Regarding the environmental aspects of the demonstration project on the integrated utilization of high-sulfur coal for oil, chemical, thermal, and electrical purposes by Shanxi Lu’an Mining (Group) Co., Ltd....

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Shanxi Lu’an Mining (Group) Co., Ltd.: We have received your company’s request titled \"Request for Review of the Environmental Impact Assessment Report for the Integrated Demonstration Project for the Clean Utilization of High-Sulfur Coal in Oil, Chemical, and Thermal Applications by Shanxi Lu’an Mining (Group) Co., Ltd.\" (Lu Kuang Ban Zi [2015] No. 614). After examination, the following decision is made: 1. The construction of this project commenced without the approval of our department for its environmental impact assessment document, in violation of the relevant provisions of the Environmental Impact Assessment Law; the illegal act has been investigated and dealt with. Your company must seriously learn from this experience, enhance its awareness of compliance with the law, safeguard its corporate environmental credit, and prevent such illegal acts from occurring again. 　　II. The project is located in the Lu’an Oil, Chemicals, and Thermal Integration Comprehensive Demonstration Park, which is part of the Wangqiao New Coal Chemical Industry Park in Xiangyuan County, Changzhi City, Shanxi Province. It makes use of the local coal resources, and employs technologies such as pressurized coal gasification and Fischer-Tropsch synthesis to produce 1.8 million tons per year of petroleum products and chemicals. The project will be constructed in two phases. In the first phase, a 1-million-ton/year iron-based Fischer-Tropsch oil production facility will be built; in the second phase, an 800,000-ton/year cobalt-based Fischer-Tropsch wax processing facility will be constructed. The main facilities include units for coal gasification and purification, hydrogen production from PSA off-gases, synthesis of iron-based oils, processing of 1 million tons per year of iron-based oils, and processing of 800,000 tons per year of cobalt-based oils. The storage and transportation engineering mainly includes enclosed coal silos, iron-based oil tanks, cobalt-based oil tanks, train loading/unloading systems, truck loading/unloading systems, hard wax warehouses, etc. Auxiliary facilities mainly include water treatment plants, chemical water treatment stations, deaerated water supply stations, circulating water systems, drainage systems, on-site thermal power plants, waste heat power generation systems, flare systems, and maintenance workshops. Environmental protection projects mainly include acidic water stripping units, sewage treatment systems, recycled water systems, membrane concentration systems, evaporation crystallization systems, flue gas treatment units, devices for treating hydrocarbon gases and volatile organic compounds, dryers and incinerators for hazardous waste, on-site temporary storage areas for hazardous waste, and off-site waste disposal sites. The raw materials for the first phase of the project consist of a mixture of 60% high-sulfur coal (with a sulfur content of 3%) and 40% low-sulfur coal (with a sulfur content of 0.3%). The raw materials required for cobalt-based Fischer-Tropsch synthesis in the second phase are procured from the market. The plant produces a total of 20 types of products, with an annual production volume of 1.9685 million tons. Of this, the first phase of the plant generates 1.1769 million tons per year in output, including 716,500 tons per year of diesel (Grade V), 253,600 tons per year of naphtha, and 87,200 tons per year of liquefied petroleum gas (LPG), among others ； The annual production capacity of the Phase II project is 791,600 tons. The main products include 116,800 tons/year of white oil, 285,400 tons/year of low-pour-point diesel (National Standard V), 46,800 tons/year of Group II lubricating oil base stock, 50,300 tons/year of Group VI lubricating oil base stock, 50,000 tons/year of liquid wax, 49,800 tons/year of hard wax, 75,800 tons/year of Solvent Oil No. 1, and 54,200 tons/year of Solvent Oil No. 2, among others. 　　The project generally meets the requirements of the \"Environmental Access Requirements for Modern Coal Chemical Industry Construction Projects (Trial)\“. However, in certain areas within the project site, the ability to prevent groundwater contamination is poor. There is a risk of polluting groundwater-sensitive areas such as the key protection zone of the Xin’an Spring area and the centralized water source area in Wangqiao Town. Given that the region has limited environmental carrying capacity and a dense population, it is essential to strictly implement various pollution prevention and control measures as well as regional reduction measures. The population size within the industrial park must be strictly controlled, and the strictest possible environmental risk prevention measures and environmental monitoring plans should be adopted. After strictly implementing the regional reduction measures and all environmental protection measures stipulated in the Environmental Impact Report, the emissions of various pollutants can meet the standards, and the emissions of major pollutants comply with the total quantity control requirements. Taking all factors into account, our department generally agrees with the nature, scale, technology, location, and environmental protection measures of the construction projects outlined in your company’s environmental impact report. 　　