SPEED POST. titled, "Guidelines for CEMS - Selection l

Transcription

1 SPEED POST No. CPCBjA-21018jETSj Dated: August 13, 2013 To The Member Secretary, Maharashtra State Pollution Control Board, Kalpataru POint, 2 nd, 3 rd & 4th Floor, Opp. Cineplanet, Near Sion Circle l Sion (E), Mumbai 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 same l titled, "Guidelines for CEMS - Selection l 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 Secretary

2 GUIDELINES FOR CEMS SELECTION, INSTALLATION AND OPERATION Prepared for Industries participating in the Pilot Emissions Trading Scheme for Particulate Matter from Stationary Sources (Stacks) Issued 5 th August

3 CONTENTS 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 Step 4.1.1: Set-up DAS (Data Acquisition System) Step 4.1.2: Data logger Step 4.2: Get user id & password from SPCB Step 4.3: Registration of CEMS installed Step 4.4: Software Set-up Step 4.4.1: Installing 2 softwares (CEMS Software & ETS Bridge Software) Step 4.4.2: Set Configuration of the CEMS software Step 5: Calibration of PM CEMS device and Performance Test Step 5.1: Iso-kinetic sampling for Calibration of PM CEMS Step 5.2: Post-Calibration Performance Test Step 5.3: Calibration of Flow Meter Step 6: Operations and Maintenance Step 6.1: Regular Maintenance Step 6.2: Monthly Zero Check Step 6.3: Re-calibration Step 6.4: CEMS Audit Appendix A1.1 Physical Accuracy Requirement of CEMS Device Appendix A2.1 User ID request form Appendix A3.1: Sample Contract Between Industry and Vendor

4 EXECUTIVE SUMMARY 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 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 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 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 system for ensuring highquality 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 3

5 document along with 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 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. 4

6 OVERVIEW FLOW CHART FOR PM-CEMS SELECTION Presentation and Review of Technology Options VENDOR INDUSTRY Technology demonstration Technology choice Ensure technology compatibility with ETS requirements vis-à-vis hardware and software requirements (system integration test) Technology and vendor choice as per ETS guidelines set by CPCB and available with SPCBs Final vendor and technology selection and procurement Port installation test Spare parts and repairs Monthly physical check of installation (testing, cleaning, alignment) Quarterly maintenance and servicing Installation of CEMS DAS setup Data transfer PM CEMS Registration PM CEMS Calibration Form filling Re-calibration CEMS Audit 5

7 PURPOSE OF THIS DOCUMENT 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 below) 3. Install CEMS 4. Set-up Data Transfer System 4.1. Hardware Set-up Set up DAS (Data Acquisition System) (PC with internet connection at the industry) Lay cable from CEMS device to DAS Data logger 4.2. Get user ID & password from SPCB 4.3. Registration of CEMS installed 4.4. Software Set-up Installing 2 softwares (CEMS Software & ETS Bridge Software) 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. 6

8 STEP 2: PM CEMS DEVICE SELECTION 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. Parameter 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: DC Tribo Mass Flow Monitor AC Tribo Mass Concentration Monitor Electrodynamic Light Scatter Technology Opacity Monitor Wet Extractive Technology Measured Value Direct in mg/m3 mg/m3 mg/m3 mg/m3 mg/m3 g/s, kg/hr Velocity Monitor X Required Duct < 1m Diameter X * Duct >1m to 4m * Diameter Duct > 4m Diameter X X X X * Electrostatic X X X Precipitator Stack Gas *** *** *** Temperature > C Wet Scrubber or X X X X X Water Droplet <70 0 C Large particles> X X 20um 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. 7

9 Type b) Flow meter selection matrix: Irregular Flow Max Flue Gas Temperature Impact Differential Pressure (Pitot Tube) Single point Multiport Thermal anemometer 1 Bi-directional ultrasonic Infrared correlation X 2 2 Upto 550 C Upto 550 C o C (Model Specific) 450 C 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 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. 8

10 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 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 SYSTEM 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 Step 4.4: Software Set-up 9

11 STEP 4.1: HARDWARE SET-UP 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 site 1. 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 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. 1 The 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. 10

12 STEP 4.4: SOFTWARE SET-UP 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. 11

13 Following points should be taken into account for iso-kinetic sampling: 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 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. 12

14 STEP 5.3: CALIBRATION OF FLOW METER 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 MAINTENANCE 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 isokinetic 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. 13

15 The table below describes situations triggering both types of recalibration events Situation Type of Re- Remarks Calibration 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 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 Calibrate and perform Post- Calibration Performance Test with the new iso-kinetic samples. 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. 14

16 APPENDIX A1.1 PHYSICAL ACCURACY REQUIREMENT OF 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/nm 3 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 flowmeter should also have international certification (such as US EPA, MCERTS or TUV) covering basic operational characteristics. 15

17 APPENDIX A2.1 USER ID REQUEST FORM To be submitted to designated SPCB officer Industry name:.. Industry Address:.. Key contact person from the industry Name: Designation: Contact number: address: Fax: Date: Signature: Industry s stamp: 16

18 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. 1 st, 2 nd 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 ). IT IS HEREBY AGREED THAT: 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 17

19 Schedule A: Terms and Conditions 1 Procurement 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. 2 Warrantee Period I. The warrantee period shall be calculated from the date of delivery to the date [number] months thereafter. II. III. IV. 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). 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. 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). 3 Maintenance 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. 18

20 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. IV. Payment during the maintenance will be made as per actual work done only. 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. 19

21 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

22 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 1

23 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 Dr. D. Saha Chair Sh. S.K. Sharma Sh. A. Pathak Sh. N.M Tabhani Sh. Chirag Bhimani Sh. V.M. Motghare Sh. S.C. Kollur Sh. R. Dhanasekaran Dr. Anant Sudarshan Sh. Harsh Singh Ms. Amber Luong Sh. Jasdeep Mandia Ms Sujata Tilak Organization Central Pollution Control Board Central Pollution Control Board Central Pollution Control Board Gujarat Pollution Control Board Gujarat Pollution Control Board Maharashtra Pollution Control Board Maharashtra Pollution Control Board Tamil Nadu Pollution Control Board J-PAL South Asia J-PAL South Asia J-PAL South Asia J-PAL South Asia DAHS Consultant (J-PAL South Asia) 2

24 Table of Contents 1. EXECUTIVE SUMMARY PILOT FOR EMISSIONS TRADING SCHEME IN INDIA ROLE OF CONTINUOUS EMISSIONS MONITORING SYSTEMS FOR MEASUREMENT THE ROLE OF DIFFERENT PARTIES IN A MONITORING REGIME PERFORMANCE REQUIREMENTS OF THE CONTINUOUS EMISSIONS MONITORING SYSTEM GUIDANCE ON INSTALLATION AND CALIBRATION OF CEMS HANDLING OF THE DATA FROM CEMS GLOSSARY OF TERMS INTRODUCTION: PILOT EMISSIONS TRADING SCHEME FOR PARTICULATE MATTER CONTINUOUS EMISSIONS MONITORING SYSTEMS BENEFITS OF CONTINUOUS RECORDING OF PARTICULATE EMISSIONS ACCEPTABLE TYPES OF TECHNOLOGY CONFIGURATION CALCULATING TOTAL PM LOAD CEMS REQUIREMENTS Hardware Requirements Software Requirements Performance Requirements Required Variation in PM Emissions level during Calibration CEMS OPERATIONS ROLE OF DIFFERENT PARTIES IN MONITORING REGIME CEMS OPERATIONS OVERALL FLOWCHART ACTIVITIES IN CEMS OPERATIONS Activity: PM CEMS Installation, Registration and Configuration Activity: Standard Reference Method for Parallel Measurement Activity: Calibration and Post-Calibration Performance Test Activity: Re-calibration of CEMS Type A Re-calibration Type B Re-calibration Activity: CEMS Audit and CEMS Audit Performance Test Activity: Commenting on CEMS Data DATA ACQUISITION AND HANDLING SYSTEM (DAHS) DAHS ARCHITECTURE DAHS SCHEMATIC PARAMETERS SPECIFICATION Parameters Details Parameters transferred to ETS Bridge Software ETS BRIDGE INTERFACE Interface Overview

