AAETI Anil Agarwal Environment Training Institute SELF- INSPECTION

Transcription

1 Anil Agarwal Environment Training Institute SELF- INSPECTION

2 Inspection Requirement The inspector must keep in mind the objective or purpose of the inspection. He/ She is required to have prior knowledge on CEMS before visiting the facility. Inspector must be aware of the Technology, working principle, suitability, limitations. Correct installation requirement, Data acquisition and transfer system Best practices. Refer: CPCB s guidelines for CEMS and CSE s- CEMS: A technical guidance manual

3 Prior Information on: key components of CEMS Particulate matter CEMS Gaseous CEMS Data Acquisition System (DAS) Light source and receiver, probe/sensor, sampler and sample line, air blower Sampler, heated/non-heated sampling line, sample conditioning system, analyzer, flue gas temperature monitors, flow meter, pressure monitor Analog to digital converter (in case analyser produce analog data), or LAN/GPRS communication, internet connection, REST based API (Representational State Transfer based Application Programming Interfaces), server software, server installed at facility and SPCB and CPCB Inspection should also be carried for infrastructure facilities where and how these components have been placed and managed.

4 Prior Information on: Facility overview The inspector needs to know the following basic background information of the industry/facility before visit: General information of industry- Name, type of industry, location, capacity, production, number of units Plant layout and process flow diagram- focussing on emission and effluent flow and outlets where monitoring needs to be carried Operational process and conditions like raw material, fuel, flue gas characteristics (temperature, pressure, moisture, flow, dust and gaseous pollutants) etc. from each unit. Industry s any future change in production which may affect the suitability and performance of pollution monitoring devices.

5 Prior Information on: compliance CTE, CTO conditions Norms for individual parameters, both in air and water pollution Current consent compliance status Pollution parameters to be monitored continuously or manually Various units and their respective monitoring points where CEMS is required to be installed Historical monitored data (online and offline) from the plant Analysis of manual and real time data along with operating conditions in order to identify any discrepancy in the data and average emission levels Findings of last inspection and any changes after that.

6 Information on: Pollution control and monitoring facilities Individual unit and its operations/processes, APC, stack/duct, pollution monitoring system List of CEMS installations in the facility that are registered at CPCB and SPCBs Types of CEMS installed for respective parameters Location of manual monitoring port hole and CEMS

7 Overview of CEMS installations Name and number of units where CEMS needs to be installed. Unit wise- where CEMS need to be installed Name of the parameters Total number of CEMS required Unit wise- where CEMS already installed Name of the parameters Total number of CEMS required Entire facility: Total number of CEMS installed Entire facility: Total number of CEMS needed be installed Number of CEMS installations not completed Reason of non-compliance regarding CEMS installation requirements?

8 Visual primary observation of CEMS Are all the units operating? Note if CEMS with all working unit are functional or not Note if CEMS in temporarily non-working units are working or not Note if CEMS in shut-down units are working or not. For working CEMS, notice the visual dust emission from stack and compare if the monitored data displayed on the DAS screen For working CEMS, note if the data displayed at analyser display panel and DAS are matching or not? Are any CEMS not in working condition? Note the details. Unit/process, Parameters, reason, timelines of nonworking conditions, Information made to regulators or not Check if non-working CEMS being reflected so at DAS or not. If data is appearing despite CEMS being non-working, it is indication of data tampering.

9 Location of installation: Stack or duct? Is the platform approachable for regular maintenance? Is the platform safe?- Width, Guardrail, Safe ladder etc. CPCB guideline: stack monitoring material and methodology for isokinetic sampling If installed in Stack Stack material, height, diameter (at last disturbance point in upstream and downstream) Height of the point of manual monitoring and CEMS Does it fit in 8D/2D formula? CEMS at-least 500mm below manual monitoring? See if installed monitors don t affect each other. If installed in duct Is it a single duct, or two or more ducts joining? Fits in 8D/2D Duct length (between last disturbances in down/upstream) Shape of duct, Duct diameter/width & height

10 Position of installation What all CEMS are installed? PM CEMS Gaseous CEMS Position of CEMS Are CEMS installed at a position that assures isokinetic sampling? Is manual sampling port installed at same position/plane? If manual sampling port is in stack, enquire what led plant to install CEMS in duct, why not at same platform in stack. If PM CEMS is installed Is the position ensures isokinetic sampling? Position of PM CEMS with reference to manual monitoring port (distance in mm above or below manual port) Gas monitors positions with reference to manual port Are PM and gaseous monitors in same plane?

