Letter:

According to the “Construction Environmental Protection Acceptance Technical Guidelines for Construction Projects”, “6.3.2 Environmental Quality Impact Monitoring: Mainly for environmental impact reports (tables) and the environmental quality of environmentally sensitive protection targets that are of concern in the approval decisions of the approval departments, This includes monitoring of surface water, groundwater and seawater, ambient air, acoustic environment, soil environment, and radiation environmental quality. How to judge this "concern". For example, in the EIA report, the three simultaneous acceptance forms refer to the groundwater seepage prevention requirements, and the environmental monitoring plan has the groundwater monitoring category. Should the groundwater monitoring be carried out during the project acceptance process?

Reply:

I. “Technical Guidelines for Environmental Protection Acceptance of Completion of Construction Projects” “6.3.2 Environmental Quality Impact Monitoring: Environmental Quality Impact Monitoring is mainly for environmental impact reports (tables) and environmentally sensitive protection targets of concern in the approval decisions of the approval departments. "Concern" in the environmental quality, including surface water, groundwater and seawater, ambient air, acoustic environment, soil environment, radiation environmental quality, etc., refers to the environmental impact report (form) and the EIA approval document Environmentally sensitive protection goals. Monitoring the environmental quality of environmentally sensitive protection targets during acceptance can provide a basis for determining the impact of construction projects on the surrounding environmental quality.

 2. If the “three simultaneous” acceptance form in the EIA report refers to groundwater seepage prevention requirements and there is a groundwater monitoring category in the environmental monitoring plan, groundwater monitoring should be carried out during the acceptance. The monitoring points and factors can be selected according to the requirements of the environmental assessment.

Reply to the "Technical Specifications for Environmental Protection in the Catering Industry" and the "Research on the Law of the People's Republic of China on Prevention and Control of Air Pollution"

Letter:

1. "Technical Specifications for Environmental Protection in the Catering Industry" HJ554-2010 6.1.1 The gas collecting hood should be installed above the processing facilities such as the stove, steamer and oven (box) of the kitchen. The exhaust pipes of the oil fume and hot steam should be set separately. . Consult: After the exhaust ducts of the oil flue gas and the hot steam are respectively set, whether the layout requirements of the hot steam discharge port are similar to or lower than the layout requirements of the fume exhaust port. 2. The second paragraph of the Law of the People's Republic of China on Prevention and Control of Atmospheric Pollution prohibits the construction and renovation of commercial residential floors adjacent to residential buildings in residential buildings, commercial and residential complexes not equipped with dedicated flue, and commercial and residential complexes. Expansion of catering services that produce soot, odor and waste gas. Ask: The restaurant specializes in dumplings, buns, clams, bone soup, all kinds of covered noodles and other foods. The steaming hot steam collected by the gas collecting hood above the processing facilities such as noodle pot, soup pot and steamer is discharged to the store through the exhaust fan. Whether such steamed hot steam with odor is in the category of "exhaust gas".

Reply:

1. The Technical Specification for Environmental Protection in the Catering Industry (HJ 554-2010) requires that the gas collecting hood should be installed above the processing facilities such as the stove, steamer and oven (box) of the kitchen. The exhaust ducts of the oil fume and the hot steam should be respectively separated. Set up and stipulate the layout requirements of the soot discharge. There is no requirement for the arrangement of the hot steam discharge port, but it is necessary to avoid the impact on the surrounding residents' lives and lead to complaints.

 Second, the cooking steam with hot odor in the restaurant belongs to the special odor produced by the catering industry, and is implemented according to the odor concentration index of the odor emission standard (GB14554-93).

Reply on how to judge the eligibility of the quality control sample in the online comparison

Letter:

"H.H.T. 354-2007 Water Pollution Source Online Monitoring System Acceptance Technical Specification" in "5.1.2.2 Quality Control Sample Evaluation", in which "the relative error of quality control sample measurement is not more than ±10% of the standard value" should be understood, for example The concentration of the certified quality control sample purchased is (0.400±0.02)mg/L, and the online equipment monitoring concentration is 0.371mg/L. The data is qualified. How to calculate it, thank you, some online operation and maintenance manufacturers inform them to use online monitoring directly. The value is compared with ±10% of the standard value, that is, 0.371 mg/L is in the range of (0.36~0.44) mg/L, indicating that it is qualified, but no clear text is found, and the relative error of the quality control sample is said in the standard. "What is the meaning, and personal understanding of the relative error is a percentage, ± 10% of the standard value is an accurate range of values, can this be compared?

