what matters should be paid attention to in the preparation of environmental assessment documents for construction projects? The following Zhongda Consulting brings you an introduction of relevant contents for your reference.
at present, there are some problems in the preparation of environmental impact assessment documents for construction projects. This paper summarizes these problems according to project overview, engineering analysis, general layout, total control, risk assessment, impact analysis during construction, feasibility of management, public participation, change of environmental assessment, reconstruction and expansion projects, environmental monitoring, project maps and environmental protection investment, and puts forward specific matters needing attention.
China has carried out environmental impact assessment for decades, which has played a positive role in China's ecological environment protection and the sustainable development of the national economy, but there are still many problems in the preparation of specific environmental impact assessment documents. Based on the experience accumulated and the situation encountered in the environmental impact assessment of construction projects, this paper summarizes the matters needing attention in the preparation of environmental impact assessment documents of construction projects (hereinafter referred to as environmental impact assessment documents), and makes a concrete analysis from three aspects.
I. Basic information of the construction project
(I) General information of the project
The basic information of the project should be as detailed as possible, and the basic information should be complete and complete, including the main functions (such as clubs and commercial facilities) and scale of each building; On the general plan, the specific location and scale of public and auxiliary facilities such as power distribution station, pressure regulating station, garage, garbage room (station), pumping station and emergency power generation room should be marked, and it is best to attach the main building or overall effect diagram. The description of sensitive points around the project should indicate the location on the map, and the scale of sensitive points, the distance from the project, the protection level of atmosphere and other elements, as well as the medium-and long-term planning, etc.; For the surrounding water bodies, explain the river conditions (river width, water surface width, water depth, flow direction, velocity and flow rate) and their functions (shipping, flood discharge, irrigation) as far as possible; For the sensitive information provided by the owner and design unit, we must go to the site to seriously investigate, verify and take photos as the attached drawings of the report.
(II) Engineering analysis
1. Industrial projects. For industrial projects, firstly, the amount and source of raw and auxiliary materials should be given in combination with products and production processes, and some raw and auxiliary materials should also be explained in terms of their composition, material state and supply (transportation) mode. Then, the production process flow chart should be given according to the product situation (indicating the pollution discharge nodes), and the production process should be properly described, and the production situation of pollutants (pollutant concentration, waste water/waste gas quantity, working conditions and standard temperature and pressure, production mode, etc.) should also be explained. In addition to the main production process, the supporting public and auxiliary facilities should also be described quantitatively, including function, scale, location and pollutant generation; If it is a reconstruction and expansion project, the supporting situation should be explained; Draw water balance diagram and main pollutant balance diagram according to the quantity of production process materials given by the design unit. When quoting the monitoring data of established enterprises, the monitoring data accumulated by enterprises for a long time can be used in the EIA report according to the specific situation, but under some conditions, it needs to be properly processed, such as online real-time monitoring data needs to be processed into data comparable to the corresponding emission standards, and the authenticity and representativeness of the data should be analyzed and screened; The completion acceptance data belongs to the "optimal" data under the condition of "the best working condition of environmental protection", and there are few sample data, so it can not be directly used to calculate the pollutant discharge, and it needs to be processed to some extent; When analogy data are used, the analogy working conditions should be explained, such as production equipment and facilities, raw materials and products, production working conditions, environmental protection facilities and whether analogy conditions are similar.
2. Non-industrial projects. In the surface water impact analysis of non-industrial construction projects, water consumption and displacement can not be estimated by themselves, but should be provided by the owner and the design unit, and verified with reference to empirical data, on the basis of which a water balance diagram is given; Catering wastewater should be given the amount of wastewater, pollutant concentration, treatment method, whether it is discharged into a pipe or not, and the treatment method should be described, best illustrated, and the final discharge direction should be explained. In the analysis of atmospheric impact, the details of the entrance and exit of the garage and the exhaust pipe should generally be provided by the owner or design unit and marked on the plan; The type, exhaust volume, purification effect (efficiency and emission concentration) of the fume purifier should be given according to the scale of the kitchen, and the distance from the nearest sensitive point should be explained. The specific conditions of the surrounding roads should be given, and the traffic volume should generally be measured. If analogy data is used, great care should be taken, and the road grade, geographical location, surrounding environment and road direction should be fully considered. For sensitive projects, attention should be paid to strengthening the analysis of the current situation of the external environment in EIA to find out the restrictive factors that affect this project, such as: hospitals are sensitive to external environmental noise, and food processing projects are sensitive to external atmospheric environment and water supply quality; At the same time, we should also pay attention to the influence of internal pollution sources on the project. The sensitive factors of the construction project itself should also be paid attention to in the EIA, such as hospital medical wastewater and medical waste, and "safety" should be considered; For self-sensitive projects such as hospitals, nursing homes and high-grade houses, attention should be paid to the influence of internal noise sources such as cooling towers, pumping stations, central air conditioners, boiler rooms, substations and emergency generator sets, whether the location and design of garbage stations can ensure the minimum impact on the odor of this project, whether the design technology of underground garages meets the design specifications of fire prevention and drainage, and whether the impact on the atmosphere and noise of surrounding sensitive points can be controlled.
