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What do you need to do to apply for pollutant discharge permit and follow-up work?Take you through this article

来源:Shenlong Environmental Protection      Release time:2022-05-16       Number of readings:

Analysis of the new regulations for enterprises to apply for emission permits in 2022


Technical specification for Application and Issuance of emission Permit Industrial Solid Waste (Trial)The official implementation has also changed many aspects of the previous emission permit application, so what problems do solid waste discharge units need to pay attention to?
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Concern 1: Does the discharge permit of the waste producing unit need to be renewed immediately within the validity period?





After the implementation of the new regulations, some waste production units may have questions: "Enterprises now have a pollution permit, still within the validity period, need to immediately replace it??”
You don't have to worry, the "certificate" already in hand in this case is completely legal and effective。Recently issued by the Ministry of Ecology and EnvironmentNotice on the Administration of Industrial Solid Waste discharge permits(EIA (2021) No. 26) clearly requires,In order not to increase the burden on enterprises, after the implementation of the new regulations, it is not mandatory to apply for changes and replacements immediately。When the discharge permit of the production and waste unit expires and needs to be extended, or when it needs to apply for a change due to other reasons, it shall apply for a new certificate again。
By the end of September last year, the country had issued 34.70,000 permits to pollute。According to this calculation, 280,000 emission permits will expire and should be renewed by the end of 2023。Then by the end of 2023, at least 80.More than 7% of pollutant discharge units have incorporated the content of industrial solid waste management into their pollutant discharge permits。Need to remind, before the production and waste units to apply for a pollutant discharge permitMake a "physical examination" against the "solid waste Technical Specifications" and find that the problems that do not meet the specifications should be rectified。Do not fill in the declaration "all at once", otherwise it is difficult to pass the application。After rectification and compliance with the relevant requirements of the "Solid Waste Technical Specifications", the waste production unit can log in the enterprise side of the national emission permit management information platform and submit the application materials for industrial solid waste emission permit。The materials include basic information of industrial solid waste, information of self-storage, utilization and disposal facilities, information of ledger records and execution reports, and technical requirements for pollution prevention and control of industrial solid waste。If the above materials are in line with the specifications, you can wait for the good news。

Focus 2: How to do the accounts and execution reports of the production and waste units?





At present, the most "stuck neck" place of solid waste supervision is that the bottom number is not clear, which has increased the difficulty of relevant pollution control tasks。How do we figure it out?This time, the industrial solid waste is included in the management of pollutant discharge permits, the implementation of the requirements of article 36 of the new solid waste Law, and the pioneering proposal: the requirements of the general industrial solid waste ledger are also written into the pollutant discharge permits!In this way, let the production and waste units do a good job of accounting records, through checking the accounting records, you can find out what the specific production and waste information of each enterprise is, and where these industrial solid waste "go".?The "closed-loop evidence chain" is formed through the "information flow" to realize the traceability and query of industrial solid waste。Therefore, once a waste producing unit has obtained a discharge permit, it cannot "put it on the shelf", not use it or throw it aside。The environmental management ledger should be used to record the type, quantity, flow direction, storage, utilization, disposal and other information of industrial solid waste, among which each batch of solid waste should be marked。In the past, the requirements for general industrial solid waste accounts were not clear and uniform enough, and the new regulations set out to "break through" this issue and clarify the new requirements。The specific requirements are recorded in accordance with the provisions of the Guidelines for the Formulation of General Industrial Solid Waste Management Ledger (Trial)。
Hazardous waste has always been the focus of government control, management is relatively strict, there was a relatively complete system in the past。At present, all production and waste units still have to comply with the previous"Guidelines for the development of management plans for hazardous waste generating unitsThe requirements of the ledger are recorded。The new version of the "Technical specifications for the development of Environmental Management plans and accounts for Hazardous waste production units" has been completed for public consultation, and the "new version" will be the main one after its release。In addition to the ledger, another core implementation of corporate responsibility system is the executive report。Enterprises have the obligation to report the implementation and operation of solid waste pollution prevention and control measures to the ecological environment department。In the report on the implementation of the discharge permit, basic information and the production and discharge links, industrial solid waste and changes in storage, utilization and disposal facilities shall be submitted。If the storage, utilization, and disposal of solid waste exceed the scope of capacity, beyond the scope of types, or there are problems such as extended storage, it is necessary to report to the environmental protection department in a timely manner and explain the reasons。

Focus 3: Focus on the production and waste units!Do a good job of storage, utilization, disposal and other key links!





