Accelerating Emission Control at Coal Fired Power - 230730 - 085833

JULY 2023
ACCELERATING EMISSION
CONTROL AT COAL-FIRED
POWER PLANTS IN INDIA
DR LESLEY SLOSS – ICSC
SANJEEV K KANCHAN – CONSULTANT
DR WOJCIECH JOZEWICZ – AEA, USA
A C C E L E R AT I N G
E M I S S I O N C O N T R O L AT
C O A L -F I R E D P O W E R P L A N T S
IN INDIA
INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

EPSILON HOUSE
THE SQUARE
GLOUCESTER BUSINESS PARK
GLOUCESTER
GL3 4AD
UNITED KINGDOM
+44[0]20 3905 3870
WWW.SUSTAINABLE-CARBON.ORG
AU TH O R S DR L ES LEY S LO S S
S AN JEE V K K AN CH A N
DR WO J C IEC H JO ZE W IC Z
© IN TE R N A T IO N A L CE N TR E FO R
S US T A IN AB LE C AR B O N
PUB L IC A T IO N DA TE JU L Y 2 023
ACK NO W LE D GE M E N T S
The ICSC acknowledges the contribution of Paul Baruya and Malgorzarta Wiatros-Motyka in the
preparation of this report.

ACCELERATING EMISSION CONTROL AT COAL -FIRED POWER PLANTS IN INDIA
3
PREFACE
This report has been produced by the International Centre for Sustainable Carbon (ICSC) and is based on
a survey and analysis of published literature and information gathered in discussions with interested
organisations and individuals. Their assistance is gratefully acknowledged. It should be understood that the
views expressed in this report are our own and are not necessarily shared by those who supplied the
information, nor by our member organisations.
The International Centre for Sustainable Carbon was established in 1975 and has contracting parties and
sponsors from Australia, China, Italy, Japan, South Africa.
The overall objective of the International Centre for Sustainable Carbon is to continue to provide our
members, the International Energy Agency (IEA) Working Party on Fossil Energy and other interested
parties with definitive and policy-relevant independent information on how various carbon-based energy
sources can continue to be part of a sustainable energy mix worldwide. The energy sources include but
are not limited to coal, biomass, and organic waste materials. Our work is aligned with the UN Sustainable
Development Goals (SDGs), which include the need to address the climate targets as set out by the United
Nations Framework Convention on Climate Change. We consider all aspects of solid carbon production,
transport, processing, and utilisation, within the rationale for balancing security of supply, affordability,
and environmental issues. These include efficiency improvements, lowering greenhouse and
non-greenhouse gas emissions, reducing water stress, financial resourcing, market issues, technology
development and deployment, ensuring poverty alleviation through universal access to electricity,
sustainability, and social licence to operate. Our operating framework is designed to identify and publicise
the best practice in every aspect of the carbon production and utilisation chain, so helping to significantly
reduce any unwanted impacts on health, the environment and climate, to ensure the well-being of
societies worldwide.
The International Centre for Sustainable Carbon is a Technology Collaboration Programme organised
under the auspices of the International Energy Agency (IEA) but is functionally and legally autonomous.
Views, findings, and publications of the International Centre for Sustainable Carbon do not necessarily
represent the views or policies of the IEA Secretariat or its member countries.
Neither the International Centre for Sustainable Carbon nor any of its employees nor any supporting
country or organisation, nor any employee or contractor of the International Centre for Sustainable
Carbon, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for the
accuracy, completeness or usefulness of any information, apparatus, product, or process disclosed or
represents that its use would not infringe privately owned rights.
4
BACKGROUND
This technical report represents the results from a piece of work which forms part of a significant
project undertaken by the ICSC on behalf of the US Department of State, Agreement Number:
SLMAQM19CA238: ‘Capacity building in Southeast Asia to reduce mercury and other pollutant emissions
from the coal combustion sector’.
The project comprises two major lines of effort to reduce emissions from the coal-fired power sector:
one in Indonesia focusing on mercury (Hg) emissions; and the second in India which addresses
additional pollutants (SO2, NOx and particulates) as well as mercury.
The project in India is focused on knowledge sharing and capacity building, in 3 pillars of work:
• Pillar 1 – emissions monitoring

• Pillar 2 – emission reduction, and ash management
• Pillar 3 – flexibility of plant operation
This report presents work from Pillar 2 – the evaluation of the status of emission control at coal-fired
power plants in India. The conclusions of this report will inform the development of training and
capacity building to be delivered within India.
More detail on this US Department of State project can be found on the ICSC website.

5
ABSTRACT
The coal-fired power sector is one of India’s most polluting industrial sectors – coal-fired power plants
contributed 60% of the total particulate matter (PM), 45% of the total SO2, 30% of the total NOx, and
more than 80% of the total mercury emissions from all industrial sectors in the country in 2020. In
response to ongoing environmental concerns, the Indian government has set new emission limits for
PM, SO2, NOx and mercury from coal plants. However, this legislation has been hindered by delays
and derogations which hinge on the argument that compliance is either too technically challenging for
Indian coals or too expensive to implement.
This report discusses the challenges faced by India and the reasons why compliance is slow.
Technology options appropriate for India are only briefly summarised. Economics, logistics and
political force in India are complex. However, in terms of health effects and GDP within India,
compliance with the new emission limits is significantly more cost-effective than non-compliance. It
is therefore vital that all stakeholders work together to facilitate compliance in the most cost-effective
way. This report is intended to assist stakeholders in the implementation of policies in India. Once
informed about the best solutions, both policy- and technology-wise, stakeholders can then conduct
true cost-benefit analyses and best describe how their needs create the market for goods and services
in India.

6
ACRONYMS AND ABBREVIATIONS
BCCL Bharat Coking Coal Ltd, India
Capex capital expenditure
CCL Central Coalfields Ltd, India
CEA Central Electricity Authority, India
CEM continuous emission monitor(s)
CIA carbon in ash
CFB circulating fluidised bed
CFD computational fluid dynamics
CIL Coal India Ltd
CPA critically polluted area
CPCB Central Pollution Control Board, India
CSE Centre for Science and Environment, India
DISCOM energy distribution company
DSI dry sorbent injections
ECL Eastern Coalfields Ltd, India
EEC Excellence Enhancement Centre, CEA, India
EPCA Environmental Pollution Prevention and Control Authority, India
EPRI Electric Power Research Institute, USA
ESP electrostatic precipitator
FF fabric filter=baghouse
FGD flue gas desulphurisation
FGR flue gases recirculation
FR fuel ratio
GDP gross domestic product
GENCOM energy generation company
HEI Health Effects Institute, India
I3E Institute for Initiation for Impact Evaluation
ICSC International Centre for Sustainable Carbon
IEA International Energy Agency
L/G liquid-to-gas ratio (in a wet FGD scrubber)
LNB low NOx burner
LOI loss on ignition
MCL Mahanadi Coalfields Ltd, India
MEEP moving electrode electrostatic precipitator
MOEFCC Ministry of Environment, Forest, and Climate Change, India
MOP Ministry of Power, India
NAQMP National Air Quality Monitoring Programme, India
NCL Northern Coalfields Ltd, India
NCR National Capital Region
NCAP National Clean Air Programme, India

7
NGT National Green Tribunal, India
OFA overfire air
Opex operational expenditure
PCB Pollution Control Board
RAP Regulatory Assistance Project, India
ROFA rotated overfire air
SCR selective catalytic reduction
SDA spray dryer absorber
SECL Southern Eastern Coalfields Ltd, India
SNCR selective non-catalytic reduction
SOFA separated overfire air
SPCB State Pollution Control Board
SWFGD seawater FGD
TERI The Energy and Resources Institute, India
UN United Nations
UNEP United Nations Environment Programme
USDOS United States Department of State
USEPA United States Environmental Protection Agency
WCL Western Coalfields Ltd, India
Note: all monetary values are in United States dollars ($) unless otherwise stated.

8
UNITS
acfm actual cubic feet per minute
GW gigawatt
GW/h gigawatt per hour
INR Indian rupee
km kilometre
kW kilowatt
kW/h kilowatt per hour
mg milligramme
mg/m 3
mg/m3 milligramme per cubic metre
mg/Nm3 milligramme per normal cubic metre
Mt million metric tonnes
MW megawatt
PM particulate matter
PM2.5 particulate matter below 2.5 µm in diameter
PM10 particulate matter below 10 µm in diameter
ppm parts per million (concentration)
ppmw parts per million by weight
t metric tonne
ton 0.907 tonne
tons/h tons per hour
TWh terawatt-hour
µm micrometre (10-6 metre)
CHEMICALS
ABS ammonium bisulphate
NOx oxides of nitrogen
SO2 sulphur dioxide
SO3 sulphur trioxide

9
CONTENTS
P R E FA CE 4
B A C K G R OU N D 5
A B ST R ACT 6
A C R O N Y M S A N D A B BR E V IAT I O NS 7
C O N TE NT S 10
L I ST OF F I GU RE S 11
L I ST OF T A BL ES 12
1 I N TR O D UCT I O N 13
2 E M I SS I O N ST A N DA R DS I N I N DI A 16
2.1 Emission limits 16
2.2 Amendments to the emission limits 17
2.3 Comments 20
3 P A R TIC UL AT E C O NT RO L 22
3.1 Technology options 22
3.2 Status of PM capture and opportunities for improvement 23
3.3 Comments 26
4 N O x C O NT R O L 28
4.2 Selection of NOx control 30
4.3 NOx control Installation status in India 32
4.4 Comments 33
5 S O 2 C O NT R O L 35
5.2 Selecting FGD systems in India 37
5.3 Status of SO2 control in India 37
5.4 Costs versus benefits 44
5.5 Comments 45
6 M E R CU R Y C O N T R O L 47
6.1 Co-benefit mercury reduction 47
6.2 Potential for mercury reduction in India 50
6.3 Mercury-specific control options for India 54
6.4 Multipollutant control options for India 55
6.5 Conclusions 56
7 O N G O I N G A N D E M E RG I N G C HA LL E NG ES 58
7.1 Challenges to financially viable plant operation 58
7.2 Challenges with enforcing compliance 59
7.3 New challenges – biomass cofiring and plant flexing 61
7.4 Comments 61
8 C O N CL US I O N A N D REC O M M E N D ATI O N S 63
9 R E FE R EN CE S 64

10
LIST OF FIGURES
Figure 1 India’s air pollution and CO2 emissions by sector in the IEA State Policies Scenario, 215,
219, 2040 13
Figure 2 History of delays and derogations 19
Figure 3 Compliance status of category C plant 20
Figure 4 PM control by unit size on the Indian coal fleet 22
Figure 5 Increasing ESP size and tightening emission limits over time 23
Figure 6 Implementation progress of PM control in India 25
Figure 7 NOx control implementation progress according to CSE Coal Power Watch as
of August 2022 32
Figure 8 Status of SO2 compliance technologies in India, 2000-24 39
Figure 9 Definition of FGD installation in India 40
Figure 10 FGD status for retrofits and new plants, 2021 40
Figure 11 Comparison of CSE estimates with estimates from this study 41
Figure 12 FGD status by state in 2021, MW 42
Figure 13 Mercury co-benefit flow chart 49
Figure 14 Emissions of mercury from a 500 MW unit with ESP only 52
Figure 15 Mercury emissions from a 500 MW unit with ACI 55

11
LIST OF TABLES
Table 1 Current emission standards for coal-fired power plants in India 16
Table 2 Ranking of plants for compliance deadlines 18
Table 3 Penalties for non-compliant power plants, rupees/kWh 18
Table 4 Comparison of cost and benefits of using different NOx controls 30
Table 5 Comparison of DeNOx options 31
Table 6 Comparison of FGD systems 37
Table 7 ‘Critical’ list of plants requiring FGD in India 43
Table 8 Relative cost of mercury removal 50
Table 9 ‘Average’ coal properties for the co-benefit analyses 51
Table 10 Potential mercury reduction at Indian plants, estimated with the iPOG 53

12
INTRODUCTION
1 INTRODUCTION
India relies on coal to deliver 80% of the country’s energy demand (IEA, 2021). The installed
electricity capacity was 384 GW (gigawatt) in 2021, of which 234 GW was coal. A further 36 GW of
coal capacity is expected to be online by 2025 (MOP, 2021). Coal-fired power plants are an integral
part of the Indian power grid and will remain so for some time to come, even as the country moves
towards higher capacity and output from renewable energy.
Without state-of-the-art control systems on most plants, emissions of pollutants from the Indian coal
fleet remain high. Figure 1 shows the most recent estimate from the International Energy Agency
(IEA) of sectoral emissions of SO2, NOx and PM2.5 (fine particulate matter below 2.5 µm in diameter)
(IEA, 2021). Emissions from the power sector in 2015 and 2019, in light blue, are the largest source of
SO2 emissions and the second largest source of NOx emissions. Emissions from industry (in light and
dark purple), which include coal use in captive power plants and cement kilns, are also significant.
Figure 1 India’s air pollution and CO2 emissions by sector in the IEA State Policies Scenario,
215, 219, 2040 (IEA, 2021)
The emission estimate values for 2040 in Figure 1 are based on the IEA’s Stated Policies Scenario
(STEPS) which assumes the successful implementation of current national emission reduction plans
and strategies. According to the IEA model, if India implements the current emission standards for
pollutants at coal-fired power plants, then emissions of SO2 and NOx will be reduced significantly –
coal combustion would no longer be the main source of these emissions. This suggests that India has
the political will to reduce emissions from the coal combustion sector. However, as this report will
show, there continue to be significant delays in the implementation of legislation in India which could
result in the prolongation of detrimental effects.

13
INTRODUCTION
A report from the Health Effects Institute (HEI, 2018) in India appears to disagree with the IEA
projection, suggesting that, even assuming compliance with the new emission standards, emissions
from coal-fired power plants will still almost double between 2015 and 2050 and that only an
‘aspirational’ scenario, where emissions are targeted aggressively and India moves away from coal to
alternative fuel sources, will reduce emissions from the sector. Regardless, the application of emission
limits and moves to reduce emissions across the sector will result in the reduction of future
environmental challenges and, although compliance with the emission standards will be expensive,
these costs would be more than offset by the benefits to the Indian population.
A STUDY PUBLISHED IN THE LANCET CONCLUDED THAT

OVER 17% OF THE TOTAL DEATHS IN INDIA IN 2019 WERE
DUE TO POLLUTION AND THAT 1.3 6% OF THE
COUNTRY’S GDP WAS LOST AS A RESULT (PANDAY AND
OTHERS, 2021)
Srinivasan and others (2018) suggest that implementing the new emission standards could reduce the
projected emissions of SO2 by 95%, NOx by 87% and PM by 83% by 2030. Non-compliance with the
emission standards could contribute to 300,000–320,000 premature deaths between 2019 and 2030,
as well as 50 million hospital admissions for respiratory conditions (HEI, 2018). Without compliance
with the new emission standards, the associated costs of deaths and illness from air pollutants would
exceed US$11 billion between 2015 and 2030. In addition to the costs of deaths and illness to the
health system, costs are also associated with less extreme health issues, such as 126 million workday
losses. If the new emission norms were met by 2025, the monetised health benefits are estimated at
the equivalent of INR 9,62,222 crore (over US$129 billion). In the same HEI study, the cost of
compliance with the new Indian emission limits on coal-fired power plants was estimated at 2,50,000
billion crores (US$33 billion) by 2030.
THE COST OF I NVESTMENT IN POLLUTION CONTROL ON

COAL PLANTS IN INDIA IS ONLY 25% OF THE PROJECTED
FINANCIAL BENEFIT TO INDIA AND THUS MONEY WELL
SPENT
The IEA Energy Outlook report for India (IEA, 2021) emphasised the challenge of predicting future
energy scenarios in India due to a wide range of factors such as post-Covid-19 pandemic economic
recovery, bold renewable energy goals, increased demand for flexible power to compensate for a lack
of energy storage, and rapidly improving standards of living (increasing the per capita emissions). The

14
INTRODUCTION
future of energy in India is continuing to evolve in a changing environment. However, the role of the
existing coal fleet is likely to remain relatively stable until reliable and affordable alternatives come
online. This report will not focus on the potential change in the Indian energy portfolio mix going
forward but rather on the existing coal fleet. Although some older and less efficient plants may be
upgraded or replaced entirely, the majority of the existing fleet could continue to operate for several
decades. It is this existing fleet which is the focus of the new Indian emission limits for SO2, NOx and
mercury. The existing fleet is also the focus of the emerging Indian strategy for compliance under the
UN (United Nations) Minamata Convention on Mercury. Many plants in the existing fleet will be
required to install control technologies to comply with these new emission standards. Whilst
well-established control technologies exist and have been successful internationally, Indian coals can
be more challenging. India uses relatively low-quality coal containing 20–40% ash, 0.4–0.6%% sulphur
and 0.01–1.5 ppm of mercury (BEE, 2021). These coals are different from those in regions such as
Europe and the USA where emission reduction techniques have been refined. It is this difference in
coal characteristics which forms much of the Indian industry’s argument against the new emission
limits in India. It is therefore critical that appropriate pollution control systems are identified and
installed specifically to solve Indian problems and that they are operated and maintained correctly.
The current status of emission legislation and control for the coal-fired power fleet in India has been
reviewed in a previous report from the International Centre for Sustainable Carbon (ICSC) (Adams
and others, 2021). Legislation and compliance are also addressed in a report produced by the ICSC for
the US Department of State (USDOS) which focuses on emission monitoring (Sloss and others, 2021).
This current report addresses the challenges faced by existing Indian coal-fired power plants with
respect to compliance with the new emission limits set by the Indian government. It uses published
data to indicate that, despite the difference in coal characteristics, Indian coal plants can meet these
limits. Chapter 2 summarises the Indian emission standards, reviewing why there are still issues with
the application of these limits in practice. Chapters 3, 4, 5 and 6 each briefly review the status of
compliance for PM, SO2, NOx and mercury from coal-fired power plants, focusing specifically on
approaches that are most appropriate for Indian coals. However, the emphasis of these chapters is the
identification of the challenges and bottlenecks for compliance. Chapter 7 looks at two important
changes to basic plant operation which are current in India now – cofiring of biomass and increased
plant flexing. Both of these changes could affect the efficacy of standard control technologies and
significantly affect emissions in the future. However, Indian stakeholders will ultimately formulate
markets for their technology needs based on the policy and legislation in place.

