Currently there are some problems in the process of environmental impact assessment document preparation for construction projects, the article for these problems according to the project overview, engineering analysis, general layout, total control, risk assessment, construction period impact analysis, the feasibility of nano-pipeline, public participation, change the EIA, alteration and expansion of the project, environmental monitoring, project drawings and environmental protection investment in parts of the summary, and puts forward the specific Attention.
China has carried out decades of environmental impact assessment, ecological environmental protection in China and the sustainable development of the national economy has played a positive role, but in the preparation of specific EIA documents there are still many problems. In this paper, according to the experience accumulated in the construction project EIA work and the situation encountered, the environmental impact assessment of construction projects (hereinafter referred to as the EIA document) preparation of the notes summarized, the following from three aspects of the specific analysis.
I. Basic information of the construction project
(I) Overview of the project
The basic information of the project should be as exhaustive as possible, and the basic information should be complete without omission, including the main functions of each building (such as the clubhouse and the commercial support facilities, etc.) and the scale of each building; the specific location and scale of the public and auxiliary facilities, such as the transformer/distribution station, regulating station, garage, garbage room (station), pumping station, emergency power generating room, etc., should be marked out on the general plan, and the specific location and scale of the public and auxiliary facilities should be preferably indicated. On the general plan, the specific location and scale of the substation, regulator, garage, garbage room (station), pumping station, emergency power generation room and other public facilities should be marked out, and it is best to attach the main building or the overall effect. The description of sensitive points around the project should be marked on the map, and the text explains the scale of the sensitive points, distance from the project, the protection level of the atmosphere and other elements, as well as the mid- and long-term planning situation, etc.; for the neighboring water bodies, as far as possible, explain the situation of the river channel (width of the river surface, width of the surface of the water surface, depth of the water, direction of the flow, flow rate of the flow rate) and its function (navigation, flood discharge, irrigation), etc.; for the sensitive points provided by the builder and the design unit, the information Be sure to go to the site to carefully investigate, verify and take photos as the report attached.
(II) Engineering Analysis
1. Industrial projects. Industrial projects should first be combined with the product and production process to give the amount and source of raw and auxiliary materials, some raw and auxiliary materials should also explain its composition, physical state, supply (transportation) mode, and then according to the product to give the production process flow chart (marking out the nodes of sewage), and appropriate description of the production process at the same time to explain the generation of pollutants (pollutant concentration, wastewater/exhaust gas volume, working conditions and standards, the way of generation, etc.) In addition to the main production process, the supporting public facilities should also be quantitatively described, including the function, size, location, pollutant generation; such as the expansion project should be described in reliance on the situation; according to the number of materials given by the design unit of the production process to draw the water balance, the main pollutant balance diagram. When citing the monitoring data of the established enterprises, the monitoring data accumulated by the enterprises for a long time can be used in the EIA report according to the specific situation if the monitoring frequency reaches a certain level, but it is also necessary to carry out appropriate processing under certain conditions, such as the online real-time monitoring data need to be processed into data comparable with the corresponding emission standards, etc., and the authenticity and representativeness of the data shall be analyzed and screened; the data of the completion acceptance is the "environmental best working condition". The completion and acceptance data is the "optimal" data under the condition of "environmental protection best working condition", and the sample data is also less, generally can not be directly used for the calculation of pollutant emissions, and need to carry out certain processing; the use of analogous data, it should be stated that the analogous working conditions, such as production equipment, facilities, raw and auxiliary materials and products. When using analogous data, the conditions of analogous conditions should be described, such as production equipment, raw and auxiliary materials and products, production conditions, environmental protection facilities, and whether the analogous conditions are similar.
