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What Standards should be Followed for Raw Materials, Emissions, Acceptance and Treatment Rates?


Time:

2022-05-23

6 common VOCs-related issues, together to understand what standards should be followed for raw materials, emissions, acceptance, and treatment rates.

Question 1: For Projects Involving VOCs Emissions, What Measures can be Adopted for Their Control Measures?

For projects involving VOCs emissions, is it forbidden to adopt single treatment measures of adsorption, low-temperature plasma, photocatalysis and photo-oxidation, in addition to the treatment of odor and odor? If not a single governance measure, is a composite governance measure feasible? For example, is it feasible to use photocatalysis + activated carbon adsorption? If not, are the governance facilities already in use and need to be replaced?

Reply Content:

According to the "Notice on Printing and Issuing" (Huanqiqi [2019] No. 53) issued by the Ministry of Ecology and Environment, the concentration technologies such as zeolite rotor adsorption, activated carbon adsorption, wind reduction and concentration increase should be used for low-concentration and high-volume exhaust gas to increase the concentration of VOCs. Post-purification treatment; high-concentration waste gas, priority is given to solvent recovery, and if it is difficult to recover, high-temperature incineration, catalytic combustion and other technologies should be used. Oil and gas (solvent) recovery should adopt technologies such as condensation + adsorption, adsorption + absorption, membrane separation + adsorption. Low-temperature plasma, photocatalysis, and photo-oxidation technologies are mainly suitable for the treatment of odor and odor; biological methods are mainly suitable for the treatment of low-concentration VOCs waste gas and the treatment of odor and odor. Water-insoluble VOCs waste gas is prohibited from being sprayed and absorbed by water or aqueous solution. If the one-time activated carbon adsorption technology is adopted, the activated carbon should be replaced regularly, and the waste activated carbon should be regenerated or disposed of. Conditional industrial parks and industrial clusters, etc., promote centralized spraying, centralized solvent recovery, centralized regeneration of activated carbon, etc., strengthen resource sharing, and improve the efficiency of VOCs treatment.

 

 

 
Question 2: Consultation on the VOCs EIA and the Content of the Approval for the Collection of High-altitude Emissions

The existing EIA and approval in 2016, the construction content is a new touch display integrated module project, which involves VOCs processes such as glue lamination, glue dispensing, baking and curing, etc. The generated VOCs are evaluated as high-altitude emissions after collection. , Now that the construction project has been completed and is ready to be put into production, may I ask, when the completion acceptance is carried out, is it to conduct self-monitoring and acceptance according to the original EIA and approval content, and then upgrade the supporting VOCs waste gas treatment facilities according to the current policy? Or should we first go to supporting VOCs waste gas treatment facilities and then carry out independent monitoring and acceptance according to the current policy?

Reply Content:

If the current policy has higher requirements for VOC waste gas treatment facilities, you can go to the facility first and then carry out independent acceptance monitoring according to the current policy.

 

 

Question 3: How to Determine that the Use of Raw and Auxiliary Materials With High VOCs Content Complies With the Situation that "the Replacement Process cannot be Implemented at this Stage"?

The "Guangdong Province 2021 Air Pollution Prevention and Control Work Plan" requires "strictly implement the national product VOCs content limit standard requirements, and prohibit the new production and use of high VOCs content raw and auxiliary materials projects, except for processes that cannot be replaced at this stage." How to determine that "it is indeed impossible to implement an alternative process at this stage"? What procedure do I need to go through?

Reply Content:

It is recommended to refer to the current practices in Dongguan. Dongguan's approach is to organize well-known experts in the industry to demonstrate the use of the process, demonstrate that it really needs to use anhydrous ethanol (with an alcohol content of more than 99%) and there is no other mature process to replace it at this stage. There are the best processes for governance. After the expert argumentation, the relevant expert opinions will be reported together with the EIA materials.

 

 

Question 4: Solvent-based Coatings, Inks and Adhesives Meet the National Product VOCs Content Limit Standards, Are They Not Included in High-VOC Raw and Auxiliary Materials?