15
EMISSION STANDARDS IN INDIA
2 EMISSION STANDARDS IN INDIA

As in most countries, the Indian regulations for air quality have evolved and originated from several
different agencies and ministries. However, the situation in India is more complex than in most other
countries and it is important to assess how the regulations have developed to understand why
challenges with implementation remain. Perhaps most importantly, Indian legislation appears to be
more open to debate and dispute from the power sector than in many other countries. This perceived
lack of strength from the ministries and their willingness to concede when challenged has contributed
to the current stagnation in policy implementation. However, the economics and technical scale of
achieving compliance across India are also contributing factors to ongoing delays.
2.1 EMISSION LIMITS

In December 2015, the MOEFCC introduced strict environmental standards under the Environment
Protection Act of 1986. These 2015 standards introduced by the MOEFCC included SO2, NOx, and
mercury emission limits for the first time, as shown in Table 1.
TABLE 1 CURRENT EMISSION STANDARDS FOR COAL-FIRED POWER PLANTS IN INDIA (ADAMS AND OTHERS,
2021)
PM, SO2, NOx, Mercury,

mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3
Old standard 150–350 None None None
2015 Norms (limits)
Units installed before 31 December 2003 100 600 (<500 MW) 600 0.03
200 (≥500 MW)
Units installed between 2004-16 50 600 (<500 MW) 300 0.03

200 (≥500 MW) 450*
Units installed from 1 January 2017 50 100 100 0.03
* Relaxed in 2020, as outlined in the text below
PM, SO2, NOx and Hg units in the table are in mg/Nm3, ‘normal’ is defined as corrected to a 6% O2 dry basis
Before 2015, Indian coal-fired power plants were expected to meet plant-specific PM standards in the
range of 150–350 mg/Nm3, depending on the size and age of the plant. The limit is now significantly
tighter. For example, for coal-fired units smaller than 210 MW, the pre-2015 emission limit for PM
was 350 mg/Nm3. For units larger than 210 MW the limit was 150 mg/Nm3. Current PM emission
standards are between 100 and 50 mg/Nm3, depending on the installation date for the unit – less than
half the previous limit.
The National Clean Air Programme (NCAP), announced by the MOEFCC in January 2019, sets a target
reduction of 20% for PM2.5 (PM below 2.5 µm in diameter) and 30% for PM10 (PM below 10 µm in
16
diameter) in ambient air by 2024, with 2017 as the base year (CPCB, 2019). For these reduction targets
to be met, Indian stakeholders will need to monitor the trends in ambient air concentrations of PM
and, if it appears that targets will not be met, then this may result in pressure upon the authorities to
strengthen the pressure on sources such as coal plants to comply with the new PM emission limits or
even tighten them further.
Prior to 2015, India had no emission limits for SO2 and NOx for coal-fired utilities. The standards set
were therefore challenging as they required a significant change in the technologies required by coal
plants. In 2021, the Indian Ministry of Power (MOP) reiterated that, for the country to become
self-reliant in power generation and to be free from polluting elements, thermal power plants must
apply various measures such as upgrades of electrostatic precipitators (ESP), installation of flue gas
desulphurisation (FGD) systems, and combustion modifications to comply with new standards, or
‘norms’, for PM, SO2, and NOx (MOP, 2021). However, as discussed below, the emission limits listed
in Table 1 are still not being applied in practice due to continuing variations, derogations, and
amendments.
2.2 AMENDMENTS TO THE EMISSION LIMITS

Emission limits for SO2, NOx and mercury are all new to Indian coal utilities and the values listed in
Table 1 were perceived as relatively challenging. One of the main concerns for the utilities was the
short timeframe for compliance and the associated costs of installing pollution control equipment.
Power plants were required to comply with 2015 standards by 2017 – this deadline was not met.
Whilst this is probably due to the cost of compliance, many utilities hesitated on fulfilment due to
confusion around the continuing evolution of the emission limits. This lack of clarity on policy
requirements and firm compliance dates continues to result in delays.
When faced with inactivity and confusion within the utility sector, the Indian government proposed
a ‘graded action plan for adopting new emission norms’ which includes relaxation of compliance dates
in a staged manner across the fleet, according to plant location and size. Staged implementation was
introduced in April 2021 at which time the MOEFCC formed a task force comprising representatives
from MOEFCC, MOP, CEA, and CPCB to rank power plants into three categories as shown in Table 2.

17
TABLE 2 RANKING OF PLANTS FOR COMPLIANCE DEADLINES (MOEFCC, 2021)
Rank Timeline for Compliance

Category Location/area
Non-retiring units Retiring units
Within a 10 km radius of the national

1 Category A capital region or cities with a Up to 31 Dec 2022 Up to 31 Dec 2022
population >1 million*
2 Category B Within a 10 km radius of a critically Up to 31 Dec 2023 Up to 31 Dec 2025

polluted area† or non-attainment city†
3 Category C Other than those included in Category Up to 31 Dec 2024 Up to 31 Dec 2025
A and B
* as per 2011 population count † as defined by CPCB
Depending on the plant ranking, the deadlines for compliance published by MOEFCC start from
December 2022 and continue through December 2025. The period allowed for compliance varies with
the location of the plant as this affects the environmental challenge – compliance is required soonest
for Category A plants, located within a 10 km radius from National Capital Region (NCR) or cities with
more than 10 lakh (1 million) population. A deadline a year later is set for Category B plants, located
within a 10 km radius of Critically Polluted Areas (CPAs) or Non-attainment cities. All remaining
plants (Category C) are given two years longer to comply than Category A plants.
Retiring units which are not in compliance by the deadline should close immediately. However, units
declaring retirement before the date specified in the ‘retiring units’ column of Table 2 will not be
required to meet the specified limits provided they submit a petition to CPCB and CEA for an
exemption. However, these units will be subject to penalties at the rate of 0.20 rupees per unit of
electricity generated (kWh), if they continue to operate beyond the date specified in their petition.
Schedules of penalties for non-retiring non-compliant units are shown in Table 3 below. Penalties
increase with the increasing length of the non-compliance period and depend on the plant’s category
classification.
TABLE 3 PENALTIES FOR NON-COMPLIANT POWER PLANTS, RUPEES/KWH (MOEFCC, 2021)
Non-compliant operation beyond Category A Category B Category C

the timeline
0–180 days 0.10 0.07 0.05
181–365 days 0.15 0.10 0.075
366 days and beyond 0.20 0.15 0.10
The penalties described in Table 3 appear to be substantial but affordable. For example, a
non-compliant 500 MW unit operating at 60% capacity for the first year after the compliance deadline
would be required to pay 131,400,000 rupees (US$1.8 million) for the first half of the year and
197,000,000 rupees (US$2.6 million) for the second half of the year to give a total of 328,400,400

18
rupees (US$4.4 million) for the year. To put this in perspective, the same plant would generate
approximately 2628 GWh during one year of operation. Assuming the average price of electricity in
India of rupees 5.43/kWh, the value of electricity produced would be 14,270,040,000 rupees (US$192
million). Aggarwal (2022a) states that only 5% of Category C power plants (78% of the whole fleet)
are currently in compliance with the emission standards.
The Indian government continues to allow delays and derogations in the implantation of the emission
standards, as shown in Figure 2.
Figure 2 History of delays and derogations (Aggarwal, 2022)
Even with the recent relaxation to allow staged implementation, delays continue. In December 2018
the Supreme Court granted a five-year extension of the original compliance deadline of 2017 to
December 2022 (RAP, 2019). However, in March 2021 the deadline for the new standards was moved
again to 2024. Then, just over a year later, in May 2022, the MOP asked for a huge twenty-year
extension on the emission standards for the 398 coal-fired power plants within Category C (Aggarwal,
2022). These plants represent 78% of the coal power fleet. The reasons for the requested extension
were given as follows:
• The delay would allow the development of phased manufacturing of FGD to encourage
‘Atma Nirbhar Bharat’ – ‘self-reliant India’;
• The cost of FGD would almost treble the cost of electricity to consumers;
• Ongoing issues from the Covid-19 pandemic have led to challenges with planning, tendering
and implementation of FGD;
• There are import constraints on FGD components such as borosilicate and absorber linings
due to ‘geopolitical conditions’.
Although Aggarwal (2022) noted that only 5% of Capacity C plants are already in compliance with the
SO2 limit, a further 40% have already awarded bids for FGD installation – these plants could therefore
meet the 2024 deadline. A further 29% in Category C had initiated bids for FGD by 2022 and could still

19
meet the deadline if work goes ahead. This would leave only 26% of the Category C plants unlikely to
meet the deadline, as summarised in Figure 3.
Figure 3 Compliance status of category C plant (Aggarwal, 2022)
Aggarwal (2022) argues that, since the majority of the coal fleet is on track to meet the deadline or
could feasibly do so in the remaining time, the proposed extension would significantly stall achievable
progress. The proposed delay would derail what could be almost 75% compliance and result in up to
95% of the fleet failing to comply by the current deadline. This does not make good policy sense. At
the time of publishing this report, the requested 20-year delay has not been approved.
2.3 COMMENTS
India’s environmental legislation has evolved in a somewhat fragmented manner and continues to shift.
In 2015, the government set challenging emission limits for coal-fired plants, and these included an
equally challenging deadline for compliance. The Indian utilities argued that the targets were too
stringent, the timeline was too short, and that compliance was not possible due to both cost and
availability of equipment and expertise. The emission limit values themselves remain largely intact,
but the Indian Government continues to weaken the rules when asked to by industry, and timelines
continue to extend. The CEA recently request that the emission limits be deferred until 2034 and, in
May 2022, the MOP proposed an extension of 20 years (to 2044) for Category C plants, almost 78% of
the fleet. This should be hard to justify considering that over 70% of the fleet could be compliant by
the deadline, based on current tenders and projects.
If the Indian Government were to enforce the current limits, compliance would result in an over 80%
reduction of SO2, NOx and PM by 2030. At the same time, public health would be improved
significantly, deaths would be reduced, and the costs of air pollution-associated health issues could be
reduced by over US$1.1 billion by 2030, far outweighing the cost of compliance. The current Indian

20
approach of requiring agreed consensus from industry to comply with the standards is not tenable –
the Indian government must recognise that enforcement of the limits is cost-effective for the Indian
population. However, although the cost-effectiveness may be obvious, facilitating this in practice
would not be straightforward. Currently, the Indian government and population would reap the
benefits of reduced pollution while the utilities bear all the cost. There is therefore an urgent need for
stakeholder consultation across the entire sector to decide how best to facilitate funding or create
tariffs. Significant debate is needed to agree on how finances can be leveraged in a fair, appropriate,
and effective manner.

21
PARTICULATE CONTROL
3 PARTICULATE CONTROL
The new emission limit for PM discussed in Chapter 2 is lower than half of the previous limit and will
therefore requires some plants to improve their emission control systems. Indian coals are known to
be higher in ash, often over 40%, than other coals which results in significantly more particulate matter
being released from the boiler. The following sections briefly review the technology options for
particulate matter (PM) control in India, taking the challenge of high ash Indian coals into account.
There then follows a review of how these systems will ensure that Indian complies with PM emission
limits cost-effectively.
3.1 TECHNOLOGY OPTIONS

The majority of coal-fired power units in India have PM controls installed. Figure 4 shows the installed
PM controls across the Indian coal-fired fleet by unit size. Those units with no PM controls in place
are commonly below 300 MW. However, a small number of larger (500–600 MW) units appear to lack
PM controls.
Figure 4 PM control by unit size on the Indian coal fleet (Adams and others, 2021)
The installation of PM controls is the minimum requirement for emission control at any coal utility
plant around the world. There are two major technologies for PM control for full-scale coal-fired
power plants – electrostatic precipitators (ESP) and fabric filters (FF). Hybrid systems such as wet
ESP or electrostatically charged FF have emerged over the years for specific applications, largely for
achieving ultra-low emission limits. Since the emission limits in India are not yet ‘ultra-low’, these
advanced systems may not be considered part of a cost-effective PM emission control strategy and
therefore are not yet relevant in India.
22
PARTICULATE CONTROL
3.2 STATUS OF PM CAPTURE AND OPPORTUNITIES FOR

IMPROVEMENT
As mentioned previously, most Indian coal-fired power plants use ESP rather than FF. Previous PM
limits for plants were 150–350 mg/Nm3 depending on plant size but have now been reduced to
50 mg/Nm3 for any plant built after 2003. These new limits should be achievable by all Indian plants
with installed PM controls, assuming that they are operating correctly and take into account the
specific challenges of high ash Indian coals.
Most if not all coal-fired plants in India already have PM controls in place, with only around 5% of
capacity, mainly comprised of units smaller than 300 MW, still without adequate PM controls. The CSE
study (CSE, 2021b) calculated that approximately 105 GW capacity comprising over 235 units had
met the PM standard by 2018 or had the potential to comply immediately. In addition, 79 GW
(comprising around 315 units) would have had to comply between 2019 and 2022. CSE expected that
a maximum of 73% of the coal fleet would meet the PM emission limit by the, then, 2022 deadline. The
survey found that over 6 GW capacity had planned to or were in the process of upgrading their ESP to
meet the standard. Any remaining plants that cannot meet the current PM limits could do so with
refurbishments and upgrades. However, there may be a few plants with extremely poor PM control
performance that may need major overhauls and re-designs of their PM control strategy.
Information on what individual plants or utilities are doing to meet the new PM emission standards is
not publicly available. However, trends in ESP upgrades in India can be derived from sales of ESP
equipment. Figure 5 shows, on the right, the progressive tightening of emission limits for PM in India
over time. On the left, the figure shows the increase in the size of ESP installed to meet the tightening
standards.
Figure 5 Increasing ESP size and tightening emission limits over time (CSE, 2016)

