Acceptance Comments

Energy-Saving and Environmental Protection Retrofit Project of Luoyang Tianping Molecular Sieve Co., Ltd.

Opinions on the Environmental Protection Acceptance upon Completion

On April 9, 2020, Luoyang Tianping Molecular Sieve Co., Ltd. conducted the acceptance inspection of this project in accordance with the “Environmental Protection Acceptance Monitoring Report for the Completion of the Energy-Saving and Environmental Protection Retrofit Project of Luoyang Tianping Molecular Sieve Co., Ltd.” and in compliance with the “Interim Measures for Environmental Protection Acceptance upon Completion of Construction Projects,” as well as relevant national laws and regulations, the technical specifications/guidelines for environmental protection acceptance upon completion of construction projects, the “Environmental Impact Report Form for the Energy-Saving and Environmental Protection Retrofit Project of Luoyang Tianping Molecular Sieve Co., Ltd.,” and the approval document issued by the Jili Branch of the Luoyang Municipal Environmental Protection Bureau regarding the Environmental Impact Report Form for the aforementioned project (Document No. Luoji Huan Shen [2019] No. 10). During the acceptance process, due to deficiencies in the company’s environmental protection facilities—specifically falling under Paragraphs 1 and 2 of Article 8 of the “Interim Measures for Environmental Protection Acceptance upon Completion of Construction Projects” (Guohuan Gui Huanping [2017] No. 4)—namely: (1) failure to construct environmental protection facilities in accordance with the requirements set forth in the environmental impact report (form) and the approval decisions of the reviewing authorities, or inability of such facilities to be put into operation or used concurrently with the main project; and (2) non-compliance of pollutant emissions with applicable national and local standards, the provisions of the environmental impact report (form) and its approving authority, or the total pollutant emission control targets—the acceptance panel did not issue a favorable opinion. The company was therefore required to carry out rectification measures and subsequently organize another acceptance inspection. From May to July 2020, Luoyang Tianping Molecular Sieve Co., Ltd. implemented the necessary rectifications, prepared the “Post-Implementation Environmental Impact Assessment Report for the Energy-Saving and Environmental Protection Retrofit Project of Luoyang Tianping Molecular Sieve Co., Ltd.,” filed it with the Jili Branch of the Luoyang Municipal Environmental Protection Bureau, and obtained a pollution discharge permit.

On August 9, 2020, Luoyang Tianping Molecular Sieve Co., Ltd. once again organized the acceptance inspection of this project. The acceptance committee put forward the following comments:

I. General Overview of the Project Construction

Luoyang Tianping Molecular Sieve Co., Ltd. is located on the north side of Daonan Road in the Jili Science and Technology Park, Luoyang High-Tech Development Zone, covering an area of over 50 mu. The company primarily engages in the research, development, and production of molecular sieves, with an annual production capacity of 3,000 tons.

The energy‑saving and environmental‑protection renovation project of Luoyang Tianping Molecular Sieve Co., Ltd. was filed with the Development and Reform Commission of Jili District, Luoyang City, on October 11, 2017, under filing number 2017‑410306‑26‑03‑023405. This project represents a technological upgrade undertaken by the company based on its existing 3,000 t/a molecular sieve production facility. Specifically, the original one coal‑fired boiler and two coal‑fired calcination furnaces have been replaced by one gas‑fired boiler and six gas‑fired calcination furnaces, with a total investment of RMB 1.8 million. The scope of this acceptance inspection focuses primarily on the pollutant emissions and the operational status of the environmental protection facilities following the conversion of one coal‑fired boiler and two coal‑fired calcination furnaces into one gas‑fired boiler and six gas‑fired calcination furnaces; it does not cover any other aspects of the production process.