2. Non-industrial projects. Non-industrial construction projects in the surface water impact analysis, water consumption and drainage generally can not be estimated, should be provided by the owner and the design unit, and with reference to the empirical data to be verified, based on which the water balance diagram is given; catering wastewater should be given to the amount of wastewater, pollutant concentration, treatment, whether or not to discharge into the pipeline, the treatment should be a certain description of the best illustration, and to explain the final discharge destination. In the analysis of atmospheric impact, the specifics of the entrance and exit of the garage and the exhaust pipe should be provided by the owner or the design unit, and marked in the plan; the smoke emission of the catering should be combined with the scale of the kitchen to give the type of the oil smoke purifier, the exhaust volume, the purification effect (efficiency and emission concentration), and the distance from the nearest sensitive point. Surrounding roads should give the specific conditions of the roads, and the traffic flow should be measured, such as the use of analogous data should be very cautious, and fully consider the road grade, geographic location, the surrounding environment, the direction of the road, and so on. For the more sensitive project itself, the EIA should pay attention to strengthening the analysis of the status quo of the external environment and find out the constraints affecting the project, such as: hospitals are very sensitive to external environmental noise, food processing projects are very sensitive to the external atmospheric environment and the quality of water supply; and attention should also be paid to the impacts of internal pollution sources on the project. The sensitive influencing factors of the construction project itself should also be emphasized in the EIA, such as medical wastewater and medical waste in hospitals, and the "safety" issue should be considered; hospitals, nursing homes, high-grade housing and other sensitive projects should pay attention to the impact of cooling towers, pumping stations, central air-conditioning, boiler rooms, substations, emergency generator sets and other sources of internal noise, the location and design of dumping stations and whether the project is sensitive to external environmental noise. The location of the garbage station and its design can ensure that the project's odor impact is minimized, underground garage design process is in line with fire, drainage and other design specifications and the surrounding sensitive points of the atmosphere, noise impact is controllable.
Two, environmental impact analysis and evaluation
(I) general layout reasonableness evaluation
General layout reasonableness evaluation includes the following: should analyze the upwind and downwind factors are reasonable, such as sensitive to the atmosphere should be laid out in the dominant wind direction upwind, emissions should be laid out in the dominant wind direction downwind or side wind direction; whether the ground elevation is designed to be reasonable, and whether it will be flooded during rainstorms and floods. Whether it will be flooded in case of heavy rain and flood, especially the sensitive equipment and facilities (such as electrical equipment, acid and alkali and dangerous chemicals storage, etc.); whether the building with high vibration requirements is far away from the vibration source, and whether the building with acoustic environment requirements is far away from the high noise source.
(II) Total Control
In order to further standardize the total amount of major pollutants discharged in the EIA documents of the construction projects during the "Twelfth Five-Year Plan" period, many localities have compiled regional accounting rules according to the rules of the Ministry of Environmental Protection of the People's Republic of China, for example, the Shanghai Municipal Bureau of Environmental Protection formulated the "Twelfth Five-Year Plan". For example, Shanghai Municipal Environmental Protection Bureau has formulated the "Accounting Rules for Total Emission Reduction of Major Pollutants in EIA Documents of Construction Projects during the 12th Five-Year Plan Period" (Shanghai Environmental Protection Assessment [2012] No. 409). According to the new requirements, the total amount control chapter in the EIA document should include the following contents: firstly, briefly describe the total amount control related requirements of the state and Shanghai; secondly, clarify the types of wastewater and exhaust gas emission of the project, as well as the names of pollutants that should be included in the total amount control category; once again, summarize the measures that the project intends to take to improve the level of clean production and comprehensive utilization of resources, and to intensify the efforts of pollution control; and then fill in the project's total amount control Then fill out the statistical table of total project control indicators to clarify the new increase in the total amount of pollutants under control of the project, the "new with the old" reduction, the total amount of pollutants that will eventually be added to the total project after the implementation of the project (the existing project and the newly implemented project combined); and finally, clarify the source of the total amount of indicators for the balance of the project.