25 6.4.2 Interface Details Data Exchange Process SYSTEM INTEGRATION TEST FOR CEMS SOFTWARE Why System Integration Test? Procedure for System Integration Test REFERENCES APPENDIX A1: FORMATS FOR ALL THE FORMS A1.1 CEMS REGISTRATION FORM A1.2 INSTALLATION CHECKLIST A1.3 FUNCTIONAL TEST CHECKLIST A1.4 SAMPLE REPORTING FORM APPENDIX A2. BACKGROUND CALCULATIONS A2.1 CALCULATION OF THE CALIBRATION FACTORS A2.2 CALCULATION OF THE POST-CALIBRATION PERFORMANCE TEST A2.3 CALCULATION OF THE CEMS AUDIT PERFORMANCE TEST APPENDIX A3. GUIDELINES A3.1 CEMS INSTALLATION GUIDELINES A3.2 STACK CHARACTERISTICS MATRIX : PM CEMS TECHNOLOGY A3.3 STACK CHARACTERISTICS MATRIX : FLOW MEASUREMENT TECHNOLOGY APPENDIX A4.1 FEEDBACK FORM

26 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. 5

27 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 Activity: Calibration and Post-Calibration Performance Test and Section 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 postcalibration CEMS reading. Here, m and c are estimated 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 6

28 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 7

29 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: APCD: Calibrate: Calibration Drift: CEMS: CEMS Audit: CEMS Requirements: CEMS Software: CEPI: Cluster: 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. Air Pollution Control Device 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 for details. The difference between the instrument response and a reference value after a period of operation without recalibration. Continuous emission monitoring system. 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 for details. Set of Hardware, Software and Performance required for the CEMS installed by the participating industry. See Section 4.4 for details. 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. 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. 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. 8

30 Combustion: Compliance: Compliance Period: Concentration: CPCB: DAHS: DAHS Server: DAHS Software: DAS: EPA: ETS: ETS Bridge: 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. A unit that has abided by all the regulations of the Emissions Trading Scheme is said to be in compliance. 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 standards set acceptable pollution levels by measuring pollutants base on mass per volume. 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. Data Acquisition and Handling System Data Acquisition and Handling System Server is the server installed at the regulator office 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 Data Acquisition System is a PC at the participating industry which send the data to the DAHS Server The United States Environment Protection Agency 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. 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. 9

31 Functional Test: Flue Gas: Mass flow standard: Parameter Specification: Tests used to assure that CEMs have been installed and are operating correctly. 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. 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. 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 for details. Permits: Point Sources: QA/QC: Random Error: Re-calibration: 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. Specific points of origin where pollutants are emitted into the atmosphere such as factory smokestacks. Quality Assurance/ Quality Control. Protocols to ensure quality data on an ongoing basis. The non-systematic deviation experienced in any step of an analytical procedure that can be estimated by standard statistical techniques. Calibrating the PM CEMS device again to override the previous calibration equation. This can be triggered because of various conditions. See Section 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: Software Requirements: Category of Units defined by producing the same or similar products, such as chemicals, textiles and the like. Set of requirements for the software side of the DAS installed at the participating industry. See Section for details. 10

32 SPCB: PM: Source: Stack: Systematic Error: System Integration Test: Unit: Valid Calibration Range: velocity max vol_flowmax: Weekly: Zero Drift: State Pollution Control Board. State Pollution Control Boards are the primary body responsible for enforcement of environmental regulations in India. 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 micrometers and larger. PM places no restriction on particle size. 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. A chimney, smokestack, or vertical pipe that discharges used air. 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. A test performed on the CEMS Software to test if its compatible with the ETS Bridge Software. See Section 6.6 for details. 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. 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. velocity max is the maximum of the velocity rate measured during calibration/cems Audit, ID Fan Output. 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=(Velocity max )X(cross-sectional area of the duct) In this document, a week is defined as Monday to Sunday The change in instrument output over a stated time period of nonrecalibrated, continuous operation, when the initial input concentration is zero; usually expressed as a percentage of the full scale response. 11

33 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. 12

34 4. Continuous Emissions Monitoring Systems This section provides guidance on the selection and use of continuous emission monitoring systems for the measurement of particulate matter (henceforth PM CEMS) in stationary sources (stacks) 1. It is intended to ensure the reliability and accuracy of emissions data generated by an industry with a PM CEMS installation. 4.1 Benefits of Continuous Recording of Particulate Emissions There are four clear benefits to continuous recording of particulate emissions as opposed to manual stack sampling at specified intervals Real Time Information: Manual stack sampling provides no information on particulate emissions in the intervals between monthly monitoring. However actual emissions may vary quite widely in real time as a function of operating processes, the operational status of air pollution control devices (APCD), fuel type and fuel quality and so on. For this reason it is impossible to accurately estimate total emissions from any given industry (or group of industries) in a region from occasional stack sampling. This is a major drawback especially in critically and severely polluted areas where even small increases in pollutant load can be a major health concern Load Standards PM CEMS data enables the use of load standards instead of concentration standards as the basis for regulating stationary source emissions. In many situations, load standards have a number of important advantages over concentration standards, especially because health and environmental concerns are normally influenced by the mass or volume (in the case of effluents) of pollutants that are emitted and not directly by the concentration. A higher pollution load will normally translate into higher ambient concentrations while a limit on concentration of emissions may still allow for a high total load to be emitted (through an increase in operating hours, stack volume or the number of stacks in an area). In addition, while load standards often make more environmental sense than concentration standards, they also increase the number of options industry has available in order to comply with regulation. For instance, total load can be reduced by decreasing operating hours. However this is not a helpful option for an industry in attempting to comply with concentration standards Market Based Regulatory Mechanisms: Market based regulatory mechanisms such as emissions trading provide a number of benefits to industry. The principal advantage is that emission reductions can be made at lower cost. Under cap and trade for instance (a form of emissions trading), only the total emissions load from a number of industries is fixed but individual units are free to trade emission permits amongst each other such that reductions are undertaken by those units for whom it is cheapest to do so. This flexibility can significantly reduce overall costs. In addition, since a cap and trade is based on a load standard the benefits of regulating load vs. concentration also carry over to industry. 1 Here and elsewhere in this document the term particulates or the abbreviation PM should be understood to refer to total particulate matter (TPM). 13

35 4.1.4 Transparency and Openness: The use of PM CEMS technologies presents industry, regulators and potentially the public with high quality, ongoing information on emissions from each source so equipped. In turn, this means that regulation based on this data is also transparent and clear, industry can predict and be aware of the costs of compliance and plan accordingly, and the public at large obtains the best possible information on environmental performance of regulated units and the total emissions load in an area (from regulated stationary sources). 4.2 Acceptable Types of Technology Configuration A first step for adopting CEMS is to select a CEMS device (or combination of devices) optimally suitable for the stack characteristics at hand. Acceptable technology configurations for meeting the PM mass flow rate continuous monitoring standards can be broadly divided into two categories: 1) mass flow based and 2) mass concentration based. Concentration based CEMS can be further divided into configurations with and without volumetric flow meters installed. For the purpose of this pilot emissions trading program, concentration based technology without a volumetric flow meter is not recommended. Without a flow meter, unrealistic assumptions must be made to estimate PM load, undermining the pursuit of high data-quality. The diagram below illustrates the different CEMS configuration types. Type of Configurations Type 1 PM Mass Flow Based Technology PM Mass Concentration Based Technology Type 2 Volumetric Flow Meter Installed Type 3 Volumetric Flow Meter NOT Installed (Not Valid for ETS) Type 1 Configuration: PM Mass Flow Based Technology: This consists of a PM CEMS that directly measures PM mass flow. In such a case, the CEMS is calibrated to PM mass flow using iso-kinetic sampling and provides mass flow data directly. An example of this configuration is the triboelectric probe. Type 2 Configuration: PM Mass Concentration Based Technology with Volumetric Flow Meter: This consists of a PM CEMS device that measures mass concentration of PM emissions and a separate flow meter device that measures volumetric flow of the flue gas. Each analyzer should be calibrated separately. The performance tests performed for the initial calibration, re-calibration and CEMS Audits. Examples of mass concentration based CEMS are opacity meters and light-scattering devices 14

