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54 common problems in environmental protection

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54 common problems in environmental protection

Release date:2019-07-08 Author: Click:

One During the inspection and acceptance, particulate matter is not organized but 2-50m in the direction of pollution source rather than the plant boundary.

A: there are two main parts of particulate matter monitoring: no organization in workshop and no organization in workshop.

Two When does the inspection and monitoring process take place? When will the factory boundary be unorganized and when the workshop is not organized?

Answer: general acceptance monitoring should be conducted in accordance with the characteristics of enterprises' pollutants and the state's key control pollutants.

In the discharge standard, there are requirements for unorganized discharge in the workshop, and shall be monitored during acceptance.

Three When the noise is checked and monitored, does the enterprise with no homework at night measure the day?

Answer: acceptance monitoring is carried out under working conditions. There is no working condition at night, so only days are measured.

Four Do we need to carry out total accounting for unorganized emissions?

A: because the amount of emissions from unorganized emissions can not be tested practically, it can only be obtained by mode calculation. At present, only the calculation model of the total amount of unorganized emissions is provided in the technical specification for emission permits of iron and steel industry. In other industries and the general regulations for the application and issuance of technical specifications for pollutant discharge permits (HJ942-2018), no organization emission limits the concentration limit and does not permit emission limits.

Five Is there any specific monitoring frequency, frequency or number of days when the enterprise accepts its own acceptance monitoring (or entrust the third party)?

Answer: there are special chapters in the technical specifications and technical guidelines for industrial acceptance monitoring (pollution impact category) that have been issued to make the minimum frequency of monitoring (monitoring days and the number of monitoring times per day) required.

Six If there are environmental sensitive points in the acceptance monitoring, should we simultaneously determine pollutant emissions and ambient air quality?

Answer: environmental quality impact monitoring is mainly targeted at environmental sensitive protection targets in EIA and approval. Therefore, EIA and approval must be monitored at the same time. It is best to proceed when sensitive targets are in the downwind direction.

Seven During the acceptance monitoring, the general boiler and precipitator select GB16157 to determine the concentration of particulates. Is it feasible to report <20mg/m3?

Answer: it is not necessary to convert the pollution source to the monitoring result and report "<20mg/m3" when the monitoring result is less than 20mg/m3. For the boiler that needs to be converted to the emission concentration, the concentration after conversion can not be determined, so it can not be reported as "<20mg/m3".

Eight When the exhaust gas is checked and monitored, whether the low concentration particulate matter must be synchronized with the two samples, should the whole procedure be deducted?

Answer: synchronous double sampling is a quality control measure. In 7.3.8 of HJ836-2017, "when sampling synchronous samples, each sample should be synchronized with two samples. Synchronous sampling should meet the requirements of appendix A". Among them, "each sample" refers to a sample of effective data (such as multiple samples collected at equal intervals in 1 hours), so not all samples must be synchronized with double samples. The concentration of synchronous double samples is calculated and the relative deviation is allowed.

The blank of the whole procedure can not be deducted.

The blank of the whole procedure is also a quality control measure to judge and evaluate the validity of the sampling results. In HJ836-2017, 10.3.4 stipulates that any sample which is below the blank weight gain of the whole procedure is invalid. The blank weight gain of the whole procedure divided by the average volume of the corresponding measurement series should not exceed 10% of the emission limit. "10.3.7 stipulates that when the particle concentration is lower than the detection limit, the corresponding blank weight gain of the whole procedure should not be higher than 0.5mg, and the weightlessness should be no more than 0.5mg".

Nine For particulate matter (before and after treatment facilities), should we get enough 1H for GB16157?

Answer: in GB/T16157-1996, the sampling time for particle sampling is only 3 minutes, and the total sampling time of the cartridge is not specified. However, all kinds of exhaust gas evaluation standards are marked as the mean value of 1 hours of concentration emission. Therefore, each valid evaluation value should be collected for 1 hours.

Ten In the analysis methods such as Cl2 and NH3, the sampling time is not consistent with the average hour requirement in GB16297. According to that requirement, is it collected?

Answer: the recommended sampling time for a single sample is given in the method standard. It is a suggestion, not a requirement. The sampling time of a specific sample is determined according to the emission concentration of the pollutant in the exhaust gas. It is not contradictory to collect 2-4 samples with continuous 1 hours sampling in GB16297 or equal interval in 1 hours.

Eleven Does the acceptance of sewage treatment plant require monitoring of soil within and outside the plant? If we need to monitor how to deploy?