(C) Risk Evaluation
Risk evaluation has been increasingly emphasized in EIA, and the Ministry of Environmental Protection has issued the Notice on Further Strengthening the Management of Environmental Impact Evaluation to Guard Against Environmental Risks (Huanfa [2012] No. 77) and the Notice on Effectively Strengthening Risk Prevention and Strictly Managing the Evaluation of Environmental Impacts (Huanfa [2012] No. 98), which require that construction projects be Risk review, risk chapter for retrospective analysis, the whole process evaluation, and strengthen the linkage of the preplanning, and strengthen the standardization of the preparation of special chapters (special sections) involving risk content. Risk or abnormal working conditions analysis should be communicated with the owner and the design unit, and the actual occurrence of working conditions consistent with the scenario, not arbitrary "assumptions", such as: dust collector generally only exists in the case of reduced dust removal efficiency and there is no dust removal efficiency is "0", "explosion" type of construction project, the risk of "explosion", the risk of "explosion" type of construction project, the risk of "explosion" type of construction project. "Explosion" type of pollutant leakage generally does not exist in the plant personnel in the near downwind stay more than 10 minutes; in addition to considering environmental protection equipment and facilities, there are also production process equipment risks and abnormal situations, such as: garbage (hazardous waste) incineration on the existence of incineration temperature does not reach more than 850 ℃. For the renovation and expansion project, first of all, the existing project should be risk analysis and summary, focusing on the analysis of the same process content, risk prevention should reflect the "new with the old". Atmospheric risk prediction, it is not appropriate to choose the average meteorological conditions, should pay attention to the representativeness of the meteorological conditions, such as: D stability, average wind speed is not representative, sometimes E, F stability is not representative, and A, B stability, but the representativeness of a better, should be a specific analysis of the specific problem, but also can be used to "test than to choose".
(4) Feasibility of drainage pipeline
Feasibility of drainage pipeline should be explained in the EIA document as follows:
(1) First of all, it should be explained that the external conditions of pipeline can be accommodated, whether there is a pipeline at present (or in the near future), its specific location and distance from the project, and whether it is necessary to build external pipeline, and if it is necessary to construct pipeline, it should be explained that the construction time, the investment, funding conditions, and the length of pipeline, the length of the pipeline, the length of the pipeline, and the length of the pipeline. If it is necessary, it should explain the construction time node, investment amount, funding conditions and the length, diameter, material and direction of the pipeline.
(2) The capacity of the external pipeline: the diameter of the pipeline, the sewage discharge capacity, the amount of the current pipeline, and the surplus pipeline capacity, including the "pipeline capacity" in the plant.
(3) Nano-pipe standards: the pollutant indicators allowed to be nano-pipe, whether the project meets the standards of nano-pipe, how to meet the standards of nano-pipe.
(4) The final destination of the sewage, the design capacity, the current treatment capacity, the surplus capacity to meet the requirements of the newly increased sewage volume.
(5) The basic situation of the final pipeline wastewater treatment facilities (plants): wastewater treatment process, suitable for what kind of wastewater, whether it is suitable for the project to discharge wastewater; it should also be noted that the project wastewater discharge is in line with the "shortest distance from the pipeline".
(6) The final report should be a comprehensive statement of "compliance" and "non-compliance" with the situation of pipeline, and attached in the annex to the pipeline agreement certificate.
