Workshop on Continuous Emission Monitoring System

A day long workshop on “Continuous Emission Monitoring System” was organized by Centre for Science and Environment (CSE) on 21st July 2015 at CSE, Tughlakabad Institutional Area, New Delhi. This was the first attempt from CSE to understand and identify the issues in the newly introduced CEMS.

CSE’s two decades of research experience in the Industrial sector had shown utmost requirement of strengthening the pollution monitoring, reporting and regulatory regime in India. Even though the pollution norms more or less have improved with time, monitoring and reporting framework has been weak, therefore, adoption of continuous/ real-time pollution monitoring system is felt important. It is in the initial stage in India, therefore requires stakeholders discussions on pros and cons, technicalities, framework and adaptability etc.

To step in this direction as part of its advocacy work, CSE has organised a workshop on CEMS which involved experts including technical experts, regulatory officials and manufacturers etc.

This workshop was intended to deliberate on the potential of CEMS in environmental regime of the country and the existing capacity of India on CEMS.

The following representatives were present,

Santosh Harish, Post Doctoral Fellow, J-PAL
Abhijith Pathak, Scientist ‘C’, Central Pollution Control Board
V.Thiagarajan, Assistant Director (Lab), Tamil Nadu Pollution Control Board
Deepa Arora, Assistant Scientific Officer, Uttar Pradesh Pollution Control Board
Tushar Mishra, Senior Production Manager, Fuji Electrics
Neeraj Chaturvedi, Scientific Assistant, Uttar Pradesh Pollution Control Board
Venkatesh Rao, Global product manager, Alstom India
Jaya Nangia, AVP-Sales service, Chemtrols
Preeti Malhotra, Director global public affairs, Alstom India
Rakesh Agarwal, Technical advisor, Rave Innovations
Sanjeev K Kanchan, Deputy Programme Manager, CSE
Aditya Batra, Programme Director – Board & Funding, CSE
Abhishek Rudra, Programme Officer, CSE
Soundaram Ramanathan, Research Associate, CSE

Summary of the deliberations

Mr. Aditya Batra welcomed the stakeholders and gave an overview on the Centre for Science and Environment and it’s Green Rating Project (GRP). Mr. Sanjeev Kumar Kanchan then gave a brief summary on Continuous emission monitoring system’s need and initiated discussions on the need for a framework of legislation as in the United States (US) and European Union (EU) to streamline and initiate continuous emission monitoring as an effective regulatory regime for pollution monitoring and control. He also shared about the poor state of emission reporting in the industry. Examples were quoted from the GRP study where Indian coal-based power plants reported abnormal NOx emissions of less than 0.1mg/Nm3 while the global best NOx emissions (with control) is reported to achieve 80mg/Nm3. Similar findings on unreliable reporting of SO2 PM emission was also shared. Following are the key discussions to understand the US and EU framework during the first presentations:

Blatant reporting and regulation: Mr. Abhijit Pathak, CPCB agreed that blatant reporting errors were happening on the ground and could be avoided in future with more robust data from CEMS. He shared that there is another problem with our regulation which fails to deal with such violations. In India, such violations are dealt under criminal law, unlike EU and US where civil law works. Under criminal law, emission trading system can’t work. Pilot level trial that CPCB has started is in very early stage and is facing many challenges; we are in data collecting phase.

Device inherent Error: Mr. Sanjeev, while discussing EU framework for CEMS, shared the provision of inherent error (PM- 30%, SOx, NOx-20%) with the device and raised the question if such uncertainities are possible in the device how compliance shall be checked? Mr. Pathak, answered that apart from error in device other issues like error in calibration gases are also the issues CPCB has to deal. We are dependent on imported gas analysers and calibration gas. Calibration gas, during import, gets some error due to temperature, pressure changes. People also use, expired calibration gases which doesn’t give correct result. These issues make compliance check very difficult. CPCB is still in process to deal with that.

Valid and invalid data: Mr. Sanjeev shared that EU, USEPA, discusses about valid and invalid data recording by CEMS device but CPCB is not talking on these things in notification. Data during abnormal conditions (start-up, shut down etc.) shouldn’t be checked for compliance. Mr. Pathak shared that CPCB has not discussed this yet. Our biggest challenge is to implement the CEMS successfully and collect the data. Once we collect the data, we experience the system, we can get into fine tuning it, shared Mr. Pathak.