A: acceptance monitoring does not require monitoring of soil in the plant boundaries. The environmental monitoring of factory boundary environment is carried out according to EIA requirements. According to the "soil environmental monitoring technical specification" (HJ/T166-2004) and the national soil risk point monitoring in the "waste water type enterprise" layout requirements, according to the direction of wastewater discharge points.

Twelve Does the acceptance of sewage treatment plants need to monitor the water quality of the polluted water?Do you want to measure the background value of the polluted water body?

Answer: according to the requirements of EIA and approval, the impact of sewage treatment on the environment is monitored. At the time of monitoring, the control cross section is placed upstream of the inlet of the sewage treatment plant.

Thirteen If there is no national or industry testing standard, should the working instruction set by itself be examined and approved by the quality supervision and management department? (for example, soil Cr+6)?

Answer: according to the work instruction, the work instruction for a project that is formulated by oneself is approved by the metrology accreditation and appraisal team organized by the Quality Supervision Bureau. It can be used as an effective analysis method for the project of this unit.

Fourteen What is the function of flue damper?

Answer: this happens when the design volume of fan is too large. The function of baffle is to increase resistance so as to reduce the volume of gas extraction.

Fifteen Office building acceptance, personnel are not admitted, the property is not admitted, no trash cans, waste water generated, what is the acceptance process? Do they need to prepare the trash cans for acceptance?

Answer: this kind of situation is no working condition and can not be accepted. At present, the office building project belongs to the "environmental impact registration form".

Sixteen There are 15 exhaust cylinders in a cement plant, 7 of which are not standardized, and can not be sampled for safety reasons. Now enterprises do not want to rectify. If an enterprise requests another third party inspection organization to monitor the 7 exhaust cylinders, can the monitoring organization put the monitoring data of other monitoring organizations in the acceptance monitoring report?

Answer: at present, the inspection data of the other third organizations can be placed in the report for the enterprises to accept or entrust the third party to complete the inspection and acceptance. However, what data should be specified in the report, which are measured by themselves, and which are the monitoring data provided by other enterprises, and require the enterprise to provide the sealed data report as the attachment of the report.

Seventeen When the boiler is monitored, the oxygen content of the boiler is measured to be about 17-18%. The measured concentration is not high, but the conversion concentration is very high. How can this situation be improved (a bag dedusting facility) to reduce O2?

Answer: first, check whether the pipeline and treatment facilities before the monitoring section of the system have breakage and leakage. If there is no obvious leakage, the high oxygen content should belong to the production load, but the boiler induced draft fan and blower can not be adjusted according to actual needs. Oxygen content can only be reduced by increasing production load and less air distribution.

Eighteen If, according to the 3 directions of the upper wind direction and the downwind, the enterprises are in the industrial park, sometimes the reference point of the wind direction is close to the transportation hub point. Therefore, the wind direction data on the TSP data can be distributed around the factory boundary (East, South, West and North) according to the wind direction data.

Answer: the layout of monitoring points for unorganized emissions of plant emissions must be carried out in accordance with the requirements of the technical guidelines for air pollutants emission monitoring (HJ/T 55-2000), the comprehensive discharge standard for air pollutants (GB 16297-1996) appendix C, and the emission monitoring requirements of various industries. It is not possible to lay the same points around the factory boundary.

The layout of control points should avoid local pollution sources.

Nineteen How far is the distance from the groundwater monitoring logging to the general source? How deep is it?The south water table is relatively high and easy to discharge.

Answer: according to the requirements of the "2.3 monitoring points (monitoring wells) setting method" in the HJ/T164-2004 "groundwater environmental monitoring technical specification".

Twenty At present, many of the acceptance projects do not have a sewage permit. Most people, including the environmental protection department, have accepted the sewage permit before accepting the approval. How can we solve this problem?

Answer: according to the general rules for application and verification of emission permits.

(HJ942-20182018.2.8 Implementation), taking exhaust gas as an example.

5 Determination of product link corresponding discharge port and permitted emission limits

The 5.1 product corresponds to the outlet.

... The emission limits are more stringent than the geographic coordinates of discharge ports, the height of exhaust gas outlet, and the discharge concentration and commitment of national and local pollutants.

General principles of 5.2.1

Twenty-one What is the requirement for working conditions when monitoring pollutant discharge permits?

Answer: according to the regulations on environmental protection and management of construction projects (revised in 2017), the Interim Measures for the acceptance of environmental protection for completion of construction projects ([2017]4) and the general rules for the application and issuance of technical specifications for pollutant discharge permits (HJ942-20182018.2.8 Implementation), the new construction projects can be debugged after obtaining the pollutant discharge permit, and all kinds of monitoring activities should be carried out during the commissioning period.Therefore, the amount of pollutant discharge permit for new projects should be calculated according to the corresponding industry discharge permit application and the technical specifications issued or the "general permit for pollutant discharge permit application and the issuance of technical specifications" (HJ942-20182018.2.8 Implementation).

