On the accounting of emissions of pollutants into the atmospheric air

  1. Who keeps records of emissions of pollutants into the atmosphere?

Records of emissions of pollutants into the atmosphere are kept by all business entities engaged in economic and other activities related to emissions of pollutants into the atmosphere, regardless of whether they have a permit for emissions of pollutants into the atmosphere or a comprehensive environmental permit.

  1. Is it necessary to keep records of emissions from non-regulated emission sources?

Records of emissions of pollutants into the atmosphere are kept from all stationary emission sources, including non-regulated ones.

In this case, according to the approaches to keeping records of emissions of pollutants into the atmosphere from stationary emission sources using the instrumental or calculation-instrumental method (POD-2) using data from the project of permissible emission standards, this method is applied to regulated emission sources. Accordingly, records of emissions of pollutants into the atmosphere from non-regulated emission sources should be kept by the calculation method in the POD-1 journal.

  1. How to determine the method for keeping emission records?

The method for keeping emission records (calculation, instrumental, or calculation-instrumental) is determined directly by the business entity itself.

In this case, it is advisable to keep records of

According to the Ministry of Natural Resources, if sampling and measurement of atmospheric air pollutant emissions from a stationary emission source are carried out once a year, then it is advisable to keep records of emissions from such a source using the calculation method with the completion of the POD-1 logbook.

  1. When keeping records using the instrumental or instrumental-calculation method, for what period does the measurement report apply?

When recording emissions of atmospheric air pollutants using the instrumental or calculation-instrumental method with the completion of the POD-2 logbook, the report on measurements of atmospheric air pollutant emissions from stationary emission sources applies to the month in which sampling and measurements were carried out, and the month(s) of the reporting quarter following it.

Please note that when keeping records of emissions, measurement reports from the state institution "Republican Center for Analytical Control in the Field of Environmental Protection" may also be used.

  1. Should emissions of atmospheric air pollutants be recorded based on the indicator "total organic carbon" or individual volatile organic compounds?

Records of atmospheric air pollutant emissions from stationary emission sources should be kept for those pollutants (or summary indicator) for which emission limits are established in the permit for emissions of atmospheric air pollutants or in the integrated environmental permit, namely:

if the emission limit for total organic carbon is established, emissions should also be recorded based on this indicator;

if emission limits for individual volatile organic compounds are established, emissions should be recorded for each such compound.

  1. What calculation methodologies should be used when keeping records of emissions using the calculation method?

 When accounting for emissions of pollutants into the atmosphere using a calculation method, the same technical regulatory legal acts (TRLA) that were used during the inventory of emissions of pollutants into the atmosphere should be used. If the TRLA according to which the emission inventory was carried out has lost its validity, then the current TRLA should be followed.