23
PARTICULATE CONTROL
As the emission limits tightened (on the right of

Figure 5), many plants that needed to achieve greater PM
capture efficiencies did so by installing larger ESP or ESP
with larger specific collection areas (SCA). At a constant
CASE STUDY
flue gas flow rate, the larger the SCA, the greater the
Mitsubishi installed their
capability of the ESP to capture fly ash.
proprietary high-performance
According to CSE (2016), a “considerable proportion” of ‘Moving Electrode Electrostatic
plants have ESP which are adequate to meet the new PM Precipitator’ (MEEP) at Rihand
emission limits and only ‘minor’ refurbishment is required Super Thermal Power Station
on the remainder. Plants commissioned between 1990 and (500 MW x 2). Through this retrofit,
2008 (43 GW) may need to upgrade to meet the new the PM concentration at the ESP
emission limits. This upgrading could be achieved by outlet was reduced from
3
adding more fields. Others may simply need basic 500–600 mg/Nm to below
refurbishments such as gas flow optimisation and reduced 50 mg/Nm3 (Omine and others,
leakage. The cost for these upgrades was estimated at 2017).
Rs5–15 Lakh/MW (6200–18,600 $/MW), depending on
A non-leak type, finned-tube gas
what is required. A shutdown of up to 30 days for the plant
cooler was installed in front of the
would also be required for some upgrades. The CSE report
MEEP, and the flue gas temperature
suggested that plants with ESP over 25 years old (around
at the ESP was lowered to 90–100°C
36 GW capacity) which opt to continue operation could
(a typical ESP operates at
upgrade or replace their ESP systems cost-effectively. For
130–160°C). Fly ash resistivity was
example, the NTPC’s (formerly known as National
lowered to the range where PM was
Thermal Power Corporation) Rihand plant upgraded its
easily detached by rapping. Lower
ESP to a more advanced moving field system
resistivity of fly ash prevented
(see Case Study box, right).
decline of the particulate collection
The main challenge for effective PM control at power performance of the ESP due to
plants in India is the high ash content of coals (30–45% polarity issues.
ash; CSE, 2020d). Because of this elevated ash, more PM The operation of the retrofitted units
is produced during the generation of each unit of power at Rihand showed the new system to
than for coal plants elsewhere in the world using coal be significantly more effective than
with significantly less ash. This means that if larger PM the conventional system in the
controls are needed for Indian plants firing Indian coals removal of not only PM, but also
to achieve the emission control comparable to these in mercury, selenium (Se), and sulphur
other countries. trioxide (SO3).
If PM controls do not capture particulates efficiently,

then this can create negative effects on any additional

24
PARTICULATE CONTROL
pollution control systems installed downstream, such as FGD for SO2 control. The high ash loading
from Indian coals means that PM control systems must work efficiently and be larger than similar
systems in plants in other regions. In addition, a tighter and more comprehensive maintenance system
is required to ensure the proper operation of the PM emission control device.
A CSE report (CSE, 2020e) which focussed on emission monitoring with the Indian emission limits
suggested that at that time:
• Only 53% of the coal utility fleet in India was confirmed as complying with the PM emission
limits;
• Nearly 8% already had ESP upgrades planned;
• 1% of units had to retire; and
• Data for the remaining 38% were not available.
Despite NTPC being the largest power-producing organisation, data were not available for 25% of their
units. In the NTPC Annual Report 2020-21 (NTPC, 2021), it is suggested that most of the NTPC units
comply with the PM emission limits. However, ESP repair and maintenance is underway at around 5
GW of capacity in 16 units to ensure that they meet the new standards.
A review of the status of PM emission control from coal-fired power plants in India (Pachouri and
Saxena, 2020) suggested that, out of the total of 197 GW of plant capacity considered, 73 GW (37%)
were non-compliant for PM emissions. The report claimed that 66 GW of this non-compliant capacity
has been considered for ESP upgrades, but no specific information is available.
The webpage Coal Power Watch, operated by CSE provided the data in August 2022 for Figure 6.
Figure 6 Implementation progress of PM control in India (CSE, 2022)

25
PARTICULATE CONTROL
The data in Figure 6 suggest that just under half of the coal capacity (101.8 GW out of 209.4 GW) is
confirmed as compliant with the emission limits for PM. A further 92 GW may be compliant, but data
are not available.
A complementary report from ICSC on emission reporting in India (Sloss and others 2021) reported
that fewer than 50% of plants are reporting their PM emission data to the regulators. However, based
on the available data and considering yearly average values, 71% of the units providing data showed
PM emissions below the emission limit. These data are somewhat different from those used for
regulatory compliance – the latter is assessed based on 15 mins average values. However, the reported
yearly average values would indicate that PM control at many more plants is inadequate.
Since reliable PM emission data are only available for around half of the Indian fleet, it is not possible
to confirm the actual status of compliance of Indian coal-fired power plants with the new emission
limit. Neither is it possible to determine PM system performance in India nor the need for further
upgrades or retrofits.
An important point raised in the CSE (2016) report is that, if a plant is planning to install an FGD
system for SO2 control (see Chapter 5), then the combination of ESP and FGD could mean that the ESP
size can be reduced. And so Indian plants should not be considering PM or SO2 control requirements
separately but rather in combination, to maximise the overall pollutant control efficiency of systems
working together in tandem. Further, while multipollutant strategies and modifications such as this
are considered, it is an ideal opportunity to include mercury reduction potential through co-benefit
effects. This will be discussed more in Chapter 6.
3.3 COMMENTS
PM controls are well established and commercially available internationally, offering over 95% and
often over 99% capture efficiency. Although Indian coals are high in ash and can have high resistivity,
there are well-established approaches to ensure that PM controls can handle these characteristics. The
performance of PM systems relies on adequate maintenance and repair, and, in the past, Indian coal
plants have reported issues with ageing ESP systems. However, it seems most plants have either
upgraded their PM controls or are in the process of doing so.
Currently, it is hard to determine just how well Indian PM systems are performing. Although PM
emissions must be measured and reported live to the regulators in real-time in India, this system is not
currently running effectively and fewer than 50% of sources are providing the data as required. Further,
the state regulators rely heavily on emission sources ‘self-regulating’ to ensure emissions are
controlled adequately. Until there is sufficient supervision, auditing and enforcement, there is still a
significant risk that some plants may exceed the new PM emission limits, and that little will be done to
correct this.

26
PARTICULATE CONTROL
It is important to note that the PM loading of the flue gas can affect the performance of downstream
pollution control systems such as FGD and SCR/SNCR (selective catalytic and selective non-catalytic
reduction for NOx control). Some plants may need to modify or upgrade their existing PM systems to
ensure that they do not damage these additional controls. At the same time, however, there are
combinations of PM, SO2 and NOx systems which, when working together, are more efficient and
cost-effective than when considered alone. Indian coal plants should therefore tackle emission control
with a multipollutant control approach, including mercury, to ensure that the best combination of
systems is installed.

27
NOX CONTROL
4 NOx CONTROL
Many countries have set stringent NOx emission limits and have used various commercially available
NOx control for decades. These technologies have been demonstrated to be effective on different
types of coal, including coals with high ash content such as those used in India. As mentioned in
Chapter 2, many stakeholders in India continue to argue that the proposed emission limits for NOx are
too challenging for power plants firing Indian coals. It is important to evaluate the main arguments
that some Indian stakeholders have raised. These are:
• NOx control techniques and technologies are less effective on high-ash Indian coals;
• Flame stability issues arise in low NOx firing conditions when plants run at low capacity;
• Plant footprints may not provide the space required for retrofitting NOx controls;
• There is a lack of local suppliers and equipment;
• There is limited availability and storage facilities for new reagents such as ammonia or urea;
• There is a lack of national skills in NOx reduction;
• Plant modifications will be expensive and running costs will be high;
• The requirement to maintain flue gas temperature for new SCR (selective catalytic
reduction) and SNCR (selective non-catalytic reduction) flue gas cleaning systems will be
challenging for Indian plants.
However, most if not all of these concerns can be overcome. Previous ICSC reports (Adams and others,
2021; Wiatros-Motyka, 2019; Wiatros-Motyka and Nalbandian-Sugden, 2018) have provided detailed
information on NOx control and so this chapter will only briefly review the technical information
before moving on to the situation and specific policy challenges in India.
NOx control technologies can be broadly divided into primary and secondary measures
(Wiatros-Motyka and Nalbandian-Sugden, 2018). The sections below summarise the technology
options for NOx control, highlighting their relevance for Indian coals and power plants.

Optimising combustion should be the first action taken to reduce emissions since efficient combustion
reduces coal consumption. With respect to NOx, combustion optimisation can have many forms,
including ensuring optimal mill performance and coal fineness, adjusting air/fuel ratio, trimming
excess oxygen in the furnace, and fine-tuning combustion controls. The effectiveness of combustion
optimisation depends on several factors, including coal properties; coal fineness; air/fuel ratio and
distribution to each burner; all air flows – primary, secondary, tertiary, overfire air; and bulk furnace
temperature, which can vary with boiler cleanliness and/or load (Holappa, 2020a; Fortum eNext,
2020; Storm, 2020). Fortum eNext (2020) carried out a study of more than 70 coals (domestic and
imported) used for power generation in India. The study proposed general guidelines to make

28
NOX CONTROL
assessments of whether certain coals can be reduced to below a NOx emission limit of 300 mg/Nm3
and concluded that there is a clear correlation between the nitrogen content of the fuel and the
fuel-to-air ratio.
CONTRARY TO SOME STAKEHOLDER ARGUMENTS,

INDIAN COAL PROPERTIES ARE GENERALLY NOT
CHALLENGING FOR PRIMARY MEASURES FOR NOX
CONTROL.
Despite the achievability of NOx reductions, until recently, in India, many boilers used only overfire
air (OFA) and/or fuel biasing (adjustment of flow) to reduce NOx emissions and only a few low NOx
burners (LNB) were deployed within the sector. This situation is changing due to the new emission
standards, and many plants built between January 2004 and December 2016 are retrofitting LNB. All
Indian coal-fired power plants built after 2017 have LNB fitted as a standard technology. Additionally,
units built between January 2004 and December 2016 must comply with the NOx limit of 450 mg/Nm3,
which would require the installation of LNB, OFA or both as well as optimised combustion. Separated
overfire air (SOFA) system has been installed at an Indian coal plant, CLP Jhajjar, Haryana – NOx
emissions were reduced to below 300 mg/Nm3 at two units (Fortnum eNext, 2020). GE has been
contracted to carry out SOFA installation at 19 of NTPC’s units totalling almost 10 GW. An emission
target of 400 mg/Nm3 was requested by NTPC, but greater reductions would have been possible if a
further SOFA layer had been installed (Kendhe, 2020).
The NOx that escapes into the flue gas from the combustion zone can be reduced by post-combustion
controls SCR or selective non-catalytic reduction (SNCR). SCR is the most effective NOx control
technology with up to 90–95% removal rates. The technology can be arranged in three different
layouts in a coal-fired power plant: high-dust or hot-side (before the PM control system, between the
economiser and air heater), low-dust (after the PM system), and tail-end position (after all control
systems) (Wiatros-Motyka and Nalbandian-Sugden, 2018; BHEL, 2016). Hot-side is the most widely
used SCR configuration; issues related to high ash coal utilisation, such as in India, can be addressed
by proper design (Zmuda, 2020).
SNCR also relies on the post-combustion injection of reagent to reduce NOx but does not rely on a
catalyst. On average, SNCR can reduce NOx by 30–60% on its own, but when used in combination
with primary measures the reduction rates can be as high as 70% (Wiatros-Motyka and Nalbandian-
Sugden, 2018; IFS, 2021). The efficiency of SNCR depends largely on temperature where the reagent
is injected. SNCR is always used in combination with primary NOx controls and can also be combined
with SCR.

29
NOX CONTROL
An NTPC study (NTPC, 2021) suggested that SNCR systems were not suitable for Indian coal plants.
Following short trials of SNCR, NTPC concluded that the SNCR was not effective enough. However,
most, if not all, of the concerns raised by NTPC against the suitability of SNCR in India, can be
addressed through the modification of SNCR systems to suit plant-specific conditions.
4.2 SELECTION OF NOx CONTROL

The choice of appropriate NOx controls depends on several factors but largely on the required level
of NOx reduction. In countries where more stringent NOx emission regulations have been introduced
over time, it has been standard practice to start with primary measures such as LNB and OFA and then
add an SCR or an SNCR or a combination of both. The experience with Indian boilers shows that levels
of 300 mg/Nm3 can be achieved for most Indian units with the latest primary measures alone. A
combination of primary and secondary measures will be required to achieve NOx emissions below
200 mg/Nm3.
Table 4 lists qualitative costs for primary and secondary NOx control measures recommended for
Indian power plants. It should be noted that the cost will always vary between individual power plants.
TABLE 4 COMPARISON OF COST AND BENEFITS OF USING DIFFERENT NOX CONTROLS (MODIFIED FROM FORTUM
eNEXT, 2020; CONRADS, 2020)
Advanced fuel & Primary NOx Selective Selective catalytic

air measurement solutions by non-catalytic reduction (SCR)
Fortum eNext* reduction (SNCR)
(LNB+SOFA) +
some optimisation
Relative initial 0.2–1.0 3–6 2–3 10–20

investment
Opex NA NA $6.5-16.4 million Approximately $6.5

depending on the million depending
reagent on the amount of
consumption and reagent and
cost catalyst
replacement
NOx reduction 10% by better fuel Up to 70% 20–60% 80–90%

and air tuning
Additional benefits Reduced CIA, Lower cost for

such as increased reduced slagging, secondary measures
efficiency, increased efficiency
decreased CIA etc
LNB = low NOx burner; SOFA = separated overfire air
A decision on which primary measures should be chosen must be made on a plant-by-plant basis. But
in general, primary measures will include LNB, OFA, combustion optimisation and coal selection,
which are already practised in Indian plants. Further details of technologies for NOx control and their
estimated cost per MW in India are given in Table 5 (CSE, 2016).

30
NOX CONTROL
TABLE 5 COMPARISON OF DENOX OPTIONS (CSE, 2016)
Available In-combustion Post-combustion

technology/parameters
Combustion Selective non-catalytic Selective catalytic

modification reduction (SNCR) reduction (SCR)
Variants and measures Low NOx burner Reagent: Catalyst type:

to control NOx Wind box modification Anhydrous/aqueous Plate/honeycomb
Various types of overfire ammonia or urea Reagent:
air (OFA) processes Anhydrous/aqueous
ammonia or urea
Installation cost 0.1–0.15 cr/MW 0.04 cr/MW1–0.15 cr/MW 0.2 cr/MW2

0.15 cr/MW3 (hybrid)
Reagent quantity None For every tonne of NO For every tonne of NO

removal 1.1 tonne of removal 1.1 tonne of
ammonia4 is required or ammonia5 is required or
2 tonne of urea 2 tonne of urea
Reagent cost None Rs 21,000 per tonne Rs 2.5–2.7 lac/MW

(imported technical grade (catalyst replacement –
urea) once in three years
Process of NOx Staging combustion air Using ammonia: NO Nitric oxide/nitrogen

reduction reacts with ammonia and dioxide reacts with
oxygen to form nitrogen ammonia and oxygen to
and water form nitrogen and water
Using urea: NO reacts
with urea and oxygen to
form nitrogen, water and
carbon dioxide
Ammonia slip (excess Less than 2.5 ppm

ammonia), which can
potentially react with
sulphur in the flue gas
and form ammonium
(Possible to limit less than 0.5 ppm)
bisulphate increasing
corrosion of the
preheater
SO2 to SO3 conversion Less than 1 per cent
Mal-distribution or Less than 5 per cent

improper mixing
Source: NTPC Limited and CSE survey of manufacturers

1
if base NOx level less than 400 and target 300 mg/Nm3
2
3
4
1 mol of nitric oxide reacts with 1 mol of ammonia and ¼ mol of oxygen to produce 1 mol of nitrogen and 3/2 mol of
water. Molar mass of nitric oxide = 20 and ammonia = 17; nitric oxide: ammonia = 20.17; considering wastage 30% nitric
oxide: ammonia requirements = 1:1.1
5
1 mol of nitric oxide reacts with 1 mol of ammonia and ¼ mol of oxygen to produce 1 mol of nitrogen and 3/2 mol of
water. Molar mass of nitric oxide = 20 and ammonia = 17; nitric oxide: ammonia = 20.17; considering wastage 30% nitric
oxide: ammonia requirements = 1:1.1
Table 5, produced within India, confirms that the sector is aware of the effectiveness of NOx control
technologies on Indian coals, the achievability of the emission limits, and the associated costs.
31
NOX CONTROL
4.3 NOx CONTROL INSTALLATION STATUS IN INDIA

In India, the majority of existing boilers are tilting tangential type, have OFA and are supplied by the
Indian company BHEL (BHEL, 2016). Many also apply fuel handling measures to reduce their NOx
emission. However, the exact status of NOx control installation for the majority of units (155 GW of
capacity out of 209.4 GW) is unknown, as of April 2022 (CSE, 2022). There is also a discrepancy in
data between the S&P Global database and some Indian sources, which highlights the complexity of
the evaluation. For example, CSE Coal Power Watch, which tracks control implementation (CSE,
2022), noted that only about 13.6 GW of capacity was complying with the current norms. However,
it is not specified which units are compliant and with which norms they comply (600 mg/Nm3 or
450 mg/Nm3) (see Figure 7).
Figure 7 NOx control implementation progress according to CSE Coal Power Watch as of
August 2022 (CSE, 2022)
Additionally, the CSE data show that 12.3 GW of capacity has both LNB and OFA, while 5 GW have
OFA and 3.3 GW has LNB. This differs from S&P Global which says that in Dec 2021, 40 units of a total
capacity of 19.7 GW had LNB installed, including two units that have both LNB and OFA (S&P Global,
2021). At the same time, S&P Global noted that 45 units have some form of NOx controls, equalling
21.3 GW of capacity, which is just above 10% of the total capacity (excluding captive plants). However,
it is likely that more plants may already comply with the new norms since they will only need to
optimise their combustion to achieve the 600 mg/Nm3 and 450 mg/Nm3 emission limits. This theory
is supported by the complementary ICSC report on CEMS (Sloss and others, 2021a) which showed
that only about 42% of plants are reporting NOx data and so it is possible that compliance is being
achieved without being reported.

