No. CPCBjA-21018jETSj Dated: August 13, 2013 To
The Member Secretary,
Maharashtra State Pollution Control Board, 3rd
Kalpataru POint, 2nd , & 4th Floor, Opp. Cineplanet, Near Sion Circlel
Sion (E), Mumbai 400 022
Sub: Guidelines for CEMS - Selection, Installation & Operation - Reg. Sir,
The document titled, "Specifications & Guidelines for CEMS for PM measurement in ETS Program" was mailed to yo~r end on July 01, 2013 for your views j comments. In this series, a brief version of the samel titled, "Guidelines for CEMS - Selectionl Installation &
Operation" has been prepared for circulation to all participating lndustries j industrial associations in an organized workshop, is enclosed. This document would help the industry understand better the CEMS - Selection, Installation & Operation besides development of confidence.
With a view to comply with the resolution taken in the Steering Committee meeting on ETS for rolling out of CEMS in piloted industries in your State, a plan for installation of CEMS is required phases.
It would be appreciated if a consolidated plan for CEMS rollout program is prepared and made available to this office from your end.
Yours faithfully,
Encl:
A/a
~~t.
( J.S.
~m@raT
Member Secretary1
G U I D E L I N E S F O R C E M S
S E L E C T I O N , I N S T A L L A T I O N A N D
O P E R A T I O N
__________________________________________________________________________________ __________________________________________________________________________________Prepared for Industries participating in the Pilot Emissions Trading
Scheme for Particulate Matter from Stationary Sources (Stacks)
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Executive Summary ... 3
Pilot for Emissions Trading Scheme in India ... 3
Role of Continuous Emissions Monitoring Systems for Measurement ... 3
The Role of Different Parties in a Monitoring Regime ... 3
Overview Flow Chart for PM-CEMS Selection ... 5
Purpose of this document ... 6
Sequence of Steps for Industries ... 6
Step 1: Meet PM CEMS Vendors ... 6
Step 2: PM CEMS Device Selection ... 7
Step 2.1: Select PM CEMS Technology ... 7
Step 2.2: Select PM CEMS Vendor ... 8
Step 3: Install CEMS ... 9
Step 4: Set-up Data Transfer System ... 9
Step 4.1: Hardware Set-up ... 10
Step 4.1.1: Set-up DAS (Data Acquisition System) ... 10
Step 4.1.2: Data logger ... 10
Step 4.2: Get user id & password from SPCB ... 10
Step 4.3: Registration of CEMS installed ... 10
Step 4.4: Software Set-up ... 11
Step 4.4.1: Installing 2 softwares (CEMS Software & ETS Bridge Software) ... 11
Step 4.4.2: Set Configuration of the CEMS software... 11
Step 5: Calibration of PM CEMS device and Performance Test ... 11
Step 5.1: Iso-kinetic sampling for Calibration of PM CEMS ... 11
Step 5.2: Post-Calibration Performance Test ... 12
Step 5.3: Calibration of Flow Meter ... 13
Step 6: Operations and Maintenance ... 13
Step 6.1: Regular Maintenance ... 13
Step 6.2: Monthly Zero Check ... 13
Step 6.3: Re-calibration ... 13
Step 6.4: CEMS Audit ... 14
Appendix A1.1 Physical Accuracy Requirement of CEMS Device ... 15
Appendix A2.1 User ID request form ... 16
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PILOT FOR EMISSIONS TRADING SCHEME IN INDIA
Emissions trading systems have been applied to a variety of pollutants around the world in order to guarantee environmental outcomes while minimizing compliance costs. The US EPA pioneered such trading under the Clean Air Act to limit a variety of common air pollutants. Following this example, environmental trading programs have proliferated in the European Union, Canada and, increasingly, developing Asia. In India, environmental markets are in their early stages, with small Renewable Energy Certificates and carbon offset markets in existence. Emissions trading, however, is yet to be used in environmental regulation.
In this context, the Ministry of Environment & Forests (MoEF), the Central Pollution Control Board (CPCB) and the State Pollution Control Boards (SPCBs) of the states of Gujarat, Maharashtra and Tamil Nadu have come together to design and pilot an emissions trading scheme for particulate matter air pollution from industrial point sources. Particulates are the most severe air pollution problem in India, with most major cities and many industrial areas out of compliance with the National Ambient Air Quality Standards (NAAQS) (CPCB, 2010; CPCB 2011). The model of industrial development in tightly-clustered industrial estates means that industrial combustion is a key source of particulate pollution in many areas.
ROLE OF CONTINUOUS E MISSIONS MONITORING SYSTEMS FOR MEASUREMENT
The pilot emissions trading scheme will rely on continuous emissions monitoring systems (CEMS) for measurement. The term CEMS refers to the instrumentation and software required to measure emissions from a stationary source on a practically continuous basis. Unlike for carbon dioxide or energy consumption, input-based methods of measurement are not reliable for particulates, since particulate emissions are a complex function of combustion conditions and abatement technology. Therefore, the role of CEMS is to measure the total load of particulate matter (PM) coming from each source. Total emissions can then be reconciled against permit holdings in the trading scheme.
The purpose of this document is to serve as a technical specification for accurate, reliable CEMS measurement of particulate matter. A document of this nature is imperative for supporting the pilot emissions trading program. The measurement and regulation of particulate matter is a concern worldwide, this specification is unique primarily because it is also designed to measure total load (equivalently average mass flow rate) over an extended period of time, as opposed to only mass concentration of particulates at any instant of time.
THE ROLE OF DIFFERENT PARTIES IN A MONIT ORING REGIME
The monitoring regime proposed is based upon CEMS but not limited to the instrumentation itself; rather, it encompasses a complete institutional and technical system for ensuring high-quality emissions data.
For successful implementation of the programme, most responsibilities have been entrusted to the pilot participating industries and SPCBs, with a view to guide the technical issues involved in this programme, including monitoring and reporting requirements outlined in this
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vendors to install, calibrate and help maintain a monitoring system suitable for its characteristics as an emissions source. The industry alone remains accountable for ensuring the performance of CEMS, documenting that performance through calibration, and sending quality data to the SPCBs concerned.
The SPCBs will oversee the monitoring regime, record and validate emissions data from CEMS and use that data to implement the pilot emissions trading scheme. The SPCBs may intervene in the monitoring of a particular industry as they see fit to keep data quality high. They may also coordinate the supporting roles of third parties such as accredited labs, CEMS vendors and CEMS working groups in each industrial cluster.
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Presentation and Review of Technology Options
Technology and vendor choice as per ETS guidelines set by CPCB and available with SPCBs
Port installation test
Spare parts and repairs
Monthly physical check of installation (testing, cleaning, alignment) Quarterly maintenance and servicing INDUSTRY VENDOR Technology choice Technology demonstration
Ensure technology compatibility with ETS requirements vis-à-vis
hardware and software requirements (system
integration test)
Final vendor and technology selection and procurement Installation of CEMS DAS setup Data transfer PM CEMS Registration PM CEMS Calibration Form filling Re-calibration CEMS Audit
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This guidance note describes a set of requirements for industries to streamline the selection, purchase, installation, and operation of CEMS devices. For the details, if required, industry should refer to “Specifications and Guidelines for Continuous Emissions Monitoring System (CEMS) for PM Measurement in Emissions Trading Scheme.” This full specification document is available with the SPCBs in case further clarification is needed.