During presentation, Mr. Sanjeev shared that US, EU framework, as presented, are well establish and advance. How we can learn from these and adopt considering Indian conditions, is a challenge. Current format of CEMS notification) needs serious improvement.

Point to point discussion was carried in following presentations:

Mr. Pathak presented an overview on the efforts made by CPCB to push CEMS

Listing various notifications and guidelines put forth by CPCB with regard to CEMs, Mr. Pathak agreed that the CPCB initially had issued certain directions and guidelines which were incomplete and difficult to implement by industries. These directions and draft notifications were issued without ensuring perquisite. We had issued direction to install CEMS equipment, but deadline was short so it kept delayed.

Regarding the issue of draft notification for CEMS, we understand there is a lot of problem. However the board is working steadfastly to review and ensure proper guidelines in the coming time. Some key points shared by him are:

Certification: USEPA and EU framework of CEMS is well developed but can’t be adopted as such in India. We have to develop the system for Indian condition. Device certification agency like MCERTs, etc. for certifying sensors are currently not available in India. For this, indigenous certification of analyser will be done with the help of NPL. Certification of calibration gas is a challenge we have not found the exact answer yet.
Selection of device: Clarity on the technology option matrix for different pollution parameters is currently being updated by the CPCB. Number of technologies is available for CEMS which CPCB has provided in the guideline to the industries. CPCB is aiming to leave it on industry’s discretion to choose the technologies available to monitor a single pollutant.
Number of pollutants to be monitored is high: Another challenge is the number of pollutants required to be reported by industries. It is not clear that all the parameters are to be monitored by CEMS or not. Some industries like hazardous waste incinerators, pesticides etc. have to monitor a number of critical pollutants such as HCL, HF, P2O5, PCDD/F which are released in very small amount and are technically very difficult, time taking and costly to monitor. We have less expertise for these. In some case, monitoring the parameters are not affordable such as in bio-med waste incinerator. CPCB in the beginning is focusing on PM, NOx, SO2, CO, HCl. Cl2, NH3 and F only. Additional parameters – flow, temperature, moisture, O2/CO2/CO are required to be monitored.
Certification and laboratory empanelment is a critical issue. We have to depend on internal certification system until we develop our own. None of our lab is competent to do that. Training and capacity building if required not only for lab but also for industry officials and SPCBs. Industry and SPCB people have problem in manual sampling which is required during verification for CEMS also.
Calibration: Talking about the importance of calibration, Mr. Pathak highlighted various gaps in the current calibration processes. Ideally three calibrations – one at full load and the other two at part loads were essential. The present system of one point calibration was leading to severe errors in dust load factors. Mr. Pathak discussed plans to mandate three point calibration through provisions and to make certified calibration gases (SO2 NOx, CH4) available through NPL and CSIR, India. He mentioned that Dr. Praval Gupta and Shankar Agarwal of NPL, CSIR could be contacted for purchase of certified calibration gas.

Representatives from Fuji electrics, Chemstrol, raised the point that current guidelines don’t mandate detailed calibration need and highlighted the difficulties in obtaining certified calibration gases.

Mr. Pathak, said that another challenge CPCB are facing in states like Tamilnadu, Gujaratand Maharashtra, is the range of with imported analysers. For example we have norm of 400mg/Nm3 for SO2. The device monitoring range should be 200-600 ideally, but the instrument imported have inbuilt range of 20-1000mg/Nm3. Now when industries monitor the emission it is reported low 80mg/Nm3 which is incorrect. CPCB is in process to set the calibration range for the equipments (2 to 2.5 times) at different load of the operation.

Mr. Pathak also requested the manufacturers to make provision to allow recording of zero logging, which is not happening with CEMs device.

Manufacturers were further urged to calibrate the entire system (Calibration gas must pass right from the tubes till the device while calibrating) rather than the device in isolation.

