Summary: In order to strengthen the management of pollutant discharge permits and promote the quality and efficiency of pollutant discharge permits, the Ministry of Ecology and Environment continued to organize and carry out the normalized technical review of the quality of pollutant discharge permits, found a number of problematic enterprises, and sorted out typical cases of pollutant discharge permit problems.
Management Category Error (Demote Management)
A charcoal factory belongs to "Forest Products Chemical Products Manufacturing 2663". According to the "Catalogue of Classified Management of Pollutant Discharge Permits for Fixed Pollution Sources" (2019 Edition) (hereinafter referred to as the "Directory"), pollutant dischargers that do not have pyrolysis or hydrolysis processes and do not contain simple mixing or sub-packaging belong to simplified management, and pollutant dischargers with pyrolysis or hydrolysis processes belong to key management.
By checking the information of the production line in the pollutant discharge permit, it was found that the pollutant discharger was actually involved in the carbonization process, which belonged to the pyrolysis process, and the pollutant discharger should belong to the key management, while the pollutant discharge permit management category was incorrectly filled in as "simplified management", which belonged to the downgraded management situation in the "management category error".
【Enlightenment Significance】
To determine whether there is an "wrong management category", it is necessary to combine the information such as production facilities, product production capacity, process flow diagram, and amount of raw and auxiliary materials in the pollutant discharge permit, as well as the list of key pollutant discharge units, and conduct research and judgment according to the "Directory", focusing on determining whether there is a downgrading management of the pollutant discharge permit.
Missing the main drain
A technology company belongs to "environmental sanitation management 782", the main production unit involves "by-product processing - livestock and poultry oil processing", using oil residue filter press process, belongs to the "slaughtering and meat processing industry 135" production process, so the pollutant discharge permit should meet the "technical specifications for the application and issuance of pollutant discharge permits Environmental health management industry" (HJ 1106-2020) and "technical specifications for the application and issuance of pollutant discharge permits Agricultural and sideline food processing industry - slaughtering and meat processing industry" (HJ 860.3— 2018).
According to the Technical Specifications for the Application and Issuance of Pollutant Discharge Permits Agricultural and Sideline Food Processing Industry - Slaughtering and Meat Processing Industry, the discharge port of livestock and poultry oil processing wastewater is the main discharge outlet, and the pollutant discharger is wrongly identified as a "general discharge outlet", which is the problem of "missing the main discharge port" caused by the wrong identification of the discharge port category.
【Enlightenment Significance】
To determine whether there is a "problem of missing the main discharge outlet", it is necessary to analyze the "pollution production link", "discharge destination" and "discharge port name" in the pollutant discharge permit according to the corresponding industry pollutant discharge permit technical specifications in combination with the environmental impact report (form) of the pollutant discharging unit and its approval documents, environmental impact registration form and filing materials, completed environmental protection acceptance documents and acceptance opinions, standardized setting of sewage outlets and monitoring holes, floor plan, monitoring point location diagram, production process flow diagram and other materials and other information to meet the conditions of the main discharge port in the technical specifications, especially to determine whether there are other applicable technical specifications to jointly determine the type of discharge port in combination with the process flow and the production and discharge node diagram, and carry out on-site inspection if necessary. It is important to determine whether there is a situation where the main discharge port is wrongly identified as a general discharge port.
Emission standards and limits are incorrect
A building materials Co., Ltd. belongs to the "clay bricks and building blocks manufacturing 3031", the air pollutant sulfur dioxide should implement the "brick and tile industry air pollutant emission standard" (GB 29620-2013) and its modification list, the emission limit should be 150mg/m3, but the sulfur dioxide in the pollutant discharge permit did not implement the concentration limit in the modification sheet, and the original standard limit of 300mg/m3 was filled in incorrectly, and there was a problem of "pollutant emission standards and limit values".
【Enlightenment Significance】
The pollutant discharge standards and limits of the pollutant discharge permit shall be determined according to the emission concentration and emission rate in the current effective national or local pollutant discharge standards and their modification lists, and in accordance with the requirements of the "Measures for the Management of Ecological and Environmental Standards" (Order No. 17 of the Ministry of Ecology and Environment), the applicability and priority of the standards, the timeliness of the national standard and the landmark, the compatibility or intersection principle of the industry standard and the comprehensive discharge, and the mixed discharge in the emission standard. Whether there are problems with special regulations such as the relationship between the height of the exhaust cylinder and the emission limit, we should also pay attention to the standard update information, including the revision of the standard and the modification order, the implementation time of the new standard, and the updated standard limit.
Emission standards and limits are incorrect
An agricultural technology company belongs to "Chemical Pesticide Manufacturing 2631", according to the "Technical Specifications for the Application and Issuance of Pollutant Discharge Permits Pesticide Manufacturing Industry" (HJ 862-2017), to deal with the COD and ammonia nitrogen permitted emissions from the main discharge ports of wastewater, but the COD and ammonia nitrogen permitted emissions are omitted from the pollutant discharge permit, and the pollutant discharger has the problem of "wrong permitted discharge".
【Enlightenment Significance】
To determine whether there is an "error in the permitted discharge", it should be determined whether there is an omission of the permitted emission control factor or the wrong filling of the permitted emission according to the "wastewater (waste gas) category, pollutant type, discharge method and pollution prevention and control facilities" in the technical specifications for the corresponding industry pollutant discharge permit, and in combination with the EIA documents and approvals.
For air pollutants, verify whether the allowable amount control factors are omitted from the main discharge outlets one by one. It is necessary to pay attention to the permissible control factors of general discharge outlets (such as steel, cement and other industries) and unorganized emission sources (such as steel, petrochemical and other industries) of individual industries.
For water pollutants, the allowable discharge of pollutants that exceed the standards of chemical oxygen demand, ammonia nitrogen, and the environmental quality of the receiving water body and are included in the relevant pollutant discharge standards is usually the allowable discharge; for the pollutant dischargers located in the "13th Five-Year Plan" for ecological and environmental protection and the total phosphorus and total nitrogen control areas stipulated by the Ministry of Ecology and Environment, the main discharge outlets of wastewater should also be examined to see if the total phosphorus or total nitrogen allowable control factors are omitted.
Source | China Pollutant Discharge Permit
Edit | Small fish
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