36 Type 3 Configuration (Not Recommended): PM Mass Concentration Based Technology without Volumetric Flow Meter: This consists of a PM CEMS device that measures PM mass concentration only. The CEMS device is calibrated to PM mass concentration using iso-kinetic sampling, however volumetric flow (vol_flow max ) is assumed to be constant. The value for Vol_flow max is the maximum of: the volume measured during calibration; the volume measured during the time of calibration or CEMS Audit; or the ID fan output. Both the certification test (post-calibration) and CEMS audit is conducted on the product of the concentration and vol_flow max,which is equal to the PM mass flow. The table below summarizes the characteristics of each configuration type. Type of Technology Calibration Mass Flow Configuration Type 1 PM mass flow CEMS PM mass flow using iso-kinetic sampling Reading of the CEMS after calibration Type 2 PM mass concentration CEMS & Volumetric flow meter Each device to be calibrated separately Multiplication of both CEMS and flow readings Type Calculating Total PM Load PM mass concentration CEMS only Mass concentration CEMS calibrated using iso-kinetic sampling Multiplication of PM CEMS, cross-sectional area and velocity max =max {max. velocity during calibration, max. flow during Calibration/CEMS Audit, ID Fan Output} Total PM Load is calculated by the summing the continuous PM mass flow measurements over a specified compliance period. Although PM Mass flow values will vary for the different technology configurations (as explained in the table above), it is assumed that individual mass flow measurements deviate slightly from true emissions (manual sampling). In the long run, these deviations will not affect total PM load (summed) since the expected value of the difference between CEMS readings and true emissions would converge toward zero over the length of the compliance period as explained in Section 1.4. It is this characteristic of which serves to heighten data accuracy and support the emissions trading program with reliable emissions estimates. 4.4 CEMS Requirements Beyond simply conforming to one of the configuration types, a further set of CEMS requirements is laid out to provide a final safeguard for data quality. These can be categorized as: 1) Hardware requirements 2) Software requirements 3) Performance requirements Apart from these, guidelines are also provided for selection of the appropriate CEMS technology (Appendix A3.2 Stack Characteristics Matrix : PM CEMS Technology), installation guidelines (Appendix. A3.1 CEMS 15

37 Installation Guidelines) and appropriate technology for flow measurement (Appendix A3.3 Stack Characteristics Matrix : Flow Measurement Technology) Hardware Requirements The hardware requirements for the ETS monitoring regime consist of the following two devices: 1) A PM CEMS device for PM mass flow measurement (as per one of the two valid configuration types listed above) 2) A PC with (DAS i.e Data Acquisition System): a. fast and reliable internet connection b. Dedicated broadband internet connection with 24x7 connectivity (min 256Kpbs) 3) Data logger unit for saving the CEMS data (even when PC fails) for atleast 7 days PM CEMS Hardware Requirements Once the particular configuration of the CEMS device is selected, an additional three requirements must be met. 1) The device should ideally measure and report the both calibrated and uncalibrated data to the DAS. That is, the CEMS device should report CEMS readings before the calibration equation is applied. The calibration equation will be applied later by the DAS. For devices unable to send uncalibrated data, the device should register a calibration factor of 1 and in this case calibration settings should be password protected. 2) PM CEMS device and flow-meter should be tamper-proof. 3) The selected CEMS device (hardware) and flow meter must meet specifications of key operating parameters such as: physical deviation in measurement, response time, minimum detection limit (for flow meters), security measures to prevent unauthorized maladjustment, and inclusion of diagnostic flags. The following table specifies the key operating parameters to which CEMS and flow meter devices must conform. See also Appendix A3 for technology selection guidelines based on stack conditions. Note that regardless of technology choice, all CEMS installations must pass the independent performance standards detailed in this document. Name of Parameter Specifications PM CEMS Flow Meter Measurement range User defined User Defined Instrumental detectable 10 mg/nm 3 or less 1 m/s (minimum detectable limit) concentration Data acquisition 1 minute 1 minute Data transmission 1 minute 1 minute Deviation in the raw < 5% <2% of measuring range reading 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 16

38 CEMS Hardware Certification: 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 Data Acquisition System The Data Acquisition System (DAS) is a PC consisting of a vendor-designed CEMS Software and an application called the ETS Bridge Software. The former is designed to accept incoming data from the CEMS device and convert it into a standard format while the latter is designed to read data from the CEMS device and send it to the SPCB. For more details about the DAS, see Section 6.2 DAHS Schematic Software Requirements The PM CEMS device must be equipped with accompanying CEMS Software, either designed by the CEMS vendor or by a third party software firm. The CEMS Software must be ETS compatible, meaning it must output data in the prescribed format and pass the System Integration Test. For details of the System Integration Test see Section 6.6 System Integration Test for CEMS Software. For details of the data exchange process with the ETS Bridge Software, see Section 6.4 ETS Bridge Interface. The CEMS Software must be password protected so that no actual data should be transferred to the ETS Bridge Software Performance Requirements Operating parameter specifications constitute the broad hardware requirements for PM CEMS devices under the emissions trading pilot. Once the hardware is finalized, the remaining safeguard for data quality is a performance requirement. As opposed to physical device characteristics, the performance requirement is a statistical test aimed at ensuring that emissions readings measured by CEMS is as close as possible to the true value. The performance test must first be carried out after the device is calibrated (called the Post-Calibration Performance Test). This only acknowledges that initial calibration is sufficiently accurate for the purpose of the ETS pilot 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 tests are in Section Activity: Calibration and Post-Calibration Performance Test and Section Activity: CEMS Audit and CEMS Audit Performance Test. Calculations for the performance tests during calibration and CEMS Audit 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. If instruments fail this test, industry needs to re-calibrate the device Post-Calibration Performance Test Details of this test are in Section Activity: Calibration and Post-Calibration Performance Test. Calculations for this test are in Appendix A2.2 Calculation of the Post-Calibration Performance Test, Valid Calibration Range & Maximum Volumetric Flow. If instruments do not pass, the industry must re-calibrate the device and complete the test again. 17

39 CEMS Audit Performance Test Note that the Post-Calibration Performance Test only certifies that initial calibration is sufficiently accurate for the purpose of the ETS pilot and does not exempt the industry from the requirement to carry out periodic quality control performance tests as described in Section Activity: CEMS Audit and CEMS Audit Performance Test (refer Appendix A2.3 for calculations) Required Variation in PM Emissions level during Calibration To ensure that the calibrated CEMS readings are valid under differing operational conditions, if possible, the PM emissions should be varied as much as possible within the normal operations of the plant during calibration. The failure to vary the range of conditions adequately will result in a narrower Valid Calibration Range, which defines the range of data that s considered valid by the SPCB. The Valid Calibration Range is calculated as the range from zero to 120% of the maximum concentration of mass flow that occurred during the Post-Calibration Performance Test. The industry must take a minimum number of measurements for calibration with variation in the emission levels as follows. 2 point at zero load 4 points at 75% - 100% load For measurements at load parallel measurements from the CEMS device and iso-kinetic sampling should be recorded. For taking parallel measurements at near zero load, either the emission source should be shut down or the device can be operated outside the stack (there is no need to do isokinetic sampling in this case). If possible, it is recommended to take 2 points at no load along with 7 valid parallel measurements with variation in emission levels. Emission level variation may be achieved through variation of load, feed rate, turning off ESP cells or other methods. 5.0 CEMS Operations 5.1 Role of Different Parties in Monitoring Regime A number of different parties are involved in implementing a monitoring regime built around a continuous emissions monitoring system. The most important roles are those of regulated industry and the state pollution control board (SPCB). It is the responsibility of regulated industry to comply with the specifications outlined in this and other applicable documents and to ensure that high quality and reliable data may be transmitted to the state board. Conversely it is the responsibility of the SPCBs to oversee the monitoring regime, clearly outline expectations from all parties and implement the regulatory framework that uses the PM CEMS information. Other parties such as accredited labs, CEMS vendors and CEMS working groups in each industry cluster play essential support roles. 18

40 Central Pollution Control Board: The CPCB is responsible for overall standards, framework of associated regulation such as emission trading, and modifications in standards as needed. State Pollution Control Board: The SPCBs are responsible for implementation of the CEMS monitoring regime and any associated regulatory framework such as emissions trading. In order to utilize PM CEMS data effectively it is necessary that the SPCBs provide information to industry on how such data is to be generated and transmitted (the purpose of this document) and applicable penalties in case of non-compliance. In order to oversee a network of PM CEMS equipped stationary sources, SPCBs must be equipped with Necessary infrastructure to receive and utilize real time emissions data Trained staff capable of interpreting and analyzing this information CEMS field team to conduct back-checks on PM CEMS installations in regulated units CEMS field team to evaluate installed PM CEMS in cases where transmitted data is unsatisfactory Regulated Industries: It is the responsibility of regulated industry to comply with mandates to install PM CEMS where applicable and follow the specifications outlined for the same. It is the responsibility of the industries to make sure that CEMS device passes the Performance Tests. Because ultimate responsibility for compliance lies with industry it is strongly recommended that they specify terms of technical support, data quality expectations, maintenance and availability of spares and delivery and installation timelines when placing orders with vendors. Industry may also choose to sign annual maintenance contracts and other ongoing quality control measures with vendors to ensure their PM CEMS installations remain reliable and accurate. Accredited Labs and CEMS Working Groups: Labs currently accredited to perform manual stack sampling for PM measurement have an important role to play in providing the independent technical expertise necessary to implement the specifications outlined in this document. CEMS working groups may be set up in each regulated cluster to provide additional support to industry in the regular maintenance of PM CEMS installations. These groups may also provide local expertise on calibration methods and protocols. If determined by the appropriate pollution control board these working groups may also be accredited to undertake some or all of the calibration and Performance Testing required by this specification. CEMS Vendors: Vendors of PM CEMS technology are responsible for producing analyzers. Vendors are also responsible for provision of spare parts, warranty covered repairs and ongoing maintenance and cleaning in cases where an 19

