incoming letter:

According to the "Technical Guidelines for Environmental Protection Acceptance of Construction Projects - Pollution Impact Category", section 6.3.2 "Environmental Quality Impact Monitoring: mainly focuses on monitoring the environmental quality of sensitive protection targets that are of concern in the environmental impact report (table) and its approval decision by the approval department, including surface water, groundwater and seawater, ambient air, acoustic environment, soil environment, radiation environment quality, etc." How to determine this "concern". If the three simultaneous acceptance table in the environmental impact assessment report mentions the requirement for groundwater seepage prevention, and there are groundwater monitoring categories in the environmental monitoring plan, should groundwater monitoring be carried out during the project acceptance process?

reply:

1、 6.3.2 Environmental Quality Impact Monitoring: Environmental quality impact monitoring mainly focuses on the environmental quality of sensitive protection targets that are concerned in the environmental impact assessment report (table) and its approval decision by the approval department, including monitoring of surface water, groundwater and seawater, ambient air, acoustic environment, soil environment, radiation environment quality, etc. "in the" Technical Guidelines for Environmental Protection Acceptance of Construction Project Completion "refers to the environmental sensitive protection targets explicitly listed in the environmental impact assessment report (table) and environmental impact assessment approval documents. Monitoring the environmental quality of environmentally sensitive protection targets during acceptance can provide a basis for determining the degree of impact of construction projects on the surrounding environmental quality.

2、 If the "Three Simultaneities" acceptance form in the environmental impact assessment report mentions the requirement for groundwater seepage prevention, and there are groundwater monitoring categories in the environmental monitoring plan, groundwater monitoring should be carried out during the acceptance. The monitoring points and factors can be selected according to the environmental impact assessment requirements.

Reply to inquiries regarding the Technical Specifications for Environmental Protection in the Catering Industry and the Air Pollution Prevention and Control Law of the People's Republic of China

incoming letter:

1. "Technical Specifications for Environmental Protection in the Catering Industry" HJ554-2010 6.1.1 Gas collection hoods should be installed above processing facilities such as stoves, steamers, and ovens (boxes) in kitchens, and exhaust pipes for oil fume and hot steam should be installed separately. Excuse me: After setting up separate exhaust ducts for oil fume and hot steam, are the layout requirements for the hot steam exhaust outlet similar or lower than those for the oil fume exhaust outlet. Article 2 of the Air Pollution Prevention and Control Law of the People's Republic of China prohibits the construction, renovation, or expansion of catering service projects that generate oil fumes, odors, and exhaust gases in residential buildings, commercial and residential complexes without dedicated smoke ducts, and adjacent commercial floors within commercial and residential complexes. Please ask: The catering store mainly sells dumplings, steamed buns, Wonton, bone soup, various kinds of covered noodles and other foods. The steaming steam collected by the gas collecting hood above the processing facilities such as the noodle pot, soup pot, and steaming pot is discharged outside the store through the exhaust fan. Whether this kind of steaming steam with odor belongs to the category of "exhaust gas".

reply:

1、 The "Technical Specification for Environmental Protection in the Catering Industry" (HJ 554-2010) requires that gas collection hoods should be installed above processing facilities such as stoves, steamers, and ovens (boxes) in kitchens, and exhaust pipes for oil fume and hot steam should be set up separately. The layout requirements for oil fume discharge outlets are also specified. There are no requirements for the layout of the hot steam discharge outlet, but it should be avoided from affecting the daily lives of surrounding residents and causing complaints.

2、 The steaming and boiling steam with odor in restaurants belongs to the special odor generated by the catering industry, and the odor concentration index shall be implemented in accordance with the "Emission Standards for Odor Pollutants (GB14554-93)".

