CENTRAL POLLUTION CONTROL BOARD, Zonal office (South), Nisarga Bhawan, Thimmaiah Road, 7th –D-main, Shivanagar, Bengaluru-560 079 Report on Evaluation of Online Monitoring System (OLMS) Connected with the Stacks in M/S Orient Cements, Devapur, Kasipet Mandal, Telangana 1. Background The 17 category industries which are highly polluting were directed/issued notices by the Central Pollution Control Board (CPCB), State Pollution Control Board (SPCB) and Pollution Control Committees (PPCC) to comply with the directions in implementing on line monitoring system by June, 30, 2015. There was considerable progress in implementing online monitoring system and linking online monitoring system to central servers of CPCB, SPCBs and PPCC. Subsequently, based on the data uploaded in the server of CPCB, a short message service (SMS) automatically generated against the exceedance of the standard limits as configured in the software of central server were communicated to the respective nodal officers of each industry. The response/feedback about the action taken/implementation in controlling the emission with respect to SMS communicated to the industries were not received considerably. Viewing on the huge no. of short messages generated against the standard limits and frequent exceedances, CPCB, Delhi has screened top 4 industries-sector wise which have generated several SMS and in turn directed CPCB, Zonal Office to investigate the reason thereof and to assess the status of operation, maintenance, calibration, documentation and suitability of the online measurement in accordance with CPCB guidelines. Also directed to collect sample through manual method to compare the results obtained through online. In this connection, team of officials Shri.K.Karunagaran STS and Shri.S.Natarajan have been deputed to the industry M/s Orient Cements, Devapur, Kasipet Mandal, Telangana to which 5024 no. of SMS communicated, to investigate the issue on the source emission and to carry out stack monitoring in the stacks which have reported as exceeded several times. 2. Inspection and Verification of Online Monitoring System. 2.1 M/s Orient Cement Industries., Devapur, Telangana As reported, M/s Orient Cement Ltd, a C.K. Birla group company started its operation in 1982 at Devapur in Adilabad District of Telangana State with a capacity of 0.45 Million Tons per 1 Annum and extended to 0.90 Million tons per annum in the year 1990. The plant was upgraded to a capacity of 1.18 Million Tons per Annum in the year 1997. Further the plant was upgraded to 1.75 Million Tons per Annum (Clinkerisation) in May 1999. Line-I is of L&T/FLS, Denmark started in 1982, Line-II is of Cimmco / KHD, Germany started in 1990 and Line-III FLS, KHD. The present installed capacity of the industry is 3500000 TPA of Clinker and 3070000 TPA of OPC and PPC Cement. The process technology is based on dry process suspension Preheater with pre-calcinatory technology. The products of Ordinary Portland Cement (OPC) and Portland Pozzolana cement (PPC) (43 Grade & 53 Grade) under the brand name of Birla-A1 is manufactured and marketed through extensive dealer network in Andhra Pradesh, Telangana, Maharashtra, Chhattisgarh and other states. Industry has obtained a combined order of consent for Air, Water and Hazardous Authorization valid till 30th day of June 2017 issued by Telangana State Pollution Control Board, Telangana. (copy of a consent is enclosed in annexure-1). Industry has installed air pollution control devices like Electro Static Precipitators (ESPs), RABH and Bag Filters as applicable to each process and also an online monitoring system in the stacks. These on line monitoring systems are also connected to the central server of CPCB wherein, an automatic short messages were generated if the level of concentration exceeds beyond the standard limits fixed by pollution control boards. 2.2 Status of SMS Alert Generation and Communication It was informed by CPCB, Delhi that 5024 SMS alert were generated against the exceedance of the standard limits prescribed for Particulate Matter(PM) for the stacks connected with Kiln-1, Cooler-3 and CPP during February Month 2016 and communicated to M/s Orient Cements, Devapur, Kasipet Mandal, Telangana for necessary remedial action. On interacting with the concern official about the SMS communicated to this industry, it was informed that the SMS alert were communicated to Mr.Sharma email: [email protected] (screen shot is enclosed-2) who has left the industry on his superannuation during December 2015 and reported that none of the SMS from the CPCB is received by any of the official presently working. However, industry has provided the details of the nodal officer to whom the SMS generated are to be communicated and for any other EHS related issues. (copy enclosed in annexure-2a) Name of Industry Name of Nodal Officer M/s Orient cements, Mr. K.Ravi Teja Devapur, Telangana. Contact mobile No. +91 7799791247 Email Address [email protected] 2.3 Evaluation of Track Record of Data on Source Emission. Having communicated 5024 SMS alert generated during February 2016, the data of every minute concentration measured in all seven stacks namely Kiln1-3, Cooler 1-3 CPP for the month of February, and March, 2016 were down loaded and analysed statistically. 2 Table 1 depicts the statistical evaluation of “One Minute average concentration” measured during February 2016. Out of 10,27,341 no. of data generated as one-minute average during the month of February 2016, 61,261 no.of data were treated as invalid during which the plant was in shutdown, maintenance and other valid reasons. The total no.of data 9,66,079 were treated as valid data in which the no.of exceedance with respect standard limits (80mg/Nm3 for Kilns and 115 mg/Nm3 for CPP) were found to be 8256 data which amounts to be 3.9%. of the total valid data measured. (Being a minute’s data having many parameters, the volume data is huge so hard copy of the data not enclosed herewith. However soft copy is retained in this office). Table 1 Depicts The Statistical Evaluation of One Minute Average Values Measured in each Stacks During February 2016 Statistics Kiln-1 Kiln-2 Kiln-3 Cooler1 Cooler2 Cooler3 Total No. Of Data Generated 253714 213860 Data Treated as Invalid 8001 Data Treated as Valid No.of data exceeded with in valid data Percentage of Exceedance CPP Total no.of Data 186650 146796 106905 79589 39827 10,27,341 15000 1 21681 15157 1110 312 61,262 245713 198860 186649 125115 91748 78479 39515 9,66,079 5194 2322 114 583 0 43 0 8,256 2.1 1.2 0.1 0.5 0.0 0.1 0.0 3.9 In a similar way, the one-minute average concentrations measured in all the stacks for the month of March 2016 were down loaded and analysed statistically. Table 2 Depicts the statistical evaluation of One Minute Values measured during March 2016. Out of 11,13,052 no. of data generated as one-minute average during the month of March 2016, 37,089 no.of data were treated as invalid during which the plant was in shutdown, maintenance and other valid reasons. The total no.of data 10,75,963 were treated as valid data in which the no.of exceedance with respect standard limits (80mg/Nm3 for Kilns and 115 mg/Nm3 for CPP) were found to be 6107 data which amounts to be 3.04%. of the total valid data measured. (Being a minute’s data having many parameters, the volume data is huge so hard copy of the data not enclosed herewith. However soft copy is retained in this office) Table 2 Depicts The Statistical Evaluation of One Minute Average Values Measured in each Stacks During March 2016 3 Statistics Kiln-1 Total No. Of Data Generated 277943 Data Treated as Invalid Data Treated as Valid Kiln-2 Kiln-3 Cooler1 Cooler2 Cooler3 CPP Total no.of Data 238933 198953 159013 119166 79369 39675 1113052 11380 418 5699 9385 2394 7810 3 37089 266563 238515 193254 149628 116772 71559 39672 1075963 No.of data exceeded with in valid data 2348 3001 247 38 29 349 95 6107 Percentage of Exceedance 0.88 1.26 0.13 0.03 0.02 0.49 0.24 3.04 It was also computed for an hourly average concentration for the month of February, March and up to 6th of April 2016, in which the following findings were found. (Being an hourly data, having huge volume hard copy not printed and not enclosed herewith. However soft copy is retained in this office). Evaluation of Hourly Average Data of Particulate Matter Concentration Measured in the 3 no.of Kilns, 3 nos of Coolers and 1-Captive Power Plant during February –March and till 6th April, 2016 February March April Statistical Computation of Data (29 days) (31days) (6 days) Total Hourly data to be Measured 4176 5208 1008 Data actually measured 3738 5124 1008 Not Measured/invalid/ measurement during