Reply:

In the Technical Specification for Acceptance of Online Monitoring System for Water Pollution Sources (HJ/T 354-2007), the relative error of the quality control sample measurement is not more than ±10% of the standard value, which means the relative value between the measured value of the quality control sample and the standard value. The error should be within ±10%.

The calculation formula is: (quality control sample value - standard value) / standard value × 100%. If the measured value of the quality control sample is 0.371 mg/L and the standard value is 0.400 mg/L, the relative error is (0.371-0.400)/0.400×100%=-7.2%, and it is judged that the quality control sample is qualified.

Reply to the definition of hazardous waste recovery

Letter:

The question about the recycling of a hazardous waste cannot be defined. Recently, when we inspected a garage in a jurisdiction, we found that the unit sold the used engine oil to a non-hazardous waste business license. After the investigation, the dealer resold the recovered motor oil to a construction site for demolding. use. Since the oil collected by the trader can be used for secondary use, whether the oil should be characterized as hazardous waste, whether the behavior of the garage can be characterized as an illegal act of entrusting hazardous waste to an individual without a license.

Reply:

1. The waste engine oil produced by the auto repair factory belongs to the “900-214-08 vehicle in the category “HW08 waste mineral oil and mineral oil-containing waste” listed in the “National Hazardous Waste List” (Order No. 39 of the Ministry of Environmental Protection). Waste lubricating oil such as waste engine oil, brake oil, automatic transmission oil, gear oil, etc. generated during mechanical maintenance and disassembly."

 2. The auto repair factory sells the waste engine oil to the non-hazardous waste business license. It belongs to the "People's Republic of China Solid Waste Environmental Pollution Prevention and Control Law", Article 37, paragraph 3, "Providing or entrusting hazardous waste to The case where the unit without a business license engages in the business activities of collection, storage, utilization and disposal.

Reply on whether the construction project completion environmental protection acceptance management method is abolished

Letter:

Since 2015, the National People's Congress has revised a series of laws such as the Environmental Protection Law, the Law on Prevention and Control of Air Pollution, the Law on Prevention and Control of Water Pollution, and the Law on Prevention and Control of Environmental Noise Pollution. The State Council has revised the Regulations on Environmental Protection Management of Construction Projects. The Ministry of Ecology and Environment also issued the Interim Measures for the Environmental Protection Acceptance of Construction Projects. The Ministry of Environmental Protection announced that the "Notice on Promulgating the Catalogue of Existing and Effective National Environmental Protection Department Regulations" (Announcement No. 68 of the 2016) does not include the Measures for the Administration of Environmental Protection Acceptance for Construction Projects (Order No. 13 of the State Environmental Protection Administration) Has the “Measures for the Administration of Environmental Protection Acceptance for Completion of Construction Projects” (Order No. 13 of the State Environmental Protection Administration Order) been abolished?

Reply:

On December 27, 2001, the Measures for the Administration of Environmental Protection Acceptance for Construction Projects (No. 13 of the State Environmental Protection Administration) issued by the former State Environmental Protection Administration have not been abolished.

Reply to whether waste waste caustic soda waste can be included in the enterprise sewage treatment system

Letter:

According to the National Hazardous Waste List (2016), the waste acid produced by pickling is hazardous waste, and the hazardous waste category is waste acid HW34, waste code 900-300-34. The hazardous waste category of the caustic soda produced by caustic washing is waste alkali HW35, waste code 900-352-35. In accordance with the "Technical Policy for the Prevention and Control of Hazardous Waste Pollution": 2.2 The hazardous wastes that have already been produced must be registered and registered in accordance with the relevant provisions of the State, and special facilities and sites that meet the standards should be properly preserved and a hazardous waste signage plate should be set up, and disposed of or disposed of according to relevant regulations. It shall be collected, transported, stored and disposed of by the unit holding the hazardous waste business license. Measures should be taken to reduce the volume, weight and hazard of hazardous waste during handling.

