In order to improve the water quality of rivers within the jurisdiction and enhance the environmental quality, in addition to the previous inspection and control of water pollution sources, the Bureau will actively promote the overall control plan of water environment in accordance with the characteristics and sources of pollution of the river water to create a comprehensively safe, comfortable and beautiful recreational river space. Therefore, the Bureau sets up the 2016 Plan of Changhua County’s Implementation of Water Pollution Source Inspection, Water Pollution Fee Collection Check and Total Volume Control (hereinafter referred to as the "Plan"). It is hoped that through the implementation of this Plan, the pollution sources within the jurisdiction of the city can be registered in order to facilitate follow-up control operations.
The implementation period of the Plan’s selection notes and bidding standard work started from the next day of the signing date (February 23, 2016) to November 2016, and implementation of the expanded-procurement bidding standard work started from the next day of the bid closing date (April 28, 2016) to November 30, 2016. The implementation of this Plan ended on November 25, 2016, and the implementation rate of both the bidding standard work and the expanded-procurement bidding standard work is 100%. The results of the final report are summarized as follows:
1. Assisting in the promotion of total waste (polluted) water discharge volume control measures for Changhua County’s 2nd and 3rd River in the East and West
(1) Assisting in the follow-up legally-required operations after the total waste (polluted) water discharge volume control area of Changhua County’s 2nd and 3rd River in the East and West was delineated
The year’s Plan follows up on the previous year’s plan to assist in various legal operation procedures. On March 21, 2016 the revised control measures were completed and submitted to the Environmental Protection Administration for review, and revisions were made in accordance with the Environmental Protection Administration’s view. The Environmental Protection Administration approved the control measures on April 28, 2016 and the Changhua County Government announced the "total waste (polluted) water discharge volume control measures for Changhua County’s 2nd and 3rd River in the East and West" on May 17.
In order to facilitate the follow-up control of the total volume control area, the Environmental Protection Bureau held a "Meeting on the Discussion of Power and Responsibility Division for the Total Waste (Polluted) Water Discharge Volume Control Area of Changhua County’s 2nd and 3rd River in the East and West" for the Plan on August 5, and invited the Industrial Development Bureau, Ministry of Economic Affairs, Construction Department of Changhua County Government and Changhua Farmland Water Conservancy Association to discuss on issues such as the implementation strategy, division of powers and responsibilities of the control measures and the holding of regular meetings on the control of the total volume control area, in order to reach a consensus on the control measures for the total volume control area.
(2) On-site inspection of the controlled businesses in the total volume control area
The work is divided into two stages. The first stage focuses on the confirmation of all the waste water projects of the controlled businesses in the total volume control area, the concentration survey and the confirmation of the locations of the outflow ports (to make sure whether the water acceptors are the 2nd and 3rd River in the East and West). The second stage follows up on the objects in the investigation of the first stage which have heavy metal in the raw water, and executes the inspection of the operations of wastewater treatment facilities. If the objects are suspected of secretly discharging wastewater or do not have the intention to improve the defects of facilities, the Environmental Protection Bureau personnel in charge will be asked to arrive at the site to investigate and deal with the irregularities.