SEQUENCE OF STEPS FOR INDUSTRIES
The objective of industries is to have a PM CEMS device installed on an appropriate stack, and send continuous PM mass flow data to the concerned Pollution Control Board (PCB) on a real-time basis, and according to the ETS program guidelines.
Following steps would be required to reach the objective:- 1. Meet PM CEMS Vendors
2. PM CEMS Device Selection 2.1. Select PM CEMS Technology
2.2. Select PM CEMS Vendor (including compatibility check as mentioned in section 4.4.1 below)
3. Install CEMS
4. Set-up Data Transfer System 4.1. Hardware Set-up
4.1.1. Set up DAS (Data Acquisition System) (PC with internet connection at the industry)
4.1.2. Lay cable from CEMS device to DAS 4.1.3. Data logger
4.2. Get user ID & password from SPCB 4.3. Registration of CEMS installed 4.4. Software Set-up
4.4.1. Installing 2 softwares (CEMS Software & ETS Bridge Software) 4.4.2. Set Configuration of the CEMS Software
5. Calibration of PM CEMS device and Performance Test 5.1. Iso-kinetic Sampling for Calibration of PM CEMS 5.2. Post-Calibration Performance Test
6. Operations and Maintenance 6.1. Regular Maintenance 6.2. Monthly zero check 6.3. Re-calibration 6.4. CEMS Audit
STEP 1: MEET PM CEMS VENDORS
Industry should meet PM CEMS vendors to understand and discuss the measurement technologies suitable for their stacks, PM CEMS models, costing, delivery terms and service terms.
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For ETS each industry will need to select the appropriate PM CEMS device, a process which consists of selection of both the appropriate technology and the vendor. Further detail on each of these steps follows.
STEP 2.1: SELECT PM CEMS TECHNOLOGY
PM CEMS should be able to measure and report PM emission mass flow (in kg/hour). This can be achieved by either of following configurations:
1) Installing PM CEMS which measures PM mass flow directly (e.g. DC Triboelectric). 2) Installing a PM CEMS concentration device and a flow meter device.
Configuration check / suitability check:
a) Suitability of a CEMS device depends on stack characteristics, process parameters, and air pollution control devices (APCDs) installed. The following selection matrix may be used for selecting the CEMS device:
Parameter DC Tribo Mass Flow Monitor AC Tribo Mass Concentration Monitor Electrodynamic Light Scatter Technology Opacity Monitor Wet Extractive Technology
Measured Value Direct in g/s, kg/hr mg/m3 mg/m3 mg/m3 mg/m3 mg/m3 Velocity Monitor Required X Duct < 1m Diameter X * Duct >1m to 4m Diameter * Duct > 4m Diameter X X X X * Electrostatic Precipitator X X X Stack Gas Temperature > 5000C *** *** *** Wet Scrubber or Water Droplet <700C X X X X X Large particles> 20um X X Dust> 100 mg/m3 **** X
Varying gas velocity ^ X **
* Although this technology will work on any duct diameter, the size of the sampling nozzle diameter in relation to the duct diameter means that the sample is very unlikely to be representative of the particle size distribution of the whole area. This technology is only used where others cannot be used, primarily wet stacks. ** This technology can cope only with with slowly varying velocities *** Tribo can be used for temperatures above 500 degC (Ceramic Body Tribos) **** Scatter light principle can measure readings up to 300 mg/m3
^ For applications with velocity variations around an average value a triboelectric probe calibrated to mass will be suitable for long run mass measurements. If a process change occurs resulting in permanent velocity changes a recalibration may be required to pass performance standards.
It is crucial to note that only the abovementioned technologies may be used for the ETS program, and no other technologies—such as the Broken Bag Detector—may be used as a substitute.
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Type
Impact Differential Pressure
(Pitot Tube) Thermal anemometer 1
Bi-directional ultrasonic
Infrared correlation Single point Multiport
Irregular Flow X 2 2 Max Flue Gas Temperature Upto 550 °C Upto 550 °C 200 – 300 o C (Model Specific) 450° C - 850 °C
(model specific) Upto 1000 o
C
Wet stack X X X
Low speed X (minimum 5 m/s) 1 m/s – 50m/s
High Speed Upto 40 m/s
(model specific) 1 m/s – 50m/s
Calibration Factory Factory Factory 3 Factory Factory
1 Pressure Transmitter (PT) and Temperature Transmitter (TT) are not installed with a Thermal Anemometer as it directly measures Mass Flow which is usually the required quantity. However, for the purpose of ETS in Type 2 CEMS configuration, Volumetric Flow is required and hence PT and TT are necessary to calculate density and convert mass flow calculated by the anemometer to volumetric flow.
2 Can be accounted for by using multiple probes/sensors
3 Calibration depends on physical properties (thermal conductivity, specific heat) of the gas whose flow is to be measured. Thus variation in properties of stack gas from factory calibrated values can result in inaccurate measurement.
STEP 2.2: SELECT PM CEMS VENDOR
Once the suitable PM CEMS technology and flow measurement device (if applicable) is identified, industries must select a vendor who can supply the device. After placement of a purchase order, it can take up to 1 month to procure the device. Industries are highly encouraged to engage in a specialized contract with the vendor stipulating the terms and responsibilities of each party.
Before selecting a vendor industry should keep following points into consideration (select a vendor fulfilling following requirement):-
1. Hardware
1.1. CEMS device should be tamper proof
1.2. PM CEMS device should measure and report the uncalibrated data to the DAS 1.3. PM CEMS devices and flow meter should be as per the Physical Accuracy
Requirement (See Appendix A1.1 Physical Accuracy Requirement of CEMS Device) 2. Software
2.1. Vendor should have ETS compatible software i.e it should be able to send the data in the prescribed format and should pass the System Integration Test for the CEMS Software. Details in Step 5.
3. System Integration
3.1. Vendor should install hardware and required software, integrate the whole system (Step 4), calibrate the device (Step 5) and make the real-time data transfer to the SPCB’s server possible.
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4. Performance of the CEMS
4.1. Calibrated data from CEMS must meet performance requirements in order to be deemed eligible for the ETS program. Vendor should take the responsibility that the device installed passes the Post-Calibration Performance Test. It is recommended that industries withhold payment to the vendor until the device passes this test. Details in Step 5.
5. Operations and Maintenance
5.1. Vendor should provide maintenance support (AMC) 5.2. Vendor should provide spare parts of the device
PM CEMS device and flow-meter should also have international certification (such as US EPA, MCERTS or TUV) covering basic operational characteristics.
STEP 3: INSTALL CEMS
Installation ports for PM CEMS and flow meter should be selected keeping following aspects into account:-
1. Laminar flow: Installation Point for the PM CEMS and flow meter should be such that flow is laminar at that point. As a general rule, the port hole should be at least five stack diameters downstream and two diameters upstream from any flow disturbance such as a bend, expansion, or contraction in the stack. For details refer to Appendix A3.1 CEMS Installation Guidelines of Specifications and Guidelines for Continuous Emissions Monitoring System (CEMS) for PM Measurement in Emissions Trading Scheme.
