1. Transformation projects of production facilities and equipment
[Whether the upgrading and reconstruction of the passivation line is exempted]
Our company has a manual passivation line, due to the difficulty of manual operation on cost and quality control, our company intends to upgrade the manual passivation line to a fully automatic production line. It is planned to use a climbing continuous automatic production line, so a larger operating surface is required, so the size of the tank body needs to be increased. However, there is no exhaust gas generation in the passivation line, and the production capacity and overflow speed remain unchanged, and the waste water generation will be reduced due to the reduction of running and dripping in manual operation, and the new land is still in the original plant, does this situation belong to the renovation projects listed in item 58 of the List of Construction Projects Exempted from Environmental Impact Assessment Procedures in Guangdong Province (2020 Edition) that can be exempted from the EIA procedure?
The Guangdong Provincial Department of Ecology and Environment replied on April 2, 2021 that the project only transforms the passivation line, and if it does not involve new land, the type and quantity of pollutant discharge, it can be exempted from the EIA procedures and included in the management of pollutant discharge permits in accordance with relevant regulations.
[Does the upgrading of the cleaning system need to go through the EIA procedures]
Our company is mainly engaged in the production of new drug packaging containers, the industry category is made of metal packaging containers and materials, the original EIA has cleaned wastewater generated, and now the company has rectified and upgraded the cleaning system, after rectification and upgrading, add a set of zero-discharge wastewater treatment device, the product output does not change after the technical transformation, does not involve new land, does not increase the type and quantity of pollutant discharge, so does this situation need to do environmental impact assessment?
The Guangdong Provincial Department of Ecology and Environment replied to the interactive exchange on July 13, 2021: It is recommended that you further analyze the changes in pollutant production and discharge after the transformation, and if you do not increase the type and quantity of pollutant discharge, you can be exempted from the EIA procedures in accordance with item 58 of the "List of Construction Projects Exempted from Environmental Impact Assessment Procedures in Guangdong Province (2020 Edition)", but relevant environmental protection measures should be implemented to prevent environmental pollution and ecological damage, and be included in the management of pollutant discharge permits in accordance with relevant regulations.
[Increase production without increasing pollution]
Our company was established in 2003, belongs to the 1713 cotton textile printing and dyeing finishing industry, the company has gone through many times of clean production, the equipment has been updated and upgraded, and the production capacity has increased by more than 30%, realizing the increase in production without increasing pollution. The company's production land has not increased, the number of production equipment is consistent with the original EIA, the type and quantity of pollutant discharge have not changed, and the total amount of pollutant discharge permits has not exceeded (nor has it exceeded the total amount of EIA), whether our company's situation belongs to the spirit of the notice [Yuehuanhan [2020] No. 108 of the Notice of "List of Construction Projects Exempted from Environmental Impact Assessment Procedures in Guangdong Province (2020 Edition)", item 30, others, the situation of category 58 "transformation projects", that is, it does not involve new land, Projects that do not increase the type and quantity of pollutant emissions and basically do not have an impact on the ecological environment are exempted from environmental impact assessment procedures.
The Guangdong Provincial Department of Ecology and Environment replied on April 17, 2020: If the renovation project does not involve new land use and does not increase the type and quantity of pollutant discharge, it can be exempted from the EIA procedures in accordance with Item 58 of the List of Construction Projects Exempted from Environmental Impact Assessment Procedures in Guangdong Province (2020 Edition), but relevant environmental protection measures should be implemented to prevent environmental pollution and ecological damage, and be included in the management of pollutant discharge permits in accordance with relevant regulations.
[Increase in production equipment]
The company is a chemical enterprise, and the ammonia-containing waste gas is discharged in the production process, which is sprayed with dilute sulfuric acid to produce ammonium sulfate-containing wastewater (transferred to a wastewater treatment institution with treatment capacity). Due to the blockage of the spray system due to the crystallization of ammonium sulfate during use, it is proposed to add a set of high-temperature crystallization filtration device (electric) to the spray system to remove ammonium sulfate, improve spray efficiency, prolong the use time of the spray system and reduce the amount of spray wastewater, and ammonium sulfate meets the requirements of industrial grade and is sold as a product. May I ask whether the addition of "high-temperature crystallization filtration device (electric)" and ammonium sulfate as products belong to the category of "58, transformation projects" in the "List of Construction Projects Exempted from Environmental Impact Assessment Procedures in Guangdong Province (2020 Edition)" (Yue Huan Han [2020] No. 108). If it is not exempt, how to go through the EIA procedures for this addition.
