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◉ Introduction to Online Monitoring and Comparison
Online monitoring device comparison verification refers to the service of evaluating the performance and verifying the accuracy of data of various online monitoring equipment through third-party testing institutions. Using manual monitoring as a reference method, the monitoring behavior of verifying the accuracy and effectiveness of pollutant automatic monitoring equipment monitoring results ensures that the monitoring device can provide reliable and accurate data in actual operation, meeting regulatory requirements in environmental pro
◉ Introduction to Emergency Response Plan for Sudden Environmental Incidents
The emergency plan for sudden environmental incidents refers to the work plan formulated by enterprises in advance in order to take emergency measures to avoid or minimize the entry of pollutants or other toxic and harmful substances into environmental media such as the atmosphere, water bodies, and soil outside the factory boundary in response to various accidents and natural disasters.
According to the "Management Measures for the Filing of Emergency Plans for Sudden Environmental Incidents in Enterprises and Institutions (Trial)", "Guidelines for the Review of Emergency Plans for Sudden Environmental Incidents in Enterprises and Institutions", and "Management Measures for Emergency Plans for Sudden Environmental Incidents in Jiangsu Province (Suhuanfa [2023] No. 7)", enterprises and institutions shall formulate emergency plans for sudden environmental incidents in accordance with relevant national regulations and report them to the competent environmental protection department and relevant departments for filing.
◉ What enterprises or units need to prepare emergency plans for sudden environmental incidents
Article 85 of the Solid Waste Pollution Prevention and Control Law of the People's Republic of China: Units that generate, collect, store, transport, utilize, and dispose of hazardous waste shall formulate preventive measures and emergency plans for accidents in accordance with the law, and file them with the local ecological environment department and other departments responsible for the supervision and management of solid waste pollution prevention and control; The ecological environment management department and other departments responsible for supervising and managing the prevention and control of solid waste pollution should conduct inspections.
Article 77 of the Water Pollution Prevention and Control Law of the People's Republic of China: Enterprises and institutions that may experience water pollution accidents shall formulate emergency plans related to water pollution accidents, make emergency preparations, and conduct regular drills.
Article 3 of the "Management Measures for the Filing of Emergency Plans for Sudden Environmental Incidents in Enterprises and Institutions (Trial)": The environmental protection department shall apply these measures to the guidance and management of the filing of environmental emergency plans for the following enterprises: (1) Pollutant discharge enterprises that may experience sudden environmental incidents, including operating enterprises of centralized sewage and household waste treatment facilities; （2） Enterprises engaged in the production, storage, transportation, and use of hazardous chemicals; （3） Enterprises that generate, collect, store, transport, utilize, and dispose of hazardous waste; （4） Tailings pond enterprises, including wet storage industrial waste storage and power plant ash storage enterprises; （5） Other enterprises that should be included in the scope of application.
In addition, the competent departments of each district and city will release an annual list of enterprises that should be registered for environmental emergency plans every year. Enterprises should pay attention to it in real time. In addition, if the environmental impact assessment documents explicitly require the preparation of emergency plans for sudden environmental incidents, plans should also be prepared.
◉ When should the emergency plan for sudden environmental incidents be prepared?
According to Article 17 of the "Notice on Issuing the Management Measures for Filing of Emergency Plans for Sudden Environmental Incidents in Enterprises and Institutions (Trial)" (Huan Fa [2015] No. 4), the environmental emergency plan formulated by the construction unit or the revised enterprise environmental emergency plan shall be filed with the local acceptance department in accordance with the requirements of Article 15 of these Measures before the construction project is put into production or use.
Therefore, the emergency plan for sudden environmental incidents should be implemented after the environmental impact assessment (for projects that require environmental impact assessment procedures) and before the completion of environmental protection acceptance. If the enterprise has a trial production stage, the content of the trial production includes debugging activities, and the preparation of the environmental emergency plan should be completed before the trial production.
◉ Does the project implementation entity (enterprise) change, and does the emergency plan for sudden environmental incidents need to be recompiled and filed?
According to Article 8 of the "Notice on Issuing the Management Measures for Filing of Emergency Plans for Sudden Environmental Incidents in Enterprises and Institutions (Trial)" (Huan Fa [2015] No. 4), enterprises are the responsible parties for formulating environmental emergency plans. Based on the needs of responding to sudden environmental incidents, they carry out the work of formulating environmental emergency plans and are responsible for the authenticity and operability of the content of the environmental emergency plans. Article 12: In any of the following circumstances, timely revisions shall be made: (1) If there is a significant change in the environmental risk faced and a new environmental risk assessment is required; （2） Significant changes have occurred in the command system and responsibilities of emergency management organizations; （3） Significant changes have occurred in the environmental emergency monitoring, warning, and reporting mechanisms, response processes and measures, and emergency support measures; （4） Significant changes have occurred in important emergency resources; （5） Discovering problems during actual emergency response and emergency drills that require significant adjustments to the environmental emergency plan; （6） Other situations that require revision.
Therefore, after the change of project subject (enterprise), the emergency management organization and command system and responsibilities of the enterprise have undergone significant changes. Therefore, the emergency plan for sudden environmental incidents should be revised in a timely manner and re filed.
◉ Does the company need to organize a review every three years when revising its environmental emergency plan?