41 Annual Maintenance Contract is signed. For this reason it is important for all PM CEMS vendors, especially those providing analyzers to industry participating in the pilot Particulate Emission Trading Scheme, to ensure sufficient availability of parts and technically trained personnel. Only CEMS Softwares, which passes System Integration Test, can send data to the ETS Bridge Software and thus participate in the CEMS for ETS. For the most part ETS Compatible CEMS Software can be provided to the industry by the CEMS vendors, however independent software organizations can be contracted. Local Industry Associations: A switch to continuous emission monitoring and its application to regulatory frameworks such as emission trading can bring many advantages to industry, regulators and the public. However there is also a learning curve involved. Industry associations can play a critical role at the cluster and national level in providing information and guidance to regulated units, liaising between regulators, industries and CEMS. 5.2 CEMS Operations Overall Flowchart The flowcharts below show the general interaction of different stakeholders involved in the pilot program and the detailed process of work flow through which data quality from CEMS is maintained at the highest level. Details of each process and their interactions are described in Section 5.3 Activities in CEMS Operations CEMS Operations Overall Flowchart Environ Lab Stack Iso-kinetic Sampling for PM Emissions Measurement CEMS Vendors Industry PM CEMS Installation DAS Setup Data Transfer PM CEMS Registration PM CEMS Calibration Form Filling Recalibration CEMS Audit PM CEMS Devices Flow meters Providing AMC Providing Spare Parts SPCB Administration Data Collection Calculation of Calibration Factors CEMS Post-Calibration Performance Test CEMS Audits 20

42 Accredited Lab PM CEMS Post-Calibration Performance Test Conducts Iso-kinetic sampling Submits the reports in the standard format to the industry Industry CEMS Operations Overall Flowchart: Detailed PM CEMS : Installation, Registration and Configuration PM CEMS device, DAS installation and set up. Registration of PM CEMS to SPCB Getting Configuration and Composite Id from SPCB Configuring ETS-Compatible CEMS Software Submission of Installation and Functional Test Checklists to SPCB System ready for Calibration PM CEMS Post-Calibration Performance Test Asks accredited labs to conduct Iso-kinetic sampling as per the protocol. Submits the results to the SPCB via ETS Bridge Software. Gets reports from the SPCB (Server Software) on the PM CEMS Calibration and Post-Calibration Performance Test Test Passed Test Failed SPCB PM CEMS : Installation, Setup and Configuration Checks PM CEMS registration data and sends the approval to industry. Sends the Unique Composite ID (for each stack) and other configurations to the industry. Accepts the Self-Attested Installation and Functional Test Checklist from industry PM CEMS Post-Calibration Performance Test Accepts the iso-kinetic reports from industry. Does Post-Calibration Performance Test. Calculates & reports the Calibration Factors and Valid Calibration Range. External Factors Triggering Re-Calibration If Post-Calibration Performance Test passed, feeds the Calibration factors, Valid Calibration Range etc. to the CEMS software Go for Recertification Change in Process, Fuel, APCD or the PM CEMS Device PM CEMS operating outside Valid Calibration Range Failure of CEMS Audit PM CEMS Re-Calibration Performance Test Asks accredited labs to conduct Iso-kinetic sampling as per the protocol. Submits the results to the SPCB via ETS Bridge Software. Gets reports from the SPCB Server on the Post-Calibration Performance Test

43 5.3 Activities in CEMS Operations To summarize the CEMS operational requirements discussed in earlier sections of this document, the following activities are mandatory for this pilot emissions trading program: PM CEMS Installation, Registration and Configuration Standard Reference Method for Parallel Measurement Calibration and Post-Calibration Performance Test CEMS Audit and CEMS Audit Performance Test with Recalibration when required This specifications document attempts to provide a detailed discussion of each activity, and if followed closely, the outlined CEMS regime will form a strong backbone of the ETS program.

44 5.3.1 Activity: PM CEMS Installation, Registration and Configuration This is the first activity performed in setting up the PM CEMS device. The following flowchart provides a detailed explanation of the steps involved in the process. Industry SPCB PM CEMS : Installation, Setup and Configuration 1. PM CEMS & Flowmeter Installation Installation as per the guidelines 2. DAS Setup Establish data transfer to DAS Install ETS Bridge Software Download & Install ETS-Compatible CEMS Software 3. CEMS Registration Submits the CEMS Registration form using ddd ETS Bridge Software to SPCB 4. Configuration of CEMS Software Industry sets the configuration of the ETS- Compatible CEMS Software which includes Configuration ID, ToC, ToP 5. Installation and Functional Test Checklist Industry performs the Installation Checklist and submits it to SPCB via ETS Bridge Software Industry performs the Functional Test Checklist and submits it to SPCB via ETS Bridge. SPCB checks the CEMS Registration form and sends the approval to the industry. SPCB sends the Unique Composite ID and other configuration to the industry Based on the self-attested Installation and Functional Test submitted by industry, SPCB tells industry if the PM CEMS is ready for calibration or not. 6. PM CEMS Ready for Calibration 23

45 STEPS: Step 1: Installation of CEMS device and flow meter (if applicable): a. Industry contracts a CEMS supplier to install the PM CEMS device and flow meter as per the guidelines in A3.1 CEMS Installation Guidelines Step 2: Setup of Data Acquisition System (DAS): a. Industry installs a PC with internet connection called the Data Acquisition System (DAS). b. Industry establishes direct data transfer from the CEMS device to the DAS and installs ETS compatible CEMS Software (which has passed System Integration Test for CEMS Software). For details of testing, see Section 6.6 System Integration Test for CEMS Software. c. Industry downloads the ETS Bridge Software (free of cost) to the PC. The primary purpose of the software is to read incoming CEMS data from the DAS and transfer it to the SPCB server on a continuous basis. Additionally, the user interface allows industries to fill in and send registration details of the CEMS device to SPCB staff. For more details on the ETS Bridge Software, see Section 6.4 ETS Bridge Interface. Step 3: CEMS Registration: a. Industry runs the ETS Bridge Software for registration form. The following details must be filled and submitted. SPCB staff will review details and inform industry when device is registered. (Format: Appendix A1.1 CEMS Registration Form) i. Basic details of the Industry and contact information ii. Information on stack, process and APCD iii. Information on PM CEMS and flow meter iv. Information on ETS Compatible CEMS Software (which have passed System Integration Test for CEMS Software) b. Obtaining unique CEMS identification information i. ETS Bridge Software to send the registration form to the ETS Central Software (located at the SPCB). ii. When registered, the ETS Central Software will send a composite ID and other configuration details to the industry via the ETS Bridge Software. Step 4: Configuration of CEMS Software: Industry inputs parameters received from ETS central software (composite ID, Type of pollutant, type of technology configuration) to the ETS Compatible CEMS Software (which passed System Integration Test for CEMS Software, Section 6.6). For details on these parameters see Section Configuration Data. Step 5: Installation and Functional Test Checklist a. After the device(s) is installed, the CEMS supplier performs the installation checklist with oversight from industry operator. Note that this is done after installation and before calibration. b. Industry to input relevant details from the installation checklist into the corresponding form of the ETS Bridge Software and send to SPCB. Format for filling installation checklist is found in Appendix A1.2 Installation Checklist c. CEMS supplier fills the functional test checklist and submits to industry operator, who fills corresponding form in ETS Bridge Software and submits to SPCB. Format for filling functional test checklist is found in Appendix A1.3 Functional Test Checklist. Sub-groups in the functional test checklist: i. Visual inspection

