A Review Report

on new SO2 emission norms

August 2021 TPRM Div. CEA

 Background
 In December 2015, MOEF&CC first time introduced environmental emission
standards for controlling SO2, NOx & Mercury emissions from coal-based TPPs
under the Environment (Protection) Act, 1986.
 SCR technology is not proven in Indian coal and 300 mg/ NM3 can not be achieved
by combustion modification, CEA took up the matter with MOP & MOEF&CC and
finally the NOx norms was revsied from 300 mg/Nm3 to 450 mg/NM3.
 Post 2015, Thermal power stations had to upgrade ESP, implement the SO2 control
technology & combustion modification and a detailed phasing plan was prepared to
implement FGD by 2024.
 The detailed phasing plan prepared by CEA in consultation with all stake-holders and
was sent to MoEF&CC in June,2017.
 However, the time line was squeezed by MoEF&CC to December, 2022.
 CEA started monitoring the implementation of measures to comply with new norms.
More than 90% TPPs are installing wet lime stone based FGD system as it is
economical.
 It was found that thermal power plants are facing many issues/challenges during the
implementation of FGD system.
 Challenges in Implementation of FGD
 Till the end of 2015 no SO2 norms were applicable, thus FGD manufacturing capacity was
almost nonexistent in the country.

 FGD technology being new to our country, there are at present limited vendors with limited
capacity to supply FGD components. Therefore, there is an availability constraint.

 A sudden surge of demand has arisen as all thermal generating units, about 470 running units
of 180 GW capacity, have to implement FGD system in one go. Proper planning was not there
for development of infrastructure to meet the demand surge.

 Although India has the manufacturing capability of more than 70% FGD components, it
depends on the imports from other country as manufacturing capacity is insufficient to cater to
huge demand in a short period of time.

 Balance 30% of FGD component is not manufactured in India. Thus, import from other
countries is the only option and to create a manufacturing capability of these items in India
would take few years.
 Challenges in Implementation of FGD (contd.)
 A huge foreign exchange for importing technology, equipment and skilled manpower
from other countries shall be required.
 Placing order for installation of FGD in all the plants simultaneously without
ascertaining its performance in Indian condition may not be a proper decision.
 Thus, no time for fine tuning of the specification is possible, considering the
implementation time of about 36 months and all the orders being placed in one go,
targeting December 2022 deadline.
 Due to huge gap in demand and supply of FGD equipment, prices are escalating
exorbitantly and it can also lead to market manipulation.
 Impact of Covid-19 pandemic on planning, placing of order, supply chain of
equipment and installation of FGD is severe.

 Increasing cost of electricity.

CEA paper on

Plant Location Specific Emission Standards

 Plant Location Specific Emission Standards

Background
 To overcome all the above issues /challenges being faced by power industry, CEA prepared
a paper on plant location specific emission standards and suggested a graded action plan
for FGD implementation in TPP.

 The report was prepared based on the ambient air quality data received from various power
stations, air quality data published by CPCB, satellite images of atmospheric SO 2 from
NASA and study conducted by IIT Kanpur.

 The ambient air quality can be made as the guiding factor for formulating emission control
strategy. The gradation of ambient air quality would be helpful in prioritizing the
installation of emission control equipment in a phased manner.
 Plant Location Specific Emission Standards

Thermal Power Plant Emissions

 Thermal Power Plant emissions have both local and global impact. Global impact is
mostly due to the production of greenhouse gases CO2 and locally (country specific)
it contributes large quantity of bottom ash, fly ash (PM) and some emissions of
SO2/NOx.
 Stack height is designed to take care of the dispersion of emissions from thermal
power plants. Its impact can be seen from the ground based Ambient Air Quality
measurements carried in the immediate vicinity of the power plants.
 For ascertaining Dispersion of Emissions from the stack, the modelling studies and
the satellite imagery are useful tools. Satellite imagery indicates the hot spots which
would need to be effectively taken care of on priority basis.
 Plant Location Specific Emission Standards
Satellite Imagery of SO2 Emissions
 TPRM, CEA Division had contacted Nasa for providing the latest satellite imagery for SO 2
atmospheric levels and Nasa has shared the images for the period 2005 to 2019.
 The figure indicates the changes in the
Vertical Column Density of atmospheric
SO2 from year 2005 to 2019. It shows that
the SO2 hot spots are concentrated in small
clusters in states of Odisha, WB, Jharkhand,
Chhattisgarh, Maharashtra, Tamil Nadu and
Gujarat, etc. having incidentally large
capacities of Thermal Power Plant, which
would need to be effectively taken care off
on priority basis.
 Satellite images indicates the concentration
of SO2 at certain height (900 m and above)
and not ground level SO2 in the area.
Hence, Ground Air Quality measurements
play an important role.
 Plant Location Specific Emission Standards