 In the production process of an enterprise, acid and alkali are used for pickling and alkali washing to produce waste acid and caustic soda. According to the actual test results, the waste acid PH<2, the waste alkali PH>12.5, according to the “corrosion identification of hazardous waste identification standards” is dangerous. Waste, can this waste acid and waste alkali be neutralized by the company or enter the company's own sewage treatment system?

Reply:

The waste acid and waste alkali produced by your company can be disposed of and disposed of according to relevant regulations. However, the construction of treatment and disposal facilities must be strictly in accordance with the requirements of the EIA document to ensure that the disposal and disposal facilities are stable and up to standard discharge.

Reply to the selection of soil status monitoring factors

Letter:

The large-scale water conservancy project will carry out the monitoring of the status quo of the soil environment. The area is the valley section. The current situation is basically farmland or unused land. According to the new guidelines, it is proposed to select 36600 soil risk management standards for construction land within the reservoir area (including the dam site area). According to the prescribed 45 factors, 8 factors specified in the 15618 Agricultural Land Soil Pollution Risk Control Standard are selected outside the reservoir area, and the soil background salt content is additionally measured. Is it appropriate to understand and select soil environmental monitoring factors? Do you need to monitor the downstream of the dam site?

Reply:

For the large-scale water conservancy project, the monitoring of the status of the soil environment is carried out. The area is the valley section. The current situation is basically farmland or unused land. It is proposed to select 45 monitoring factors specified in GB3600 within the scope of the reservoir area. The monitoring factor is added to measure the salt content of the soil background. Whether the selected soil environmental monitoring factor is appropriate, and whether there is a need to report the problem of monitoring the downstream of the dam site:

 “Technical Guidelines for Environmental Impact Assessment Soil Environment (Trial)” (HJ964-2018) stipulates that “the monitoring factors of soil environmental status are divided into basic factors and characteristic factors of construction projects. The basic factors are the basic items specified in GB15618 and GB36600, respectively. According to the type of land use within the scope of investigation and evaluation; the characteristic factor is the unique factor produced by the construction project."

After confirming with the letter, the letter area indicated by the letter is the flooded area of the water conservancy project, and does not include the dam area. Generally, the basic factors for monitoring the status of soil environment in the scope of investigation and evaluation should adopt the basic items stipulated in GB15618. However, if the status of land use within the reservoir area is the construction land with pollution sources (such as landfills, etc.), the basic items specified in GB36600 and the characteristic pollutants that may exist should be used.

The large-scale water conservancy project belongs to the ecological impact type. The selection of characteristic factors should consider the influencing factors of special soil types such as salinization, acidification and alkalization. For example, the acidification soil characteristic factor should be selected pH, and the salinized soil characteristic factor should be selected from pH and salt. the amount.

 Whether it is necessary to carry out monitoring at the downstream of the dam site is mainly determined according to the scope of investigation and evaluation. HJ964-2018 stipulates that “the scope of investigation and evaluation shall include the scope of possible impacts of construction projects, which can meet the requirements for soil environmental impact prediction and evaluation; the scope of investigation and evaluation of the status of renovation and expansion projects should also take into account the scope of possible impact of existing projects”.

 Reply on sewage discharge standards

Letter:

After the implementation of the “Integrated Wastewater Discharge Standard for the Yellow River Basin in Shaanxi Province” DB 61/224-2018, for the indirect discharge of sewage, and there is no industry standard, the sewage discharge shall be subject to the “Comprehensive Pollutant Discharge Standard” GB 8978-1996 or “Sewage Discharge into Urban Sewers”. Water quality standard CJ 343-2010.