II. Analysis and evaluation of environmental impact
(I) Rationality evaluation of general layout
Rationality evaluation of general layout includes the following contents: it is necessary to analyze whether the factors of up and down wind directions are reasonable, such as those sensitive to the atmosphere should be arranged in the upwind direction of the dominant wind direction, and those that produce waste gas emissions should be arranged in the downwind direction or crosswind direction of the dominant wind direction; Whether the ground elevation design is reasonable, whether it will be flooded during rainstorm and flood, especially sensitive equipment and facilities (such as electrical equipment, storage of acid and alkali and dangerous chemicals, etc.); Whether buildings with high vibration requirements are far away from vibration sources, and whether buildings with high acoustic environment requirements are far away from high noise sources, etc.
(II) Total Amount Control
In order to further standardize the total amount accounting of major pollutants discharged in the environmental assessment documents of construction projects during the Twelfth Five-Year Plan period, many places have compiled regional accounting rules according to the detailed rules of the Ministry of Environmental Protection. For example, Shanghai Environmental Protection Bureau has formulated the Accounting Rules for Total Amount Reduction of Major Pollutants in the Environmental Assessment Documents of Construction Projects during the Twelfth Five-Year Plan period (Shanghai Environmental Protection Review [2112] No.419). According to the new requirements, the chapter of total amount control in the current EIA document should include the following contents: firstly, briefly describe the relevant requirements of total amount control in China and Shanghai; Secondly, the types of waste water and waste gas discharged by the project and the names of pollutants that should be included in the total amount control category are clarified; Summarize again the measures to be taken in this project, such as improving the level of clean production and comprehensive utilization of resources, and strengthening pollution control; Then fill in the statistical table of the total amount control indicators of the project, and make clear the new amount of pollutants controlled by the total amount of the project, the reduction amount of "bringing the old with the new", and the total amount of pollutants finally added by the total project (the total of existing projects and the newly implemented projects) after the implementation of the project; Finally, make clear the source of the total project balance index.
(3) Risk assessment
Risk assessment has been paid more and more attention in environmental assessment. The Ministry of Environmental Protection has issued the Notice on Further Strengthening the Management of Environmental Impact Assessment to Prevent Environmental Risks (No.77 [2112]) and the Notice on Effectively Strengthening the Management of Risk Prevention and Strict Environmental Impact Assessment (No.98 [2112]), which require a risk review of construction projects. When analyzing the risk or abnormal working conditions, we should communicate with the owner and the design unit, which is consistent with the actual working conditions, and we should not "assume" at will. For example, the dust collector generally only has a reduced dust removal efficiency but does not have a dust removal efficiency of "1", and there is generally no situation that people in the factory stay in the downwind for more than 11 minutes due to a large amount of leakage of "explosive" pollutants; In addition to considering the environmental protection equipment and facilities, there are risks and abnormal conditions of production process equipment. For example, when garbage (hazardous waste) is burned, the incineration temperature cannot reach above 851℃. For reconstruction and expansion projects, we should first analyze and summarize the risks of existing projects, focusing on the same process content, and the risk prevention should reflect "bringing the old with the new". When predicting atmospheric risk, it is not appropriate to choose the average meteorological conditions, and attention should be paid to the representativeness of meteorological conditions. For example, class D stability and average wind speed lack representativeness, and sometimes class E and F stability lack representativeness, while class A and B stability are better. Specific problems should be analyzed, and "trial comparison and selection" can also be adopted.
(IV) Feasibility of drainage pipe acceptance
The feasibility of drainage pipe acceptance in the EIA document should explain the following contents:
(1) First, it should explain the external conditions of the pipe acceptance, whether there is a pipe acceptance at present (or in the near future), the specific location and the distance from the project, whether it is necessary to build an external pipe acceptance, and if necessary, it should explain the construction time node, investment amount, investment conditions, the length and length of the pipe.
(2) capacity of external pipe-receiving: diameter of pipe-receiving, sewage discharge capacity, pipe-receiving capacity at present and surplus pipe-receiving capacity, including "pipe-receiving capacity" in the factory.
(3) management standards: pollutant indicators allowed to be managed, whether the project meets the management standards and how to meet them.
(4) The final destination of the sewage after receiving the pipe, and whether the design capacity, current treatment capacity and surplus capacity meet the requirements of the newly increased sewage volume.
(5) the basic information of the sewage treatment facilities (factories) that will be finally taken over: the sewage treatment process, what kind of wastewater is suitable, and whether it is suitable for the project to discharge wastewater; At the same time, we should also pay attention to whether the wastewater discharge port of the project meets the "shortest distance between pipes".
(6) the final report should comprehensively explain the "compliance" and "non-compliance" of the custody, and attach the custody agreement certificate in the annex.