III. Key tasks to be prioritized in the design, construction, and operation management of projects
(1) Strictly implement all measures for preventing and controlling air pollution. 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 the treatment facilities must meet the required standards, and the height of the exhaust stacks must comply with relevant regulations to ensure that emissions of various air pollutants satisfy both national standards and local requirements. 　　The waste gas from low-temperature methanol washing is treated using a process of \"washing tower + desulfurization tank adsorption\"; the removal efficiencies for methanol and hydrogen sulfide should reach 89.2% and 22%, respectively, so that the gas can be released into the atmosphere after meeting the requirements set out in the \"Emission Standards for Pollutants in the Petrochemical Industry\" (GB31571-2015) and the \"Emission Standards for Odorous Pollutants\" (GB14554-93). The sulfur-recovering waste gas is treated using the \"two-stage Claus sulfur production + SOP acid production\" process, with a total sulfur recovery rate of 99.99%; after meeting the requirements specified in the \"Emission Standards for Pollutants in the Petroleum Refining Industry\" (GB31570-2015), the gas is released into the atmosphere. 　　The heating furnace uses clean fuel and employs low-nitrogen combustion; the exhaust gases meet the Requirements for Emissions of Pollutants in the Petroleum Refining Industry (GB31570-2015) before being released into the atmosphere. The flue gas from the thermal power plant boilers is treated using a process that combines \"low-nitrogen combustion + SCR denitrification + bag filtering + ammonia-based desulfurization + two-stage wet electrostatic precipitators.\" The removal rates for dust, sulfur dioxide, and nitrogen oxides should reach 99.975%, 98%, and 84%, respectively, in order to meet Standard I for ultra-low emissions as specified in the \"Opinions of the General Office of the Shanxi Provincial People’s Government on Promoting Ultra-Low Emissions from Coal-Fired Power Generators across the Province\" (Jin Zheng Ban Fa [2014] No. 62). Mercury and its compounds are to be emitted at levels that comply with the \"Emission Standards for Air Pollutants from Thermal Power Plants\" (GB13223-2011). 　　The hazardous waste incinerator uses a treatment process that includes \"two-stage dust removal + SNCR denitration + activated carbon adsorption + two-stage acid removal.\" The removal rates for dust, sulfur dioxide, nitrogen oxides, hydrogen chloride, hydrogen fluoride, and dioxins should reach 95%, 80%, 30%, 90%, 90%, and 90% respectively; the exhaust gases are then released through a 45-meter-high exhaust stack in compliance with the \"Standards for Pollution Control in Hazardous Waste Incineration\" (GB18484-2001). 　　Adopt equipment leakage detection and repair technologies to strengthen control measures against volatile organic compounds and malodorous pollution. Naphtha, diesel, mixed alcohols, light contaminated oil, heavy oil storage tanks, as well as other tanks for cobalt-based oils, use internal floating roof tanks. Heavy contaminated oil, heavy diesel, stabilized wax, and qualified wax are stored in dome tanks, with oil and vapor recovery being achieved through a process that combines condensation, membrane separation, and adsorption. For the recovery of oil and vapor during vehicle loading/unloading and train loading/unloading, a \"condensation + membrane separation + adsorption\" process is employed; the overall efficiency of oil and vapor recovery should reach 98%. The exhaust gases, after meeting the requirements specified in the \"Emission Standards for Pollutants in Petroleum Refining Industry\" (GB31570-2015) and the \"Emission Standards for Air Pollutants from Oil Storage Depots\" (GB20950-2007), are discharged through exhaust stacks 15 meters high. Waste gases from the pretreatment facilities, primary sedimentation tanks, hydrolysis-acidification tanks, sludge thickening tanks, and other components of the closed wastewater treatment plant are collected and treated using the \"biological trickling filter + activated carbon adsorption\" method. The removal rates for non-methane total hydrocarbons, hydrogen sulfide, and ammonia should reach 95%, 80%, and 70%, respectively; only after meeting the requirements set out in the \"Emission Standards for Odorous Pollutants\" (GB14554-93) and the \"Emission Standards for Pollutants in the Petroleum Refining Industry\" (GB31570-2015) can these gases be released through exhaust stacks that are 15 meters high. The transportation of ash and slag involves humidification and sealing; for ash and slag landfilling, zoned landfilling is employed along with water spraying to suppress dust. All emergency accident ponds and storage tanks have been covered to ensure effective control of uncontrolled emissions. 　　