32
NOX CONTROL
Available data indicate that around 22% of plants comply with the new emission limits. CSE confirms
average NOx emissions of 200–400 mg/Nm3 for the majority of plants, which is below the current
450 mg/Nm3 limit. However, at the same time, some plants have emissions of NOx as high as
1190 mg/Nm3 (CSE, 2020c). Accurate monitoring is required to confirm the current rates of NOx
emissions from plants.
According to the Indian regulations, 160 GW of coal power capacity (comprising about 435 units)
were to comply with the NOx emission limits (Table 1 in Chapter 2) by 2022, over and above the 115
units which should have complied in 2019 and 2020. As described in Chapter 2, the proposal to relax
the NOx emission limit from 300 to 450 mg/Nm3 for plants built between January 2004 and December
2016, was approved in October 2020. This means that units with well-tuned combustion and other
primary measures such as LNB, and OFA can easily comply with the relaxed norms. However, plants
commissioned after 1 January 2017, must meet the limit of 100 mg/Nm3 (or about 50 ppm) and this is
not possible without secondary NOx control measures such as SCR, SNCR or their combination, in
addition to primary measures. At the time of writing (March 2023), none of the new Indian units has
operational SCR or SNCR and the only full-scale SCR installation has been implemented at the
Harduaganj 660 MW unit, which is currently under commission. Only smaller-scale slipstream SCR
trials have been conducted in some NTPC units (Kumar and Bhagchandani, 2018; Reuters, 2019;
Tripathi, 2020).
The information collated by ICSC during this project and the complementary report by Adams and
others (2021) indicate that all but one of the NOx control systems currently planned in Indian coal
plants are combustion modification/primary measures only. Technology companies such as GE Power
and BHEL have been given orders for NOx controls to be completed in a phased manner. For example,
as mentioned earlier GE has a contract with NTPC to improve NOx emissions in 19 units, equating to
almost 10 GW. Work is ongoing and involves the installation of SOFA which is predicted to be finished
by the end of 2022. The NTPC units undergoing upgrades are at Mouda, Vindhyachal, Sipat, Simhadri,
Vallur and Talcher (GE, 2019). Additionally, two NTPC Dadri’s 490MW units, already have SOFA
systems supplied by UCC, USA (NTPC, 2020).
If all Indian plants are to comply with the new emission limits, then more utilities need to start
investigating their current emission limits and tendering for control systems accordingly.
4.4 COMMENTS
Evidence shows that although the ash content of Indian coal is challenging, this has little impact on the
effectiveness of NOx emission controls. Most units could achieve emissions of around 300 mg/Nm3 at
all loads while deploying only primary controls. These are relatively inexpensive solutions and can
result in increased plant efficiency and reduction of all pollutants, not just NOx. Combustion
modifications for NOx have a payback time of only 1–2 years.

33
NOX CONTROL
New plants built after 1 January 2017, must meet tighter emission limits (see Table 2) and may need
both primary and secondary measures such as SCR and/or SNCR. NTPC has argued that SCR and SNCR
technologies will not be effective on Indian coal plants. However, data and practice from international
SCR and SNCR show this to be inaccurate.
Arguments that the new emission limits are not achievable in Indian coal plants are demonstrably
invalid – technology suppliers and international experts are confident that all NOx controls, including
SCR and SNCR, can work successfully in Indian coal-fired power plants. The current challenge is
therefore to ensure that the Indian coal utility fleet steps up to comply with the achievable emission
limit. Any remaining barriers are likely to be based on affordability as well as the availability and
skillset of equipment suppliers.

34
SO2 CONTROL
5 SO2 CONTROL
As shown in Table 1 in Chapter 2, there is now an emission limit for SO2 in India which ranges from
200 to 600 mg/Nm3, depending on the size and age of the plant. Since there has never been an emission
limit for SO2 in the past, this means that many plants in India are facing a new compliance challenge.
With the continuing delay on firm legislated deadlines discussed in Chapter 2, utilities are justifiably
confused over their requirements for compliance, and this may be stalling action on retrofitting
pollution control systems.
The coal used in coal-fired power plants in India has a relatively low 0.4–0.6% sulphur content. It also
has a low calorific value and high ash content. This leads to higher coal consumption and therefore
higher SO2 emissions per unit of power generated. Burning compliance coal (coal with SO 2 emissions
below current standards) alone is unlikely to be enough to ensure compliance with the new SO 2
emission standards and so most power plants will need to install sulphur controls.
The SO2 rule was also amended to consider stack height, a fairly unique approach these days. This
approach was previously used internationally but has been determined as not improving
environmental quality and as largely been replaced by a single emission limit that applies to all plants,
regardless of location or stack height. Therefore, for India to reintroduce stack height as a
consideration for compliance seems to be a backwards step simply dispersing the pollution more
diffusely rather than actually reducing emissions.

The main technology for SO2 control is flue gas desulphurisation (FGD). FGD is commonly applied as
a post-combustion process. The type of FGD is defined by the reagent used and/or the by-product:
dry FGD is where the flue gas is not saturated with water and the by-product is dry, and wet FGD
involves saturating the flue gas with water to produce a wet by-product. Wet FGD systems commonly
produce gypsum as a by-product whereas sulphite is produced by dry systems. Dry and wet FGD
technology options are summarised briefly below.
Dry Sorbent Injection (DSI) is a low-capital cost option suitable for plants burning low-sulphur coal.
DSI utilizes calcium-based (or sometimes sodium-based) alkaline sorbent addition into the duct and
the spent sorbent is captured in the PM control device. The use of DSI could result in considerable
changes in plant operation in India, increasing the PM loading and characteristics at the ESP or FF inlet
stream (CEA, 2019). DSI use in India is likely to be restricted to smaller units or older units; the CEA
(2020a) advised that DSI is particularly applicable to smaller coal-fired units (60–250 MW), those
running on low plant load factor, and those with short remaining plant life (7–9 years).

35
SO2 CONTROL
Spray drying is a common approach to SO2 control for units operating on low to medium sulphur coals.
Hydrated lime slurry is prepared in a lime slaker and is introduced to flue gas after being finely
atomised by the rotary atomiser. Compared to wet FGD, spray dryer absorber (SDA) systems require
lower capital and operating costs and have lower overall power consumption. There is no liquid waste
and the solid by-product from the spray drying process is suitable for landfilling (He and others, 2017).
Circulating fluidised bed (CFB) dry scrubbing may be a good alternative to spray dryer FGD
technology as it promises high SO2 removal efficiencies, extremely low water consumption, and the
ability to bridge the size gap between the wet and dry scrubbing FGD. The extended contact time with
sorbents in CFB, compared to spray dyer systems, results in improved SO2 removal efficiencies within
a small retrofitted FGD system footprint. CFB systems have been successfully installed at plants firing
high-sulphur (up to 3.5%) coal. Unlike spray dryers, there is no technical limit on the fuel sulphur
content that can be addressed using CFB technology. Demonstrated SO2 removal efficiencies are more
than 95% and can be as high as 99% (depending on inlet SO2 loading) (He and others, 2017).
Wet FGD is versatile, capable of handling flue gas from high sulphur coal, and is widely used for large
units worldwide. Limestone is used most often as a sorbent although lime or dolomitic lime can also
be used. Dry sorbent (limestone, lime, or dolomitic lime) is crushed and finely milled, then made into
a slurry before it is pumped into an absorber vessel where it is sprayed into the flue gas. The sprayed
reagent reacts with SO2 through a series of gas-liquid and liquid-solid reactions, eventually forming
calcium sulphite and sulphate. The CEA (2020a) suggest that wet FGD technologies be selected in
India based on plant-specific factors such as plant configuration, size, and remaining lifetime.
Limestone wet FGD has a larger footprint, relatively higher capital cost and reagent purity issues
compared with dry FGD technologies. The use of gypsum by-products from wet FGD is discussed
separately in an ICSC report by Sloss and others ‘Achieving 100% ash utilisation at coal-fired power
plant in India’ (May 2023).
Seawater FGD (SWFGD) uses seawater as the scrubbing medium for SO2 removal and is often
preferred by plants located in coastal areas because of the lower capital cost compared to an entirely
new limestone wet FGD. The flue gas is brought into contact with seawater in the absorber which takes
advantage of its natural alkalinity to react with SO2. The seawater from the absorption zone is treated
in the aeration basins to ensure oxidation of the sulphite to sulphate before the discharge of the
processed water to the sea. As with limestone wet FGD, the seawater will remove soluble oxidised
mercury from the flue gas. In limestone FGD the mercury is retained in the gypsum by-product. Unless
specialised mercury-focused treatment of seawater is implemented, there is the potential for mercury
to be released into the environment. It is therefore critical to note that SWFGD, while an effective and
attractive relatively low-cost approach to controlling emissions of SO2, may be contributing a
substantial amount of mercury effluent to seawater and emissions to air.

36
SO2 CONTROL
5.2 SELECTING FGD SYSTEMS IN INDIA

The advantages and disadvantages of FGD technologies must be considered on a case-by-case basis
during the selection process. Table 6 shows details of the different FGD system options that may be
considered for a 500 MW unit.
TABLE 6 COMPARISON OF FGD SYSTEMS (JOHANSSAN, 2012)
Dry FGD Seawater FGD Limestone FGD
Features Low investment No reagent High-efficiency spray zone

Dry by-product No by-product Low-cost reagent
Small footprint By-product flexibility
Multipollutant control
Reagent Lime Seawater Limestone
By-product Landfill Seawater Marketable gypsum or landfill
Maximum coal sulphur 3% <1.5% <6%
Removal efficiency 98% 98% 99%
Capital cost 0.7x 0.8x x
Power consumption 0.7% 0.7–1.5% 1.0–2.0%

(including booster fans)
Absorbent cost Significant Zero Low
By-product cost/price Significant Zero Can be significant or can

bring in profit (gypsum)
Wet limestone FGD can achieve up to 90–99% SO2 removal efficiency whereas SWFGD has 70–98%
efficiency (MP, 2021). Coastal plants in India may prefer the option of cheaper and more effective
(concerning SO2, not mercury) SWFGD. Smaller plants with shorter remaining lifetimes are likely to
select DSI, spray dryer FGD or wet limestone FGD.
Generally, for applications in India, the CEA has recommended DSI technology for units smaller than
250 MW and dry or wet FGD for larger size units. The CEA has also recommended selection criteria
for wet FGD retrofits and operational criteria for 500 MW power plants. It has recommended that
plants have at least 25 years of service life remaining, annual maintenance of a maximum of 15 days,
and capital maintenance of 45 days every five years (CEA, 2017).
5.3 STATUS OF SO 2 CONTROL IN INDIA

The status of FGD installation in India is uncertain. There is commonly a three-year period between a
feasibility study and the commissioning process. It is, therefore, possible, in an ideal situation, for all
plants in India to complete the FGD installation process within 4–5 years. In practice, this scenario is
hindered by a lack of materials, expertise, and funding in many regions.

37
SO2 CONTROL
According to CSE (2020f), the total capacity of coal power in India is almost 200 GW (650 units).
Some of these plants will be able to avoid installing FGD for numerous reasons:
• 9 GW are due for retirement;

• 6 GW already have FGD installed;
• 5 GW are CFBC systems which do not need FGD;
• 5 GW claim to be compliant already (presumably through coal quality measures);
• 9 GW claim that space is not available onsite for FGD installation.
However, the majority of plants (162 GW) claim to be planning FGD installation. The following
sections look at the data on FGD installation in India to try to determine to what extent compliance is
really being achieved. The power plants in India which already have operational FGD include:
• three units of Adani Power (Mundra);

• one unit of NTPC Vindhyachal;
• four units of JSW Energy (Ratnagiri);
• two units of Adani Power (Dahanu);
• two units of CLP (Jhajjhar);
• four units of NTPC Dadri.
Several coastal power plants have adopted SWFGD:
• JSW Energy (Ratnagiri);

• Tata Power (Trombay);
• Adani Power (Mundra).
The online availability of installed FGD is unknown. Bids had been awarded for 157 FGD systems
(69 GW capacity) and tenders were invited for the remaining 325 FGD (132 GW capacity). The
leading technology and service providers who have been awarded the FGD tenders include:
• Bharat Heavy Electricals Limited (BHEL)

• GE Power, Larsen & Turbo (L&T)
• Mitsubishi Hitachi Power Systems (MHPS)
• Alstom
• ISGEC Heavy Engineering Ltd (ISGEC)
• United Conveyor (UCC)
• Thermax
According to the CSE (2020c,b) study, approximately 70% of units with deadlines for SO2 compliance
were unlikely to meet them as prescribed. For these units which are not yet compliant, the status is:
34% are performing a feasibility study, 31% are at the tender stage, and 5% remain without plans for
38
SO2 CONTROL
installation. Only 17% of capacity has awarded tenders for FGD. The low rate of FGD deployment at
power plants in India was confirmed in a report by the Vasudha Foundation (Vasudha Foundation,
2020). As of June 2020, only about 1% of the planned 167 GW FGD retrofits at coal-fired power plants
in India have been installed.
This ICSC report attempts to update information on the FGD installation rate in India, based on data
gathered in late 2021 and early 2022. For this, a dataset was collated based on FGD installation
estimates and updates published by the CEA with additional information from CSE (CSE 2020c,b).
Further data were gathered from the S&P database (S&P Global, 2021). Finally, gaps in the data and
further insight were provided through personal communication with stakeholders in the industry.
Figure 8 shows the estimated rate of desulphurisation within India between 2000 and 2024, based on
the S&P Global database (2021).
Figure 8 Status of SO2 compliance technologies in India, 2000-24 (S&P Global, 2021)
According to the published data, many plants in India still control emissions through firing low sulphur
coal (shown in orange). It is important to note that, due to the high ash content of Indian coals, a larger
fraction of the coal is incombustible and, as a result, the relative sulphur content would not be defined
as low compared to most international coals. For many plants, this will mean that low sulphur coal is
insufficient to allow them to comply with the new emission limit for SO 2. Since 2021 there has been
notable growth in installations of dry FGD systems (in blue), largely CFB systems (light blue). Growth
in wet FGD and SWFGD (grey) is slightly higher. Data are still not available for 43 GW of capacity
(shown in green).