Reply:

Article 50 of the Law of the People's Republic of China on Prevention and Control of Water Pollution stipulates: “The discharge of water pollutants from urban sewage centralized treatment facilities shall comply with the national or local standards for discharge of water pollutants.” “Comprehensive discharge standards for wastewater from the Yellow River Basin in Shaanxi Province” (DB 61/224-2018) stipulates: “The emitters that implement indirect emissions implement the corresponding national emission standards.” According to this, after the implementation of DB61/224-2018, for units that indirectly discharge sewage, there should be no national industry emission standards. Implement the indirect emission control requirements of the Integrated Wastewater Discharge Standard (GB 8978). When sewage is discharged into the urban drainage pipe network, it should also meet the relevant requirements of urban drainage management.

Reply to the implementation of domestic sewage in the industry standard

Letter:

The industry standards for "Contaminant Discharge Standards for Rubber Products Industry (GB 27632-2011)" and "Emission Standards for Pollutants for Battery Industry (GB 30484-2013)" all clarify that the displacement includes domestic sewage in the plant area, but it is not clear whether domestic sewage discharge should be implemented. standard. At the time of project review, experts are required to implement the above-mentioned industry standards for domestic sewage that is taken over to the municipal sewage treatment plant.

In the administrative area where we are located, the municipal sewage pipe network has been well-equipped, the district has built a centralized sewage treatment plant with sufficient capacity, and the local environmental authorities also require the enterprise four water (production wastewater, domestic sewage, clean water and Rainwater is diverted and requires production wastewater to be reduced or a certain percentage of reuse requirements. Domestic sewage relies on the established municipal facilities, and the production wastewater is discharged and reused by itself, which is more in line with the environment. Excuse me, rubber products and battery processing companies, can domestic sewage be implemented in the city sewage treatment plant takeover standards?

Reply:

"Rubber Products Industrial Pollutant Emission Standards" (GB 27632-2011) and "Battery Industry Pollutant Emission Standards" (GB 30484-2013) all specify the effluent wastewater including the domestic sewage in the plant area in the definition of "discharge volume". The main consideration is prevention. The production of domestic sewage in the plant-related area is mixed with industrial characteristic pollutants, and the production wastewater is discharged through the domestic sewage drainage pipe. To this end, the domestic sewage of the relevant enterprises should be controlled in accordance with industry emission standards. If the living and production wastewater is completely isolated, and effective measures are taken to prevent the risk of mixing between the two, such domestic sewage can be managed according to general domestic sewage.

Reply on GB36600 and risk management of contaminated soil

Letter:

Regarding the first type of land and the second type of land in the GB36600 standard, if the land is a first type of land, the investigation found that the pollutants in the soil exceeded the screening value of the first type of land, and there was pollution, but the pollutant content did not exceed the first The second type of land use screening value. Is it possible to use the second type of land that transports the contaminated soil of the plot to a clearly planned use as a risk management tool?

Reply:

According to the survey, whether the contaminated soil of the first type of land use value in the GB36600 standard exceeds the value of the second type of land use screening site can be transported to the second type of land that has been clearly planned for use as a risk management and control means:

 Contaminated soil transport is not a means of risk control, and transporting contaminated soil should not be used as a solution to soil pollution problems. If it is necessary to carry out ectopic repair or reuse of the soil after repair in the process of implementing contaminated soil treatment and repair, it is necessary to meet the following requirements:

 1. Article 38 of the Law on the Prevention and Control of Soil Pollution stipulates that the implementation of risk management and control activities shall not cause new pollution to the soil and the surrounding environment.

 2. The Technical Guidelines for Risk Control and Pollution Remediation of Polluted Lands (Trial) (HJ25.5-2018) stipulates that if the soil is transported to other plots after remediation, the risk should be based on the soil exposure scenario of the receiving site. The evaluation determines the evaluation standard value, or uses the higher of the soil background concentration of the receiving site and the screening value corresponding to the receiving land property in GB36600 as the evaluation standard value, and ensures the groundwater and environmental safety of the receiving place. Risk assessment can be performed with reference to HJ25.3.