11 Measurement site and sectionaaeti

12 Mounting location of measuring systems AAETI

13 Maintenance Quality Assurance AAETI Technology suitability Installed PM CEMS technology Suitability of installed PM CEMS technology/measuring range- Stack/duct wise (Refer Technology matrix in CPCB s CEMS guidelines and CSE s CEMS A Technical Guidance Manual ) Is the CEMS certified? If yes, which certification? If not certified, how did the industry ensure the quality? If not certified, is CEMS fit in performance specification as per guidelines? (Refer CPCB guidelines for acceptance of CEMS until Indigenous certification system is placed) Are the monitors given proper protection from weather? Enquire what all consumable parts have been replaced with equipment and at what frequency. Are the equipments or parts rusted? In case of extractive type, is the shelter maintained? Check if AC is working sufficiently? Check the purging air status. Is the instrument operating? In case of tribo, check the probe insertion length and its coating.

14 Data Check AAETI Calibration and drift checks When PM CEMS was first calibrated? When PM CEMS was last calibrated? Who calibrated? When? How many points, loads? Are the calibration records available in DAS? What is the dust factor? Is the dust factor same as during installation? o If not, when changed? Why? Recorded in DAS? Informed to PCB? What is the zero and span drift check frequency? Are the consecutive drifts >10% higher and frequent, recalibration will be needed. As per CPCB, zero drift should be carried everyday at 10:00 a.m. and and span should be carried drift every Friday at fixed time (10:00 a.m.) zero Check the monitored data recorded during calibration period. Does the data reflect calibration? Is the data capture rate of more than 85%? Compare the CEMS data with manual monitoring data- What is the % difference? Does it comply to the guidelines? (If comparison shows very high difference (>10%) for more than five days, as per CPCB, recalibration is needed.

15 Maintenance Quality Assurance AAETI Technology suitability Parameters wise- installed Gaseous CEMS technology and brand o SO2 and NOx, Other gaseous pollutants o Additional parameters- CO2, CO, O2 o Flow meter, Temperature monitor Is remote calibration facility available? Suitability of technology/ measuring range? Is the CEMS certified? If yes, which certification? If not certified, is CEMS fit in performance specification as proposed by CPCB guidelines? (Refer CPCB guidelines for acceptance of CEMS until Indigenous certification system is placed) Do the monitors have proper protection from weather? Enquire what all consumable parts have been replaced with equipment and at what frequency. Are the equipments or parts rusted? In case of extractive, is the shelter properly maintained? Check if AC is working sufficiently? Check the purging air status. Is it working?

16 Data Check Calibration and drift checks AAETI Gas conditioning system Gas conditioning system installed? Understand the process. Are there complete heated lines from probe till analyser? If sampling line feels hot? Any visible non-heated portion? If condensate trap is working properly (to avoid flooding ) Any water droplet, or blue depositions in sampling line? Are Nafion tubes installed in sampling lines? If sampling line moving downward from probe to analyser. When Gaseous CEMS was first calibrated? Check if calibration gas cylinders are valid, not expired When Gaseous CEMS was last calibrated? Who calibrated? Date, time and frequency of calibration When was last remote calibration carried? Are the calibration records available in DAS? Zero and span drift check frequency? Consecutive drifts >10%, frequent- recalibration needed. What is the average % zero and span drift? As per CPCB, zero drift everyday (10 a.m); zero and span Friday (10 a.m.) Similar to PM CEMS

17 Thank you Sanjeev K. Kanchan Programme Manager- Environment Governance (Industry) Centre for Science and Environment, 41, Tughlakabad Institutional Area, New Delhi Tel: , Extn Mobile: Fax: