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Q & a list - how to prepare the local work plan for comprehensive treatment of volatile organic compounds in key industries

Q & a list - how to prepare the local work plan for comprehensive treatment of volatile organic compounds in key industries?, Coating,

Q & a list - how to prepare the local work plan for comprehensive treatment of volatile organic compounds in key industries

december 21, 2020

comprehensive treatment plan for volatile organic compounds in key industries

1 The document on comprehensive control of VOCs in key industries in Jiangxi Province requires all districts and cities to prepare the local work plan for comprehensive control of volatile organic compounds in key industries in combination with local air quality improvement objectives and industry characteristics. The plan is highly professional. How does the city formulate it

answer: according to the comprehensive treatment plan for volatile organic compounds in key industries issued by the Ministry of ecological environment and the provincial department, a VOCs treatment plan that conforms to the category and scale of local industries can be formulated. According to the information system of volatile organic compounds in key industries of Jiangxi Province, the results of source list and the statistical data of second pollution popularization, all cities can sort out the VOCs emissions of key industries in the region, from the petrochemical industry, pharmaceutical, pesticide, coating, ink, adhesive, rubber and plastic products and other chemical industries, automobile, furniture, container, electronic products, engineering machinery and other industrial coating industries, plastic flexible packaging and printing Among the national key industries such as packaging and printing industries such as iron printing and can making, and oil storage, transportation and marketing, select the key regulated industries in the region, and formulate targeted treatment plans. Regions with conditions are encouraged to select key VOCs regulated industries and regional coatings according to the results of local source analysis and source list

2. The document sent the residual samples of the tested samples through the escort belt, requiring 44 provincial key enterprises to take the lead in carrying out "one enterprise, one policy" and LDAR. What are the specific requirements? Is there a fixed format like cleaner production audit? When is the "one enterprise one policy" required to be formulated? Enterprises organize their own VOCs "one enterprise, one policy" review. Is it just the enterprise's own internal review, or does it need to organize experts to review? Does the management of the ecological environment department need to participate in the review meeting? After the enterprise submits the remediation materials, the ecological environment department should organize the verification and review of the enterprise. Has the province established an expert database on VOCs

answer: "one enterprise and one policy" can be formulated according to Annex 4 technical guide for review and implementation effect verification of comprehensive treatment scheme of VOCs key enterprises in Jiangxi Province and other annexes. It is required that the "one enterprise and one policy" treatment scheme of key enterprises should fully cover the replacement of raw and auxiliary materials, unorganized collection, organized waste gas treatment, etc., and be rectified by the end of 2020. "One enterprise and one policy" has no fixed format and can be prepared by the enterprise itself. However, due to its strong professionalism, it is recommended that the enterprise hire a third-party professional team to prepare it and assist the monitoring means to obtain the measured data. "One enterprise and one policy" shall be reviewed by the enterprise itself, but the review process shall be attended by the management personnel of the local ecological environment department, and experts in VOCs governance inside and outside the province shall be designated for review. The review and implementation effect verification results of key enterprises at the municipal level shall be submitted to the ecological environment bureau of each city divided into districts for review and filing. Key enterprises at the provincial level shall be submitted to the Provincial Department of ecological environment for review and filing. The Provincial Department of ecological environment will spot check and sample key enterprises and demonstration enterprises at the municipal level to evaluate the implementation effect

3. How to determine the municipal key enterprises? Is there a unified principle

answer: enterprises involved in national key industries such as petrochemical, chemical, industrial coating, packaging and printing can be selected according to the information system of volatile organic compounds in key industries in Jiangxi Province, the results of source list and the statistical data of second pollution. They can be sorted according to the production and emission of VOCs. Priority should be given to enterprises with large emissions, many residents' complaints or large environmental impact of characteristic pollutants