Here, Mr. Rakesh Agarwal also requested CPCB to urge NPL to supply calibration gas at least with two years shelf life. Currently NPL supplies calibration gas with a year shelf life warranty and imported calibration gases have two years shelf life. However imported gas transport and storage are supposed to happen at very low temperatures. Maintaining such low temperatures is proving costly, poor maintenance often leading to changes in gas specifications.

• Data recording and compliance: Data recording and validity of the data was also discussed as a major issue. Mr. Pathak, clarified that a plant would be required to give data for atleast 85 percent of its total operational time. CPCB has not discussed anything on valid and invalid data. Priority is to ensure CEMs installation, make it in practice and collect online data as far as possible. Once we experience how the system works, we can make improvements.

Mr. Sanjeev questioned that like CPCB has mentioned, “Is it possible that all the data complies the norm?” Even EU or USEPA don’t put this criterion despite having well sophisticated system in place. Mr. Pathak agreed that it is truly not possible. But this is something we have been instructed from the top. On compliance check, the stakeholders were of the opinion that CEMs data must not be used immediately for any compliance related action as it is in the trail stage.

Mr. Rakesh Agarwal quoted an incidence of his client who was issued notice by the pollution board for exceeding standard for just few minutes in a day. The industry then was not so enthusiastic and was trying to switch off the instrument thereafter putting forth excuses.

Here, Mr. Pathak clarified that presently the board’s intention was only to collect data and is not use it as a means to monitor compliance of industries, at least for the coming year or two until full-fledged installations and data acquisition happen.

• Mr. Pathak also emphasized that none of the standards from abroad like the US, China or EU would be adopted until the suitability to India is ascertained. Monitors used in EU and USEPA, works at different atmospheric temperature, different flue gas quality, so the equipments need to be suited at Indian conditions. The CPCB plans to fetch data for various pollutants for a year to observe variations etc. and then propose to cut-off levels.

Next session was started by Mr. Sanjeev to collect information on Indian framework on CEMS

Different points/recommendation on CEMS in India

• Installation on CEMS device: Mr. Pathak shared that however there has been postponement of the deadlines, but most of the industries directed for, have installed the CEMs device. For selection of device CPCB had given possible options, and industries have choosed based on their requirement. For gas analysers, extractive type system is more common. But there is a catch to ensure and record the dilution of extracted gas; flue as need to be monitored at the entry of analyzer and at the dilution point also.

Mr. Sanjeev questioned that different types of devices may have different technologies so it may be tedious job to inspect and verify the calibration by SPCB. Huge manpower and training will be required. Mr. Pathak agreed that training will be required and CPCB has already started the training.

• Cost-issue: Mr. Sanjeev, questioned if costs presented a major issue, since the devices are imported with no other indigenous manufacturers available. However, according to equipment manufacturers like Alstom and Chemstrol - only sensors were being imported while other components were available locally. Only, two companies – Scitech and IFI in Pune manufacture sensors locally. Manufacturers also said the cost of installation of CEMs very insignificant when compared to project costs, CEMs installations run fourth digit when compared to the actual project costs.

• Certification and Laboratory empanelment: Labs in India are not that competent to certify the device so we have to depend on international certifications like MCERTS, TUV. BIS was approached but it declined. NPL has agreed to be the certifying agency. Till the time, the system is put in place, international certification system will work. All the systems, already installed are certified by international agencies only.

Laboratory will be tested before get empanelled and the certification will have to be renewed periodically based on test. Mr. Sanjeev asked if the perquisites such as specifications, guidelines, test process etc, are ready. Mr. Pathak answered that detail specifications and guidelines are being prepared. Some of the guidelines for system are already available but these need to be referred under notification to make it a legal document.

• Calibration and Zero and span check: Mr. Sanjeev shared that calibration frequency has been kept very high. Shouldn’t we keep it lower? Mr. Pathak agreed that calibration may not be required in such high frequency if zero and span check is carried properly.

Daily zero check has been asked which is possible. Span check needs costly span gas so has been asked to do weekly. All the stakeholders should suggest on this. We are also learning these things, suggestions will help CPCB to improve this. So far, CPCB has not received any comment from CEMs.

