Training on Continuous Emission Monitoring System- From Understanding to Implementation

Background

A one week training on “Continuous Emission Monitoring System- From Understanding to Implementation” was organized by Centre for Science and Environment (CSE) from 8th - 12th August 2016 at JSW Steel Complex, Vidyanagar, Bellary, Karnataka. This training was an initiative for capacity building of regulators under the tripartite agreement between CSE, Ministry of Environment, Forest and Climate Change (MoEF&CC) and Central Pollution Control Board (CPCB). The training programme was designed to develop knowledge base of regulators on following aspects of CEMS:

• Basic understanding of “Real time monitoring/ or continuous emission monitoring system (CEMS)” and its importance. 

• Status of CEMS implementation and challenges in implementation

• Technical knowledge and practical experience on device selection, installation, operation & maintenance, data transmission, inspection and compliance check.  

• Knowledge on successful CEMS frameworks around the world and their role in environmental governance. 

The programme was organized in collaboration with JSW steel. JSW steel had extended the support in accommodation, conference venue, food and local travel. 

The training was attended by 21 participants from 10 SPCBs and one from CPCB. The participation included environmental engineers, scientists and field officers. They were trained by resource persons from different domains like regulators, manufacturers, and service providers. The training consisted of lectures, group discussions, group exercises, visit to the industry and hands on experience.

Summary of the training sessions

Day 1

The training was started with introduction of regulator’s training initiative and its objective.  The present status of CEMS implementation was discussed and need of training on CEMS was emphasized. CSE shared how it has been supporting this initiative and working with MoEF&CC and CPCB. It was shared that CSE has also constituted a CEMS expert committee to deliberate and strategise CEMS implementation initiative.  CSE is developing guidelines and protocols for CEMS in consultation with European experts. It will also help in capacity building of regulators and industries through trainings; this particular training is one of them.

Resource person form CPCB shared the objective and plan of CEMS initiative by government. He also highlighted the experience and updates from pilot scale emission trading initiative in Gujarat, Maharashtra and Tamil Nadu. JSW Steel shared the industry perspective on CEMS and highlighted various challenges from industry perspective. Regulator from KSPCB shared the initiative they are taking for CEMS implementation and highlighted the CSE’s survey on CEMS.

After brief introduction of factory premise, the regulators were taken for factory tour where they understood the steel making process, pollution sources, control practices and CEMS installation. The day was long, ended at 7:30 pm in the evening. However, participants found it very informative and useful.

Day 2

The second day of the programme discussed various available technologies, location of installation and type of stack CEMS shall be installed etc. The discussion in detail highlighted some key confusion:

• Which all stacks should install CEMS?
  Discussion clearly uncovered the confusion on the type of stack, industry should install CEMS. However, it was concluded that the stacks that have to meet pollution standards as per environmental clearance conditions, shall install CEMS. For instance, JSW which claimed to have 373 stacks but need to install CEMS for around 70 stacks only.

• Location of CEMS installation?
  Locations of CEMS installation have to be in reference to the position of sampling port and height of the stack. In EU, all the CEMS devices are installed below sampling port whereas it has no clarity in Indian context. Even if the device is installed in stack it need to follow 8D/2D formula or in rare case 2D and 1/2D formula. 

• Improper device selection?
  It was agreed by all, that many inadequate technologies are in the market which are cheaper and industry are installing. This requires training of the regulators and industry on how suitable devices should be selected.

• Additional parameters to monitor?

  Participants learned that only stipulated parameters monitoring is not sufficient. Some additional parameters like moisture, temperature, O2 /CO2 etc. need to be monitored in addition for data accuracy and check proper functioning of the device. It was noted that many vendors don’t guide the industry properly and it affects the cost. No proper instruction was given by CPCB, as this is common practice and was expected to be followed. 

Based on the presentation, participants did group exercise and presentation on device selection, parameters to be monitored, location of installation and key points to check during inspection. The participants were actively involved and well appreciated the exercise. 

Day 3

The third day of the programme was focussed on operation and maintenance of the CEMS device. Experts shared the process of calibration and maintenance issues and also shared common practical issues on the ground. 

Post presentation and discussion, three groups were formed and taken for hands on experience in calibration, zero and span check for PM and gaseous CEMS. The resource person also had installation at JSW so they had their team to discuss and teach the participants in details. The session was very informative. However few key issues were noticed:

• Appropriate calibration and maintenance?

  Despite JSW is a large plant, one of its vendors failed to show calibration as they didn’t have proper equipments and facilities. It indicates the smaller industries may have many such issues. One of the service providers was also noticed not following proper practices of CEMS operation and maintenance. 

• Appropriate monitoring and reporting?

  Participants also noticed that one of the external lab carrying PM monitoring for JSW steel was not doing monitoring correctly. Issue of incorrect reporting (by lab) during manual monitoring was also noted. This indicates that small industries may have many such problems.  

Post visit, participants again joined the discussion on suitable technology selection and practices for data accuracy. The day was long, ended at 7:30 pm in the evening. However, participants found it very informative and useful.

