I. Environmental impact assessment

As the basis of enterprise environmental management, EIA covers 99% of subsequent enterprise environmental management, including local environmental planning, environmental quality, emission standards, pollutant discharge equipment, pollutant concentration and total amount, environmental protection equipment and treatment methods, environmental risks, and so on. In a new project, the first environmental protection aspect is the environmental impact assessment. Of course, as an enterprise HSE, you do not need to be able to write, but you must be able to read.

So what are the points to pay attention to? (The following points are from the perspective of the company, not the reporting organization)

(1) Overall

1. Land nature (industrial land) and urban planning

Residential land for a factory? A factory in a residential area? Drinking water source plant?

These are very important but they are not important. The EIA unit will not receive them if there is a site problem.

2. Environmental assessment level

These are related to fees for enterprises, if the contract has been negotiated, there is basically no need to pay attention to.

3. Environmental function zoning and environmental quality standards

Need to understand, but not the focus, generally is directly concerned with its related emissions standards.

4. Environmental emission standards

Focus on.

There are many standards, such as national standards, local standards, industrial standards, etc., which standard to implement is crucial. Each pollution factor needs to personally confirm its corresponding emission standards, rather than blindly trust EIA units.

(2) Engineering

1. Types and quantities of raw and auxiliary materials and pollution producing equipment

Focus on.

If you are in charge of this EIA project, please be sure to confirm with the production and design department the type and quantity of raw materials and sewage production equipment, and keep the paper documents or emails. These directly affect the total amount and types of the most important pollutants in the EIA. If the amount is too different from the actual amount, it will lead to failure to pass the acceptance, too much or too little total pollutant discharge, and the selection of environmental protection facilities.

2. Four waste treatment measures and feasibility analysis

Most important.

If it is a relatively large project, environmental protection facility manufacturers will give the design scheme at the EIA stage, and the EIA unit will be directly used on the line. If it is a small project, it may be the EIA unit made up by itself, and the subsequent owners will directly buy the corresponding equipment. As an enterprise HSE, advice directly memorized, can be used in many occasions.

3. Water balance and material balance

Be familiar with key points.

If the water balance is in the report preparation stage, please check it at least once to ensure that it can be balanced.

4. Technological process and corresponding pollutant types

Must be familiar with.

These can be said to be the embodiment of the basic quality of enterprise HSE. If the entire process and corresponding pollutants can not be identified, then forget about environmental protection.

(3) The common ginseng

Don't want to say too much, there is always a way...

Relevant regulations:

Look directly at the EIA report for its basis.

Two, environmental acceptance

At present, only solid waste environmental protection facility acceptance needs approval from the Environmental Protection Bureau. When the new solid waste law is implemented, it should be completely independent acceptance, that is, there will be no official approval.

Personally, I think the acceptance is quite easy. If the company is willing to pay me, I can try to write the acceptance report......

The main purpose of the inspection is to confirm whether the environmental protection measures set out in the EIA have achieved the expected effect.

The first thing to pay attention to in acceptance is the time node:

The following contents refer to the Interim Measures for Environmental Protection Acceptance of Construction Projects upon Completion.

The starting node is "after completion of the project." The maximum duration shall not exceed 12 months.

"With the exception of water and air pollution prevention and control facilities requiring discharge permits, the acceptance period for other environmental protection facilities shall generally not exceed three months; If it is necessary to debug or rectify such environmental protection facilities, the acceptance period may be extended appropriately, but not more than 12 months.

The term for inspection and acceptance refers to the period from the date of completion of the environmental protection facilities of the construction project to the date when the construction unit discloses the inspection and acceptance report to the public."

Two premises in particular need to be noted:

1. Environmental protection facilities shall be completed simultaneously with the main project

2. Has obtained the emission permit (shall obtain the emission permit)

If the above two conditions are met, then the construction unit can "debug the environmental protection facilities of the construction project" (in the words of the enterprise, it is ready to produce, but I am in order to debug the environmental protection facilities).

There is another regulation on the acceptance of construction projects, called the "Measures for the Management of the Acceptance of Environmental Protection upon Completion of Construction Projects". Although it has not been explicitly abolished, it has basically ceased to be used. This is where the term "trial production" comes from.

Acceptance is the best opportunity to correct EIA errors. If there is any small problem, it can be put forward and corrected in the acceptance report. As long as it is not a major change, it can pass the acceptance. What is a major change? By far the most important document is the "Notice on the Issuance of a List of Major Changes to Construction Projects in the Central Sub-Industries of EIA Management", which contains clear standards for some industries, while others are subject to consultation and judgment. Generally speaking, it is based on the nature, scale, location, production technology and environmental protection measures of the five comprehensive judgment.

