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Reply regarding the environmental impact report for the Shenhua Baotou Coal-to-Olefins Upgrading Demonstration Project

2020-03-29View Original

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Approval regarding the Environmental Impact Assessment Report for the Shenhua Baotou Coal-to-Olefins Upgrade Demonstration Project Author/Source: Ministry of Ecology and Environment of the People’s Republic of China Date: 2020-03-27 Views: 73 Shenhua Baotou Coal Chemical Co., Ltd.: We have received your company’s request for approval of the Environmental Impact Assessment Report for the Shenhua Baotou Coal-to-Olefins Upgrade Demonstration Project (Document No. Shenbao Meihan [2019] 44). After examination, the approval is as follows: 1. The project is located in the Jiuyuan Industrial Park of Baotou City, Inner Mongolia Autonomous Region. It involves expanding an existing coal-to-olefins plant with a capacity of 600,000 tons per year to 700,000 tons per year, while also upgrading and modernizing the existing facility. The proposed project will use the coal resources in western Inner Mongolia as raw material, and employ processes such as pressurized coal gasification, purification, methanol synthesis, and methanol-to-olefins conversion to produce 700,000 tons per year of polyolefin products. Following the expansion, the production capacity for coal-to-olefins products will increase from the current 600,000 tons per year to 1.3 million tons per year.   The main components of the project include units for coal gasification under pressure, shift reaction, low-temperature methanol washing, sulfur recovery, methanol synthesis, methanol to olefins (MTO), polyethylene production, polypropylene production, and air separation. Utility and auxiliary engineering mainly includes tank farms, circulating water systems, flare systems, etc. Environmental protection projects mainly include wastewater treatment systems, reclaimed water systems, evaporation crystallization units, exhaust gas treatment facilities, oil and gas recovery devices, and the construction of a new off-site slag yard. Additionally, certain public utility and auxiliary works as well as environmental protection facilities within existing projects will be renovated, expanded, or upgraded. The main products of the project are 400,000 tons per year of polyethylene and 350,000 tons per year of polypropylene, while the main by-products include sulfur, among others.   The project construction meets the overall requirements of the \"Environmental Access Conditions for Modern Coal Chemical Industry Projects (Trial)\“. The project is located in the middle and upper reaches of the Yellow River. Baotou City, where it is situated, is a water-scarce region; currently, the levels of inhalable particulate matter and fine particulate matter in the ambient air exceed the standards. There is significant pressure to improve the regional environmental quality. Therefore, it is necessary to strictly implement various pollution prevention and control measures as well as environmental risk prevention measures, formulate and enforce stringent environmental management systems and monitoring plans, and establish a timely and effective emergency response and coordination mechanism. After comprehensive consideration, our department principally agrees to the nature, scale, process, location of the construction project, as well as the environmental protection measures outlined in your company’s environmental impact report.   II. The following tasks should be given priority in project construction and operation management: (1) Implement the relevant requirements for ecological protection and high-quality development in the Yellow River Basin, adopt the concepts of ecological protection and environmental quality improvement. During design, construction, and operation, in line with the goals of \"environmental protection first\" and \"green development\", as well as the principles of circular economy and clean production, it is necessary to further optimize process routes and design schemes, use high-quality equipment and raw materials, and strengthen energy-saving, consumption-reducing, and water-saving measures in various facilities, thereby reducing the generation and emission of pollutants at the source.   (II) Strictly implement various measures for air pollution prevention and control. Depending on the properties of the pollutants in various process exhaust gases, treatment methods such as washing, incineration, filtration, and recycling are employed. The processing capacity and efficiency of these treatment facilities must be sufficient to ensure that emissions of various air pollutants comply with ** and relevant local standards.   Dusty exhaust gases generated from coal silos, transfer stations, etc. are treated using bag filter technology, and are discharged after meeting the secondary standards of the \"Integrated Emission Standards for Air Pollutants\" (GB16297-1996). The waste gas from coal drying in the gasification unit is treated with bag filters for dust removal; after meeting the specific emission limits specified in the \"Emission Standards for Pollutants in the Petrochemical Industry\" (GB31571-2015), it is released into the atmosphere.   