 3. Article 41 of the Law on the Prevention and Control of Soil Pollution shall, in the case of repairing the transfer of contaminated soil by the construction unit, shall formulate a transshipment plan to report the transportation time, mode, route and quantity, destination and final disposal measures of the contaminated soil. The competent authority for the ecological environment of the location and receiving area. The contaminated soil that is transported is classified as hazardous waste, and the repairing construction unit shall dispose of it in accordance with the requirements of laws, regulations and relevant standards.

 4. If the soil pollution concentration received at the receiving place exceeds the risk screening value of the first type of land use, it is necessary to implement risk management and control on the receiving place, and propose environmental management recommendations in accordance with HJ25.5-2018. After receiving the contaminated soil at the receiving place, if the soil pollution status survey, detailed inspection and monitoring, on-site inspection indicate that there is soil pollution risk, or the use is changed to residential, public management and public service land, according to the "Soil Pollution Prevention and Control Law" Conduct a survey of soil pollution status. If the assessment of the soil pollution status report indicates that the pollutant content exceeds the soil pollution risk management and control standards, the units and individuals that transport the contaminated soil shall bear the responsibility for soil pollution.

Reply to the consultation on the completion and acceptance of environmental protection facilities for construction projects

Letter:

In June 2016, our company submitted an application for completion acceptance of construction project environmental protection facilities to the provincial government. In January 2017, the provincial monitoring station issued the environmental monitoring report of the project. In March 2017, the provincial government organized experts to accept the site and put forward rectification opinions. In August, the boiler rectification (increasing the bag dust removal and desulfurization device) and other rectification items were completed. Since it is a heating boiler, the rectified flue gas monitoring needs to be carried out during the heating period (after November). In November, the project site environmental monitoring station will be monitored on site. The monitoring report was issued and the results were satisfactory. The local environmental protection department also issued the acceptance opinions after the rectification.

After our company sent the rectified inspection opinions and monitoring reports to the provincial government, the reply was due to changes in the environmental protection acceptance policy in October, and the completion and acceptance of the construction project environmental protection facilities were organized and accepted by the enterprises themselves. The provincial government has not given an acceptance report. Would you like to consult this situation, can the environmental protection department that organizes the inspection and acceptance still issue an acceptance report to our company? Must we again organize environmental protection acceptance by the company itself?

Reply:

Implementation of construction projects Completion of environmental protection enterprises for self-acceptance is an important measure to deepen the reform of the “environmental management” of the ecological environment system and further implement the main responsibility of the enterprise's ecological environment protection. At present, the "Environmental Protection Law of the People's Republic of China", "The Law of the People's Republic of China on Prevention and Control of Atmospheric Pollution", "The Law of the People's Republic of China on Prevention and Control of Water Pollution" and "Regulations on Environmental Protection Management of Construction Projects" have been revised and successively promul The acceptance of the atmospheric and water pollution prevention and control facilities of the construction project shall be changed by the ecological environment department to the construction unit for self-acceptance.

The Law of the People's Republic of China on the Prevention and Control of Environmental Pollution by Solid Wastes, the Law of the People's Republic of China on the Prevention and Control of Environmental Noise Pollution is still being revised. According to relevant regulations, before the implementation of the above-mentioned solid waste law and noise law, the ecological environment department will The solid waste pollution prevention and control facilities are inspected and accepted.

Please ask your company to classify and deal with the types of pollution prevention and control facilities, that is, organize inspection and acceptance of atmospheric and water pollution prevention and control facilities, and apply for environmental and environmental protection departments to check and accept noise and solid waste pollution prevention facilities.

Reply to the monitoring related issues of the automatic monitoring facility

Letter:

According to the "Technical Regulations for Comparison of Automatic Monitoring Equipment for Pollution Sources", the total number of comparison tests shall be no less than 3 times, and 2 of them shall be qualified for comparison with the actual water samples. In the actual law enforcement process, law enforcement officers found The automatic monitoring facility's digestion time, temperature and other settings do not meet the relevant technical specifications, immediately collect 2 bottles of actual water samples, one bottle immediately on the machine to read the instrument data, and another bottle to the monitoring station for manual monitoring, if found The second comparison is unqualified. There is only one set of comparison data. Can it be determined that the equipment is not working properly? If only the parameter settings such as digestion time and temperature are found to be inconsistent with the technical specifications, and the relevant comparison monitoring is not performed, it can also be determined that the device is not operating normally.

