◎ Yang Honghui
On April 17, the China Rubber Industry Association (CRIA) held the standard publicizing meeting by teleconference for the first time during the epidemic on the Technical specification for application and issuance of pollutant permit Rubber and plastic products industry (hereinafter referred to as Technical Specification).
On March 27, the Ministry of Ecology and Environment issued the Technical Specification as the Announcement No. 23 [2020], which will be implemented from the date of promulgation. According to the requirements of the Ministry of Ecology and Environment, all pollutant emission units in rubber products industry must complete the cleanup and rectification before the end of April, and complete the issuance and registration of pollutant permit before the end of September.
In the past, standard publicizing was an industry conference, where experts gave their interpretations, and participant representatives fully communicated at the meeting. However, the sudden epidemic this year blocked the form of face-to-face communication, causing difficulties to standard publicizing. In order to let rubber products enterprises better understand the content of Technical Specification and successfully complete the issuance and registration of permit, CRIA and Tianjin Eco-Environmental Science Research Institute launched the first large-scale online teleconference during the outbreak, where experts gave their interpretations online, and meeting representatives fully communicated in the message area, achieving excellent results.
At the meeting, three experts from Tianjin Academy of Environmental Sciences/National Key Laboratory of Malodor publicized the Technical Specification and relevant content. Senior Engineer Lu Zhiqiang interpreted the text of standard, and Engineer Meng Jie made a report on Analysis of Current Status and Characteristics of Pollutant Discharge in Rubber Products Industry. Xiao Xiande (Engineer) systematically explained Introduction to the Application System of Pollutant Permit for Rubber Products Industry and Key Points for Application.
Principles for Standard Setting
The Technical Specification is applicable to the implementation of Emission standard of pollutants for rubber products industry (GB 27632) and the management scope of pollutant permits for air pollutants and water pollutants from tire retreading and pollutant emission units. This standard is not applicable for reclaimed rubber manufacturing, while Technical specification for application and issuance of pollutant permit Waste resources processing industry (HJ 1034) applies.
The principles for formulating the Technical Specification are, firstly, to coordinate with existing laws, policies, and regulatory standards, secondly, to reflect the characteristics of the industry, thirdly, to classify management, and fourthly, to be applicable and practical.
For example, in connection with the characteristics of production and emission in rubber industry, identify types of waste gas and wastewater, and pollutant emission standards implemented, distinguish between main outlets and general outlets, and give methods for determining the permitted emission concentration limits and permitted emission amount, as well as requirements for unorganized emission control, comprehensive treatment of volatile organic compounds, etc., to guide the pollutant emission units of rubber products industry to fill in the application for pollutant permit, and the issuing authority to audit and determine the pollutant permit.
At this stage, the focus of control is mainly on atmospheric pollutants, that is pollutant emission of particulate matters, volatile organic compounds, and malodorous pollutants. Combined with the current usage of raw and auxiliary materials in the industry, determine the classification principles for key management and simplified management, major outlets and general outlets, and propose different management methods for key management and simplified management.
Pollution Status and Prevention Technology
It is learnt that the current status of industry pollution and control is mainly reflected in wastewater and waste gas.
The main sources of wastewater include circulating cooling water from equipment and components, concentrated water from gas boiler rooms, biological spray waste-water, etc. In addition to the above sources, daily-use and medical rubber products manufacturing enterprises also have wastewater from product cleaning and soaking, water removal process, etc. At present, the combined process of “regulating tank + coagulation sedimentation, air floatation + flocculation sedimentation + biochemical + final sedi-mentation tank” is used to remove COD, SS, Zn in waste-water, which will be discharged after reaching the takeover standard of sewage pipe network.
The waste gas is discharged mainly by regenerative thermal oxidation, regenerative catalytic oxidation, low temperature plasma, photocatalytic oxidation and other oxidative decomposition methods, as well as adsorption, absorption, membrane separation and other physico-chemical methods, and biological scrubbers, biological filtration tanks, bio-trickling filter and other biological methods. At the same time, the above multiple technologies are also used in combination. The situation of unorganized emissions in rubber products industry is relatively serious. Due to the limitations of production process characteristics, the collection of waste gas is mainly by gas-collecting hood, and the overall efficiency of waste gas collection is relatively low.
To this end, the Technical Specification gives feasible techniques for pollution prevention and control. For the pollutant emission unit that adopts the feasible technologies listed in this standard, it is considered in principle to possess pollution prevention and control facilities or pollutant treatment capacity meeting the regulations. For the pollutant emission unit that does not adopt the feasible technologies listed in this standard, it shall provide relevant certification materials (such as providing pollutant emission monitoring data within six months, feasibility demonstration materials for the technology adopted, etc.) when applying. For the prevention and control technology that is adopted for the first time at home and abroad, explanatory materials such as pilot test data should also be provided to prove that the treatment capacity equivalent to the feasible technology for pollution prevention and control is achieved. For pollution prevention technology that is not a feasible technology for pollution prevention, the pollutant emission unit shall strengthen self-monitoring and standing book records to assess the feasibility of reaching the standard. For the pollutant emission unit that implements special emission limits for waste gas and waste water, it shall fill in the feasible pollution prevention technology and management requirements by itself.
The Technical Specification sets forth specific requirements on the operation and management of pollution prevention and control technologies such as organized and unorganized emission of waste gas, wastewater emission, solid waste, groundwater and soil pollution, etc.
In addition, Senior Engineer Lu Zhiqiang also emphatically introduced the reporting requirements of basic condition for key management and simplified management of pollutant emission units, methods for determining corresponding outlets and permitted emission limits in pollutant producing and discharging links, management requirements of self-monitoring, requirements for preparing environmental management standing book records and pollutant permit execution reports, methods for compliance determination, etc.
Application of Pollutant Permit
The general principle for pollutant emission units to apply for pollutant permits is to fill in relevant information in the application system of the national pollutant permit management information platform in accordance with the requirements of Technical Specification. If not included in the reporting system, and the local competent department of ecological environment stipulates the need to apply or the pollutant emission unit believes that it is necessary to report, it may add contents on its own. Local eco-environmental authorities at the level of city divided into districts and above may, according to local laws and regulations on environmental protection, increase the content that needs to be stated in the pollutant permit. For the pollutant emission units that have not obtained the approval opinions for the environmental impact assessment of construction projects in accordance with the law, or have not obtained the relevant certification materials on lawful treatment and rectification issued by the local government in accordance with relevant state regulations, and units that have adopted pollution prevention facilities or measures that fail to meet the permitted emission concentration requirements, as well as other pollutant emission units that need corrective actions in accordance with regulations, when first applying for a pollutant permit and filling in application information, they shall fill in the content that need to be corrected, correction measures, and time limit requirements in the applying system of the management information platform.
Xiao Xiande detailedly introduced the applying process in application system of the national pollutant permit management information platform, and summarized the points where mistakes are easy to be made.
In the message and discussion area of the meeting, the participant representatives also discussed issues such as how to determine the key management and simplified management, how to sample, analyze and report the toxic components and proportion of raw and auxiliary materials, the requirements and conditions of key outlets, online monitoring and installation, etc.
Xu Wenying, vice president and secretary general of CRIA, as well as the secretary generals of various branches of the association, and nearly 300 representatives from industry-related enterprises participated in the meeting. Zhu Hong, deputy secretary-general and director of the Technology and Economic Committee of CRIA, presided over the meeting.
