Who submits the summary operating records
The operator of a stationary source listed in Annex No. 2 to Act No. 201/2012 Coll., on Air Protection, keeps operating records and every year by 31 March reports the summary operating records data for the previous calendar year through ISPOP.
The operator must keep the operating records for at least 6 years at the place where the source is operated, so that they are available for inspection.
The report uses the form F_OVZ_SPE. Its content is based on Annex No. 11 to Decree No. 415/2012 Coll..
A current overview of forms and deadlines is also published by ISPOP – Air agenda.
Source, vent and facility are different data items
A prerequisite for correct reporting is a correctly described structure of the facility.
A stationary source is a specific technology or activity classified under Annex No. 2 to the Act. A vent or stack is the point through which emissions are discharged into the air. One facility may contain several sources, and each of them may be connected to one or more vents.
At the same time, several sources may discharge into a common vent.
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| Technical situation | Correct representation in the records |
|---|---|
| One furnace → one stack | 1 source, 1 vent |
| One painting line → two vents | 1 source, 2 vents |
| Two process units → common filter → one vent | 2 sources, 1 common vent |
| Technology with both channelled and fugitive emissions | Source and the relevant emission outputs according to the actual arrangement |
| Several separate technologies in one facility | Each source must be correctly classified and linked to the corresponding vents |
It is precisely an incorrect source → vent link that is among the errors that can subsequently complicate also the authorised emission measurement and the inspection of the facility.
Error no. 1: numbering does not match the operating permit
The serial numbers of sources and vents should be stable in the long term and clearly linked to the documentation of the facility.
A problem arises, for example, when the permit lists source 101, the operating rules designate the technology as Z1, the emission measurement report refers to source 001 and in ISPOP the same technology is kept under yet another designation.
The form F_OVZ_SPE works with the serial numbers of sources and vents within the facility. The same identification is also used for the electronic reporting of one-off emission measurements.
Before changing the numbering, it is therefore advisable to verify the link to the valid operating permit and to previous reports.
A well-run facility has a clear link between:
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| Document | What should match |
|---|---|
| Operating permit | Designation and classification of individual sources |
| Operating rules | Sources, vents and emission abatement equipment |
| ISPOP F_OVZ_SPE | Source and vent numbers |
| Emission measurement report | Measured source and the relevant vent |
| F_OVZ_JME | Electronic identification of the measured source and vent |
| Internal operating records | Operating hours, consumption, production and emission data |
Error no. 2: an old source remains in the records or a new one is missing
When production is modernised, the technological arrangement often changes, but the ISPOP structure remains carried over from the previous year.
A typical example is the dismantling of an old furnace and the installation of a new one, the splitting of one technology into two separate lines or the addition of new extraction.
Before reporting, it is necessary to verify that the records correspond to the state in the reported year and at the same time to the valid operating permit. If the technology was changed without a corresponding change of the permit, the SPE check may point to a more substantial problem in the permitting documentation.
Merely editing the ISPOP form does not replace a change of the operating permit.
Error no. 3: incorrect classification under Annex No. 2 to the Act
Every listed source must be classified under the correct code of Annex No. 2 to the Air Protection Act.
When production changes, the historical classification may no longer be up to date. The reason may be an increase in capacity, a change of raw material used, of organic solvent consumption, of fuel or of the production process itself.
The classification has a direct impact on emission limits, measurement frequency, the scope of records and possibly also the obligation to have operating rules.
We therefore recommend that, in the event of a more significant change of technology, the source code from the previous report is not taken over automatically.
Error no. 4: vents do not correspond to actual operation
Annex No. 11 to Decree No. 415/2012 Coll. requires, for stacks and vents, data such as their height, cross-section, coordinates, velocity and temperature of the waste gas, operating time and emissions.
A frequent problem is a historically created vent whose parameters were changed during a reconstruction.
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| Checked item | Typical error |
|---|---|
| Vent number | Designation differs from the permit or the emission measurement |
| Height | Taken over from the old project after the roof or stack was rebuilt |
| Cross-section | Duct diameter given instead of the cross-sectional area in m² |
| Coordinates | Coordinates of the facility instead of the specific vent |
| Gas velocity | Old value not corresponding to the current extraction output |
| Gas temperature | Taken over without checking from a measurement several years old |
| Connected sources | Vent assigned to the wrong technology |
| Operating hours | Automatically taken over from the operating time of the whole plant |
Especially for larger facilities, it makes sense to create once an overview table of sources and vents, which is then used for permitting, emission measurement and annual reporting.
Error no. 5: operating hours are estimated too generally
The operating hours of a source need not correspond to the number of hours the whole plant is open.
A production site may operate 6,000 hours a year, while a specific furnace was in operation for 4,800 hours, the painting line for 2,100 hours and the standby diesel generator for only 12 hours.
Similarly, a vent may have a different operating time than the source itself, if the extraction is started only during a certain production operation or, conversely, continues to run after it ends.