39
SO2 CONTROL
The data in Figure 8 include plants below 100 MW, which are excluded from the SO2 emission limit.
However, since this amounts to only around 19 GW out of over 230 GW (2021 data), it does not affect
the data significantly – most plants in India (over 90% in 2021) do not have controls fitted for SO2. If
the projection in Figure 8 is still valid, then over 80% of the Indian coal fleet will remain without SO2
control in 2024.
For this study, we used the S&P Global database as a starting point but updated the FGD installation
projection with more recent data from our in-country consultant. For this, it was necessary to define
the status of FGD projects. From the published data, there are several different stages of FGD tendering
and installation and, since stalling or failure is more likely at earlier stages, it is important to clarify the
situation as clearly as possible. Figure 9 shows the groupings used within this study.
Figure 9 Definition of FGD installation in India (authors’ analysis)
Based on data collated during this study, Figure 10 shows our estimate of the state of FGD compliance
in India.
Figure 10 FGD status for retrofits and new plants, 2021 (authors’ analysis)

40
SO2 CONTROL
It is estimated that 4% of Indian coal-fired power plant capacity has FGD installed/operating
(construction is complete, but the plant may not be at full operation) – these data are consistent with
the data published by S&P Global (2021). Around 51% of plants could be compliant within 1–2 years
if construction is smooth and carried out without delay. A further 18% are at the bid tender stage, and
operation could be 2–3 years away. Feasibility studies are underway at 12% of the capacity but 15% of
plants have no plans or there are no data which means that FGD installation is potentially a minimum
of 4 years away. However, some plants could be too old or inefficient to justify large capital investment
and others could be struggling with land, finance, and resources. The estimate in this report, Figure 11,
largely agrees with the data published in 2020 by CSE, as shown in Figure 12.
Figure 11 Comparison of CSE estimates with estimates from this study (authors’ analysis)
There is a general agreement between the CSE estimate and our estimate. The CSE value of 40% for
‘tender floated’ has dropped to 18% in our estimate (bid/tender stage), suggesting the tenders are
complete and these plants are moving towards installation. Projects at the feasibility stage have also
dropped from 21% to 12%, which may suggest a progression to the bid/tender stage but could also
indicate that plans have been discarded.

41
SO2 CONTROL
Figure 12 FGD status by state in 2021, MW (authors’ analysis)
No Indian state is anywhere near reaching full deployment of SO2 control across the fleet. Utter
Pradesh is leading with the largest percentage of its capacity either with installed controls or with bids
awarded. It would appear that Odisha and Tamil Nadu are lagging compared to others, although Tamil
Nadu has bids to install FGD to 2 GW of lignite plants. There is only a total of 6 GW of lignite utility
plants in India and the FGD control on such units can be more challenging.
When the data are reviewed in terms of plant age, it is clear that the majority of plants with no FGD
committed or planned are older units. The majority of plants with no FGD plans are 15 years old or
older. This could suggest that states are hesitant to begin the FGD installation process on units which
they consider too old to warrant the investment.
Using the data collated for this study, it was possible to produce a list of plants which would be
considered ‘critical’ which respect to SO2 reduction (Table 7). These are among the largest plants in
India (>1000 MW each) which, at the time of publishing this report, do not appear to have any strategy
or proposed strategy for FGD.

42
SO2 CONTROL
TABLE 7 ‘CRITICAL’ LIST OF PLANTS REQUIRING FGD IN INDIA (AUTHORS’ ANALYSIS)
Plant name State Commissioning Sum of

date (average size/capacity
of units)
INDIA NATIONAL TOTAL INDIA 2004 82330
1 Chandrapur TPS (MAHAGENCO) Maharashtra 1997 2920
2 Vedanta Limited (thermal power plant) Sterlite Odisha 2011 2640
3 Karadi TPS (MAHAGENCO) Maharashtra 2002 2400
4 OP Jindal, Tammar (JPL) Chhattisgarh 2015 2400
5 Bara TPP (Prayagraj Power Generation Company Uttar Pradhesh 2016 1980
Ltd) PPGCL
6 North Chennai TPS (TANGEDCO) Tamil Nadu 2002 1830
7 Dr Narla Tata Rao TPS Andhra Pradesh 1991 1760
8 Rayalseema TPS Andhra Pradesh 2005 1650
9 Anpara TPS Uttar Pradesh 1990 1630
10 NTPC Darlipalli Super Thermal Power Plant Odisha 2020 1600
11 Sagardihi TPS-WBPDC West Bengal 2012 1600
12 Sri Damodaram Sanjeevaiah TPS Andhra Pradesh 2015 1600
13 Darlipali Super Thermal Power Project (NTPC Ltd) Odisha 2017 1600
14 Mettur TPS Tamil Nadu 1993 1440
15 Raikheda TPP (GMR Chattisgarh Energy Ltd) Chhattisgarh 2016 1370
16 Nasik Rattan India TPP Maharashtra 2014 1350
17 Khaparkheda TPS (MAHAGENCO) Maharashtra 1998 1340
18 Sanjay Gandhi Thermal Power Station Madhya Pradesh 1998 1340
19 Satpur TPS (MPPGCL) Madhya Pradesh 1992 1330
20 Chhabra TPP (RRVUNL) Rajasthan 2018 1320
21 Sembcorp Gayatri Power Ltd Andhra Pradesh 2017 1320
22 Thermal Powertech Corporation India Ltd, Sembcorp Andhra Pradesh 2015 1320
Energy
23 Suratgarh TPS (RRVUNL) Rajasthan 2001 1250
24 BHUSAWAL TPS (MAHAGENCO) Maharashtra 2003 1210
25 Ampara C (Lanco) TPS Uttar Pradesh 2011 1200
26 Derang TPS (JITPL) Odisha 2015 1200
27 ITPCL TPP Tamil Nadu 2016 1200
28 Kalisindh TPS (RRVUNL) Rajasthan 2015 1200
29 Muthiara TPP Tamil Nadu 2015 1200
30 Salaya Power Plant (Essar) Gujarat 2012 1200
31 Torangallu TPS EXT (JSW Energy) Karnataka 2005 1200
32 Jindal India Thermal Power Ltd Odisha 2015 1200
33 Nariyara TPP (KSK)/Mahanadi Chhattisgarh 2014 1200
34 Parli TPS (MAHAGENCO) Maharashtra 2001 1170
35 Parichha TPS Utter Pradesh 2001 1140
36 Kakatiya TPS Telangana 2013 1100
37 Uchpinda TPP (RKM Power Gen Pvt Ltd) Chhattisgarh 2017 1080
38 Bakreswar TPS (WBPDCL) West Bengal 2000 1050
39 Tuticorin TPS, TANGEDCO Tamil Nadu 1985 1050
40 Visag TPP Andhra Pradesh 2016 1040
41 Bellary TPS (Kuditini TPS) KPCL Karnataka 2010 1000
42 Kothagudem TPS (TSGENCO) Telangana 2002 1000
OTHERS 21700

43
SO2 CONTROL
These plants are all large and therefore, if they continue to run at high capacity without emission
control, their sulphur emissions will also remain significant. It would therefore be prudent for Indian
stakeholders to focus on these larger plants as these may include candidates for the most cost-effective
FGD installations. However, to determine which plants should be prioritised for FGD, the following
factors would need to be considered:
• Operating capacity (Do these plants run often or rarely? What is their annual coal
consumption?);
• The remaining projected lifetime for these plants – plants which plan to operate for longer
periods will give a higher return on investment.
The rate of FGD installation in India is far below what is required for the country to comply with the
new emission limits and to reduce pollution to levels which improve public health. The Indian
Government has prioritised compliance for those plants which are in regions close to densely
populated areas. However, it would be wise for stakeholders to analyse the current FGD installation
status across the country and consider targeting larger plants, with a decade or more of potential
remaining operation, and call for targeted and accelerated compliance at these units.
5.4 COSTS VERSUS BENEFITS

Cropper and others (2017) compared the cost of FGD installation with the benefits to the health of
those who live near coal-powered power plants in India. The estimated capital cost for FGD installation
was estimated as follows:
Wet limestone FGD Seawater FGD

Capital cost ($/MW) 109,091 94,364
Fixed operating cost ($/kWh) 0.473 0.364
Cropper and others (2017) estimated that the cost of removing SO2 with FGD was around 613 $/t. By
comparing this with the cost of treating SO2-associated health effects (such as heart and lung diseases
and cancer) it was noted that the investment in FGD would result in significant health sector savings.
By targeting 72 selected plants, almost 13,000 lives could be saved. Although the direct comparison of
FGD costs with the value of human life is not possible, Cropper and others (2017) concluded that
investment in FGD would have significant benefits to the health of the Indian population. The
cost-benefit would be highest if the location, age, and SO2 emissions of plants were taken into account
as this would facilitate the targeted reduction in emissions in areas where the pollution risks are highest
for the local population.
Whilst the benefits to the Indian population are clear, the issue is that the cost of sulphur control is
currently to be borne entirely by the utility. Most utilities argue that the cost is prohibitive – sulphur
control requires significant plant modification, new consumable expenses, operation and maintenance
44
SO2 CONTROL
costs, creates new by-product handling requirements and can reduce plant output by several
percentage points. Indian utilities consistently argue that the cost is prohibitive. In response, Tuli
(2020) proposes three measures to accelerate approval for FGD financing:
• Tariff increases – the cost of FGD can be passed to end users via tariff increases and this is
already in place in principle for plants with long-term power purchase contracts. This usually
allows lenders to be assured that their investment will be returned. However, the current
status of delays in India means that many investors will see lending for FGD as risky until an
advantageous tariff is confirmed;
• Cost pass-through – around 25 GW of power in India does not have a long-term contract
and therefore is struggling to find financing. These plants would also benefit from an
approved tariff which prioritised power from cleaner plants;
• Waiver of the clean energy ‘cess’ (levy) – coal plants have had to pay a levy, based on coal
burned, since 2010. Those plants with FGD could be excused from this levy, which would
help them recover investment costs sooner.
A tariff revision for the energy sector is already being considered to cover the expenditure on new
technologies and respective instructions and guidelines have been issued by the tariff regulators in
India. According to a recent media report (Mercom, 2021), the MOP had proposed a INR 835 billion
($10.44 billion) plan to meet the cost of FGD installation to improve air quality. The Forum of
Regulators has recommended that the clean energy levy, collected to the tune of INR 1.15 trillion
($14.4 billion) from 2010 to 2020, should be brought back to the electricity sector to mitigate the
incremental cost of FGD installation.
The Indian government could help accelerate the uptake of FGD by appreciating that, if the benefits
of emission control will be reaped by the population, then it is only fair that the costs be shared. The
use of tariffs and levies, as discussed above, could go a long way to accelerating investment in control
technologies by utilities.
The government could also help financially or bureaucratically by strengthening the pollution control
sector in India. An indigenous manufacturing base could be developed, national resources could be
utilised effectively, technology could be fine-tuned for local conditions, and skilled manpower could
be developed in India (MOP, 2021). However, this may initially require skilled training and input from
international experts and vendors.
5.5 COMMENTS
The predominant use of relatively low-sulphur coal in India offers the opportunity for a broad
selection of FGD technologies. Dry FGD systems are suited for Indian low-sulphur coals and use less
water than their wet FGD counterparts. They should be considered in areas which need to alleviate

45
SO2 CONTROL
existing and future water supply pressures. Dry FGD systems are particularly suited for smaller plants
and some systems can be integrated into existing PM control devices, thus reducing the requirement
for an additional footprint area at existing plants with space constraints.
Wet FGD systems are common internationally and can be just as effective on Indian plants as they are
elsewhere, although some plant modifications may be required (such as enhanced dust control
upstream). Wet FGD systems will require significant amounts of limestone and similar sorbents.
However, India has significant natural resources and healthy industry in these areas already. The
gypsum produced will generate a new and valuable by-product stream.
SWFGD systems are ideal for SO2 at coastal plants, as water and space requirements are reduced,
control efficiencies are high, and costs are lower than for other FGD options. However, the mercury
captured by SWFGD systems appears to be re-released into the sea or even volatilised into the local
air from SWFGD and this should be avoided.
Because only a small fraction of the coal-fired generating capacity currently has FGD installed, it is
unlikely that Indian operators will be able to meet the existing timeline for compliance with national
emission standards for SO2. From publicly available information, it appears that several power plants
are in varying stages of tenders for FGD systems. Construction, trials, and commissioning schedules
are not known for planned FGD. However, it is clear that few plants in the Indian coal fleet will meet
the compliance deadline. In this report, we have produced a ‘critical’ list of those plants which, due to
age, size, or activity, would be the most cost-effective targets for prioritised emission reduction.
Since the Indian population will benefit from reduced emissions, the costs to achieve these emission
reductions could be shared. This could be achieved through tariff and levy modification within the
existing financial arrangements established for the Indian grid.

46
MERCURY CONTROL
6 MERCURY CONTROL
Compliance with the current mercury standard in India (0.03 mg/Nm3) is not seen as a challenge by
coal-fired power plants since it is around an order of magnitude more lenient than the limits for most
plants in Europe and the USA. Some Indian coal-fired power plants will therefore comply without
taking any action. In February 2018, the MOEFCC submitted to the Supreme Court that “all units are
likely to meet mercury emission norms after installation of pollution control equipment (ESP, FGD and
SCR) as a co-benefit” (CSE, 2020b). The timeline for mercury reduction will therefore likely follow the
FGD installation timeline since FGD has the greatest co-benefit effect for mercury control. However,
for these co-benefits to materialise in the near future, air pollution control equipment for PM, SO2, and
NOx must be installed effectively and soon and must be well-maintained thereafter.
Although the current emission limit for mercury is relatively lax, it will probably be tightened in India
in the future, to align with tighter emission limits set internationally. It is therefore prudent for India
to ensure that mercury control is considered within current plant retrofit plans as much as possible, as
this could significantly offset mercury-specific control costs in the future.
Even with ESP, FGD, and SCR systems installed, mercury emission monitoring is critical to the
understanding of mercury speciation in flue gas, and the confirmation of mercury emission reduction.
The MOEFCC has not yet mandated mercury monitoring at all coal-fired power plants (CSE, 2020c)
although the most recent CEM guidelines specify mercury real-time monitoring in coal-fired power
plants that have this condition within their Environmental Clearance permit. Additionally, some State
Pollution Control Boards have started to ask for the installation of mercury CEM at coal plants (Sloss
and others, 2021a). The more mercury monitoring is carried out, the greater the understanding the
industry will have on whether co-benefit mercury reduction is indeed reducing mercury emissions.
6.1 CO-BENEFIT MERCURY REDUCTION

The United Nations Environment Programme (UNEP, 2021) has produced a best practice guidance
document on mercury reduction from coal-fired power plants to be used by signatories of the
Minamata Convention. The interested reader is referred to this detailed document for more detail and
also to several previous ICSC reports on this subject (Sloss, 2021b, 2017, 2015). The following sections
will summarise mercury reduction strategies with particular focus on how these can be relevant to
India.
Most if not all of the emission reduction technologies discussed in previous chapters of this report, for
PM, NOx and SO2, will have a significant effect on mercury reduction, as a free co-benefit effect. The
potential for mercury reduction through PM, SO2 and NOx control systems is dependent on the
chemistry of the coal and the type and configuration of the pollution control system:

47
MERCURY CONTROL
• ESP systems for PM control provide limited mercury co-benefit control as only a fraction of
the mercury is captured on particulates;
• FF for PM control can offer greater mercury control than ESP since the residence time on
the filter is longer, allowing more opportunity for mercury to adsorb to fly ash, especially
any unburnt carbon;
• SCR systems for NOx control use catalysts which can also oxidise mercury, promoting its
capture in downstream pollution control systems (such as PM devices or FGD);
• Dry FGD systems can absorb mercury into the dry by-product and wet FGD systems can
capture mercury in both the wastewater and the gypsum.
Although numbers can be quoted for mercury co-benefit capture in these systems, they generally
range from 0–95% and are highly dependent on everything from the coal chemistry to the plant
configuration. It is therefore not appropriate to assume any value to estimate mercury capture in
Indian coal plants without further, more detailed analyses.
The inherent mercury capture by pollution control systems can generally be enhanced in one of two
ways:
• Sorbent injection – to provide an attractive surface to which mercury will adhere.