This project was constructed prior to obtaining the requisite approval. The Jili Branch of the Luoyang Municipal Environmental Protection Bureau imposed a penalty and required the completion of the necessary formalities. On May 9, 2019, the enterprise paid the fine and commissioned Beijing Huaxia Boxin Consulting Co., Ltd. to prepare the “Environmental Impact Report Form for the Energy-Saving and Environmental Protection Retrofit Project of Luoyang Tianping Molecular Sieve Co., Ltd.” In June 2019, the Jili Branch of the Luoyang Municipal Ecology and Environment Bureau reviewed and approved the energy-saving and environmental protection retrofit project of Luoyang Tianping Molecular Sieve Co., Ltd., issuing Document No. Luoji Huan Shen [2019] No. 10.

The project was publicly announced as completed on October 25, 2019. From November 2019 to January 2020, relevant equipment was commissioned and adjusted. By January 2020, all equipment had been fully commissioned and was operating normally. On January 17–18, 2020, Henan Sanqing Environmental Testing Co., Ltd. conducted acceptance monitoring for the “Luoyang Tianping Molecular Sieve Co., Ltd. Energy-Saving and Environmental Protection Retrofit Project.” Because the project’s gas-fired calcination furnace did not meet the conditions for installing low-NOx burners, the EIA requirement to install such burners on all gas-fired calcination furnaces was not fulfilled, and the actual total emissions of nitrogen oxides exceeded the EIA‑calculated baseline. In response, the company carried out corrective measures from May to July 2020, conducted a post‑implementation environmental impact assessment for the project, and filed the results with the Jili Branch of the Luoyang Municipal Environmental Protection Bureau.

II. Engineering Change Details

The project’s land area, geographic location, surrounding environment, principal construction components, and plant‑site layout are all consistent with the environmental impact assessment (EIA). The main changes are as follows: ① Since the enterprise’s gas‑fired calcination furnace does not meet the technical requirements for installing low‑NOx burners, the EIA requirement to equip all such furnaces with low‑NOx burners was not implemented. Consequently, the total NOx emissions have increased compared with the EIA estimates; however, they still comply with the special emission limit of 100 mg/m³ for NOx stipulated in the “Emission Standard for Pollutants from the Inorganic Chemical Industry” (GB 31573‑2015). According to the post‑evaluation findings, the project’s actual total NOx emissions exceed the amount approved in the EIA, but this has not resulted in any measurable changes in regional ambient air quality, indicating a limited environmental impact on the local area. ② Compared with the EIA, an additional exhaust stack has been installed for the flue gases from the calcination furnace’s material loading and unloading processes; this addition reflects an environmentally‑friendly upgrade of the enterprise’s dust‑control measures. The project’s site location, production process, production scale, and environmental protection measures remain unchanged; therefore, these modifications do not constitute significant changes.

III. Construction, Commissioning, and Emission Status of Environmental Protection Facilities

1. Waste gas

The waste gases generated by this technical renovation project primarily consist of flue gases from natural gas-fired boilers and natural gas calcination furnaces, with particulate matter, SO2, and NOx as the major pollutants. The exhaust from the gas-fired calcination furnace contains particulate matter as the primary pollutant.

During the acceptance monitoring period, the natural gas boiler was equipped with a low‑NOx burner (model CZI series ultra‑low‑NOx steam boiler [LSS2‑1.0‑Q]). The flue gas emissions—particulate matter, SO₂, and NOₓ—were all found to comply with the limit values specified in the Special Emission Standards of the “Emission Standard for Air Pollutants from Boilers” (GB 13271‑2014), namely particulate matter ≤ 20 mg/m³, SO₂ ≤ 50 mg/m³, NOₓ ≤ 150 mg/m³, and flue gas opacity ≤ Grade 1 (at a reference oxygen content of 3.5%). Furthermore, these results met the requirements set forth in the “Notice of the Henan Provincial Department of Ecology and Environment on Issuing Six Special Action Plans for Industrial Air Pollution Prevention and Control in Henan Province” (Yu Huan Wen [2019] No. 84), specifically the “Henan Province 2019 Comprehensive Boiler Remediation Plan,” which stipulates that newly built industrial gas‑fired boilers shall undergo simultaneous low‑NOx retrofitting, with NOₓ emission concentrations not exceeding 30 mg/m³.