The waste gas from low-temperature methanol washing is treated using a water washing process; it is discharged only after meeting the emission limits specified in the \"Emission Standards for Pollutants in the Petrochemical Industry\" (GB31571-2015) as well as the requirements of Grade 2 standards set out in the \"Emission Standards for Odorous Pollutants\" (GB14554-93) ; The exhaust gas scrubber of the existing low-temperature methanol washing unit was modified, and as a result, the exhaust gas from this unit meets the emission limit requirements specified in the \"Emission Standards for Pollutants in the Petrochemical Industry\" (GB31571-2015). The regenerated waste gas from the MTO unit is treated to meet the special emission limits specified in the \"Emission Standards for Pollutants in the Petrochemical Industry\" (GB31571-2015) before being released.   The sulfur recovery unit employs a process consisting of “hydrogenation reduction + selective oxidation + tail gas incineration + alkali washing”. After meeting the special emission limits stipulated in the “Emission Standards for Pollutants from Petroleum Refining Industry” (GB31570-2015) and the secondary standards outlined in the “Emission Standards for Offensive Odor Pollutants” (GB14554-93), the tail gas is discharged at high altitude ; Desulfurization upgrades are carried out on the existing sulfur recovery units in the plant; after the upgrades, the exhaust gases meet the special emission limits specified in the \"Emission Standards for Pollutants in the Petroleum Refining Industry\" (GB31570-2015). The regenerated waste gas from the C4/C5+ comprehensive utilization unit is sent to the waste heat boiler of the MTO unit for treatment. For the polyethylene and polypropylene plants, hydrocarbon-containing gases and dust-laden waste gases are treated respectively by catalytic combustion and bag filtration. The treated exhaust gases are discharged only after meeting the special emission limits stipulated in the “Emission Standards for Pollutants from the Synthetic Resin Industry” (GB31572-2015).   Dust removal retrofits are carried out on existing incinerators for industrial waste alkali liquor; after the retrofits, the exhaust gas meets the “Pollution Control Standards for the Incineration of Hazardous Wastes” (GB18484-2001) ; Implement ultra-low emission upgrades on the boilers in existing power station facilities.   The project will not install any new coal-fired boilers; heating and steam supply will rely on the existing power stations of the facility. Compressors located in areas that are not classified as explosion-hazardous, such as those in the air separation units, will be powered by electric drives.   Strengthen control measures for pollution caused by volatile organic compounds (VOCs), foul odors, and toxic and harmful gases, so as to effectively control fugitive emissions. Establish a leak detection and repair system, and regularly inspect the static and dynamic sealing points of equipment and facilities. Improvement measures such as the installation of oil and vapor recovery devices are taken for the existing internal floating roof methanol storage tanks and MTBE loading platforms, respectively. The sewage treatment station is equipped with a covered and sealed structure. For existing sewage treatment stations, measures are taken to modify them into covered and sealed structures. The collected waste gases are treated using the “biological deodorization + activated carbon adsorption” process. Only after meeting the requirements stipulated in the “Emission Standards for Odorous Pollutants” (GB14554-93) and the “Emission Standards for Pollutants from the Petrochemical Industry” (GB31571-2015) can the waste gases be discharged. Earnestly implement waste gas pollution control measures for coal storage bins and similar facilities.   A 1,200-meter atmospheric environment protection zone is established around the plant area, while a 250-meter atmospheric environment protection zone is set up around the slag yard.   The total annual emissions of sulfur dioxide, nitrogen oxides, soot and dust, and VOCs for this project shall not exceed 31.04 tons/year, 342.14 tons/year, 101.41 tons/year, and 282.52 tons/year, respectively.   Drawing on existing engineering experience, research and implement carbon dioxide emission control measures and explore ways to comprehensively utilize carbon dioxide, in order to minimize the project’s carbon dioxide emissions as much as possible.   (III) Strictly implement various water pollution prevention and control measures. The water supply and drainage system is constructed in accordance with the principles of separating rainwater from wastewater, separating clean water from polluted water, treating water according to its quality, and reusing water. Further optimize the water usage plan, increase the rate of water reuse, and reduce the consumption of fresh water as well as the generation of wastewater. Further optimize the wastewater treatment and reuse solutions, and upgrade the existing industrial wastewater treatment systems to ensure that production wastewater is treated and reused in a manner appropriate to its specific characteristics under normal operating conditions. Construct a wastewater holding system with sufficient capacity to ensure that wastewater does not enter the external environment under abnormal operating conditions.   