maintenance 438 177 226 No.of Data Valid 3621 4952 780 No. of Exceedance Occurred 117 70 25 Total % of data exceeded the standard limit 3.13 1.4 2.5 It is found that the percentage of data generated in seven stacks (3-kilns, 3-coolers and 1CPP) during February is 90%, March 98%, and in April for 6 days 100% out of which the percentage of exceedance (80mg/Nm3 for Kilns and 115 mg/Nm3 for CPP) against the prescribed standard limit are 3.1%, 1.4% and 2.5% during February, March and April 2016 respectively. Most of the exceedance were found to be in kiln -1, because the plant is oldest one referring to other plants. The above statistics, reveals that the SMS generated in the central server is not in line with the standard limits prescribed in respect of each parameters for respective stacks. On viewing the 4 web site of M/s Orient cements Pvt Ltd, it is understood that the standard fixed in the server (copy of snap shot enclosed in annexure-2b) is very low which has caused to trigger several SMS for each stacks. The details of standards limit already fixed in the central server and the standard limit actually to be set in accordance with the consent order No. TSPCB/RCP/ADB/76/CFO&HWM/HO/2014-661 dt 03.01.2015 (copy of consent is enclosed in annexure-1) are reflected in table 3. In this regard, the letter from the industry requesting to amend the standard limits fixed in the central server is also enclosed annexure-2. It is also noted that TSPCB in their consent issued to M/s Orient Cements has specified the standard limits only for particulate matter and not specified for gaseous pollutants. Therefore, an amendment including standard limits for SO2 (600mg/Nm3) and NOX (800mg/Nm3) have to be incorporated in their consent in accordance with the standard limits prescribed by MoEF&CC notification. Table 3 Depicts the deviation of standard limit fixed in the server and in the consent order of TSPCB Sl.No Name Stack of Parameter 1. 2. 3. 4. Cooler-1 Cooler-2 Cooler-3 Kiln-1/RM 5. Kiln-2/RM 6. Kiln-3/RM 7. CPP Std Limit Set in Central Server of CPCB, Mg/Nm3 Standard limit to be set in CPCB Server as per consent order of TSPCB Mg/Nm3 50 50 50 50 ----50 ----50 ----50 ----- 80 80 50 80 ----80 ----50 ----115 ----- Particulate Matter Particulate Matter Particulate Matter Particulate Matter NOx SO2 Particulate Matter NOx SO2 Particulate Matter NOx SO2 Particulate Matter NOx SO2 Standard limit as per MoEF&CC Notification and to be incorporated in the Consent order of TSPCB ------------800 600 ----800 600 ---800 600 ----800 600 3. Source Emission Monitoring by Manual Method. In addition to the statistical analysis of the track record of source emission data generated in each online monitoring system, a manual sampling following an isokinetic sampling procedure for particulate matter(PM) and using flue gas analyser for SO 2, NOx, CO, CO2, O2 were also collected/measured April 06th-07th 2016 from the stacks connected with Kiln-1, Coooler-3, Captive Power Plant(CPP) which have been reported as exceeded against the prescribed standard limits 5 and communicated alert messages to the industry. The analysis results obtained through manual method (copy of the analysis results enclosed in annexure-3) and the results obtained through online measurement are depicted in tabule-4 as below. Table 4 Comparing the results of Manual sampling and Online measurement during the inspection (April 06th-07th 2016) Name of Parameter the stack Duration of Manual Monitoring Results Mg/Nm3 Kiln-1 6th April, 2016 15-17hrs Flue gas Analyser Particulate Matter Sulphur Dioxide Oxides of Nitrogen Cooler Mill- Particulate 3 matter Captive Particulate Power Plant matter (CPP) Sulphur Dioxide Oxides of Nitrogen 7th April, 2016 09-12 hrs 7th April, 2016 16.30-19hrs Flue gas Analyser Online Results Mg/m3 Std Limit as per Consent Mg/Nm3 63.2 35.4 80 8.6 4.0 600 368.5 251.0 800 26.7 41.5 50 80.6 57.0 115 480.5 169.0 600 163.6 87.0 800 The measurement results reveal that the concentration values reflected in the online measurement system is Mg/m3 whereas the results of manual monitoring for particulate matter is computed for Mg/Nm3. The measurement values obtained through online and manual sampling is almost correlative and found to be within the prescribed limit by TSPCB. It is also verified that the industry is carrying out third party manual monitoring and the results of the same in enclosed in annexure-3a which found to be with in the prescribed standard limit. 