Centre for Science and Environment (CSE) carried a survey of industries engaging with some state pollution control boards (SPCBs) to understand the status of CEMS implementation in India. CSE also completed training cum exposure visit to Germany on the best practices and policy framework needed for successful Continuous Emission Monitoring System (CEMS) implementation and prepared a task force report based on the learning from visit. Our assessment is that there are gaps in implementation of the CEMS programme and one of the critical issues is lack of guidelines for CEMS implementation. To bridge the gap, CSE has prepared a document on “draft guidelines for CEMS implementation in India” in consultation with experts from Europe. The document covers information on issues like- selection of suitable device, correct installation, performance check, regular maintenance and compliance check.
To discuss on the draft guidelines, CSE organized a multi-stakeholder workshop on 10th and 11th November 2016 at CSE, New Delhi. The workshop agenda included discussion on the draft guidelines document for CEMS and strategy for lab accreditation and device certification system in India.
This workshop involved participants from SPCBs, Industries, CEMS manufacturers, service providers, laboratories and CEMS expert committee members. The stakeholders actively participated in brainstorming and come up with important suggestions which could be useful in proper implementation of CEMS.
Brief on the workshop
The workshop began with an introduction of CSE's initiative to support CEMS programme in India. The findings of the survey conducted by CSE were shared and the need of the guidelines for CEMS was emphasized.
Central Pollution Control Committee (CPCB) also shared that they are working for drafting guidelines and protocols for CEMS for Indian scenario. Taking this workshop as a platform, all the stakeholders discussed on the guidelines and strategy for way forward.
Based on the discussions, the workshop has come up with following recommendations:
1. Suitable technology/device selection
A technology matrix is required. For correct device selection for PM CEMS, a table should be provided for parameter matrices including stack diameter, particle size, moisture content, measuring range, isokinetic sampling and velocity.
The guideline should be sector specific covering gases to be measured with ranges for each type of process unit stack. For example, blast furnace, coke oven battery etc. in steel plant
A sector wise best available technology (BAT) matrix can be referred for technology selection guidelines. For example, waste incinerator or a cement kiln using incineration of waste / petcoke/bio mass will have a high moisture background of 40 - 60 vol% level with soluble gases like HF, HCL, NH3, VOC, etc and will require Best Available Technology recommendation. Example: multi component FTIR spectroscopy for reliable measurements.
Guidelines matrix should cover for the different type of fuels. For example, cement kiln stack with only coal fired the measurement of CO, SO2, NOx may be fine, however alternative fuel operation using petcoke, waste, coal, bio mass, etc. may have to measure different parameters.
The guidelines should put forth applicable technologies only rather than all available technologies. Those technologies not in use should not be recommended in the guidelines.
It has to be clarified whether inbuilt QAL3 equipments are acceptable or not.
2. Correct installation and operation of CEMS
Guidelines on installation of CEMS location and isokinetic procedure should be defined and indicated.
At the time of installation, performance check should be mandated for new CEMS. The tests, procedures and standard reference methods should be indicated.
Testing and calibration of CEMS, not only the analyser but including probe, sampling line and other accessories, by an accredited lab should be mandated to be done within 6 months of time. The labs accredited by NABL/EPA/CPCB can be considered and trained for this.
Acceptable uncertainty related to parameters should be clearly defined along with norms.
In long go, laboratories for calibration and testing can be assigned randomly by local state regulators to bring transparency and credibility in third party tests. A similar system is being followed by GPCB in Gujarat.
The specific corrections such as for O2, CO2, temperature, moisture etc. should be specified with respect to particular technology. For example, In-situ technology is exposed on online dynamic interference of stack flue gas from temperature, pressure & moisture needs online measurement for correction. However, extractive type measures under controlled temperature, pressure and after moisture removals. Hot extractive type measures with moisture will require measuring H2O for correction online.
Formula for normalization should be a part of the guidelines for industry / vendor to follow. As per EN standards this specific point has been clarified that CO2 cannot be used for correction / normalization as the CO2 curve is inverted bell shape and therefore O2 is used for online CEMS correction / normalization. CEMS with two-way communication protocol should be mandated. Existing one way installations should be asked to shift gradually.
A harmonized maximum response time for the CEMS should be indicated. For example in EU maximum response time is given as 200 seconds. May be a chart with response time of analysers and relevant parameter can be prepared.
Proper operation and data collection demands correct installation and maintenance of device. For example, the guideline should mandate installation of heated probe (above dew point), operational air conditioning of the analyser panel/ room. Ambient corrections /controlled environment at site is necessary for reliable CEMS, so can be mentioned in guidelines.
3. Roles and Responsibility
Clear responsibility matrix is required for operator, analyser vendor, regulator, and data server operator.
Plant operator should be clearly made responsible for source emissions, infrastructure like stack holes, ladder access, platform, stack flue gas testing, analysis data and availability of utilities such as power supply etc.
The second day of the workshop was focused on two important requirements for up scaling proper implementation of CEMS in India - Device Certification and Lab accreditation/empanelment. The discussion started on the importance and need of device certification and lab accreditation/empanelment in India and the prevailing system in United States of America (USA) and Europe (EU).
Based on their understanding, the stakeholders recommended the following:
1. CEMS Product Certification
Certification of complete CEMS system (including analyser, probes, sampling line and other accessories) is needed. The guideline, standards, protocols are well proven and defined in the countries like UK, Germany etc. which can be adopted.
CPCB can take lead and initiate the process with consultation to the organizations like BIS, TUV etc. External agencies are ready to invest in the facility; however, they may require assurance. These external agencies may be asked to submit the proposal for setting such a system. A strategy should be prepared to develop the basic system in two years.
Till the certification system is set-up, performance testing of CEMS during installation should be mandated. NABL recognized laboratories can be trained to the job of performance testing during installation. The tests, standard reference methods etc. shall be defined. These labs need to be trained by the time.
A list of certified products /manufacturer can be published. It came to notice that some manufactures is carrying certificates from labs which are not accredited to certify the CEMS in India.
2. Lab accreditation
Accreditation of lab is crucial for performance testing during installation, calibration and testing during operation and maintenance. Lab accreditation system must be set-up within 2 years. NABL appears to be the most suitable organization which follows EN 17025 and falls under ILAC and performs accreditation for labs already but not for CEMS. NABL can be consulted for this. They would require to be accredited for carrying the relevant tests. Other competent agencies like NPL can also be explored/ considered for this.
If third party periodical testing and calibration by accredited lab is mandate, independent labs themselves will come forward and develop the facility. They may require training for this.
For detail, please contact the undersigned
Sanjeev K. Kanchan
Programme Manager | Environmental Governance- Industry
Centre for Science and Environment | 41, Tughlakabad Institutional Area, New Delhi-110062
Phone: 011-29956110, 29955124-25, Extn.-266
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|Draft Guidelines for CEMS
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|CEMS Laboratory Accreditation/ Empanelment for CEMS
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