The monitoring of actual emissions is not required by actual conditions.

Twenty-two Where there is no obvious wind direction or no change in wind direction during the monitoring period, how should we deal with it?

Answer: when the wind speed is low, it is suitable for monitoring without monitoring, but no obvious wind direction or wind direction changes more than 45 degrees. Suitable weather conditions should be selected.

Twenty-three And the standard of heat conducting oil furnace? And the information and attention points you need to know?

Answer: in the application scope of the GB13271-2014 standard, the standard is applicable to all kinds of hot water boilers and organic heat carrier boilers. The heat carrier boiler is commonly known as "heat transfer oil stove". Therefore, if the EIA and approval do not specify the evaluation criteria, that is to implement the emission standards of corresponding fuels in the emission standards for boiler air pollutants.

Twenty-four How are the 3 measurements of organized exhaust gas determined to be effective? (for air volume?

Answer: the availability of effective data is achieved in strict accordance with the requirements of monitoring standards, from the requirements of work conditions, layout, sampling, analysis, data calculation, and quality control of all links. The parallelism of data proves that the monitoring process is stable and without accidental error. When the data fluctuate greatly, we should check each item, especially the changes of the working conditions and the parameters in the sampling records, so as to determine whether there is any wrong operation.

Data auditor can judge the rationality of the data according to the technological characteristics of the pollution source, the air volume and the working experience of the fan.

Twenty-five At the time of acceptance, the noise level of the factory boundary exceeds the standard and the sensitive point is up to standard. How should we deal with it?

Answer: the acceptance of noise is still the examination and approval system. The noise level in the factory boundary exceeds the standard and the sensitive points are up to standard but not yet disturbing the people. Noise sources should be monitored in a targeted way. If the noise level of factory boundaries caused by excessive noise sources exceeds the standard, the management requirements should be put forward, and no acceptance will be accepted.

Twenty-six At the site investigation stage, it is found that pollution sources are not mentioned in the EIA. Should it be checked?

Answer: it depends on whether the pollution source involves major changes in the project. If the newly increased pollution source is caused by the change of content or process, it involves the recompilation and approval of the EIA. If it is only a post processing facility added on the basis of the original technology, it should be checked and accepted.

Twenty-seven How should we deal with the emission standards when the emission concentration reaches the standard and the total emission exceeds the standard?

Answer: the total amount is not up to standard and can not be accepted.

In the EIA report, there is a summary table of pollutant emissions. We can see that the sum of emissions from a single pollutant source is consistent with the total amount. Therefore, one by one compares the pre assessment of EIA to see which source of pollution exceeds the forecast and has targeted transformation of treatment facilities.

Twenty-eight Is the noise adjacent to the factory boundary monitored?

Answer: in principle, no measurement is required.

Twenty-nine How to accurately measure formaldehyde in high temperature flue gas? Fiber board enterprises, the production process involves steaming and steaming temperature 56 degrees, 10.2% moisture content, environmental protection facilities for cyclone dust removal and water curtain. During the monitoring process, there is visible absorption of water vapor into the absorption liquid.

Answer: formaldehyde is soluble in water. According to GB/T16157, the sampling tube should be heated during sampling to prevent condensation water from adsorbing formaldehyde.

Thirty Boiler oxygen monitoring, boiler oxygen content (gas) in the actual process can reach 10%, how to troubleshoot the problem? Another gas boiler test CO is more than 1000 mg/m3, SO2 is 1500 mg/m3, O2 is 8.3%. Is the SO2 value anomaly due to CO interference? Or is there any other exhaust gas coming in? (the factory produces six sulfur fluoride gas, because pipes are all underground, and can not be inspected).

Answer: the high oxygen content of gas fired boiler is caused by gas distribution. 10% of the oxygen content is acceptable, and no need for investigation.

Gas boiler sulfur dioxide 1500 mg/m3, CO1000 mg/m3, CO interference is very likely. Other methods should be used for testing, such as infrared, ultraviolet or Fourier transform infrared methods, to determine whether the monitoring result is CO interference or the result of mixing process tail gas.

Thirty-one How to deal with the change of facilities for process waste gas treatment? For example, a steel anticorrosion processing plant, EIA and approval request exhaust gas from activated carbon adsorption, from 15 meters exhaust cylinder drain. The actual construction is replaced by photooxidation catalysis, and no exhaust cylinder is disposed after treatment. How to deal with this situation? Does one side exhaust without tissue? Or do we have to set up the exhaust gas and measure the exhaust gas? In addition to the exhaust emissions from the side bodies, are there any non polluting exhaust gases?