2. Accessibility for Maintenance: Device should be installed such that it’s accessible for regular maintenance.
Industry should provide the ports (flanges if requested) on the stack as requested by the CEMS vendor for installation.
Additional installation guidelines such as selecting the measurement plane and mounting location are provided in the Specifications and Guidelines for Continuous Emissions Monitoring System (CEMS) for PM Measurement in Emissions Trading Scheme.
STEP 4: SET-UP DATA TRANSFER SYS TEM
Setting-up the data transfer system involves following 4 activities:-
Step 4.1: Hardware Set-up
Step 4.2: Getting user id and password from SPCB
Step 4.3: Registration of CEMS installed
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Hardware set-up consists of following 2 requirements:-
Step 4.1.1: Set-up DAS
Step 4.1.2: Install data logger
STEP 4.1.1: SET-UP DAS (DATA ACQUISITION SYSTEM)
The hardware for a DAS must also be set up to allow for data transfer from CEMS to the SPCB on a continuous basis. It should have:-
Set up a dedicated PC on site1. This PC is referred to as the Data Acquisition System (DAS) and will consist of CEMS software for data acquisition from the device, and an “ETS bridge software” for sending the data in the prescribed format to the SPCB (see section 4).
Fast and reliable internet connection (dedicated broadband internet connection, min 256Kbps). This would facilitate the real-time data transfer.
STEP 4.1.2: DATA LOGGER
Industry should ensure that the vendor installs data loggers to provide a temporary backup in case of computer failure. Data logger should be able to store the data at least for a month.
STEP 4.2: GET USER ID & PASSWORD FROM SPCB
A web-based application will be made available to industries for viewing the CEMS data and conducting certain administrative procedures. After entering into the system, an industry can: In order to enter the web-based system, the industry is required to have a User ID and password. To obtain this, the industry has to submit a “User ID Request Form” (See Appendix A2.1 User ID Request Form) to the designated officer at the SPCB (a signed form must be submitted manually, not electronically).
After receiving the physical form, the designated SPCB officer will email a user ID and password to the industry’s key contact person, after which the industry can begin accessing the web-based application.
STEP 4.3: REGISTRATION OF CEMS INSTALLED
Using the user ID and password, industry can log in and do the registration of the CEMS installed. Following registration, industries are required to submit an installation and functional checklist to the SPCB through the web-based application. The checklists are designed to ensure CEMS was installed properly and according to a standard procedure and is functioning at an optimal level. This activity should be done in close coordination with the vendors as vendors would be filling in the installation checklist and functional checklist.
1The Data Transmission System for Online Real-time Continuous Monitoring System shall ensure that the data
being transmitted are non-editable & non-modifiable and that the system should be tamper-proof and that the system shall be certified by the supplier for the same.
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Software Set-up has following 2 activities:-
Step 4.4.1: Installing 2 software’s (CEMS Software and ETS Bridge Software)
Step 4.4.2: Setting configuration of the CEMS Software
STEP 4.4.1: INSTALLING 2 SOFTWARES (CEMS SOFTWARE & ETS BRIDGE SOFTWARE)
The software requirements for industry are two-fold: 1. CEMS software
2. ETS bridge software
Additionally, a web-based application will be made available for industries to view emissions data and administration related activities (already discussed in Step 4.3).
CEMS Software: The CEMS software is designed by the vendor (or a third-party) to accept and convert CEMS data into a standard format as per the ETS. It is installed on the DAS (industry PC) and outputs important emissions parameters required for operating the ETS program.
As discussed in “Step 2.2: Select PM CEMS Vendor”, industry should make sure that the vendor has ETS Compatible CEMS software and has passed the System Integration Test for the CEMS Software.
ETS Bridge Software: The ETS bridge software is designed by the ETS team and is available for free download. The CEMS software outputs data in a standard format, and the ETS bridge software reads this data and sends it to the SPCB server on a continuous basis.
STEP 4.4.2: SET CONFIGURATION OF THE CEMS SOFTWARE
Using the Step 4.4, each industry stack will get a unique configuration ID. Vendor should set that configuration in the CEMS Software and initiate the data transfer activity from CEMS device to the SPCB server.
STEP 5: CALIBRATION OF PM CEMS DEVICE AND
PERFORMANCE TEST
STEP 5.1: ISO-KINETIC SAMPLING FOR CALIBRATION OF PM CEMS
Although the industry will not calibrate the PM CEMS device, it is important that they oversee the calibration process and ensure it is in accordance with the protocol stipulated in the ETS program guidelines. Calibration of the PM CEMS device is done using iso-kinetic sampling for PM emission measurement as the Standard Reference Method.
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Select a lab to carry out iso-kinetic sampling for calibration of CEMS. Only the following labs are authorized to conduct PM sampling
o NABL certified labs o MoEF accredited EIA lab o Labs approved by SPCB
PM samples taken for calibration should be done in accordance with any one of the approved iso-kinetic sampling methods: CPCB method 1, EPA method 5, EPA method 17.
The number of PM samples required will depend on whether a given industry has the ability to vary emission levels through means such as variation of load, feed rate, turning off ESP cells, or other methods.
At a minimum, for industries where a wide range of load variation is not possible, ensure that at least 4 non-zero PM samples are taken for calibration. These samples should be taken in the following manner, to ensure an accurate calibration range:
o 2 points at zero load
o 4 points at 75%-100% load
If further variation is possible, it is recommended to take 2 points at no load along with 7 valid parallel iso kinetic samples with variation in emission levels achieved by the means described above.
For a given PM sample to be considered valid for calibration there are two primary criteria that should be met. Industry has responsibility for submitting the results of the iso-kinetic sampling to the SPCB and should request additional samples to be taken by the environmental laboratory if either condition is not met:
o During iso-kinetic sampling, data availability from the CEMS device during the time frame parallel to the time frame over which the sample was taken should be more than 95%
o Iso-kineticity of the sampling should be in the range of 0.9-1.1
Once the required number of valid samples have been taken, using the web-based application, industry should submit the results of the iso-kinetic sampling to the SPCB server and the server will do the Post-Calibration Performance Test.
STEP 5.2: POST-CALIBRATION PERFORMANCE TEST
On installation of the CEMS device and the lab conducts iso-kinetic sampling, the CEMS must pass Post-Calibration Performance Test in order to be deemed eligible for ETS.
If an industry passes a Post-Calibration Performance Test, instrument is deemed eligible for ETS and ready for operation. Otherwise, CEMS vendor should be contacted and industry needs to do the iso-kinetic sampling again or replace device.
As discussed in “Step 2.2: Select PM CEMS Vendors”, industry should make sure that vendor should take the responsibility that the device installed passes the Post-Calibration Performance Test and payment should be made once a device passed this test.
