Key points for the review of the pollutant discharge permit implementation report

Mondo Social Updated on 2024-02-10

(1) Summary table of the implementation of pollutant discharge permits

The basic information, production and discharge nodes, pollutants and pollution control facilities, environmental management requirements, and changes in the self-storage, utilization and disposal facilities of industrial solid waste should be completely filled. If there are changes in the above contents, the corresponding supporting materials (such as business licenses, on-site **, environmental impact assessment report approval documents, etc.) should also be submitted, and the changes should be consistent with the supporting materials.

(2) The basic information table of the enterprise

The operating time, the output of the main products, the amount of raw and auxiliary materials, the energy consumption, the annual production load and the information of intake and drainage should be completely filled. When the output of the main products or the amount of main raw and auxiliary materials exceeds the production capacity or consumption specified in the license, the relevant explanation shall also be submitted.

(3) The operation of pollution prevention and control facilities

1.Waste water and waste gas pollution prevention and control facilities

The operating hours, treatment capacity, and treatment efficiency of wastewater pollution prevention and control facilities, and the operating hours and operating efficiency of waste gas pollution prevention and control facilities should be completely reported. When the treatment facility involves the use of chemicals and sewage reuse, the amount of chemicals used and the sewage reuse rate should also be reported.

If the pollution prevention and control facilities have been suspended or abnormal operation (including equipment maintenance, equipment failure, etc.), the "Summary Table of Abnormal Situations of Pollution Prevention and Control Facilities" shall be filled in completely, including the time period of suspension (abnormal), the faulty facilities, the causes of the failure, the countermeasures taken and other information, which shall be consistent with the enterprise ledger or abnormal situation reporting records and other materials. If the pollutant discharge permit has monitoring requirements for the suspension (abnormal) period, the emission concentration of each pollution factor during the period shall also be completely reported. If the form is not filled, it should be made clear in the summary of this chapter that there is no abnormal situation in the pollution prevention and control facilities.

2.Industrial solid waste is self-stored and utilized in disposal facilities

For licensees who have updated the solid waste management information in the pollutant discharge permit in accordance with the Technical Specifications for the Application and Issuance of Pollutant Discharge Permits for Industrial Solid Waste (Trial) (HJ1200-2021), they should complete the "Self-Storage, Utilization, and Disposal Facilities Compliance Explanation Form". When there is a situation of exceeding capacity, exceeding type, overdue storage or other situations that do not meet the technical requirements for pollution prevention and control stipulated in the pollutant discharge permit, the specific situation and reasons shall be explained in the summary of this chapter, and if environmental protection procedures are involved, the environmental protection procedures shall also be supplemented in the summary.

(4) Self-monitoring of the situation

The implementation of self-monitoring should be completely filled in according to the requirements of the pollutant discharge permit. The data reported in such as pollutant emission concentration and emission rate should be consistent with the monitoring report and ledger records submitted, and in principle, should also be consistent with the data of the "National Pollution Source Monitoring Information Management and Sharing Platform".

1.Organized emissions

The effective monitoring data quantity, concentration (rate) monitoring results, number of excess data, and excess rate of each exhaust gas (water) discharge port under normal working conditions should be completely filled in, and the monitoring report related to the calculation of actual emissions should be submitted. Among them, the data of the excess rate should match the corresponding information in the "hourly (daily) average report of the period when the organized waste gas (wastewater) pollutants exceed the standard".

If there are abnormal working conditions or special periods, at least the relevant discharge port number, the type of pollutant discharge during the period and other information should be filled in completely. When the pollutant discharge permit has self-monitoring requirements for this period, the relevant monitoring information should also be filled in completely, and the filling requirements are consistent with the monitoring requirements of the discharge outlet under normal working conditions.

2.Fugitive emissions

The monitoring points (facilities), monitoring time, concentration monitoring results, exceeding the standard and the reasons for exceeding the standard should be completely filled in according to the unorganized emission control requirements specified in the pollutant discharge permit and the unorganized emission control requirements in the plant boundary and the plant area.

If the pollutant discharge permit specifies the requirements for the control of fugitive emission sources such as leakage (including sampling) of equipment and pipeline components, the control of fugitive emission sources should also be reported in the summary of this chapter.

For fugitive emissions that do not have the conditions to collect or eliminate pollutant emissions, such as shipbuilding, etc., the fugitive emission control measures taken (such as source reduction, process control, etc.) should be reported in the summary of this chapter.

(5) Ledger management information

The licensee shall complete the implementation of the environmental management ledger records. If the pollution prevention and control facilities are out of operation or abnormal in the operation form of the pollution prevention and control facilities, the ledger records of the abnormal period of the pollution prevention and control facilities shall also be submitted.