The gasification wastewater, shift wastewater, wastewater from the methanol-water separation tower in the low-temperature methanol washing unit, stripping wastewater from the methanol-to-olefins unit, pelletizing wastewater from the polyolefins unit, as well as domestic sewage, are all sent to a wastewater treatment plant for treatment. This plant uses a treatment process consisting of “two-stage A/O + denitrifying biological filter + BAF” ; The wastewater from the water output and circulation systems, as well as the wastewater from the chemical water treatment station, is sent back to the water utilization system; after being treated through the processes of \"lime/sodium carbonate softening + high-efficiency sedimentation + ultrafiltration + reverse osmosis\", most of it is reused ; The concentrated water from the existing process wastewater recycling system is sent to a membrane concentration system; after being treated through a series of processes including buffer adjustment, chemical softening, precipitation, filtration, ion exchange, decarburization, and high-efficiency reverse osmosis, most of it is reused. The concentrated water is then fed into a salt separation evaporation crystallization unit, where the processes of nanofiltration, evaporation, and membrane separation are used to gradually crystallize sodium chloride and sodium sulfate that meet relevant product standards, which are sold as by-products.   (IV) Strengthen various environmental risk prevention measures to effectively avert environmental risks. Strengthen the management of storage, transportation, and use of chemical materials and hazardous substances. Install automatic monitoring, alarm, emergency shutoff, and emergency shutdown systems in accordance with relevant standards, as well as monitoring and alarm systems for flammable and toxic gases and online analysis systems. Additionally, implement accident response systems for fire, explosion, and poisoning incidents. In the event of an accident, the process exhaust gases from various units are sent to the flare system for treatment.   An accident water pollution prevention and control system has been established, which includes retaining walls around the processing area and fire dikes around the tank farm, as well as an initial rainwater collection pond in the processing area and an overall plant-wide accident water collection pond, to ensure the effective containment of untreated wastewater and accident water. Optimize the pathways for collecting and transporting accident water, with the two accident water collection tanks in the plant serving as backups for each other ; Strictly manage the construction of rainwater and sewage pipelines, implement separation of the two, and prevent accident-related sewage from contaminating the rainwater system. Facilities for controlling water pollution caused by accidents and facilities for temporarily storing wastewater should be designed and constructed separately, and must not be used interchangeably in non-accident situations. In emergency situations, rely on the park’s accident pool. The collected accident water is sent to the wastewater treatment plant for proper disposal. Your company should take effective measures to ensure that accident wastewater does not enter the Yellow River in the event of any accidents.   Improve the emergency response plan for sudden environmental incidents, the special emergency response plan for sudden groundwater pollution incidents, and the special emergency response plan for hazardous substance leaks; refine the emergency evacuation plans. In accordance with the principles of \"classified management, hierarchical response, and regional coordination\", an emergency response mechanism is established between the project and Jiuyuan Industrial Park, local authorities, as well as relevant departments. Regular emergency drills for sudden environmental incidents are carried out to effectively prevent and control environmental risks.   (5) Effectively implement measures for preventing and controlling groundwater and soil pollution. The prevention and control of groundwater pollution shall be carried out in accordance with the principles of “source control, zonal prevention and control, pollution monitoring, and emergency response”. In strict accordance with the requirements of the \"Technical Specifications for Seepage Control in Petrochemical Projects\" (GB/T50934-2013), seepage control measures are implemented in designated areas for pollution control, such as key pollution control zones and general pollution control zones, further strengthening the seepage control requirements for sewage and accident water collection tanks (channels). Carry out pipeline modifications on existing projects, as well as anti-seepage repairs for key facilities such as gasification and sewage treatment. Strengthen the daily maintenance of the leak prevention facilities; any damaged ones should be repaired and reinforced promptly to ensure their stability and safety. Strengthen the detection of leaks in concealed works; once a leak is detected, immediate remedial actions should be taken to prevent contamination of groundwater and soil.   