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If the industry has selected a technology configuration that also requires installation of a flow meter, industry should also ensure that the flow meter is factory calibrated. However, after flow meter installation, industry can cross-check the reading against the standard reference method of flow measurement (manual method). Measurement of flow during the calibration process of the PM CEMS can also be used to cross-check the flow meter calibration.
STEP 6: OPERATIONS AND MAI NTENANCE
STEP 6.1: REGULAR MAINTENANCE
Industry should do the regular preventive maintenance of the device. Industry should take the maintenance manuals of the device from vendor and perform the maintenance accordingly. Industry may opt for an Annual Maintenance Contract for correct operation of the device.
STEP 6.2: MONTHLY ZERO CHECK
Zero check of the device should be done and adjusted at least once a month. This frequency can change depending on the device and vendor.
STEP 6.3: RE-CALIBRATION
There are certain situations where a re-calibration of CEMS is required, necessitating iso-kinetic sampling again (elaborated in the table below). Industries are responsible for overseeing any CEMS re-calibrations and ensuring it is carried out according to the protocol described below.
Industry should recalibrate the PM CEMS device every 6 months. The frequency of calibration of PM CEMS device is subject to change based on the on-field performance of the device.
Recalibration of CEMS is of two types: A and B. In a Type A recalibration event, PM samples during initial CEMS calibration can be considered for re-calibration and calculation of the calibration factor. In a Type B recalibration event, previous PM samples will not be considered. All PM iso-kinetic samples must be new.
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Situation Type of
Re-Calibration
Remarks
Recalibration after every 6 months Type B Industry should do the re-calibration of the PM CEMS device every 6 months.
Calibrate and perform
Post-Calibration Performance Test with the new iso-kinetic samples. PM CEMS operating out of range. This
is defined as either:
• 10% or more of the CEMS output (45 minute average) in a week are outside the Valid Calibration Range for five weeks or more
• 40% or more of the CEMS output (45 minute average) in a week are outside the Valid Calibration Range for one week or more.
Type A Industry should take at least 2 more iso-kinetic samples above the valid calibration range.
PM CEMS device (hardware) changed but the same model and same
manufacturer
Type B Calibrate and perform
Post-Calibration Performance Test with the new iso-kinetic samples. Change in fuel or process Type B Same as above
Major changes in the APCD which might change the profile of the PM emissions or flow.
Type B Same as above
Failure of a CEMS audit Type B Same as above. However, samples taken for the CEMS Audit
Performance Test can be used for recalibration
STEP 6.4: CEMS AUDIT
To protect the integrity of emissions data underpinning the pilot ETS, the PM CEMS requires ongoing maintenance and quality control. A CEMS Audit must be performed at least once in a year. The industry is responsible for overseeing the CEMS audit.
During the CEMS audit, labs are required take 4-6 iso-kinetic samples according to the standard methods. Then, using the same calibration equation derived for the initial calibration, the CEMS Audit Performance Test is performed using the iso-kinetic sampling data for at least 4 samples. In case an instrument fails the test, the industry will recalibrate the device with sample points at different load conditions. Four points used for doing the CEMS Audit Performance Test can be used for the calibration purpose.
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CEMS DEVICE
Industries must also ensure the device contains specifications of key operating parameters such as: physical accuracy, response time, minimum detection limit (for flow meters). The following table provides guidance on the key operating parameters to confirm for PM CEMS and flow meters:
Name of Parameter Specifications
PM CEMS Flow Meter
Measurement range User defined User Defined Instrumental detectable
concentration
10 mg/Nm3 or less 1 m/s (minimum detectable limit)
Data acquisition 1 minute 1 minute Data transmission 1 minute 1 minute
Accuracy* < 5% <2% of measuring range Drift < 1% per month Overall zero & span drift
should be < 1% per month Flue gas User specific Minimum 1 dew point; User
Specific Power supply 220 +/- 10 V at 50 Hz
*Accuracy: It is the accuracy in measurement of the raw value of what flow meter measures. For Differential Pressure based flow meter, it is the Pressure, So accuracy here represents the accuracy in the measurement of pressure difference.
Apart from above said requirements of the CEMS hardware, the PM CEMS device and flow-meter should also have international certification (such as US EPA, MCERTS or TUV) covering basic operational characteristics.
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To be submitted to designated SPCB officer
Industry name: ………..
Industry Address: ……….. ………
……… ………
Key contact person from the industry Name: ……… Designation: ……… Contact number: ……… Email address: ……… Fax: ……… Date: ……… Signature: ……… Industry’s stamp:
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APPENDIX A3.1: SAMPLE CONTRACT BETWEEN INDUSTRY
AND VENDOR
***DISCLAIMER: The following vendor contract is in initial draft form and is subject to change
upon further discussion with CEMS vendors.
__________________________________________________________________________________
SAMPLE PM CEMS ANALYSER CONTRACT
[Insert name of Industry] And
[Insert PM CEMS Analyser Vendor’s full legal name] AGREEMENT
Relating to the Supply of [Inset PM CEMS Analyser Name]
THIS AGREEMENT is made on the [Enter number for day; e.g. 1st, 2nd etc.] day of [Select Month], [Select Year]
BETWEEN:
[Insert name of Industry], of [Address] (“the Customer”); And
[Insert PM CEMS Analyser Vendor’s full legal name], of [Vendor’s Address] (“the Supplier”) (“the Parties”).
A.A
1. The Supplier shall sell and the Customer shall purchase in accordance with this Agreement
2. The price of the Analysers shall be the price stipulated in the contract after agreement between the parties. For the
purposes of this Agreement, the Customer’s Contact is [insert contact name] of [insert contact address]; the Supplier’s Contact is [Supplier contact name] of [Supplier contact address].
3. This Agreement is governed by the terms and conditions as set out in this agreement and schedule A
4. This Agreement shall take effect on the date of this Agreement (“the Effective Date”) and shall expire on [insert date], unless it is otherwise terminated in accordance with the provisions of this Agreement or otherwise lawfully terminated or otherwise lawfully extended as agreed between the Parties. (“the Term”).
The Customer reserves the right to extend the Term for a period or periods of up to [INSERT NUMBER] months with a maximum of [NUMBER] such extensions permitted subject to its obligation at law.
SIGNED for and on behalf of the Customer SIGNED for and on behalf of the Supplier ________________________________ _________________________________ (being a duly authorised officer)
Witness Witness
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Schedule A: Terms and Conditions
i. The Supplier shall be responsible for correctly examining conditions at the industry site and supplying appropriate Analyser. In the case that Analyser is found to be inappropriate for the industry site, Supplier shall reimburse the Customer in full.
ii. The Supplier shall only supply the CEMS technologies stipulated in the ETS CEMS guidelines.
iii. The Supplier shall be responsible for ensuring that the Analyser is properly installed and calibrated at the industry site. The Supplier shall be responsible for identifying measurement plane and mounting locations as per ETS CEMS guidelines
iv. The Supplier shall be responsible for making sure the Analyser clears the Post-Calibration Performance Test as set by the regulator specified in the ETS CEMS guidelines at the time of installation and calibration.
v. Customer must fill the installation checklist available on the ETS Bridge attesting to the completion of all installation related activities. A functional test (as per ETS CEMS guidelines) shall be carried out upon installation of CEMS by the Supplier. Supplier is required to understand the necessary procedures and describe to industry where needed in filling out the appropriate installation and functional checklist form.
vi. Both the Supplier and Customer shall be responsible for ensuring that the Analyser clears CEMS Audit Performance Test at a later date.
vii. The supplier shall ensure the device warranty and industry shall ensure maintenance of optimum operating conditions according to the CEMS device.
viii. Supplier shall be responsible for providing accompanying CEMS software which meets the requirements of the ETS guidelines, and this is to be installed on the industry PC and tested for [NUMBER] days. The CEMS Software should pass the System Integration Test.