Reply:

For the identification of suspected abnormal operation of automatic monitoring equipment, refer to the relevant provisions of Article 19 of the “Measures for On-site Supervision and Inspection of Pollution Source Automatic Monitoring Facilities” (formerly the Ministry of Environmental Protection Decree No. 19), including: Failure to follow technical specifications, resulting in The pollution source automatically monitors the data with obvious distortion; arbitrarily changes the relevant parameters and data of the pollution source automatic monitoring system.

In the actual law enforcement process, according to the technical specification requirements and law enforcement monitoring results, it is judged whether the data is obviously distorted due to failure to follow the technical specifications, and the operation and maintenance records and the acceptance records are combined to determine whether there is a situation in which the parameter setting is arbitrarily changed.

 Regarding the automatic monitoring facilities for pollution sources, the pollutant discharge unit is responsible for organizing the acceptance of the relevant questions and answers.

Letter:

On August 3, 2017, the Ministry of Environmental Protection issued the “Notice on Accelerating the Automatic Monitoring of Key Polluting Units in Key Industries in Key Industries” (Circular Office [2017] No. 61), clearly stating: “Installation of automatic monitoring equipment for key pollutant discharge units After the completion of the networking or renovation work, the main funders of the acquisition and construction shall organize the inspection and acceptance according to the relevant technical standards, and the relevant materials shall be submitted to the environmental protection department with jurisdiction for the record. Please refer to the problems encountered during the actual implementation process, as follows:

1. How long does it take to complete the acceptance after the installation of the automatic monitoring equipment of the sewage disposal unit? If the acceptance is not completed according to the time limit, is there any corresponding law or regulation to punish?

2. Does the discharge unit organize the acceptance of the need for the participation of relevant experts, is there a specific operational procedure?

3. Does the environmental protection department have to issue opinions on the acceptance information reported by the pollutant discharge unit? Do you want to conduct an on-site audit?

4. Does the automatic monitoring facility acceptance report issued by the pollutant discharge unit have specific format and content requirements?

5. Does the pollutant discharge unit automatically monitor the acceptance of the facility if it needs to be publicized? How long is the public announcement period?

6. The inspection and acceptance time of the automatic monitoring facilities of the sewage disposal unit shall be based on the date of the comparison monitoring report, the date of the automatic monitoring facility acceptance report, or the date of the acceptance data report.

Reply:

1. The specific problems of the automatic monitoring and implementation of the key pollutant discharge unit can be referred to the “Technical Specification for Continuous Monitoring of Fixed Pollution Source Flue Gas (SO2, NOx, Particulate Matter)” (HJ 75) and “Technical Specification for Acceptance of Online Monitoring System for Water Pollution Sources” ( HJ 354) and relevant regulations issued by the local ecological environment department. There are no mandatory requirements for current laws and regulations, departmental regulations, and regulatory documents issued by the Ministry.

 2. If the acceptance is not completed as required, there is no specific punishment clause in the current law. However, the key pollutant discharge units shall install and use automatic monitoring equipment in accordance with laws, regulations and standards, and network with the monitoring equipment of the competent department of ecological environment to ensure the normal operation of the monitoring equipment, preserve the original monitoring records, and be responsible for the authenticity and accuracy of the automatic monitoring data. In the case of regulatory enforcement, it is found that the automatic monitoring equipment is not installed and connected according to the regulations, the monitoring equipment is not guaranteed to operate normally, or the pollutants are discharged by means of tampering or forging monitoring data, etc., in accordance with the Air Pollution Prevention and Control Law. Articles IX and 100 shall be punished in accordance with the relevant provisions of Articles 82 and 83 of the Law on the Prevention and Control of Water Pollution.

