ensure that the concentration of harmful components in the overhaul slag leaching solution does not exceed the control limit of hazardous waste allowable landfill"; From the current industry practice, there is a risk of illegal disposal of the unit that undertakes the disposal of electrolytic cell overhaul slag by an external unit, and the waste anode generated by the electrolytic aluminum project without supporting the anode system has the risk of entering the furnace of other enterprises as fuel, resulting in the transfer of fluoride pollution. In view of the characteristics of aluminum ash slag that is easy to produce ammonia in a humid environment, the "Approval Principles" proposes that "ammonia collection devices and gas purification facilities should be set up in aluminum ash storage warehouses".

Fifth, implement the requirements for regional reduction of pollutants. In order to implement the requirements of the "Opinions of the Central Committee of the Communist Party of China and the State Council on Deepening the Battle of Pollution Prevention and Control", strictly control the access points of high-energy-consuming and high-emission projects, and strictly implement the requirements for regional reduction of pollutant emissions, the "Examination and Approval Principles" proposes that "construction projects with new major pollutant emissions should implement the requirements of the Notice on Strengthening the Supervision and Management of Regional Reduction Measures for Construction Projects in Key Industries" (Environmental Assessment [2020] No. 36).

Sixth, promote the supervision of the whole process of fluoride. Fluoride is a characteristic pollutant of electrolytic aluminum construction projects, and the "Approval Principles" strengthen the supervision of fluoride from the aspects of project site selection, source strength accounting, atmospheric environmental impact prediction, waste gas pollution control, wastewater pollution control, comprehensive utilization of solid waste, and environmental monitoring plan. For example, the construction of projects in areas with excessive fluoride standards will be strictly restricted; In view of the source intensity accounting process, it is proposed that the calculated source strength of organized and unorganized fluoride should be analogous to the measured values of similar enterprises in production, and the gaseous fluoride and solid fluoride should be accounted for separately, and the requirements for the accounting method of source strength of fugitive emission waste gas are proposed. The pollution prevention and control measures put forward the requirements for the collection and treatment of waste gas in the electrolyzer roasting process and the residual cooling process, and clarified that the flue gas in the electrolyzer roasting startup process and the residual cooling process should be collected and discharged into the electrolytic flue gas purification system. When the atmospheric environmental impact prediction is carried out in the electrolytic aluminum workshop, it is distinguished between gas fluorine and solid fluorine, and it is proposed that the start of electrolytic cell roasting should be predicted as an abnormal working condition.

Seventh, greenhouse gas emissions will be included in the management of environmental impact assessment. The annual electricity consumption of the electrolytic aluminum industry exceeds 500 billion kilowatt hours, accounting for about 6.8% of the total electricity consumption of the whole society, and the carbon emissions are about 420 million tons, accounting for 64% of the carbon emissions of the entire non-ferrous industry. In order to implement the requirements of "incorporating greenhouse gas control into environmental impact assessment management" in the "Opinions of the Central Committee of the Communist Party of China and the State Council on Deepening the Battle of Pollution Prevention and Control", the Ministry of Ecology and Environment issued the "Guiding Opinions on Coordinating and Strengthening the Work Related to Climate Change and Ecological Environmental Protection" and the "Notice on Carrying out the Pilot Environmental Impact Assessment of Carbon Emissions of Construction Projects in Key Industries", steadily promoting the inclusion of greenhouse gas control in the environmental impact assessment work, and taking the non-ferrous industry as a pilot industry for the environmental impact assessment of carbon emissions of construction projects. In order to implement the above requirements, the "Approval Principles" clearly include greenhouse gas emissions in the environmental impact assessment of electrolytic aluminum projects, and encourage the adoption of collaborative pollution reduction and carbon reduction technologies.