• Oxidation – the use of chlorine or bromine to convert elemental mercury to oxidised
mercury so that it will either adsorb to a sorbent (usually a form of activated carbon) or
dissolve in FGD process water.
Oxidants can be added in combination with sorbents to maximise both effects. It is easiest to
summarise the effect through a flow chart as shown in Figure 13a and 13b. Figure 13a focuses on plants
with no NOx control (or SNCR only) and Figure 13b focuses on plants with NOx control.

48
MERCURY CONTROL
Figure 13 Mercury co-benefit flow chart (authors’ work)
The options in Figure 13a and 13b are largely the same, with only minor variations in the use of
activated carbon and/or sorbents, depending on the assumed inherent oxidation provided by any SCR
system in place.
The flow chart is intended only as a guideline, any decision on plant modifications or additives must
be based on results from investigative trials at the plant in question or relevant modelling.
As much as possible, the UNEP guidance includes details of the potential costs of mercury control
options. Since these vary with technology as well as with geographical considerations such as
availability, the costs are given qualitatively, as shown in Table 8.

49
MERCURY CONTROL
TABLE 8 RELATIVE COST OF MERCURY REMOVAL (UNEP, 2019)
Approach Capital cost O&M cost Comments
Coal washing Moderate Low Washing less expensive than chemical

treatment
Coal blending Very low Very low May require adjustment and/or
refurbishment of pulverisers
Hg oxidation additives Very low Low Halogenated additives significantly

increase Hg oxidation and capture
Re-emission control additives Very low Low Potential for re-emission of Hg should be
mitigated
Selective Hg-oxidation SCR Low Low Only referring to Hg-specific catalyst, may
catalyst* require coal blending
Activated carbon injection (ACI) Low Low to Preservation of ash quality an issue.
moderate Higher incremental costs for
‘concrete-friendly’ sorbents
* with downstream FGD
Even the costs for the most ‘advanced’ options for enhancing mercury co-benefit capture (such as ACI
injection) are considered low or moderate compared to other pollution control retrofits (such as for
PM, SO2 and NOx control).
6.2 POTENTIAL FOR MERCURY REDUCTION IN INDIA

As mentioned in previous chapters, India is moving to control emissions from their coal-fired power
plants to comply with their emission regulations for PM, NOx, and SO2. As these technologies are
installed, there will be a co-benefit reduction in mercury emissions.
The Indian government expects that the current requirements for PM, SO 2 and NOx will ensure that
all coal-fired power plants in India will automatically comply with the mercury emission limit due to
co-benefit effects. In this study, we want to confirm if this is true.
This section of the report will present novel calculations to illustrate the potential for mercury
co-benefit capture for the ‘average’ Indian coal and a hypothetical 500 MW unit in a coal-fired power
plant. The predictions in this section were made with the iPOG (integrated Process Optimisation
Guidance model) produced for the UNEP Coal Partnership Area by Niksa Energy Associates, USA. The
use of the iPOG for estimating mercury emissions from plant-specific data is discussed in more detail
in the previous ICSC report by Sloss and others (2021b).
To determine the ‘average’ Indian coal for this exercise, an analysis of coal production in India was
conducted. Over 80% of the total coal production in India in 2020-21 was produced by Coal India Ltd
(CIL). India’s coal production during 2020-21 was 716 Mt. For the same period, coal production of CIL
was 596 Mt (MOC, 2022). CIL has seven major coal-producing subsidiary companies: Central

50
MERCURY CONTROL
Coalfields (CCL), Eastern Coalfields (ECL), Bharat Coking Coal (BCCL), Northern Coalfields (NCL),
Western Coalfields (WCL), Southern Eastern Coalfields (SECL), and Mahanadi Coalfields (MCL)
(UNEP, 2014). Coal production in 2020-21 by the combined NCL, SECL, and MCL was around 70% of
total CIL production. Thus, for this analysis, it is reasonable to assume the characteristics of an ‘average’
coal based on the properties of the combined NCL, SECL, and MCL coals, as shown in Table 9 below.
TABLE 9 ‘AVERAGE’ COAL PROPERTIES FOR THE CO-BENEFIT ANALYSES (AUTHORS’ ANALYSIS)
Production, Moisture, Ash, GCV, Sulphur, Mercury,

million ton % % kcal/kg % ppm
(2020-21)
NCL Coal 115.04 7.1 31.5 4437 0.37 0.21
SECL Coal 150.61 6.2 25.4 5318 1.09 0.14
MCL Coal 148.01 5.9 40.1 3779 0.46 0.20
‘Average’ coal 6.4 32.3 4511 0.64 0.18
* Coal properties from UNEP, 2014
The values for this ‘average’ Indian coal were applied within the iPOG to predict the effectiveness of
different pollution control technologies to reduce mercury emissions in India via co-benefits, as
detailed in the Sections to follow.
Assumptions were made to allow for the evaluation of the mercury concentration in flue gas for
different plant configurations using the iPOG. The iPOG predicts mass emissions of mercury, for
example as gHg/h. However, the mercury concentration in the flue gas (in µg/m3) would be more
informative for potential users, allowing a direct comparison of potential emissions against the
emission limit. The current Indian standard for mercury emissions is lenient at 30 µg/m3. By
presenting the iPOG results in µg/m3 we can determine how mercury emissions could be reduced
beyond the current emission limit. We have used the following assumptions to covert the g/h iPOG
output to µg/m3 values for an average 500 MW unit:
• the unit burns the ‘average’ coal described above for power generation;
• the 500 MW unit has 35% efficiency and produces approximately 700 m 3/s of flue gas;
• the unit is operated under ‘typical’ combustion parameters of 110% excess air in the boiler
and has 10% air heater in-leakage.
The numbers given in the following section are of an engineering estimate nature. The actual amount
of flue gas produced by the unit will depend on operational combustion conditions in the furnace (heat
rate, excess air and so on), coal quality and preparation (milling), or maintenance of the facility
downstream of the boiler (in-leakages). The best determination of actual mercury concentration in
the flue gas is stack sampling and continuous emission monitoring. However, since such data are not

51
MERCURY CONTROL
yet available in India, we are providing a ‘best guess’ of mercury emissions from an average Indian
500 MW coal-fired power plant firing average Indian coal.
Assuming the characteristics of the ‘average’ Indian coal, the iPOG predicts that a 500MW unit installed
with ESP only will remove only 3.5% of the mercury introduced into the unit with the coal. As a result,
the plant mercury emissions would be estimated at around 52 g/h, as shown in Figure 14 below.
Figure 14 Emissions of mercury from a 500 MW unit with ESP only
With combustion conditions assumed as described above, this would correspond to a flue gas mercury
concentration of around 21 µg/m3, which is below the 30 µg/m3 emission limit. These predictions were
made for a well-maintained ESP. Should the ESP perform below its specifications or should the plant
fire coal with a higher mercury content, then the mercury removal rate would be lower and the
corresponding mercury concentration in the flue gas would be higher.
For comparison, the same unit was simulated with an FF installed in place of an ESP. In this situation,
the mercury removal was predicted to increase to over 25% with lower mercury emissions of about
40 g/h (flue gas concentration of 16 µg/m3). Based on these estimates, it is likely that all plants in India,
with efficient ESP or FF, can comply with the current mercury emission limit of 30 µg/m3.
The iPOG was used to predict mercury emissions in a plant where a wet FGD has been installed
downstream of an ESP. Emissions from the unit with ESP and wet FGD are projected to be 43 g/h
(around 17 µg/m3), comparable to previously estimated emissions from this unit equipped with a
fabric filter. The iPOG results estimate that a unit with an ESP and wet FGD would produce
significantly different mercury speciation compared to the same unit with ESP only. The ESP-only unit
52
MERCURY CONTROL
would release about 70% of total mercury emissions as elemental mercury. The ESP + wet FGD unit
would release almost all of its mercury emissions as elemental mercury.
Oxidised mercury is highly soluble and can be almost completely captured in a wet FGD and so, if the
speciation of mercury could be shifted more towards the oxidised form, a wet FGD could achieve
higher total mercury removal. One approach to increase mercury oxidation is through the addition of
bromine to the coal. According to the iPOG calculations, the addition of 200 ppm of bromine would
achieve over 40% emission reduction for the unit with wet FGD, or mass emissions of about 30 g/h.
These mass emissions would correspond to a mercury concentration of approximately 12 µg/m3.
The iPOG also suggests that approximately 22 g/h of mercury emissions could be avoided due to the
installation of bromine enhanced wet FGD (in addition to ESP) on a single 500 MW unit. This 44%
mercury emission reduction rate would translate into almost 200 kg of mercury emissions averted in
a year from this one hypothetical 500 MW unit. The corresponding mercury concentration in the flue
gas would decrease from about 21 µg/m3 to 17 µg/m3.
By adding SCR to the plant, the iPOG estimates that over 60% mercury removal could be achieved,
(see Table 10) reducing mercury emissions to 20 g/h – approximately 8 µg/m3. The SCR+ESP+wet
FGD system performance could be improved further by the addition of chlorine to the coal. The iPOG
predicts mercury mass emissions of 10 g/h (4 µg/m3 in the flue gas) with 100 ppm of chlorine addition.
TABLE 10 POTENTIAL MERCURY REDUCTION AT INDIAN PLANTS, ESTIMATED WITH THE IPOG (AUTHORS’ ANALYSIS)
PM SO2 NOx Halogen Mercury Mercury Mercury Reduction

control control control addition emission, emission, reduction, in
g/h µg/m3 % emissions,
kg/y
ESP None None None 52 21 4 10

FF None None None 40 16 25 93
ESP Wet FGD None None 43 17 19 70
ESP Wet FGD None Br in coal* 30 12 44 163

ESP Wet FGD None Br in 43 17 19 70
FGD**
ESP Wet FGD SCR None 20 8 63 234
ESP Wet FGD SCR Cl 12 5 77 290
ESP = electrostatic precipitator; FF = fabric filter; ppmw = parts per million by weight
Annual emissions at full load and 80% capacity factor
Concentrations for 2,500,000 m3 /h flue gas flow
Coal: 0.18 ppmw Hg and 0.64% S
Uncontrolled Hg emissions 375 kg/y
Additives: * 200 ppmv Br in coal; ** 0.008 g/m3 Br in flue gas
It is important to note that these values are based on extremely basic and generic assumptions and use a
model rather than any real measurements. These results should not be used as the basis for any technology
choices but could be used to direct further plant analyses and to inform pilot or slipstream projects.

53
MERCURY CONTROL
These iPOG estimates suggest that the application of current and impending emission limits for PM,
SO2 and NOx could help reduce mercury mass emissions by up to 50% or more. This reduction could
be accomplished by the installation of additional equipment such as SCR and/or wet FGD to achieve
NOx and/or SO2 emission limits, respectively. However, as shown above, additional measures to
improve mercury oxidation in addition to SCR and/or wet FGD could reduce mercury concentration
in the flue gas to below 10 µg/m3.
The two scenarios presented above that predicted mercury concentrations below 10 µg/m3 were:
• ESP+wet FGD+ 200 ppm bromine addition; and

• SCR+ESP+ wet FGD+300 ppm chlorine addition.
Neither of these scenarios may be particularly attractive to Indian utilities currently. The first scenario
relies on the addition of significant amounts of bromine, which may promote corrosion and thus may
require enhanced, more expensive, materials for the construction of downstream equipment and
ductwork. The second scenario relies on the deployment of SCR which is an expensive technology
(see Chapter 4).
The illustrative co-benefit mercury reduction values for India presented above are relatively low
compared to other countries. For example, the majority of coal plants in the USA managed to reduce
emissions to comply with an emission limit of around 3 µg/m3 through co-benefit effects alone.
According to our iPOG estimates, Indian utilities would find it difficult to achieve mercury
concentrations below 10 µg/m3 without the introduction of mercury-specific control technologies
(discussed in Section 6.2 to follow). The use of mercury-specific control technologies could eliminate
the challenging scenarios, including abrasive halogens, presented above and could prepare Indian
utilities for the future tightening of the currently somewhat weak mercury standard.
6.3 MERCURY-SPECIFIC CONTROL OPTIONS FOR INDIA

Although the mercury emission standard is currently lenient in India compared to other countries,
mercury emissions are likely to be reduced significantly as a result of the emission limits placed on
other pollutants. This may mean that Indian stakeholders will regard mercury-specific control as a low
priority in the near term. However, as discussed above, any more stringent mercury standard could
be difficult to comply with through co-benefit alone. The estimates in Table 11 suggest that the tactical
addition of halogens such as chlorine and bromine could build on co-benefit mercury control to bring
emissions down almost to the emission limits set in Europe and the USA (1–3 µg/m3). However, this
approach would have to consider the potential corrosive damage to plants from using these chemicals
and plan measures to minimise this effect.
As international commitments to the aims of the UN Minamata Convention on Mercury (to which
India is a ratified party) tighten, mercury emission limits in India may eventually tighten to the point
54
MERCURY CONTROL
where they would require significant mercury emission reductions, forcing unit operators to consider
the need for mercury-specific control strategies.
One such example of a common mercury-specific control technology application is shown below in
Figure 15 for the same set of assumptions as used in Section 6.2 for coals and plant configurations in
India.
Figure 15 Mercury emissions from a 500 MW unit with ACI
If untreated (non-brominated) ACI were injected (at a rate of 0.032 g/m3), this could achieve a
moderate mercury removal rate of 38%, with a mass emission rate of 33 g/h and a mercury
concentration in the flue gas of 18 µg/m3, comfortably below current standard but probably not
enough to meet any tightened standard. However, brominated ACI at the same rate could result in a
dramatic reduction in mercury emissions. A removal rate of 84% could be achieved (mass emission of
8.8 g/h). This corresponds to approximately 5 µg/m3 of mercury in the flue gas, almost at the low
emission standard level set in regions such as the USA and Europe.
Whilst the use of ACI for mercury control is established in regions such as the USA, it does require
the retrofitting of sorbent injection systems and can create new waste issues.
6.4 MULTIPOLLUTANT CONTROL OPTIONS FOR INDIA

The ICSC report by Sloss (2015) lists the current commercial options for mercury control through
multipollutant technologies as well as mercury-specific systems. These include:

55
MERCURY CONTROL
• Advanced PM controls such as TOXECON (a combined ESP and FF system designed by

EPRI);
• Catalytic filter systems such as SNRB (SOx-NOx-ROx-Box process, designed by Babcock and
Wilcox);
• Advanced regenerating sorbents.
There are also advanced mercury-specific control technologies which are either commercially
available or at the trial stage such as NeuStream, ReACT, Lextran, CEFCO and so on. The current
development status installed capacity of these multipollutant control options for mercury would need
to be established before serious consideration is given to any of them for the Indian challenge. The
mercury control technology marketplace has slowed somewhat due to the reduction in international
sales. US plants are largely compliant with the national emission standards already and in Europe, those
plants which exceed the mercury emission limit are likely to be on a path to closure anyway (due to
the move away from carbon-based power). Asian countries such as China and India have installed their
own advanced control systems for mercury, although in most cases co-benefit methodologies have
been sufficient.
The market for mercury-specific emission controls in India will not emerge until the emission limits
in India tighten to the point where co-benefit effects will not be enough. However, with the delays and
derogations for compliance with emission standards for PM, SO2 and NOx still ongoing, any move to
tighten limits for mercury is likely to be a long way off.
6.5 CONCLUSIONS
India introduced an emission limit for mercury from coal-fired power plants in 2015. However, the
limit (30 µm/m3), is lenient compared to those in other countries (an order of magnitude tighter in
most cases). The limit is unlikely to require dedicated mercury removal strategies at any Indian
coal-fired power plants.
India has set stringent emission limits for PM, SO2 and NOx. If and when Indian coal plants comply
with these emission limits, mercury emissions will also be reduced due to co-benefit effects. Although
these co-benefit effects may only be around 50% in most plants (when they are installed with ESP/FF
and FGD), they will result in a significant reduction in mercury emissions at no added cost. However,
currently, only nine power plants are known to have FGD installed – around 10 GW, out of India’s
over 230 GW installed coal-fired capacity. Any mercury co-benefits effects will therefore be delayed
as long as Indian sources continue to delay and derogate the current emission limits.
Although Indian coal plants will see mercury reduction through co-benefit effects, our study suggests
that further reduction in mercury emissions down to the emission limits seen in other countries (such
as around 1–3 µg/m3 in Europe and the USA) will be challenging. Indian coals do not appear to respond

56
MERCURY CONTROL
well to oxidation strategies, and these may be seen as risky in Indian due to the corrosive nature of the
chemicals used. Whilst activated carbon could reduce mercury emissions down to low levels, this
requires modifications to existing PM systems and may create new waste challenges. Since the current
mercury emission limit is relatively lenient, Indian stakeholders should take advantage of this period
to monitor mercury behaviour in Indian plants closely to ensure that, if and when emission limits
tighten, appropriate strategies for India have been determined.
The new mercury emission standard, although not challenging and requires only minimal compliance
effort, does have the benefit of requiring coal plants to monitor mercury emissions regularly. This
information will be useful to determine whether mercury emissions are of concern at some plants and
if so, whether targeted action would be appropriate. Emission information will also be useful to
confirm the efficacy of co-benefit effects and, based on plant comparisons, maximise these as
appropriate. As shown in the previous report on CEM (Sloss and others, 2021a), there are few, if any
mercury monitoring systems currently in place and operational in India.