Reply on how to determine whether the quality control sample assessment results in online comparison are qualified

incoming letter:

How to understand "5.1.2.2 Quality Control Sample Assessment" in the "HJ/T 354-2007 Technical Specification for Acceptance of Online Monitoring System for Water Pollution Sources", where "the relative error of quality control sample determination is not greater than ± 10% of the standard value"? For example, if the purchased certified quality control sample concentration is (0.400 ± 0.02) mg/L and the online equipment monitoring concentration is 0.371 mg/L, is the data qualified and how to calculate it specifically? Thank you. Some online operation and maintenance manufacturers have informed them to directly compare the online monitoring value with ± 10% of the standard value, which means that 0.371 mg/L is within the range of (0.36-0.44) mg/L, indicating qualification, but no explicit regulation has been found. What is the meaning of "relative error of quality control sample" in the standard, and I personally understand the relative error. It's a percentage, and ± 10% of the standard value is an accurate range of values. Can this be compared?

reply:

The "Technical Specification for Acceptance of Online Monitoring System for Water Pollution Sources" (HJ/T 354-2007) states that "the relative error of quality control sample measurement shall not exceed ± 10% of the standard value", which means that the relative error between the measured value of the quality control sample and the standard value should be within ± 10%.

The calculation formula is: (measured value of quality control sample - standard value)/standard value x 100%. If the measured value of the quality control sample is 0.371mg/L and the standard value is 0.400mg/L, the relative error is (0.371-0.400)/0.400 × 100%=-7.2%, and it is judged that the quality control sample has passed the assessment.

Reply on the Definition of Hazardous Waste Recycling

incoming letter:

I am unable to define the issue of hazardous waste recycling and would like to seek your advice. Recently, during an inspection of a car repair shop in our jurisdiction, we found that the unit sold waste engine oil to a vendor without a hazardous waste management license. After further investigation, the vendor resold the recovered waste engine oil to a construction site for demolding purposes. Since the oil collected by the vendor can be reused, should the oil be classified as hazardous waste, and can the behavior of the auto repair shop be classified as an illegal act of entrusting hazardous waste to individuals without a business license for disposal.

reply:

1、 The waste engine oil generated by auto repair shops belongs to the category of "waste mineral oil and waste containing mineral oil" listed in the "National Hazardous Waste List" (Order No. 39 of the Ministry of Environmental Protection), which includes "waste lubricating oil such as waste engine oil, brake oil, automatic transmission oil, gear oil, etc. generated during the maintenance and disassembly of vehicles and machinery".

2、 Selling waste engine oil to unlicensed vendors by auto repair shops falls under the category of "providing or entrusting hazardous waste to unlicensed units for collection, storage, utilization, and disposal activities" as stipulated in Article 57 (3) of the Solid Waste Pollution Prevention and Control Law of the People's Republic of China.

Reply on whether the Management Measures for Environmental Protection Acceptance upon Completion of Construction Projects have been abolished

incoming letter:

Since 2015, the National People's Congress has successively revised a series of laws such as the Environmental Protection Law, the Air Pollution Prevention and Control Law, the Water Pollution Prevention and Control Law, and the Environmental Noise Pollution Prevention and Control Law. The State Council has revised the Regulations on Environmental Protection Management of Construction Projects, and the Ministry of Ecology and Environment has also issued the Interim Measures for Environmental Protection Acceptance of Construction Projects upon Completion. The Announcement of the Ministry of Environmental Protection on Publishing the Catalogue of Effective Regulations of National Environmental Protection Departments (Announcement No. 68 of 2016) does not include the Management Measures for Environmental Protection Acceptance of Construction Projects (Order No. 13 of the State Environmental Protection Administration). Has the Management Measures for Environmental Protection Acceptance of Construction Projects (Order No. 13 of the State Environmental Protection Administration) been abolished?

reply:

The "Management Measures for Environmental Protection Acceptance of Construction Projects upon Completion" (Order No. 13 of the State Environmental Protection Administration) issued by the former State Environmental Protection Administration on December 27, 2001 has not been abolished.

Reply on whether hazardous waste of waste acid and alkali can be included in the enterprise sewage treatment system

incoming letter:

According to the National Hazardous Waste List (2016), the waste acid produced from acid washing belongs to hazardous waste, with the hazardous waste category being waste acid HW34 and waste code 900-300-34. The hazardous waste generated by alkaline washing is waste alkali HW35, with waste code 900-352-35. According to the "Technical Policy for Prevention and Control of Hazardous Waste Pollution": 2.2 For hazardous waste that has already been generated, it must be declared and registered in accordance with relevant national regulations, specialized facilities and places that meet standards must be constructed and properly stored, and hazardous waste signs must be set up. It can be disposed of by itself or handed over to units holding hazardous waste business licenses for collection, transportation, storage, and disposal in accordance with relevant regulations. During the disposal process, measures should be taken to reduce the volume, weight, and degree of danger of hazardous waste.

