Professional Documents
Culture Documents
Kimberley A. Warren
University of Hong Kong
Ning Duan
China National Cleaner Production Center
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mental Protection of Capital Construction Projects to receive project approval from governmental agencies, such as planning or land management
departments. The guidelines establish an overall environmental management system for construction projects, which consists of five stages:
Project proposal
Project feasibility study
Project design
Project construction, and
Inspection and approval (of the completed project).
The first two stages of the system are part of the EIA regulatory process;
the latter three stages are carried out under the three synchronizations
program. This program stipulates that environmental protection measures
that are identified in the first two stages of the EIA management process
must be designed, constructed, and operated simultaneously with the design,
construction, and operation, respectively, of projects main facilities.
The project proposal stage is designed to provide a brief introduction to
the project, including facility siting issues and potential environment impacts. In the second stage, the project feasibility study, an EIA is carried
out. In theory, this suggests that project proponents carry out EIA analyses
prior to the design stage of their projects. However, in practice it is common
for project proponents to write their project proposals after decisions about
the projects location and final design have been made. Thus, major decisions regarding process technologies and plant design are made prior to
the feasibility study phase, i.e., before an EIA is carried out. As discussed
later, by bringing their completed plant and treatment facility designs to
the table at such an early stage, project proponents make it difficult for
alternative project designs (e.g., cleaner production technologies) or facility
locations to be considered and integrated into subsequent EIA analyses.
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completed, the organization conducting the EIA carries out the EIA and
submits the EIA report to the responsible environmental agency. The latter
organizes a second review meeting to evaluate the EIA report and decide
whether the project requires additional EOP treatment facilities to reduce
the projects environmental impacts, or whether the project should be
allowed to go forward.
The aforementioned two review meetings by SEPA or a local EPB play
a key role in controlling the quality of the EIA and the project. Participants
at these meetings include environmental agency staff and environmental
experts invited to participate in the reviews. Officials and invited experts
often focus strictly on the degree of environmental impact that a proposed
project may cause; however, they also may evaluate specific technical details
of the project, such as the type of production process selected.
Limitations of the Existing EIA System in China
Several serious limitations exist in the current EIA system in China. First,
EIA procedures and requirements, as defined in the Environmental Protection Law of the PRC (1989) and the Management Procedures for Environmental Protection of Capital Construction Projects (1986) do not specifically require the use of cleaner production. Although this situation has
improved with the November 1998 revisions to the management guidelines,
which now include CP provisions for some industry construction projects,
the effects of those revisions will not be felt immediately. The past regulatory climate continues to ensure that project proponents overwhelmingly
choose EOP treatment facilities to satisfy EIA requirements. This occurs
at all levels of investment.
Second, EIAs have primarily been conducted for large industrial projects;
most small industrial pollution sources have ignored EIA requirements.
Third, as discussed earlier, EIAs have often been conducted well into
the development stage of a construction project, long after project design
decisions have been made. The failure to conduct EIAs prior to the design
and facility siting phases of a development project makes it difficult to
integrate cleaner production approaches into the projects overall development. Last, the financial capabilities of enterprises have not been adequately accounted for in the EIA review process. As a result, enterprises that
cannot afford to operate treatment facilities continue to receive project
and EIA approvals.
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grated into Chinas EIA procedures. These regulations and policies often
assume that pollution will be created, and that the way to deal with it is
to require the purchase and use of EOP treatment facilities. This situation
encourages enterprises to view environmental protection (and EIA procedures) in terms of EOP treatmentto the great detriment of the promotion
of cleaner production concepts and methodologies in China.
Moreover, with regards to the evaluation and approval of EIAs, in the
past it has been the case that if a proposed project meets national and local
discharge standards, in general it will be approved. In other words, as long
as the project proponent installs sufficient EOP facilities to meet discharge
standardsregardless of whether the production technology selected is the
least polluting choicethe project is approved. For example, in China,
many old factories produce serious pollution. When proposals are submitted
to expand or renovate these factories, the EIAs must examine the pollutants
created by all production processes. The requirement that expanded renovated factories meet environmental standards often is satisfied by installing
sufficiently large EOP treatment facilities, rather than through technical
innovations or cleaner production measures.
