On the accounting of atmospheric air pollutant emissions
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.
2. 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 instrumental or calculation-instrumental methods (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 using the calculation method in the POD-1 journal.
3. 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 emissions of pollutants into the atmosphere from stationary emission sources using the same method that was used during the inventory of emissions of pollutants into the atmosphere. Approaches to choosing the method for conducting emission inventory are defined in Chapter 3 of the Regulation on the procedure for conducting inventory of emissions of pollutants into the atmosphere, approved by the Resolution of the Ministry of Natural Resources and Environmental Protection of the Republic of Belarus dated December 27, 2023 No. 33.
In the event that an automated system for monitoring emissions of pollutants into the atmosphere (ASK) is installed at the emission source, filling out the POD-2 journal for recording emissions of pollutants, which are monitored continuously, is not required.
4. What method should be used to keep emission records if sampling and measurements are carried out at the emission source once a year?
According to the Ministry of Natural Resources, if the 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, filling out the POD-1 logbook.
5. When keeping records using the instrumental or instrumental-calculation method, for what period does the measurement report apply?
When recording atmospheric air pollutant emissions using the instrumental or calculation-instrumental method with the completion of the POD-2 logbook, the measurement report for atmospheric air pollutant emissions from stationary emission sources applies to the month in which sampling and measurements were carried out, and the subsequent month(s) of the reporting quarter.
Please note that when keeping emission records, measurement reports from the state institution "Republican Center for Analytical Control in the Field of Environmental Protection" may also be used.
6. Should emissions of atmospheric air pollutants be recorded based on the indicator "total organic carbon" or individual volatile organic compounds?
Emissions of atmospheric air pollutants from stationary emission sources should be recorded for those pollutants (or summary indicator) for which permissible emission limits are established in the permit for emissions of atmospheric air pollutants or in the integrated environmental permit, namely:
- if the permissible emission limit is established for total organic carbon, emissions should also be recorded for this indicator;
- if permissible emission limits are established for individual volatile organic compounds, emissions should be recorded for each such compound.
7. What calculation methods should be used when keeping emission records using the calculation method?
When accounting for emissions of pollutants into the atmosphere using the calculation method, the same technical regulatory legal acts (TRLA) should be used as were applied during the inventory of emissions of pollutants into the atmosphere. If the TRLA, in accordance with which the emission inventory was carried out, has lost its force, the current TRLA should be followed.
Data from the official website of the Ministry of Natural Resources and Environmental Protection on the global computer network Internet minpriroda.gov.by.
Important! In accordance with paragraph 3 of Article 21 of the Law of the Republic of Belarus of December 16, 2008 No. 2-Z "On the Protection of Atmospheric Air" (hereinafter referred to as Law No. 2-Z), legal entities engaged in economic and other activities related to emissions of pollutants into the atmosphere from stationary emission sources are obliged to submit departmental reporting on the results of accounting in the field of atmospheric air protection.
Based on the foregoing, the Ministry of Natural Resources and Environmental Protection has developed and approved, in the prescribed manner, the form of departmental reporting "Report on the results of accounting in the field of atmospheric air protection". The departmental reporting "Report on the results of accounting in the field of atmospheric air protection" must be submitted by legal entities engaged in activities related to emissions of pollutants into the atmosphere, based on a permit for emissions of pollutants into the atmosphere (integrated environmental permit), in electronic form to the regional or Minsk city committees of natural resources and environmental protection at the location of the object affecting the atmospheric air (submission to territorial inspectorates is possible).