(E) Public Participation
Public participation is an important chapter in the EIA document, and the basic requirements are the four principles of openness, equality, breadth, and convenience, and the sensitive protection objectives cannot be omitted and full coverage is required. According to the Ministry of Environmental Protection's "Notice on Effectively Strengthening Risk Prevention and Strict Management of Environmental Impact Assessment" (Huanfa [2012] No. 98) and Shanghai's relevant requirements, the EIA unit to prepare the EIA document for the public participation chapter, must be in the website for the two online public notices, the local newspaper published announcements and relevant grass-roots organizations information bulletin boards to post announcements; the construction project to carry out the on-site questionnaires must be in the basic report and after the second online public notice; construction projects to carry out on-site questionnaire survey must be in the basic report. The site questionnaire survey of the construction project must be carried out after the report is basically completed and the second online public announcement is made; the compendium submitted to the environmental protection department must include the details of the public participation chapter. When the investigator distributes on-site questionnaires, the number of written questionnaires distributed for construction projects with significant environmental risks or impacts shall be more than 200, the number of written questionnaires distributed for construction projects with potentially greater environmental risks or impacts shall not be less than 150, the number of written questionnaires distributed for other construction projects shall not be less than 100, and the ratio of distributed and recovered questionnaires to those targeted for investigation within the sensitive targets shall not be less than 1,000. The distribution and recovery ratio of questionnaires shall be not less than 70%. The questionnaire shall be designed in a targeted manner, and different projects shall be adjusted accordingly to highlight the content of public concern. The report should be accompanied by a basic information sheet of the surveyed public, while attention should be paid to the representativeness of the survey respondents, which can be illustrated by the distribution map of the participating respondents. Public participation in statistical analysis of the project "does not matter" point of view, can not be simply counted as "support", the opposition should be visited, if there are more than three should be given in the list, while the table should be given to deal with the views of the owner if there is a commitment to the best attached to the letter of commitment If the owner has any commitment, it is better to attach a letter of commitment. For the objection, the conclusion of "not adopted" should not be made lightly, and it should be particularly cautious and carefully consider whether the reason is valid and whether it is an environmental problem. The public participation of the reconstruction and expansion project should increase the relevant content of the "existing project", which should be reflected in the "public questionnaire" and "online public notice", and should be investigated with the relevant departments. Whether there are any complaints about the "existing project" at present and in the near future, the object and content of the complaints, etc., should be reflected in the EIA document.
(F) Environmental impact during the construction period
The impact of the construction project on the neighboring area during the construction period mainly includes noise, exhaust gas, sewage and solid waste. In the impact analysis, the construction phase should be according to the sequence of construction and the division of the construction area to explain the construction content, construction methods, construction equipment, the amount of work (such as the balance of earth volume), the construction cycle and the planned progress; put forward mitigation measures in addition to the consideration of sewage (slurry water, sewage), waste gas (dust, emission of waste gas), noise (all types of construction noise), solid waste (slag, waste materials and living garbage) In addition, construction sequences and nodes should also be analyzed, and optimization in this regard can also mitigate environmental impacts; road projects should be careful to mention "noise barriers", fully enclosed transportation, etc.; whether or not to use "commercial concrete" for civil engineering projects should be considered on a case-by-case basis; It should be noted that the scope of application of the "no night construction" measure is not mandatory for any project.
(VII) environmental protection investment
EIA documents should be given as much as possible in the list of environmental protection investment by sub-item, and give its proportion of the total investment, the data should be provided by the owner and the design unit, can not be arbitrarily estimated so as not to avoid large errors, environmental protection investment calculation of specific considerations include: (1) the direct construction of the investment in pollution control in order to be counted in the environmental protection investment, the single Energy-saving construction investment is generally not environmental protection investment, such as: a single waste heat recovery, waste heat utilization of materials such as drying. (2) and pollution control is too close to the energy-saving construction investment, workshop sanitation construction investment can be counted as environmental protection investment. (3) owners and design units to provide environmental protection investment refers to the static investment, the proportion of environmental protection investment should also be used to calculate the static total investment. (4) environmental protection construction projects, the entire project construction investment can be included in the environmental protection investment, the project itself still need to calculate the project itself for pollution control of environmental protection investment. (5) "Expansion project", a period of construction has often been part of a two-phase **** with the second phase of the environmental protection construction content, at this time, the proportion of environmental protection investment in the second phase and a period of time than tend to be low, this situation should be explained in the EIA documents, while in the corresponding "Engineering Analysis "Content should also be clearly stated.