The policy climate for EIA, however, is rapidly changing. EIA regulations
and procedures currently are being revised at both the national and local
levels in China (e.g., some new provisions require use of cutting-edge CP
technologies by firms in the industrialized provinces of southeast China),
and these policy changes are applying increasing pressure on enterprises
to incorporate CP options into their proposed projects.
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CP includes the use of non-toxic production processes, raw materials substitution, internal recycling, and energy efficiency measures.
Since 1992, with the assistance of the World Bank, the United Nations
Industrial Development Organization (UNIDO), the United Nations Environment Programme (UNEP), and other agencies, China has conducted
theoretical research, enterprise demonstration projects, and information
dissemination activities for cleaner production. These activities have been
part of an on-going project (referred to as the B-4 project) conducted
jointly with SEPA to fast-track the adoption of CP methods in China.
So far, remarkable progress has been made.
As part of the B-4 project, CP audits have been carried out in more than
200 enterprises in the following sectors: textiles, chemicals and petrochemicals, electroplating, pharmaceuticals, breweries, food and beverages, and
pulp and paper. The demonstration projects have shown that outstanding
economic and environmental benefits can be achieved by enterprises implementing CP technologies.6
In addition to sponsoring demonstration projects, the B-4 project supported the creation of the China National Cleaner Production Center
(CNCPC) in 1994. Provincial and sector-related cleaner production centers
were established through China in the mid and late 1990s. These national
and regional CP centers now function as the core strength for developing
and disseminating CP methods in China.
Moreover, through close exchange with foreign CP experts and continuous participation by many domestic enterprises, China has established its
own CP methodology system. This methodology has been accepted as the
standard for China by the CNCPC, regional and sector CP centers, and
academic and industrial organizations involved in CP work. These organizations have promoted the use of this CP methodology by enterprises in
China through publication of CP audit manuals and training materials for
enterprises. The following section elaborates on the CP methodology and
discusses how it will be integrated into procedures for EIA in China.
CP Index and Evaluation System in China
Based on research conducted by SEPA and the CNCPC on incorporating
cleaner production analysis into EIA, a CP Index and Evaluation System
(CPIES) was developed. In devising this system, SEPA and the CNCPC
consulted with environmental management staff at enterprises, and EIA
and CP experts in numerous Chinese organizations (e.g., universities). Staff
6
In general, with a very low investment, a typical enterprise participating in the B-4 project has reduced
its total amount of wastewater discharged by 10% to 20%, and its total pollutants generated by 8% to
15%. According to results from the B-4 project for 29 key enterprises, each 1,000 yuan ($120 US) investment
in CP reduced the amount of COD wastewater generated by 5.4 tons per year, and yielded annual average
economic benefits of 30,674 yuan ($3,696 US). The 29 enterprises invested a total of 0.78 million yuan
($93,976 US) to carry out no- and low-cost CP options. Economic benefits from some of these CP options in
individual factories led to annual economic benefits of up to 2.9 million yuan ($349,000 US) (CRAES 1996).
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at SEPA and CNCPC also reviewed data on CP audits in China and abroad,
and they conducted site visits to 100 enterprises to collect and analyze CP
results. These analyses revealed that enterprises needed a simple, easy-touse method to evaluate their existing and proposed products, production
processes, equipment, and technologies in terms of CP. The CPIES system
was developed to address this need, and the system will be applied to EIA
projects in China in an effort to decrease the time it takes to conduct CP
audits in enterprises.
The index and evaluation system is based on CP criteria, i.e., criteria
against which enterprises or EPB staff can measure and evaluate CP performance.7 As shown in Table 1, the CP criteria are divided into four main
categories: raw materials, products, resource use, and pollutant generation.
