The new "Standards for Pollution Control of Hazardous Waste Storage" has been released. How should enterprises respond to it?

The Ministry of Ecology and Environment and the State Administration for Market Regulation jointly issued the newly revised "Pollution Control Standards for Hazardous Waste Storage" (GB 18597-2023), which will come into effect on July 1, 2023. The new version of the standard has made significant revisions compared to the original one. To facilitate enterprises in better implementing and promoting the new standard, conducting self-inspections and rectifications, we have compiled the following contents for you. Let's take a look at the important changes in the new standard. 

Type of storage facilities 

The original standard mainly stipulated the pollution control requirements for two types of storage forms of hazardous waste - warehouse-style and stacking. This revision, based on actual circumstances, has refined the hazardous waste storage facilities into four types: storage warehouse, storage site, storage pool, and storage tank area, in order to meet diverse storage needs. 

The storage facility is a warehouse-type storage structure, which can be used to store various types of hazardous waste. 

2) The storage site is an open storage facility with a rain-proof roof (cover), mainly used for storing large quantities of hazardous waste that do not produce toxic or harmful gases. 

3) The storage pool is a rainproof structure of a pool-like structure, used for storing liquid or semi-solid waste of a single category. 

4) The storage tank area is a fixed storage facility consisting of one or more tanks and related ancillary facilities, used for storing liquid waste. 

2. Requirements for the location selection of storage facilities 

The revised standard modification document for storage facilities stipulates that "the location of the hazardous waste centralized storage facility and the distance from it to the surrounding population shall be determined based on the conclusion of the environmental impact assessment, and it must be approved by the environmental protection administrative department with the approval authority." The new standard further improves the location requirements for hazardous waste storage facilities, including the need to comply with laws and regulations, planning, and the "three lines and one list" ecological environment zoning control requirements. They should not be selected in the ecological protection red line areas, long-term basic farmland, and other areas that require special protection. They should not be selected in the riverbanks, lake shores, canals, channels, reservoirs, and the floodplain and slopes below the highest water level of the reservoirs. Also, they should meet the distance from surrounding environmental sensitive targets clearly stipulated in the environmental impact assessment documents. 

3. Construction requirements for storage facilities 

The new standard sets more detailed requirements for the construction of storage facilities compared to the original standard. It systematically presents general regulations for storage facility construction and the specific requirements for various types of storage facilities: 

In the storage facility, appropriate partition and isolation measures should be taken based on the type of waste. Corresponding pollution prevention measures such as containment of liquid accidental leaks, collection and purification of gases, and prevention of leakage should also be implemented according to the hazardous characteristics and pollution routes of the stored waste. 

2) The storage site should pay special attention to preventing the entry of external liquids such as rainwater and surface runoff. At the same time, it should also ensure the collection and diversion of wastewater and waste liquid within the site, so as to avoid increasing the amount of waste during the storage process and guarantee that the waste does not spread or leak. 

3) For the storage pool, special attention should be paid to strengthening the overall seepage prevention of the pool body and the foundation seepage prevention. At the same time, measures should be taken to prevent rainwater and runoff from flowing in, as well as to prevent unorganized emissions of atmospheric pollutants. 

4) For the storage tank area, special attention should be paid to the construction of the retaining walls, as well as the implementation of anti-seepage and anti-corrosion measures, as well as measures to prevent and control accidental liquid leakage. The wastewater and waste liquid collected within the retaining walls should be properly handled. 

4. Specific requirements for the storage repository 

The storage depot is the most common hazardous waste storage facility for enterprises. The detailed requirements are as follows: 

1) Surface Sealing - Surface sealing mainly targets the floor and the baseboard. The original standard's requirement that "the floor and baseboard should be constructed with sturdy and leak-proof materials" was rather general. The new standard is more practical and stipulates that the surface sealing material should be compatible with the materials or pollutants it comes into contact with. It can use anti-seepage concrete, high-density polyethylene film, sodium-based bentonite waterproof blanket, or other materials with equivalent sealing performance. 