57
ONGOING AND EMERGING CHALLENGES
7 ONGOING AND EMERGING CHALLENGES

The previous chapters of this report have highlighted some of the bureaucratic, technical and
economic challenges of emission reduction across the Indian coal utility fleet. The following sections
highlight some additional and emerging challenges which have not been covered so far.
7.1 CHALLENGES TO FINANCIALLY VIABLE PLANT OPERATION

The Energy and Resources Institute, India (TERI, 2020) produced a discussion paper on the challenges
of the emission limits for the existing fleet and summarised their conclusions according to which
stakeholders were affected:
• DISCOMS (energy distribution companies) will face new challenges in balancing the
delivery of electricity to the grid while completing the technical requirements associated
with compliances (such as shutdown during refurbishment).
• The GENCOS (generation companies) are more concerned is more about cost – the costs of
retrofitting and ensuring that the correct choice of control technology is made as well as
recouping these costs through tariffs. There also appears to be concern over a lack of bidders
for projects, which would suggest a shortage of availability of pollution control technology
suppliers and vendors within and available to India.
• For manufacturers and suppliers, the issue is both technical (such as access to the plant,
availability of materials and the availability of qualified staff) as well as with time to
implement retrofits. Manufacturers/suppliers are asking for clearer guidance on what
technologies are most popular as well as more time to build up both the skillsets and the
materials to deliver the retrofits.
• Funders are confused over which plants are most appropriate for investment and are
hesitant over investing in plants which may not be able to recuperate spending over their
remaining operating life.
There appear to be several actions which would go a long way to accelerating the sector whilst
addressing many of the issues listed above, including:
• A reconsideration of allocated power contracts. Any long-term contracts should be

negotiated to allow power plants to remain economically viable while offline for retrofitting.
• The CEA should provide clearer guidance on what technologies they recommend, including
publishing case studies to accelerate sharing of lessons learned. These guidelines should be
updated regularly to allow the addition of new and emerging emission reduction options.
CEA should also publish details of costs for projects, to allow appropriate planning for plants
as they proceed to bids and tenders.

58
• Tariffs should be redesigned to provide high payments and or more frequent contracts for
plants with lower emissions.
• Greater cooperation and honesty between vendors and equipment providers on costs, time
for retrofits and potential secondary effects on plant operation.
• There should be guidance to help plants determine whether the cost of investment in
pollution control will be recovered over the remaining plant lifetime. This is problematic but
could still be improved through clarity on future energy requirements, examples of real costs
from case study plants, adjustment in the tariff to prioritise ‘cleaner plants’.
In their brief report, TERI concludes that there needs to be more sharing of experience from early
uptake plants to ensure that lessons learned are passed through the fleet. This will help to expedite
decision-making and lower the perceived risk of significant plant modifications. The report also
strongly supports the concept of emission-based dispatch, whereby cleaner plants are given priority
access to the grid. This may cause changes in costs, due to higher electricity prices for plants recovering
retrofit investment costs. However, as mentioned in Chapter 1, any cost for cleaner plants will be more
than offset by the improvements in the health of the Indian public. How these costs are shared between
power producers, distributors, end users and the government (through subsidies or support) needs to
be clarified.
7.2 CHALLENGES WITH ENFORCING COMPLIANCE

To demonstrate that emission standards are being met, coal-fired utilities are required, by law, to
report their emission data directly to the authorities in India. This is a significant technical challenge,
as discussed in the complementary report for USDOS (Sloss and others, 2021a). The CPCB keeps an
updated list of industries which have not submitted details of their compliance reporting protocols.
According to information available in 2018, 24 out of the 28 States and 4 out of 8 Union Territories
named power plants which had not yet filed their reporting plans (CPCB, 2021). The list has not been
updated since 2018.
Sloss and others (2021a) detailed the technical requirements for all coal plants to feed data direct from
continuous emission monitors (CEM) to computing systems hosted by the regional pollution control
boards. The online reporting system is designed to ensure that the pollution control servers send alerts
to sources (coal plants) in situations of emission exceedance or incomplete CEM data submission (CSE,
2021a). However, according to the CPCB, the objective of the requirement to install CEM with
real-time data transfer capabilities at power plants was to initiate self-monitoring – not necessarily to
create a policing command and control centre. And so, even though monitoring data are received by
the CPCB, the board does not validate the data except on limited occasions. CPCB received CEM data
from approximately 90 GW in 2016 and from over 160 GW in 2021. However, CSE analysis found that
only 40–50% of the units regularly transmitted data from CEM to the regulators. This could be due to

59
malfunctioning of the CEM, CEM and/or units out-of-service, or reporting non-compliance (CSE,
2021a).
As noted by Aggarwal (2018), the CPCB does not have enough staff to check all the industries and all
the alerts raised by the online system. Inadequate staffing has often been mentioned with the number
of employees ranging from as few as 75 for Bihar SPCB to 200 for Delhi SPCB, and up to 1000 for the
Maharashtra SPCB (RAP, 2019). The Regulator Assistance Project (RAP) study notes that there is a
significant staffing problem in the northeastern SPCBs.
Kanchan (2019) states that the current approach of self-reporting is largely inefficient for controlling
emissions from power plants. In instances when a pollutant emitted by a power plant is over the
emission limit, the system only sends a text message to the power plant. Based on the number of text
messages, the plants should take appropriate action to control emissions. However, the enforcement
of compliance is lacking. This current system of non-enforcement exists largely because of claims that
the quality of CEM data generated is poor and therefore plants cannot be held responsible for default
based on the data generated by them. Further, there is a lack of ability to hold plants accountable for
their emissions. Currently, non-compliant sectors cannot be fined by the regulators. Instead, there is
a long-drawn-out process of filing a case in a court of law. The courts have jurisdiction to impose fines
or penalties. However, since environmental cases are not often a priority for courts, there is a
significant backlog of these cases. These delays combined with a low rate of convictions result in a
reduction in the efficacy of compliance enforcement (CSE, 2020a).
The International Initiative for Impact Evaluation (I3E) conducted a pilot project on the usefulness of
CEM for controlling the extent of air pollution in India (I3E, 2020). The project was run in
coordination with MOEFCC and the Gujarat SPCB. The authors concluded that it was unclear if the use
of CEM has had an impact on emissions from any given source. Industries were not changing their
behaviour because of the absence of a structured methodology for regulators to use – the regulators
could not enforce any penalties based on the data provided.
CEM data are therefore not being used effectively as a legal compliance check tool because of the
absence of legally binding requirements by relevant Acts and Rules. For real-time CEM data to be
effective in police compliance, amendments must be made to the Air (Prevention and Control of
Pollution) Act, 1981, the Water Pollution (Prevention and Control of Pollution) Act, 1974 and the
Environment (Protection) Act, (Kanchan, 2018). There is no known legal initiative in India to do so
at the time of preparation of this report.

60
7.3 NEW CHALLENGES – BIOMASS COFIRING AND PLANT

FLEXING
Although not considered in this report, there is the potential for significant change in fuel properties
in India which could affect emission control efficiencies. These could include:
• Fuel switching and blending – variations in production rates and costs may mean that
Indian plants switch from domestic to imported coals which will have different ash
properties and combustion characteristics;
• Coal cleaning – treatment of coal at the mine and/or before combustion can remove ash and
other impurities which will lead to improved combustion performance and lower ash
content;
• Cofiring of biomass – the MOP has asked states to propose means for increasing biomass
cofiring at power plants and to formulate means to include this cofiring within new tariffs
(TOI, 2022). Aggarwal (2022b) notes that the aim to replace 5–7% of coal with biomass
could be challenging to the existing infrastructure, in terms of supply and delivery.
Concerning emissions, biomass contains less sulphur and is carbon neutral. However, the
characteristics of biomass can affect combustion conditions and the effect on downstream
pollution control systems such as ESP and FF should be monitored.
Another significant issue for the existing Indian coal fleet will be operational flexibility – their ability
to ramp up and down to increase and decrease power to offset any fluctuation in grid demand caused
by the variability of increasing volumes of renewable energy. The ICSC has recently produced a report
and a training course on flexibility in India (Sloss and Storm, 2021) and so this will not be discussed
in detail here. However, it is important to note that increased plant flexibility can put significant strain
on the operation which, in turn, can lead to issues with ESP and FF performance, especially at low
loads. These include problems such as corrosion, ash re-entrainment and reduced capture efficiency.
Plants moving to more flexible operation should ensure that any changes are monitored and controlled.
7.4 COMMENTS
The previous chapters of this report have reviewed the emission limits set in India and the
technologies available for plants to comply with those emission limits. The techniques and
technologies are readily available – and so why is India unlikely to meet its compliance deadline?
There is a combination of challenges:
• Bureaucratic – the emission standards have been undergoing continuous modification and so
utilities are loath to invest in upgrades until the guidelines are clear.
• The technologies are relatively new to India and so costs and timelines for retrofits, as well
as the availability of materials and expertise, are relatively undefined.
61
• The cost for plant upgrading currently lies entirely with the utility. Funding is problematic as
it is unclear whether plants can recover the cost of compliance over their remaining
operating lifetime.
• Data on actual plant emissions are scarce – emission monitoring for compliance is not yet
functional across the fleet and so plants are rarely held to account for their emissions or lack
of control technologies.
• New discussions on the potential requirements for biomass cofiring across the Indian coal
fleet could significantly affect emissions as well as the efficacy of emission control
equipment.
• The increase of variable renewable energy in India will require the coal fleet to ‘flex’ – to
ramp operations up and down to meet demand. Coal plants operating in a flexing mode can
be less efficient than plants operating at base load and the effectiveness of emission control
strategies can also be reduced during flexing mode.
India faces many current and emerging strategies which make it challenging for coal plants to
determine if, when and how they can best install control technologies. Clarity from the Indian
government and related power sector agencies would go a long way to help plants in the
decision-making process. This could be achieved through the sharing of case studies, clarity on the
most appropriate technologies and their costs and, perhaps most importantly, a rethink of the
electricity tariff system to ensure that the cost and risk of upgrading and retrofitting plants does not
become the main barrier that stalls compliance.

62
CONCLUSION AND RECOMMENDATIONS
8 CONCLUSION AND RECOMMENDATIONS

The Indian Government has set emission limits for PM, SO2 and NOx which, once implemented, will
significantly reduce emissions. However, the implementation of these limits relies on cooperation and
participation from industries and stakeholders at a level of flexibility that is not seen elsewhere. The
Indian government continues to allow delays and derogations in the implementation of these emission
limits based on arguments from the utilities, most if not all of which are surmountable. Over 40% and
up to almost 70% of the fleet could be compliant with the new emission limits by the deadline, based
on current tenders and projects. Any continuing fluidity of policy will result in wasted time and money
as well as significant loss of life. The financial analyses are clear – in terms of lives saved, improvement
to the public and health services and increase in GDP, ‘expensive’ emission control systems pay for
themselves. Enforcement of the current limits would result in an over 80% reduction of SO2, NOx and
PM by 2030. At the same time, public health would be improved significantly, deaths would be reduced,
and the costs of air pollution-associated health issues could be reduced by over US$1.1 billion by 2030,
far outweighing the cost of compliance.
Some stakeholders within India argue that Indian coals differ from those used elsewhere (they are
higher in ash, have lower volatility and can be lower in sulphur) and suggest that, because of this,
emission control technologies which succeed elsewhere in the world will not work as well in India.
Whilst Indian coals will sometimes prove more challenging than other coals, studies have shown that
modifications to the plant and the control technologies can ensure that the reduction efficiencies for
PM, SO2 and NOx achieved elsewhere can be achieved in India too.
The one pollutant which may remain challenging will be mercury. Co-benefit reductions of up to 50%
may be achievable in many Indian plants which install PM, SO2 and NOx controls. Maximising mercury
reduction through co-benefit routes should be built into all emission reduction tenders for any
pollutant within India going forward. This will reduce the need for, and cost of, mercury-specific
reduction strategies in the future.
The technical challenge of emission control in India is currently less significant than the economic and
bureaucratic challenge. India can achieve emission reduction but to do so requires clearer guidance
which should include shared experience and lessons learned from plants which have already been
through the compliance process. This could include the establishment of in-country skills and a highly
qualified Indian pollution control sector, in alignment with the national ‘self-reliant India’ goals.

63
REFERENCES
9 REFERENCES
Adams D, Lockwood T, Baruya P, Wiatros-Motyka M, Zhu Q (2021) A pathway to reducing
emissions from coal power in India. IEACCC/CIAB. London, UK, International Centre for Sustainable
Carbon, 147 pp (January 2021)
Aggarwal M (2018) CPCB pushes for broader adoption of emissions monitoring systems. Available
from: https://india.mongabay.com/2018/09/cpcb-pushes-for-broader-adoption-of-emissions-
monitoring-systems/ Mongabay, 1 pp (Sep 2018)
Aggarwal (2022a) Polluting coal power plants may get a blanket 20-year extension of compliance
deadlines. Available from: https://www.downtoearth.org.in/news/pollution/polluting-coal-power-
plants-may-get-blanket-20-year-extension-of-compliance-deadlines-83022 Down to Earth, India,
2 pp (May 2022)
Aggarwal (2022b) Biomass co-firing: why India’s target for coal power plants is challenging.
Available from: https://www.downtoearth.org.in/news/energy/biomass-co-firing-why-india-s-
target-for-coal-power-plants-is-challenging-83261 Down to Earth, India 2 pp (Jun 2022)
BEE (2021) Chapter1: Fuels and Combustion. Available from:

https://beeindia.gov.in/sites/default/files/2Ch1.pdf New Delhi, India, Bureau of Energy Efficiency,
26 pp (accessed 2021)
BHEL (2016) New environment norms on NOx for thermal power generation. Available from:
http://www.eecpowerindia.com/codelibrary/ckeditor/ckfinder/userfiles/files/1_BHEL%20New%2
0Environmental%20Norms%20on%20NOx%20PART%201.pdf (Apr 2016)
CEA (2017) Standard Technical Specification for Retrofit of Wet Limestone Based Flue Gas
Desulphurisation (FGD) System in a Typical 2 X 500 MW Thermal Power Plant, Central Electricity
Authority, New Delhi, India, 448 pp (2017)
CEA (2019) CEA recommendation on operational norms for thermal generation stations. Available
from: https://cercind.gov.in/2020/draft_reg/Appendix%20I.pdf (2019)
CEA (2020a) Advice on FGD Technology Selection for Different Units Size (from 07th February 2020
onwards), Central Electricity Authority, New Delhi, India, 5 pp (2020)
CEA (2020b) Renovation & Modernisation of Thermal Power Stations. Available from:
https://cea.nic.in/wp-content/uploads/notification/2020/12/TRM_Sep_09_2020.pdf Quarter:
Jul-Sep, p 10-12 (2020)
Conrads H (2020) PROMECON process measurement control GmbH, Steinfeldstraße 5, 39179

Barleben, Germany, personal communications (Oct 2020)
CPCB (2019) Annual report 2018-2019. Available from: https://cpcb.nic.in/annual-report.php

