Pollutant Permits for the Water Treatment Sector: Applicable Specifications, Compliance Determination and Common Rework Points

1. Choose the right technical specification first

Two national environmental protection standards run in parallel for the water treatment sector, and picking the wrong one is the most common cause of rework in permit applications:

• HJ 978-2018, Technical specification for application and issuance of pollutant permit - Wastewater treatment (on trial), issued and effective on 2018-11-12. It applies to municipal wastewater treatment plants, centralized industrial wastewater treatment plants, and other domestic wastewater treatment plants receiving industrial wastewater with a treatment capacity of 20,000 m3 per day or more, covering water pollutants, air pollutants and solid waste. Other water treatment units may apply it by reference.
• HJ 1120-2020, Technical specification for application and issuance of pollutant permit - General wastewater treating process, issued and effective on 2020-03-11. It applies to discharges from water treatment facilities of mining, manufacturing and service sector pollutant-emitting units, that is, in-plant wastewater treatment stations.

Both documents carry exclusion clauses. Wastewater treatment facilities and discharge outlets inside a facility that belongs to another industry are governed by that industry's specification and are outside HJ 978. HJ 1120 likewise states that where an industry-specific technical specification exists for the emitting unit, that industry specification governs. In addition, a centralized industrial wastewater treatment plant treating wastewater from a single industry follows that industry's specification where it makes explicit provision.

2. Scope of controlled pollutants: concentration items and quantity items are two separate lists

Table 1 of HJ 978 splits pollutants into "permitted discharge concentration items" and "permitted discharge quantity items", which is the core structure of the application form:

• Municipal wastewater treatment plants and other domestic wastewater treatment plants: concentration items are pH, suspended solids, colour, chemical oxygen demand, ammonia nitrogen, total phosphorus, total nitrogen, five-day biochemical oxygen demand, animal and vegetable oils, petroleum oils, anionic surfactants, faecal coliforms, total cadmium, total chromium, total mercury, total lead, total arsenic, alkyl mercury, hexavalent chromium and other pollutants, with the outlet classified as a major discharge outlet; quantity items are chemical oxygen demand, ammonia nitrogen, total phosphorus and total nitrogen.
• Plants treating wastewater from a single industry: determined according to that industry's wastewater discharge standard.
• Other centralized industrial wastewater treatment plants: pH, suspended solids, colour, chemical oxygen demand, ammonia nitrogen, total phosphorus, total nitrogen, five-day biochemical oxygen demand, petroleum oils, plus other pollutants determined by the discharge standard applicable to the incoming wastewater.

Three footnotes must be remembered:

1. Pollutants present in the influent and listed in Table 3 of GB 18918 are included at the discretion of the local ecological environment authority based on the categories of industrial pollutants received;
2. where the effluent is directed to reuse, no pollutant discharge quantity is permitted (note c to Table 1 of HJ 978; HJ 1120 contains the same rule and further specifies that for centralized industrial wastewater plants neither concentration nor quantity is permitted when the effluent is reused);
3. units located in areas subject to total phosphorus and total nitrogen load control as defined in formal documents issued by the ecological environment authority must control annual permitted quantities of total phosphorus and total nitrogen.

3. Air pollutants and fugitive emissions: three outlet categories

Tables 2 and 3 of HJ 978 divide the air side into organized and fugitive emissions. The entries most relevant to wastewater plants are:

• Deodorization unit stack: permitted concentration (or rate) items are odour concentration, hydrogen sulfide and ammonia, classified as a general discharge outlet with no permitted quantity;
• Hazardous waste incinerator stack and general solid waste incinerator stack: long pollutant lists including dioxins, classified as major discharge outlets with permitted quantities for particulate matter, sulfur dioxide and nitrogen oxides;
• Fugitive emissions at the site boundary: ammonia, hydrogen sulfide and odour concentration; at the point of highest volume concentration within the site: methane (explicitly referring to the influent pump station, primary sedimentation tank, aeration tank, sludge storage tank, sludge thickener, sludge dewatering room and storage sheds).

The general principle of clause 5.2.1 also matters: for air pollutants, major outlets are permitted both quantity and concentration, while general outlets and boundary fugitive emissions are permitted concentration only, with no quantity. The annual permitted quantity is defined as the maximum amount of a pollutant the unit may discharge over any continuous 12 months, and it is also used to assess actual discharge in a calendar year.

4. Records: electronic and paper in parallel, kept at least three years

Both specifications impose the same requirements. The emitting unit must establish a record-keeping system with responsible department and responsible person, and is accountable for the authenticity, completeness and standard compliance of the records. Records must be maintained in both electronic and paper form and kept for no less than three years.

Clause 8.1.2 of HJ 978 requires four categories of facility information: influent information (quality and quantity at the main influent port); daily operation of wastewater treatment facilities (facility parameters, influent and effluent, sludge, chemical consumption, equipment electricity consumption); daily operation of waste gas treatment facilities; and daily operation of sludge treatment facilities (sludge generation and moisture content, treatment method, treated sludge quantity and moisture content, on-site storage, comprehensive utilization, self-treatment, and quantity and identity of the entrusted treatment party). Maintenance records must capture the fault or maintenance status, start and end times, cause, pollutant quantity and concentration, and whether it was reported, and must in principle be recorded immediately after an abnormal condition occurs and reported promptly.

5. Execution reports: frequency, deadlines and content

5.1 Frequency and deadlines

• Units under key management must submit both annual and quarterly execution reports; units under simplified management must submit the annual report. Local ecological environment authorities may require quarterly or monthly reports on the basis of management needs, stated explicitly in the permit.
• The annual report must be submitted to the permit issuing authority by the end of January of the following year. Where the permit has been held for less than three months in a year, the annual report may be omitted for that year and the information carried into the next annual report (HJ 1120 contains the same rule for holdings under three months).
• HJ 1120 further specifies that the quarterly report must be submitted within fifteen days after the end of the quarter; a quarter with less than one month of permit holding may be omitted and carried into the next quarter; and where an annual report is submitted, the fourth quarter report for that year need not be submitted.