Raw materials criteria gauge the comprehensive environmental impact of
the extraction, processing, and utilization of raw materials in a production
process or product cycle. Products criteria analyze the environmental impacts of a products sale, distribution, consumption, and disposal. Resource
use criteria estimate the amounts of water, energy, and other resources
used during production of a single unit of product. Pollutant generation
criteria quantify the total and individual amounts of pollutants created in
producing a single unit of product. In effect, the CP criteria gauge the total
impact to the ecological environment of an enterprises single production
process or product line, or of entire production systems.
The CP criteria listed in Table 1 can be separated into two general
classes: qualitative criteria (raw materials criteria and product criteria) and
quantitative criteria (resource use criteria and pollutant generation criteria).
Different weighting (which CP and EIA experts in China are now evaluating) and scores in the final evaluation are assigned to qualitative and quantitative criteria, as shown in Tables 2 and 3. Note that lower marks on an
individual criterion correspond to more damaging environmental impacts.
Thus, when each of the individual marks is given a weight and the weighted
marks are summed to provide a total score, a higher score corresponds to
a cleaner project in terms of environmental impacts and CP performance.
The final evaluation of cleaner production is simple. Enterprises sum the
weighted scores for each criterion and compare their results with those
listed in Table 4. If the total score an enterprise receives is above 80, it
means, on average, the proposed construction project reaches an advanced
CP level. In other words, according to the present technological level the
process, product, project, or enterprise is clean. Scores between 70 and
80 indicate an advanced project, process, or enterprise in terms of CP,
and so on.
7
The CPIES and the principle of using criteria to assess and evaluate environmental performance was
based on the theory and practice of lifecycle assessment (LCA). The latter involves evaluating the effects
that a product has on the environment over the entire period of its lifecycle, from raw material extraction
to the ultimate disposal of the product.
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Criterion
Toxicity
Ecological impact
Recoverability
Energy intensity
Reusability and
recyclability
Products
Sale and
distribution
Consumption
Product life
optimization
Disposal
Resource use
Fresh water
Energy
Others
Pollutant
generation
Wastewater
Waste gas
Solid waste
Meaning of Criterion
Degree of impact to ecological environment
caused by toxic component of the raw
materials
Degree of impact to ecological environment
caused by the extraction of raw materials
Degree to which raw materials can be
recovered to produce new raw materials
(e.g., chemical recovery)
Degree of energy consumption of
extracting and producing the raw
materials
Degree of reuse and recycling of raw
materials (which may cause secondary
environmental problems)
Degree of environmental impact from
product sale, transport, and distribution
(e.g., from factory to consumer retail
outlet)
Degree of impact caused by consumption
of products, including consumption of
energy and other products during
product use
Degree of product lifetime optimization,
including technical and aesthetic product
service life (e.g., length of acceptable
aesthetic appeal to consumers)
Degree of environmental impact caused by
product disposal after final use
Amount of fresh water consumption per
unit product
Amount of energy consumption per unit
product
Amount of other material consumption per
unit product
Amount of watewater generated per unit
product
Amount of main pollutants (e.g., heavy
metals) in wastewater per unit product
Amount of waste gas generated per unit
product
Amount of main pollutants in waste gas
per unit product
Amount of solid waste generated per unit
product
Amount of main pollutants in solid waste
per unit product
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Quantitative criteria
Values
Value Meaning
Range of
Marks
High
Medium
Low
Very clean
Clean
Ordinary
Poor
Very poor
0.71.0
0.30.7
0.00.3
0.81.0
0.60.8
0.40.6
0.20.4
0.00.2
To use the CPIES, factories, EIA consultants, and local EPBs will need
detailed and accurate information on best CP practices and available technologies for any given industrial category. In addition to data supplied by
factories to local EPBs and other government units, information sources
for using the CPIES include industrial ministries, technical associations,
environmental agencies, international organizations, CP roundtables, and
companies specializing in CP.