On April 24, 2020, the Guangdong Provincial Department of Ecology and Environment replied to the interactive exchange: If the project does not involve new land use and does not add new pollutant discharge, it can be exempted from environmental impact assessment procedures in accordance with item 58 of the List of Construction Projects Exempted from Environmental Impact Assessment Procedures in Guangdong Province (2020 Edition), but it should be included in the management of pollutant discharge permits in accordance with relevant regulations;
2. Pollution prevention and control facilities renovation projects
[Does the wastewater transformation project need to do an environmental impact assessment]
Our company is a printing enterprise, the production process will produce plate-making process processing wastewater, printing workshop will produce ink wastewater, and the laminating workshop cleaning equipment will produce industrial wastewater, the EIA approval requires that the industrial wastewater is not discharged, handed over to a qualified unit for treatment. This is how our company has always dealt with it. Now, the company is considering adding a distiller to treat the ink wastewater in the printing workshop, and the recovered clean water and solvent are used for the cleaning of the printing equipment again, and the wastewater is not discharged, and a set of sewage treatment facilities is added to treat the industrial wastewater of the plate-making process and the cleaning of the laminating machine, the treated industrial wastewater is not discharged, and is directly reused for cleaning equipment, the maximum daily processing capacity of the factory is 1 ton of wastewater, and the waste generated in the sewage treatment process such as sludge will be treated as hazardous waste. May I ask, according to item 95 of the project category "sewage treatment and recycling" in the "Catalogue of Classified Management of Environmental Impact Assessment of Construction Projects (2021 Edition)", can our wastewater transformation project be exempted from EIA?
The Guangdong Provincial Department of Ecology and Environment replied to the interactive exchange on May 20, 2021: If the new wastewater treatment facilities of the project do not add new land, the type and quantity of pollutant discharge, they can be in accordance with the "Notice of the General Office of the People's Government of Guangdong Province on Issuing the Guiding Opinions on Deepening the Reform of the Environmental Impact Assessment System in Our Province" (Yue Ban Han [2020] No. 44) on "basically no impact on the ecological environment" Construction projects are not included in the spirit of EIA management, exempted from EIA procedures, and included in the management of pollutant discharge permits in accordance with relevant regulations, and subject to the supervision and management of the ecological environment department.
【Renovation of the treatment process of organic waste gas pollution prevention and control facilities】
The original environmental impact assessment and completion of the acceptance of the organic waste gas prevention and control facilities treatment process for UV photolysis + activated carbon adsorption, now the company considers the fire safety of UV photolysis, plans to transform the organic waste gas prevention and control facilities, pre-the original treatment process UV photolysis + activated carbon adsorption to activated carbon adsorption + activated carbon adsorption, does it meet the relevant requirements of environmental protection?
The Guangdong Provincial Department of Ecology and Environment replied to the interactive exchange on December 21, 2021: In June 2019, the Ministry of Ecology and Environment issued a notice on the "Comprehensive Treatment Plan for Volatile Organic Compounds in Key Industries" (Huan Qi [2019] No. 53), which requires "(3) Promote the construction of suitable and efficient pollution control facilities. Enterprises building new pollution control facilities or renovating existing pollution control facilities should reasonably select treatment technologies according to the concentration, composition, air volume, temperature, humidity, pressure, and production conditions of the exhaust gas. Encourage enterprises to adopt a combination of technologies to improve the efficiency of VOCs treatment. For low-concentration and large-volume exhaust gas, it is advisable to use concentration technologies such as zeolite rotor adsorption, activated carbon adsorption, and wind reduction and concentration enhancement to increase the concentration of VOCs and purify the waste gas; Oil and gas (solvent) recovery should adopt condensation + adsorption, adsorption + absorption, membrane separation + adsorption and other technologies. Low-temperature plasma, photocatalytic and photooxidation technologies are mainly suitable for the treatment of odor and odor, while biological methods are mainly suitable for the treatment of low-concentration VOCs waste gas and odor.
Non-water-soluble VOCs exhaust gas is forbidden to be sprayed and absorbed by water or aqueous solution. If the disposable activated carbon adsorption technology is adopted, the activated carbon should be replaced regularly, and the waste activated carbon should be regenerated or disposed of. Qualified industrial parks and industrial clusters, etc., promote centralized spraying, centralized solvent recycling, centralized regeneration of activated carbon, etc., strengthen resource sharing, and improve the efficiency of VOCs treatment. Standardize engineering design. If the adsorption treatment process is adopted, it should meet the requirements of the "Technical Specifications for Industrial Organic Waste Gas Treatment Engineering by Adsorption Method". If the catalytic combustion process is adopted, it should meet the requirements of the "Technical Specifications for Catalytic Combustion Industrial Organic Waste Gas Treatment Engineering". If other treatment processes such as regenerative combustion are adopted, they should be designed in accordance with the requirements of relevant technical specifications.
Implement dual control of emission concentration and removal efficiency of key emission sources. If the initial emission rate of VOCs is greater than or equal to 3 kg/h and the key area is greater than or equal to 2 kg/h, the control should be strengthened, in addition to ensuring that the emission concentration is stable and up to standard, the removal efficiency should also be controlled, and the removal efficiency shall not be less than 80%; According to item 100 of the "Catalogue of Classified Management of Environmental Impact Assessment of Construction Projects (2021 Edition)", "air pollution control projects such as desulfurization, denitrification, dust removal, and VOCs treatment", the registration form should be filled. The construction of the project should also meet the relevant requirements of the "Guangdong Province 2021 Air Pollution Prevention and Control Work Plan".