4. Is there a clear definition of low VOCs raw and auxiliary materials? What kind of raw and auxiliary materials belong to low VOCs raw and auxiliary materials? How should the management personnel of the ecological environment department judge whether the raw and auxiliary materials used by the enterprise belong to low VOCs raw and auxiliary materials

answer: according to the requirements of the comprehensive treatment plan for volatile organic compounds in key industries issued by the Ministry of ecological environment and the Provincial Department "Water based, powder, high solid, solvent-free, radiation curing and other low VOCs content coatings, water-based, radiation curing, plant-based and other low VOCs content inks, water-based, hot-melt, solvent-free, radiation curing, modified, biodegradable and other low VOCs content adhesives, as well as low VOCs content and low reactivity cleaning agents, can replace solvent-based coatings, inks, adhesives and cleaning agents", Low VOCs raw and auxiliary materials can be understood as water-based, powder, high solid and other raw and auxiliary materials mentioned above; According to the requirements in the control standard for fugitive emission of volatile organic compounds (GB), low VOCs raw and auxiliary materials can be understood as the mass proportion of VOCs < 10%2 Accepted products containing VOCs; At the same time, it can be distinguished by referring to the quality standards of raw and auxiliary materials such as the limit of toxic substances in Waterborne Wood Coatings for interior decoration materials (GB) and the limit of harmful substances in adhesives for interior decoration materials (GB)

5. The document requires that by the end of 2020, the replacement of low VOCs raw and auxiliary materials in surface coating enterprises should reach more than 20%, and that in organic chemical enterprises should reach more than 10%. This proportion refers to the proportion of the number of enterprises? Or the proportion of raw and auxiliary materials? Or does it mean the proportion of raw and auxiliary materials used

answer: the replacement of low VOCs raw materials in the surface coating industry and the organic chemical industry, especially the rapid economic growth of developing countries such as China and India, should be understood as the reduction of VOCs raw and auxiliary materials, VOCs quality content or high reactivity raw and auxiliary materials. The surface coating industry should use powder, water-based, high solid, radiation curing and other low VOCs content coatings to replace solvent based coatings; The chemical industry uses non-toxic and low toxic raw materials or wastes generated in the production process to replace highly toxic or seriously polluting raw materials, such as non halogenated and non aromatic solvents (ethyl acetate, ethanol, acetone, etc.) to replace toxic solvents (benzene, chloroform, trichloroethylene, etc.), and promotes water-based preparations. The raw and auxiliary materials of VOCs with low reactivity can be replaced by the key controlled VOCs in the table below

category

VOCs under key control

o3 precursors

M/p-xylene, ethylene, propylene, formaldehyde, toluene, acetaldehyde, 1,3-butadiene, trimethylbenzene, o-xylene, styrene, etc.

pm2.5 precursors

toluene, n-dodecane, M/p-xylene, styrene, n-undecane, n-decane, ethylbenzene, o-xylene, 1,3-butadiene, methylcyclohexane N-nonane and other odor substances

methylamine, methyl mercaptan, methyl sulfide, dimethyl disulfide, carbon disulfide, styrene, cumene, phenol, acrylate and other highly toxic substances

benzene, formaldehyde, vinyl chloride, trichloroethylene, acrylonitrile, acrylamide, ethylene oxide, 1,2-dichloroethane, isocyanate, etc.

6 Is there a fixed format for the enterprise's raw and auxiliary material substitution scheme? Need expert review? If the enterprise uses a single raw material, how to replace it? Does the replacement of raw and auxiliary materials require environmental assessment

answer: the need for EIA changes after the replacement of raw and auxiliary materials can be defined in accordance with the notice on printing and distributing the list of major changes in construction projects of different industries in Central China under EIA Management (HB [2015] No. 52) and the notice on printing and distributing the list of major changes in construction projects of 14 industries including pulp and paper making (HB [2018] No. 6). If they are major changes, they need to be re assessed, However, the use of water-based coatings instead of solvent based coatings, and the replacement of raw and auxiliary materials does not lead to new pollutants or increase in pollutant emissions can be recognized as non significant changes. If the production process of a chemical enterprise is a one-step process or other simple process, and it is difficult to replace the raw and auxiliary materials, the enterprise shall provide written instructions and supporting materials. The supporting materials shall include the name of VOCs raw and auxiliary materials and their VOCs content, environmental assessment report, acceptance report and the third-party waste gas detection report of the previous year. The raw and auxiliary materials replacement requirements can be exempted after being reported to the local ecological environment department for filing

