Emissions reduction |


In January 2019, India’s National Clean Air Programme (NCAP) announced a reduction target of 20% for PM2.5 and 30% for PM10 in ambient air by 2024 relative to 2017 as the base year, with the contribution of the coal-fired power sector, thanks to the new limits, expected to be significant. Unfortunately, this was not to be, and the new norms did not help. The new emissions limits notified in December 2015 were supposed to be met by December 2017. India’s Ministry of Power (MOP) formed a committee in 2016 which, in June 2017, recommended a stage-wise compliance plan for the PM and SO2 a relaxation of the NOx


limits but proposed emission limit to 600


mg/Nm3


. It also pushed the 2017 compliance deadline to 2022. This issue was raised in the Supreme Court of India, seeking a direction from the government to follow previous deadlines. The Environment Pollution (Prevention and Control) Authority (EPCA), a Supreme-Court- appointed committee for pollution control in the Delhi–National Capital Region (dissolved in April 2021), also recommended earlier implementation of the new norms – PM and NOx


standards by 2018-19 and the SO2 limit by


2020, without any relaxation. This was contested by the MOP and the Association of Power Producers.


The coal plant sector has come to accept that compliance with the new PM emission limits can be achieved by upgrading ESPs and that the installation of FGD equipment can deliver compliance with the SO2 with the new NOx


limits was neglected as they


were considered unnecessary and too costly. Raising the issue of domestic coal quality, the MOP, meanwhile, appealed for relaxation of the NOx


limit from 300 to 450 mg/m3 , which was


subsequently notified as the new standard. An ICSC report (Adams et al, 2021) concluded that a limit of 300 mg/m3


was achievable. Various pilot-


scale technology studies jointly carried out by technology providers and India’s leading power producer, NTPC, had allegedly shown this, but various media reports claim that the findings were presented to portray the non-suitability of SCR and SNCR technology to avoid investment and support relaxation of the norms. In July 2018, the Supreme Court of India rebuked the MOEFCC for its inability to enforce compliance with the 2015 standards. The MOEFCC, the MOP, and the CEA asked the Supreme Court for a further extension, to December 2024, pointing to the inability of power plants to allocate the required capital and operating expenditures within the previous


time frame, as well as the lack of available space, water, and necessary raw materials. The Supreme Court granted a five-year extension of the deadline to December 2022.


This was not the end of the matter. Since the


norms were relaxed and could be met via combustion optimisation, a residual issue for the majority of plants was the need for a large investment in FGD installation. In January 2021, the MOP proposed a stepwise FGD implementation schedule (to MOEFCC), with priority given to the power plants in the low ambient air quality areas, highlighting considerations such as shortages of equipment available on the market, increasing imports instead of indigenous manufacturing, the price burden on utilities and consumers, and possible loss of opportunities to develop national resources and foster Indian skilled manpower. This stepwise FGD implementation timetable based on the categorisation of power plants was adopted in 2021, pushing the compliance deadline from December 2022 to December 2025.


NOx


Although a CEA report, Review report on SO2 norms, 2021, mentions the idea of pushing the


norms. But compliance


deadline to 2034, at the time of writing, the deadline for compliance with the new limits of December 2025 remains in force. Indian coal-fired power plants have been ranked according to their proximity to populated areas and polluted regions and placed into one of three categories, A, B and C. They have been allotted new deadlines, with penalties for failure to comply (see table below).


Under these rules, the penalties for non- compliance range from Rs 0.05 to 0.20 per unit of electricity produced. A non-compliant 500 MW plant operating at 60% capacity would need to pay Rs 32.84 crore (about $4 million at the current conversion rate) per year. Over the same period, this plant would generate around 2628 GWh of electricity, earning it around Rs 1427 crore (about $184 million at the current conversion rate) at a power price of Rs 5.43 per kWh.


Unwillingness to comply The Indian power generation sector’s unwillingness to meet new standards was evident from day one. The position of “not doable” in the beginning changed to concerns about cost, technology, and timelines, influenced by public pressure, judicial intervention, and global attention. Undoubtedly, the challenges arising from the scale of the investment required, technology suitability


and availability, and the short timelines were genuine, but compliance was surely achievable had the government been proactive, with timely planning, co-ordination, and support. This was lacking initially. In time, the coal-fired power generators realised that the new standards could not be derailed completely. Also, the government increased its efforts to make it happen (albeit with significant delays) by making provisions for investment recovery via added tariffs, stretching timelines and promoting pilot- scale technology tests.


Not only was the first deadline of 2017 a failure, but studies also indicate that the revised deadline of 2022 is unlikely to see sufficient compliance.


A 2020 survey by the Centre for Science and Environment, a Delhi based NGO, found that most plants had ESPs installed, and with suitable upgrades, nearly 73% of them could meet the new norms by the 2022 deadline. In contrast, only 20-30% of plants could comply with the new SO2


and NOx limits by the same


deadline. While FGD installation issues received attention and could be evaluated, information on NOx


available. Since the NOx 450 mg/Nm3


opt for combustion optimisation for NOx


control measures was much less readily norm was relaxed to


, most of the plants are expected to control


and not SCR or SNCR installation. Compliance with the mercury norm has not received much attention as it is not generally considered a problem and, as already mentioned, it is believed that it can be easily met as a co-benefit from the installation of ESP, FGD and SCR. An ICSC assessment has found that the Indian government’s continued amendments, derogations and delays have compromised the pressure on utilities to comply, making the new standards less effective in achieving the health benefits in a demonstrably cost-effective manner. India, therefore, continues to face a significant task in closing the gap between what it wants to achieve in respect of coal plant emissions reduction and what can be achieved.


Lackadaisical CEMS implementation Accurate and reliable emissions data for each coal-fired plant is therefore of the utmost importance and, here, correct implementation of real-time pollution monitoring is needed, in place of manipulated, or estimated data, as a basis for sound policymaking and the taking of appropriate corrective actions.


Unfortunately, the status of real-time emissions monitoring at Indian coal-fired power plants is not very encouraging.


Ranking of Indian coal-fired power plants, compliance deadlines and penalties for non-compliance (MOEFCC, 2021) Rank Category


Location/area 1 Category A 2 Category B


Within 10 km radius of National Capital Region or cities with a population >1 million


Within 10 km radius of a Critically Polluted Area or Non-attainment City


3 Category C Plants not included in Category A and B Timeline for compliance


Non-retiring units


Up to 31 Dec 2022


Up to 31 Dec 2023


Up to 31 Dec 2024


Up to 31 Dec 2022


Up to 31 Dec 2025


Up to 31 Dec 2025


Penalties for non-compliance (Rs/kWh) Retiring units 0-180 days 181-365 days >366 days 0.10 0.07 0.05 0.15 0.10 0.075 0.20 0.15 0.10


14 | May 2022| www.modernpowersystems.com


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