During the production process of an enterprise, acid and alkali are used for acid and alkali washing, resulting in waste acid and alkali. According to the actual test results, the pH of the waste acid is less than 2 and the pH of the waste alkali is greater than 12.5. According to the "Identification Standards for Hazardous Waste Corrosivity Identification", it belongs to hazardous waste. Can this waste acid and alkali be neutralized by the enterprise itself or treated in its own sewage treatment system?

reply:

The waste acid and alkali produced by your company can be treated and disposed of according to relevant regulations, but the construction of treatment and disposal facilities must strictly comply with the requirements of environmental impact assessment documents to ensure stable and compliant emissions.

Reply on the Selection of Monitoring Factors for Soil Status

incoming letter:

For large-scale water conservancy hub projects, soil environment monitoring will be carried out in canyon areas with mostly farmland or unused land. According to the new guidelines, 45 factors specified in the 36600 construction land soil risk control standard will be selected within the reservoir area (including the dam site area), and 8 factors specified in the 15618 agricultural land soil pollution risk control standard will be selected outside the reservoir area. In addition, soil background salt content will be measured. Is it appropriate to understand and select soil environmental monitoring factors in this way? Is it necessary to set up monitoring points downstream of the dam site?

reply:

For large-scale water conservancy hub projects, soil environment status monitoring will be carried out in the canyon area, which is mainly farmland or unused land. It is proposed to use 45 monitoring factors specified in GB3600 within the reservoir area, and 8 monitoring factors specified in GB15618 outside the reservoir area. In addition, soil background salt content will be measured. Answer to the question of whether the selected soil environmental monitoring factors are appropriate and whether it is necessary to deploy monitoring points downstream of the dam site:

According to the "Technical Guidelines for Environmental Impact Assessment - Soil Environment (Trial)" (HJ964-2018), "the monitoring factors of soil environment status are divided into basic factors and characteristic factors of construction projects. The basic factors are the basic items specified in GB15618 and GB36600, which are selected according to the land use types within the scope of investigation and evaluation; The characteristic factor is the unique factor generated by the construction project.

After communication and confirmation with the sender, the reservoir area referred to in the letter is the flooded area of the water conservancy project, excluding the dam construction area. Usually, the basic factors for monitoring the current status of soil environment in the scope of investigation and evaluation should adopt the basic items specified in GB15618. But if the current land use status within the storage area is construction land with pollution sources (such as landfills, etc.), the basic items and possible characteristic pollutants specified in GB36600 should be adopted.

Large scale water conservancy hub projects belong to the ecological impact type, and the selection of characteristic factors should consider the influence factors of special soil types such as salinization, acidification, and alkalization. For example, the characteristic factor of acidified soil should be selected as pH, and the characteristic factor of saline alkali soil should be selected as pH and salt content.

Whether it is necessary to deploy monitoring points downstream of the dam site is mainly determined based on the scope of investigation and evaluation. HJ964-2018 stipulates that the scope of investigation and evaluation should include the potential impact of the construction project, which can meet the requirements of soil environment impact prediction and evaluation; the scope of investigation and evaluation of the current situation of renovation and expansion construction projects should also take into account the potential impact of existing projects.

Reply on Sewage Discharge Standards

incoming letter:

After the implementation of the "Comprehensive Wastewater Discharge Standards for the Yellow River Basin in Shaanxi Province" DB 61/224-2018, for indirect wastewater discharge without industry standards, the wastewater discharge shall comply with the "Comprehensive Pollutant Discharge Standards" GB 8978-1996 or the "Water Quality Standards for Wastewater Discharge into Urban Sewers" CJ 343-2010.

reply:

Article 50 of the Water Pollution Prevention and Control Law of the People's Republic of China stipulates that "the discharge of water pollutants into urban sewage centralized treatment facilities shall comply with the national or local water pollutant discharge standards." The "Comprehensive Wastewater Discharge Standards for the Yellow River Basin in Shaanxi Province" (DB 61/224-2018) stipulate that "pollutant discharge units that implement indirect discharge shall comply with the corresponding national discharge standards." Therefore, after the implementation of DB61/224-2018, for units that indirectly discharge wastewater, if there is no national industry discharge standard, they shall comply with the indirect discharge control requirements of the "Comprehensive Wastewater Discharge Standards" (GB 8978). When sewage is discharged into the urban drainage network, it should also comply with the relevant requirements of urban drainage management.

