Sık Sorulan Sorular
1. What is the Pollutant Release and Transfer Register?
The Pollutant Release and Transfer Register (PRTR) is the international definition of the inventory that is called and implemented as European PRTR (E-PRTR) at the European Union level. PRTR is an electronic database that contain information regarding certain industrial pollutants that are released to receiving environments such as air, water, and land, and that are transferred via wastewater for such procedures as treatment and processing. It further contains information regarding hazardous and non-hazardous waste transfers and is based on regular reporting of facilities.
2. How was the Pollutant Release and Transfer Register Created?
During the United Nations Conference on Environment and Development held in Rio de Janeiro (Rio Conference) in 1992, the first steps were taken to create an emission inventory to provide the public with information on pollutant substances. Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters (Aarhus Convention), which was opened for signature by the United Nations Economic Commission for Europe on June 25, 1998 in the Danish city of Aarhus, is the most significant step that allowed public to reach environmental information. With “European Pollutant Emission Register (EPER)” and Integrated Pollution Prevention and Control (IPPC) Directive that entered into force in 1996 in the European Union, the first significant steps were taken to create a pollutant release and transfer register. In 2003 the Kiev Protocol was signed, followed by publication and entry into force of the Regulation on European Pollutant Release and Transfer Register in 2006 with the aim of meeting the requirements of the protocol. Even if it is not a party to Aarhus Convention or Kiev Protocol, Turkey aims to implement Pollutant Release and Transfer Register due to its membership to the OECD and within the scope of the commitments under Turkey’s National Program for 2008 regarding Adoption of the European Union Acquis.
3. Which facilities are subject to Pollutant Release and Transfer Register?
The facilities that are listed under Annex-1 List of Activities of the Regulation on Pollutant Release and Transfer Register and that exceed relevant threshold values are subject to the PRTR. Annex-1 List of Activities covers 65 activities grouped under nine different sectors. The sectors falling under the scope of the PRTR are listed below: • Energy • Production and processing of metals • Mineral industry • Chemical industry • Waste and wastewater management • Paper and wood production and processing • Intensive livestock production and aquaculture • Animal and vegetable products from the food and beverage sector, and • Other activities
4. Which pollutants are required to be reported under Pollutant Release and Transfer Register?
The list of pollutants that are to be reported if released to air, water and land is given in table under Annex-3 of the Regulation on Pollutant Release and Transfer Register. The list given in Annex-3 of the PRTR Regulation covers 91 pollutants in 7 different groups: • Greenhouse Gases • Other Gases • Heavy Metals • Pesticides • Chlorinated Organic Compounds • Other Organic Compounds • Inorganic Compounds
5. What will be reported by the facilities that are subject to PRTR?
The facilities that are listed in Annex-1 List of Activities under PRTR Regulation report: • The amounts of releases to air, water, and land for the pollutants specified in Annex-3, • The amount of the waste transferred, the name and address of the recovery or disposal company for the off-site transfer of hazardous wastes, and the place of recovery or disposal process, in such a manner separately for recovery and disposal, in cases where a total of more than 2 tonnes of hazardous wastes and more than 2000 tonnes of non-hazardous wastes are annually transferred out of the facility for recovery or disposal purposes, with the exception of disposal activities related to land improvement and deep injection, • The amounts of pollutants, which are referred to in Annex-3 of the Regulation, in the wastewater transferred off-site for wastewater treatment purposes, including the transfers via sewage systems, and the name and address of the wastewater treatment plant and the river basin in which it is located.
6. Which methods can be used in the reporting phase and what is the reporting frequency?
Pollutant Release and Transfer Register can be filled with data that have been created using measurement, calculation or estimation methods. In case it is specified that the data is determined based on a measurement or calculation, it shall be reported that which analytical method and/or method of calculation has been used. PRTR contains information related to releases and transfers caused by all intentional, accidental, routine and non-routine activities. The facilities are required to report their pollutant release and transfer registries as total annual loads.
7. Will there be any additional financial burden (measurement device, personnel, laboratory analysis etc.) for the facilities within the scope of the PRTR system?
The facilities are responsible for providing complete and high quality information in their annual reports, and they should use the best available information consisting of internationally accepted monitoring data, emission factors, mass-balance equations, indirect monitoring or other calculations, engineering decisions and other methods approved by the Ministry. The PRTR Regulation does not require the facilities to perform additional analyses or to install equipment.