(6) Actual emissions

1.Organized emissions

The actual discharge of the main pollutants of exhaust gas (water) under normal working conditions should be completely reported, and the specific calculation process and supporting materials should be submitted.

If there are relevant monitoring data under abnormal working conditions or special periods, the actual emissions should be reported in the summary of this chapter or the "Actual Emissions of Exhaust Air Pollutants in Special Periods", and the specific calculation process and supporting materials should be submitted.

2.Fugitive emissions

If the discharge permit specifies five types of fugitive sources of volatile organic compounds: leakage of equipment and pipeline components (including sampling); loss of volatile organic liquids storage and blending; volatilization loss of organic liquid loading; Wastewater collection, transportation, storage, treatment and disposal process escape; The actual emissions of cooling towers and circulating water cooling systems should be reported in the summary of this chapter, and the detailed calculation process and basis should be submitted. If the petrochemical industry has delayed coking fugitive emissions, it should also report its actual emissions and submit the calculation process and basis.

For fugitive emissions that do not yet have the conditions to collect or eliminate pollutant discharge, the fugitive emissions of volatile organic compounds can be calculated when the enterprise implements the relevant fugitive emission control requirements (such as source reduction, process control, etc.) specified in the pollutant discharge permit.

3.Excessive emissions

When there is excessive discharge, the information such as the time period, discharge port, pollutant type, actual emission concentration, and reason for exceeding the standard should be completely filled, and the relevant information should correspond to the self-monitoring data of exceeding the standard. Among them, the period of excess waste gas should be reported hourly, and the period of excess wastewater should be reported on a daily basis.

(7) Information disclosure

The licensee shall fully fill in the implementation of information disclosure.

(8) Attachments

The licensee shall upload the self-monitoring distribution map (the monitoring points are marked completely, truthfully reflecting the actual monitoring point location), as well as the relevant information description, monitoring report, actual emission calculation process and basis that need to be submitted in items (1) to (7).

(9) The construction and operation of the internal environmental management system

The licensee shall fill in the summary of this chapter the internal environmental management system and operation of the enterprise, including personnel security, facility allocation, enterprise environmental protection planning, the construction and implementation of relevant rules and regulations, and the implementation of relevant responsibilities.

(10) The implementation of other pollutant discharge permits

The licensee shall fill in the summary of this chapter the implementation of the emergency plan, cleaner production and other management requirements specified in the pollutant discharge permit.

(11) Other circumstances that need to be explained

Matters not included in items (1) to (10) above are reported in the summary of this chapter.

(12) Compliance with changes in production and discharge

If there are changes in the scale, type, and destination of the main product output or the main raw and auxiliary materials in the reporting cycle, the adjustment of pollutants and pollution control facilities, and the self-storage and utilization of industrial solid waste, etc., the changes in the scale, type, and destination of the disposal facilities shall be compared with the national list of major changes and the detailed provisions of the Shanghai Municipal Implementation of the Environmental Rating Management List of Construction Projects according to the stage of change, and whether the changes are consistent with the relevant environmental impact assessment report approval documents submitted. The materials such as the environmental impact analysis and description of non-major changes in the construction project are consistent.

(13) Compliance with actual emission concentrations and emissions

1.Emission concentrations

(1) Monitor the validity of data. The monitoring data provided by the licensee shall meet the requirements of the relevant standards and technical specifications of national environmental monitoring. Among them, the automatic monitoring data shall be provided by the automatic monitoring equipment that meets the requirements of the "Relevant Regulations on the Construction, Networking, Operation and Maintenance and Management of Automatic Monitoring of Fixed Pollution Sources in Shanghai" and operates normally; The monitoring data of exhaust gas pollutants should meet the data validity requirements of the Technical Specification for Continuous Monitoring of Flue Gas (SO2, NOX, Particulate Matter) Emissions from Stationary Pollution Sources (HJ 75); The monitoring data of wastewater pollutants should meet the data validity requirements of the Technical Specification for Data Validity Discrimination of Water Pollution Source Monitoring System (CODCR, NH3-N, etc.) (HJ 356). Manual monitoring data should be provided by a certified unit with a monitoring quality system that meets the requirements of the specification or a testing institution certified by the national metrology administrative department (with CMA metrology certification mark). Law enforcement monitoring data is provided by the ecological and environmental monitoring department.

(2) Compliance. Under normal working conditions, the effective daily average value of the automatic exhaust gas (water) monitoring equipment meets the requirements of the permitted emission concentration, and the manual monitoring data meets the requirements of the permitted emission concentration. If the emission standards provide otherwise, it shall be judged according to its requirements. In case of abnormal working conditions, the licensee shall provide a reasonable explanation for the exceedance, including the suspension of treatment facilities, failures and abnormal conditions of monitoring facilities that have been reported to the ecological environment department.