Reply on the Implementation Issues of Domestic Sewage in Industry Standards

incoming letter:

The industry standards of "Pollutant Discharge Standards for Rubber Products Industry (GB 27632-2011)" and "Pollutant Discharge Standards for Battery Industry (GB 30484-2013)" both specify that the discharge volume includes domestic sewage in the factory area, but do not specify whether the discharge of domestic sewage should comply with this standard. Experts now require that the domestic sewage taken over to the municipal sewage treatment plant must also comply with the above industry standards during project review.

In terms of our administrative region, the municipal sewage pipeline network has been fully equipped, and centralized sewage treatment plants with sufficient capacity have been built in the area. The local environmental authorities also require enterprises to separate the four types of water (production wastewater, domestic wastewater, clean water, and rainwater), and require the reduction of production wastewater or a certain proportion of reuse. Domestic sewage relies on existing municipal facilities, while production wastewater is self treated and discharged or reused to meet standards, which is more in line with the perspective of environmental benefits. May I ask if rubber products and battery processing enterprises can comply with the urban sewage treatment plant takeover standards for domestic sewage?

reply:

The "Emission Standards for Pollutants in the Rubber Products Industry" (GB 27632-2011) and the "Emission Standards for Pollutants in the Battery Industry" (GB 30484-2013) both specify in the definition of "discharge volume" that the discharged wastewater includes domestic sewage in the factory area. The main consideration is to prevent the mixing of industry characteristic pollutants in the factory area's domestic sewage related to production, as well as the discharge of production wastewater through domestic sewage drainage pipelines. Therefore, the domestic sewage in the factory areas of relevant enterprises should be controlled in accordance with industry discharge standards in principle. If the domestic and production wastewater are completely isolated and effective measures are taken to prevent risks such as mixed discharge, this type of domestic wastewater can be managed as general domestic wastewater.

Reply on GB36600 and Risk Management of Polluted Soil

incoming letter:

Regarding the first and second types of land in the GB36600 standard, if the plot belongs to a certain type of land and the investigation finds that the pollutants in the soil exceed the screening value of the first type of land, there is pollution, but the pollutant content does not exceed the screening value of the second type of land. Can the contaminated soil of the plot be transported to the second category of land with clear planned use as a risk management measure?

reply:

Regarding the investigation into whether contaminated soil from plots that exceed the screening value for Class I land in the GB36600 standard but do not exceed the screening value for Class II land can be transported to Class II land that has been clearly planned for use, as a risk control measure:

The transportation of contaminated soil is not a means of risk control, and the transportation of contaminated soil should not be used as a method to solve soil pollution problems. If it is necessary to carry out ex situ remediation or reuse of the remediated soil during the implementation of polluted soil treatment and remediation, and it is necessary to transport it, the following regulations must be met:

1、 Article 38 of the Soil Pollution Prevention and Control Law stipulates that risk control and remediation activities shall not cause new pollution to the soil and surrounding environment.

2、 According to the Technical Guidelines for Risk Control and Soil Remediation Effect Evaluation of Polluted Land (Trial) (HJ25.5-2018), if the repaired soil is transported to other land parcels, the risk assessment should be conducted based on the exposure scenario of the receiving soil to determine the evaluation standard value, or the higher of the background concentration of the receiving soil and the screening value corresponding to the nature of the receiving land in GB36600 should be used as the evaluation standard value, and the groundwater and environmental safety of the receiving soil should be ensured. Risk assessment can be carried out in accordance with HJ25.3.

