Answers from the provincial department: problems such as the implementation standard of particulate matter emission during acceptance

Q: What is the implementation standard of air pollutant discharge?
Our company is a fine chemical enterprise. At present, the exhaust gas complies with the relevant requirements in the Emission Standard for Volatile Organic Compounds in the Chemical Industry (DB323151-2016), while the individual indicators in the Comprehensive Emission Standard for Air Pollutants in Jiangsu Province (DB324041-2021) implemented on July 1, 2022 are more strict. As a chemical industry, does it only need to implement industrial standards? Or should the stricter of the above two standards be followed?
Jiangsu Provincial Department of Ecological Environment A:
If there are industrial standards, the industrial standards shall be implemented. The chemical industry of Jiangsu Province shall implement the Emission Standard of Volatile Organic Compounds for Chemical Industry (DB323151-2016).
Q: VOCs online monitoring equipment requirements?
Article 9 of the Measures of Jiangsu Province for the Administration of Automatic Monitoring of Pollution Sources (for Trial Implementation) stipulates that the chemical industry with a design hourly VOCs emission of 10000 cubic meters or more shall install VOCs automatic monitoring equipment. Is there a requirement for monitoring equipment? Is it in the form of FID or PIG? What is the online method for waste gas from hazardous waste storage with low VOC emissions?
Jiangsu Provincial Department of Ecological Environment A:
1. Requirements for monitoring equipment. Article 10 of the Measures for the Administration of Automatic Monitoring of Pollution Sources in Jiangsu Province (Trial) (Su Huan Fa [2021] No. 3) specifies the requirements that pollutant discharging units must meet when building automatic monitoring and monitoring equipment and supporting facilities, including: requirements for product applicability testing, requirements for product information registration and filing, and requirements for equipment installation and commissioning.
2. VOCs monitoring instrument method. At present, different standards have different requirements for the characterization of VOCs of fixed pollution sources. Generally, non methane hydrocarbon is the main standard, and some standards are benzene series. You are consulting a chemical enterprise. VOCs should be represented by non methane total hydrocarbons. When selecting VOCs automatic monitoring equipment, you should select appropriate monitoring equipment in accordance with the requirements of the Technical Specifications for Continuous Monitoring of Non methane Total Hydrocarbons in Exhaust Gas from Stationary Pollution Sources (DB32/3944-2020) and the Technical Requirements and Detection Methods for Continuous Monitoring System of Non methane Total Hydrocarbons in Exhaust Gas from Stationary Pollution Sources (HJ1013-2018). DB32/3944-2020 specifies that "this standard is applicable to the construction, operation and management of the continuous monitoring system for non methane total hydrocarbons in the exhaust gas of fixed pollution sources using hydrogen flame ionization detector (FID)". Therefore, it is necessary to select the instrument with FID method according to the standard when installing the online monitoring instrument for non methane hydrocarbon.
3. On line monitoring method for waste gas with low VOCs emission. For low concentration VOCs fixed pollution sources, the method and equipment requirements for online monitoring instruments are the same as those for high concentration VOCs fixed pollution sources. When selecting instruments, it is necessary to select instruments with appropriate range according to the actual emission concentration.
Q: What is the standard for particulate matter emission during acceptance?
In the environmental assessment and approval documents, the particulate matter emission from the exhaust funnel shall be subject to the Integrated Emission Standard of Air Pollutants (GB16297-1966). During the acceptance, is the particulate matter emission from the exhaust funnel subject to the standards proposed in the original environmental assessment or the Jiangsu provincial local standard Integrated Emission Standard of Air Pollutants (DB32/4041-2021)?  