Establish a comprehensive monitoring system for groundwater and soil. Taking into account existing and proposed projects, and based on the layout of key pollution control areas, the flow direction of groundwater, and environmental protection objectives, groundwater and soil monitoring sites are reasonably designated, with strict implementation of the groundwater and soil monitoring plans. Once groundwater pollution occurs, immediate emergency measures should be taken to minimize the adverse environmental impact on water bodies and soil.   (6) Improve the level of operational management, intensify personnel training, and strengthen environmental protection efforts under abnormal operating conditions. Comprehensive inspection and maintenance procedures should be established from an environmental protection perspective; process routes and design schemes should be further optimized. Necessary coal blending measures shall be taken to ensure stable quality of coal used in the project, thereby reducing the frequency of abnormal operating conditions such as startup and shutdown as well as pollutant emissions. The design and operational management of flare systems need to be strengthened, with strict prohibitions on excessive pollutant emissions during prolonged abnormal operating conditions.   Under abnormal operating conditions such as startup, shutdown, inspection, and maintenance of production facilities, waste gases should be directed to the flare system for treatment. It is necessary to strengthen the operational management of sulfur recovery units to prevent equipment failures from causing large volumes of acidic gases to be flared. Strengthen the management and monitoring of low-temperature methanol washing exhaust gas from purification units to effectively control hydrogen sulfide emissions.   The wastewater treatment system should be commissioned and tested prior to the start-up of the main production units. Under abnormal operating conditions, wastewater should be temporarily stored in wastewater holding tanks of sufficient capacity, depending on its quality; the wastewater in these tanks is then sent back to the wastewater treatment plant for further processing. Further optimize the design of the temporary storage pool system by installing high liquid level alarm devices and plant-wide shutdown interlock devices to prevent operation at high liquid levels. Establish a comprehensive management and scheduling system for water systems to achieve refined management of these systems; if necessary, take measures such as reducing the production load of the main equipment or shutting down operations to ensure that wastewater is not discharged outside.   (7) Strictly implement measures to prevent and control solid waste pollution. In accordance with relevant national and local regulations, and following the principles of \"reduction, resource utilization, and harmlessness,\" solid waste is collected, processed, and disposed of in a manner that prevents secondary pollution.   Recyclable waste catalysts and similar materials are collected by the manufacturers. The waste alkali solution from the olefin separation units is sent to incinerators designed for treating such waste alkali solutions. The waste alkali solution and biochemical sludge from the C4/C5+ comprehensive utilization units are processed using existing gasification facilities. Waste mineral oil, crystalline impure salts, as well as waste catalysts and ceramic balls that cannot be recycled are all disposed of safely through hazardous waste treatment projects that are available for this purpose. The landfills used for such disposal must meet the requirements specified in the \"Standards for Pollution Control of Hazardous Waste Landfills\" (GB18598-2019). General solid wastes such as gasification ash and slag are given priority for comprehensive utilization; those that cannot be comprehensively utilized are sent to project landfills for disposal.   This project shall not be put into operation until the slag yard and the associated hazardous waste disposal facility are completed.   (8) Implement measures for the protection of the acoustic environment. Priority should be given to the use of low-noise equipment, and noise reduction measures such as sound insulation, vibration damping, and noise cancellation should be employed to ensure that the noise level at the factory boundary meets the corresponding standard limits specified in the \"Emission Standards for Environmental Noise at the Boundaries of Industrial Enterprises\" (GB12348-2008).   (IX) Strictly implement various monitoring plans for pollution sources and the ecological environment during the construction period and operation period. Improve the environmental monitoring plan in accordance with relevant standards and regulatory requirements. Establish a registry system for pollution sources, carry out long-term monitoring, retain original monitoring records, and regularly disclose the results of pollutant emission monitoring to the public. Install an online continuous monitoring system for pollutant emissions as required, and connect it to the ecological and environmental authorities. In the event of excessive pollutant emissions, the cause must be identified immediately and measures taken.   (10) Establish an environmental management team suited to the project’s environmental protection efforts, improve various corporate environmental management systems, and strengthen environmental management. During the project construction and operation phases, the company proactively releases information on environmental protection efforts and willingly accepts social oversight. Establish smooth channels for public participation, strengthen publicity and communication efforts, promptly address environmental issues raised by the public, and meet their legitimate demands for environmental protection.   (11) Project construction must strictly implement the \"three simultaneities\" system, which requires that environmental protection facilities be designed, constructed, and put into use simultaneously with the main project. The construction tender documents and construction contract should specify environmental protection provisions and responsibilities, and ensure the implementation of environmental protection measures during the construction period. Conduct the environmental protection acceptance upon completion in accordance with the prescribed procedures.   Once the environmental impact assessment report is approved, if there are significant changes in the nature, scale, location, production processes, or environmental protection measures of the project that could lead to substantial changes in the environmental impact (particularly an increase in adverse environmental impacts), the environmental impact assessment report for the project must be submitted for approval again.   (12) Before any actual discharge of pollutants occurs in the project, all environmental protection measures shall be carefully identified and implemented in accordance with the approved environmental impact assessment documents. The list of pollutant discharges and other relevant information shall be included in the pollution discharge permit; thus, the environmental impact assessment is seamlessly linked to the application for and renewal of the pollution discharge permit, and discharges shall be carried out in compliance with the permit requirements. In accordance with the \"Administrative Measures for Post-Evaluation of Environmental Impact of Construction Projects (Trial)\\", a post-evaluation of the environmental impact of the entire plant shall be conducted within 3 to 5 years after the project goes into operation, and the compliance with the emission permit requirements shall serve as an important basis for such post-evaluation.   III. Your company shall assist local people’s governments at all levels and relevant departments in carrying out the following tasks.   (1) In coordination with the Baotou Municipal People’s Government, implement the relevant requirements regarding ecological protection and high-quality development in the Yellow River Basin. In accordance with the “Notice on Issuing the Implementation Plan for the Management of Discharge Outlets into Rivers under the Tailwater Project in Baotou” (Baofu Banfa [2018] No. 6) and the “Opinions on the Rectification Plan for the Discharge Outlets into Rivers under the Tailwater Project in Baotou” (Huanghu Guan [2019] No. 1), expedite the implementation of the rectification project for the discharge outlets into rivers under the Tailwater Project in Baotou, as well as related projects for the comprehensive improvement of rivers flowing into the Yellow River in Baotou.   (II) In coordination with the People’s Government of Baotou City and relevant departments, as well as the People’s Government of Jiuyuan District, and in accordance with the requirements set out in the “Report on the Preliminary Opinions Regarding the Total Emission Limits for Major Pollutants in the Shenhua Baotou Coal-to-Olefins Upgrading Demonstration Project” (Nei Huan Fa [2019] No. 162), the “Reply from the People’s Government of Baotou City Regarding the Reissue of the Regional Reduction Plan for Total Emissions of Major Pollutants from the Shenhua Baotou Coal-to-Olefins Upgrading Demonstration Project” (Bao Fu Zi [2020] No. 11), and the “Explanation from the People’s Government of Jiuyuan District on the Progress of Measures to Address the Problem of Coal Burning in Agarutai Sumu”, all necessary measures to control total pollutant emissions for this project shall be completed on schedule. This includes reforms such as the desulfurization and denitrification of the flue gases from the two roasting furnaces at Baotou Dongfang Hope Carbon Co., Ltd., the