According to the "Notice of the General Office of the People's Government of Guangdong Province on Printing and Distributing the Work Plan for the Prevention and Control of Air, Water, and Soil Pollution in Guangdong Province in 2021": "Implement the source substitution project for products with low VOCs content. Strictly implement the national product VOCs content limit standard requirements, in addition to existing In addition to the replacement process that cannot be implemented at this stage, new production and use of raw and auxiliary materials with high VOCs content are prohibited.” If the solvent-based coatings, inks, and adhesives used meet the national product VOCs content limit standards, are they not included in high VOCs? Raw and auxiliary materials, in line with the policy?

Reply Content:

Solvent-based coatings, inks, and adhesives should meet the national product VOCs content limit standard. The Ministry of Ecology and Environment's "Notice on Printing and Issuing" (Huanqiqi [2019] No. 53)" clarifies that "the process of using raw and auxiliary materials with VOCs content (mass ratio) less than 10% does not require the adoption of fugitive emission collection measures." , If the country has not specified relevant standards, materials with low VOC content can also be judged according to this.

 

 

Question 5: The Acceptance of the Waste Gas Treatment Equipment Project is Not Carried Out

The company is in the printing industry, and its main products are cartons. Among them, the volatile auxiliary materials water-based ink (0.6t/a) and white latex (0.8t/a) will be used in the production process, and the volatility coefficient is 5%, and it has passed the EIA acceptance, and no waste gas treatment equipment has been installed until the EIA acceptance. At present, the project is arranged for acceptance, and the project vocs fugitive emission standard has reached the requirements of the newly issued "Yuehuanfa (2021) No. 4". Can the project acceptance be carried out without installing waste gas treatment equipment according to the new regulations?

Reply Content:

The Ministry of Ecology and Environment's "Notice on Printing and Issuing" (Huanqiqi [2019] No. 53)" clearly states that "enterprises use coatings, inks, adhesives, etc. that comply with the national regulations on products with low VOCs content, and the emission concentration is stable and up to the standard, and the emission rate and emission performance are stable. If the relevant regulations are met, the corresponding production process may not require the construction of end treatment facilities. The process of using raw and auxiliary materials with VOCs content (mass ratio) less than 10% may not require the adoption of fugitive emission collection measures.” Please follow the relevant requirements to do a good job in the collection of fugitive emissions and end-to-end treatment. If during the construction process of your company, the production process and the use of raw materials are inconsistent with those of the EIA approval, resulting in significant changes in VOCs emissions, please follow the "Construction Project Completion Environmental Protection Acceptance Technical Guidelines for Pollution Impacts" In accordance with the requirements of the “Class”, consult the local ecological environment department in a timely manner, and perform relevant procedures in accordance with laws and regulations.

 

 

Question 6: Consultation on the Treatment Efficiency of a Certain Unit's Waste Gas Terminal Treatment Facility

In the existing UV monomer production project, in the production process, the waste gas from the reaction kettle and the distillation kettle is directed to the condenser for condensation and reflux, in which the reaction kettle and the condensate are directly refluxed to the reaction kettle, and the condensate of the distillation kettle is carried out by the water separator. The separation of solvent and organic matter, and the non-condensable gas after the condenser of the reaction kettle and distillation kettle are all treated by the process of "biological trickling filtration + activated carbon adsorption". The waste gas from the reaction kettle and distillation kettle in the UV monomer production process implements the standard limits in Table 5 of the "Petrochemical Industry Pollutant Emission Standard" (GB 31571-2015), and the removal efficiency of other organic waste gas is ≥97%. The reaction kettle of this project Is the condenser matched with the distillation still a terminal treatment facility, and can the treatment efficiency of the condenser be included in the total waste gas treatment efficiency?

Reply Content:

The condenser matching the reaction kettle and the distillation kettle is a necessary production facility for the production process of the product, not an end treatment facility for organic waste gas. The organic waste gas monitoring results of "biological trickling filtration + activated carbon adsorption" are used as the basis. Thank you for your attention and support.

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