As of October 27, the inspection in the first phase of the Plan has been completed for 47 controlled manufacturers in the control area. The wastewater quality of 25 manufacturers does not meet the discharge water standard, and the wastewater quality of 34 manufacturers does not meet the irrigation water standard. Compared with the number of wastewater pipes, their purposes and concentration ratio recorded in the licenses, the number of wastewater pipes all corresponds to the information in the license, the purpose of wastewater pipes of 32 manufacturers does not correspond to the information in the license and the quality of wastewater does not meet the irrigation water standard, and the heavy metal content 19 manufacturers does not correspond to the information in the license. For those manufacturers who exceed the irrigation water and discharge water standards, after telephone counseling of the Plan, 25 of them already submitted their changes made to the licenses before the announcement. A list of those which have not submitted their changes made to the licenses before the announcement has been sent to the Environmental Protection Bureau for the counseling of the Industrial Development Bureau to control the concentration and quality of water at the source of the manufacturing process. After the confirmation of the locations of the outflow ports, the water pipes of manufacturers which are not controlled are located in the 2nd and 3rd River in the East and West, and the water is discharged into Yafan Ditch (16 manufacturers), Yangtsitsuo Creek (17 manufacturers) and Wu Creek (6 manufacturers). According to the contract, in the second stage the inspection of at least 74 manufacturers should be completed. Currently the inspection has been completed for 41 electroplating manufacturers, 10 dyeing and finishing manufacturers and 7 metal surface treatment manufacturers; a total of 83 manufacturers. After the second inspections, three manufacturers were further inspected on-site with the presence of the personnel in charge. The three manufacturers were punished due to violation of the relevant provisions of the Water Pollution Control Law, and the violations are operation of waste water treatment facilities not in compliance with the contents of the license, discharge water quality not meeting the water discharge standard, and on-site records not comprehensively retained (for 5 years).
(3) Inspection of manufacturers in the total volume control area which are not controlled
As of October 27, 132 manufacturers in the total volume control area which are not controlled were inspected, and six of them were found not in compliance with the definition of manufacturer in the Wastewater Law, including four metal surface treatment manufacturers, one dyeing and finishing manufacturer and one manufacturer of other types. The personnel in charge ordered the manufacturers to suspend work site, and the relevant punishments are in the process of being issued.
(4) The total volume control measures for water bodies in the total volume control area were planned
The "Control Measures for Total Waste (Polluted) Water Discharge Volume Control Area of Changhua County’s 2nd and 3rd River in the East and West" was announced on May 17, 2016. To protect the water quality of specific water bodies (the 2nd and 3rd River in the East and West in the total volume control area and their irrigation and drainage systems), the control strategies and measures for the total volume control area are proposed in the Plan, covering the seven aspects of source reduction, pipe end treatment, centralized treatment, permit management, inspection control, irrigation waterway inspection, regular monitoring of water quality and integration of water quality monitoring data. Furthermore, the relevant authority units based on the division of powers and responsibilities for implementation of various control strategies and measures include Construction Department of Changhua County Government, Industrial Development Bureau of Ministry of Economic Affairs, Changhua Farmland Water Conservancy Association and Changhua County Environmental Protection Bureau. Through meetings for discussion on the division of powers and responsibilities, issues such as implementation of relevant control measures for the total volume control area, strategies and measures as well as division of powers and responsibilities and holding of regular meetings for control measures in the total volume control area were discussed in order to reach a consensus on the implementation of control measures for the total volume control area.
(5) Analysis on the trend of water quality change in the total volume control area
In order to understand the water quality improvement effect of the water bodies after the announcement of implementation of the total volume control area, the locations of the water quality monitoring stations of the Environmental Protection Bureau and Changhua Farmland Water Conservancy Association were used by the Plan as the indicator stations to track and evaluate the water quality change and improvement. According to the results of heavy metal water quality testing of the 12 monitoring stations in the total volume control area from 2000 to January to August 2016, the heavy metal of irrigation water in the 12 stations showed an improvement trend. From January to August 2016 the overall achievement rate of the water quality monitoring stations in the total volume control area reached 98.3%, and the overall achievement rate of the water quality monitoring stations of the Changhua Farmland Water Conservancy Association reached 100% (only the period of January to June 2016 was analyzed due to the time difference of the announcement of Changhua Farmland Water Conservancy Association’s testing data).
From the overall achievement rate it can be found that from 2000 to 2012 the heavy metal achievement rate showed a slow rate of growth, but from 2013 onward it showed a significant increase. Up to today it maintains a rate close to 100%, indicating that the water quality in the total volume control area of Changhua County’s 2nd and 3rd River in the East and West has significantly improved from 2000.