Dusty exhaust gases from components such as the crusher chamber in solid material storage and transportation systems, the coal silos in gasification units, and the ash silos are treated using bag filters; the dust removal efficiency should reach 99.9% to ensure that the emissions meet the requirements of the \"Integrated Emission Standards for Air Pollutants\" (GB16297-1996) ； The exhaust gas from the slag scooper in the gasifier ash system is discharged into the atmosphere after meeting the requirements of the \"Emission Standards for Odorous Pollutants\" (GB14554-93). Strictly implement control measures for unorganized emissions of waste gases in areas such as coal storage zones and ash dumps, as well as at relevant processing stages, to prevent secondary pollution. 　　(II) 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. Give priority to using mine dewatering water and rainwater to further increase water reuse, reduce the consumption of fresh water, and minimize wastewater discharge. Further optimize the wastewater treatment and reuse plan; under normal operating conditions, all treated production wastewater will be reused. Later, the rainwater is discharged through the rainwater drainage pipes and eventually flows into the southern source of the Zhuozhang River. 　　After being treated via “stripping + clarification”, the gasification wastewater, together with the wastewater from the hazardous waste incineration facility, enters the gasification pretreatment unit, where it is processed using the “flocculation sedimentation + two-stage oxidation + adsorption” process. The oily wastewater generated from oil synthesis is treated through \"oil removal + alcohol extraction\"; the wastewater from the plant area and initial rainwater are subjected to oil separation before entering the oil-containing pretreatment unit, where they are processed using a \"oil separation and adjustment + two-stage air flotation\" process. 　　The pretreated gasification wastewater, wastewater from hazardous waste incineration units, oily wastewater, washing wastewater, initial rainwater, as well as the methanol-containing wastewater from low-temperature methanol washing processes and domestic sewage are sent to the wastewater treatment plant, where they are treated using the \"hydrolysis acidification + precipitation + two-stage biological treatment\" process. 　　The effluent from the wastewater treatment plant, along with purified water and saline wastewater, is sent back to the water treatment system. It is treated using a process that includes clarification, three-stage filtration, ultrafiltration, and reverse osmosis; the purified water is used as makeup water for the circulating water system. The concentrate from reverse osmosis is sent to a membrane concentration unit, where it is treated through a process that involves chemical water softening, clarification, ultrafiltration, weak acid cation exchangers, a decarburization tower, nanofiltration, and reverse osmosis. The resulting water is then reused as makeup water for the circulating water system. Concentrated brine is sent to the evaporation crystallization system to produce crystallized mixed salt. 　　(III) Effectively implement measures to prevent and control groundwater pollution. Through the inclined-hole grouting seepage control technique, the foundation protection performance of the entire plant should be achieved at a level no lower than that of equivalent cohesive soil with a thickness of 6 meters and a seepage coefficient of 1.0×10-7 cm/s. After the grouting work is completed, a test report must be issued by a qualified entity; if the required impermeability standards are not met, the project shall not be put into operation. 　　Taking into account the current distribution of groundwater in the region, the hydrogeological conditions, and leakage prevention measures, the locations of key pollution control areas such as tank farms are optimized and adjusted; construction is prohibited in areas with highly developed karst formations, numerous sinkholes, or karst funnels. In accordance with the requirements of the \"Technical Code for Oil and Chemical Industry Leakage Prevention Engineering\" (GB/T50934-2013), leakage prevention measures are implemented in zones such as key pollution control areas and general pollution control areas. For off-site ash disposal sites, measures and construction plans should be further optimized during the design and construction phases to ensure compliance with the “Emission Standards for Pollutants from Storage and Disposal Sites of General Industrial Solid Wastes” (GB18599-2001). 　　