Reply to the work consultation related to acceptance after the change of the EIA level

Letter:

In recent years, due to the adjustment of relevant laws and regulations and the classification management catalogue of construction projects, we often encounter the problem of changing the level of project environmental assessment in daily law enforcement. How to deal with the following two situations in the special request department: 1. The enterprise has applied for the EIA report or report form, and according to the new construction project classification management catalogue, the project grade has been adjusted to the registration form, and whether such projects still need to be environmentally friendly. Facilities acceptance? 2. The enterprise has applied for the EIA registration form, but according to the new classification management catalogue, the project grade has been adjusted to the report or report form. Does the project need to re-apply the EIA procedures and complete the environmental protection facility completion acceptance according to the new EIA rating?

Reply:

Except for clear laws, regulations and documents, the relevant work is carried out in accordance with the requirements of the original environmental assessment.

Reply to the problem of several samples of HJ 836 low concentration particulate matter

Letter:

Under the consultation of HJ 836-2017 low-concentration particulate matter standard sampling, the quality control mentioned: the sample collection should ensure that the weight gain of each sample is not less than 1mg, or the sampling volume is not less than 1M3, and the sampling site can not guarantee the weight gain requirement. The sampling volume can only be required to be no less than 1 cubic, so that one sample can be used for about 30 minutes at a constant velocity of 30 L/min, or 40 minutes for sampling time or more for 1 hour. At the same time, the 836 standard refers to the sampling procedure. See GB/T 16157 sampling procedure requirements and quality assurance measures should meet the requirements of HJ/T397 on-site sampling assurance measures. These two GB/T 16157 and HJ/T 397 standards refer to particulate matter/boiler particulate matter. At least 3 samples are taken for sampling, so the standard is used to perform the sample. It is necessary to sample 3 samples of low-concentration particles, and the accumulated time takes about 3 hours. The sampling time cost of one exhaust gas is greatly increased, and the sampling time of the low concentration itself is 1 hour. The sample is already representative, and it is not necessary to collect 3 times to calculate the average. If you want to measure 3 times and reduce the sampling time cost, the sampling instrument on the market needs a larger sampling nozzle and an air pump to meet, but it is also necessary to shorten the sampling time based on the conditions (uncontrollable) allowed by the manufacturer's field conditions. However, it has been greatly improved compared with the previous standard sampling time, and the impact on the actual sampling work is a bit large.

Reply:

Letters from HJ 836-2017 low-concentration particulate matter with several samples were received. The research answers are as follows: HJ 836 is a monitoring method standard, which is a method for determining low-concentration particulate matter in fixed-source exhaust gas. In actual monitoring work, samples The number, frequency, etc. of the collection should also comply with the corresponding monitoring technical specifications. Therefore, according to the requirements of HJ 397, at least three samples need to be collected.

Regarding whether the wastewater in the water-based paint production process is dangerous or not, please reply

Letter:

I am a company that produces water-based paints (water-based acrylic and water-based epoxy paints). The production process will produce washing wastewater. The test results of toxic and hazardous substances in wastewater have not reached the standard of hazardous waste. According to the 2016 version of the hazardous waste list, HW12 dyes, paint waste content, 264-011-12, "other inks, dyes, pigments, paints (excluding water-based paint) production process waste mother liquor, residues, intermediates The content of the waste should not be considered hazardous. However, one expert said that if you apply 900-299-12, the contents of the production, sales and use of the process of failure, deterioration, failure, elimination, fake ink, dyes, pigments, paints, Substance as waste paint can also be said to be dangerous. I would like to ask if the washing wastewater generated in the production process of our company should be treated as hazardous waste or general solid waste.

Reply:

Regarding whether the wastewater in the water-based paint production process is dangerous or not, please write to us that the reply to the question raised in the letter is as follows: If the washing wastewater produced by your company's production process can meet the General Principles of Solid Waste Identification Standards (GB34330- 2017) The relevant provisions of Article 7 may not be managed as liquid waste, and are not classified as solid waste; if they cannot meet the relevant provisions of Article 7 of the General Rules for the Identification of Solid Wastes (GB34330-2017), they are managed as liquid waste and are solid. Waste, and according to the National Hazardous Waste List or national hazardous waste identification standards and identification methods to determine whether it is hazardous waste.