To comprehend and evaluate county (city) permit reviewing agencies, public and private premises’ implement suggestions and encounter problems since permit management regulations of stationary sources pollution amended in 2019, we managed to continuously improve the regulations. Moreover, to be in line with the revision of management regulation of periodic inspection and strengthen the quality and administration of permit personnel, we promoted the legalization of premises integration and the quality and quantity of periodic inspection, evaluated the management of permit applicants and reviewing personnel, check of technician visa, and updated the expand functions of stationary pollution sources management information system and database quality inspection. According to our goals, the project was divide into 4 major parts, including 1) stationary pollution sources management, 2) periodic inspection control, 3) permit regulation personnel, 4) system supporting tools. The following work respectively according to the content of the project descriptions are as follows:
Considering the revision of management regulations of stationary sources pollution in 2019, the planning of classification of permit management, expansion of simplified administration and horizontal connection of permit regulation amendment was necessary. Therefore, we collected the relevant permit management systems of Southern California, United States, and planned management methods of the whole plant, manufacturing process, and verification. In addition, we eliminated sources with minor emission, simplified the fuel permit application process and integrated with the revised periodic inspection regulations. Furthermore, we summarized the explanatory letters related to the permit administration law in the last five years, and to review measures for permit administration before and after. Based on the results, we adjusted the third-category permit application and review procedures, operating permit verification content, fuel use permit application simplification, environmental assessment verification items, control equipment and instrument settings, and revised guidelines for permit reviewing according to adjusted content.
To response to the addition of third-category stationary pollutions sources in the permit administration, we analyzed the current control state of the first to eighth permit batches. The results revealed that there were about 1,477 permits’ operations using non-toxic substances with annual emission of particles, SOx, NOx and VOC all less than 0.5 metric ton, and about 305 permits’ operations with annual emission of particles, SOx, NOx and VOC all less than 1 metric ton. The added third-category permits are mainly located in Taoyuan City, Taichung City, Changhua County,Tainan City and Kaohsiung City. To increase permit reviewing efficiency, simplified procedures such as combining installation and operating permit application, simplifying the technician visa and supplying alternative plan for commissioning and inspection are available. In the announcement conditions part, we evaluated the management of organic solvents in manner of pure materials, similar with air pollution fee collection and labor safety related hazardous workplace control. Thus, we adjusted the calculation method for the amount of organic solvents and acid-base solutions based on the percentage of organic solvents or acid-base solutions. In order to increase the permit management percentage of VOCs in stationary pollution sources, the annual consumption of the 9 batch of organic solvents or acid-base solutions over 5 metric tons should apply for a permit, excluding organic solvent content less than 10%. 1,290 metric tons/year VOCs emissions are expected to be managed. Besides, we also evaluated waste recycling process draft and managed to involve processes such as hot melting and sludge drying for waste plastic reuse. Regarding boiler management for the whole plant, it is expected to manage 167 steam boilers, after involving boilers with the total steam evaporation more than 5 metric tons/hour in the whole plant, regardless of fuel type, and eliminating natural gas boilers with the total steam evaporation less than 20 metric tons/hour in the whole plant.
The revised permit administration in 2019 has limited the inspection species and verified the purpose of emission standard, which mildly solved the various species problem in commissioning and lower the number of inspections about 40%. To revise permit administration and regulation relevant with dedicated personnel, we reviewed periodic inspection regulation as priority, and planned two-staged inspection management regulation, the first stage remained the current independent management system for public and private premises, and provides better self-management frequency adjustment specifications to reduce the inspection word load, which was estimated to reduce by 45% of the number of testing pipelines. Furthermore, to enhance the representativeness of testing and encourage public and private premises to maintain more autonomously and strengthen honest reporting, the connection between revised inspection regulation and permit air pollution emission test plan and the regulation that premises’ dedicated personnel were asked to perform supervision during inspection were set. In second stage, the new functional evaluation system is added to randomly check and coordinate the inspection time of public and private premises. Besides verifying the autonomously maintenance of premises, the system can also provide the solution for the implementation issue of audit. The evaluation results can extended to be used to the coefficient review. However, the inspection regulation of public and private premises will still need to be in line with the environmental inspection law formulated by the Environmental Analysis Laboratory in the future, through third-party inspection regulation for fineness and fairness for the whole inspection law.
Coordinating with the revised inspection regulation, the 1 and 2 batches of inspection announcement conditions were also revised and integrated with object announced with periodic inspection and regulations for the inspection period authorized by Air Pollution Act Article 22. Moreover, the third-batch of inspection announcement conditions was evaluated to simplify the administration. We not only adjusted the evaluation perspective of periodic inspection regulation through actual supervision and verification operation of premises’ inspections, but also held supervision education training of inspection for reviewing personnel to be familiar with on-site inspection process and strengthen the supervision ability.
To promote the implementation of various regulation of stationary pollution sources, we grasped the permit personnel executive problem, and analyzed the current situation of permit applicants, reviewing personnel and environmental engineering technicians. To solve the permit management problems, permit applicants will be asked to reveal their basic information, and the permit application should be restricted by the dedication personnel regulation. The guideline of air pollution technician visa examination was evaluated, refer to the practice of the Department of Soil and Water Conservation, for the quality of exemption of technician visa. To enhance the quality of management of reviewing personnel, the system plan of personnel selection, education and usage were established. Moreover, 4 education and training meeting about permit common cases, system functions and execution performance were held to enhance the professional ability of reviewing personnel. In the part of management and implementation of performance appraisal to local authorities, 150 cases of permit on-site verification operation and 30 cases of verification of technicians visa were performed, furthermore, the permit application and issuance of public and private premises transferred from the temporary factory registration or the unregistered factory to the specific factory registration were also grasped.
Stationary pollution sources management information system included permit application and issuance, periodic inspection declaration and the update and operation of the big data database of permit control. To strengthen the information management of stationary pollution sources, this year (2021) we integrated the connection with the information system, revealed the basic information of permit applicants, added the declaration function of the periodic inspection and the declaration and reviewing of the functional inspection. Furthermore, in data quality improvement part, a total of 19,151 factories were under management, and more than 7,000 public and private premises have been managed. To maintain the system and data quality, we performed 10 times of data checking operation till November, 2021. The average corresponding rate of data is 90.8%.
