CSE strongly believes that it is crucial to involve the key CEMS stakeholders in the process of implementation of CEMS in India. This is why, the CEMS expert committee has been set-up to support, provide feedback and guide on the initiative taken by CSE in this direction. The expert committee constitutes following members:
J. S. Kamyotra, Director, CPCB
D. Saha, Incharge & Head- Air Laboratory, CPCB
Abhijit Pathak, Scientist B, Air Laboratory, CPCB
R. Dhanasekaran, Assistant Director, Care Air Centre, TNPCB
S. M. R. Prasad, Assistant Vice- President, JSW Steel
Tejbir Singh, Assistant Vice President- Marketing and Business Development, ABB
Sameer Bhandarkar, Business Unit Head, Forbes Marshall
Mayank Chauhan-CEO- Logic Ladder
Members from CSE
Chandra Bhushan, Deputy Director General, CSE
Sanjeev K. Kanchan, Deputy Manager, CSE
Kanika Bahel, Research Associate, CSE
The first meeting of CSE’s CEMS expert committee was called to discuss the present status of the CEMS framework, its gaps and measures need to be taken to bridge these gaps. The broad objective of the meeting was to discuss the strategy and timeframe of various initiatives to be taken by CPCB, CSE and others stakeholders in order to help successful implementation of CEMS in India.
Key points of discussion
Post introduction, the committee discussed the present status of CEMS installation and various issues. CSE shared that CEMS is a very important tool that can take our environmental regime to a new level. It has potential to solve many of the problems with our existing conventional pollution monitoring regulation. Therefore it is crucial to implement it successfully. CSE also mentioned that rounds of meetings have taken place between CSE and CPCB, where short term and long term approaches to bridge the gaps in CEMS implementation were discussed in details. CPCB and CSE have agreed to work together on it. The experts are expected to give advices and support in this programme.
The discussed key activities and plan for CEMS implementation are as follows:
1. Publishing guidelines and protocols instead of draft notification: Experts discussed that there are some basic requirement to ensure before notification is finalized. Some of them which shall be dealt quickly- are preparing guidelines and protocols for CEMS installation, performance test, and calibration etc. It was agreed that it is better to publish different sets of guidelines/protocols, instead of notification, as it is easier to modify at a later stage.
2. Suitable device selection and installation: Most of the 17 categories industries have already installed CEMS, however device selection and installation is not perfect due to lack of adequate skills and information among industries. The present status of device selection and installation need to be studied. To understand the present status of implementation, CPCB and CSE are carrying independent survey.
It was discussed that large scale industries managed to install CEMS somehow, which may not be possible for comparatively smaller Red category of industries. Some SPCB’s have started asking red category industries to install CEMS. It will be important to provide proper guidelines and protocol to them.
It was agreed that CPCB will be preparing device selection matrix – based on device accuracy, error, range, availability and cost etc.
Experts will also review PM CEMS and Effluent CEMS guidelines documents and provide feedback. PM CEMS technology matrix will be reviewed for Thermal power and Cement sector. Gaseous CEMS technology matrix will be developed considering key sectors- Cement, Thermal power (>=500MW and captive TPP) and refinery.
ABB and Forbes Marshall will give feedback on how well PM CEMS technology is working.
3. Location of CEMS device installation- CSE shared that industries also have no clarity on type of stacks and the location in the stack where CEMS is required to be installed. Presently, directions ask for CEMS installation in all the stacks. However, TNPCB doesn’t ask industry to install CEMS in all stacks but only in the stack where relevant pollutants are emitted and controlled for compliance.
CPCB agreed that it will clarify which all stack are not required to install CEMS.
CPCB shared that the draft notification has mentioned the location of device. CSE will prepare a note on the same, with a pictorial presentation and circulate among experts.
4. CEMS data quality- Following will done with respect to data quality:
CPCB will analyse 5-6 paper plants data for water CEMS data quality. Accordingly, provision shall be put for data quality improvement.
TNPCB will also carry analysis on water monitoring data from TNPL.
Many CEMS installation doesn’t have CO2 and O2 monitor which are crucial for data correction. Most of plants have not installed these analysers. Question was raised, whether CPCB can give a direction that such analysers are mandatory. CPCB responded that it will check the possibility.
