01

Background
For real-time pollution monitoring, the Central Pollution Control Board
(CPCB) has mandated installation of Continuous Emission Monitoring
System (CEMS) for stack emissions and Continuous Effluent Quality
Monitoring System (CEQMS) for effluent-quality monitoring in 17
categories of highly polluting industries and common pollution-control
facilities in India. The initiative took off with directions issued by CPCB
in February 2014. Installation of CEQMS was also mandated in February
2014 for grossly polluting industries that dispose of effluents in the Ganga
River and its tributaries. The purpose of implementing the continuous
monitoring programme is to improve environmental compliance and
enforcement by ensuring credible and accurate pollution monitoring and
reporting in Indian industries.

Nearly 4,000 industries needed to instal CEMS and CEQMS. A majority

have already installed and connected with the CPCB and their respective
State Pollution Control Boards (SPCBs) or Pollution Control Committees
(PCCs) for online data transfer and reporting.

Mere installation of equipment and online data transfer to the regulatory

agency doesn’t serve the purpose; the majority of installations have
been noted to be problematic. Owing to the complex technology and cost
involved, complications were high largely in correct CEMS selection,
installation, operation and maintenance (O&M), and data transfer. The
absence of the CEMS guidelines for over three years from the start of
the CEMS initiative made it susceptible to going wrong. Issues related
to CEQMS are fewer as its technologies are less complex and costly than
CEMS’s and, simultaneously, brief Guidelines for Online Continuous
Monitoring Systems for Effluents1 were also made available by November
2014, i.e. within six months after the initiative took off. However, with an
absence of adequate skills, installation and operation issues also appear
with regard to CEQMS.

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With the absence of adequate information and timely guidance, the
industries and regulators failed to ensure proper implementation of the
real-time monitoring initiative. The problematic or incorrect installations
need to be corrected in order to ensure accurate pollution monitoring and
reporting.

The CPCB published Guidelines for Continuous Emission Monitoring

Systems in August 2017,2 after a gap of over three years since the inception
of the CEMS initiative. This gave an opportunity for course correction.
Compliance enforcement is the responsibility of regulators and it is the
need of the hour that the SPCBs and PCCs carry out an inspection of
the CEMS installations in industries, assess and evaluate the need for
corrective measures and strategically plan for corrective actions.

This inspection manual has been prepared with the objective of guiding
regulators in the inspection of CEMS and CEQMS technology selection,
installations, operation and maintenance, data acquisition, and reporting
practices in order to strengthen the compliance enforcement system.
Industry officials can also use this manual to carry out self-assessment
of CEMS and CEQMS implementation in their facilities and initiating
corrective measures accordingly.

1.1 NEED FOR AN INSPECTION MANUAL TO

IMPLEMENT REAL-TIME MONITORING
Inspection is a process of careful and systematic examination. The objective
of an inspection is to examine whether implementation of the continuous
monitoring system3 in a particular facility is correct, and it follows the
standards and other regulatory requirements.

This inspection manual aims to guide pollution-control officials and

environment professionals from industries with regard to proper
inspection of installation of continuous monitors, assessing gaps in
implementation and possible corrective measures. Post-inspection,
regulators can suggest adequate corrective measures to rectify identified
issues. Through inspection, industry personnel can self-assess and take
corrective measures for proper implementation of CEMS and CEQMS.

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The approach of regulators should be proactive, rather than only reactive.
They should be able to guide, train, create awareness and assist industries
in rectifying problems and improve the pollution-control and monitoring
regime. Industry personnel also need to be proactive with regard to
proper implementation of continuous monitoring systems in the facility.

1.2 ABOUT CONTINUOUS MONITORING SYSTEMS

Continuous monitors are tools for monitoring the characteristics of gas
(flue gas and ambient air) and effluent quality in real-time. CEMS is used to
monitor flue gas characteristics such as concentration of particulate matters
(PM), gaseous pollutants (sulphur dioxides, nitrogen oxides, oxygen, carbon
monoxide, hydrogen chloride, hydrogen fluoride, ammonia, mercury etc.),
temperature, moisture, pressure and gas flow etc.

A complete CEMS comprises a particulate matter probe, flue gas

sampling system, sample conditioning system, and a set of analysers or
sensors integrated with hardware and software. The PM sensor directly

Key components of CEMS and CEQMS

• Light source and receiver
• Probe/sensor
Particulate matter
• Optics
CEMS
• Sampler and sample line
• Air blower

• Sampler
• Heated/non-heated sampling line
• Sample conditioning system
Gaseous CEMS • Analyser
• Flue gas temperature monitors
• Flow meter
• Pressure monitor

• Sampler
• Sampling line
• Holding jar
CEQMS
• Probe/sensor
• Video camera
• Flow meter

• Analog to digital converter (if the analyser produces analog data) or LAN/GPRS
communication
Data acquisition • Internet connection
system (DAS) • REST-based API (Representational State Transfer-based Application Programming
Interfaces)
• Server software, server installed at facility, SPCB, PCC and CPCB

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monitors dust in flue gas, the sampling system collects the gas sample,
the conditioning system prepares the sample for optimal analysis in the
analyser, and hardware and software carry tools for data acquisition,
storage and transfer. In the case of ambient air quality, continuous
ambient air quality monitoring system (CAAQMS) is used.

Similarly, CEQMS is used to monitor the quality of water or wastewater

parameters such as pH, biochemical oxygen demand (BOD), chemical
oxygen demand (COD), total dissolved solid (TDS), total suspended solids
(TSS), dissolved oxygen (DO) and flow. As in CEMS, it comprises a sampling
system, and analyser or sensors integrated with hardware and software
systems to collect and handle the data.

Apart from the above mentioned components of CEMS and CEQMS,

inspection will be carried for infrastructure facilities where and how
these units are placed and managed.

Implementation of real time monitoring framework in India includes the

following aspects:
• Selection of suitable quality assured monitoring system
• Correct installation
• Calibration during installation
• Real-time data acquisition and transfer system
• Regular operation and maintenance for quality control during
operation
(See Figure 1: Schematic representation of a typical continuous monitoring
system framework in India)

1.3 LEGAL PROVISIONS

The CPCB has mandated installation of continuous monitors in industries
and common pollution treatment facilities. So far, the initiative has
targeted installation of monitors and acquisition of real-time data to state
and central regulators, not real-time data for compliance checks. There
is no legal provision in the existing environmental legislation to use real-
time monitored data for compliance enforcement.

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