Answer from the provincial department: whether the RTO emergency evacuation pipeline needs to be equipped with VOCs online monitoring facilities

Recently, Jiangsu Provincial Department of Ecology and Environment has made a reply to the online question about whether the RTO emergency evacuation pipeline needs to be equipped with VOCs online monitoring facilities. This article has compiled it into one article for your reference.
Q: Does the RTO emergency evacuation pipeline need to be equipped with VOCS online monitoring facilities?
According to 4.3.2.3 in the Notice of the Provincial Emergency Management Department and the Provincial Ecological Environment Department on Printing and Distributing the Safety Technical Requirements for the Regenerative Incinerator (RTO Furnace) System (Su Emergency [2021] No. 46), the emergency evacuation pipeline with high concentration or containing low ignition point substances shall be set independently, and it is strictly prohibited to share the chimney with the high-temperature evacuation pipeline for emission. Is it necessary to install VOCS online monitoring facilities on the emergency evacuation pipeline?
Jiangsu Provincial Department of Ecological Environment A:
Hello, your message has been received. Thank you very much for your attention to ecological environment protection. According to your message, after research, we reply as follows:
The emergency evacuation pipeline is opened under extreme circumstances, and online monitoring facilities do not need to be installed.
Q: Is it necessary to install cooling measures for activated carbon
As specified in 6.5.4 of the Technical Code for Treatment of Industrial Organic Waste Gas by Adsorption Method (HJ2026-2013), the temperature in the device shall be lower than 83 ℃, and when the temperature exceeds, it shall be able to automatically alarm and start the cooling device. The temperature of our organic waste gas is normal temperature, and the back end of the activated carbon adsorption device is directly connected to the exhaust funnel for emission. In this case, please ask whether it is necessary to install alarm and cooling devices according to the requirements of the specification. Thank you.
Jiangsu Provincial Department of Ecological Environment A:
Hello, the alarm and cooling devices should be installed according to the requirements of the specification.
Q: Is it necessary to convert particulate matter and non methane total hydrocarbon in synthetic resin enterprises?
Our company belongs to the synthetic resin industry and implements the Emission Standard of Pollutants for the Synthetic Resin Industry (GB31572-2015). The measured emission concentration of air pollutants at the emission outlet of organic waste gas from incineration in 5.1.5 of this standard must be converted into the standard emission concentration of air pollutants with a reference oxygen content of 3%, and compared with the emission limit to determine whether the emission is up to standard. Do you need to convert the following pollutants: sulfur dioxide, nitrogen oxides, particulate matter and non methane hydrocarbon?
Jiangsu Provincial Department of Ecological Environment A:
The questions are mainly about the application of the reference oxygen content in the standard. According to the definition of Technical Guidelines for the Formulation of National Emission Standards for Air Pollutants (HJ945.1-2018), "reference oxygen content" refers to "the reference value of oxygen content specified for converting the emission concentration of air pollutants from combustion sources." According to the requirements of 5.1.5 of Emission Standards for Synthetic Resin Industrial Pollution Sources (GB31572-2015), All pollutants discharged from the "incineration type organic waste gas outlet" specified in the EIA approval or emission permit shall be converted into the standard emission concentration of atmospheric pollutants with a reference oxygen content of 3% according to the standard, and the emission limit shall be compared to determine whether the emission is up to the standard.
Q: What kind of VOCs online monitoring facilities are installed?
Hello, leaders of Provincial Department of Ecology and Environment, our company is an enterprise producing rubber products. The environmental assessment and pollution discharge permit show that our company discharges volatile organic compounds, and we are also a key pollutant discharging unit. There are three exhaust outlets in total, and the exhaust emission of one exhaust outlet is more than 30000 m3/h. As required, we should install VOCs online monitoring facilities, but we encountered some problems.
1. How should our company choose VOCs online monitoring facilities. The pollution discharge permit shows that the self monitoring indicator is "volatile organic compounds", and the allowable concentration limit is 10mg/m ³。 Can we install online monitoring facilities for TVOCs? Or according to the measurement of non methane hydrocarbon? If non methane hydrocarbon is installed, the monitoring factors are inconsistent with our pollution discharge permit.
2. Our company is a key pollutant discharge unit with three outlets, but only one outlet is larger than 30000 cubic meters. Whether it is possible to install online monitoring facilities only at outlets larger than 30000 cubic meters, and not at other outlets.
Jiangsu Provincial Department of Ecological Environment A:
Hello, your message has been received. Thank you very much for your attention to ecological environment protection. According to your message, after research, the reply is as follows: According to the fourth paragraph of Article 9 of the Measures for the Administration of Automatic Monitoring of Pollution Sources in Jiangsu Province (for Trial Implementation) (Su Huan Fa [2021] No. 3), the chemical industry with a design hourly VOCs emissions of 10000 cubic meters or more and other industries with 30000 cubic meters or more shall install VOCs automatic monitoring equipment. According to your message, your company has three VOCs exhaust outlets, which belong to the rubber products industry. The outlets with a design hourly exhaust volume of 30000 cubic meters and above should be equipped with VOCs automatic monitoring equipment. The outlets with a design hourly exhaust volume of less than 30000 cubic meters can not be equipped with VOCs automatic monitoring equipment temporarily.
As for VOCs monitoring instrument and method: different standards have different requirements for the characterization of fixed source VOCs. Generally, non methane hydrocarbon is the main standard, and some standards are benzene series. According to your statement, VOCs should be represented by non methane total hydrocarbons. When selecting VOCs automatic monitoring equipment, FID monitoring equipment should be selected according to the requirements of Technical Specifications for Continuous Monitoring of Non methane Total Hydrocarbons in Exhaust Gas from Fixed Pollution Sources (DB32/3944-2020) and Technical Requirements and Detection Methods for Continuous Monitoring System of Non methane Total Hydrocarbons in Exhaust Gas from Fixed Pollution Sources (HJ1013-2018).
Source: Jiangsu Provincial Department of Ecological Environment
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