Emissions reduction |
CEM data 49%
No CEM data 48%
CEM data 41%
No CEM data 49%
CEM data 42%
No CEM data 49%
Units monitoring for PM
Total = 597
Units monitoring for SO2
Total = 597
Units monitoring for NOx Total = 597
NA 3%
NA 10% Units reporting average annual concentrations
Units reporting no data (due to no CEM involved or no data reporting activity) Units admitting issues with reporting data
Above: Figure 1. CEMS data reporting pattern for Indian coal-based power sector, 2020-21. Source: ICSC, 2020-21
Real-time pollution monitoring was mandated first in February 2014, with the installation of continuous emission monitoring systems (CEMS) for air pollution monitoring and continuous effluent quality monitoring systems (CEQMS) for water pollution monitoring in 17 industries identified as major polluters, coal-fired power generation being one of them. The mandate was later extended to more industries, expanding the real-time monitoring market in India to over $ 800-900 million currently and involving most of the world’s leading technology providers. Real-time monitoring, which has been practised in the USA and EU over the last 40-50 years, has proven its ability to deliver such advantages as credibility, accuracy, timely control, improved process optimisation and self- monitoring benefits; unfortunately, is yet to be properly realised in India.
ICSC assessed the CEMS data from the Indian coal-based power plant fleet for the year 2020- 21 (Figure 1). The findings were disappointing. Even though almost all the coal-fired power plants have installed CEMS, only half of them were sending regular data to the CPCB (Central Pollution Control Board) and SPCBs (State Pollution Control Boards) and the data quality was low. Most of the non-reporting (despite a minimum 85% data reporting requirement) is attributable to CEMS not being in use, CEMS being out of order or under maintenance, plant under maintenance and connectivity problems. Though the non-reporting plants regularly receive notifications from the system and intermittent enquiries from the regulators, the absence of legal enforcement does not encourage plants to abide by the regulations. ICSC’s deep-dive uncovered some fundamental challenges: missing quality assurance and quality control systems; missing third party testing and quality control provisions; inherent implementation challenges in the plants; and lack of required skills and knowledge.
Broadly speaking, there are two basic approaches to CEMS quality assurance and control, the heart of effective real-time monitoring:
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● the EU type regime, which allows only certified CEMS to be installed for quality assurance, followed by a system of quality assurance levels (QALs) for quality control; and
● the USA type approach, which permits non- certified systems but requires a series of performance tests during installation followed by periodical quality control tests.
India chose to have a hybrid of both approaches but failed to create the required infrastructure. In addition, the delay in publishing the guidance manual and continuing lack of required knowledge and skills among the stakeholders created many problems – ranging from selecting incorrect technology to faulty installation, incorrect set-up, missing data validation and standardisation and data tampering. Figure 2 summarises some of the main CEMS implementation challenges in India. Except for big corporates that can afford a sizable skilled technical in-house team, the Indian coal-fired generation industry largely depends on technology vendors for maintenance and troubleshooting and, unfortunately, most of the vendors’ ground- level employees themselves need good training and capacity building, as do the power plant operators and regulators.
A lack of transparency has been another barrier to obtaining the full benefits of real-time
Non-availability of correct point of installation
monitoring in India. Low confidence in the data compels both the CPCB and respective SPCBs to find excuses and seek various ways to evade making data available to the public. The lack of public scrutiny has not helped and has kept the government from using the CEMS data for checking legal compliance. Only a very few SPCBs, including Madhya Pradesh Pollution Control Board (MPPCB) and Odisha Pollution Control Board (OSPCB), have made efforts to publish the CEMS data. The majority remains reluctant.
Indigenous innovation On the plus side, experience with data quality problems across various sectors has led India to indigenously develop some interesting innovations in the area of real-time emissions monitoring. Highly automated and sophisticated data acquisition and handling and the practice of remote calibration are particularly noteworthy.
The indigenously developed advanced CEMS data acquisition and handling system, shown in Figure 3, allows direct data transfer from all the monitors, through the internet of things (IoT) and data logger, in parallel to the central server of CPCB and respective SPCBs without any intermediate device, thus avoiding any potential tampering. With the required authorisation, industry, regulators, and relevant stakeholders
NA 9%
Improper calibration
No performance test of equipment
Inaccurate set-up of equipment
Compliance check
Wrong measurement
No data validation
Non-standardised raw data transfer
Intermediate server between analyser and regulator
Above: Figure 2. CEMS implementation challenges in India. Source: Sanjeev K Kanchan, ICSC, 2020-21
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