Beware of backward production capacity in disguise

Recently, "Benchmarking and Benchmarking Levels of Energy Efficiency in Key Fields of High Energy-Consumption Industries (2021 Edition)", "Opinions on Deepening the Battle of Pollution Prevention and Control", "Action Plan for Carbon Peaking Before 2030", "On Complete, Accurate and Comprehensive Implementation of New Development Concepts" Policies related to green and low-carbon development such as the Opinions on Doing a Good Job in Carbon Reaching Peak and Carbon Neutralization are frequently issued
.
This shows from one point of view that while the phased goals and tasks have been successfully completed, the structural, root causes and trend pressures of China's ecological environment protection have not been fundamentally alleviated.
The level of contradictions involved in prevention and control is becoming deeper and wider
.
Among them, the tendency of backward production capacity to defraud living space after disguising is more worthy of vigilance
.

First, we must be alert to the lack of strict control over the planning and construction of industrial park projects, which leads to the breakthrough of the ecological red line
.
For example, the "Guidelines for the Development of the Yangtze River Economic Belt Negative List (Trial)" issued by the relevant state departments in January 2019 clearly stipulates that it is prohibited to build or expand chemical parks and chemical projects within 1 km of the main and tributaries of the Yangtze River.
High pollution projects such as steel, petrochemical, chemical, coking, building materials, non-ferrous metals, etc.
are newly built or expanded outside the park
.
However, according to a report issued by the Ministry of Ecology and Environment on October 9 this year, when inspecting Sichuan, the fifth central ecological and environmental protection inspection team found that since 2019, Jiang'an County Industrial Park has started construction one after another outside the scope of compliant parks included in the national announcement catalog.
Construction of 5 chemical projects including the expansion project of chlorinated titanium dioxide with an annual output of 50,000 tons of Yibin Tianyuan Haifeng Hetai Co.
, Ltd.
The planned construction scope of some projects even exceeds the 1-kilometer red line of the main stream of the Yangtze River
.

Second, we must be wary of putting new materials on high-risk craft products in the name of industrial chain projects
.
Aramid is a typical new chemical material.
The industrial scale of aramid and many downstream industries in China ranks first in the world
.
Recently, the Ministry of Industry and Information Technology conducted a survey on more than 130 key basic materials across the country.
Recently, Inner Mongolia Zhongchen Technology Co.
, Ltd.
, Gansu Jiuquan West New Material Co.
, Ltd.
, and Jiangsu Yancheng De'ande New Material Technology Co.
, Ltd.
have all been approved Lun industrial chain project
.
However, after reading the EIA report, it was found that the monomer production capacity declared by these projects is far greater than the supporting production capacity required for aramid production.
The industrial chain projects are all declared in the way of the monomer project first and then the aramid polymer project.
, the first phase of the project is actually the "two high" product dinitrobenzene or its downstream product phenylenediamine with backward technology
.

Inner Mongolia Zhongchen Technology Co.
, Ltd.
announced the online approval platform in the second half of last year.
The project name of the online filing work is 10,000 tons/year meta-aramid fiber industrialization project.
The previously declared monomer scale is 30,000 tons/year inter-dinitrobenzene , 40,000 tons/year mixed dinitrobenzene project, now m-dinitrobenzene and mixed dinitrobenzene have been sold externally
.

The planned production capacity of aramid fiber of Gansu Jiuquan West New Materials Co.
, Ltd.
is 3,000 tons/year, but it is understood that the company has built 15,000 tons/year of phenylenediamine and downstream products of phenylenediamine that are not in the aramid fiber industry chain.
——6000 tons/year resorcinol production line
.
At present, the first phase of 15,000 tons/year phenylenediamine production line and supporting facilities have been constructed
.

The aramid fiber project of Jiangsu Yancheng Deande New Material Technology Co.
, Ltd.
includes 3,000 tons/year of aramid fiber, 15,000 tons/year of m-phenylenediamine, 5,000 tons/year of resorcinol, 20,000 tons/year of isophthaloyl chloride, etc.

.
The project is now built but never started
.

Aramid is produced by the condensation polymerization of isophthaloyl chloride and m-phenylenediamine
.
The production of 1 ton of meta-aramid fiber consumes about 0.
475 tons of m-phenylenediamine, corresponding to 0.
76 tons of m-dinitrobenzene or 0.
893 tons of mixed dinitrobenzene
.
Based on this calculation, in the industrial chain of the above-mentioned 3,000 tons/year aramid fiber project, aramid fiber is actually a "small horse-drawn cart", while m-dinitrobenzene or mixed dinitrobenzene is the dominant one
.
In other words, a large number of products such as phenylenediamine will enter the market in the early stage
.
In the "3.
21" accident in Xiangshui, which shocked the whole country, the waste source of Tianjiayi Co.
, Ltd.
was the nitrification waste generated during the refining process of mixed dinitrobenzene
.
Meta-dinitrobenzene has been published by the Ministry of Ecology and Environment since at least 2013 and included in the list of highly polluting and high environmental risk substances in the Comprehensive Catalogue of Environmental Protection (2021 Edition)
.
It is also understood that the production of m-dinitrobenzene and mixed dinitrobenzene in the above-mentioned projects adopts the elimination process
.
It can be seen that these projects declared and approved by the aramid fiber industry chain not only have no integrated projects that are planned and constructed according to the industry chain, but also have other dangerous craft products that are not in the aramid fiber industry chain
.

Third, we must be alert to the backward production capacity of upgrading and relocation, retreating from the city and entering the park, which is a process route with high energy consumption, high pollution and high risk
.
For example, the leaders of Lianxi District, Jiujiang, Jiangxi stated at the city's industrial strong city conference that they will build the country's largest cellulose fiber industrial base and build a modern textile industry chain pattern supported by projects such as new materials and spunlace non-woven fabrics
.
However, the inspection team of the fourth central ecological and environmental protection inspection team found that the construction content of the basic material project for the chemical fiber industry of the local enterprise Jiujiang Jiuhong New Materials Co.
, Ltd.
included an ionic membrane caustic soda production line with an annual output of 600,000 tons, which was a restricted backward production capacity project
.
At present, the first part of the first phase of the company has an annual output of 150,000 tons of caustic soda production line has been completed and put into operation in December 2019, and the second part of the first phase of the 150,000-ton caustic soda production line is under construction
.
In addition, seven high-energy-consuming projects including Jiujiang Sateri (China) Company, a local enterprise with an annual output of 1 million tons of chemical fiber, and the first phase of Nanchang Jiangxi Zhaochi Semiconductor Project, were also completed and put into operation last year
.
The relevant government promised to formulate an alternative plan before the construction of the project, but it was not provided until the inspection, and the energy saving commitment became a dead letter
.

The above behaviors of the "two high" products wearing new clothes have buried invisible bombs that may explode at any time in the construction of ecological civilization, and should be paid enough attention by the relevant departments
.
To better identify these disguised items, it is recommended to:

First, when examining and approving industrial chain projects, if the supporting raw materials involve dangerous processes or high energy consumption links, the raw material projects should be constructed at the same time as the new material projects, or the new material projects should be constructed first and then the supporting raw material projects should be constructed to prevent enterprises from taking the opportunity to expand production and restrict products.

.

The second is to add a process maturity and advanced evaluation link for projects involving hazardous processes and/or high-energy-consuming processes before project approval
.
For the 18 kinds of hazardous processes stipulated by the state, the process control points and equipment selection requirements shall be evaluated for safety factor parameters.
For high energy-consuming products, the benchmark level of energy efficiency in key areas shall be used as the baseline
.