Interpretation of the principles of environmental impact assessment and approval of lithium-ion battery manufacturing construction projects

In order to implement the spirit of the National Conference on Ecological and Environmental Protection, as well as the decision-making and deployment of the Central Committee of the Communist Party of China and the State Council on in-depth pollution prevention and control, support high-quality development with high-level protection, and strengthen the management of environmental impact assessment and approval of construction projects under the new situation of coordinated pollution reduction and carbon reduction in the new era, the Ministry of Ecology and Environment recently revised and issued the "Principles for the Examination and Approval of Environmental Impact Assessment Documents for Cement Manufacturing Construction Projects (2024 Edition)" (hereinafter referred to as the "Approval Principles") to replace the "Principles for the Examination and Approval of Environmental Impact Assessment Documents for Cement Manufacturing Construction Projects (2024 Edition)" (hereinafter referred to as the "Principles for Examination and Approval"). The "Principles for the Examination and Approval of Environmental Impact Assessment Documents for Cement Manufacturing Construction Projects (Trial)" (hereinafter referred to as the "Original Examination and Approval Principles") in the Notice on Printing and Distributing the Examination and Approval Principles for Environmental Impact Assessment Documents for Construction Projects in Seven Industries such as Cement Manufacturing (Huanban EIA [2016] No. 114) (hereinafter referred to as the "Original Examination and Approval Principles") further standardize the examination and approval of environmental impact assessment of cement manufacturing construction projects, and strengthen the guidance for local approval of cement clinker manufacturing "two high" construction projects and cement kiln co-disposal of solid waste construction projects. It is of great significance to promote the ultra-low emission and green and low-carbon transformation and development of the industry.

The first is to clarify the scope of application. According to the needs of environmental management, the "Approval Principles" further clarifies its applicable objects, covering the scope of construction projects consistent with the "Original Approval Principles", with reference to the "Catalogue of Classified Management of Environmental Impact Assessment of Construction Projects (2021 Edition)" (hereinafter referred to as the "2021 Edition"), it is clear that the construction projects that apply the approval principles include three categories: (1) cement manufacturing projects (including cement grinding stations), corresponding to the project categories in the "2021 Edition" of the Directory for cement, lime and gypsum manufacturing in 301 cement manufacturing (including cement grinding stations); (2) Limestone mining project (cement clinker manufacturing supporting), corresponding to the project category in the "2021 List" is soil sand and gravel mining 101 (excluding river sand mining projects); (3) Cement kiln co-disposal of solid waste projects, corresponding to the project categories in the "2021 Edition" of the directory is hazardous waste utilization and disposal, general industrial solid waste (including sewage treatment sludge) disposal and comprehensive utilization, and domestic waste (including kitchen waste) centralized disposal. According to the "Pollution Control Standard for Solid Waste Co-disposal by Cement Kilns" (GB 30485), the solid waste in the cement kiln co-disposal solid waste project, in addition to hazardous waste, domestic waste (including waste plastics, waste rubber, waste paper, waste tires, etc.), municipal and industrial sewage treatment sludge, also includes animal and plant processing waste, contaminated soil, emergency waste, etc.

The second is to add new cement clinker production capacity in key areas of air pollution prevention and control. The cement industry is a traditional overcapacity industry, and in order to implement the requirements of "strictly prohibiting new cement clinker production capacity in key areas" in the in-depth battle of pollution prevention and control, this new content is proposed. The key areas in the "Approval Principles" at this stage refer to the "2+36" cities in Beijing-Tianjin-Hebei and surrounding areas, 13 cities in the Fenwei Plain, and 31 cities in the Yangtze River Delta region in the Action Plan for Continuous Improvement of Air Quality (Guo Fa [2023] No. 24), a total of 82 cities.

