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Learning in and from India

I have learned so much from my recent and many travels to India, not least the fact that I have so much more to learn. On paper, India’s goals for delivering clean energy (50% renewable by 2030) look challenging, but it is not until you are on the ground at regional power plants and talk to state regulators that you understand the scale and complexity of these challenges.

Our US Department of State-funded project in India requires us to evaluate the status of mercury emissions from the coal power sector and, based on our conclusions, devise appropriate training and capacity building. And, through our work on emission monitoring, plant flexibility and multi-pollutant emission control, my respect grows for those Indian stakeholders who are striving to match international achievements.

In the last few years India has moved from no emission limits for SO2 and NOx on coal-fired utilities to limits which are as stringent as those in many OECD regions. To comply with these limits, Indian power plant operators must make a huge technology leap, with associated increases in financial outlay and staff skills.

The introduction of the new emission limits brings with it the requirement to monitor those emissions. As discussed in our recent report on continuous emission monitoring systems (CEM) in India, India is installing monitoring equipment across all major sources at an unprecedented rate. However, with this admirable endeavour comes inevitable problems.

The Central and State Pollution Control Boards (CPCB, SPCB) are promoting a ’self-regulating‘ route. The SPCBs are faced with regulating many sources, often across vast areas, and, due to reported limitations in staff availability, require that each source monitor and report emissions directly. The online monitoring system prescribed by the CPCB and implemented by the SPCBs is perhaps the most automated system of its kind in the world. CEM equipment must be installed in such a way that the emissions data produced are reported directly and in real-time to the regulator and, in some situations, to the public too. Whilst this avoids any potential data tampering by the source, it also assumes that the CEM system is installed and operating correctly at all times. This is a huge assumption. The regulators can perform a ’remote calibration’ to confirm that a CEM is active. This is more of a one-off span or zero check, as a full calibration is not performed. Although this can provide immediate confirmation of whether a CEM is live and functioning, it does not necessarily confirm that it is installed correctly and operating as it should. There has to be adequate quality control and quality assurance (QA/QC) by staff at the source to ensure the CEM is indeed reporting valid data, also covered in the ICSC project.

CEM selection is largely prescribed in India. Sources have the option to install:

  • Certified CEM – equipment which has been evaluated by a certified body (such as TUV in Germany) to confirm that it is fit for purpose in specified installations. This is the EU approach
  • Any CEM system which passes a performance check on site. This is the US approach.

Whilst this combined EU-US approach theoretically offers the advantage of flexibility, allowing sources to choose which CEM to install, the reality is that the EU approach is often assumed to be more convenient as it is seen as ’plug and play‘. By buying a certified CEM, sources can avoid the perceived challenge of completing a performance check to prove the CEM is fit for purpose. This is not entirely the case, as even certified systems need to pass quality assurance testing when they are installed.

From the written test results we obtained at our workshops in both Bhopal and Bhubaneswar, it is clear that prior to our events, many of our delegates were under the misapprehension that only certified CEM systems are permitted by the CPCB. It may be partly due to this misconception that European vendors such as Durag, Sick and Siemens, dominate the CEM market in India. We were happy to provide accurate information at our training events. Thermo-Fisher (a US vendor) has a relatively strong hold in the mercury CEM market in India, largely due to having an office in Mumbai. If other US vendors are to succeed in India, they have a closing window of opportunity to demonstrate that their equipment is just as good as certified EU systems. And there are two current or impending windows which offer this opportunity:

  • The current call for tenders on CEM. In our visit to Bhubaneswar alone, we heard from 13 delegates whose sources were either in, or were entering, the procurement phase for mercury monitoring systems; and
  • The installation of FGD across the Indian coal fleet will void the applicability of most if not all of the opacity monitors currently used for particulate control.

But there is also an urgent demand for skills. We intended to provide training for 100 source operators over our first two CEM workshops in July but ended up training over 200. The desire for learning is evident. As mentioned earlier, the Indian regulators rely heavily on ’self-regulation‘ and the assumption that the emission data they receive are accurate. This, in turn, depends on the assumption that the CEM systems are installed and operated correctly. For staff who are new to this equipment, this may not always be the case. The EU and USA have had almost 40 years of learning to operate monitoring systems, and each has developed its own personnel training scheme – MCERTS-based in the EU and QSTI-based in the US. This provides the reassurance that staff operating CEM are doing so to a minimum standard. As India installs CEM at an unprecedented rate, it should provide training at a similarly accelerated rate.

Our training courses were successful and appreciated, and are a valuable contribution to what is required in India. Our aim is that our interactions with ministries, regulators, sources, and other stakeholders in India will initiate serious discussions into the establishment of a certification or standardisation programme for the training of personnel in CEM utilisation.

In a country where the challenges are immense, our training could be the catalyst for such initiatives. When we return to India later this year for our final two CEM workshops, we will continue to promote discussions among relevant stakeholders.

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