I. The warrantee period shall be calculated from the date of delivery to the date [number] months thereafter.
II. The Supplier is required to carry out all jobs mentioned in subsection “3 – maintenance (II)” free of cost during the
warrantee period (or an extended warrantee period if selected by the customer).
III. In cases of faulty design or installation, the Supplier shall replace the system free of cost within [number] months
after the need for replacement has been established.
IV. Upon expiration of the warrantee period, the Customer shall have the option of extending the warrantee by a maximum of [number] months contingent on paying [Number] Rupees per month (inclusive of all taxes).
I. Upon expiration of the warrantee period, the Customer shall have the option of entering into a maintenance contract contingent on paying [Number] Rupees per year (inclusive of all taxes).
II. The Supplier shall carry out all jobs mentioned below during the maintenance period:
a. Complete testing, cleaning, and alignments of Analyser monthly to ensure correct physical installation and re-calibration of Analyser once every six months after analyser is installed at site.
b. Preventive maintenance, servicing, and corrective maintenance of Analysers once every three months after analyser is installed at site.
c. In case of breakdowns/major faults in Analyser – precisely identify the cause of breakdown/faults and precisely identify faulty hardware or software (as the case maybe) that need to be repaired or replaced to make the system operational again.
d. Submit testing and calibration report for every visit.
2 – Warrantee Period
3 – Maintenance
1 – Procurement
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e. Visit the site at the earliest – within 24 hours of any complaint lodged by the Customer.
f. Provide troubleshooting and calibration related training to Customer’s technical staff and Engineers.
III. Payment during the maintenance will be made as per actual work done only.
IV. Customer shall pay for all the spare parts that require replacement after the warrantee period has expired. If the Customer has a maintenance contract with the Supplier, the latter will offer price list for the recommended spares.
Specifications and Guidelines for
Continuous Emissions Monitoring
System (CEMS) for PM Measurement
in Emissions Trading Scheme
Project: Continuous Emission Monitoring and Pilot Emission
Trading Scheme (ETS) for Particulate Matter from
Stationary Sources (Stack) in India
July 29
th,2013
Maharashtra Pollution Control Board
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Foreword
Continuous Emissions Monitoring Systems (CEMS) for particulate matter have the potential to improve environmental regulation in India by providing better information on the pollution load emitted from stationary sources to Pollution Control Boards, industry and the public. In addition, CEMS can enable the use of innovative regulatory tools including market based regulatory instruments to control air pollution. Market-based regulatory instruments have great potential to help India bridge the challenge of achieving both environmental objectives and robust economic growth in a harmonious manner.
The Ministry of Environment and Forests and the Central Pollution Control Board have initiated an important project to design and evaluate a pilot emissions trading scheme (ETS) for particulate matter from stationary sources, in collaboration with three states – Gujarat, Maharashtra and Tamil Nadu. This report presents specifications and guidelines for the use of Continuous Emissions Monitoring Systems, including mechanisms to calibrate CEMS, maintain quality and a guide to technology selection. These guidelines have been carefully drafted after extensive consultations, workshops and a peer review process and have been designed to support regulatory applications such as ETS that require the calculation of particulate load emitted over a period of time by stationary sources.
I would like to especially thank Mr. J.S. Kamyotra, under whose guidance the development of these specifications was possible. I would also like to thank the Technical Committee, chaired by Dr. D. Saha, and all of the state Member Secretaries: Mr. Hardik Shah, Mr. Rajeev Mital, and Dr. S. Balaji, for their support of this endeavour. I also acknowledge financial support from the Ministry of Environment and Forests. It is my hope that these guidelines will assist State Pollution Control Boards, Industries and CEMS manufacturers in ensuring high quality information from PM CEMS installations and enable the country as a whole to move to a cleaner environment and better air quality.
Ajay Tyagi Chairman, CPCB
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Acknowledgments
We would like to acknowledge the contributions of all members of the Technical Committee in developing these guidelines. We also acknowledge the contributions and peer review provided by Mr. Alan Leonard of Ricardo-AEA. Additional peer review comments were provided by Dr. Laura Diaz Anadon (Harvard University) and Dr. Richard Schmalensee (Massachusetts Institute of Technology). This report was prepared with financial support from the Ministry of Environment and Forests, GoI.
Technical Committee Member Organization Dr. D. Saha – Chair Central Pollution Control Board Sh. S.K. Sharma Central Pollution Control Board Sh. A. Pathak Central Pollution Control Board Sh. N.M Tabhani Gujarat Pollution Control Board Sh. Chirag Bhimani Gujarat Pollution Control Board Sh. V.M. Motghare Maharashtra Pollution Control Board Sh. S.C. Kollur Maharashtra Pollution Control Board Sh. R. Dhanasekaran Tamil Nadu Pollution Control Board Dr. Anant Sudarshan J-PAL South Asia
Sh. Harsh Singh J-PAL South Asia Ms. Amber Luong J-PAL South Asia Sh. Jasdeep Mandia J-PAL South Asia
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Table of Contents
1. EXECUTIVE SUMMARY ... 5 1.1 PILOT FOR EMISSIONS TRADING SCHEME IN INDIA ... 5 1.2 ROLE OF CONTINUOUS EMISSIONS MONITORING SYSTEMS FOR MEASUREMENT ... 5 1.3 THE ROLE OF DIFFERENT PARTIES IN A MONITORING REGIME ... 5 1.4 PERFORMANCE REQUIREMENTS OF THE CONTINUOUS EMISSIONS MONITORING SYSTEM ... 6 1.5 GUIDANCE ON INSTALLATION AND CALIBRATION OF CEMS ... 7 1.6 HANDLING OF THE DATA FROM CEMS ... 7 2. GLOSSARY OF TERMS ... 8 3.INTRODUCTION: PILOT EMISSIONS TRADING SCHEME FOR PARTICULATE MATTER 12 4. CONTINUOUS EMISSIONS MONITORING SYSTEMS ... 13 4.1 BENEFITS OF CONTINUOUS RECORDING OF PARTICULATE EMISSIONS ... 13 4.2 ACCEPTABLE TYPES OF TECHNOLOGY CONFIGURATION ... 14 4.3 CALCULATING TOTAL PM LOAD ... 15 4.4 CEMS REQUIREMENTS ... 15 4.4.1 Hardware Requirements ... 16 4.4.2 Software Requirements ... 17 4.4.3 Performance Requirements... 17 4.4.4 Required Variation in PM Emissions level during Calibration ... 18 5.0 CEMS OPERATIONS... 18 5.1 ROLE OF DIFFERENT PARTIES IN MONITORING REGIME ... 18 5.2 CEMS OPERATIONS OVERALL FLOWCHART ... 20 5.3 ACTIVITIES IN CEMS OPERATIONS ... 22 5.3.1 Activity: PM CEMS Installation, Registration and Configuration ... 23 5.3.2 Activity: Standard Reference Method for Parallel Measurement ... 25 5.3.3 Activity: Calibration and ‘Post-Calibration Performance Test’ ... 25 5.3.4 Activity: Re-calibration of CEMS ... 28 Type A Re-calibration ... 28 Type B Re-calibration ... 28 5.3.5 Activity: CEMS Audit and ‘CEMS Audit Performance Test’ ... 29 5.3.6 Activity: Commenting on CEMS Data ... 29 6.0 DATA ACQUISITION AND HANDLING SYSTEM (DAHS) ... 29 6.1 DAHS ARCHITECTURE ... 30 6.2 DAHS SCHEMATIC ... 31 6.3 PARAMETERS SPECIFICATION ... 34 6.3.1. Parameters Details ... 34 6.3.2 Parameters transferred to ETS Bridge Software ... 40 6.4 ETS BRIDGE INTERFACE ... 41 6.4.1 Interface Overview ... 41
