Roundtable on "Continuous Emission Monitoring System (CEMS) in India- challenges and way ahead"

A half day meet on “Continuous Emission Monitoring System (CEMS) in India- challenges and way ahead” was organized by Centre for Science and Environment (CSE) on 24th February 2016. The meeting had participants from central pollution control board (CPCB), state pollution control boards (SPCBs) and other key stakeholders to discuss the challenges facing the CEMS implementation and suggestions to address these issues.

Since CEMS is a new technology, Indian industry has little experience in it. Implementation is therefore facing impediments such as absence of infrastructure, detailed guidelines, device certification and lab empanelment. The present meeting was called upon to set up a common platform for CPCB, SPCBs, industries, device manufacturers and service providers to share their experience and discuss on the challenges faced on CEMS implementation.

Summary

The discussion begins with introduction on the current implementation status of CEMS in India. It was shared that nearly 50% of plants (out of around 3500) have already installed CEMS and another 25% is in process. Nearly 30% of the units have connected the data transmission network to CPCB. Deadline for installations have ended and CPCB is going to take action on those which didn’t install. CPCB highlighted that it has removed the clause which demands installation of internationally certified device only, and thus local manufacturers can also install their equipments.  But certification of equipments is required to get a reliable data. India currently does not have a certification system in place. CPCB has initiated work with National Physical Laboratory (NPL) on the same. 

Following key points came out from the discussions:

Industry concerns and suggestions

• Industry shared concern on lack of harmony between CPCB and SPCBs. There is wide variations in instructions (like monitoring pollution parameters, regulatory actions on industries, CEMS implementation etc.) which is confusing for industries.  In respect to CEMS, SPCBs are asking multiple parameters to monitor even where particular pollutant in not a concern. Eg.  PM CEMS installation in reheating furnaces in steel industry is not necessary. 

• It also led to a major discussion point whether this gives enough basis for legal actions for compliance, since CEMS installation is happening based on directions only. There may be multiple legal consequences in holding any party (whether industry, device supplier or service provider) responsible for mistakes/non-compliances. 

• However certain SPCBs are issuing show cause based on the data. They also shared that every single data exceedance or other issue leads to SMS to industry, leading to flooding in of messages which is physically not possible to see. However TNPCB shared that they have provision of every 15 mins auto alert in case of any issue. 

• Industry also indicated the issue of lack of device certification system, lab empanelment system and proper guidelines. 

• There are multiple device suppliers in market. In absence of any clear instruction, industries are confused which one is to choose. CPCB should provide guidance to shortlist device/technology. Above that, CPCB is planning to take actions on those not installed.  

• Auto calibration of devices increases cost. Parameters where auto calibration facility is expected must be decided judiciously. 

• Predictive emission monitoring system should go hand in hand with CEMS for data validation, statistical forecasting and verifying the system compliance. 

• Concerns about the reporting of parameters were also raised.  The instruments report in mg/m3 while the standards are in mg/Nm3.  Industry suggested that the instrument should report in the same units after conversion.

Pollution Control Board

• TNPCB shared its experience and indicated that CEMS is improving the regulatory system. MPPCB shared the concern of high cost of instruments, missing certification system and guidelines for calibration etc.  

Device Suppliers/Service provider

• Issue of data tampering was also raised and it was suggested that it is possible to avoid if service provider is make a responsible party.  It was indicated that data tampering is possible at three places– hardware, client and analyser, however commonly happens at service provider end or by decoding analyser.  

• A common server at regulator end was discussed by all the parties. To note, a service provider indicated that it can create monopoly in the market.  Another service provider shared that open source softwares are available which can be used. TNPCB has a common software while CPCB doesn’t which also indicates coherence between SPCB and CPCB.

• Issue on lack of skilled manpower was also rose which leads to delay in repair and maintenance.

Concluding points 

• The CEMS programme has not been carried in a planned fashion. CEMS is the next generation of environmental regulations. We need to have- coherence between state and central regulatory system (CPCB and SPCBs), Best Available Technologies (BAT) for CEMS, Device certification system, Lab empanelment system, a compliance mechanism, etc. CEMS should be taken as a trigger point to bring together the Air Act, the Water Act and Environment Protection Act.

• CSE will make a multi-stakeholder committee which will work on this issue.