Three special problems of EIA
(I) Problems to be noted in changing the EIA
In the daily EIA work, we will come across the project has been prepared and approved by the environmental protection department of the EIA documents, but due to the project itself, the process or measures to make some adjustments, need to be prepared to change the EIA, the specific change of the document form is generally "the original report table corresponds to the report table", "the report table corresponds to the report table". The form of the specific change document is generally "the original report table corresponds to the report table", "the original report corresponds to the report", some of them are "supplemental EIA" (or even supplemental description), and some of them are "nearly re-compiling the EIA report". ", the specific operation can have a variety of programs, should be responsible for the approval of the environmental protection department and specific personnel to fully communicate, multiple communication, to take the pre-communication, communication and post-communication and so on. The following should be noted when the change document is prepared:
(1) First of all, the principle of changing the EIA should be clarified: the reason (background) for the engineering change, the construction content and construction before and after the change, the resulting changes in environmental protection measures, pollutant discharge methods and emission levels, and whether it will lead to changes in the evaluation level, the degree of environmental impacts and the scope of the obvious changes in the results of public participation and so on, and whether these changes will alter the conclusions of the original EIA.
(2) The changed environmental impact prediction, including level, scope, method and content, shall be carried out in accordance with the requirements of the latest guideline; the evaluation basis, environmental profile and environmental quality shall be the latest, and all the cited basic data shall pay attention to their authority in addition to adopting the "latest".
(3) Compare with the original EIA document to make clear whether the sensitive targets, planning and industrial policies of the project site have changed.
(4) the change of the document is the "report" of its "general" content can not be omitted, the "report" of the "table" involving the "general" content can not be omitted. The content of the "report form" involving the "general" can not be omitted.
(5) Some changes in the preparation of the EIA document will be required to analyze the approved document with the approved document article by article, indicating whether the basic requirements of the original approved document.
(2) expansion projects
EIA documents should pay special attention to the preparation of the expansion project, the same investment in the project's workload may be more than double the new project or even more, to write a clear "existing project" situation, and fully embodies the "new with the old! ".
(1) First of all, it should be clear that the expansion project and the interdependence of existing projects; detailed description of the existing scale of production, production processes, product programs, raw and auxiliary materials, water supply and drainage, environmental protection facilities, pollutant emissions, etc., and to analyze the existing production facilities and pollutant emissions to meet the standards of the situation, the environmental impact assessment and its completion of the inspection and acceptance of the situation.
(2) the expansion project should be put forward "to the new with the old" measures to require the expansion project environmental protection level design is better than the existing project, and should list the required environmental protection investment.
(3) in detail to give three accounts (including products, raw and auxiliary materials, energy consumption of three accounts), if necessary, must also give a more detailed production process material balance (the main raw and auxiliary materials, main components), water balance, the main pollutant balance, energy balance.
(4) cleaner production evaluation must be part of the existing evaluation at the same time, does not meet the requirements of cleaner production standards must also be proposed to "new with the old" measures.
(5) "environmental management and environmental monitoring": must reflect the "new with the old", first of all, the "status quo" should be investigated and explain the existing environmental management force, Management rules and regulations, management measures, as well as environmental monitoring sites, instrumentation, monitoring personnel and their technical level, etc., whether to meet the current requirements, whether to meet the requirements of the expansion project, if it can not meet or can not fully meet the expansion project should be combined with the "new to bring the old" to put forward specific proposals and countermeasures, but the frequency of environmental monitoring should meet the corresponding industry. However, the frequency of environmental monitoring should meet the emission standards of the corresponding industry and other relevant requirements.
(6) The public participation of the reconstruction and expansion project should investigate whether there are any complaints at present and in the near future, and the object and content of the complaints.
(7) "Risk Evaluation" chapter should first analyze the content of the existing plan and activation, whether to meet the requirements, etc., and at the same time to clarify the requirements of the expansion project on the plan, whether to improve on the basis of the existing plan or to rewrite.