4. Assessing the suitability of Online Monitoring System. Industry is having total nos of 14 stacks, out of which the online monitoring system is installed in 7 stacks. The details of these stacks and status of online monitoring system are given in table no.5 and verified the suitability of having installed online measuring equipment’s. While monitoring, the suitability of location, porthole and platform facilities were found to be satisfied. Table 5 Details of the stack and status of online measuring system 6 Height at where Duct connected with stack (mts) Height where On Line system mounted (mts) Stack dia (mts) Total Height (mts) Year of installation Discharge Rate with Unit (Nm3/hr) ESP 24.8 65.0 65.0 3.3 85.0 2010 320861 Clinker Cooler 1 ESP 9.0 18.0 18.0 3.0 30.0 2012 169662 Raw Mill & Kiln -2 ESP 11.0 57.0 57.0 3.0 82.0 2010 291800 Clinker Cooler -2 ESP 7.5 17.0 17.0 3.8 32.0 2012 191838 RABH 13.0 79.0 79.0 3.8 153.2 2009 351759 Clinker Cooler -3 ESP 9.7 27.0 27.0 3.5 39.0 2009 185880 Captive Power Plant ESP 11.0 32.0 32.0 3.2 90.0 2009 -- Raw Mill & Kiln -3 Height at Port Hole Provided for manual Sampling (mts) APC Connected Raw Mill & Kiln -1 Process Attached to Also, it has been verified the type of instruments connected with on line monitoring system and details of analysers and its supplier are depicted in table 6 Table 6 Details of the Analyzers, supplied and its model are as bellow Name of Unit Kiln-1 Cooler-1 Coal Mill-1 Kiln -2 Cooler-2 Coal Mill-2 Type of Instrument Opacity Monitor Opacity Monitor Opacity Monitor Opacity Monitor Opacity Monitor Opacity Monitor Model Eqpt. Sl.No. BHA CPM 750 7501291 BHA Group International Ltd TUV BHA CPM 750 7501255 Abha Enviro Care Pvt. Ltd,. TUV Forbes- DCEM Marshall 2100 DCEM 2100 - 1135 Forbes-Marshall TUV BHA CPM 750 750987 BHA Group International Ltd TUV BHA CPM 750 750988 BHA Group International Ltd TUV ForbesCPM 750 Marshall 750989 BHA Group International Ltd TUV Make 5. Calibration 7 Vendor Certified by It is informed that all the online source emission monitoring is under the AMC with respective supplier and supplier is regularly calibrating the analyser. However, industry has not produced any of such kind of documents on calibration claiming that are maintained by the AMC contractor. Also, it observed that there is no proper procedure/method or the reference standards are specified either by the supplier or manufacture as to verify its traceability and sensitivity. In addition, as informed by the office, the duly filled ESS Questionnaire for Cement Industries format (enclosed in annexure-4) and the format for inspection of online emission and effluent monitoring system (enclosed in annexure-5) for the cement sector collected from industry are enclosed herewith. 6. Conclusion The alert SMS generated and communicated by CPCB, was not received by the respective officer of the Industry. The alert SMS generated is based on 15 minutes’ average concentration and based on the standard limits fixed in the central server of CPCB as understood from the official of IT division, CPCB The standard limits fixed in the central server of CPCB is at very low level as compared to the standard limits consented by TSPCB which has caused to trigger several SMS alerts. The statistical analysis from the track record of one-minute average data for particulate matter for the month of February and March-2016 reveals that the percentage of exceedance with respect to the standard limits prescribed by the TSPCB are 3.9%, 3.04% respectively Whereas, the statistical analysis from the track record of hourly average data for the month of February, March and up to 6th of April 2016 reveals that the percentage of exceedance with respect to the standard limits prescribed by the TSPCB are 3.13%, 1.4% and 2.5% respectively. The highest exceedance is observed due to frequent on and off operation of kiln and cooler during February 2016. The results of manual sampling are also correlative with respect to online measurement and meeting the standard limits prescribed by the Telangana State Pollution Control board (TSPCB). It is observed that industry is lacking in carrying out periodic calibration particularly for particulate matter and in having proper