3、 According to Article 41 of the Soil Pollution Prevention and Control Law, if a restoration construction unit transports polluted soil, it shall formulate a transportation plan and report in advance to the local and receiving ecological and environmental authorities the transportation time, method, route, quantity, destination, and final disposal measures of the polluted soil. If the contaminated soil transported belongs to hazardous waste, the remediation construction unit shall dispose of it in accordance with the requirements of laws, regulations, and relevant standards.

4、 If the soil pollution concentration received by the receiving site exceeds the risk screening value for Class I land use, risk control measures need to be implemented for the receiving site, and later environmental supervision suggestions should be proposed in accordance with HJ25.5-2018. After receiving contaminated soil, if a general survey, detailed investigation, monitoring, and on-site inspection of soil pollution indicate a risk of soil pollution, or if the use is changed to residential, public management, and public service land, a soil pollution investigation shall be conducted in accordance with the Soil Pollution Prevention and Control Law. If the review of the investigation report on soil pollution indicates that the pollutant content exceeds the soil pollution risk control standards, the units and individuals transporting polluted soil shall bear the responsibility for soil pollution.

Reply to the Consultation on the Completion Acceptance of Environmental Protection Facilities in Construction Projects

incoming letter:

Our company submitted an application for the completion acceptance of environmental protection facilities for the construction project to the provincial department in June 2016. In January 2017, the provincial monitoring station issued an environmental monitoring report for this project. In March 2017, the provincial department organized experts to conduct on-site acceptance and put forward rectification opinions. In August 2017, we completed the boiler rectification (adding bag dust removal and desulfurization devices) and other rectification items. As it is a heating boiler, the smoke monitoring after rectification needs to be carried out during the heating period (after November). In November, the local environmental monitoring station of the project came to the site for monitoring and issued a monitoring report. The results were qualified, and the local environmental protection department also issued an acceptance opinion after rectification.

After our company submitted the rectification acceptance opinions and monitoring reports to the provincial department, the response was that due to the change in environmental protection acceptance policies in October, the completion acceptance of environmental protection facilities for construction projects was organized by the enterprise itself, and the provincial department no longer issued acceptance reports. I would like to inquire if the environmental protection department responsible for organizing the acceptance can still provide our company with an acceptance report in this situation? Do companies still have to organize environmental inspections themselves again?

reply:

Implementing self acceptance of environmental protection enterprises upon completion of construction projects is an important measure to deepen the "streamlining administration and delegating power" reform of the ecological environment system and further implement the main responsibility of enterprises for ecological environment protection. At present, relevant laws and regulations such as the Environmental Protection Law of the People's Republic of China, the Law of the People's Republic of China on the Prevention and Control of Atmospheric Pollution, the Law of the People's Republic of China on the Prevention and Control of Water Pollution, and the Regulations on the Management of Environmental Protection for Construction Projects have been revised and successively promulgated and implemented, clarifying that the acceptance of atmospheric and water pollution prevention and control facilities for construction projects shall be changed from the acceptance by the ecological environment department to the self acceptance by the construction unit.

The Law of the People's Republic of China on the Prevention and Control of Solid Waste Pollution and the Law of the People's Republic of China on the Prevention and Control of Environmental Noise Pollution are still under revision. According to relevant regulations, before the implementation of the Solid Waste Law and the Noise Law, the ecological environment department shall inspect the noise and solid waste pollution prevention and control facilities of construction projects.

Please classify your company according to the types of pollution prevention and control facilities, that is, organize the acceptance of air and water pollution prevention and control facilities by yourself, and apply to the ecological environment department for the acceptance of noise and solid waste pollution prevention and control facilities in accordance with the law.

Reply on Issues Related to Comparative Monitoring of Automatic Monitoring Facilities

incoming letter:

According to the Technical Regulations for Comparison and Monitoring of Pollution Source Automatic Monitoring Equipment, the total number of comparison tests should not be less than 3. Among them, 2 pairs of actual water samples that pass the comparison are considered qualified. In the actual law enforcement process, if law enforcement personnel find that the digestion time, temperature, and other settings of the automatic monitoring facility do not comply with relevant technical specifications, they immediately collect 2 bottles of actual water samples. One bottle is immediately operated on the machine to read instrument data, and the other bottle is sent to the monitoring station for manual monitoring. If the comparison is found to be unqualified, and there is only one set of comparison data, can it be judged that the equipment is not operating normally? If it is only found that the parameters such as digestion time and temperature do not meet the technical specifications, without conducting relevant comparative monitoring, it can still be determined that the equipment is not operating normally?