Answer: judging whether the change of a treatment process is feasible, the general principle is to see whether its pollutant discharge is good. Photocatalytic oxidation is a widely accepted method to replace exhaust gas from activated carbon process. However, it is not allowed to set up a 15 meter high exhaust cylinder according to the requirements of the EIA and approval, and it is a bad performance.

No emissions from the exhaust gas test and no emissions from the workshop were tested.

Thirty-two At present, post project evaluation is gradually carried out. How to check and accept the post evaluation? What is the difference between new construction, reconstruction and extension projects?

A: post project evaluation is a systematic and objective analysis and summary of the implementation effect, execution process and external environment of the project after completion and operation for a period of time. The purpose and function of post evaluation and EIA are different.

Thirty-three Mixing dust on the top of the mixing salon must be measured. How to deal with the actual situation.

Answer: particulate matters should be monitored for facilities that produce dust. In actual monitoring, temporary monitoring platforms can be built or hoisting facilities should be used as temporary platforms for monitoring.

Thirty-four The total amount of EIA and approval is particularly low, which may be several orders of magnitude lower. For example, 0.000433t/a, how can we treat the situation of total volume failing to meet the requirements in the acceptance process?

Answer: This is a question of total approval. It should be communicated between the construction unit and the total reply department.

Thirty-five After the implementation of the new standard in the brick factory, the particulate matter 30mg/m3 is too difficult to meet the standards. According to the standards implemented at the time of the EIA and the approved standards, the new standard is not up to standard, and how to deal with it in the process of acceptance?

Answer: the emission standard for air pollutants in brick and tile industry (GB29620-2013) gives the time limit (2 and a half years) for the existing enterprises to continue the implementation of the old standard limit (Table 1). During this period, enterprises should actively rectify and adopt advanced treatment facilities, so that pollutant emission can reach the more stringent limit requirements in Table 2.

The acceptance inspection strictly implements the corresponding standard limits according to the time limit stipulated in the standard. If the standards fail to meet the standards, the treatment facilities should be reformed.

Thirty-six What is the key point of the enterprise's independent acceptance?

Answer: the main point of acceptance is acceptance conclusion.

Check the following nine items one by one to list the specific unqualified items. 1) the environmental protection facilities are not fully implemented as required; 2) the pollutant emission monitoring results exceed the standard; 3) significant changes have not been carried out in the relevant environmental protection procedures; 4) the major environmental pollution has not been completely cured in the process of construction; 5) the construction projects of pollutant discharge permit management have been put into the construction of pollutant discharge permit management, and the pollution discharge and ecological damage capability of the environmental protection facilities can not meet the needs; 7) because of the punishment of violation, they have been ordered to make corrections and have not yet been completed; 8) there are significant quality defects in the acceptance report; 9) other environmental protection laws, regulations, rules and regulations can not be checked through environmental protection. If unqualified, the problems existing in the project should be identified, and follow-up rectification items with specific contents, specific requirements, technical feasibility and strong operability should be put forward accordingly.

Thirty-seven Is there any need for re approval of part of the production process change? How can it be clearly determined that part of the change is a major change?

Answer: according to the list of major changes listed by the state and the province, we should compare and judge. Those that belong to the list should be re submitted.

Thirty-eight A brick factory project involves mining and mining. It is necessary to make an environmental impact assessment before it can be checked and accepted. In the reply, it is required to draw up a plan for mine environmental treatment and ecological restoration. Is this whether it can be checked and accepted, and the ecological restoration is required. Is there any need to describe ecological restoration in my acceptance report?

Answer: if the mining sector is included in the construction of a brick factory, it is not necessary to do the EIA alone. The plan for mine environmental management and ecological restoration formulated by the approval is the basis for mine environmental management and ecological restoration, and must be compiled according to requirements. In the acceptance report, we will faithfully describe the completion of the program according to the inspection results.

Thirty-nine In view of the efficiency of treatment, especially the exhaust cylinder, many processing facilities have no exhaust pipes before they can be opened. How can they do not open the holes? If the imported openings are used, are the specifications strictly enforced in accordance with the requirements of "the next three and six"?

Answer: in the "technical guide", it is stated that the reasons for the failure to handle the monitoring conditions of efficiency (safety and facilities themselves, etc.) can be explained in the report. The "three below six" principle when selecting the monitoring section is the best requirement. When the actual situation can not meet the requirements, the method of encrypting the distribution points can be used for sampling.

Forty Is it possible for the enterprises to accept the contingency plans without filing them?