Article 36 of Chapter 6 of the "Management Measures for Emergency Plans for Sudden Incidents" (State Council Document [2024] No. 5) stipulates that "if the revision of emergency plans involves important contents such as organizational command system and responsibilities, emergency response procedures, main response measures, and grading standards for sudden incidents, the revision work should be organized in accordance with the procedures for plan preparation, approval, filing, and publication stipulated in these Measures. If it only involves other contents, the revision procedures may be appropriately simplified according to the situation; Article 18 of the "Management Measures for the Filing of Emergency Plans for Sudden Environmental Incidents in Enterprises and Institutions (Trial)" (Huan Fa [2015] No. 4) stipulates that "if there are significant revisions to the enterprise's environmental emergency plan, it shall be changed and filed with the original receiving department within 20 working days from the date of publication. The change and filing shall be handled in accordance with the requirements of Article 15 of these Measures. If there are individual adjustments to the environmental emergency plan that need to be notified to the environmental protection department, the original receiving department shall be notified in document form within 20 working days from the date of publication; The Guidelines for the Review of Emergency Plans for Sudden Environmental Incidents in Enterprises and Institutions (Environmental Emergency [2018] No. 8) specify that the review object is the environmental emergency plan and its related documents, including the environmental emergency plan and its preparation instructions, environmental risk assessment reports, environmental emergency resource investigation reports (forms), and other texts.
From the above laws, regulations, and other documents, it can be seen that the situation of "major revisions" has been clearly defined in the "Management Measures for Emergency Plans for Emergencies", and the evaluation object of emergency plans for environmental emergencies in enterprises and institutions is the environmental emergency plan and its related documents, including environmental emergency plans and their preparation instructions, environmental risk assessment reports, environmental emergency resource investigation reports (tables), and other texts. If there are significant revisions to the contingency plan, four reports must be prepared and filed after expert review; If there are no major revisions and only a few contents have been adjusted recently, an expert review meeting may not be held, and they can be directly filed after compilation.
However, if the local competent department requires the organization of a review, it must be conducted in accordance with the requirements of the local competent department. (Reminder: Pay attention to personalized requirements in some places, such as the new emergency plan filing management requirements issued by Jiangsu, Hebei, Yunnan, and Hunan in recent years.)
◉ Regarding the issue of accident emergency pool in the "Emergency Plan for Sudden Environmental Incidents in Enterprises"
At present, the normative documents related to accident emergency pools mainly include the Technical Guidelines for Environmental Risk Assessment of Construction Projects (HJ169-2018), the Design Specification for Environmental Protection of Chemical Construction Projects (GB50483-2019), and the Technical Requirements for Water Environment Risk Prevention and Control of Petrochemical Enterprises (Q/SH 0729-2018). In practice, some enterprises use cofferdams, fire embankments, drainage facilities, etc. to temporarily store accident wastewater after accidents occur, which can effectively control the accident wastewater from entering the external environment. For general enterprises, there are no specific guidance documents. In addition, when the project environmental impact assessment report requires an accident emergency pool, the accident emergency pool should be constructed according to the relevant requirements.
◉ Does it necessarily require a senior professional title for the qualification of emergency plan review experts? Is it necessary to have experts from the emergency expert database of provincial departments and prefecture level cities?
The most clear regulations on the qualification of emergency plan review experts are in the "Guidelines for the Review of Emergency Plans for Sudden Environmental Incidents in Enterprises and Institutions (Trial)" (Environmental Office Emergency [2018] No. 8):
4.3 Reviewers
The number of reviewers and their number shall be determined by the enterprise itself.
The reviewers generally include experts with relevant professional knowledge and practical experience in the field, as well as representatives of residents and units who may be affected. Among them, the review experts can be selected from the expert database of regulatory authorities, the internal expert database of enterprises, relevant industry associations, personnel with environmental protection and emergency management knowledge and experience in the same industry or surrounding enterprises. Those who have a vested interest in the enterprise should generally be avoided.
The number of reviewers should generally be no less than 5 for enterprises with a high risk of sudden environmental incidents, and no less than 3 for enterprises with general environmental risks; Among them, there shall be no less than 3 evaluation experts for enterprises with significant or higher environmental risks, and no less than 2 representatives of residents and units who may be affected. ”
There is currently no clear requirement from the Ministry of Ecology and Environment or the provincial department regarding the professional titles of evaluators. But at the same time, if the local competent department has specific regulations (generally including provincial and municipal warehouses), they should follow their regulations.
◉ Can different enterprises jointly develop emergency plans for sudden environmental incidents?
This situation is more common in "factories within factories" (rental enterprises and leasing enterprises), or enterprises that share public auxiliary facilities. For cost saving considerations, enterprises involved in this situation can jointly prepare environmental emergency plans and file them separately. However, it should be noted that when jointly preparing environmental emergency plans, different enterprise entities need to conduct environmental risk assessments and level judgments separately, clarify typical sudden environmental event scenarios, and propose comprehensive environmental risk prevention and control measures and incident response and disposal measures. Report the jointly prepared environmental emergency plan to the local ecological environment department. At the same time as submitting the filing materials, different enterprise entities should provide written explanations of their own environmental risk level, typical sudden environmental event scenarios, environmental risk prevention and control, and incident response measures in the same plan text.
◉ Will the emergency plan be punished if it is not retrospectively evaluated and re filed after more than 3 years of filing?
meeting! The enterprise's environmental emergency plan has been filed for more than 3 years without retrospective evaluation and re filing, which can be identified as the situation of "(3) failure to file the emergency plan for sudden environmental incidents in accordance with regulations" in Article 38 of the Emergency Management Measures for Sudden Environmental Incidents. The environmental protection department at or above the county level may order correction and impose a fine of not less than 10000 yuan but not more than 30000 yuan.
◉ Compliance Services
The laboratory is built and managed strictly in accordance with standards, equipped with advanced instruments and equipment, and has a professional technical team with superb skills. It has rich industry service experience and strong testing technology capabilities. Based on the principles of objectivity and fairness, it provides authoritative testing reports with legal effect to the society, and provides full chain environmental risk management support for enterprises and regulatory departments. Welcome to contact us at 400-9269-886!
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