2. Filing, reviewing and inspecting water pollution and control fee documents
(1) On-site inspection of companies categorized in the first stage of fee collection with no permits
As of October 27, 2016, on-site inspections of a total of 217 manufacturers were completed, of which 32 were in violation of the Water Pollution Control Law and produced wastewater, 53 did not produce waste water, and 4 produced non-contact cooling water only. Of the other 92 manufacturers, 86 had no processing equipment, and are amended as "permanent shutdown" in the operational status of the water system control. Among six of them, because the processing machines were not yet removed, it is necessary for them to put forward the soil testing and remove the on-site processing equipment to be removed from the control list. They are amended as "temporary shutdown" in the operational status of water pollution control. The other 36 manufacturers had their doors locked, but there was no abnormal discharge of wastewater around the sites.
(2) On-site inspection of companies categorized in the first stage of fee collection
As of October 27, inspections of a total of 150 manufacturers were completed, and the inspection work includes inspection of the comprehensiveness of the record and inspection of the discharge water volume and quality inspection report. On the site the Environmental Protection Bureau personnel collected the raw wastewater and discharged water for analysis and the results were compared with the concentration value at outflow ports reported in the second half of 2015. Those with a difference of more than 20% were reported to the Environmental Protection Bureau for subsequent reference after the on-site inspection. According to the on-site inspection results, a total of 67 manufacturers were punished due to violation of the Water Pollution Control Law, and the violation rate is 44.7%. The Environmental Protection Bureau has imposed punishment according to law.
(3) On-site inspection of companies on the water pollution control fee suspension list
This work is mainly based on the assessment item of "Water Pollution Control Fee Collection and Implementation" in the Environmental Protection Administration's assessment scheme for 2016 River Pollution Remediation Plan, and the inspection list was provided by the Environmental Protection Administration. The Environmental Protection Administration provided the first inspection list on January 15, 2016, which contained manufacturers whose reported chemical oxygen demand (COD) concentration was below the maximum discharge water standard of 10% in the first term (May and June) in the water pollution control fee reporting. There were 40 manufacturers in the county. The second inspection list contained manufacturers whose reported water discharge was 0 or significantly less than in the first term (May and June) in the water pollution control fee reporting of the second term (July to December) in 2016. There were 16 manufacturers in the county. The total number of manufacturers on the exception list in the first and the second batch was 56. According to the exception list audit results, flow meter calibration accounts for the most cases, followed by the lacking of processing facilities maintenance record. In the first stage there were 21 manufacturers with discharge water COD higher than the standard of 10%. The results of the Plan have been submitted to the Environmental Protection Bureau for further submission to the Environmental Protection Agency for collection.
(4) Trial calculation of fees payable for enhancement of water pollution control
A total of 423 manufacturers were inspected, including 217 manufacturers with no permits. In the first stage 150 manufacturers were inspected for fee collection, and 56 for being suspected on the water pollution fee list. A total of 128 manufacturers were non-compliant, of which 32 were manufacturers with no permits; in the first stage 67 manufacturers inspected for fee collection were non-compliant, and 29 were for being suspected on the water pollution fee list. The amount declared by the 108 manufacturers with no non-compliance was NT$639,643, but after the on-site inspection, the declared amount due to non-compliance was NT$54,295,722. The total amount of increase was NT$54,180,529.
(5) Water pollution fee trial calculation and exception list
In 2017, the third year of levying the water pollution control fee (the first year of levying by the animal husbandry with a preferential rate of 70%), the expected amount of levy is NT$25,658,986, of which NT$15,805,850 is from manufacturers and the industrial area’s sewage system and NT$9,853,136 from the animal husbandry, which account for 61.60% and 38.40% of the 2017 water pollution fee levies respectively.
In the water pollution control fee reporting period (reporting in January 2016) from June to December 2015, a total of 69 manufacturers were non-compliant, including two manufacturers with circumventing water discharge, 25 not obtaining permits in accordance with the law, 35 with discharge water exceeding the discharge water standard, and 10 with the flow meter not regularly calibrated or recorded. In the second term of water pollution control fee in 2015, the total additional water pollution fee to be paid by manufacturers was NT$3,525,896, including NT$3,103,606 from 25 manufacturers not obtaining permits, accounting for 88.02% of the total amount of additional water fee to be paid. Most of the manufacturers may not clearly understand the water pollution control fee charging method, resulting in water pollution fee reporting not in compliance with the method for manufacturers in violation of the regulation, or the wrong item being reported, thus causing a shortage in water pollution fee payment. A small number of manufacturers overpaid the water pollution fee due to water quality value reporting errors.