2) Basic Sealing - For solid hazardous wastes that do not easily hydrolyze or volatilize under normal temperature and pressure, they can be classified and stored separately. That is, the stored hazardous wastes directly come into contact with the ground. In this case, basic sealing measures should be taken. The sealing layer should be at least 1 meter thick clay layer (with a permeability coefficient no greater than 10 -7 cm/s), or at least 2 mm thick high-density polyethylene film and other artificial sealing materials (with a permeability coefficient no greater than 10 -10 cm/s), or other sealing materials with equivalent sealing performance. The requirements for basic sealing are the same as the original standards. Considering that most enterprises use containers and packaging to store hazardous wastes and do not allow the wastes to directly contact the ground, not all storage facilities need to adopt basic sealing. 

3) Partitioning - The original standard only stipulated that "incompatible hazardous wastes must be stored separately and have isolation barriers between them". The new standard now requires that storage facilities should be divided into different zones according to the types of hazardous wastes. Isolation measures should be taken between different storage zones, and these measures can be implemented using passageways, partitions or walls, etc., depending on the characteristics of the hazardous wastes. 

4) Liquid Leak Containment Facilities - The original standard merely stipulated that all hazardous waste storage warehouses should be designed with containment skirts. The volume enclosed by the ground and the containment skirt should be no less than 1/5 of the maximum storage capacity or total storage volume of the largest containment vessel. In practice, only the storage of liquid waste may have leakage issues. The new standard clearly states that for liquid hazardous waste stored in storage facilities or through storage zones, liquid leak containment facilities should be provided. The minimum volume of the containment facilities should not be less than the maximum liquid waste container volume of the corresponding storage area or 1/10 of the total liquid waste storage volume (the larger value). 

5) Leachate collection facilities - The original standard merely stated that all hazardous waste storage facilities should be equipped with liquid leakage collection devices. The new standard clarifies that such collection facilities are only necessary when storing hazardous waste that may produce leachate. Not all facilities for storing liquid hazardous waste need to be equipped with liquid collection devices. 

6) Gas outlet and purification device - The original standard merely stipulated that all hazardous waste storage facilities should be equipped with gas outlet and gas purification devices. The new standard, however, has made clear requirements. For hazardous waste storage facilities that generate dust, VOCs, acid mist, toxic and harmful atmospheric pollutants, and irritating odors, gas collection devices and gas purification facilities should be installed. 

7) Observation Window - The original standard stipulated that all hazardous waste storage warehouses must be equipped with observation windows. However, the new standard has removed this requirement. 

5. Requirements for Contamination Control of Containers and Packaging Materials 

The new and old standards also have different regulations regarding the use of packaging containers. The original standard stipulated that solid hazardous waste that does not decompose or evaporate under normal temperature and pressure can be stored by stacking, while other types of hazardous waste must be placed in containers. 

The new standard stipulates that solid hazardous wastes that do not easily hydrolyze or volatilize under normal temperature and pressure can be classified and stored separately. Other solid hazardous wastes should be stored in containers or packaging materials. Liquid hazardous wastes should be stored in containers, or directly stored in storage ponds or storage tank areas. Semi-solid hazardous wastes should be stored in containers or packaging bags, or directly stored in storage ponds. Hazardous wastes with thermoplastic properties should be stored in containers or packaging bags. Hazardous wastes that easily generate dust, VOCs, acid fumes, toxic and harmful atmospheric pollutants, and irritating odor gases should be stored in closed containers or packaging materials. 

When stacking and palletizing hard containers and packaging materials along with their supporting structures, there should be no obvious deformation or damage/leakage. When stacking and palletizing flexible containers and packaging materials, the sealing should be tight and there should be no damage/leakage. When using containers to hold liquid or semi-solid hazardous waste, there should be an appropriate space inside the container. The new standard no longer requires "a 100mm space should be reserved between the top of the container and the liquid surface", because different hazardous wastes and container materials have different contraction and expansion characteristics, and as long as there is no spillage, it is acceptable. 

6. Management Requirements for Operating Environment of Storage Facilities 

The new standard, in combination with the latest "Solid Waste Law", has further refined and improved the management requirements for the operating environment of storage facilities, including the inspection of labels before storage, regular inspections and clean-ups of storage facilities, the establishment of management ledgers for hazardous waste, facility management systems, operation procedures, etc. Additionally, if the enterprise is a key regulatory unit for soil environment, it is required to establish a soil and groundwater pollution hazard investigation system based on the characteristics of the storage facilities and conduct regular hazard investigations. 

