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BEST AVAILABLE TECHNIQUES, EMISSION LIMIT VALUES AND ENVIRONMENTAL SELF-MONITORING REQUIREMENTS: CHALLENGES TO RUSSIAN INDUSTRIES

И. О. Тихонова

Abstract

In Russia, new Integrated Pollution Prevention and Control (IPPC) legislation obliging larger industries to demonstrate compliance with Best Available Techniques (BATs) and to obtain Integrated Environmental Permits (IEPs), introduces also stricter requirements to environmental self-monitoring practices. Environmental self-monitoring is implemented by regulatees subject to environmental permitting, in order to ensure their compliance with regulatory requirements. The key issue for IPPC installations is compliance with Emission Limit Values (ELVs) set in IEPs. At the same time, self-monitoring includes a wide spectrum of activities: monitoring of operations; emissions and other impact factors, in several cases ? ambient conditions in the vicinity of the facility concerned, etc. Self-monitoring reports must be submitted to the competent authorities with a specified regularity, and in a duly aggregate form. Its primary goal is to ensure the earliest possible response to any environmental incompliance and, on the other hand, reduce public spending on governmental monitoring and control. A comprehensive self-monitoring programme should describe monitored parameters, sampling/direct measurement points; safe means of access to sampling points; timing considerations of monitoring and measurements; monitoring methods, quality assurance and quality control arrangements; methods of record keeping, data analysis, etc. Russian stakeholders actively discuss lists of parameters to be monitored (continuously and dis-continuously), time and funds needed to meet new requirements, and possible derogations. Respective requirements are drafted and have to be passed in 2018. Operators must develop draft self-monitoring programmes and include proposals in their applications for IEPs. Up to now, continuous measurements have not been widely spread in Russia, and only Moscow can be called an experienced region, where all significant polluters operate continuous self-monitoring equipment and report data obtained to Moscow Government. The article discusses challenges to Russian IPPC industries and suggests several win-win solutions that could be used to improve environmental self-monitoring practices of regulatees and decision-making approaches of environmental enforcement agencies.

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DOI resolver: doi.org/10.5593/sgem2018/5.1/s20.016

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