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6.4.2 Interface Details ... 41 6.4.3 Data Exchange Process ... 44 6.6 SYSTEM INTEGRATION TEST FOR CEMS SOFTWARE ... 44 6.6.1 Why System Integration Test? ... 44 6.6.2 Procedure for System Integration Test ... 45 7. REFERENCES ... 49 APPENDIX A1: FORMATS FOR ALL THE FORMS ... 51 A1.1 CEMS REGISTRATION FORM ... 51 A1.2 INSTALLATION CHECKLIST ... 53 A1.3 FUNCTIONAL TEST CHECKLIST ... 55 A1.4 SAMPLE REPORTING FORM ... 57 APPENDIX A2. BACKGROUND CALCULATIONS ... 58 A2.1 CALCULATION OF THE CALIBRATION FACTORS ... 58 A2.2 CALCULATION OF THE POST-CALIBRATION PERFORMANCE TEST ... 60 A2.3 CALCULATION OF THE CEMS AUDIT PERFORMANCE TEST ... 64 APPENDIX A3. GUIDELINES ... 68 A3.1 CEMS INSTALLATION GUIDELINES ... 68 A3.2 STACK CHARACTERISTICS MATRIX : PM CEMS TECHNOLOGY ... 73 A3.3 STACK CHARACTERISTICS MATRIX : FLOW MEASUREMENT TECHNOLOGY ... 74 APPENDIX A4.1 FEEDBACK FORM... 75
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1. Executive Summary
1.1 Pilot for Emissions Trading Scheme in India
Emissions trading systems have been applied to a variety of pollutants around the world in order to guarantee environmental outcomes while minimizing compliance costs. The US EPA pioneered such trading under the Clean Air Act to limit a variety of common air pollutants. Following this example, environmental trading programs have proliferated in the European Union, Canada and, increasingly, developing Asia. In India, environmental markets are in the early stages, with small Renewable Energy Certificates and carbon offset markets in existence. Emissions trading, however, is yet to be used in environmental regulation. In this context, the Ministry of Environment & Forests (MoEF), the Central Pollution Control Board (CPCB) and the State Pollution Control Boards (SPCBs) of the states of Gujarat, Maharashtra and Tamil Nadu have come together to design and pilot an emissions trading scheme for particulate matter air pollution from industrial point sources. Particulates are the most severe air pollution problem in India, with most major cities and many industrial areas out of compliance with the National Ambient Air Quality Standards (NAAQS) (CPCB, 2010; CPCB 2011). The model of industrial development in tightly-clustered industrial estates means that industrial combustion is a key source of particulate pollution in many areas.
1.2 Role of Continuous Emissions Monitoring Systems for Measurement
The pilot emissions trading scheme will rely on continuous emissions monitoring systems (CEMS) for measurement. The term CEMS refers to the instrumentation and software required to measure pollution emissions from a stationary source on a practically continuous basis. Unlike for carbon dioxide or energy consumption, input-based methods of measurement are not reliable for particulates, since particulate emissions are a complex function of combustion conditions and abatement technology. The role of CEMS is therefore to measure the total load of particulate matter (SPM) coming from each source. Total emissions can then be reconciled against permit holdings in the trading scheme.
The purpose of this document is to serve as a technical specification for accurate, reliable CEMS measurement of particulate matter, including for the purposes of this pilot trading scheme. While measurement and regulation of particulate matter is a concern worldwide, this specification is unique primarily because it is also designed to measure total load (equivalently average mass flow rate) over an extended period of time, as opposed to only mass concentration of particulates at any instant of time.
1.3 The Role of Different Parties in a Monitoring Regime
The monitoring regime proposed is based upon CEMS but not limited to the instrumentation itself; rather, it encompasses a complete institutional and technical ecosystem for ensuring high-quality emissions data. The most important roles are those of regulated industry and the State Pollution Control Boards (SPCBs). It is the responsibility of each regulated industry to comply with the monitoring and reporting requirements outlined in this document and related specification documents. The industry may employ CEMS vendors to install, calibrate and help maintain a monitoring system suitable for its characteristics as an emissions source. The industry alone remains accountable for ensuring the performance of CEMS, documenting that performance through calibration, and sending high quality and reliable data to the SPCB concerned.
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The SPCBs will oversee the monitoring regime, record and validate emissions data from CEMS and use that data to implement the pilot emissions trading scheme. The SPCBs may intervene in the monitoring of a particular industry as they see fit to keep data quality high. They may also coordinate the supporting roles of third parties such as accredited labs, CEMS vendors and CEMS working groups in each industrial cluster.
1.4 Performance Requirements of the Continuous Emissions Monitoring System
This section outlines the performance requirements of CEMS for particulate matter, with reference to several technical appendices which elaborate on specific calculations or procedures.
Industries regulated under the under ETS must install a PM CEMS device and ensure its accuracy is in accordance with the stipulated performance standard. The performance standard first involves passing a rigorous Performance Test after the device is calibrated (called the Post-Calibration Performance Test). This test only acknowledges that initial calibration is sufficiently well done and does not exempt the industry from the requirement to carry out periodic quality control tests. For this reason, another performance test must be carried out during periodic CEMS audits. Details of both the performance tests can be found in Section 5.3.3 Activity: Calibration and ‘Post-Calibration Performance Test’ and Section 5.3.5 Activity: CEMS Audit and ‘CEMS Audit Performance Test’ respectively. The procedure for calculating measurement accuracy for both performance tests are in Appendix A2.2 Calculation of the Post-Calibration Performance Test, Valid Calibration Range & Maximum Volumetric Flow and Appendix A2.3 Calculation of the CEMS Audit Performance Test respectively. Only if the device passes the performance test(s) can it be deemed eligible for inclusion in ETS. If the device accuracy is not in line with the performance standard, it must be re-calibrated and then tested again.