46 ii. iii. iv. Leak testing Zero and span check Serviceability Based on the self-attested Installation and Functional Test submitted by industry, SPCB tells industry if the PM CEMS is ready for calibration or not Activity: Standard Reference Method for Parallel Measurement The SRM (Standard Reference Method) for measuring and calibrating PM emissions is through iso-kinetic sampling. The CPCB and EPA have both developed guidelines for effective PM sampling from stationary sources (stacks). The approved methods for PM iso-kinetic sampling are: CPCB Method 1 US EPA Method 17 US EPA Method 5 A detailed sampling sheet is provided to document key measurements during the sampling process, and labs are required to fill the results and submit to the industry. For an example of the iso-kinetic sampling form, see A1.4 Sample Reporting Form. A SRM shall be used to sample the emissions at a sampling plane in the duct, which is as close as possible to the CEMS, such that the presence of the equipment specified in the SRM shall not significantly influence or disturb the CEMS measurements. The sampling time for each of the parallel measurements shall be 30 min or 1 hour. If the average level of particulates is lower than 10mg/m3 in concentration, the sampling time must be 1 hour. Each of the sampling pairs of CEMS output (averaged over the measurement period) and SRM value must cover the same time period. For industries participating in the pilot emissions trading program, only the below mentioned labs are authorized to conduct iso-kinetic sampling for calibration of the CEMS device: 1. NABL certified lab 2. MoEF accredited EIA lab 3. Labs approved by participating SPCB Activity: Calibration and Post-Calibration Performance Test The PM CEMS device is ready for calibration only after performing all the steps in Section Activity: PM CEMS Installation, Registration and Configuration. In order to verify that the CEMS calibration meets the performance requirements, it must undergo the Post-Calibration Performance Test. The same iso-kinetic samples used for calibration are used for the CEMS Post-Calibration Performance Test. A Software at the SPCB server performs the Post-Calibration Performance Test and informs the industry if it passes or fails. See Section Performance Requirement for details. Technical details of the calculations involved can be found in Appendix A2.2 Calculation of the Post-Calibration Performance Test, Valid Calibration Range & Maximum Volumetric Flow. 25

47 Flowchart - Activity: Calibration and Post-Calibration Performance Test Accredited Lab PM CEMS Calibration & Performance Test Industry PM CEMS Calibration & Performance Test SPCB PM CEMS Calibration & Performance Test Does Stack Iso-Kinetic Sampling for PM Emission Measurement (9 samples at specified variance) Submits the reports (in standard format) to the Industry Submits the results to the SPCB via ETS Bridge Software. Does the Performance Test and approves PM CEMS Calibration and reports the result to the industry If test passed, calculates & reports the calibration factor, valid calibration range and maximum volumetric flow Gets reports from the SPCB (ETS Central Software) on the PM CEMS Calibration Performance Test Test Passed Feeds the Calibration factors, Valid Calibration Range etc. to the CEMS Software Test Failed Go for Recertification the Test and sends the approval to the industry.

48 Below is a step-by-step description of the full calibration and Post-Calibration Performance Test: Step 1: PM emission measurement samples are taken according to an approved method for isokinetic sampling. See Section Activity: Standard Reference Method for Parallel Measurement. Step 2: PM Samples are taken at different load conditions and emissions levels as explained in Section or Section Required Variation in PM emissions level during Calibration. This is to ensure the calibrated CEMS readings are valid under different operating conditions. Step 3: Accredited labs fill the results of the iso-kinetic sampling along with other details in the sampling form provided (See Appendix A1.4 Sample Reporting Form) and give to the industry operator. Step 4: Industry submits relevant details from the sampling form to the SPCB via the ETS Bridge Software. Details asked are: a. Iso-kinetic sampling results b. Start and End time of the sampling c. Iso-kineticity. Note: Industry should keep the original copy of the Sampling Report by the accredited lab along with the field data details. Step 5: Once the SPCB receives the sampling results electronically, the DAHS Server Software performs the Post-Calibration Performance Test and calculates the factors. The DAHS Server Software then notifies the industry of the Valid Calibration range and maximum volumetric flow. See Appendix A2.1 Calculation of the Calibration Factors and Appendix A2.2 Calculation of the Post-Calibration Performance Test for details of the calcluations. Step 6: If Post-Calibration Performance Test is passed, the industry feeds the calibration factors in the ETS-Compatible CEMS Software and starts sending the data. Step 7: If Post-Calibration Performance Test is failed, the industry must re-calibrate the device. See Section Activity: Re-calibration for details. Some of the checks during iso-kinetic sampling:- During iso-kinetic sampling for calibration, make sure data availability from CEMS device should be more than 95%, otherwise the sample is considered invalid. Iso-kineticity of the sampling should be in the range of , otherwise the sample is considered invalid Required Variation in PM Emissions level during Calibration To ensure that the calibrated CEMS readings are valid under differing operational conditions, the PM emissions should be varied as much as possible within the normal operations of the plant during calibration. It is recommended that 9 samples be taken at several different load levels, however if this is not possible, a minimum of 6 samples will suffice. For details of the load variation during calibration, including suggested load levels, see Section Required Variation in PM Emissions level during Calibration Frequency of Calibration of PM CEMS Device Calibration of the PM CEMS device has to be performed every 6 months. The CEMS calibration frequency shall be reviewed based on data-observation vis-à-vis cross verification /actual physical monitoring / deviations within the acceptable limits etc.

49 CEMS Data Availability during Iso-kinetic Sampling for Calibration Atleast 95% of the CEMS data should be available during the iso-kinetic sampling for calibration, otherwise the sample would be considered invalid Activity: Re-calibration of CEMS Re-calibration of CEMS is required whenever the device begins to show high deviations, possibly due to changes in external or internal factors. Re-calibration is of two types: A and B. Type A Re-calibration In this case previous samples can be considered for the Calibration and Post-Calibration Performance Tests. Type B Re-calibration In this case previous samples cannot be considered for the Calibration and Post-Calibration Performance Tests. All the iso-kinetic samples taken should be new. Situation Triggering Re-calibration: Situation 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. PM CEMS device (hardware) changed but the same model and same manufacturer Type of Recalibration Type A Type B Remarks Industry should take at least 2 more iso-kinetic samples above the valid calibration range. Perform Section Calibration and Post- Calibration Performance Test of the PM CEMS with the previous sampling points and new sampling points. Perform Section Calibration and Post- Calibration Performance Test of the PM CEMS with the iso-kinetic sampling points as per Section Required Variation in PM emissions level during Calibration. Recalibration after every 6 months Type B Same as above 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 28

50 5.3.5 Activity: CEMS Audit and CEMS Audit Performance Test To protect the integrity of emissions data underpinning the pilot emissions trading program, the PM CEMS requires ongoing maintenance and quality control. For this pilot, A CEMS Audit must be performed at least once in a year. Steps for the CEMS Audit: Step 1: Functional Test Checklist: CEMS supplier performs functional test and submits checklist to industry operator. The components of the functional test are: a. Visual inspection b. Leak testing c. Zero and span check d. Serviceability See Appendix A1.3 Functional Test Checklist for an example of the form Step 2: Industry enters functional test checklist information into corresponding form in the ETS Bridge Software and submits electronically to SPCB. Staff from SPCB will review the checklist and send confirmation to industry. Step 3: Iso-kinetic Sampling: Environmental lab will take 4-6 iso-kinetic samples using the standard procedure in Section Activity: Standard Reference Method Step 4: CEMS Audit Performance Test: Using the same calibration equation derived for the initial calibration and Post-Calibration Performance Test, the CEMS Audit Performance Test is performed using the iso-kinetic sampling data as the standard reference method for at least 4 samples. After industry submits the iso-kinetic sampling data to SPCB using the ETS Bridge Software, the DAHS server software does the CEMS Audit Performance Test and informs the industry. In case an instrument fails the CEMS Audit Performance Test, the industry will recalibrate the device with sample points at different load conditions. 4 points used for doing the CEMS Audit Performance Test can be used for the calibration purpose. See Appendix A2.3 Calculation of the CEMS Audit Performance Test for the details of the calculations Activity: Commenting on CEMS Data In case industry is not satisfied with the CEMS data they can comment on the data and comments will be visible to the SPCB and CPCB. Industry should report the comment on the data within 15 days ( or within time limits intimated by the board). The period can be revised later stage based on the actual observations over a period of time. The final decision on the CEMS data will be of SPCB. 6.0 Data Acquisition and Handling System (DAHS) The Data Acquisition and Handling Systems (DAHS) are combinations of software and hardware that are designed to ensure the integrity of emissions data by providing a continuous emissions record for supporting industry operations and regulatory reporting. A control system controls automatic functions such as analyzer drift compensation and issuing diagnostic flags. The data acquisition unit collects CEMS data, converts it into appropriate units, records it, and can perform administrative tasks such as preparing emissions reports for internal and external use. For supporting an emissions trading program, DAHS are frequently networked 29