protocol for periodic maintenance, calibration, data management, reporting and in maintaining the documents. Also, it observed that there is no proper procedure/method or the reference standards are specified either by the supplier or manufacture as to verify its traceability and sensitivity. The officials are aware of the gaseous calibration and though gaseous calibration is reported as periodically carried out, the documents on the same is missing. This is the need of the hour to interact with all the manufacture/supplier to identify a standard procedure/protocol to calibrate the Particulate matter(PM) analyser traceable to other reference materials. 8 7. Limitations 1. The standard limits prescribed by the SPCB/PPCC in their consent are not uniform for the similar type of industry. 2. The standard limits prescribed are mg/Nm3 whereas, the measurement made by online instrument is mg/m3 in most of the case which become uncertain in comparing both the results. 3. Some of the supplier claims that mg/m3 is being normalized by applying a factor obtained by one-time measurement at the time installation of the analyser which is also not correct since the condition of the flue gas is dependent on the process operation. 4. Some of the supplier claims that the manually measured concentration from the stack is fed as a calibration value and allowed the instrument to run. Manual measurement cannot be treated as calibration value since the concentration varies time to time with variable dependent parameters. 5. Particulate Matter sampling supposed to be done based on the Isokenitic sampling whereas the analyser installed on the stacks are based on light absorption, scattering, scintillation and probe electrification which has limitation in measuring temperature, gas composition, pressure and humidity which are required for calculating the isokinetic sampling. 6. For Zero calibration, time interval for flushing of the sampling path is not properly defined and ensured the zero measurement by the supplier at field condition. 7. In general, span calibration supposed to be done on multipoint calibration (different level of Concentration) whereas, either the supplier/manufacture or the user are silent in this issue. 8. The particulate matter analyzer is fixed at very high altitude, which become a cumbersome exercise in following all the procedure for maintenance, calibration. 9. During maintenance or calibration, a group of officials are need to be involved wherein only few official’s involvement is witnessed since the man power deputed to this activity is very less which leads to doubt in achieving proper calibration. 10. It is important to interact with all the manufacture/supplier or the experts in this field to evaluate a standard procedure/protocol to calibrate the Particulate matter(PM) analyser traceable to other reference materials. 11. It is also required to organize a training to the officials working in the industry in understanding the measurement technology, calibration and the important of the data management and reporting. &&&&&&&&&&&&&&&&&&&&&&&&&&&&&& (K.Karunagaran) 9 File No.Tech/45(B)/Online/ZOB/2015-16 April 15, 2016 To The Member Secretary Central Pollution Control Board Parivesh Bhawan East Arjun Nagar Delhi-110 032 Sub: Reports on Evaluation of Online Monitoring System (OLMS) Connected with the Stacks in M/s Orient Cements Telangana and M/s My Home Industries Pvt Ltd., Mellacheruvu, Nalgonada District Sir With reference to the above and as directed by CPCB, Delhi, a team of officials Shri.K.Karunagaran STS and Shri.S.Natarajan JLA from CPCB, Zonal Office were deputed to the industry M/s Orient Cements, Devapur, Kasipet Mandal, Telangana during 6th, April 2016 – 7th April, 2016 (to which 5024 no. of SMS communicated) and M/s My Home Industries Pvt Ltd., Mellacheruvu, Nalgonada District during 8th April 2016 – 10th April, 2016 (to which 2104 no. of SMS communicated) to investigate the issue on the source emission monitoring system and to carry out stack monitoring in the stacks which have been reported as exceedance several times. The report on the investigation and manual source emission monitoring carried out are submitted herewith for further necessary action pls. Yours faithfully (S. Suresh) Zonal Officer Encls : As above 10
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