reply:

For the identification of suspected abnormal operation of automatic monitoring equipment, reference can be made to Article 19 of the "Measures for On site Supervision and Inspection of Pollution Source Automatic Monitoring Facilities" (formerly Order No. 19 of the Ministry of Environmental Protection), which includes: failure to operate in accordance with technical specifications, resulting in significant distortion of pollution source automatic monitoring data; Unauthorized modification of parameters and data related to the pollution source automatic monitoring system.

In the actual law enforcement process, it is possible to determine whether there is significant data distortion due to non-compliance with technical specifications and law enforcement monitoring results. Combined with operation and maintenance records and acceptance records, it is possible to determine whether there is unauthorized modification of parameter settings.

Reply on the issue of automatic monitoring facilities for pollution sources being inspected and accepted by the polluting units

incoming letter:

On August 3, 2017, the Ministry of Environmental Protection issued the "Notice on Accelerating the Automatic Monitoring of Key Polluting Units in Key Industries and Regions" (Environmental Office and Environmental Supervision [2017] No. 61), which clearly stated that "after the installation, networking, or renovation of automatic monitoring equipment for key polluting units is completed, the main investor in the purchase and construction should organize acceptance in accordance with relevant technical standards and specifications, and submit the relevant acceptance materials to the environmental protection department with jurisdiction for filing. We sincerely request guidance on the problems encountered during the actual implementation process. The specific situation is as follows:

How long does it take to complete the acceptance of the automatic monitoring equipment installed and connected to the network by the polluting unit? Are there any corresponding laws and regulations that impose penalties on those who fail to complete the acceptance within the specified time limit?

2. Does the organization and acceptance of pollutant discharge units require the participation of relevant experts, and are there specific operational procedures?

3. Do environmental protection departments need to provide opinions on the acceptance materials reported by polluting units? Do we need to conduct an on-site audit?

4. Does the automatic monitoring facility acceptance report issued by the polluting unit have specific format and content requirements?

5. Is it necessary to publicize the acceptance status of automatic monitoring facilities of polluting units? How long is the public notice period?

6. Should the acceptance time of the automatic monitoring facilities of the pollutant discharge unit be based on the date of signing the comparison monitoring report, the date of signing the automatic monitoring facility acceptance report, or the date of reporting the acceptance data?

reply:

1. The specific issues regarding the automatic monitoring and acceptance process of key polluting units can refer to the "Technical Specifications for Continuous Monitoring of Fixed Pollution Source Smoke (SO2, NOx, particulate matter) Emissions" (HJ 75), "Technical Specifications for Acceptance of Online Monitoring Systems for Water Pollution Sources" (HJ 354), and relevant regulations issued by local ecological environment departments. There are no mandatory requirements in current laws, regulations, departmental rules, and normative documents issued by our department.

2. There are no targeted penalty clauses in current laws for those who fail to complete the acceptance inspection as required. However, key polluting units shall install and use automatic monitoring equipment in accordance with laws, regulations, standards and specifications, connect with the monitoring equipment of the ecological environment department, ensure the normal operation of the monitoring equipment, preserve the original monitoring records, and be responsible for the authenticity and accuracy of the automatic monitoring data. If it is found during regulatory enforcement that automatic monitoring equipment has not been installed and connected to the internet in accordance with regulations, monitoring equipment has not been guaranteed to operate normally, or pollutants have been discharged by tampering or forging monitoring data to evade supervision, relevant provisions such as Articles 99 and 100 of the Air Pollution Prevention and Control Law and Articles 82 and 83 of the Water Pollution Prevention and Control Law shall be punished.