Establish a comprehensive groundwater monitoring system. Install no fewer than 10 groundwater monitoring wells. An online real-time monitoring system should be set up for these wells, and regular manual monitoring should also be conducted. Optimize the location of leachate collection wells based on hydrogeological conditions, and combine monitoring wells with collection wells. Strengthen monitoring to prevent groundwater pollution. In the event of any groundwater contamination, immediately activate the emergency response plan and measures to mitigate its effects, thereby avoiding adverse impacts on groundwater-sensitive areas such as the Xin’an Spring region. 　　(4) Strictly implement measures for the prevention and control of solid waste pollution; comply with the requirements set forth in the “Environmental Access Conditions for Modern Coal Chemical Industry Construction Projects (Trial)”; and undertake environmental protection demonstration tasks related to the treatment and disposal of hazardous waste. In accordance with relevant national and local regulations, and following the principles of “reduction, resource utilization, and harmlessness”, solid waste is classified, collected, treated, and disposed of. 　　Waste catalysts and waste protectants in hazardous waste are recycled by the manufacturers. Waste incinerators are installed as part of the infrastructure, utilizing a rotary kiln process to carry out incineration and volume reduction of biochemical sludge, sludge from gasification wastewater treatment, oil sludge, and spent activated carbon. The crystalline mixed salt shall be managed as hazardous waste for the time being; once the project is put into operation, appropriate disposal or recycling measures will be taken based on the results of its property assessment, ensuring that no secondary environmental problems arise. Crystalline mixed salts, pyrolysis waste residues, residues from hazardous waste incineration units, and certain waste ceramic balls are sent to specialized hazardous waste disposal facilities for safe treatment. Strictly implement the \"three-way receipt\" system for the transfer of hazardous waste, strengthen environmental protection measures during its transportation, and ensure that no environmental safety incidents occur during the transport process. 　　General solid wastes such as gasification ash, thermal power plant boiler ash, etc., are sent to nearby cement plants and building material factories for comprehensive utilization; when such utilization is not possible, they are sent to the Nanbianqiao slag dump for temporary storage. 　　(5) Implement various environmental risk prevention measures to effectively avert environmental risks. Strengthen the management of storage, transportation, and use of chemical raw materials and hazardous substances; install automatic monitoring, alarm, emergency shutoff, and emergency shutdown systems in accordance with standards, as well as systems for dealing with accidents such as fires, explosions, and poisonings. A three-tier prevention and control system has been established, comprising retaining walls for initial rainwater in the equipment area, fire dikes in the storage tank area, initial rainwater ponds, rainwater monitoring ponds, rainwater collection ponds, and emergency accident water ponds. Additionally, a 0.5-meter-high pollution barrier has been constructed along the factory perimeter in the low-lying area of the northwest part of the plant site to ensure that untreated wastewater and accidental effluents do not leave the premises. Wastewater temporary storage facilities and accident prevention and control facilities at the third level should be designed and constructed separately, and must not be used interchangeably in normal conditions. Optimize the collection and transportation routes for accident-related wastewater, strictly manage the construction of rainwater and sewage pipelines, resolutely implement separation of rainwater and sewage, and prevent accident-related wastewater from contaminating the rainwater collection system. Formulate emergency plans for environmental risks and establish coordination with chemical industrial parks and local emergency response teams; detail the procedures for emergency evacuation, and conduct regular drills to address environmental risks in the event of accidents. 　　