(C) EIA monitoring issues
Environmental monitoring is an important means of evaluating the current environmental quality of construction projects in the EIA. Environmental monitoring includes "environmental sampling" and "environmental analysis" two parts, the former is more likely to have problems. Environmental sampling includes point arrangement, sampling instruments, sampling timing, sampling process and other related conditions, the EIA documents should be combined with the weather and sampling conditions such as the representativeness of the monitoring data, reliability and usability of the analysis and description, and should pay special attention to the weather during the monitoring period, can not be in the rainy day monitoring, the monitoring time can be postponed according to the number of rainy days. Determination of points in the monitoring program is very important, the general location can be marked on the evaluation scope map, and then fine-tuned according to the detailed site survey; the layout of monitoring points should take into account a variety of factors, and the reasons for the determination of each point should be able to state the reasons and explain the principles/methods of the layout of the points in the EIA document, and in principle, it is required that the sensitive targets should be taken into account in the entire process. The number of atmospheric sampling points shall comply with the evaluation level requirements corresponding to the atmospheric guideline HJ2.2, and can be appropriately simplified if there are automatic continuous monitoring points in the vicinity, and the characteristic pollutants shall be taken into consideration, including the project characteristic pollutants and the regional characteristic pollutants; the number of water quality monitoring cross sections shall comply with the evaluation level requirements corresponding to the surface water guideline HJ2.3, and can be appropriately simplified if it is not enough for the third level, and the monitoring items shall be representative, and attention shall be paid to the characteristic pollutants; the noise monitoring shall pay attention to the point locations. Pollutants; noise monitoring should pay attention to the representativeness of the points, if necessary, in order to predict the needs and convenience can be more points (including in the non-ground), and sometimes also need to set up a monitoring point in the location of the sensitive points; vibration, if necessary, can be encrypted observation, requiring full coverage of sensitive targets. Environmental quality status quo monitoring results exceed the standard, should analyze the reasons for exceeding the standard. The current environmental quality information should quote the latest data as far as possible, such as the last year's environmental quality bulletin, and when quoting the data from other EIA documents, attention should be paid to the validity of the quoted distance from the points, which should be within the evaluation range of the EIA documents of the project in general.
(4) Problems of drawings
When the EIA document is prepared by combining drawings and texts, the completeness and standardization of drawings is also an important aspect of the quality of the EIA document. The basic drawings of EIA documents include: geographic location map, regional location map, general layout plan and process layout plan, of which the geographic location map is easy to mislabel the specific location of the construction project due to its large scale, so special attention should be paid to it; other drawings include: water, gas and sound evaluation scope map (including monitoring points), environmental protection target map, pollution source distribution map (wastewater and exhaust gas discharge points should be labeled), and the map of public participation survey (pie chart of the distribution of the participating objects). Participation object distribution pie chart) and so on. The scale, compass, legend and project scope should be clearly labeled in the relevant maps.
Fourth, conclusion
Environmental impact assessment of construction projects is to analyze the degree of mutual influence of the construction project and the surrounding environment, in order to accurately predict the degree and scope of the impact as much as possible, and put forward countermeasures to prevent and mitigate adverse environmental impacts and measures, EIA practitioners should be in line with the conscientious attitude, in strict accordance with the requirements of the Technical Guidelines and laws and regulations to carry out the environmental impact assessment and put forward EIA practitioners should carry out environmental impact assessment in a conscientious and responsible manner in strict accordance with the technical guidelines and the requirements of laws and regulations, and make a conclusion on whether the EIA project is feasible or not, so as to provide the environmental protection department with a scientific basis for environmental protection approval. After years of implementation of the environmental assessment system, the norms and requirements for the preparation of EIA documents have been greatly improved, and EIA practitioners should also continue to learn, strive for excellence, and strengthen the responsibility for energy conservation and emission reduction, the Code of Ethics for EIA practitioners, and the awareness of social responsibility, so as to keep abreast of the times.
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