• Data recording and compliance: Mr. Sanjeev asked that 85% data recording by CEMS has been asked by CPCB. How much of it should be valid? How data gap will be filled? Mr. Pathak answered that we have no experience of CEMS so far in India. The data we are collecting under ETS pilot programme also sees frequent problems, so it will be achievement even if we get 85% data collection, CPCB has not been talking about valid or invalid data yet, since collection of enough data is itself a problem. After a few years experience of the data, calibration and issues of system, then only we can think of fine tuning it.

There is also not any clear idea on cycle on data collection for various pollutants. It depends on the system, higher frequency is preferred. But no clear guidelines are put.

On issue of compliance check, Mr. Sanjeev asked whether we should check compliance on hourly, daily, monthly or yearly data, similar to the US and EU or not. Mr. Pathak and other stakeholder agreed that every single data compliance provision is laughable. But CPCB has no clear idea on it, and require inputs from stakeholders. How to decide on hourly, daily or monthly data compliance is a challenge.

Mr. Rakesh Agarwal added that CPCB has asked that if emission exceeds the norm for more than one hour industries have to take necessary action and inform SPCB immediately about the issue, actions taken and affect of corrective action. This is not practical. A shift incharge, working in night schedule, can’t take corrective action on his own, if there have been any such issues. He needs authorization from author. Therefore, on any such issues, information can be send to the SPCB but mitigation action needs time.

Mr. Agarwal also raised the questions on effluent monitoring. The notification doesn’t discuss on how the data will captured and checked for compliance in batch process or industries with intermittent effluent discharge. There has been incident where in intermittent discharge case, a plant reports some data during discharge and zero during non-discharging conditions and SPCB issues notice to the plant for not giving continuous data. Mr. Pathak conveyed that these issues have not been dealt so far but are required to. Please give suggestions.

• Data tampering issue: Mr. Sanjeev asked about the assurity of no data tampering with CEMS. Stakeholders shared that there has not been any system which cannot be tampered. We can only believe on the data, put penalty on operator, do more vigil on industry.

• About capacity building: On the topic of training and capacity development Mr. Pathak mentioned that 150-200 SPCB officials pan-India had been trained so far on CEMs installation. He agreed that more training and capacity building initiatives would be required not just for the state pollution boards but also towards manpower development in labs and industry.

Experience of CEMS in States by SPCB

SPCB people from UP, Uttarakhand, Tamil Nadu, Gujarat, Maharashtra were invited. Only UP and Tamilnadu officials attended. UP people shared that, CEMS has not been set-up in their region, so they don’t have experience and idea of it. There has not been any training and information shared to them, shared Mr. Neerraj, UPPCB. Tamilnadu official shared his experience in detail. Experience in Tamilnadu is below:

V.Thiagarajan, Assistant Director (Lab), Tamil Nadu Pollution Control Board shared his experience of CEMs installation.
More than 303 industries in Tamil Nadu have installed CEMs. The data is collected and monitored by officers on 3-hour shift basis 24x7.
SMSs are sent by the industries during start-up and shut down of industries. R. Dhanasekaran is the officer at the board in-charge of CEMs.
During initial days TNPCB had difficulty with interface software used - like compatibility issues between the server software and certain devices installed at the industries. This has led to a monopoly by certain software platforms in Tamil Nadu.
Costs were also reported to be a key issue

Other stakeholders shared that capacity building is required. Installation of CEMS, calibration, is not being followed. Manual sampling results are not matching CEMs data due to poor installation, poor sampling and calibration of equipment.

On emission trading scheme by CPCB and JPAL

Mr. Sanjeev requested JPAL and CPCB to share the progress of emission trading scheme in Gujarat, Maharasthtra and Tamilnadu. He questioned, if CPCB has plan to implement it to other state, based on the experience in these 3 states.
Mr. Harish, shared that JPAL is involved in it with CPCB. So far, installation of CEMS device and data collection is being done. We have been training SPCB official on CEMS system. Trading system has not been put into place. Different kind of industries, different operations, calibration, data collection and transfer etc. is being a challenge. We have not much progress in trading.
CPCB further added that trading of PM or other pollutants were not legally feasible under the present environmental protection act since it came under criminal proceedings. The violation of a standard is treated as a criminal offense in India and not a civil offense which can be mutually settled by adopting methods such as trading, rather the industry has to be punished for violations and damage.