Products
Resource use
Pollutant generation
Total score
Weight Value
Toxicity
Ecological impact
Recoverability
Energy intensity
Reusability and recyclability
Subtotal
Sales and distribution
Consumption
Product life optimization
Disposal
Subtotal
Fresh water
Energy
Others
Subtotal
7
6
4
4
4
25
3
4
5
5
17
11
10
8
29a
29
100
a
The total weight value of the resource use and pollutants generated categories is 29 each. For resource
use, the weighting values in this table are often used during the CP analysis. However, for both categories,
the weights may vary, with apportionment of the total 29 points among each individual criterion being
determined on a case-by-case basis.
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Interpretation
.80
7080
5570
4055
,40
Clean
Advanced
Ordinary
Backward
Elimination
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TABLE 5. CPIES Analysis Results for Existing Straw Pulp (No Alkali Recovery) Process at Suiping Pulp & Paper Milla
CP Evaluation
Criterion
Raw materials
Toxicity
Ecological impact
Recoverability
Energy intensity
Reusability and
recyclability
High:
High:
High:
High:
High:
High: 0.9
High: 0.9
Medium: 0.5
High: 0.7
Total wastewater
COD generated
BOD generated
Suspended solids
Subtotal
Products
Subtotal
Resource useb
Subtotal
Pollutant
generationc
Subtotal
Total score
Value: Marks
0.7
0.9
0.9
0.9
0.7
Weight
Marks
7
6
4
4
4
4.9
5.4
3.6
3.6
2.8
25
3
4
5
5
17
15
4
4
6
29
9
20.3
2.7
3.6
2.5
3.5
12.3
0.0
2.0
3.0
0.0
5.0
0
7
7
6
29
0
0
0
0
37.60
Because the existing and proposed processes use the same raw materials
and make the same products, the scores for raw materials and products
are identical. Results of applying the CPIES indicated that the existing
pulping process used by Suiping Pulp & Paper Mill had a score of only 37.6.
As Table 4 shows, any process with a score below 40 should be eliminated.
An assessment based on the CPIES was performed for the alkali pulp
recovery process proposed by the factory in its EIA report. The total score
for the proposed expansion project was 69.53, which is between 55 and 70
and thus corresponds to an ordinary level for pulp processes in China
today. The production process used in the proposed expansion project thus
is acceptable. However, the final score of 69.53 indicates that resource use
and pollutant generation aspects of the proposed new process could be
greatly improved.
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Raw
Materials
Products
Resource
Use
20.3
12.3
5.0
20.3
12.3
16.95
Pollutant
Generation
0
17.98
Total
37.60
69.53
The value of the CPIES is that its results would show that the proposed
pulp-making process is ordinary, meaning that it would result in notable
pollution discharges. Based on the factorys location and other factors,
managers at Suiping Mill or local EPB staff who are evaluating Suipings
EIA proposal could identify and predict that negative environmental impacts to local receiving waters would occur if the proposed technology were
approved. EPB staff could use these results to recommend to the factory
that to receive EIA approval, staff must reassess the proposed production
process and choose less-polluting, best available CP technologies. If the
Suiping Mill followed this recommendation and adopted additional CP
production methods, it could reduce the factorys resource use and pollution
levels, which were shown by the CP analysis to be high relative to advanced
pulp and paper mills in China and abroad.
Integrating CP into Chinas EIA System
Chinas environmental protection and economic development agencies can
use the EIA system to foster cleaner production and put an end to the
high input and low output problems that have characterized Chinese
industry for many years. CP analyses of the type done for the Suiping
Pulp & Paper Mill can help to identify industrial projects with backward
technologies, high resource and energy consumption, and serious pollution
problems. More generally, CPIES analyses could be used by local EPBs
to screen out small, poorly designed industrial projects that, in the past,
often have generated serious pollution and failed to meet standards because
of a shortage of funds to operate EOP treatment facilities.
How will cleaner production be incorporated into the existing EIA system
in China? Several possibilities exist, including EIA policy and procedural
changes and the application of cleaner production audits and the CPIES
as illustrated above for the Suiping Pulp & Paper Mill. The current EIA
system in China does not require enterprises to conduct a CP analysis or
audit during an EIA. Revisions in EIA regulations (and those of the related
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