Answer: it is a major missing item and can not be checked and accepted.

Forty-one The concentration of reference points of unorganized exhaust gas is greater than that of monitoring points.

Answer: choose suitable weather conditions to prevent the upper wind from being affected by local pollution sources and re monitoring.

Forty-two Low concentration particulate matter is measured by GB/T16157 standard. When the measured concentration is less than 20mg/m3, how can the emission concentration be converted? How do we calculate the emission rate?

Answer: unable to determine the exact measured concentration, so the calculation of conversion and emission rate can not be carried out. (suggested that 20mg/m3 be used for conversion. The conversion concentration is less than 20* conversion coefficient. If the value is lower than the emission limit, it is evaluated as the standard. If it is higher than the emission limit, it can not be used for evaluation.

Forty-three And how to determine the monitoring plan for technical transformation projects? Pollution sources that do not involve technical transformation are not available.

Answer: determine the scope and content of monitoring according to the contents of technical transformation. Pollution sources that do not involve technical transformation are not monitored.

Forty-four During the check and acceptance monitoring, is there any requirement that the working condition is less than 75%?

Answer: not necessarily. If there are technical specifications for acceptance of the industry, the acceptance shall be carried out according to the load conditions specified in the specifications, and no technical acceptance criteria for industrial acceptance shall be accepted according to the technical guidelines for pollution impact, and no load requirements for working conditions are required.

Forty-five "Total emission = flue gas flow * measured concentration" or "total emission = dry flow rate * measured concentration"?

Answer: neither. Total emissions usually refer to monthly or annual emissions. You should ask the formula for calculating the emission rate.

Emission rate = standard dry flow * measured concentration.

Forty-six Are housing projects classified as "ecological" or "polluting"?

Answer: the general real estate development belongs to the EIA registration project, does not need to check and accept, only needs to record.

Forty-seven GB16297-1996 mentioned that "the new pollution source exhaust cylinder should not be less than 15 meters in general. If the exhaust pipe of the new pollution source must be lower than 15 meters, the emission rate standard will be strictly 50%" according to the original calculation result. Is that applicable to the lampblack?

Answer: the monitoring of cooking oil fumes is based on the relevant requirements of the "cooking oil fume emission standard" (GB18483-2001). 5.3 of the regulations specify the specific requirements of "height and location of fume exhausting cylinders" by the provincial environmental protection department. There is no requirement that we can not meet the height requirements and strictly enforce the standard limit. Failure to meet the height requirements of exhaust tanks should be regarded as failure to complete the construction of environmental protection facilities according to the requirements.

Forty-eight The bearing processing plant, EIA and approval are the production of "precision" bearing accessories, and enterprises say no use of "cutting fluid". Is it reasonable to produce precision bearings without cutting fluid?

Answer: the bearing material is high mechanical strength and high wear-resistant material. The cutting fluid of the whole production line is continuously processed to reduce hot deformation and ensure product accuracy. So the enterprise says that the cutting fluid is not used. The content of heavy metals in waste cutting fluid is high, which belongs to hazardous waste.

Forty-nine How can the construction period be reflected in the compilation of environmental protection acceptance report?

Answer: according to the environmental requirements for the construction period in the EIA, check whether there are corresponding environmental requirements in the construction contract, check the relevant environmental protection contents in the construction environment supervision, and answer the completion situation one by one.

Fifty In the park, how can the sewage outlet of the park be measured only?

Answer: there are two kinds of situations:

Situation 1: after sewage pretreatment, sewage treatment facilities will be discharged into the park.

Situation 2: the enterprise self processing sewage, through the park row outlet into the environment.

In the two case, enterprises will have their own sampling ports before entering the market. The situation 1 is to understand whether the water quality can meet the requirements of water quality in the water treatment facilities of the park. 2.

In the two case, the drainage network is generally underground and observed and sampled through the manhole.

Fifty-one What issues should be noticed in environmental protection acceptance monitoring projects?

Answer: large topics, see the contents of the preparation of the acceptance report of pollution impact.

Fifty-two What information should be collected in the investigation process of environmental protection acceptance report?

Answer: big questions. Look at the compilation of acceptance report of ecological impact.

Fifty-three At present, when the enterprises independently accept the inspection and accept part of the changes, they can "check with the inspection" and check them together. What is the degree we grasp?

Answer: in contrast to the list of major changes in the state and the provinces, a major change is not allowed.

Fifty-four "Three simultaneous" registration of pollutants in the table after discharge indicators fill in, whether only fill in the total control index targets?

Answer: the pollutant index in the "three simultaneous" registration form should not only fill in the total control index, but also consider the emission targets in the discharge permit.


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