(V) Public participation
Public participation is an important chapter in the EIA document. The basic requirements are four principles: openness, equality, extensiveness and convenience, and the sensitive protection targets cannot be omitted and should be fully covered. According to the Notice of the Ministry of Environmental Protection on Strengthening Risk Prevention and Strict Environmental Impact Assessment Management (No.98 [2112] of the Ministry of Environmental Protection) and the relevant requirements of Shanghai, when preparing the public participation section of the EIA document, the EIA unit must make two online announcements on the website, publish an announcement in the local newspaper and post an announcement on the information bulletin board of relevant grass-roots organizations; On-site questionnaire survey of construction projects must be carried out after the report is basically completed and the second online publicity; The simplified version submitted to the environmental protection department must include the details of the public participation chapter. When investigators distribute on-site questionnaires, the number of written questionnaires for construction projects with significant environmental risks or impacts should be more than 211, the number of written questionnaires for construction projects that may have greater environmental risks or impacts should not be less than 151, and the number of written questionnaires for other construction projects should not be less than 111. The proportion of written questionnaires for respondents in sensitive targets should not be less than 71%. The design of the questionnaire should be targeted, and different items should be adjusted accordingly to highlight the contents of public concern. The report should be accompanied by the basic information table of the public under investigation, and at the same time, attention should be paid to the representativeness of the respondents, and the distribution map of the participants can be used for illustration. When the public participates in statistical analysis, the opinion that the project is "indifferent" cannot be simply counted as "support", and there should be a return visit to the opposition. If there are more than three opinions, they should be given in a list, and at the same time, the handling opinions should be given in the table. If the owner has a commitment, it is best to attach a letter of commitment. For the conclusion that the opposition is "not adopted", he should be particularly cautious and seriously consider whether the reasons are valid and whether it is an environmental problem. The public participation in reconstruction and expansion projects should increase the relevant contents of "existing projects", which should be reflected in the "public questionnaire" and "online publicity", and the relevant departments should be investigated whether there are complaints, objects and contents of complaints about "existing projects" at present and in the near future, and reflected in the EIA documents.
(VI) Environmental impact during construction
The impact of construction projects during construction on the surrounding areas mainly includes noise, waste gas, sewage and solid waste. In the impact analysis, the construction content, construction method, construction equipment, engineering quantity (such as earthwork balance), construction period and schedule should be explained according to the sequence of construction stages and the division of construction areas; When putting forward mitigation measures, we should not only consider sewage (mud water and domestic sewage), waste gas (dust, waste gas discharge), noise (all kinds of construction noise) and solid waste (muck, waste materials and domestic garbage), but also analyze the construction sequence and construction nodes, and the optimization in this respect can also reduce the environmental impact; Caution should be given to "noise barrier" and fully enclosed transportation during road project construction; Whether to use "commercial concrete" in civil engineering projects should be based on the specific situation; Attention should be paid to the scope of application of the "no construction at night" measure, which is not a necessary measure for any project.
(VII) Environmental protection investment
The environmental protection investment in the EIA document should be listed and itemized as far as possible, and its proportion in the total investment should be given. The data should be provided by the owner and the design unit, and the error should not be too large. The specific precautions in the calculation of environmental protection investment mainly include: (1) Only the direct construction investment related to pollution control can be included in the environmental protection investment, and the single energy-saving construction investment is generally not an environmental protection investment, such as single waste heat recovery and waste heat. (2) Investment in energy-saving construction and workshop sanitation construction, which are too closely related to pollution control, can be included in environmental protection investment. (3) Environmental protection investment provided by owners and design units mostly refers to static investment, and static total investment should also be adopted when calculating the proportion of environmental protection investment. (4) For environmental protection construction projects, the construction investment of the whole project can be totally included in the environmental protection investment. As far as the project itself is concerned, it is still necessary to calculate the environmental protection investment of the project itself for pollution control. (5) "Expansion project", when the first phase of construction, there are often some environmental protection construction contents used in the first phase and the second phase. At this time, the proportion of environmental protection investment in the second phase is often lower than that in the first phase. When this happens, it should be explained in the EIA document and clearly stated in the corresponding "engineering analysis" content.
III. Special Issues in EIA
(I) Issues to be paid attention to in changing EIA
In daily EIA work, we will encounter that the EIA document of the project has been prepared and approved by the environmental protection department, but due to some adjustments in the process or measures of the project itself, it is necessary to prepare a change EIA. The specific change documents are generally in the form of "report corresponding to report form", "report corresponding to report form" and some are "supplementary EIA" (. Some of them are "almost re-compiling the EIA report", and there are many specific plans for specific operations. We should fully communicate with the environmental protection departments and specific personnel responsible for examination and approval, and adopt communication before, during and after the event. The following contents should be paid attention to when compiling the change document:
(1) First, the principles of changing the EIA should be made clear: the reasons (background) of the project change, the construction contents and conditions before and after the change, the resulting changes in environmental protection measures, pollutant discharge methods and emissions, whether these changes will lead to changes in the evaluation level, the degree and scope of environmental impact, the results of public participation, etc., and whether these changes will change the original EIA conclusion.
(2) The changed environmental impact prediction, including grade, scope, method and content, shall be carried out according to the latest guidelines; The evaluation basis, environmental profile and environmental quality should be the latest, and all basic data cited should be "the latest"