The calcination furnace employs a premixed low-NOx combustion technology, and the concentrations of particulate matter, SO2, and NOx in its flue gas—converted to standard conditions—fully comply with the emission limits specified in the “Emission Standard for Pollutants from the Inorganic Chemical Industry” (GB 31573‑2015), namely 10 mg/m³ for particulate matter, 100 mg/m³ for SO2, and 100 mg/m³ for NOx, all based on a reference oxygen content of 8%.

After being treated by a baghouse dust collector, the particulate matter concentrations in the exhaust stacks of the roasting furnace all comply with the limit of 10 mg/m³ for particulate matter (referenced to an oxygen content of 8%) stipulated in the Special Emission Standard of the “Emission Standard for Pollutants from the Inorganic Chemical Industry” (GB 31573-2015).

2. Wastewater

During the acceptance monitoring period, all parameters at the enterprise’s total wastewater discharge outlet complied with the indirect discharge limits specified in Table 1 of the Emission Standard for Pollutants from the Inorganic Chemical Industry (GB 31573-2015).

3. Noise

Following the implementation of vibration isolation and sound insulation measures for enterprise equipment, acceptance monitoring results indicate that the noise levels at the plant’s perimeter comply with the Class 3 requirements of the Environmental Noise Emission Standard for Industrial Enterprises (GB 12348-2008).

4. Recommended Indicators for Total Volume Control

Total approved emission limits: SO2: 0.6715 t/a, NOx: 0.6596 t/a, COD: 0.2984 t, ammonia nitrogen: 0.0378 t/a; post‑environmental impact assessment calculated totals: SO2: 0.2182 t/a, NOx: 2.7836 t/a, COD: 0.0535 t/a, ammonia nitrogen: 0.0041 t/a.

During actual operation, the total emissions were as follows: SO2: 0.2182 t/a, NOx: 2.78364 t/a, COD: 0.3022 t/a, and ammonia nitrogen: 0.0041 t/a. SO2 and ammonia nitrogen remained below the total emission limits approved in the environmental impact assessment, while NOx and COD exceeded those limits, thereby complying with the total emission thresholds established in the post‑assessment of environmental impacts.

The actual emissions of nitrogen oxides exceeded the total permitted amount approved in the environmental impact assessment by 2.2124 t/a. The primary reason for this increase is that the plant’s actual natural gas consumption surpassed the design‑based consumption, and the measured concentration of nitrogen oxide emissions (43–64 mg/m³) was slightly higher than the estimated value from the EIA (41.9 mg/m³). Similarly, COD emissions were marginally higher than the total permitted amount specified in the EIA by 0.0038 t/a, primarily because the EIA did not account for the discharge of wash water from the crystallization and exchange processes at the existing facility; the COD load associated with this discharged wastewater amounts to 0.0038 t/a.

IV. Acceptance Conclusion

The acceptance report is well-structured, comprehensive in content, clearly written, and consistent with the actual on-site construction conditions. By completing the preparation and filing of the post‑environmental impact assessment report, Luoyang Tianping Molecular Sieve Co., Ltd. has addressed the issues specified in Paragraphs 1 and 2 of Article 8 of the Interim Measures for Environmental Protection Acceptance upon Completion of Construction Projects, thereby meeting the requirements of these measures. The acceptance panel unanimously agrees that the energy‑saving and environmental‑protection renovation project of Luoyang Tianping Molecular Sieve Co., Ltd. has passed acceptance.

V. Recommendations and Requirements

1. Strengthen the daily maintenance and management of environmental protection facilities to ensure their stable operation and the long-term, consistent compliance of all pollutant emissions with regulatory standards.

2. Establish and improve all environmental protection rules and regulations, strengthen daily oversight, strictly enforce national environmental protection laws, regulations, and policies, and voluntarily accept the supervision and management of the environmental protection authorities.

Luoyang Tianping Molecular Sieve Co., Ltd.

2020.8.9