5.2 Content

Clause 8.2.3.1 of HJ 978 lists eleven items for the annual report: basic information on the unit; operation of pollution control facilities; implementation of self-monitoring; implementation of record keeping; actual discharge and compliance determination analysis; information disclosure; construction and operation of the internal environmental management system; implementation of other requirements in the permit; other issues requiring explanation; conclusions; and drawings and annexes. HJ 1120 prescribes the same eleven parts for units under key management (Appendix D), while the annual report for units under simplified management is reduced to seven parts (Appendices D and E). The quarterly report includes at least actual discharge concentration and quantity, compliance determination analysis, and explanation of any exceedance or abnormal operation of pollution control facilities.

One frequently missed detail: the annual report requires analysis of any changes in unit information and any non-compliant discharge, together with the differences from the permit content and the reasons for them.

6. Compliance determination: three criteria to check one by one

Chapter 10 of HJ 978 is the basis used by both inspectors and self-auditors. The key provisions are:

• Wastewater concentration compliance means that any valid daily average concentration value (unless the discharge standard provides otherwise) meets the permitted discharge concentration. For automatic monitoring, the valid daily average concentration is the average of multiple valid monitoring data obtained within one day as a monitoring cycle.
• Air concentration compliance by automatic monitoring is assessed against the valid hourly average concentration, defined as the arithmetic mean of valid data covering no less than 45 minutes within one clock hour.
• Quantity compliance means the sum of annual actual discharges of all pollutants at the wastewater outlet does not exceed the corresponding annual permitted quantity; where a special period permitted quantity applies, the actual discharge in that period must not exceed it.
• Sludge: sludge discharge is the generation minus on-site storage, comprehensive utilization, self-treatment and entrusted treatment; if the annual actual sludge discharge is not zero, the unit is deemed non-compliant. In effect sludge must be accounted to zero discharge, and any gap in the records constitutes non-compliance directly.
• Data conflict: where enforcement monitoring data and self-monitoring data for the same period disagree and the enforcement data comply with statutory monitoring standards and methods, the enforcement data prevail.
• An outlet or pollutant that should be automatically monitored but is not is deemed non-compliant.

7. How actual discharge is calculated

Clause 9.1 of HJ 978 sets the general principle: the actual discharge of water pollutants in an accounting period equals the actual discharge at the major outlet, namely the main effluent outlet; general outlets and fugitive emissions are not accounted. The accounting period may be a quarter, a year or a special period. Clause 8.1 of HJ 1120 requires units under both key and simplified management to calculate actual discharges of chemical oxygen demand and ammonia nitrogen at the wastewater outlet, and for key heavy metal industries also mercury, lead, arsenic, chromium and cadmium.

When automatic monitoring data are used, equation (4) of HJ 1120 gives E = 10^-6 x sum of (ci x qi), where ci is the measured average discharge concentration on day i in mg/L, qi is the flow on day i in m3/d, and n is the number of discharge days in the accounting period. Two methods are available: the measurement method and the pollutant generation and discharge coefficient method.

8. Responsibility boundaries when influent is abnormal

The Notice on Further Regulating the Environmental Management of Urban (Industrial Park) Wastewater Treatment, issued by the Ministry of Ecology and Environment on 2020-12-13, gives several directly quotable positions on the responsibilities of operators and discharging enterprises:

• Discharging enterprises must pre-treat industrial wastewater as required; category I pollutants and other toxic and hazardous pollutants specified in the applicable standards must be treated to compliance at the workshop or workshop treatment facility outlet; other pollutants may only be discharged after meeting the process requirements of the centralized facility.
• Units classified as key water environment dischargers must install and use automatic monitoring equipment as required by law and share data with the local ecological environment authority and the operator.
• Where responsibilities are clearly defined, the operator and the discharging enterprise may negotiate the influent concentration for industrial wastewater, report it to the ecological environment authority, and have it entered into the pollutant permit as the basis for supervision and management. This is the most valuable provision for industrial park projects: once a negotiated influent concentration is written into the permit it acquires regulatory force.
• Where the competent industry authority or the ecological environment authority determines that an exceedance was caused by influent beyond the design specification or actual treatment capacity, and the operator reported proactively and proactively eliminated or mitigated the harmful consequences, the administrative penalty may be reduced or mitigated according to law.
• Where the operator has reported to the ecological environment authority and, for the purpose of process optimization or efficiency improvement, suspends part of the process units while the effluent still meets standards, this is not deemed abnormal use of water pollution control facilities.

9. Common rework checklist

1. Filing an in-plant wastewater treatment station under HJ 978 - use HJ 1120 or the industry specification instead;
2. Declaring a discharge quantity for a general outlet such as the deodorization stack - Table 2 of HJ 978 permits no quantity for that outlet;
3. Declaring discharge quantities for effluent sent to reuse - no quantity is permitted when the effluent goes to reuse;
4. Keeping records in electronic form only - both electronic and paper are required, retained at least three years;
5. Submitting the fourth quarter report redundantly - HJ 1120 states it is not required when an annual report is submitted;
6. Failing to account sludge to zero discharge - a non-zero annual actual sludge discharge is deemed non-compliant;
7. Averaging a full clock hour for the valid hourly air concentration - the specification requires the arithmetic mean of valid data covering at least 45 minutes.

Note: the provisions above are taken from the electronic release versions of HJ 978-2018 and HJ 1120-2020 published by the Ministry of Ecology and Environment; formal application should rely on the official printed standard texts.