51 to engineering or agency offices where the data are used for critical regulatory purposes, such as determining compliance by comparing a facility s mass emissions against the number of emissions permits they hold. For the pilot ETS in India, the DAHS will transfer data on a continuous basis to SPCB and CPCB offices. Note that although CEMS are designed to generate and store continuous emissions data, it is not a necessary requirement to have continuous reporting (real-time data transfer to DAHS Server at the regulatory agency) in a load-based ETS regime. For a scheme based on mass emissions caps, a cumulative account of mass emissions is required to reconcile permit holdings after the compliance period, but this can be done by summing up emissions data which is not necessarily continuous. As long as continuous data is being collected and stored on-site by the DAHS, data can technically be reported over larger intervals, subject to rigorous verification (in the U.S. Acid Rain Program, emissions are reported quarterly). However, given the scarce use of CEMS in India, especially for particulate mass load, it is worthwhile to receive data more frequently in order to validate data and reduce errors from missing data, out of range data, and outliers. For this pilot ETS program the DAHS will include the following devices/computers: 1. PM CEMS Device installed at industry 2. Data Acquisition System (DAS) installed at the industry. 3. CPCB Server located at Central Pollution Control Board (CPCB) 4. SPCB Servers located at State Pollution Control Boards (SPCB s) 5. Data Access Points are the Computers where CEMS data can be viewed and analyzed with various features. Each of these machines will have following software systems: 1. PM CEMS Device a. Firmware / software of CEMS vendor 2. DAS a. CEMS vendor software b. ETS Bridge Software 3. CPCB DAHS Server a. DAHS Server Software 4. SPCB DAHS Servers a. DAHS Server software 5. Data Access Points a. Client software for visualization / analysis etc. Mostly browser based The ETS Bridge Software is a standalone application that resides on the DAS in each industry. This software has a standard interface for receiving real-time data from the vendor-designed CEMS Software residing on same machine. The ETS Bridge Software collects real-time data collected by the CEMS Software and sends it to DAHS Server at the concerned SPCB (and CPCB) in a secure and reliable manner. The bridge also stores this data locally for a user-specified period. 6.1 DAHS Architecture The proposed DAHS architecture forms a well-defined network of data collection and transfer which together protect data quality and provide a record of accurate data to support the pilot scheme. In the proposed system, the PM CEMS device sends emissions data to the CEMS Software which is installed on the DAS. Among other parameters, the CEMS device will send raw emissions measurements (uncalibrated 30

52 data), diagnostics parameters such as the status and health of the instrument (called diagnostic flags), flow measurements, and temperature readings. The complete list of parameters is discussed in Section Parameters Details. Upon accepting emissions data from the CEMS device, the CEMS Software immediately converts it into the prescribed format, after which the ETS Bridge Software reads the data, stores it locally, and sends it to the SPCB and CPCB server. It is important to stress that CEMS devices should measure and report uncalibrated data to the DAS. The CEMS Software will then apply the calibration factor and send the calibrated measure to the SPCB server via the ETS bridge. In the event that CEMS devices are not able to send uncalibrated data, the device should input the calibration factor as 1 and be password protected. Figure 1: Architecture PM CEMS Device Any Approved Technology Device PM CEMS Raw Output, PM CEMS Calibrated Output, Diagnostic Flags Data transferred through 4-20 ma, RS232, RS485, Lan, Modbus, Relay (for digitalflags) DAS (Data Acquisition System) CEMS Vendors Software ETS Bridge Software Platform which is supports ETS Bridge Software Data Access Points PM CEMS Data & Analysis via Lan or High Speed Internet Server PM CEMS Data sent by ETS Bridge Via Internet (broadband / dialup / USB Modem) Window, Linux, Mac OS based Windows, Linux based 6.2 DAHS Schematic The figure overleaf shows the data flow and a description of the activities done at various levels 31

53 PM, Flow, Temp. CEMS Device Sends the raw data (PM and flow meter readings) & diagnostic flags to DAS. Data transferred through 4-20 ma, RS232, RS485, Lan, Modbus, Relay (for digital flags) DAS (Data Acquisition System) Data is read by vendor software, averaged for every 1 minute and send in the prescribed format to the ETS Bridge Software residing on DAS. Data is archived by the ETS Bridge Software for the duration of 2 years at DAS. Any data not coming in real time will be flagged as Late by ETS Bridge Software. ETS Bridge Software at DAS validates (basic data validation) the raw data and sends the data to the servers after every minute using binary format using Internet (broadband / dialup / USB Modem) Server Interacts with the all the Bridge Software s at DAS. Asks for a username and password from DAS. Hosts an url which is used to get data from all the DASs. Server gives acknowledgement to the DAS s for the data received and validated. Validates the data received from the DASs. Saves the validated data into a database Analysis of the validated data Technically & process-wise Configuration & Synchronization to be done at SPCB s server Data Access Points Validated CEMS data can be viewed and analyzed with various features Connected to the Servers only using a valid username and password Connected to Server via Lan/Internet Keeps a record of data which has been sent to the SPCB & CPCB Server

54 1) Data Transfer from PM CEMS to the DAS PM CEMS device and Volumetric Flow Meter sends the PM CEMS raw data, flow data and diagnostic flags to the DAS via 4-20mA, RS232, RS485, LAN, Modbus or Wireless. Data from the PM CEMS device should br sent directly to the DAS, and can be concurrently sent to a distributed control system (DCS) of the industry. 2) Data Storage at DAS DAS has two softwares: CEMS Software (vendor designed) and ETS Bridge Software. CEMS Software reads incoming data from the installed CEMS device by using convertors, averages it for a given interval and saves it into a defined folder on the DAS in the prescribed format. The current averaging interval is 1 minute, but can be configurable. Details of data format are in Section File Format. ETS Bridge Software reads emissions data from CEMS Software and sends it to the SPCB server on a continuous basis. It also stores data securely and locally on the DAS. Industry must make a reliable and fast internet connection available on DAS so that ETS Bridge Software can send data to server continuously. DAS platform should be compatible with ETS Bridge Software. (List of platforms will be released). Data is archived for the duration of 2 years on DAS by ETS Bridge Software. Any data not coming in real time will be flagged as Late. 3) Data Transfer from DAS to SPCB Server and CPCB Server ETS Bridge Software sends the data to the SPCB and CPCB Server in the prescribed format indicated in Section File Format. Continuous 1-minute emissions averages are collected by the CEMS Software, and ETS software sends this data every 15 minutes. Data is sent in an encrypted format via https protocol to the url hosted by the SPCB Server and CPCB Server Any data not coming in real time will be flagged as Late. Data is sent using lease line, internet connection or USB modem. ETS Bridge Software will keep a local record of data which has been sent to the SPCB Server and CPCB Server. ETS Bridge Software keeps the status of acknowledgement of packet data received by the SPCB and CPCB Server. In case DAS does not receive an acknowledgement, it resends the data. ETS Bridge Software installed at DAS also sends its unique MAC (Multimedia Access Control) address to the server each time it sends data. This will make sure that the same machine (DAS) is used for sending the data which was registered initially. Before uploading the data, the SPCB and CPCB Server asks for a username and password. 33

55 ETS Bridge Software will send the information accordingly. 4) Server Every time a DAS logs in using the ETS Bridge Software, the SPCB server asks for a username and password unique for that industry/stack. SPCB Server hosts a url used to get data from all the DAS s SPCB Servers give acknowledgement to the ETS Bridge Software for the data received and validated. SPCB Servers also check the MAC addresses of the DAS to check authenticity of the data sender SPCB Server validates the data received from the DAS according to a data validation protocol outlined in a companion document (in progress). SPCB Server saves the validated data in a database. Access Points are connected to the servers via LAN or high speed internet. Configuration (adding/editing CEMS sites) and synchronization to be done at the SPCB server, and by SPCB only. 5) Access Points Data Access Points are the Computers and LCD display screens installed in designated ETS room (called the DAHS Centre) where CEMS data can be viewed and analyzed with various features. Access Points are connected to the Servers (CPCB and SPCB) via LAN or high speed internet. They can be connected to the Servers only using a valid username and password. 6.3 Parameters Specification The list of parameters that can be sent out from a site depends on the instrument used and to an extent on the vendor specific software functionality. For the purpose of the pilot ETS, a standardized set of parameters has been detailed. All CEMS Softwares are required to output data for each parameter, unless the value is not applicable for a certain CEMS device type Parameters Details Parameters are of three types, mainly: a. Configuration data: This data is specific to a stack and instrument and collected at the time of the registration of the CEMS device to the ETS server. b. Calibration data: This data is specific to the calibration of the PM CEMS device. c. Measurement data: This is the real time measured or calculated data transferred to the server on real time basis. 34

56 Type of Data Transferred/Submitted during When will it change Configuration data Submitted by industry at the time of registration of the CEMS device to the ETS server ETS server communicates the Configuration ID of the stack to the industry Calibration data Iso-kinetic sampling details submitted by the industry to the ETS Server ETS Server software calculates calibration factors and informs industry. Measurement data Submitted by the CEMS Software to the ETS Bridge Software on real time basis When PM CEMS device is changed (from a different vendor or different make) When new calibration is done When CEMS Audit is performed Real time data Configuration Data Type of Pollutant (ToP): ToP indicates the type of the pollutant for which the data is transmitted. For Stack PM, ToP = 1. A complete list of codes for various pollutants will be published. Type of Configuration (ToC): code type of technology configuration Code Type of Configuration 0 No data being sent 1 Type 1: PM Mass Flow Based Technology 2 Type 2: PM Mass Concentration Based Technology with Volumetric Flow Meter 3 Type 3: PM Mass Concentration Based Technology without Volumetric Flow Meter Composite ID (CompID): The Comp ID pinpoints a particular stack, in a particular industry, in a particular region. CompID is a fixed-width string containing 14 characters: XXXXXXXXXXXXXX Position Count Meaning State code District code digit Industry Code Specific stack number in particular industry 13 1 Type of Pollutant 14 1 Instrument No. 35