Suitable supporting documents may include operating logs, the technology control system, shift records, electricity meters, operating-hour counters or production records.
Error no. 6: emissions in tonnes per year do not match the measurement or the balance
The summary operating records report the annual quantity of emissions in t/year, not merely the concentration measured during an authorised measurement.
A one-off measurement provides instantaneous data on concentration, mass flow and other parameters in a specific operating state. From these data, the annual mass of emissions can be determined according to the relevant method of determining emissions.
For other sources, emissions may be determined, for example, using an emission factor or by a balance calculation.
The method must comply with Section 6 of Act No. 201/2012 Coll., the implementing decree and the conditions of the specific operating permit.
A common error is the use of an old measurement result without taking into account the actual operating hours or production in the reported year.
Error no. 7: the sum of emissions for the source and for the vents does not add up
The form works with emission data for both sources and vents. For a facility with a simple one source → one vent link, the check tends to be easy.
The situation is more complicated where one source uses several vents or several sources discharge into a common stack.
In such a case, the way emissions are allocated must be technically and balance-wise defensible. It is not possible to automatically assign the whole quantity of emissions to the source and, at the same time, to each of its vents in such a way that the total is multiplied several times over.
If the structure is more complex, we recommend creating, before filling in the form, a simple balance matrix source – vent – pollutant – annual emissions.
Error no. 8: data from the authorised measurement are not correctly reflected
The authorised emission measurement report contains a number of data that can be used when checking the SPE: designation of the source and vent, operating state, volume flow, velocity and temperature of the waste gas, concentrations and mass flows of pollutants.
If the measurement took place after a technological change, it is advisable to compare its identification with the valid permit before reporting the SPE.
A different source or vent number in the report does not automatically mean an incorrect measurement, but the link must be clearly explainable.
The electronic report F_OVZ_JME also works with specific source and vent numbers. A correct set-up of the records therefore also makes the subsequent reporting of measurement results easier.
Error no. 9: VOC, raw material consumption and production do not match each other
For sources using organic solvents, VOC consumption and the material balance are among the important data.
A problem may arise, for example, when the accounting records of purchased coatings do not match the operating records, the content of organic solvents in individual mixtures is not taken into account or cleaning agents are kept outside the main production consumption.
A similar check is also important for combustion sources. Fuel consumption, operating hours, heat production and calculated emissions should form a technically credible whole.
A large year-on-year jump in emissions with almost the same production may be correct, for example after a change of fuel or a measurement result, but it should have an explainable cause.
Taking over data from the previous year saves time but requires checking
For a stable operation, it is logical to use the previous report as a basis. Fixed data often really do not change.
Every year, however, we recommend checking at least:
- changes to the operating permit, installation or decommissioning of sources, filters and vents,
- actual operating hours, fuel and raw material consumption, production and annual emissions,
- new emission measurements and any changes of classification or of the method of determining emissions.
It is precisely the thoughtless carrying over of the previous year that tends to be the source of errors which are then repeated in the records for several years.
What to prepare before filling in F_OVZ_SPE
For a larger facility, it is more efficient to first check the technical balance and only then open the ISPOP form.
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| Document | What to verify from it |
|---|---|
| Valid operating permit | Sources, codes, capacities, emission limits and method of determining emissions |
| Operating rules | Numbering of technologies, vents and emission abatement equipment |
| Previous F_OVZ_SPE | Continuity of numbering and fixed data |
| Emission measurement reports | Vents, flows, temperatures, velocities and emission data |
| Operating records | Operating hours, failures, operating parameters |
| Fuel and raw material records | Annual consumption |
| Production records | Annual capacity and production quantity |
| VOC balance | Consumption of organic solvents and related emissions |
| Project documentation | Parameters of new or modified technologies and vents |
This check also often reveals the situation where the problem is not in ISPOP itself, but in an outdated operating permit or operating rules.
Correcting a report already submitted
If the operator discovers an error after submission, it should not leave it unresolved merely because the system accepted the original report.
Technical validation of the form checks mainly the data structure and some links. Successful submission in itself does not confirm that the data are factually correct.
The correction procedure depends on the status of the report and the current functions of the ISPOP system. Before correcting, it is advisable to first determine the correct values and their link to the permit, so that the subsequent correction does not create another inconsistency.
What you can send us and what we will verify
For a check of the summary operating records, you can send us:
- the latest F_OVZ_SPE report, the valid operating permit, the operating rules and an overview of sources and vents,
- authorised emission measurement reports, annual operating hours, fuel, raw material and VOC consumption and production data,
- information on changes of technology, new vents, filters or decommissioned equipment during the reported year.
We will compare sources, vents, capacities, operating hours and emissions with the valid permit and the available operating documentation. We will check the link to the measurement results and prepare the documents for the correct F_OVZ_SPE report through ISPOP.
You will find more information on the page ISPOP and reporting – NATURCHEM.
Related legislation and sources
Act No. 201/2012 Coll., on Air Protection
Decree No. 415/2012 Coll. – requirements for operating records and summary operating records