The calibration procedure involves plotting CEMS readings against manual sample measurements and estimating a linear equation of a line through the points. The line would take the form of + ê where the Standard Reference Method (SRM) and CEMS readings are on the x and y axes respectively. ê.is a measure of how far each point is from the line and is randomly distributed.
The performance standard and calibration protocol is intended to assure that CEMS estimates for total emissions load over a compliance period (typically 12 months) in the pilot ETS will be extremely reliable. This follows because for a well-calibrated CEMS (where the relationship between CEMS readings and true emissions is linear within the calibration range), the difference between each point and the estimated line will be independent and have a mean of zero by construction. Therefore, the sum of these differences (reflecting 30-minute sampling times) will quickly average out to zero, over a 3-month to 12-month compliance period, allowing precise estimates of total emissions load for trading.
More precisely, the post calibration relationship between PM CEMS calibrated readings can be described by the equation ŷ = mx + c + e, where x is the un-calibrated CEMS reading and ŷ is the estimated post-calibration CEMS reading. Here, m and c are estimated post-calibration parameters whose values are equal to the slope and intercept of the estimated line relating CEMS readings to gravimetric sampling values. e represents residual instantaneous noise after applying the calibration equation. For an emissions trading scheme the relevant requirement involves using the PM CEMS device to measure total mass load emitted over an extended period of time, not the point concentration at any instant of time. In order to estimate total load over a period of time T it is therefore necessary to use estimates of either average concentration over
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the period T (which would need to be multiplied by average flow) or average mass flow rate (multiplied by the length of time T).
̅ ̅ (∑ ∑ ) ∑ ̅ ̅
Long term average of the estimated y = long term average of the y
As is evident, the long term average of the difference between calibrated CEMS readings and the true value will converge to its mean, namely 0, when the calibration is carried out using the prescribed method of a linear fit between SRM and CEMS readings. It is this long term average that is of interest when determining accuracy of the PM CEMS device as a monitoring technology to underpin the pilot emissions trading scheme in particulate matter. For more on statistical inference in environmental monitoring see Watson and Downing (1976), Bertheoux and Brown (2002), Gilbert (1987), Guttorp (2006), Barnett and O’Hagan (1997) and Kinney and Thurston (1993).
This can be verified (including as part of tests carried out for this pilot) by analyzing data from two different CEMS devices calibrated on the same stack. The long term averages (or total load over a period of time) computed from both sources will converge, where the sum of the differences goes to zero as explained above.
1.5 Guidance on Installation and Calibration of CEMS
To provide guidance on meeting and maintaining this performance standard, this document describes the procedures for initial selection, performance, and further ongoing maintenance and quality control of CEMS. The appendix also describes the procedure for calibration of the PM CEMS instrument and its performance tests required for operations. A CEMS instrument must also be recalibrated if: (i) it is significantly modified, (ii) if it operates for extended periods outside of the range of emissions values for which it was calibrated, (iii) if the industry changes fuels or processes, or (iv) if the PM CEMS instrument fails an audit or SPCB inspection.
The appendices also provide examples from the testing of particulate CEMS for both the initial calibration of CEMS technology to total PM mass and for the convergence of different technologies to the same estimates of total emissions mass over time.
1.6 Handling of the Data from CEMS
CEMS readings from each regulated industry will be transferred and submitted to the SPCBs and the CPCB electronically in a common format. The details of data handling are described in a companion document but this document covers the basics along with missing data procedures relevant to the CEMS monitoring regime as a whole. The missing data protocol fills in missing emissions data with increasingly punitive assumptions as the interval of the missing data grows longer. Thus industries will have an incentive to keep missing data to a minimum in order to avoid increasing their permit holding requirements.
Emissions readings and associated parameters, such as flow, operational flags, time and date, industry ID, etc. will be sent from each regulated industry to the SPCB at 1-minute intervals. The US EPA flagship air
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pollution trading programs have been based around quarterly emissions reporting, not real-time data. However, given the novelty of CEMS monitoring in India and for particulate mass load, it is advisable to receive data more frequently in order to verify reporting and reduce calibration and missing data problems. The cost of data handling and transmission is small compared to the cost of CEMS.
2. Glossary of Terms
Acid Rain: Air pollution produced when acid chemicals are incorporated into rain, snow, fog or mist. The "acid" in acid rain comes from sulphur oxides and nitrogen oxides, products of burning coal and other fuels and from certain industrial processes.
APCD: Air Pollution Control Device
Calibrate: To check, adjust, or determine by comparison with a standard (the graduations of a quantitative measuring instrument). Also it is the activity
of calibrating the PM CEMS device. See Section 5.3.3 for details. .. Calibration Drift: The difference between the instrument response and a reference value after
a period of operation without recalibration. CEMS: Continuous emission monitoring system.
CEMS Audit: Audit performed atleast once an year to make sure CEMS device are performing as per the standard. CEMS-Audit Performance Test is performed. See Section 5.3.5 for details.
CEMS Requirements: Set of Hardware, Software and Performance required for the CEMS installed by the participating industry. See Section 4.4 for details.
CEMS Software: CEMS software by the vendor installed at the DAS that takes the data form the CEMS device and saves in a prescribed format so that ETS Bridge Software can read it. This software needs to pass the System Integration Test to test its compatibility with the ETS Bridge Software. See Section 6.6 for details.
CEPI: The Comprehensive Environmental Pollution Index (CEPI) is a pollution index created and maintained by the Central Pollution Control Board. It is calculated taking into consideration the pollutants, pathway of impact on people and ecology, the level of exposure, affected population, etc.
Cluster: A cluster is a collection of industries in the same geographic region designated by the State Pollution Control Board to participate in the pilot Emission Trading Scheme.
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Combustion: Burning. Many important pollutants, such as sulphur dioxide, nitrogen oxides, and particulates are combustion products, often products of the burning of fuels such as coal, oil, gas, and wood.
Compliance: A unit that has abided by all the regulations of the Emissions Trading Scheme is said to be in compliance.
Compliance Period: The compliance period refers to the time period over which one emission permit is valid. The unit must have enough permits to cover all emissions during each compliance period.
Concentration: Concentration standards set acceptable pollution levels by measuring pollutants base on mass per volume.
CPCB: Central Pollution Control Board. The Central Pollution Control Board, a branch of the Ministry of Environment and Forests, is primarily a standards-setting and technical body. It sets environmental and technical standards as well as running national monitoring and enforcement programmes.
DAHS: Data Acquisition and Handling System
DAHS Server: Data Acquisition and Handling System Server is the server installed at the regulator office
DAHS Software: Data Acquisition and Handling System Server Software is the installed software at the DAHS Server for data collection, administration, data storage, data viewing and other features
DAS: Data Acquisition System is a PC at the participating industry which send the data to the DAHS Server
EPA: The United States Environment Protection Agency
ETS: An emissions trading scheme (ETS) is a regulatory tool used to reduce pollution emissions at a low overall cost. In such a scheme, the regulator sets the overall amount of emissions but does not decide what any particular source will emit. Industrial plants and other polluters, rather than being told a fixed emissions limit or concentration standard, face a price for their emissions and choose how much to emit, within reasonable limits, taking this price into account. The price of emissions makes pollution costly and gives polluters an incentive to cut back.