7. Environmental Monitoring and Emergency Requirements 

The new standard sets clear requirements for environmental monitoring of storage facilities. It stipulates that monitoring plans should be formulated for hazardous waste storage facilities and monitoring should be carried out in accordance with the regulations. For example, storage facilities equipped with collection and purification systems should monitor the discharge outlets; for those involving VOCs emissions, in addition to monitoring the discharge outlets, unorganized monitoring is also required; for those with odors, monitoring of odor indicators is necessary; and key regulatory units for hazardous waste environment should also conduct relevant monitoring of groundwater. 

The new standard has supplemented the environmental emergency requirements for hazardous waste storage facilities. It has proposed environmental emergency requirements for hazardous waste storage facilities from aspects such as emergency plan management, personnel, equipment, materials and early warning response. 

8. Information management requirements for key environmental regulatory units of hazardous waste 

For the hazardous waste environmental key supervision units as stipulated in HJ 1259, namely those with an annual hazardous waste generation volume of 100 tons or more, those with their own hazardous waste utilization and disposal facilities, or those holding hazardous waste operation licenses, the new standard requires these units to adopt technical means such as electronic scales, electronic tags, and electronic management ledgers to conduct information-based management of the hazardous waste storage process, thereby improving the management level of the hazardous waste storage environment. Those using video surveillance must ensure clear surveillance images and the video records should be retained for at least 3 months. 

9. Simplified management requirements for small and micro waste-producing entities (storage points) 

Among the hazardous waste-producing units in our country, there are a large number of small and medium-sized units. These units generate a small amount of hazardous waste and have relatively low environmental risks. Moreover, some of these units do not have the conditions to build centralized hazardous waste storage facilities. The storage requirements for hazardous waste differ from those of other key environmental supervision units for hazardous waste. Therefore, there is an urgent need for storage forms specifically suitable for storing small amounts of hazardous waste. Additionally, some production units have the actual need to temporarily store the generated hazardous waste near their production lines. However, there are no management regulations in the original standards addressing such situations. Thus, clear pollution control requirements need to be set for this circumstance. 

For these two scenarios, the new standard specifically adds the concept of storage points and related requirements. A storage point refers to a specific area used for storing hazardous waste at the same production and operation site, as well as the places where some waste-producing units temporarily store the generated hazardous waste near their production lines. The units included in the hazardous waste registration management units stipulated in HJ 1259, namely those with an annual hazardous waste generation of less than 10 tons and not included in the key supervision units of hazardous waste environment (small and micro waste-producing units), can set up hazardous waste storage points based on the characteristics, packaging forms and pollution routes of the hazardous waste, and adopt relatively flexible and targeted environmental risk prevention measures, simplifying the relevant environmental management requirements. Under the premise of controllable environmental risks, significantly reduce the cost of building hazardous waste storage facilities for small and micro waste-producing units. 

The basic requirements for a storage site include isolation from other areas, protection against wind, rain, sun exposure, loss, dispersion, leakage, etc. It is worth noting that the storage site should promptly remove the stored hazardous waste and the current storage volume should not exceed 3 tons. 

The original standard of GB 18597 has been in effect for over twenty years. With changes in the sources, types, and utilization and disposal methods of hazardous waste, the original standard urgently needs to be revised to further regulate the environmental management of hazardous waste storage and prevent environmental risks. 

The new standard is formulated based on the current situation of environmental risk prevention and control in the hazardous waste storage environment and the actual needs of environmental management. It adheres to the overall requirements of precise pollution control, scientific pollution control, and law-based pollution control, and comprehensively prevents environmental risks associated with hazardous waste storage. 

The new standards have brought significant changes for waste-producing entities. The top priority now is to organize the learning of the new standards, conduct a comprehensive risk assessment, implement targeted improvements and renovations, standardize the operation of facilities, and strengthen intelligent supervision. Through these measures, the level of pollution prevention and control for hazardous waste storage can be enhanced.