With a view to bring transparency and industrial self-regulation, CPCB has introduced CEMS for modern and robust online monitoring of effluents and emissions in all types of polluting industries in the country.
Central Pollution Control Board (vide its letter No. B-29016/04/06PCI-1/5401 dated 05.02.2014) issued directions under section 18(1) b of the Water and Air Acts to the State Pollution Control Boards and Pollution Control Committees directing highly polluting industries, Common Effluent Treatment Plants (CETPs) and STPs, Common Bio-Medical Waste Incinerator and Common Hazardous Waste Incinerator for installation of online effluent quality and emission monitoring systems for tracking the discharges of pollutants in a self-regulated manner. The list of industries is as follow:
- Dye & Dye Intermediate
- Chlor Alkali
- Iron & Steel
- Oil & Refinery
- Power Plants
- Pulp & Paper
- Textile (GPI) Diary (GPI)
- Slaughter House
The draft notification highlights the need of CEMS equipment for pollutant monitoring on a real time basis and to develop a system to satisfy the data quality objectives in order to implement a more transparent mechanism of environmental pollution control. For strengthening the monitoring and compliance through self-regulatory mechanism, online emission monitoring systems need to be installed and operated by the developers and the industries on - 'Polluter Pays Principle’.
The draft notification enlists a number of mandatory reports to be filed and records to be maintained. Any exceedance of values in the emissions over the prescribed standards or norms shall be considered as violation.
Selection of CEMS is the sole responsibility of the industry. CEMS shall be selected in light of their its suitability for respective flue & effluent matrix in terms of parameter type, ruggedness, data accuracy, precision & robustness, desired facility of data acquisition, handling and transfer to respective terminals including regulator for a smooth and tamper free data management.
Your choice of CEMS shall have COP (Certificate of Product) from any international agency like TÜV SÜD. Indigenous CEMS without COP needs to satisfy the performance requirement at par with internationally certified products equivalent to QAL1 and QAL2 standard or EPA performance standard criteria (40 CFR Part 75 Appendix B). Thus, TÜV SÜD advises to carefully scrutinize COP of CEMS to dodge any future non-compliance. Issues in Implementation of CEMS in India.
- Issues among the industries regarding CEMS selection
- Hyperactive business strategy of Vendors
- Knowledge gaps among Industries and even regulators
- Number of Stacks to be covered
- Presently Industries are interested to just comply with the direction by installing CEMS irrespective of fitness and performance of devices, investment is the only driving factor
- SPCBs are putting CEMS installations in Consent conditions in addition to the directed industries
- Most of the systems already installed are either not calibrated or wrongly calibrated
- In absence of any guidelines and limited clarity in issued direction the selection of components for a CEMS are not holistic to satisfy the requirement of regulation
- Competence of Vendors, laboratories, industries have not developed for calibration
A stakeholders’ survey conducted by CSE revealed, 15% incorrect installation and 15% equipment failure in CEMS already installed in industries. Mostly due to lack of knowledge about suitability of CEMS devices available in the market.
According to the guidelines, the industry is required to supply information to the SPCB and CPCB by means of registration for a new CEMS installation and also to update the existing database with information like Name of industrial premises / Facility, installed control devices, Stack height, Stack diameter (ID), CEMS type, make, model etc., CEMS analyzer types, List of parameters monitored, Date of installation and initial calibration, etc.
Furthermore, the operator shall provide a detailed description of all parameters to be monitored and their expected normal & maximum values to be measured.
All industrial premises / facility that fall under the Air (1981) Act, EP (1986) Act and its revised regulations are to submit / update the database, based on individual operating consent issued by SPCBs.
The system comprising of different units / peripherals installed to sample, transport, condition, analyze, calibrate, acquire data, record and transmit the emission data uninterruptedly to regulator on a real time basis without any editing/tampering is collectively called a Continuous Emission Monitoring System (CEMS)
The CEM system shall comprise of the following:
- Instrumentation(s) and program(s) that will sample & analyze and quantify the concentration of the specified pollutants in the gas stream.
- Instrumentation(s) and/or program(s) that will determine the flow rate of the gas stream.
- Instrumentation(s) and program(s) that will record and process the information produced and yield electronic and printed reports showing the emission rate of the specified pollutant with the time resolution.
- The system shall have Quality Assurance programs and Quality Control procedures to ensure that all measurements are done as per defined Data Quality Objectives and adequate verification and validation protocol is inbuilt in the system.
The guidelines also state stringent installation requirements for CEMS. The analysers/ instruments/ sensors have to be installed as per the specified sampling criteria, so as to have representative sampling of the emissions.
For example, all measurement ports into the stack shall be as per CEMS system requirement. Particulate CEMS devices (Cross Duct) or probe must be installed in horizontal plane; while, those for gaseous CEMS shall be installed protruding downwards, with suction system facing the direction of flow of flue gases. The construction of chimney shall adhere to CPCB publication, “Emission Regulation Part III” (COINDS/20/1984-85) unless otherwise specified by CPCB or SPCB/ PCC.
Apart from this, you must take interference, safety, serviceability, clear approach, etc. into consideration while selecting the location for CEMS installation. The update also states the calibration range for Particulate Matter Continuous Monitoring System (PM-CEMS) and criteria for acceptance of CEMS field performance. The report highlights several other technical and non-technical aspects that need to be considered while selecting and installing CEMS.
The following records must be retained and made available to SPCB/PCC/CPCB for inspection upon request:
- All pertinent information, manufacturer literature, phone logs, meeting notes
- Operations and maintenance records
- Emission measurements, system performance specification test data and field accuracy tests, calibration checks
- Excess emission reports, instrument logbooks, downtime, adjustments and maintenance
- For unusual values reported by CEMS - the reason for it with documented evidences must be recorded.
- The history of zero/span adjustments and calibration must be kept available for inspection.
The following reports need to be filed from time to time:
- CEMS Performance Test Report
- Report of Excesses Emission
- Monthly Monitoring Report
- Quarterly Monitoring Report
- Annual Report
Though the guidelines are currently in the draft stage, CPCB has already issued directions on February, 2014 to mandate installation of CEMS in 3260 industries listed under 17 Heavily Polluting Industry Categories. While the CPCB and the Ministry of Environment, Forest and Climate Change (MoEF&CC) is working tirelessly on a comprehensive technical guideline, days are not very far when CEMS would become a standard practice across all polluting industries.
Moreover, given the long-term benefits of CEMS installation viz. cost, regulatory compliance, integrating environment-friendly management practices and qualification for participation in the revenue generating Emission Trading, we strongly recommend industries to install CEMS.