57 Industry name code and stack number to be configured on server Instrument number is added to distinguish between 2 instruments installed at the same stack Type of Pollutant is added to distinguish the type of pollutant for which the file is generated For instance, an industry called Sri Ramesh Chemicals in Jalna has 5 digit unique ID with one PM CEMS of each of the three stacks would have following Composite ID s, one for each stack MHJLN MHJLN MHJLN at the last of each Composite ID refers to the instrument number. If one more PM CEMS instrument is installed at Stack no. 1, its composite ID will be MHJLN SPCB s will release the 5 digit unique ID for each industry. Stack dimensions: internal dimensions of the stack where the PM CEMS is installed (length, breadth or diameter). Cross-sectional area of the stack can be calculated using these parameters Calibration data This data is specific to the calibration of the PM CEMS device iso-kinetic sampling data: This refers to the data of the iso-kinetic sampling done by the lab. Average Pressure at the Stack during sampling (Pres_Smpl): the average of the pressure reading at the stack during various isokinetic sampling points. The unit of this parameter should be kpa. This is required to normalize the PM Calibrated data with pressure if pressure transmitter is installed. Average Temperature at the Stack during sampling (Temp_Smpl): the average of the temperature reading at the stack during various isokinetic sampling measured in degree Celsius. This is required to normalize the PM Calibrated data with temperature if temperature transmitter is installed. Calibration Factor (CF-m): dust parameter m obtained from the calibration curve (y=mx+c) obtained through an isokinetic sampling process. It is generally reported in a numerical format to 3 decimal places. Calibration Factor (CF-c): dust parameter c obtained from the calibration curve (y=mx+c) obtained through an isokinetic sampling process. It is generally reported in a numerical format to 3 decimal places. 36

58 To keep a track of which calibration factors are used, the ETS server software saves all the previous calibration factors and also the start and end time of each set of calibration factors Measurement Data CEMS vendor software sends one set of measurement data as per averaging interval (at present 1 minute) to ETS Bridge Software. All values must be read every 10 seconds or faster and averaged every 1 minute. Below is list of parameters. Date and Time Stamp (DTS): DTS data is mandated to be formatted in such a way that data is reported at the end of every one minute interval. The format of DTS is yyyymmddhhmmss using a 24 hour clock. CEMS vendor software takes the time from the system clock of the DAS. For instance, the DTS for the average of observations taken between the interval 15:29 and 15:30 on the 14 th of December, 2012 would be reported as < >, and subsequent observations would therefore be recorded < > and so on. Pressure at the Stack (Pres): the average of the pressure reading at the stack. The unit of this parameter should be kpa. In case a pressure transistor is not installed, the average of the pressure measured during the iso-kinetic sampling (Pres_Smpl) should be sent. Temperature at the Stack (Temp): the average of the temperature reading at the stack measured in degree Celsius. In case temperature transistor is not installed, the average of the temperature measured during the iso-kinetic sampling (itemp_smpl) should be sent. PM CEMS Raw Uncalibrated Output Average (PM_Uncal): the average PM CEMS device measurement reading. It is the non-calibrated output averaged across the 1-minute interval. PM CEMS Calibrated Average (PM_Cal): the average (across 1 minute) of the Particulate Matter (PM) concentration obtained after calibrating the device (using mx+c equation to convert uncalibrated data to calibrated data and normalizing it, if required). TOC Units Formula 1 Kg/hour = {(CF-m)*(PM_Uncal) + (CF-c)} 2 mg/nm 3 = {(CF-m)*(PM_Uncal) + (CF-c) }*{(273 + Temp)/(273 + Temp_Smpl) *(Pres_Smpl)/(Pres)} 3 mg/nm 3 = {(CF-m)*(PM_Uncal) + (CF-c) }*{(273 + Temp)/(273 + Temp_Smpl)*(Pres_Smpl)/(Pres)} 37

59 Velocity (Velocity): the average of the flow speed in the stack across the 1 minute interval. The unit of this parameter should be m/s. TOC Units Formula 1 NA NA 2 m/sec Direct flow meter reading 3 m/sec The maximum of the velocity during iso-kinetic samplings should be sent. Normalized Flow (N_Flow): the average of the flow speed in the stack across the 1 minute interval. The unit of this parameter should be Nm 3 /s. TOC Units Formula 1 NA NA 2 Nm 3 /sec =Velocity*(Stack Cross-sectional Area)* {298/(273+Temp)}*{(Pres)/(Atmospheric Pressure in kpa)} 3 Nm 3 /sec =Velocity*(Stack Cross-sectional Area)* {298/(273+Temp)}*{(Pres)/(Atmospheric Pressure in kpa)} PM Mass (PM_Mass): the average mass flow through the stack during the 1 minute interval. The unit of this parameter should be kg/hour. The method of calculation is different for different types of configuration. TOC Units Formula 1 Kg/hour =PM_Cal 2 Kg/hour =PM_Cal*N_Flow*(3600/ ) 3 Kg/hour =PM_Cal*N_Flow*(3600/ ) Diagnostic Flags (DF): This is the flag to indicate the health of the PM CEMS device or its availability to measure and send data. Each PM CEMS vendor has to report this and they can 38

60 make these flags a function of the diagnostic features of their device. These are not averaged over 1 minute interval, but values at the end of every 1 minute interval. Diagnostic flags consist of 4 parameters: 1) Device Mode, 2) Power Status, 3) Alarms and 4) Maintenance Alarms Device Mode (DM) Indicates current status of device. Valid values are Normal operation 0 Calibration 1 Maintenance 2 Warming up 3 System Error 4 Error in updating device status 9 Feature not available - 99 Power Status (PS) Power off 0 Power on 1 Error in updating device status 9 Feature not available - 99 Alarm (Alrm) No Alarm 0 Alarm vendor defined values. Possible alarms should be configured in ETS Server for correct interpretation Error in updating device status 9 Feature not available - 99 Maintenance Alarm (M_Alrm) No Alarm 0 Maintenance Alarm vendor defined values. Possible alarms should be configured in ETS Server for correct interpretation Error in updating device status 9 Feature not available 99 39

61 6.3.2 Parameters transferred to ETS Bridge Software The table below shows the parameter as per the type of configuration Parameter Optional / Mandatory Type 1 Type 2 Type 3 CompID Mandatory Pre-assigned Unique ID of a Stack and CEMS instrument Pre-assigned Unique ID of a Stack and CEMS instrument Pre-assigned Unique ID of a Stack and CEMS instrument ToC Mandatory CF-m Mandatory Calibration factor m Calibration factor m Calibration factor m CF-c Mandatory Calibration factor c Calibration factor c Calibration factor c Pres_Smpl Mandatory Average pressure reading during isokinetic sampling Temp_Smpl Mandatory Average temperature reading during isokinetic sampling PM_Uncal Mandatory Raw reading of the PM CEMS Device PM_Cal Mandatory PM Calibrated reading. Units= kg/hour Average pressure reading during isokinetic sampling Average temperature reading during isokinetic sampling Raw reading of the PM CEMS Device PM Calibrated reading. Units=mg/Nm 3 Average pressure reading during isokinetic sampling Average temperature reading during isokinetic sampling Raw reading of the PM CEMS Device PM Calibrated reading. Units=mg/Nm 3 Velocity Optional. Mandatory only for Type 2. Not Applicable Velocity reading from the Flow Meter Maximum Velocity Assigned. velocity max- =max {max. velocity during calibration, max. flow during Calibration/CEMS Audit, ID Fan Output} N_Flow Optional. Mandatory only for Type 2. Not Applicable Normalized Flow Meter Reading Normalzied Maximum Flow Assigned 40