denitrification and dust removal upgrades for Sintering Unit 5, Machine No. 2, at the ironmaking plant of Baotou Steel Group Co., Ltd., as well as the upgrades to the separation plants of Inner Mongolia Baotou Steel Hefa Rare Earth Co., Ltd. Additionally, the measures to address coal burning in Agarutai Sumu must also be implemented. Ensure that the corresponding reductions in sulfur dioxide, nitrogen oxides, soot and dust, and VOCs as a result of this project are at least 62 tons per year, 684 tons per year, 202 tons per year, and 565 tons per year, respectively. The requirements for the transformation measures of the replaced enterprise shall be included in the pollution discharge permit. Before the completion and commissioning of this project, it is necessary to ensure that the aforementioned measures for reducing atmospheric pollutant emissions are put into effect, and that the emission permits of the enterprises being replaced are updated or revoked.   (III) In cooperation with the People’s Government of Baotou City and the People’s Government of Jiuyuan District, accelerate the construction of the rigid landfill for hazardous waste at the Inner Mongolia Baotou Hazardous Waste Disposal Center, as well as various environmental infrastructure facilities within the park, including public emergency spill containment ponds, and environmental risk prevention measures, to ensure that the environmental protection facilities supporting this project meet the required standards.   Strengthen the management and routine maintenance of the accident water prevention and control system in the park. Under normal circumstances, wastewater must not be discharged into the park’s accident water tank; it is strictly prohibited to use this tank as a storage tank or temporary wastewater holding tank. The accident tank in the park is equipped with a return pump to promptly send wastewater back to the sewage treatment facility for processing; wastewater must not be discharged into the external environment through the accident tank.   (4) In coordination with the people of Jiuyuan District, complete the relocation of residents within the sanitary protection zone on schedule, in accordance with the requirements set forth in the “Letter Concerning the Relocation and Resettlement of Residents from Certain Villages Affected by Major Projects in the Baotou Jiuyuan Industrial Park in Inner Mongolia” (Baotou Jiuyuan Government Document No. [2019] 8). In coordination with local authorities, proper planning and control measures should be implemented: a sufficient buffer distance must be maintained between residential and industrial land uses. No environmentally sensitive buildings such as residences, educational institutions, or medical facilities may be planned or constructed within the project’s protection zone.   (5) In cooperation with the people’s government of Jiuyuan District, strengthen the capacity for environmental monitoring in the Jiuyuan Industrial Park. Establish an environmental monitoring system that covers major and characteristic pollutants. During both the construction and operation phases of projects, carry out long-term monitoring of ambient air, groundwater, etc. Once any issues with ecological and environmental quality are detected, effective countermeasures should be taken promptly.   IV. Your company must earnestly implement various environmental protection measures and environmental risk prevention measures. At the same time, in coordination with local ** and relevant departments, we carry out various tasks such as implementing regional pollutant reduction and substitution measures, constructing environmental protection projects, and building capabilities for responding to environmental risks. Before the above tasks are completed, the project shall not be put into operation.   V. Tasks such as regional pollutant reduction and substitution, for which local people’s governments at all levels bear primary responsibility, shall be incorporated into the supervision and management of ecological and environmental protection.   VI. Our department has entrusted the North China Supervision Bureau and the Ecological Environment Department of the Inner Mongolia Autonomous Region to respectively organize and carry out supervision, inspection, and management work regarding the “three simultaneities” for this project.   7. Within 20 working days after receiving this approval, your company shall send copies of the approved Environmental Impact Report to the North China Inspection Bureau of our Ministry, the Ecological Environment Department of the Inner Mongolia Autonomous Region, and the Baotou Municipal Ecological Environment Bureau. It must also comply with the regulations regarding routine supervision and inspections by ecological environment authorities at all levels.   Ministry of Ecology and Environment March 17, 2020
Reply #22020-03-29
The projects have been under construction for over a year now, yet the environmental impact assessment has only just been approved. **So, which is more important—the law or the level of authority?**

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