ETS Bridge: Software provided by CPCB installed at the DAS (industry site) which acts as a bridge and transfers the data form CEMS Software to the DAHS Server. See Section 6.0 for details.
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Functional Test: Tests used to assure that CEMs have been installed and are operating correctly.
Flue Gas: The gas exiting to the atmosphere via a flue, which is a pipe or channel for conveying exhaust gases from a fireplace, oven, furnace, boiler or steam generator. Quite often, the flue gas refers to the combustion exhaust gas produced at power plants.
Mass flow standard: A particulate emission standard expressed in terms of total mass emitted in a specified period of time. Concentration standards can be translated to a mass flow standard using a flow rate value. For example the product of the current concentration standard (150 mg/Nm3) and the maximum volumetric flow rate (vol_flowmax) of a given stack.
Parameter Specification: List of parameters measured and calculated by the CEMS and DAS. See Section 6.3 for details.
Performance Requirements: Once CEMS is installed and calibrated, set of requirements (must) to be fulfilled by the participating industry wrt to performance of the CEMS device. It consists of Post-Calibration Performance Test and CEMS Audit Performance Test. See Section 4.4.3 for details.
Permits: Each emission permit operates as a license to emit one kg of particulate matter during the compliance period for which the permit is valid. For instance, an industry holding 500 SPM permits is allowed to emit a total of 500 units of SPM within the time frame for which the permit is valid. Point Sources: Specific points of origin where pollutants are emitted into the atmosphere
such as factory smokestacks.
QA/QC: Quality Assurance/ Quality Control. Protocols to ensure quality data on an ongoing basis.
Random Error: The non-systematic deviation experienced in any step of an analytical procedure that can be estimated by standard statistical techniques.
Re-calibration: Calibrating the PM CEMS device again to override the previous calibration equation. This can be triggered because of various conditions. See Section 5.3.4 for details.
Standard Reference Method: A sampling and/or measurement method that has been officially specified by an organization as meeting its data quality requirements.
Sector: Category of Units defined by producing the same or similar products, such as chemicals, textiles and the like.
Software Requirements: Set of requirements for the software side of the DAS installed at the participating industry. See Section 4.4.2 for details.
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SPCB: State Pollution Control Board. State Pollution Control Boards are the primary body responsible for enforcement of environmental regulations in India.
PM: Particulate Matter, also known as Total Suspended Particulate Matter or TSP. Generally a complex, multi-phase system of all airborne solid and low vapor pressure liquid particles having aerodynamic particle sizes from below 0.01-100 micrometers and larger. PM places no restriction on particle size.
Source: Point of emissions of particulate matter into the ambient air, such as a boiler stack or process stack. Used also to refer to the utility or process connected to such a stack where appropriate.
Stack: A chimney, smokestack, or vertical pipe that discharges used air.
Systematic Error: A consistent deviation in the results of sampling and/or analytical processes from the expected or known value. Such error is caused by human and methodological bias.
System Integration Test: A test performed on the CEMS Software to test if its compatible with the ETS Bridge Software. See Section 6.6 for details.
Unit: Single industrial plant (industry), which may contain multiple sources. Used to refer to the industrial unit as a collection of Sources of emissions regulated under the scheme.
Valid Calibration Range: Defined as the range from zero to 120% of the maximum PM emission mass flow rate or PM emission mass concentration (whichever is applicable) that occurred during an initial calibration or recalibration. velocitymax velocitymax is the maximum of the velocity rate measured during
calibration/CEMS Audit, ID Fan Output.
vol_flowmax: Vol_flowmax is the maximum of the volume flow rate measured during the time of the calibration/CEMS Audit, ID Fan Output. It is reported in Nm3/s. Vol_flowmax=(Velocitymax)X(cross-sectional area of the duct)
Weekly: In this document, a week is defined as Monday to Sunday
Zero Drift: The change in instrument output over a stated time period of non-recalibrated, continuous operation, when the initial input concentration is zero; usually expressed as a percentage of the full scale response.
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3. Introduction: Pilot Emissions Trading Scheme for Particulate Matter
Emissions trading systems, or “cap-and-trade”, have been applied to a variety of pollutants around the world in order to guarantee environmental outcomes while minimizing compliance costs. The US EPA pioneered such trading under the Clean Air Act to limit a variety of common air pollutants beginning in 1974 (Stavins, 2003). The landmark Acid Rain program applied the cap-and-trade model to sulfur dioxide pollution, achieving sharp reductions in emissions at lower than expected costs.
Since these examples, environmental trading programs have proliferated in the European Union, Canada and, increasingly in developing Asia. China has a nascent sulfur dioxide market and has been testing market-based policies jointly with the US EPA since 1999 (Yang and Schreifels, 2003; Schreifels, Fu and Wilson, 2012). Indian industries trade in Renewable Energy Certificates and, via the Clean Development Mechanism, Certified Emissions Reductions for carbon dioxide. In 2012, the Indian government’s Bureau of Energy Efficiency launched a trading scheme based on energy consumption to encourage greater efficiency in energy-intensive industrial sectors.
In this context, the Ministry of Environment & Forests (MoEF), the Central Pollution Control Board and the State Pollution Control Boards of the states of Gujarat, Maharashtra and Tamil Nadu have come together to design and pilot an emissions trading scheme for particulate matter air pollution from industrial point sources. Particulates are the most severe air pollution problem in India, with most major cities and many industrial areas out of compliance with the National Ambient Air Quality Standards (NAAQS) (CPCB, 2010; CPCB 2011). The model of industrial development in tightly-clustered industrial estates means that industrial combustion is a key source of particulate pollution in many areas, though transport emissions have also grown rapidly (CPCB, 2009; CPCB 2011). The emissions trading scheme (ETS) will be piloted in several such large industrial areas in order both to reduce emissions and to provide a working example of emissions trading in India for a critical local air pollutant.
Sound emissions measurement is the foundation of any successful trading program. The pilot emissions trading scheme, like the landmark US programs and unlike the environmental trading schemes in India to date, will rely on continuous emissions monitoring systems (CEMS) for measurement. Unlike for carbon dioxide or energy consumption, input-based methods of measurement are not reliable for particulates, emissions of which are a complex function of combustion conditions and abatement technology. The role of CEMS is therefore to measure the total load of particulate matter (PM, also known as Total Particulate Matter or TPM outside India) coming from each source in order to record emissions and reconcile emissions against permit holdings in the trading scheme.
The purpose of this document is then to serve as a technical specification for accurate, reliable CEMS measurement of particulate matter, within the context of this pilot trading scheme. The balance of this introduction describes the context for the pilot emissions trading scheme, in order to fill out the role that CEMS will play in this new regulation. We focus in particular on the design of the emissions trading scheme and the characteristics of regulated sources. All of this material is necessarily presented very briefly as context for the role of CEMS in the pilot emissions trading system. Following the introduction, the main body of the document details the technical requirements for CEMS and the technical and institutional safeguards on CEMS operation.