To put it simply, acceptance is to check the contents of the EIA report, cheak by cheak, and finally conclude that the project meets the EIA and approval requirements.

It is necessary to pay attention to the key contents of the EIA, such as raw and auxiliary materials, types and quantities of machines, processes, pollutant emission standards, pollutant types and total amounts, and so on.

3. Operation and maintenance of environmental protection facilities

Although the title is the operation and maintenance of environmental protection facilities, but it does not mean that the specific operation of some environmental protection facilities, that is the matter of the factory department, of course, the processing principle of environmental protection facilities in the plant is sure to understand. As HSE, the focus should be on how to ensure the effective operation of environmental facilities.

So, what to do?

I think the most basic is: the company's environmental protection facilities management system is perfect.

Regulation is fundamental, though many times people don't pay much attention to it, just based on day-to-day experience (including the HSE itself). If all aspects of environmental facilities were managed better, the HSE's task would be simple: to do Cheak (inspection) and to drive Action (improvement).

The following two points should be noted:

1. Clarify the responsibilities of the position

Who is responsible for daily operation, who is responsible for daily monitoring, who is responsible for outsourcing, who is responsible for emergency response, etc., all these need to be clearly defined responsibilities. Only by clarifying the rights and responsibilities, can we not quarrel with each other when problems occur (not...). .

2. Clarify routine inspection requirements

Which posts are responsible for inspection, inspection frequency, specific inspection content, inspection form, etc.

These are important elements of the HSE audit. Within a company, HSE is the third party that supervises audits. If the work of the department is not in place and whether it is implemented in accordance with the requirements, it is not enough to only rely on the department head or some group leaders within the department to supervise, which needs to be carefully audited by HSE. After all, no matter how big the factory, everything is also done by the specific "people", these employees in the professional level, professional quality and other aspects are different, it is possible to cut corners in the execution, or understanding is not in place, or used to some problems, at this time, it is very necessary for the external department personnel to supervise and audit, to ensure that the system has been well implemented.

In addition to the system, there are some compliance requirements need to pay attention to, the factory department may be unfamiliar with some standard requirements, such as the setting requirements of the discharge outlet, the number of exhaust cylinder requirements and so on, so the need for HSE to do a good job of regulatory identification, and timely communicated to the relevant responsible department.

Four, environmental monitoring

Environmental monitoring, for most enterprises is a very simple matter, but for the key pollutant units, it is very tedious.

Monitoring is a relatively large concept, relatively large scope, continuity, for daily work, is to detect pollutant emission concentration.

Detection is divided into internal self-detection and external supervised detection:

Inside:

Periodic outsourced testing;

Self-sampling and detection;

Online detection;

External:

Government supervised testing;

In terms of monitoring, the most important thing for HSE is to formulate monitoring plans according to the Technical Guidelines for Self-Monitoring of Pollutant Discharge Units.

The monitoring programme means:

The pollutant discharging unit shall find out all the pollution sources, determine the main pollution sources and main monitoring indicators, and formulate monitoring plans. The contents of the monitoring plan include: basic information of the unit, monitoring points and diagrams, monitoring indicators, implementation standards and their limits, monitoring frequency, sampling and sample preservation methods, monitoring analysis methods and instruments, quality assurance and quality control, etc.

As an enterprise's environmental management personnel, the types of pollutants in the factory, discharge port, emission standards, monitoring frequency must be very understanding (back), what process will produce what pollutants, corresponding to which discharge port, their emission standards are which, the specific limit is how much, these should be able to blurt out.

Let's talk about some of the considerations for these types of tests.

1. Regular outsourced testing

Outsourcing here refers to a qualified third party testing unit. (This one includes three employment directions after environmental engineering graduation: HSE, sampling and testing)

Each enterprise has a different level of development and has different requirements for the third party. The most common requirement was "good communication."

For example, how to exceed the standard, to measure, or more directly, to help "deal" with it, and even some enterprises to find a third party standard is, every time to reach the standard.

Personally, I am very opposed to this direct requirement to meet standards. HSE is the environmental management personnel of the enterprise. It is understandable that HSE directly asks for assistance to "deal with" the situation in an emergency. However, it is very dereleliction in my opinion to ask for the result of meeting the standards directly no matter what (some third parties are brave enough to ask, but they also dare to agree). Because inviting a third party to test is a process of internal audit, judging our daily management or equipment status through authoritative data, blindly pursuing outsourcing test standards, is sacrificing the cost.

For higher-level enterprises, finding an authoritative and responsible third party should be more important. After all, if there's a problem with the results, whether it's a problem with the test or a problem with the site, this one will be debated for a long time.