Air Quality Dispersion Modeling Study, Jan 2020

The Study was conducted by Prof. Mukesh Sharma, Dept. of Civil Engineering, IIT
Kanpur on the behalf of Private Power Producer.
Scope of the Study
 Modeling Study on the dispersion of pollutants, mainly SO2 emission from the Talwandi
Sabo Thermal Power Plant, Punjab.
 Estimating an increase in SO2 and sulfate at ground level concentration using dispersion
model.
• Study Conclusions
 The model computed SO2 peak concentration is in the month of April 45.9μg/m3. The
peak contribution towards Delhi was 40μg/m3 at a distance of about 2.0km and drops
sharply to less than 1μg/m3 at a distance of 40km from the plant. Thus beyond 40km the
impact of SO2 becomes insignificant.
 The NO2 modelled peak concentration was in April at 52μg/m3. The peak contribution
towards S-E direction was 45μg/m3 at a distance of 2.5km and drops sharply to less than
1μg/m3 at a 40km distance from the plant. Thus, beyond 40km the impact of NO 2
becomes insignificant.
 Plant Location Specific Emission Standards

Air Quality Dispersion Modeling Study, Jan 2020

• Study Conclusions
 Similarly, it has also been indicated that the 24-hourly mean peak concentration of SO4 was 2.18
μg/m3 in the S-E direction at 12 km which drops to 0.73 μg/m3 in S-E direction at a distance of
about 250 km.

 The 24-hourly mean peak concentration of NO3 was 0.41 μg/m3 in S E direction at a distance of
about 12 km and it drops to less than 0.002 μg/m3 at a distance of about 250 km.
 Plant Location Specific Emission Standards
Ambient Air Quality Data (CPCB, 2018)

 The latest (CPCB,2018) Ambient Air Quality data (SO2, NO2, PM10, PM2.5)
monitored at 745 Stations located across the country available then was analysed by
CEA. Refer Annexure I of the report. (Data is available for 24 hr. average (min./max.) and
annual average)
 SO2 ground based levels across the country were mostly within a range of 0-
40µg/m3 (considered Good as per CPCB standards) and similar trend with some
exceptions was seen in the case of NO2 levels.
 MoEF&CC has adopted air quality standards for the country and defined the AQI index
for categorizing the Ambient Air Quality (“good” to “severe”) based on the various
sub-indices concentration levels as indicated below.

Good Satisfactory Moderately Poor Very Severe

Polluted Poor

SO2 (µg/m3) 0-40 41-80 81-380 381-800 801-1600 1600+

 The latest CPCB,2019 data

 Plant Location Specific Emission Standards

Ambient Air Quality of Thermal Power Plants

 In June 2020, CEA sent request to all the Thermal Power Generating Companies to
furnish ambient air quality data (PM/SO2/NOx) at least for past one year collected from
the AAQMS located in their plants.
 The data was collected from central sector, state sector and private sector power plants.
 Plant Location Specific Emission Standards
Ambient Air Quality, SO2 Levels (µg/m3) Central Sector Plants