Data reporting frequency is not uniform. It also needs to be checked to bring uniformity.
5. Performance check of device: Experts discussed that quality assurance through performance check is essential. Till the time certification system/ or special purpose vehicle (SPV) can be set-up, a temporary system need to be put in place. Committee agreed on the following:
TNPCB- will develop an Indian version of QAL2 tests for performance check
Next expert committee meeting will involve 4-5 major labs to understand the ability to carry various tests required for certification or performance check.
6. Guidelines and protocol of calibration: provisions on PM and gaseous CEMS calibration mentioned in draft notification was discussed.
Issue of recalibration on 10% or more deviation of two consecutive values was debated. CPCB agreed that “10% deviation” can be discussed and change for PM, gaseous and water CEMS.
85% data availability is fine at the moment. It can be developed later and increased.
Frequency of calibration was discussed. It was agreed that self calibration shall be at higher frequency- 3 months. If self calibration facility is not available, it has to be carried at empanelled lab. Calibration by third party (empanelled lab) can be at lower frequency- 6 months
Forbes Marshall was suggested to get MCERTS certification. Being a large manufacturer, it should have.
In notification, CPCB proposes the instruments/analysers for real time monitoring of gaseous emissions to be calibrated with respect to their functioning, drift, linearity detection limit, output, operating temperature and other relevant parameters before installing. It was agreed that CPCB will define the permissible range for discussed conditions like range, drift, error etc.
CSE will also get protocol and guidelines prepared from Source Testing Association (STA), UK for CEMS.
7. Lab empanelment: Provisions for lab empanelment mentioned in draft notification were discussed and found more or less fine. Following key points were emerged:
Only EPA recognized lab, most of which are NABL accredited also, will be considered for empanelment.
Proficiency tests will be carried annually.
CPCB need to develop- protocol, manpower and timeline for the same.
Forbes Marshall and ABB- shall provide the information on basic requirements for a lab for CEMS process.
8. Capacity building of CPCB and SPCB labs- Following were discussed:
CPCB will propose the develop calibration facility in CPCB’s head and zonal offices.
CPCB will develop quality control and assurance facility in all central labs in CPCB and SPCB. It shared that air quality lab is already available at CPCB head office, though it has to be developed at zonal offices. For effluent CEMS, the facility is yet to be developed.
CSE will also recommend MoEF&CC for capacity building of CPCB and SPCB labs.
9. Skill building: CSE will carry following trainings for regulators in India and abroad.
CSE will organize a training and exposure visit to Germany for selected regulators. CSE will discuss this with GIZ to help in organizing this programme.
CSE will organize more training programmes for regulators and industries in India.
10. Compliance check should be discussed later. Presently, it is not relevant.
Tasks to be done
Based on the discussion, following tasks are to be done by experts/ stakeholders:
1. To review and provide feedback on following documents:
PM CEMS guidelines document
CEMS Effluent guidelines
2. Provide inputs on Technology matrix for
Gaseous CEMS for - Cement, TPP >=500MW and captive TPP and refinery
PM CEMS for Thermal and Cement sector
Modify calibration protocols (mentioned in draft notification) for (1) PM, (2) Gaseous parameter, (3) Effluent, as per discussion
Develop Technology matrix for gaseous CEMS for - Cement, TPP >=500MW and captive TPP and refinery
Analyse water CEMS data quality for 5-6 paper mills
To propose for CEMS quality control and assurance facility in Central labs and SPCB labs
To develop air quality lab in CPCB- Zonal offices and see the possibility of developing effluent quality lab in CPCB
Setting criteria for empanelment (Infrastructure, quality control, capacity building etc.)
A note of Location of CEMS installation with Pictorial presentation
To get guidelines and protocols developed through STA
Carrying CEMS implementation survey with KSPCB and MPPCB
To carry regulators training and exposure visit to Germany
Trainings in India
Call 2nd expert committee meeting with 4-5 major laboratories
ABB and Forbes Marshall
To give feedback on how well PM CEMS technology is working.
Provide brief information on basic requirement for setting a CEMS calibration lab (onsite and offsite).
Carry analysis on water monitoring data from TNPL.
To develop Indian version of QAL2