(VI) Improve management and operational standards, and strengthen environmental protection during abnormal operating conditions. Establish comprehensive inspection, maintenance, and operation procedures to further reduce the frequency of abnormal operating conditions such as startups and shutdowns, as well as pollutant emissions, and to prevent the surrounding environmental quality from exceeding acceptable levels due to prolonged abnormal operations. Further optimize the process route and design plan, and take necessary coal-blending measures to enhance the stability of the quality of raw coal, thereby reducing the frequency of abnormal operating conditions and the amount of pollutants generated at the source. 　　Under abnormal operating conditions such as startup, shutdown, and maintenance, the exhaust gas is sent to a flare for combustion. Operational management of sulfur recovery units should be strengthened to prevent device failures from resulting in large amounts of acidic gas being sent to flares for combustion. 　　Under abnormal operating conditions, in the specific scenarios outlined in the Environmental Impact Report, wastewater may be discharged into the southwestern section of the South Source of the Luozhang River after meeting the relevant standards. In specific situations where wastewater is discharged, it is necessary to strictly adhere to the limits on the total amount of wastewater and pollutants released, and to further improve the corresponding management measures and monitoring systems. Establish a sound management and scheduling system for water systems; when necessary, take measures such as halting or restricting production to minimize the environmental impact of wastewater discharge. 　　(7) Adopt measures such as sound insulation, vibration damping, installation of silencers, and landscaping to ensure that the noise level at the factory boundary meets the Class 3 standards specified in the \"Emission Standards for Environmental Noise at the Boundaries of Industrial Enterprises\" (GB12348–2008). 　　(8) Implement various environmental protection measures during the construction period, strengthen environmental protection management during the project’s construction, and prevent wastewater, dust, and noise from having an adverse impact on the surrounding environment. Strictly control the land occupied during construction, and carry out land restoration and greening promptly after the construction is completed. To ensure a smooth transition between the environmental protection measures for Phase 1 and Phase 2 projects, it is necessary to guarantee that all pollutants are discharged within specified limits during the transition period. 　　(IX) Strictly control the emission of pollutants specific to the project, establish an environmental monitoring system that covers both such specific pollutants and conventional pollutants, and carry out environmental monitoring in accordance with the monitoring plan. In accordance with **and relevant local regulations, standard pollutant discharge outlets and solid waste disposal sites shall be established, along with signage. Install online monitoring systems for wastewater (including rainwater from the facility) and exhaust gas pollutants, and connect them to the environmental protection authorities. Chimneys shall be provided with permanent monitoring ports in accordance with regulatory requirements. 　　(10) During the project construction and operation phases, a smooth platform for public participation should be established, publicity and communication efforts should be strengthened, environmental issues that cause public concern should be addressed promptly, and the public’s legitimate environmental demands should be met. Regularly release corporate environmental information and proactively accept social oversight. 　　IV. Your company should assist the people’s governments at all local levels as well as the relevant departments in carrying out their tasks. (1) This project is a model project for the coal industry transformation and development in Shanxi Province, and it will promote the development of the downstream industrial chains in the Wangqiao New Coal Chemical Industry Park and its surrounding areas. In coordination with the people’s government of Changzhi City, it is necessary to make rational plans for water resource allocation based on the regional capacity to carry water resources. Regional development plans should be further optimized and adjusted, with the improvement of environmental quality as the core objective of environmental protection. Chemical and other industrial projects should be planned carefully, the scale of development controlled, industrial structures adjusted, and efforts made to promote the clean and efficient use of coal as well as the improvement of regional environmental quality. 　　(II) Freeing up environmental capacity through regional pollution reduction is a prerequisite for the environmental feasibility of this project. In accordance with the “Notice on the Division of Responsibilities for Regional Pollution Reduction Tasks” (Changzhi Government Document No. 1 [2016]), the people of Changzhi City must strictly implement these measures as planned, ensuring the timely completion of various actions aimed at reducing regional pollutants, such as shutting down, merging, or restructuring enterprises; upgrading environmental protection facilities; substituting clean energy sources; and constructing new wastewater treatment plants. 　　(III) In cooperation with the People’s Government of Xiangyuan County and the People’s Government of Lucheng City, and in accordance with the commitments set out in Document Xiang Zheng Fa [2016] No. 8 and Document Lu Zheng Ban Fa [2016] No. 16, the relocation and resettlement of residents within the health protection zone shall be carried out on schedule; the project shall not be put into operation until such relocation is completed. Actively cooperate with local authorities in carrying out planning and control; no environmentally sensitive buildings such as residential, educational, or medical facilities shall be planned or constructed within the project’s protection zone. 　　(IV) In cooperation with the People’s Government of Xiangyuan County and the industrial park, an environmental monitoring network covering the entire industrial park as well as the key protection areas in the Zhuozhang River basin and Xin’anquan area shall be established. A comprehensive monitoring system for characteristic pollutants such as non-methane hydrocarbons, volatile organic compounds, hydrogen sulfide, ammonia, and benzene derivatives, along with conventional pollutants, shall be put in place. Monitoring plans shall be formulated, specifying details such as the monitoring schedule, funding requirements, monitoring sites, frequency, pollutants to be monitored, and methods of implementation. The results of the monitoring shall be submitted to the local environmental protection authorities for record-keeping. 　　V. The construction of this project must strictly adhere to the environmental protection principle of \"simultaneous design, simultaneous construction, and simultaneous commissioning\" for environmental protection facilities, ensuring that these facilities are developed alongside the main project. Carry out environmental supervision during the construction period; specify environmental protection clauses and responsibilities in the construction tender documents, construction contract, and tender documents for project supervision. Regularly submit reports on environmental supervision of the project to local environmental protection authorities. In accordance with the Measures for the Post-Evaluation of Environmental Impact of Construction Projects, a post-evaluation of the environmental impact shall be conducted within 3 to 5 years after the project comes online. 　　VI. If, after the environmental impact assessment report is approved, there are significant changes in the nature, scale, location of the project, or in the measures taken to prevent pollution and ecological damage, the environmental impact assessment report for that project must be submitted for approval again. If it takes more than 5 years from the date of approval of the environmental impact assessment report before construction of the project is commenced, the environmental impact assessment report shall be submitted to our department for re-examination. 　　VII. Our department has entrusted the North China Environmental Protection Inspection Center and the Shanxi Provincial Department of Environmental Protection with carrying out the supervision and inspection regarding the \"three simultaneities\" principle, as well as the overall supervision and management of this project. 　　8. Your company shall, within 20 working days after receiving this approval, send the approved environmental impact assessment report to the North China Environmental Protection Inspection Center under our department, the Shanxi Provincial Department of Environmental Protection, the Changzhi Municipal Environmental Protection Bureau, and the Xiangyuan County Environmental Protection Bureau, and shall submit itself to the regular supervision and inspection by the environmental protection authorities at all relevant levels as required by regulations. 　　Ministry of Environmental Protection March 4, 2016 CC: **Commission for Development and Reform, Shanxi Provincial Department of Environmental Protection, People’s Government of Changzhi City**, Changzhi City Environmental Protection Bureau, People’s Government of Xiangyuan County**, People’s Government of Lucheng City**, Xiangyuan County Environmental Protection Bureau, Beijing Zhonghuan Guohong Environmental Resources Technology Co., Ltd., North China Environmental Protection Inspection Center of the Ministry of Environmental Protection, and Environmental Engineering Assessment Center. 　　Issued by the General Office of the Ministry of Environmental Protection on March 8, 2016