2.Actual emissions

(1) Calculation principle. The actual emissions of major pollutants should be calculated based on the actual monitoring results. If the six types of VOCs fugitive emission sources are involved, the fugitive emissions should also be calculated in accordance with the Notice of the Shanghai Municipal Environmental Protection Bureau on Printing and Distributing the General Calculation Method for Volatile Organic Compound Emissions of Industrial Enterprises in Shanghai (Trial) (Hu Environmental Protection General 2017 No. 70) and the Notice of the Shanghai Environmental Protection Bureau on Printing and Distributing the Interim Measures for the Accounting of Volatile Organic Compound Emissions of Industrial Enterprises (Hu Environmental Protection General 2016 No. 62) and other documents.

(2) Data selection order. The monitoring data used to calculate the actual discharge of major pollutants shall be selected in accordance with the principles of automatic monitoring data, law enforcement monitoring data, self-monitoring, and manual monitoring data.

(3) Automatic monitoring data application. The actual emissions of the main pollutants of exhaust gas (water) should be calculated by multiplying the concentration of each time period in the CEMS data by the flow rate, and then the accumulation method should be used to calculate. If the ** data is missing, the missing data should be supplemented in accordance with the methods specified in HJ 75 and HJ 356. If the missing period exceeds 25%, the automatic monitoring data cannot be used as the basis for calculating the actual emissions.

(4) Application of manual monitoring data. The first is the actual emission of the main pollutants of exhaust gas. It should be calculated according to the method of multiplying the measured average emission concentration of pollutants per hour by the average flue gas volume and operating time in each manual monitoring period, and the weighted average should be when there are multiple sets of monitoring data in the monitoring period. The second is the actual discharge of major pollutants in wastewater. If there is a cumulative flow meter, it should be calculated according to the weighted average concentration of wastewater flow multiplied by the annual cumulative wastewater flow; When there is no wastewater flow monitoring, it can be calculated by multiplying the wastewater discharge amount specified in the permit by the measured average discharge concentration of pollutants.

(5) Other circumstances. First, the actual discharge of the main pollutants during the excess period should be calculated according to the method of multiplying the measured average concentration of pollutants during the excess period by the flue gas volume (waste water volume) and the excess time. Second, when the actual production time exceeds the time specified in the permit, the actual emissions shall be calculated according to the actual production time. Third, when the pollutants are not detected, the actual emissions of the main pollutants in the period do not need to be calculated. Fourth, if the licensee fails to carry out self-monitoring as required during the reporting period, the actual emissions shall be calculated according to the pollution production coefficient method or the material balance algorithm. Licensees are encouraged to truthfully calculate the actual emissions from start-up and shutdown, inspection and maintenance, and accident emissions.

(6) Emissions compliance. Compare the actual emissions of the whole plant with the permitted emissions of the exhaust gas (water) pollution factors one by one, and check whether the actual emissions in the reporting cycle meet the requirements of the pollutant discharge permit. Among them, the actual emissions of the organized source item and the unorganized source item should be calculated separately for the exhaust gas pollution factor.

(14) The implementation of environmental management requirements

1.Self-monitoring requirements

Combined with the "Notice on Printing and Distributing the Guidance Plan for Self-monitoring and Assistance of Pollutant Discharging Units in 2020" (Huanban Monitoring Letter No. 2020 No. 388) and other audits on the implementation of self-monitoring by licensees, it is important to review whether the monitoring facilities are installed in a timely manner and whether the frequency of manual monitoring meets the requirements.

(1) Automatic monitoring equipment. Through the effective monitoring of the number of data and other information, review whether the licensee has completed the construction, networking and filing of automatic monitoring equipment for fixed pollution sources within the specified time limit in accordance with the requirements of the Notice on Printing and Distributing the Relevant Provisions on the Construction, Networking, Operation and Maintenance and Management of Automatic Monitoring of Fixed Pollution Sources in Shanghai (Hu Huan Gui 2022 No. 4).

(2) Manual monitoring. Through the information such as the number of effective monitoring data, check whether the manual monitoring frequency of each pollution factor meets the monitoring frequency requirements of the permit.

(3) No organizational control. If equipment and pipeline components are involved in leakage, review whether their leak detection and repair meet the relevant requirements of the license.

2.Requirements for the operation and management of pollution control facilities

(1) Running time. The operating time of pollution control facilities (including desulfurization, denitrification, dust removal facilities, etc.) shall be reviewed according to the actual production time of each production unit in the implementation reporting cycle. In principle, the operating time of the pollution control facility should be greater than the actual production time of the corresponding pollution production unit.

(2) Removal efficiency. If the pollutant discharge permit specifies the removal efficiency requirements of the pollution control facility, it shall be combined with the relevant monitoring data to check whether the actual removal efficiency of the pollution control facility meets the permit requirements.

* |Eco-environmental learning.

: VOCs Frontier

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