7. According to the document, on the premise that all industries meet the VOCs emission standards, if the enterprises adopt products that meet the relevant national regulations on low VOCs content, the emission concentration is stable and up to standard, and the emission rate and treatment efficiency meet the relevant regulations, the corresponding production processes may not require the construction of terminal treatment facilities. What do these "relevant provisions" and "relevant provisions" specifically refer to

answer: first, products with low VOCs content should meet the quality standards for raw and auxiliary materials such as the limit of toxic substances in Waterborne Wood Coatings for interior decoration materials (GB) and the limit of harmful substances in adhesives for interior decoration materials (GB); In addition, it can be defined according to the expression in the control standard for fugitive emission of volatile organic compounds (GB), such as "the use process of products containing VOCs with a mass ratio of VOCs ≥ 10% shall be carried out with closed equipment or closed operation...", "The emission of collected pollutants shall comply with the limits of GB 16297 or relevant industrial emission standards. When the initial emission rate of non methane total hydrocarbons in the waste gas is ≥ 3kg/h, VOCs treatment facilities shall be equipped, and the treatment efficiency shall not be less than 80%"

8. By the end of 2020, the coverage rate of collection equipment will reach 100%, which refers to the collection equipment of five types of emission sources, such as storage, transfer and transportation, equipment and pipeline component leakage, open liquid level overflow and process

answer: Based on the principle of "collecting all accounts receivable and collecting by quality", five kinds of emission sources including the storage, transfer and transportation of VOCs containing materials (including VOCs containing raw and auxiliary materials, VOCs containing products, VOCs containing wastes and organic polymer materials), leakage of equipment and pipeline components, escape of open liquid level and process are controlled through sealing of equipment and places, process improvement Exhaust gas is used to detect the welding strength and peel strength of aluminum alloy, which is the material of the door. Effective collection and other measures are taken to reduce the unorganized emission of VOCs. The coverage rate of collection equipment reaches 100%, which can be understood as: on the premise of ensuring safety and not affecting normal production, all the above unorganized processes that may produce VOCs should be sealed or collected

9. Can the leakage detection and repair (LDAR) enterprise carry out it by itself? Or does it have to be carried out by a qualified third party? What are the requirements for LDAR frequency

answer: LDAR can be carried out by the enterprise itself, but the enterprise should have the testing ability required by the LDAR specification. It can also be carried out by a third-party testing agency. The frequency requirements can refer to the control standard for fugitive emission of volatile organic compounds (GB). Petrochemical enterprises should implement the industrial standards

10. According to the plan, the chemical industry park shall complete the construction of monitoring points for ambient air and unorganized VOCs at the plant boundary by the end of 2020, and build a monitoring, early warning and monitoring platform. How to define chemical industry parks? Can it be understood as the Industrial Park listed in Schedule 3

answer: the plan requires that 16 provincial key parks should build monitoring points and monitoring and early warning platforms for ambient air and unorganized VOCs at the plant boundary by the end of 2020. In addition, other chemical parks are encouraged to build sophisticated traceability control platforms (including ambient air, unorganized VOCs monitoring points within the plant boundary, quantitative traceability, diffusion prediction, etc.). Chemical parks can be understood as: after consulting the recent chemical parks and chemical enterprise troubleshooting accounts of the provincial industry and information technology department, there are 54 chemical parks in the province, including chemical parks (including industrial parks) approved by the provincial government, the provincial development and Reform Commission and the Department of industry and information technology

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