Delhi, India, Central Pollution Control Board, 160 pp (Apr 2019)
CPCB (2021) Updated state-wise list of industries which have not submitted information through
Compliance Reporting Protocol to CPCB as of 13.12.2018. Available from:
https://cpcb.nic.in/updated-list-of-industries-who-have-not-submitted-information-through-crp-1/
New Delhi, India, Central Pollution Control Board, 1 pp (accessed Feb 2021)
Cropper M, Guttikunda S K, Jawahar P, Malik K, Partridge I (2017) Costs and benefits of installing
flue gas desulphurisation units at coal-fired power plants in India. Chapter 13. Disease Control
Priorities, Third Edition (Volume 7): Injury Prevention and Environmental Health, pp 239 -248
(Oct 2017)

64
REFERENCES
CSE (2016) Clearing the Air – Pollution control technology for coal-based power plants. Available from:
https://www.cseindia.org/regulators-workshop-on-power-sector-compliance-and-enforcement-
6699 p 9 (2016)
CSE (2020a) Status of compliance monitoring and enforcement in India. Available from:
https://www.cseindia.org/status-of-compliance-monitoring-enforcement-in-india-10036 New Delhi,
India, CSE Centre for Science and the Environment, 17 pp (Mar 2020)
CSE (2020b) Report on the need for a certification system for CEMS in India. Available from:
https://cdn.cseindia.org/userfiles/report-on-need-of-certification-system-for-CEMS-in-India.pdf
New Delhi, India, CSE Centre for Science and the Environment, 17 pp (Mar 2020)
CSE (2020c) Coal Based Power Norms- Where Do We Stand Today. Available from:
https://www.cseindia.org/coal-based-power-norms-coal-based-10125 New Delhi, India, CSE Centre
for Science and the Environment, 120 pp (2020)
CSE (2020d) An Ashen Legacy. Available from: https://www.cseindia.org/an-ashen-legacy-10422

New Delhi, India, CSE Centre for Science and the Environment, vp (2020)
CSE (2020e) Coal-based Power Norms - Where Do We Stand. Available from:

https://www.cseindia.org/coal-based-power-norms-coal-based-10125 New Delhi, India, CSE Centre
for Science and the Environment, p 28 (2020)
CSE (2020f) Flue gas desulphurisation. Limestone availability and gypsum use. Available from:
https://www.cseindia.org/content/downloadreports/10043 New Delhi, India, CSE Centre for
Science and the Environment, 30 pp (2020)
CSE (2021a) Overview of CEMS and CEQMS. Presented during Online Training Programme on
“CEMS and CEQMS- Technology selection, its installation, Data Handling and its Audit
Methodology” July 14-27 (2021)
CSE (2021b) Understanding Environmental Laws for Better Environmental Management. Available
from: https://cdn.cseindia.org/attachments/0.50244100_1625478271_ad-on-online-training-on-
understanding-environmental-laws.pdf Sep 1-10 (accessed 5 Aug 2021)
CSE (2022) CSE Coal Power Watch. Available from: CSE Coal Power Watch (cseindia.org) (accessed
12 April) (2022)
Fortum eNext (2020) White paper Employing Primary Methods for NOx emission reduction (2020)
GE (2019) GE Power Wins INR 142 crore Contract for NOx Reduction Technology Across 10GW Power
Plants In India. Available from: https://www.ge.com/news/press-releases/ge-power-wins-inr142-
crore-contract-nox-reduction-technology-across-10gw-power Sep 1-10 (2021)
He J, Chen K, Xu J (2017) Urban air pollution and control. Encyclopaedia of Sustainable Technology;
Available from: https://www.sciencedirect.com/topics/engineering/dry-flue-gas-desulfurisation-
technology 243-257 (2017)
HEI, Health Effects Institute (2018) Burden of disease attributable to major air pollution sources in
India. Available from: https://www.healtheffects.org/system/files/GBD-MAPS-SpecRep21-India-
revised_0.pdf (2018)
Holappa J (2020a) Fortum eNext, Fortum Power and Heat Oy, POB 100, 00048 FORTUM, Finland,
personal communication (Sep 2020)
IEA (2021) India Energy Outlook 2021. Available from:

https://iea.blob.core.windows.net/assets/1de6d91e-e23f-4e02-b1fb-
51fdd6283b22/India_Energy_Outlook_2021.pdf Paris, France, International Energy Agency, 251 pp
(2021)
65
REFERENCES
IFS (2021) Power Plant NOx Reduction SCR Vs SNCR Technology - Which Is Better? Available from:
https://ifsolutions.com/power-plant-nox-reduction-scr-vs-sncr/ (Dec 2021)
I3E (2020) Continuous Emissions Monitoring Systems (CEMS) in India, Impact Evaluation Report 111,
International Initiative for Impact Evaluation, 202-203 Rectangle One D-4, Saket District Centre New
Delhi, India, 46 pp (Mar 2020)
Johanssan L E (2012) Presentation-Different Aspects to Consider Selection FGD Type of Technology.

Available from: https://www.npti.gov.in/sites/default/files/presentation-
document/different_aspects_to_consider.pdf (2021)
Kanchan S (2018) CEMS and CEQMS Implementation in India: Inspection Manual. Available from:
https://csestore.cse.org.in/books/industry-and-environment/cems-and-ceqms-implementation-in-
india-an-inspection-manual.html 68 pp (Mar 2018)
Kanchan S (2019) Presentation-Sector-Specific Approach and Post Installation Assessment of CEMS for
Proper Implementation. Available from:
https://erc.mp.gov.in/Documents/cssmeet/Presentation_Sanjeev.pdf 43 pp (Dec 2019)
Kanchan S (2019a) Real-time Monitoring-a Step Ahead. Available from:

https://blogs.knowledgelens.com/index.php/2019/05/23/real-time-monitoring-a-step-ahead/
(May 2019)
Kanchan S (2020) For A New India, Millennium Post. Available from:

http://www.millenniumpost.in/sundaypost/inland/for-a-new-india-410022?infinitescroll=1
(accessed Sep 13 2021)
Kendhe M (2020) GE Power India Limited, Corporate Office: Axis House, Tower 5, 5 th Floor sector
128, Jaypee Wishtown, Noida-201301, Uttar Pradesh, India, personal communication (Oct 2020)
Kumar R, Bhagchandani T (2018) An overview of NOx mitigation techniques by SNCR/hybrid

technologies in power plants. Available from: http://210.212.126.93:8000/ft/IPS2018/Session-
3B%20EnvironmentWater%20Management/05.An%20Overview%20of%20Nox%20mitigation%20te
chniques%20.pdf (Jun 2020)
MHPS (2019) MHPS technologies for FGD, ESP and SCR. Available from:
https://cea.nic.in/old/reports/cea-jcoal/presentation/MHPS_presentation.pdf
MOC (2022) Ministry of Coal, Major Statistics. Available from: https://coal.gov.in/en/major-

statistics/production-and-
supplies#:~:text=The%20all%20India%20Production%20of%20coal%20during%202020%2D21%20we
re,a%20negative%20growth%20of%200.78%25
MOEFCC (2015) Ministry of the Environment, Forest, and Climate Change Notification. Available from:
https://erc.mp.gov.in/adminfiles/RTM/Draft_Notification.pdf New Delhi, India, MOEFCC, 11 pp
(Apr 2015)
MOEFCC (2021) Ministry of the Environment, Forest, and Climate Change Notification 192. Available
from: https://moef.gov.in/wp-content/uploads/2021/04/GSR243.pdf New Delhi, India, MOEFCC,
3 pp (dated March 31, 2021, and issued April 1, 2021)
MOP (2021) Ministry of Power, Power Generation Capacity. Available from:

https://pib.gov.in/PressReleseDetailm.aspx?PRID=1742675 Posted on: 05 Aug 2021 1:24 pm by PIB,
New Delhi, India, MOP (Aug 2021) (accessed 17 Aug 2021)
MP (2021) Flue gas desulphurization plant. Available from:

https://power.mhi.com/products/aqcs/lineup/flue-gas-desulfurization Mitsubishi Power webpage
(Dec 2021)

66
REFERENCES
NTPC (2020) NTPC Dadri Striving To Become Cleanest Coal-Fired Power Plant in India. Available
from: https://www.ntpc.co.in/en/media/press-releases/details/ntpc-dadri-striving-become-
cleanest-coal-fired-plant-india (2029)
NTPC (2021) Annual Report 2020-21. Available from:

https://www.ntpc.co.in/sites/default/files/downloads/Annual-Report-2020-21.pdf p 64
Pachouri R, Saxena A (2020) Emissions Control in Thermal Power Stations: Issues, Challenges, and the
Way Forward, The Energy and Resources Institute, Darbari Seth Block, India Habitat Centre, Lodhi
Road, New Delhi – 110 003, India
RAP (2019) Controlling emissions in India’s electricity sector: An analysis of options. 52 pp. The
Regulatory Assistance Project, Montpelier, Vermont, USA. Available from:
https://www.raponline.org/wp-content/uploads/2020/06/athawale-bharvirkar-controlling-
emissions-india-power-sector-2019-july.pdf Prepared by Athawale R and Bharvirkar R (Jul 2019)
Reuters (2019) NTPC rejects foreign emission reduction technology, to miss December deadline;
shuts out GE, others from $2 bn orders. Available from: https://www.firstpost.com/business/ntpc-
rejects-foreign-emission-reduction-technology-to-miss-december-deadline-shuts-out-ge-others-
from-2-bn-orders-7802591.html
S&P Global (2021) World electric power plants. Power Plants Database. London, England, S&P Global
(2021)
Sloss L L (2015) The emerging market for mercury control. CCC/245. Available from:
https://www.sustainable-carbon.org/report/the-emerging-market-for-mercury-control-ccc-245
London, UK, International Centre for Sustainable Carbon, 75 pp (Feb 2015)
Sloss L L (2017) Emerging markets for pollution control retrofits. CCC/274. Available from: emerging-
markets-for-pollution-control-retrofits-ccc-274 (1).pdf London, UK, International Centre for
Sustainable Carbon, 82 pp (Feb 2017)
Sloss L L, Storm S (2021) Improving coal utility power plant flexibility and performance in India.
High-level flexibility assessment toolkit guidance and training delivery plan. Available from:
Improving-coal-utility-power-plant-flexibility-and-performance-in-India (10).pdf London, UK,
International Centre for Sustainable Carbon, 45 pp (Aug 2021)
Sloss and others (2021a) Status of continuous emission monitoring systems at coal-fired power plants in
India. Available from: Status-of-CEM-systems-at-coal-fired-power-plants-in-India-1 (11).pdf London,
UK, 74 pp (Dec 2021)
Sloss and others (2021b) Reducing mercury emissions from the coal combustion sector in Indonesia.
Available from: Reducing-mercury-emissions-from-the-coal-sector-in-indonesia-Phase-1 (5).pdf
London, UK, 6 pp (Jan 2021)
Srinivasan, S, Roshana, N, Guttikunda, S, Kannudia, A, Saif, S, Asundi, J (2018) Benefit-Cost

Analysis of Emission Standards for Coal-based Thermal Power Plants in India. Available from:
https://shaktifoundation.in/wp-content/uploads/2018/07/Benefit-cost-analysis-of-emission-
standards-for-coal-based-thermal-power-plants-in-India-1.pdf
Storm S (2020) Electric Power Research Institute (EPRI), 1300 West W T Harris Blvd, | Charlotte,
NC 28262EPRI, USA, personal communication (Nov 2020)
TERI (2020) Discussion Paper 2020: Emissions control in thermal power stations: issues, challenges, and
the way forward. Available from: https://www.teriin.org/sites/default/files/2020-02/emissions-
control-thermal-power.pdf New Delhi, India, The Energy and Resources Institute, 20 pp (2020)

67
REFERENCES
TOI, Times of India (2022) Power minister asks states to formulate plans for biomass cofiring in
power plants. Available from:
http://timesofindia.indiatimes.com/articleshow/93085649.cms?utm_source=contentofinterest&utm
_medium=text&utm_campaign=cppst Times of India, 1 pp (Jul 2022)
Tripathi B (2000) India’s largest power producer wants NOx norms diluted for new coal plants.
Available from: https://www.indiaspend.com/indias-largest-power-producer-wants-nox-norms-
diluted-for-new-coal-plants/
Tuli V (2020) Flue gas desulphurisation: an RS 80,000 crore investment opportunity. Available from:
https://www.financialexpress.com/opinion/flue-gas-desulphurisation-a-rs-80000-crore-investment-
opportunity/1987779/ Financial Express, India, 2 pp (Jun 2020)
UNEP (2014) Publications of the Coal Partnership Area. Available from:

https://www.unep.org/globalmercurypartnership/resources?keys=&type=All&area=357 Vp
(Oct 2014)
UNEP (2019) Guidance of best available techniques and best environmental practices. Geneva,
Switzerland, United Nations Environment Programme, 62 (2019)
UNEP (2021) Guidance of best available techniques and best environmental practices. Geneva,
Switzerland, United Nations Environment Programme, 193 pp (2021)
Vasudha Foundation (2020) 2020 India’s Power Outlook, Volume 2. Vasudha Foundation, CISRS
House, New Delhi, India, 32 pp (Jun 2020)
Wiatros-Motyka M (2016) Optimising fuel flow in pulverised coal and biomass fired boilers. CCC/263.
London, UK, International Centre for Sustainable Carbon, 61 pp (Jan 2016)
Wiatros-Motyka M (2019) Power plant design and management for unit cycling. CCC/295. London,
UK, International Centre for Sustainable Carbon, 94 pp (Sep 2019)
Wiatros-Motyka M, Nalbandian-Sugden H (2018) NOx control for high ash coals. CCC/285. London,
UK, International Centre for Sustainable Carbon, 85 pp (2018)
Żmuda R (2020) SBB Energy S.A. 45-324 Opole, ul. Łowicka 1, Poland, personal communication
(Dec 2020)

68

Accelerating Emission Control at Coal Fired Power - 230730 - 085833

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Accelerating Emission Control at Coal Fired Power - 230730 - 085833

Uploaded by

Copyright:

Available Formats

JULY 2023

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

+44[0]20 3905 3870

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

• Pillar 1 – emissions monitoring

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

A STUDY PUBLISHED IN THE LANCET CONCLUDED THAT

THE COST OF I NVESTMENT IN POLLUTION CONTROL ON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

2 EMISSION STANDARDS IN INDIA

2.1 EMISSION LIMITS

PM, SO2, NOx, Mercury,

Old standard 150–350 None None None

2015 Norms (limits)

Units installed between 2004-16 50 600 (<500 MW) 300 0.03

Units installed from 1 January 2017 50 100 100 0.03

* Relaxed in 2020, as outlined in the text below

2.2 AMENDMENTS TO THE EMISSION LIMITS

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

TABLE 2 RANKING OF PLANTS FOR COMPLIANCE DEADLINES (MOEFCC, 2021)

Rank Timeline for Compliance

Within a 10 km radius of the national

2 Category B Within a 10 km radius of a critically Up to 31 Dec 2023 Up to 31 Dec 2025

* as per 2011 population count † as defined by CPCB

TABLE 3 PENALTIES FOR NON-COMPLIANT POWER PLANTS, RUPEES/KWH (MOEFCC, 2021)

Non-compliant operation beyond Category A Category B Category C

0–180 days 0.10 0.07 0.05

181–365 days 0.15 0.10 0.075

366 days and beyond 0.20 0.15 0.10

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

Figure 2 History of delays and derogations (Aggarwal, 2022)

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

Figure 3 Compliance status of category C plant (Aggarwal, 2022)

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

3.1 TECHNOLOGY OPTIONS

3.2 STATUS OF PM CAPTURE AND OPPORTUNITIES FOR

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

As the emission limits tightened (on the right of

If PM controls do not capture particulates efficiently,

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

Figure 6 Implementation progress of PM control in India (CSE, 2022)

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

4.1 TECHNOLOGY OPTIONS

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

CONTRARY TO SOME STAKEHOLDER ARGUMENTS,

INTERNATIONAL CENTRE FOR SUSTAINABLE CARBON

4.2 SELECTION OF NOx CONTROL

Advanced fuel & Primary NOx Selective Selective catalytic

Relative initial 0.2–1.0 3–6 2–3 10–20

Opex NA NA $6.5-16.4 million Approximately $6.5

NOx reduction 10% by better fuel Up to 70% 20–60% 80–90%