Reply to the Consultation on Acceptance Related Work after Environmental Impact Assessment Level Change

incoming letter:

In recent years, due to the adjustment of relevant laws and regulations and the classification management directory of construction projects, we often encounter the problem of changes in project environmental impact assessment levels in our daily law enforcement. How should we handle the following two situations in the department: 1. If the enterprise has already obtained an environmental impact assessment report or report form, and according to the new construction project classification management directory, the project level has been adjusted to a registration form, does this type of project still need to undergo environmental protection facility acceptance? 2. The enterprise has completed the environmental impact assessment registration form, but according to the new classification management directory, the project level has been adjusted to report or report form. Does this type of project need to reapply for environmental impact assessment procedures and undergo environmental protection facility completion acceptance according to the new environmental impact assessment level?

reply:

Except for clear legal regulations and document requirements, all related work shall be carried out in accordance with the original environmental impact assessment approval requirements.

Reply to the issue of collecting several samples of low concentration particulate matter in HJ 836

incoming letter:

Regarding the quality control of HJ 836-2017 low concentration particulate matter standard sampling, it is mentioned that sample collection should ensure that the weight gain of each sample is not less than 1mg, or the sampling volume is not less than 1M3. However, the sampling site cannot guarantee the weight gain requirement, and can only require a sampling volume of not less than 1 cubic meter. In this way, one sample can be sampled at a constant flow rate of about 30L/min, and the sampling time may also take 40 minutes, or to improve representativeness, one hour value may be used for sampling. At the same time, the 836 standard mentions that the sampling steps refer to the requirements of GB/T 16157 sampling steps and quality assurance measures should comply with the requirements of HJ/T397 on-site sampling assurance measures. These two GB/T 16157 and HJ/T 397 standards mention that at least three samples should be collected for particulate matter/boiler particulate matter sampling. To implement this standard, three low concentration particulate matter samples need to be sampled, and the cumulative time required is about three hours. The sampling time cost of one exhaust gas is greatly increased, and whether one hour of low concentration sampling already has sample representativeness does not require collecting three times for averaging. If three measurements are required and the cost of sampling time needs to be reduced, larger sampling nozzles and vacuum pumps are needed for sampling instruments in the market. However, it is also based on the conditions allowed by the manufacturer's on-site conditions (uncontrollable) to shorten the sampling time as much as possible. However, compared to the previous standard sampling time, it has greatly increased, which has a significant impact on the actual sampling work.

reply:

We have received the letter regarding the issue of sampling low concentration particulate matter in HJ 836-2017. After research, the response is as follows: HJ 836 belongs to the monitoring method standard, which regulates the determination method of low concentration particulate matter in fixed pollution source exhaust gas. In actual monitoring work, the number and frequency of sample collection should also comply with the corresponding monitoring technical specifications. Therefore, according to the requirements of HJ 397, at least three samples need to be collected.

Reply to the inquiry about whether the wastewater generated during the production process of water-based paint is hazardous waste

incoming letter:

I am a company that produces water-based paints (water-based acrylic and water-based epoxy paints). During the production process, there is wastewater generated from washing tanks, and the toxic and harmful substance detection results of the wastewater do not meet the hazardous waste standards. According to the 2016 version of the hazardous waste list, HW12 dye and coating waste, under section 264-011-12, "Waste mother liquor, residue, and intermediate waste generated during the production of other inks, dyes, pigments, and paints (excluding water-based paints)", should not be classified as hazardous waste. But an expert said that if we apply 900-299-12, the content of "ineffective, deteriorated, unqualified, obsolete, and counterfeit ink, dye, pigment, and paint generated during production, sales, and use" can also be considered hazardous waste if the cylinder wall material is treated as waste paint. I would like to ask whether the washing wastewater generated during our company's production process should be treated as hazardous waste or general solid waste.

reply:

We have received your inquiry regarding whether the wastewater generated during the production process of water-based paint is hazardous waste. Regarding the questions raised in the letter, the response is as follows: If the washing wastewater generated during your company's production process meets the relevant provisions of Article 7 of the "General Rules for Identification of Solid Waste" (GB34330-2017), it can be managed as liquid waste and does not belong to solid waste; If it cannot meet the relevant provisions of Article 7 of the "General Rules for Identification Standards of Solid Waste" (GB34330-2017), it shall be managed as liquid waste and classified as solid waste. It shall be determined whether it belongs to hazardous waste according to the "National Hazardous Waste List" or the national hazardous waste identification standards and methods.