What is the difference between the management of industrial solid waste discharge permits and that of water and gas discharge permits?Understanding this problem can help waste production units to grasp the key links of industrial solid waste discharge permit management。
Industrial solid waste does not have the concept of discharge, according to the law, industrial solid waste is not allowed to discharge。From the previous pilot experience, the change of solid waste generation fluctuates greatly, and it is difficult to use the authoritative production coefficient to "assess", so the essence of solid waste management is a dynamic supervision of the whole process。In the management of water and gas emission permits, the control of "sewage outlet" is the "top priority", but if industrial solid waste is not allowed to be discharged, how should it be controlled?Experts say,"To incorporate industrial solid waste into the emission permit management, it is necessary to highlight the whole process supervision characteristics of solid waste management.。Among them, the production and waste units' own storage, utilization and disposal facilities are the most critical links。”Therefore, these facilities can be regarded as solid waste "sewage outlet", to carry out key control。On this basis, the technical requirements of pollution prevention and control in the production and operation period of waste production units are put forward, and the management boundaries are divided。It can be said that these facilities are not only the "starting point" of the future examination and approval units, but also the most important part of the future enterprises to apply for emission permits。When a waste producing unit applies for a pollutant discharge permit, it shall report two key points。One is basic information on the production of industrial solid waste。Including name, category, physical or hazardous characteristics, production process and destination (storage, use, disposal or entrusted to others);The other is the name, capacity and technical requirements for pollution prevention and control of self-storage, utilization and disposal facilities。

03

What should an enterprise do after obtaining a pollutant discharge permit


In order to facilitate the discharge units to know the various work that should be carried out after obtaining the discharge permit, the key matters of post-certification management are sorted out as follows for reference。


Carefully check discharge permits



After the pollutant discharge unit obtains the pollutant discharge permit, it must first carefully compare the contents recorded in the pollutant discharge permit, and verify the consistency of the content contained in the pollutant discharge permit with the EIA document, the business permit, the enterprise site, and the technical specifications。In particular, the pollutant discharge units entrusted with the tripartite agencies to fill in the report must be carefully verified item by item to ensure that the pollutant discharge permit is consistent with the actual production situation of the enterprise。


Hang the original discharge permit



A pollutant discharge unit shall hang the original of the pollutant discharge permit in a place convenient for public supervision in the place of production and business operation。


Keep good books



The pollutant discharging unit shall record according to the record information required in the account recording in the pollutant discharge permit。The records are recorded in electronic ledger and paper ledger。The storage period shall not be less than 3 years (the hazardous waste business unit shall keep the ledger records for more than 10 years, and the ledger records for disposing of hazardous waste by landfill shall be permanently preserved)。Specific in the emission permit "Environmental management requirements - Environmental management ledger record requirements" check。

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The account record template can be downloaded from the national pollutant discharge permit management information platform enterprise side account record module。The completed electronic account can be uploaded in this module。


Conduct self-monitoring



The pollutant discharging unit shall carry out self-monitoring according to the monitoring content and frequency determined in the "self-monitoring requirements" in the pollutant discharge permit。Specific in the emission permit "Environmental management requirements - self-monitoring requirements" view。

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Pollutant discharge units that carry out self-monitoring can be disclosed in the monitoring record block of the enterprise side of the national pollutant discharge Permit management information platform。


Submit execution report on time



The pollutant discharging unit shall, in accordance with the requirements of the copy of the pollutant discharge permit on the content and frequency of the implementation report, prepare the report on the implementation of the pollutant discharge permit。The executive report is divided into annual report and quarterly report。Units under key management of pollutant discharge shall prepare annual reports and quarterly reports;Pollutants-discharging units with simplified management are required to prepare annual reports。See "Environmental Management Requirements - Enforcement (compliance) reporting Requirements" for the emission permit。

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The preparation of the implementation report can be directly added to the annual report or quarterly report in the implementation report module of the enterprise side of the National emission Permit Management information platform, fill in the relevant content, submit and disclose。The quarterly executive report is submitted within 15 days after the end of the quarter;The annual implementation report is submitted by the end of January of the following year。At the same time, a written implementation report printed through the national emission Permit Management information Platform is submitted to the department of ecology and environment。The written implementation report shall be signed or sealed by the legal representative or the principal responsible person。


Do a good job of information disclosure



The national emission permit information disclosure system or other means that are convenient for the public to know the information disclosure in accordance with the relevant provisions of the "Measures for the Disclosure of Information of Enterprises and Institutions" and the "Measures for the Administration of Emission Permits (Trial)"。Information disclosure mainly includes:

1.Basic information, including the name of the unit, organization code, legal representative, production address, contact information, as well as the main content, products and scale of production, operation and management services;2.Pollutant discharge information, including the names of major pollutants and characteristic pollutants, discharge methods, number and distribution of discharge outlets, discharge concentration and total amount, exceedance of standards, as well as the discharge standards implemented and the total amount approved;

3.The construction and operation of pollution control facilities;

4.Environmental impact assessment of construction projects and other administrative permits for environmental protection;

5.Emergency plan for environmental emergencies;

6.Relevant contents in the quarterly and annual emission permit implementation report;

7.Other environmental information that should be disclosed。


Source: From the Internet