2. Self-sampling and detection

As an auxiliary reference, it is necessary to focus on the competence of field personnel

3. Online detection

Online testing is different from outsourcing testing. Although both of them have to be reported to the Environmental Protection Bureau, one can wait until it is confirmed to be qualified, while the other transmits data in real time. The specific affairs involved are not good to talk about, buy a better equipment, find a better maintenance unit, can save a lot of worry. To look at the relevant specifications, do HSE, there is no way to do all aspects of the expert, but to do all aspects of the understanding of some, and according to the relevant specification materials to make a correct judgment.

4. Government supervision testing

Like the final exam, if you usually do a good job of daily management, self-testing is no problem, then you are not afraid, if you usually do nothing, muddle, then this is a big problem.

This kind of inspection is different from environmental protection inspection. If there is a lack of environmental protection inspection, the less serious ones will be rectified. However, once the inspection exceeds the standard, it is often accompanied by a fine. The local EPA will have a discretion to check it out and get a sense of what's being fined and how much.

Updated in November 2022

After more than two years, basically not much management of environmental protection, suddenly heard that the brother factory because of the environmental emergency plan was opened to rectify the problem, but also appeared to urge more friends, so write some more.

5. Environmental emergency response

When it comes to environmental emergency, the most common problem is: Should we make environmental emergency plans and file them with the Environmental Protection Bureau?

Let's start with laws and regulations. The requirement for the source of environmental emergency plan is Article 47 of the Environmental Protection Law:

Enterprises and institutions shall, in accordance with relevant State regulations, formulate emergency plans for environmental emergencies and submit them to competent environmental protection departments and other relevant departments for the record. When environmental emergencies occur or are likely to occur, enterprises and institutions shall take immediate measures to deal with them, promptly notify the units and residents that may be harmed, and report to the competent environmental protection department and other relevant departments.

The relevant regulations refer to the Measures for the Record Management of Emergency Plans for Environmental Emergencies of Enterprises and Institutions (Trial) (No.4 of Environmental Development [2015]).

Yes, you read that right. It is November 2022, and the Ministry of Environmental Protection is still using the same pilot measures introduced in 2015. After seven years of trial implementation, the Ministry of Environmental Protection is serious enough and prudent enough.

So what does this trial method say?

Article 3 These Measures shall apply to the guidance and management of the filing of environmental emergency plans of the following enterprises by the competent environmental protection authorities:

(1) Enterprises that discharge pollutants, including enterprises operating facilities for the centralized treatment of sewage and household refuse, which may cause environmental emergencies;

(2) Enterprises that produce, store, transport or use hazardous chemicals;

(3) Enterprises that produce, collect, store, transport, utilize and treat hazardous waste;

(4) tailings pond enterprises, including wet storage of industrial waste slag storage, power plant ash storage enterprises;

(5) other enterprises that shall be included in the scope of application. These Measures shall not apply to the filing of emergency plans for nuclear and radiation environment. The competent department of environmental protection at the provincial level may, in light of the actual situation, publish a list of enterprises that shall be put on record with environmental emergency plans in accordance with the law.

According to this statement, 99.99% of manufacturing enterprises are to prepare environmental emergency plans and record, of course, there will be some detailed rules, there will be more specific requirements, such as Xiamen Environmental Protection Bureau notice:

Enterprises that involve a small maximum amount of environmental risk substances or involve only general chemicals in a small quantity may be included in the encouraged category in accordance with Article 4 of the Measures for the Administration of Archival Filing of Pre-Plan, and the preparation of pre-plan may be relatively simplified. The compilation process and archival materials shall not be simplified.

According to this statement, enterprises with a small amount of environmental risk substances can be classified as encouraged, that is, "other enterprises are encouraged to develop a separate environmental emergency plan, or develop a special chapter of environmental emergency plan in emergency response plans, and put on record". That is to say, there is no need to make emergency plans, but this measure is in the hands of the government. If you ask, you will not get a reply of "no need".

Can I write it and file it myself? Save some money without expert review.

No.

(4) Reviewing and practicing environmental emergency plans. Enterprises organize experts and representatives of potentially affected residents and units to review environmental emergency plans and conduct drills for testing. The review experts should generally include personnel from relevant government administrative departments involved in the environmental emergency plan, representatives of relevant industry associations, and personnel with experience in relevant fields.

Do to do a full set, such as the above encouraged enterprises, if you do, to the plan content can be simple, the other is a little less.

Having said so much, if you are still not resigned to the idea that my factory has nothing and does not need an emergency plan, then you should at least prepare an environmental emergency plan by yourself. Review and record will be another matter. General environmental risk small company, as long as there is an emergency plan, can pass most of the audit, rarely check you have not to record.

All right, so much space on the question of whether or not to do it. Now let's talk about the details.

Environmental emergency plan, the core or how to prevent untreated pollutants discharged in the external environment.