(6) Holding water pollution control fee advocacy seminars
In order to assist the manufacturers to quickly and surly understand the relevant laws and regulations, and be familiar with the operation of water pollution source control information management system and the Water Pollution Law related information disclosure platform for the sake of information disclosure, the Bureau invited controlled manufacturers in Changhua County to attend the three seminars. Three sessions of the Water Pollution Control Law and the Water Pollution Fee Collection Method Advocacy Seminar were completed for the Plan on March 9 and 10, 2016 (Wednesday and Thursday), with 792 manufacturers attending. The attendance rates were between 48.1% and 64.1%. Non-attending manufacturers were classified as those to be further inspected in the hot zone. If they are not located in the hot zone, the personnel in charge will promote the policy by phone and remind them of the relevant provisions of the Water Pollution Law.
3. Implementing scientific inspection and control of water pollution sources
As of October 27, the inspection of 100 manufacturers in the pollution hot zone has been completed for the Plan, including the sampling of 28 manufacturers with water discharge. In the inspection process, five manufacturers were found to have circumventing water discharge, and one which should have been shut down were found to be still working. During the inspection the Plan’s personnel preserved the evidence on the site and notified the Environmental Protection Bureau to arrive at the scene for the issuing of penalty. One of the manufacturers with circumventing water discharge was detected by the police and the prosecutor together.
4. Handling application approval and database management matters
This work is an expansion of the procurement work, and the implementation period was from Aril 29 to November 30, 2016. The following is a summary of the implementation results of the work as of October 27:
(1) Assisting in the water pollution control plan and handling and reviewing the approval of all types of applications
The Plan assisted in the review of all types of permit applications, with a total of 1,638 permit applications processed. The current types of permits are classified into the following six categories: water pollution control plan permit, surface water discharge body permit, simple discharge permit, storage permit, soil discharge permit and runoff wastewater reduction plan permit. Except the soil discharge permit which has no application for, the applications for the remaining types of permits are shown in Table 5.2.1-1. From the table it can be seen that the surface water discharge body permit has the most applications of 651, accounting for 39.7% of the total applications, followed by the simple discharge permit of 551, accounting for 33.6%.
(2) Assisting in handling on-site surveys of the applications
On-site surveys were handled in accordance with the provisions of Article 27 of the Measures for Water Pollution Control and Permit Application Review, and assistance was provided to 34 cases of on-site surveys, with a non-compliance rate of 76%. The analysis of non-compliant items clearly shows that regardless of the type of application, non-compliance of processing units and processes has the highest rate, with a total of 16 cases. The main reason for this anomaly should be that the agencies which filled out the form on behalf of the manufacturers did not verify whether the site configuration is consistent with that in the permit. There were 15 cases of sewage disposals, including 13 technician certifications. The site surveyors have informed the manufacturers to make an improvement at the site, and requested follow-up documents verifying the completion of the improvement in order to facilitate the follow-up application of changes to the registered documents.
(3) Assisting in the internet disclosure of manufacturers’ systems or sewage systems
After the issuing of the water pollution control permit, the Plan’s personnel notify the manufacturer to check the content of the permit. If the content is incorrect, the applicant shall submit a statement for correction. Finally the manufacturer shall publish the water pollution control permit. The Plan then assists to have the first page of the water pollution control permit disclosed on the EPA designated website, and issues certification. As of October 27, from April to October there were totally 134 certificates issued, and the water pollution control permits and their first pages have been fully disclosed.
