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In recent years, illegal dumping of hazardous waste has been repeatedly exposed, leading to numerous chemical enterprises being taken to court and ordered to pay substantial environmental remediation costs. As the Yangtze River basin is home to a dense concentration of chemical plants, pollution levels there have grown increasingly severe. In response, the state has introduced a series of environmental protection policies, and environmental inspection teams have conducted thorough audits of chemical enterprises along the riverbank. Nevertheless, safeguarding the Yangtze remains a long and arduous task. As early as April this year, the Ministry of Ecology and Environment launched “Operation Clean Waste 2019” to crack down on illegal activities involving solid waste, aiming to curb the discharge of hazardous and solid waste along the river and protect the Yangtze. |
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01 Hazardous Waste Storage Facility
Inspection content:
1. Are the warehouse’s measures for wind protection, rain protection, sun protection, leak prevention, and corrosion resistance adequate? Has a leak‑containment collection system been installed?
2. Is a containment dike installed around the hazardous waste storage facility to prevent liquids from spilling outside the facility and to stop rainwater from backflowing into the facility?
3. Are gas venting outlets, gas purification systems, safety lighting fixtures, observation windows, and other such facilities installed within the warehouse?
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Key points of the standard:
1. Hazardous waste storage facilities shall be located outside the premises of warehouses for flammable and explosive materials, as well as beyond the protection zones of high-voltage transmission lines.
2. The floor of the storage area must be hardened and coated with a high-density epoxy layer at least 2 mm thick to prevent leakage and corrosion.
3. A liquid‑leakage collection system (including collection trenches and sumps to capture leachate and prevent overflow or loss) must be provided, along with gas venting outlets and a gas‑purification system. The facility shall also be equipped with safety lighting and observation windows.
4. Areas designated for the storage of containers holding liquid or semi-solid hazardous waste must have a corrosion-resistant, hardened floor with a seamless surface.
5. A containment sump shall be provided to capture leaks, and the volume enclosed by the floor and the sump shall be no less than one-fifth of the maximum storage capacity of the largest container or the total storage capacity.
6. Incompatible hazardous wastes must be stored separately and segregated by designated barriers.
02 Hazardous Waste Storage Containers
Inspection content:
1. Are the containers used to hold hazardous waste intact and undamaged?
2. Have all containers and packages containing hazardous waste been affixed with hazardous waste labels?
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Key points of the standard:
1. Containers used for storing hazardous waste must be intact and undamaged.
2. The material and lining of containers used to store hazardous waste must be compatible with the hazardous waste (i.e., they must not react with one another).
3. Containers used for packing liquid or semi-solid hazardous waste must have sufficient headspace, with at least 100 mm of clearance between the container lid and the liquid surface.
4. Containers used to store hazardous waste must be labeled in accordance with the requirements set forth in Appendix A of the “Standard for Pollution Control on the Storage of Hazardous Waste.”
03 Storage of Hazardous Waste
Inspection content:
1. Is collection and storage carried out in accordance with the classification of hazardous waste characteristics?
2. Do the stacking height, wall clearance, and other parameters comply with relevant standards?
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Key points of the standard:
1. The foundation must be impermeable; the impermeable layer shall consist of a clay layer at least 1 meter thick (with a permeability coefficient ≤ 10⁻⁷ cm/s), or high-density polyethylene with a thickness of at least 2 mm, or another synthetic material with a thickness of at least 2 mm and a permeability coefficient ≤ 10⁻¹⁰ cm/s.
2. Enterprises must collect and store hazardous waste in accordance with its characteristics, and incompatible hazardous wastes must not be stored together.
3. The liner shall be placed on a foundation or base; it must be capable of covering the area potentially affected by hazardous waste or its leachate; the liner material must be compatible with the hazardous waste being stored; and a leachate collection and removal system shall be designed and constructed on top of the liner.
4. Hazardous waste piles shall be protected from wind, rain, and sunlight.
5. Hazardous wastes of the same type contained in containers may be stacked; a handling aisle shall be provided between each stack.
04 Storage Management
Inspection content:
1. Is there a hazardous waste ledger, and, in conjunction with this ledger, verify whether the types, quantities, and disposal methods of the enterprise’s hazardous waste are consistent with those specified in the environmental impact assessment?
2. Hazardous Waste Transfer Manifest (whether the hazardous waste transfer plan has been approved, and whether the enterprise has accurately completed the “Producer” section of the manifest and affixed its official seal)
3. Has a sound system for the prevention and control of hazardous waste pollution been established? Are the responsible persons clearly designated with well-defined responsibilities, and are they familiar with the relevant laws, regulations, systems, standards, and specifications governing hazardous waste management?