April-19

June-19
May-19

Mar-20
Nov-19
Aug-19
July-19

Dec-19
Sep-19

Feb-20
Oct-19

Jan-20
NTPC Plants

Type
Data
NTPC/IGSTPP 9.4 9.0 8.6 8.0 8.0 8.1 8.3 7.2 6.5 8.4 13.5 12.0 Max.
NTPC/Unchahar TPS 22.6 6.6 10.5 11.2 11.1 10.7 11.4 6.7 7.6 7.5 7.6 15.9 Max.
NTPC/Barh TPS 16.4 16.2 16.3 16.4 13.2 18.0 14.8 23.2 24.2 23.6 23.6 24.8 Max.
NTPC/Kahalgoan TPS 12.4 15.3 15.1 16.4 15.8 63.3 23.5 9.3 20.7 24.0 14.8 28.9 Max.
NTPC/Talcher Kaniha TPS 20.8 24.9 25.6 17.4 20.5 28.4 26.9 26.7 21.6 20.8 19.8 27.3 Max.
NTPC/Bhilai TPS 27.5 18.9 22.8 18.6 20.1 19.5 21.8 16.4 19.7 40.0 35.6 40.0 Max.
NTPC/Sipat TPS 35.1 57.3 37.0 14.9 19.4 22.8 15.9 18.9 11.4 41.1 30.3 12.4 Max.
NTPC/Vindhyachal TPS 30.1 29.5 31.7 35.9 56.4 46.2 24.9 25.6 23.2 33.5 23.5 20.3 Max.
NTPC/Mouda TPS 14.2 119.7 53.1 16.7 19.3 19.7 23.9 46.2 23.4 23.1 16.8 28.1 Max.
NTPC/Farakka TPS 74.8 12.4 21.5 30.3 32.0 37.0 40.0 29.4 32.4 33.9 38.3 24.4 Max.
NTPC/Kudgi TPS 238.9 27.1 20.3 12.6 18.7 18.6 18.2 15.4 16.8 48.9 96.4 62.6 Max.
NTPC/TandaTPS 49.4 62.1 58.4 35.2 16.9 7.8 20.9 99.0 54.2 88.0 94.0 75.0 Max.
NTPC/Simhadri TPS 72.9 55.6 17.9 26.6 32.4 41.6 106.2 61.3 88.4 72.4 98.8 66.2 Max.
NTPC/Rihand TPS 142.3 192.2 213.7 18.5 14.6 21.0 32.7 29.7 38.3 27.6 32.8 33.8 Max.
NTPC/Solapur TPS 43.9 38.9 174.9 49.7 74.6 196.9 51.4 29.8 66.1 33.0 35.1 53.0 Max.
NTPC/Talcher Thermal TPS 239.0 236.2 177.2 24.2 26.5 22.9 23.0 27.2 28.9 30.1 31.7 29.6 Max.
NTPC/Vallur TPS 30.7 50.4 36.6 88.5 75.0 92.8 93.5 92.1 92.1 94.5 89.5 88.8 Max.
NTPC/Singrauli TPS 78.2 33.6 17.0 16.4 35.5 26.0 156.5 197.8 139.6 74.9 Max.
NTPC/Barauni TPS 82.0 80.0 75.0 83.0 86.0 78.0 92.0 75.0 91.0 73.0 69.0 65.0 Max.
NTPC/Dadri TPS 86.0 55.9 99.8 213.4 172.4 73.4 21.0 26.5 30.6 223.7 14.9 23.8 Max.
NTPC/Kanti TPS 110.0 120.7 125.0 156.0 190.0 125.1 154.0 145.0 160.0 164.0 110.0 80.0 Max.
NTPC/Ramagundam TPS 193.6 249.5 199.4 107.7 186.0 129.0 142.6 118.9 139.0 142.9 143.6 56.1 Max.
NTPC/Korba TPS 218.3 230.7 156.5 25.0 12.8 71.8 65.2 399.1 446.4 155.7 177.2 158.5 Max.

Good Moderately Polluted

Satisfactory Poor
 Plant Location Specific Emission Standards

Ambient Air Quality, SO2 Levels (µg/m3) Central Sector

Plants
NLC/DVC

April-19

June-19
May-19

Mar-20
Nov-19
Aug-19
July-19

Dec-19
Sep-19

Feb-20
Oct-19

Jan-20

Type
Data
Plants
NLCIL/TPS-II 5.9 5.9 5.8 7.2 4.0 3.7 3.7 3.3 3.5 3.8 3.5 5.2 Max. Avg
NLCIL/TPS-1 Expansion 7.4 8.5 6.4 6.1 8.1 7.3 9.9 5.4 5.4 4.9 4.9 5.0 Max. Avg
NLCIL/TPS-1 9.6 9.2 9.3 6.3 7.8 7.7 11.0 5.5 5.6 5.6 4.2 6.2 Max. Avg
NLCIL/Barsingsar TPS 9.6 9.0 9.2 8.1 8.0 8.2 8.6 9.2 11.9 10.0 9.9 11.5 Max.
NTPC/Unchahar TPS 22.6 6.6 10.5 11.2 11.1 10.7 11.4 6.7 7.6 7.5 7.6 15.9 Max.
NLCIL/TPS-II Expansion 10.4 12.9 9.9 9.0 23.6 17.8 20.0 9.8 5.1 7.3 17.0 7.2 Max. Avg
DVC/Meija TPS 22.0 21.8 18.8 17.9 17.9 17.9 17.6 7.6 19.8 21.1 19.6 18.2 Avg.