Jiangsu Provincial Department of Ecological Environment A:
Article 4 of the Measures for the Administration of Ecological Environment Standards (Decree No. 17 of the Ministry) stipulates: "In areas where there are local ecological environment quality standards, local ecological environment risk control standards and local pollutant discharge standards, priority shall be given to the implementation of local standards according to law; Article 24 stipulates that: "The local pollutant discharge standards take precedence over the national pollutant discharge standards; projects not specified in the local pollutant discharge standards shall be subject to the relevant provisions of the national pollutant discharge standards." Therefore, the particulate matter emission during the acceptance shall be subject to the Jiangsu provincial local standard Integrated Emission Standard of Air Pollutants (DB32/4041-2021).
Q: Questions about the acceptance of Technical Specifications for Continuous Monitoring of Non methane Hydrocarbons in Exhaust Gas from Fixed Pollution Sources?
Chapter 9.4.1 of the Technical Specifications for Continuous Monitoring of Non methane Hydrocarbons in Exhaust Gas from Stationary Pollution Sources (DB32/3944-2020) stipulates that "the acceptance of technical indicators of non methane hydrocarbons includes the acceptance of analysis cycle, indication error, zero drift, range drift and accuracy, and the operation steps and calculation formulas are in accordance with the relevant requirements of Chapter 8".
Whether the acceptance is carried out in strict accordance with the above steps. Drift detection requires at least 7 days, and the accuracy acceptance should be carried out after 7 days of drift detection; Or do you perform accuracy acceptance while drift?
During the acceptance, if the previous item does not meet the technical requirements, can we continue the acceptance of other items?
During drift detection, the results are required to meet the standards. Is it the result of 7 days per day or the average value of 7 days?
For accuracy acceptance, it is required that the results meet the standards. Is it the results of three days, the average value of the results of three days, or the results of at least 27 groups of data in three days?
Jiangsu Provincial Department of Ecological Environment A:
1. 8.4 of Technical Specifications for Continuous Monitoring of Non methane Hydrocarbons in Exhaust Gas from Stationary Pollution Sources (DB32/3944-2020) stipulates that "no calibration and maintenance is allowed during zero drift and range drift"; 8.6.1 It is specified that "when other parameters pass the performance requirements, the production equipment can operate normally and stably, and the accuracy can be tested". Therefore, the accuracy test can only be carried out after the 7-day drift test is completed. It is not allowed to conduct accuracy acceptance while drifting to avoid the impact on the accuracy of instrument zero point and range.
2. 9.4.1 of the Technical Specification for Continuous Monitoring of Non methane Hydrocarbons in Exhaust Gas from Fixed Pollution Sources (DB32/3944-2020) specifies the specific contents and technical index requirements related to acceptance testing. If any one of the technical indicators fails to meet the requirements, it shall be deemed as unqualified. If the previous item does not meet the technical requirements, the acceptance test of other items can also be continued to provide a preliminary understanding of the performance of other indicators, but the results can only be used as a reference, not as a basis for the final conclusion.
3. During drift detection, Technical Specification for Continuous Monitoring of Non methane Hydrocarbons in Exhaust Gas from Fixed Pollution Sources (DB 32/3944-2020) requires that the results meet the requirements of the standard, but it is not clear whether it refers to "7-day daily results" or "7-day mean values", The relevant national standard Technical Requirements and Detection Methods for Continuous Monitoring System of Non methane Hydrocarbon in Exhaust Gas from Stationary Pollution Sources (HJ 1013-2018) requires that "all 24h zero drift values and 24h range drift shall meet the standard requirements". According to local standards, it shall not be lower than the requirements of national standards. When drift detection is carried out according to DB 32/3944-2020, the daily results shall meet the requirements of the standards.
4. During accuracy acceptance, according to 8.6.3 of the Technical Specifications for Continuous Monitoring of Non methane Total Hydrocarbons in Exhaust Gas from Fixed Pollution Sources (DB 32/3944-2020), "at least 9 pairs of valid data are taken every day for accuracy calculation", it is necessary to calculate the accuracy of data every day, and the results of each day must meet the standard requirements.
Source: Jiangsu Provincial Department of Ecological Environment