Report on Evaluation of Online Monitoring System (OLMS)

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
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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
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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
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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.
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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
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