What the law requires from Category I NVOS facilities, why predictive systems are legitimate, and how the issue is settled in world practice.
Federal Law No. 96-FZ “On Atmospheric Air Protection” sets the general framework for emission control and maximum allowable concentrations (MAC).
Federal Law No. 98-FZ amended the core environmental legislation: Category I NVOS facilities (negative environmental impact) are required to run continuous automated emission control at major sources. Government Decree No. 87 defines the rules of industrial environmental control.
Importantly: the law mandates continuous automated control itself but does not prescribe a specific instrument type — a gas analyzer or a validated calculation system.
Government Decree No. 301 of 11.03.2021 establishes requirements for automated emission control systems (ASKVOA): data formats, transfer to the state monitoring system, storage periods.
Federal Law No. 116-FZ “On Industrial Safety of Hazardous Production Facilities” applies where emission sources are part of hazardous facilities: equipment and control systems must meet industrial safety requirements, overseen by Rostechnadzor.
Supervision over environmental requirements is carried out by Rosprirodnadzor; approvals of alternative-type measuring systems run through its regional offices.
Mendeleev VNIIM (All-Russian Research Institute of Metrology) is developing a set of six national standards for predictive emission monitoring systems, with DCT participating. Status as of the publication date — all standards are under development.
| Standard (working title) | Scope | Status |
|---|---|---|
| GOST R “PEMS. Terms and definitions” | Common terminology | Under development |
| GOST R “PEMS. General requirements” | Architecture, functions, data | Under development |
| GOST R “PEMS. Model validation methods” | Mobile-complex verification | Under development |
| GOST R “PEMS. Accuracy requirements” | Error limits vs CEMS | Under development |
| GOST R “PEMS. Information security” | Integrity, isolated runtime | Under development |
| GOST R “PEMS. Metrological assurance” | Traceability, checks | Under development |
The first Russian PEMS projects — implemented by DCT — are registered in the ARSHIN registry (the state registry of measuring instruments, maintained by FBUs including the Center for Standardization and Metrology) as automated emission measuring systems of an alternative type.
This is an operating precedent: readings from predictive systems are accepted for reporting where the deployment is properly approved.
1. DCT prepares the documentation package and metrological justification.
2. The mobile instrumental complex validates the model at the facility.
3. The system is registered in ARSHIN / Gosreestr as an alternative-type measuring system.
4. Readings go to the supervisory authority under Decree No. 301 formats.
We support the process with Rosprirodnadzor at the facility location.
| Jurisdiction | Document | Status of PEMS |
|---|---|---|
| USA | 40 CFR 60 / 61 / 63, Performance Specification 16 | PEMS is an approved alternative to CEMS since 1993 |
| USA (energy) | 40 CFR 75, Appendix E | PEMS for continuous emission monitoring at power plants |
| European Union | CEN/TS 17198:2019 | Technical specification for predictive systems |
| China | HJ/T 76-2007 | Requirements for continuous emission monitoring, incl. calculation methods |
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