Good Moderately Polluted

Satisfactory Poor
 Plant Location Specific Emission Standards
Ambient Air Quality, SO2 Levels (µg/m3) State Sector Plants

June-19
May-19

Mar-20
Nov-19
Aug-19
July-19

Dec-19
Apr-19

Sep-19

Feb-20
Oct-19

Jan-20
State Sector Plants

Type
Data
WBPDCL/ Sagardighi TPS - - - 2.7 7.1 3.1 2.8 3.0 3.7 5.3 4.7 6.6 Avg.
WBPDCL/Kolaghat TPS 9.9 9.1 9.1 11.0 9.6 9.2 9.1 9.8 9.7 10.6 10.7 14.2 Avg.
GSECL/ Sikka TPS 6.1 6.1 5.9 9.3 8.8 7.6 8.8 10.9 11.8 22.1 18.2 19.4 Avg.Avg
GSECL/ Gandhinagar TPS 13.4 13.4 11.9 12.6 10.3 7.8 8.7 11.4 13.2 12.4 11.6 12.6 Avg.Avg
HPGCL/ DCRTPP 11.4 10.6 11.8 12.3 13.0 12.7 12.6 13.8 13.3 14.4 14.8 12.5 Max. Avg
HPGCL/RGTPP,Hissar 16.3 15.3 15.7 14.3 13.0 13.7 14.7 17.7 15.3 15.7 16.3 15.7 Max. Avg
GSECL/ Wanakbori 20.6 17.3 16.8 16.4 7.0 7.4 19.5 8.0 20.7 22.0 20.5 21.6 Avg.Avg
GSECL/ Ukai TPS 14.5 18.7 17.5 17.6 14.9 18.1 20.8 18.5 18.1 19.8 19.7 18.5 Avg.Avg
GSECL/ Kutch Lignite TPS 26.7 26.1 24.6 22.6 23.5 21.5 21.3 21.4 22.8 21.7 20.3 19.8 Avg.Avg
HPGCL/ Panipat TPS 24.3 23.8 21.4 - - 20.8 25.6 23.4 22.5 - 18.6 25.4 Max.
RRVUN/ Suaratgarh TPS 27.9 34.6 38.2 64.3 33.5 34.1 25.0 14.7 48.4 6.7 30.3 11.6 Max.
RRVUNL/Kalisindh TPS 55.2 59.1 64.0 83.9 122.0 7.6 - 3.0 0.0 0.0 0.0 0.0 Max.
MPPGCL/ Amarkantak TPS 11.5 10.3 4.8 4.4 14.0 5.3 17.5 31.3 187.8 30.4 41.2 234.8 Max.
MPPGCL/ Satpura TPS 94.5 82.6 80.0 0.0 79.6 63.3 54.3 51.6 48.5 43.5 46.6 52.8 Max. Avg
MPPGCL/ Shree Singaji TPS 63.0 6.5 144.4 66.6 58.7 37.9 74.8 77.7 72.1 68.2 62.6 61.4 Max. Avg
GGSSTPP/ Rupnagar 87.0 92.0 89.0 86.0 87.0 88.0 91.0 94.0 84.0 89.0 87.0 - Max.
MPPGCL/Sanjay Gandhi TPS 572.8 372.0 290.9 87.9 66.4 13.0 154.4 136.3 - 313.1 544.1 294.2 Max. Avg

Good Moderately Polluted

Satisfactory Poor
 Plant Location Specific Emission Standards

Ambient Air Quality, SO2 Levels (µg/m3) Private Sector

Plants

June-19
May-19

Mar-20
Nov-19
Aug-19
July-19

Dec-19
Apr-19

Sep-19

Feb-20
Oct-19

Jan-20
Pvt. Sector Plants

Type
Data
Adani Power/ Udupi Power 8.2 8.7 9.1 8.2 8.8 10.8 8.8 6.5 6.5 9.5 9.6 6.9 Avg.Avg
NPL/ Rajpura TPS 10.7 6.4 7.4 7.2 7.9 7.9 9.0 11.3 9.7 9.1 11.0 11.3 Avg.Avg
CESC/ Budge Budge TPS 9.8 11.1 12.0 15.3 17.8 20.5 22.7 24.2 4.0 3.3 6.1 7.3 Max.
PPGCL/Bara TPS 14.2 13.2 14.4 21.0 21.0 21.8 13.1 12.8 12.8 15.2 15.0 13.0 Max. Avg
Tatapower/CGPL,Mundra 16.8 16.4 15.8 16.7 12.7 13.1 13.5 16.6 16.7 16.6 17.1 17.2 Avg.Avg
Adani Power/ Kawai 16.2 17.5 14.0 17.6 19.1 16.7 17.0 18.6 17.2 18.2 20.0 21.3 Max. Avg
Adani Power/Mundra 28.5 25.0 21.7 26.0 27.0 29.3 27.1 29.5 26.6 27.5 27.3 25.7 Max. Avg
Tatapower/ Maithon 37.5 38.6 41.1 40.8 36.9 36.3 35.6 34.9 34.2 33.6 33.0 29.6 Avg.Avg
Tatapower/ Jojobera TPS 41.5 42.2 43.1 39.6 33.5 31.7 43.0 37.9 39.7 38.7 36.5 40.9 Avg.Avg
Tatapower/ Trombay TPS 45.2 43.9 41.0 39.3 36.7 34.5 34.3 40.6 39.2 38.4 43.5 40.4 Avg.Avg
Dhariwal Ltd./ Chandrapur 47.1 54.8 32.1 88.0 41.4 32.1 24.1 13.6 73.4 16.6 39.8 33.9 Max.