For the Plan the approved water pollution control permits (documents) of 1,494 manufacturers and sewage systems of the 1st to the 5th echelon which are required by the EPA to be disclosed on the website have been produced. There are 547 manufacturers in the 1st echelon, and the disclosure completion rate is 97%; 147 out of the 151 manufacturers in the 2nd echelon have had their permits disclosed, and the disclosure completion rate is 97%; 180 out of the 189 manufacturers in the 3rd echelon have had their permits disclosed, and the disclosure completion rate is 95%; 26 out of the 27 manufacturers in the 4th echelon have had their permits disclosed, and the disclosure completion rate is 96%; all the 528 manufacturers in the 5th echelon have had their permits disclosed, and the disclosure completion rate is 100%. As of October 27 there are 1,410 manufacturers that have had their permits disclosed. There are still 84 manufacturers in the 1st to the 5th echelon that have not had their permits disclosed, of which 83 are temporarily suspended manufacturers, and one has its permit contents concealed and not disclosed.
From January 1, 2017 onward all the water pollution control permit application and periodic reporting for the manufacturers’ or sewage system are required to be processed via internet transmission. In this Plan three general seminars and four seminars specifically to the controlled manufacturers have been held for the promotion of regulations and the convenience of online reporting. Currently 747 manufacturers have been consulted to change from reporting in writing to voluntary online reporting.
(4) Filing and managing water pollution control related computer database and documents
During the implementation of the Plan, the Bureau assisted in the completion of data filing, including 31 (1%) water pollution control documents, 1,380 (60%) water pollution source voluntary filing documents and 875 (39%) inspection and punishment information filings. By the types of documents, among the water pollution source voluntary filing documents, there were 1,234 records of regular monitoring and test reporting which account for the most; among the inspection and punishment information there were 719 inspection records which account for the most. The highest number of total files occurred in April 2016, and they were mainly water pollution source voluntary filing documents, with 568 records of regular monitoring and test reporting which account for the most.
(5) Reviewing and filing declaration information of waste (sewage) water inspection
The following is an analysis of the Plan on the semi-annual reporting in the second-half of 2015, the semi-annual reporting in first half of 2016, the first quarterly reporting in 2016, the second quarterly reporting in 2016, the third quarterly reporting in 2016, and the fourth quarterly reporting in 2016. There are 2,252 manufacturers which are controlled under the Water Pollution Control Law and need to regularly file reporting to the authority. Most of them are in animal husbandry, followed by the metal surface treatment industry. Among them 20 manufacturers shall file reporting every quarter (of which 4 do not need to report every quarter), and the actual number of manufacturers which filed reporting was 16. 1,094 manufacturers shall file reporting every six months, and the actual number of manufacturers which filed reporting was 1,094. 23 manufacturers shall file reporting every year, and the actual number of manufacturers which filed reporting was 23. The reporting rate was 100%.
5. Stable operation of the water quality and quantity automatic survey (monitoring) system and connecting and transmission facilities
In the County there are 41 manufacturers which meet the condition of installing connected automatic continuous monitoring facilities, including four with special sewage systems for industrial areas with a water discharge volume over 2,000 CMD as in the first announcement, one non-power plant manufacturers with water discharge volume over 15,000 CMD as in the second announcement, two non-power plant manufacturers with water discharge volume over 5,000 CMD as in the third announcement, and 34 with major violations. Among them those with major violations are still in the process of resuming the relevant work procedures and have not yet formally resumed their work, and those in the third announcement are also at the processing stage. Therefore there are actually a total of 23 manufacturers that are connected. During the course of the Plan there were 16 abnormalities, some of which were caused by the abnormalities of the interception program developed by the CWMS system personnel, resulting in the data transmission being too slow and the system web page not presenting the real-time data. In addition, during the period manufacturers’ data could not be uploaded to the Bureau’s server. The Plan’s personnel actively contacted the EPB’s personnel in charge, the information staff, the CWMS system personnel and the EPA’s personnel in charge to carry out system repair. If the Plan’s personnel find any abnormality in the daily inspection, they will immediately notify the manufacturer and confirm the cause of the abnormality. After reporting to the personnel in charge, they will continue to pay attention to the repair situation and notify the personnel in charge after the completion of the repair.