8. Will the data collected within the scope of PRTR be publicly available?
Provisions regarding making the PRTR publicly available will enter into force on the date to be determined by the Ministry.
9. What will publicly available PRTR contain?
Once the PRTR data have been made publicly available, the public will be able to access the following information: • Information on the facility falling under the scope of PRTR, including the facility’s parent company where applicable, as well as the facility’s activities and geographical location, including related river basin • Out of the pollutant releases required to be reported by facility operators, the ones where releases to air, water and land exceed the threshold values specified in Annex-3 • The amounts of hazardous and non-hazardous wastes that are required to be reported by facility operators, total amounts of which exceed 2 tonnes and 2000 tonnes annually, respectively • Wastewater pollutants that are transferred off-site, which are required to be reported by facility operators since they exceed the threshold values specified in column 1b of Annex-3 • Pollutant releases from diffuse sources, where such information is available.
10. Are the facilities allowed to apply for confidentiality for a certain pollutant/data?
In cases where the operator wishes any information to be kept off the publicly accessible PRTR system, the operator must apply to the Ministry to seek confidentiality, specifying concerned information and justification thereof. Upon receiving the application the Ministry makes a decision in accordance with the Law No. 4982 on Right to Information of October 09, 2003 and the Law No. 6698 on Protection of Personal Data of March 24, 2016. The type of confidential information and justification thereof are specified separately for each facility seeking confidentiality.
11. Who will verify and approve the data?
Provincial Directorates are responsible for conducting both initial check and data verification of annual reports submitted by facility operators. The Ministry, on the other hand, is responsible for approving the annual reports upon checking their eligibility.
12. Will there be on-the-spot checks within the scope of the PRTR?
PRTR Regulation allows Provincial Directorates and/or Ministry to perform on-the-spot checks as deemed necessary.
13. Is there a guidance available for PRTR software and reporting?
The Ministry has prepared a guidance for reporting and software, and concerned documents are available in the “Documents” section of the PRTR website.
14. Which authority will assign the Facility I.D. Number in the PRTR system?
The facility I.D. number is automatically assigned by the PRTR upon completion of the registry.
15. Will the facility owner be able to report via environmental consulting firm within the scope of the PRTR system?
The PRTR system assigns one user name and e-mail for each facility. The facilities are allowed to report using this user name, which can be used by facility personnel or an environmental consulting firm. However, sustainability of the communication between the Ministry and the facility is under the responsibility of the facility considering all communication will be ensured through the e-mail address to be assigned.
16. What should the facilities do in case of a change in capacity or scope?
In cases where PRTR registry information has changed or the operator of the facility has been replaced, or in cases where the facility has undergone a change that may affect PRTR reporting requirements, the facility operator is required to inform the Ministry in writing within 30 days to make required amendments on the PRTR registry.
17. Will the wastewater disposed to the sewage be reported?
Within the scope of the PRTR system, the amounts of pollutants in wastewaters transferred off-site for wastewater treatment purposes, together with the name and address of the wastewater treatment plant and the river basin where it is located are reported under wastewater transfer, which covers the transfers via sewage systems.
18. What are the benefits of PRTR?
PRTR is beneficial for decision makers since it makes it possible to monitor how pollutants are created and released and what their impacts are, to determine priorities in reducing and avoiding pollution, and to decrease regulatory burdens requiring monitoring and criminal acts. It can further be used in risk assessments for human health and environment as it is an input for pollution pattern models. PRTR is beneficial for the industry since it makes it possible to compare the environmental performance in the sector and to save money by reducing releases. It can further be used to plan how to use lands and while getting permits for new facilities. Finally, it encourages industrial facilities, business world and public to reduce releases and waste transfer and to use clean production techniques. Furthermore it is beneficial for other parties since it makes it possible for concerned or indirectly-affected parties to ask questions. It motivates people to analyze the developments from the viewpoint of environmental quality and human health, reflects and spreads the goals and targets of non-governmental organizations, allows researchers and academicians to use PRTR data in their modelling and other studies. Moreover, the finance sector can use PRTR data in investment proposals, insurance applications and sustainability assessments. And finally, thanks to PRTR, the public learns about the releases/transfers in their vicinities and about the environmental performances of miscellaneous industrial facilities, economic sectors, and regulatory public institutions.