The third is to put forward new requirements for new reconstruction and expansion projects to encourage ultra-low emissions. The cement industry is a key air pollution control industry, and the industry has a large amount of pollutant emissions, and the current national industry standard control requirements are generally loose. In order to implement the requirements for promoting the ultra-low emission transformation of cement industry enterprises in the in-depth battle of pollution prevention and control, combined with the content of the "Opinions on Promoting the Implementation of Ultra-low Emissions in the Cement Industry" (hereinafter referred to as the "Ultra-low Opinions") formulated by the Ministry of Ecology and Environment, the "Examination and Approval Principles" put forward requirements for encouraging ultra-low emissions for new construction, reconstruction and expansion of cement clinker manufacturing projects and cement grinding station projects. (1) Comprehensively propose high-standard environmental protection facilities that effectively control pollutant emissions. This time, combined with the "ultra-low opinions", the requirements for organized, unorganized and clean transportation were proposed. In terms of organized emission control, the cement kiln is equipped with a low-nitrogen burner, adopts low-nitrogen combustion technologies such as staged combustion and fine control of oxygen content in other decomposition furnaces, and adopts combined denitrification technologies such as selective non-catalytic reduction (SNCR) and selective catalytic reduction (SCR) in the exhaust gas at the kiln tail to take effective measures to control ammonia escape. The cement kiln and the kiln tail waste heat utilization system (kiln tail) and cooler (kiln head) should be built simultaneously with advanced and efficient dust removal facilities; When the sulfur content in the raw fuel is high and the sulfur dioxide in the flue gas cannot be stably discharged, a desulfurization facility should be set up. In terms of fugitive emission control, the storage and transportation of dust-producing materials should be sealed or closed. In terms of clean transportation, limestone and other raw materials are preferentially transported into the factory by clean methods such as railways, waterways, tubular belt conveyors, belt corridors, etc., and new energy or national VI emission standard vehicles should be used for automobile transportation in the factory to further provide application scenarios for new energy heavy trucks. Through the EIA to implement the requirements of the above measures, so that the relevant pollutant emission concentration of the new reconstruction and expansion project is better than the standard discharge, through the EIA in the source strength accounting and prediction evaluation, etc., and finally determined in the form of pollutant emissions, for the follow-up pollutant discharge permit to effectively control the discharge of key pollutants, according to the law enforcement supervision to provide strong support. (2) There are restrictions on the types of construction projects that achieve ultra-low emission levels. In the "Approval Principles", for "projects relying on existing cement kilns for co-disposal of solid waste", based on the consideration that the implementation plan for carbon peaking in the building materials industry supports the use of cement kilns to co-dispose of solid waste to achieve carbon reduction and is consistent with the scope of application in the "Ultra-low Opinions", no ultra-low emission requirements are proposed. This requirement shall be implemented if the new construction, reconstruction and expansion of cement clinker manufacturing projects are synchronously equipped with the function of co-disposal of solid waste. (3) Clarify the requirements for meeting emission standards. In view of the non-standard implementation of emission standards in the EIA approval, and some approval departments directly quote the pollutant emission limits specified in the management documents instead of the emission standards, according to the category of the construction project, the "Approval Principles" classifies and lists the emission standards that should be implemented for the discharge of pollutants in the project, so as to ensure that the bottom line of compliance and compliance with the standard in the EIA and approval of the project is maintained, and the pollutant emission standards that are stricter than the current applicable standards are not proposed.

Fourth, it has supplemented and improved the relevant requirements of the cement kiln co-disposal solid waste project. In recent years, the cement industry approval projects are mainly cement kiln co-disposal solid waste projects, and with the continuous deepening of the industry's dual carbon work, raw fuel substitution as one of the effective ways to reduce carbon emissions, with the support and encouragement of national policies, the number of cement kiln co-disposal solid waste projects will continue to grow, and cement kiln co-disposal solid waste projects are mainly approved at the county level. In order to strengthen the guidance for the environmental impact assessment and approval of cement kiln co-disposal solid waste projects, firstly, the content of solid waste control into the kiln is added, combined with the provisions of the "Pollution Control Standard for Solid Waste Co-disposal in Cement Kilns" (GB 30485), the "Technical Specification for Environmental Protection of Solid Waste Co-disposal in Cement Kilns" (HJ 662) and the "Guidelines for the Review of Business Licenses for Co-disposal of Hazardous Wastes in Cement Kilns (Trial)", it is clear that the type, scale, location and facilities of solid waste co-disposal in kilns should be determined in accordance with the above-mentioned standards and specificationsto ensure that the heavy metal emissions of such projects meet the requirements of the standards and the environmental impact is controllable. Secondly, the requirements for pollution prevention and control measures are put forward in a targeted manner, and it is clarified that the kiln tail dust removal of the cement kiln co-disposal solid waste project should adopt high-efficiency bag (or electric bag composite) dust removal facilities; Storage facilities that treat waste gas by introducing into the high-temperature area of the cement kiln should also be equipped with other gas purification devices for use during the shutdown of the cement kiln. Thirdly, the requirements for the emission control of bypass vented air are clarified. It is proposed that the bypass exhaust flue gas of the cement kiln co-disposal solid waste project should be combined with the kiln tail flue gas, and if the combined discharge cannot be combined, the same emission control requirements of the kiln tail flue gas should be met.

Fifth, the environmental impact assessment of greenhouse gases has been added. First of all, in order to implement the requirements of including greenhouse gas control in the EIA management proposed in the battle of pollution prevention and control, and combined with the cement industry (cement clinker manufacturing) as a pilot industry for the environmental impact assessment of carbon emissions determined by the Ministry of Ecology and Environment, it is proposed to include greenhouse gas emissions in the environmental impact assessment of cement clinker manufacturing projects, calculate the greenhouse gas emissions of the project, promote the synergy of pollution reduction and carbon reduction, and promote the demonstration and application of carbon reduction technology innovation. Secondly, combined with the "Implementation Plan for Carbon Peaking in the Building Materials Industry" (Ministry of Industry and Information Technology Lianyuan [2022] No. 149) and the "14th Five-Year Plan" National Cleaner Production Implementation Plan (Fagai Huan Zi [2021] No. 1524), etc., requirements are put forward from the pilot demonstration aspects of raw material substitution, fuel substitution, energy efficiency improvement, and carbon capture, utilization and storage integration.