62 PM_Mass Mandatory PM Calibrated reading Units kg/hour. PM_Mass=PM_Cal*N _Flow*(3600/ ) Units kg/hour. PM_Mass=PM_Cal*N_F low*(3600/ ) Pres Optional Pressure Reading Pressure Reading Pressure Reading Temp Optional Temperature Reading Temperature Reading Temperature Reading DM Optional Mode of the device Mode of the device Mode of the device PS Optional Power Status Power Status Power Status Alrm Optional Alarms Alarms Alarms M_Alrm Optional Maintenance Alarms Maintenance Alarms Maintenance Alarms 6.4 ETS Bridge Interface The ETS Bridge Software has to collect and send data from the CEMS device to the SPCB and CPCB server. Hence it is imperative that there is a standard interface for the communication between the CEMS Software and the ETS Bridge Software. All CEMS vendors should ensure that their software provides the required data as per the ETS Bridge interface Interface Overview The current version of the ETS Bridge has a File based Interface. It supports only communication from the CEMS Software to the ETS Bridge Software. This means that a file in the prescribed format is generated by the CEMS Software and read by the ETS Bridge Software. This is to ensure that all vendors can easily incorporate any required changes in their software to comply with this interface Interface Details Interface Configuration The following items need to be configured for the interface and both CEMS vendor software and ETS Bridge Software must refer to this file. This file will be stored in the same folder as the ETS Bridge and will be named ETSBridge.ini. 1. Folder where data files will be generated by CEMS vendor software 2. Archive folder where data files will be moved after a file is completely processed by ETS Bridge 3. Averaging interval in seconds (1 minute for now) 41

63 The format of this file will be like an.ini file with a single section called [Config] and name=value pairs under it : [Config] DataFolder=<data folder path> ArchiveFolder=<archive folder path> AvgInterval=<averaging interval in seconds> Example of this file : [Config] DataFolder=C:\\ETS\SPM\data ArchiveFolder=C:\\ETS\SPM\archive AvgInterval= Data File Naming and Creation A separate file will be created for each date for each CEMS device connected to the DAS. The file will be stored in the folder specified in interface configuration file. The file will be named as: <Creation date>_<compid given in configuration data section>.csv <yyyymmdd>_<compid>.csv For example, the file for stack 001 at Sri Ramesh Chemicals in Jalna (having unique code 21908) created on 14 th Dec 2012 will be named as : _ MHJLN csv Whenever the CEMS Software runs, it will look for the file with the current date for each instrument. If found, it will open and append new data to this file, otherwise it will create a new file. It will also create a new file for each instrument when the date changes. The CEMS Software should always open the file in such a way that ETS Bridge Software is able to open same file simultaneously and read data from it File Format Each file will have a header row, number of data rows (ideally per minute) and a footer row Header Format The 1 st row of the file will always be a header row. Its format should be <ToP,ToC,CompID> 42

64 For example, a sample header row for PM CEMS device installed at a stack would look like 1,1, MHJLN The 2 nd row of the file will contain the calibration data. <CF-m,CF-c,Pres_Smpl, Temp_Smpl> For example, 2 nd row would look like 5.1,0.024, ,310.1 Data Format Subsequent rows in the file will contain data and each row will have following format <DTS,PM_Uncal,PM_Cal,Velocity,N_Flow,PM_Mass,Pres,Temp,DM,PS,Alrm,M_Alrm> Comma is used as a delimiter between parameters No spaces should be used at any point in the file If a parameter is not measured / applicable for the given instrument, write NA in place of value If there is an error in the instrument / DAS when reading a parameter, write err in place of value Each row must end with a CRLF (carriage return/line feed) character Some examples of valid and invalid data rows ,10.1,55.6,NA,NA,55.6,99.21,150.2,0,1,0,0< Valid CRLF> ,9.0,50.1,NA,NA,50.1,97.122,err,0,1,0,0<C RLF> Valid Error in reading temperature ,10.1,55.6,NA,,55.6, 99.21,150.2,0,1,0,0<CRLF> Invalid - Space after comma - Empty instead of NA ,10.1,55.6,NA,NA,55.6,99.21,150.2,0,1,0, ,5,5.1,10.1,55.6,NA,NA,55.6,99.21,150.2,0,1, Invalid - No CRLF after 1 st row and 0,0 hence 2 nd row (red) in continuation with 1 st row ,5,5.1,10.1,55.6,NA,NA,55.6,99.21,150.2,2, 1,0,0<CRLF> Invalid Device in Maintenance Mode ,5,5.1,10.1,55.6,NA,NA,55.6,99.21,150.2,0, 1,0,2<CRLF> Valid Maintenance Alarms from the device Footer Format Footer row indicates that CEMS vendor software has completed writing this file and the next data set will be written in a new file. This is always the last row in the file. It contains a single word eof 43

65 6.4.3 Data Exchange Process 1. Whenever the CEMS Software starts, it will look for the file with the current date for each instrument connected to it. If found, it will open this file, otherwise it will create a new file. It will also create a new file for each instrument when the date changes. 2. When the ETS Bridge Software starts, it will load information about the number and type of CEMS instruments connected to the DAS via the CEMS vendor software. This information will be obtained from the server or from a local file. 3. Then ETS Bridge Software will look for files from each instrument and open these files for reading. 4. It will read all new rows already existing in the file since last reading. 5. Then it will wait for new data rows to arrive in the file. As soon as a new row is appended to the ETS Bridge Software will read that row. 6. ETS Bridge Software will add one more date and time stamp at the beginning of each data row. This time stamp specifies when ETS Bridge Software read the row. If difference between the ETS Bridge Software time stamp and CEMS Software time stamp is more than a threshold, the server will add a late flag for this row. This indicates that the data was not received by the ETS Bridge Software in real time. 7. ETS Bridge Software will send the data to the SPCB server every 15 minutes. 8. ETS Bridge Software will also store all data locally in a different folder in encrypted format. 9. ETS Bridge Software will also generate an error file logging all errors encountered. 10. When the date changes, the CEMS Software will write a footer row in the previous day s file and close that file. After this, the CEMS Software cannot write any new data in this file. 11. After encountering a footer row in a file, the ETS Bridge Software will close that file and move it to an archive folder specified in the configuration file. If the CEMS Software cannot read data in real time from an instrument due to whatever reason, it can read this data later and write it to the appropriate files before a footer row is written. In this case, all this data will be treated as late by the server. However, this must be done before the CEMS Software starts writing real time data to the current file. Thus, the CEMS Software cannot keep an older file open while writing data in a newer file. 6.6 System Integration Test for CEMS Software Why System Integration Test? The ETS Bridge supports a file-based interface for communication with CEMS Software at the industry. Each CEMS vendor who wishes to participate in the pilot ETS project must incorporate this interface in their CEMS software package and pass the System Integration Test (i.e. 44

66 compatibility with ETS Bridge Software. It is necessary to carry out this test for the following reasons: 1. It will ensure parity on data transfer among different vendors participating in the project. 2. It will ensure that CEMS software follows data transfer guidelines established for ETS. The software should transfer the required parameters in prescribed format and carry out underlying calculations appropriately. 3. It will establish that timely, uncorrupted and secure data transfer takes place from CEMS software to Central Server via ETS Bridge. Passing the System Integration Test will be the responsibility of the CEMS Vendor Procedure for System Integration Test A web-based portal hosted by the Central Pollution Control Board (CPCB) will be made available to vendors for carrying out the steps required for System Integration Test. Vendor would register on the portal following which a user-id and password would be provided to the vendor to carry out further integration tasks. The portal will have sections for uploading the required data files and documentation. The portal would be capable of carrying out automated checks on conformance of transferred data with data transfer guidelines and generate reports on mismatched data. Vendors could go through the automated reports and rectify the mismatches to proceed with software testing procedure. The procedure for system integration test of CEMS Vendor Software has been divided in two broad steps. Flowchart below mentions the overall procedure: 45

67 Activities Registration will include: 1. Registration Form asking vendor details, available CEMS device models and technologies, present working installations in India, hardware certification (if any) and other details. 2. Details of parameters as per ETS interface units, NA parameters, alarms etc. 3. Offline Test Data files in prescribed format Data file parameters are checked automatically. Steps for Integration Vendor visits System Integration Test Portal for registration Step 1: Registration & Data file conformance test Vendor fills up registration form and uploads offline test data files Form details and data files conform to guidelines? No Rectification Steps Vendor is notified on missing/incorre ct information along with an automatically generated data file mismatch report (if any). Vendor takes necessary action and reapplies for registration as need be. Vendor installs ETS Bridge Software on a PC and puts up request for proceeding with Step 2 on System Integration Portal. Vendor Software generates simulated data and transfers it to System Integration Portal via ETS Bridge Software. This step of testing continues for 72 hours. Yes Step 2: CEMS Vendor s Software coupling with ETS Bridge CEMS Vendor proceeds for establishing connection between CEMS Vendor Software and ETS Bridge Data transfer is smooth and conforms to guidelines? Yes No Automated report generated by System Integration Portal sent to the vendor, highlighting the problems. Vendor rectifies the same and goes through Step 2 again. CEMS Vendor s Software passes the System Integration Test 46