AAETIAnil Agarwal Environment

Training Institute

SELF- INSPECTION

The inspector must keep in mind the objective or purposeof the inspection. He/ She is required to have priorknowledge 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 andCSE’s- CEMS: A technical guidance manual

Inspection RequirementA

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Particulate matter CEMS

Light source and receiver, probe/sensor, sampler and sample line, air blower

Gaseous CEMS

Sampler, heated/non-heated sampling line, sample conditioning system, analyzer, flue gas temperature monitors, flow meter, pressure monitor

Data Acquisition System (DAS)

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

Prior Information on: key components of CEMS

Inspection should also be carried for infrastructure facilities where andhow these components have been placed and managed.

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The inspector needs to know the following basicbackground information of the industry/facility beforevisit:

• General information of industry- Name, type of industry,location, capacity, production, number of units

• Plant layout and process flow diagram- focussing onemission and effluent flow and outlets where monitoringneeds to be carried

• Operational process and conditions like raw material,fuel, flue gas characteristics (temperature, pressure,moisture, flow, dust and gaseous pollutants) etc. fromeach unit.

• Industry’s any future change in production which mayaffect the suitability and performance of pollutionmonitoring devices.

Prior Information on: Facility overviewA

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• 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 discrepancyin the data and average emission levels

• Findings of last inspection and any changes after that.

Prior Information on: complianceA

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• 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

Information on: Pollution control andmonitoring facilities

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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 requiredUnit 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?

Overview of CEMS installationsA

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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 stackand compare if the monitored data displayed on the DASscreenFor working CEMS, note if the data displayed at analyserdisplay panel and DAS are matching or not?Are any CEMS not in working condition? Note the details. Unit/process, Parameters, reason, timelines of non-

working conditions, Information made to regulators or notCheck 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.

Visual primary observation of CEMSA

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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 isokineticsampling http://www.cpcb.nic.in/newitems/15.pdf

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

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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?

Position of installationA

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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”)

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ce 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)

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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.

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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? Informedto 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 zeroand span should be carried drift every Friday at fixed time (10:00 a.m.)

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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, asper CPCB, recalibration is needed.

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Parameters wise- installed Gaseous CEMS technology and brand o SO2 and NOx, Other gaseous pollutantso Additional parameters- CO2, CO, O2o Flow meter, Temperature monitor

Is remote calibration facility available? Suitability of technology/ measuring range ?

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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)

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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?

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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.

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When Gaseous CEMS was first calibrated?Check if calibration gas cylinders are valid, not expiredWhen 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.)

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Thank you

Sanjeev K. Kanchan Programme Manager- Environment Governance (Industry)

Centre for Science and Environment , 41, Tughlakabad Institutional Area, New Delhi – 110062

Tel: 011-40616000, Extn.- 266 Mobile: +91-0-8800855090 Fax: 011-29955879www.cseindia.org

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