Day 4

The presentation and discussion was carried on Water continuous monitoring system/ Effluent quality monitoring system. Resource persons shared the various technologies and their use. Proper maintenance and monitoring of parameters were discussed. Issues were raised on concept of zero liquid discharge (ZLD). Improper installation of device and video cameras were also discussed in detail.

Many queries on effluent monitors installation was raised by JSW which were also discussed in detail. Post discussion, participants were taken to the installation site. To the surprise, device installation was not correct. The device was installed in air near the effluent outlet which had no effluent. Video camera was focussed on the same outlet. However, the treated effluent pipeline was going further which was being used for gardening.  The visit clarified following points:

• Improper installation of devices

  Location of installation of flow meter was not clear to industry as well as participants. There was no clear guideline as well. It was discussed in detail and agreed upon the flow a meter was supposed to be installed at the outlet of ETP, not the final effluent outlet which is dry. pH meter, conductivity meter etc. were installed in air (dry atmosphere) at JSW, which should ideally be installed in water. In the case of JSW Steel, the devices were destroyed and were giving wrong figures. This gave idea of situation in comparatively smaller industries where not enough skill or information is available.  

In later half of the day, a trip to Humpi (UNSECO Heritage site) was organized for the participants. 

Day 5

Last day of the training was started with CEMS framework available in Europe and USA. It was conveyed, since we don’t have such system set in India, we can learn how it has been followed in other countries. We can’t copy all of them but can learn the process of evolution and experience.

Next presentation discussed on data acquisition and handling system. The resource person also shared the practical experience on problems in the field. With sharing real time data, he explained how issues or manipulation can be checked.

At the end of the programme, participants were asked to prepare a check-list on what they will check during inspection of the plant. A list was prepared by discussion among the participants and resources person.

Finally programme was wrapped-up with feedback collection and certificate distribution. Participants were very positive and appreciated CSE, JSW and resource persons for this capacity building initiative. They also requested CSE to organise more of such training programmes on CEMS in future.

Findings & Conclusion

1. Capacity Building of regulator is much needed

The participants had limited knowledge on CEMS. They appreciated this training programme as it gave them a chance to learn on the subject. It was observed that they need more training on the following key aspects of CEMS:

• Suitable technology selection

• Location of device installation

• Mandatory and additional parameters to be monitored

• Appropriate calibration and maintenance of the instruments

• Appropriate monitoring and reporting practices

2. Guidelines and protocols are most important

Most of the problems in CEMS implementation are due to the absence of proper guidelines and protocols. CSE is developing guidelines and protocols which will be ready in October. Once prepared, CSE have to take initiative to get these implemented and disseminated.

System for device certification and lab empanelment are other crucial requirements which are time taking. Till date no improvements have been made in this direction. Further discussions are felt needed to develop a strategy for the same.

3. Even larger Industries are not running CEMS properly

We cannot take even larger industries on face value as far CEMS implementation is concern. JSW steel despite being a large steel plant had no clear idea which stacks require CEMS installation. The location of device installation was also not clear. Calibration and maintenance was all left on vendors and some of them were not running CEMS properly. 

In addition, the third party lab which was carrying manual monitoring for the plant was not skilled enough. During site visit, it was found that they were not following proper methodology even for manual monitoring. No doubt, there might be similar problems in other industries.

JSW steel was expected to have proper CEMS installation and operation. However, it was not the case. If such a large plant has failed to install CEMS adequately, challenges with smaller industries may be more complicated. This certainly demands more training for the industry.

4. CPCB and SPCB’s need to work together

Not all the SPCB’s are adequately interested in implementation of CEMS. Some of the states are not properly following up CEMS implementation in industries. Some have not even installed server for data collection. SPCB’s officials from these states had very limited knowledge even on various guidelines related to CEMS installation, pollution monitoring and reporting. Participants from such SPCB’s had less or no exposure to CEMS.

5. Vendors are not giving right information to industry

Everyone agreed that there are many devices/vendors in the market whose authenticity is in question. Since we have no certification system, participants have emphasized that only certified equipments should be used. 

Even the large and reputed vendors are not educating the industry during the sell of equipment in order compete the price in the market. Need of instructions for the vendors were also raised.

Regulators as well industries also need to develop knowledge base on CEMS.

6. CSE has a major role to play

CSE is already working together with MOEF&CC and CPCB for proper implementation of CEMS but there is a lot more to do. 

• Developing Guidelines and protocols: CSE is already in process.

• Capacity building of regulators: This was the first training on CEMS. Training on best practices on CEMS is also being conducted by CSE through an exposure visit to Germany. Regulators demanded more of such trainings. CPCB officials and other resource person appreciate the initiative. More training needs to be planned. 

• Capacity building of Industry: Such trainings need to be planned for industries as well.

• Developing checklist for stakeholders: Participants and resource persons requested CSE to develop a checklist of “do’s and don’ts” on CEMS for industries and regulators.