4. Are hazardous wastes transferred in a timely manner?
5. Status of locking the hazardous waste storage facility.
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Key points of the standard:
1. Both hazardous waste generators and operators of hazardous waste storage facilities are required to maintain records of hazardous waste, which shall specify the waste’s name, source, quantity, characteristics, the type of packaging container, date of receipt, storage location, date of dispatch, and the name of the receiving entity. Such records and accompanying manifests must be retained for a period of three years following the return of the hazardous waste.
2. The hazardous waste storage room shall be managed in accordance with the “dual‑person, dual‑lock” system. (The two keys shall be held by two designated hazardous waste managers; no single individual may hold both keys.)
3. Hazardous waste shall not be stored for more than one year; if storage exceeds one year, approval must be obtained from the environmental protection authority.
05 Safety Protection of Storage Facilities
Inspection content:
1. Are hazardous waste storage areas equipped with hazardous waste warning signs and labels, and are these signs accurate, clear, and intact?
2. Are the hazardous waste storage facilities equipped with emergency protective equipment, fire-fighting facilities, and other such measures?
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Key points of the standard:
1. Facilities and sites used for the storage of hazardous waste shall be equipped with both hazardous waste warning signs and hazardous waste labels, which must be affixed to the warehouse door or on both sides of the door.
2. A perimeter fence or other protective barrier shall be installed around hazardous waste storage facilities.
3. Hazardous waste storage facilities shall be equipped with communication devices, lighting systems, personal protective equipment, and tools, and shall include emergency response and protection facilities.
Common hazards:
1. The hazardous waste storage facility is non-compliant;  |
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2. Hazardous waste labeling is non-compliant; |
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3. Timely transportation of hazardous waste is not ensured; |
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4. Self-built hazardous waste treatment units and facilities are not in operation;
5. Some enterprises do not maintain clear and detailed records of hazardous waste;
6. Hazardous waste has not been effectively segregated;
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7. Failure to submit information related to the dynamic management of hazardous waste on time and to implement the manifest system.
06 Procedure for Obtaining a Hazardous Waste Handling Permit
1. Preparation of application materials.
2. The applying entity shall submit the application materials to the Provincial Department of Environmental Protection.
3. Technical Review. The Provincial Environmental Protection Department has entrusted the Provincial Hazardous Waste Management Center to conduct a technical review of the submitted materials and to carry out on-site technical inspections of the applicant organizations.
4. Approval. The Provincial Department of Environmental Protection shall review the submitted materials and the conclusions of the technical assessment. For applications that meet the approval requirements, a public notice shall be posted; upon expiration of the notice period, a hazardous waste operation permit shall be issued. For applications that do not meet the approval requirements, the application shall be rejected, and the applicant shall be notified in writing with an explanation of the reasons.
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If interprovincial transfer is required, a hazardous waste transfer manifest must be completed. The manifest consists of five copies:
After the first and second copies of the joint form are completed, they shall be stamped with the official seal, submitted to the transport unit for signature and verification, and then retained by the submitting party for record‑keeping.
After the second copy is completed by the generating unit, stamped with the official seal, and verified by the transport unit through signature, it shall be submitted to the local environmental protection administrative authority for filing.
The second copy of the auxiliary certificate is handled in the same manner as the first, with the generating unit submitting it to the environmental protection authority at the place of departure for archival purposes.
The third copy of the document is handled in the same manner as the first and is filed by the transport unit.
The fourth copy is handled in the same manner as the first and is filed by the receiving unit.
The fifth copy shall be handled in the same manner as the first copy and filed by the environmental protection authority of the receiving locality.
The retention period for the manifest is five years; for hazardous waste, the retention period of the manifest shall be the same as the storage period for such hazardous waste.
Summary
Environmental inspections are becoming increasingly stringent, and reports of chemical companies and industrial parks relocating along the Yangtze River are emerging one after another. Yet the path to remediation and governance remains fraught with challenges. First, legacy pollutants have yet to be fully addressed, while new sources of pollution continue to surface; second, many enterprises still rely on production processes that generate substantial hazardous waste. Relying solely on relocation or setting distance requirements addresses symptoms rather than root causes—moving away from the Yangtze may simply shift pollution to other areas. The “2019 Waste Cleanup Campaign,” which spans 11 provinces and 126 cities, not only seeks to standardize hazardous‑waste discharge and production practices among riverside chemical firms but also aims to complete environmental remediation efforts to protect the Yangtze’s waterways. Riverside chemical companies should take note: a mechanism for monitoring and managing solid waste is set to be established, so they must act swiftly to comply with these new requirements.
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