On the calculation of total pollutant emissions in corporate environmental impact assessments

The total amount of waste discharged by the enterprise must be recalculated or adjusted; an application must be submitted to the local environmental protection authorities, along with relevant supporting documents, including but not limited to environmental impact assessment reports, monitoring reports on waste discharge, and proof of changes in production capacity. The environmental protection authorities will review the materials provided by the enterprise as well as its actual pollution discharge levels to decide whether to approve an adjustment to the total amount of pollution discharged. .

Sure. But it won’t work with the original project; a new application must be submitted, along with going through a series of corresponding approval procedures, which is quite challenging.

As environmental protection policies become stricter and more comprehensive, the total amount of pollutants emitted is an environmental indicator that is strictly controlled at the local level. Without new processes, products, or technologies, it is extremely difficult to reduce the total amount of pollutants emitted from existing production facilities.

During the environmental impact assessment carried out at the initial stage of project construction, the total emissions estimated back then might have been insufficient; as time has passed, no one, including the government, paid enough attention to this aspect, which is why we were shocked when we did the calculations now! The next step is to make some adjustments, but it might be quite difficult!

The main reason for this situation is inadequate research on the company’s process protocols. Those responsible for preparing the environmental impact assessments may have limited technical skills; more likely, the emission figures are deliberately set low so that the assessments can be approved easily during the expert review process. Environmental authorities prefer data showing lower levels of pollution. It is only when the company faces the consequences that it realizes the problems.

It’s highly likely that it won’t be possible to make adjustments to increase its size; after production, environmental inspections will focus on checking any discrepancies between the actual conditions and those specified in the environmental impact assessment. To meet the criteria and requirements of environmental impact assessments, it is necessary to invest heavily in process improvements and technological upgrades... Many of these criteria are becoming increasingly stringent, and the regulations issued by local authorities require ultra-low emissions to be achieved within set deadlines, forcing enterprises to comply. In the first half of the year, I saw some extremely extreme cases in Inner Mongolia: the environmental impact assessment specified zero wastewater discharge (the indicator for clean production is several dozen tons of wastewater per ton of product); during trial production, a small amount of discharge was allowed, but zero discharge was required by the end of the year. (All wastewater is reused through neutralization and desalination; as for solid waste, there are no examples of continuous production in this industry.)

This problem is likely to exist in many companies: the amount of pollutants estimated during the preliminary phase of a project is low, while the actual amount of pollutants generated during implementation is higher. Previously, environmental impact assessment reports were prepared in response to such changes (commonly known as post-evaluation), and the pollution discharge permits were updated accordingly, but some environmental protection authorities did not accept this approach. The best approach is to make use of new projects; during the environmental impact assessment for such projects, the missing items and quantities can be supplemented and completed in the description of the existing projects, and the pollution discharge permit can then be amended after the new project is completed.