【Upgrading of waste gas treatment facilities】
The enterprise has complete environmental protection procedures, and currently uses activated carbon adsorption to treat the organic waste gas produced in the production process, and now plans to upgrade the waste gas treatment facilities and use the RTO process instead, in which RTO uses natural gas for combustion, and the combustion process produces soot, sulfur dioxide and nitrogen oxides, so as to improve the treatment efficiency and reduce the total amount of exhaust, but increase the types of pollutant emissions, please ask: 1. Do you need to report to the EIA?2. Do you need to apply for an increase in the total amount of pollutant emissions?
The Guangdong Provincial Department of Ecology and Environment replied to the interactive exchange on May 31, 2021: According to item 100 of the "Catalogue of Classified Management of Environmental Impact Assessment of Construction Projects (2021 Edition)", "air pollution control projects such as desulfurization, denitrification, dust removal, and VOCs treatment" should fill in the registration form and be included in the management of pollutant discharge permits in accordance with relevant regulations.
3. Hazardous waste disposal
【Hazardous Waste Reduction】
In 2019, an EIA of a resin manufacturer obtained the EIA approval, and the esterified waste liquid in the EIA report was hazardous waste, and it planned to entrust the esterified waste liquid to a qualified unit for treatment and disposal. At present, the company plans to pretreat the esterified waste liquid to meet the takeover standard of the park sewage treatment plant, and then discharge it into the park sewage treatment plant for further treatment and discharge. Is this hazardous waste reduction project an environmental impact statement or an environmental impact statement form?
The Guangdong Provincial Department of Ecology and Environment replied on April 17, 2023: According to the requirements of item 101 of the "Utilization and Disposal of Hazardous Waste (excluding Medical Waste)" in the "Catalogue of Classified Management of Environmental Impact of Construction Projects (2021 Edition)", the project of "Utilization and Disposal of Hazardous Waste (except for internal recycling and reuse by generating units; except for simple collection and storage)" shall prepare an environmental impact report.
【Supplementary consultation on waste circuit board crushing and disposal】
Circuit board waste generated by the company (900-045-49) 1. In order to ensure the information security of the waste, can the company use a crusher to completely crush it, and then hand it over to a qualified hazardous waste disposal company in the market for final environmental treatment? 2. If the above behavior can be carried out, what environmental protection procedures and environmental protection measures does the company need to perform in advance? Is this behavior a hazardous waste disposal act as stipulated in Article 80 of the Solid Waste Pollution Prevention and Control Law?
The Guangdong Provincial Department of Ecology and Environment replied to the interactive exchange on August 4, 2023: Your company does not need to apply for a permit for the behavior of building its own hazardous waste pretreatment facilities and pretreating the hazardous waste generated by the project in accordance with the law. Please change the hazardous waste management plan and management ledger in a timely manner, and truthfully record the facilities and operation conditions such as pretreatment.
[Can enterprises dispose of their own hazardous waste]
For example, if the amount of hazardous waste and solid waste generated by a certain company is 3 tons per month, the company purchases small treatment equipment/reduction equipment (the equipment can meet the emission standards). If the company only uses this small equipment to treat/reduce the amount of hazardous waste and solid waste generated by itself, and does not accept and treat the hazardous waste generated by other companies, is it legal for the company to do so? PS: Personally, I believe that if a small-scale waste production enterprise itself has equipment to completely treat or reduce hazardous waste and solid waste, and the equipment treatment process does not affect the environment, the enterprise can treat/reduce the amount by itself, which can not only reduce the treatment pressure of the hazardous waste treatment center, but also avoid the risk of leakage during the transportation of hazardous waste.
On March 11, 2020, the Guangdong Provincial Department of Ecology and Environment replied to the interactive exchange: Encourage your company to use legal facilities to use and dispose of the solid waste generated by itself to achieve source reduction. Regarding the issue of how to handle the environmental impact assessment procedures of the supporting hazardous waste treatment and disposal facilities of the project, if the project has not carried out the environmental protection acceptance of completion, and the construction of hazardous waste treatment and disposal facilities has not led to major changes in the main project, it can be included in the environmental protection acceptance management of completion, and if the project has completed the environmental protection acceptance, the environmental impact assessment can be carried out according to the provisions of the "Classified Management List of Environmental Impact Assessment of Construction Projects".
Fourth, whether the renovation project needs to be accepted
[Whether the enterprise needs to be re-accepted for upgrading and transformation]
The enterprise has gone through the approval and acceptance, because of the upgrading, so the use of part of the treatment facilities (added strains, aging), and in order to make the water quality more stable, change some of the facilities, after the transformation and at the same time apply for the pollutant discharge permit, do you need to go through the acceptance procedures again?
The Guangdong Provincial Department of Ecology and Environment replied on April 9, 2020: According to the Notice on Printing and Distributing the <> of the List of Construction Projects Exempted from Environmental Impact Assessment Procedures in Guangdong Province (2020 Edition) (Yue Huan Han [2020] No. 108), such technical transformation projects are construction projects in the list and do not need to go through environmental impact assessment and acceptance procedures.
Source: EHS