Good Moderately Polluted

Satisfactory Poor
 Plant Location Specific Emission Standards

Ambient Air Quality in Thermal Power Plants

 The data was analyzed for an installed capacity of 86,272MW by CEA and
has been tabulated as below. Plant capacity is categorized considering the
maximum and average value of SO2 levels in their vicinity.

 Thermal Power Plant capacity categorized considering the average value of

SO2 in their vicinity.

SO2 Avg. 0-10 11-15 16-20 21-25 26-30 31-35 36-40 >40
(μg/m3)

Thermal 23,330 16,770 24,954 10,320 2,700 2,520 2,527 1,930

Capacity
Percentage 27.43% 19.72% 29.34% 12.13% 3.17% 2.96% 2.97% 2.27%
 Plant Location Specific Emission Standards

Ambient Air Quality in Thermal Power Plants (contd.)

 Thermal Power Plant capacity categorized considering mainly the maximum levels
of SO2 in their vicinity averaged over a period of one year.
SO2 Max.
0-10 11-15 16-20 21-25 26-30 31-35 36-40 >40
(μg/m3)
Thermal
Capacity 10,920 10,160 7,560 6,340 9,834 10,380 2,528 28,550
Percentage 12.66% 11.78% 8.76% 7.35% 11.40% 12.0% 2.93% 33.09%

 As per the above data, immediate action may have to be considered for a capacity of
about 33% and for 15% in the next phase.
 Plant Location Specific Emission Standards
Merits of Phased Execution
 Various technologies are available to control the Flue Gas Emissions and their suitability
and efficacy needs to be ascertained in the Indian conditions.
 Phasing will help in better understanding the impact of the emission control equipment
on their effectiveness and shall give time for future course correction.

Implementation of emission control measures in all the Power Plants simultaneously may
not be the best option to adopt and will inevitably lead to the following which is not in the
overall interest of the country.
 Lack of time for developing indigenous manufacturing facility,
 Resorting to import of equipment thus creating market for mainly foreign companies,
 Huge investment of over one lakh crore required. Majority of which will lead to the
foreign exchange drain for outsourcing of new technology, skilled manpower and
equipment as there is lack of time to develop the facility indigenously.
 Plant Location Specific Emission Standards

Recommendations:
To mitigate the challenges faced by the New Emission Norms following measures can be
adopted.
1. Uniform Ambient Air Quality across the country and not the uniform emission norms for
Thermal Power Plants. Implementing uniform emission norms of TPS may result in different
air quality at different location. Identical norms for Thermal Power Plants located in critically
polluted area and in areas where air quality is good doesn’t look to be proper as additional
costs are involved. Aim should be to achieve Uniform Air Quality throughout the country.
It is proposed to implement FGD for the Thermal Power Plants region-wise as given in the table
below:
Region Ambient Air SO2 levels FGD Installation
3
 In areas where the development is
1 >40μg/ m Immediately
high, the atmospheric air quality is
2 3
>30μg/ m & ≤ 40μg/ m
3 nd
In 2 phase poor and is prone to serious
3 3
>20μg/ m & ≤ 30μg/ m
3 atmospheric pollution problems, strict
3 3 Not required at control of emissions shall be required
4 >10μg/ m & ≤ 20μg/ m in such key areas for TPS as
present
5 3
>0μg/ m & ≤ 10μg/ m
3 categorised under Region 1.
 Plant Location Specific Emission Standards
Recommendations (contd.)

 In next phase FGD to be implemented in the Power Plant which are under Region 2
 Presently, no action shall be required for Power Plant those are under Region 3,4 & 5.

2. Graded Action Plan for adopting new emission norms rather than adopting a single
deadline for large base of Thermal Power plants.

 Unworkable time schedule will create market scarcity leading to import, jacked up prices
unnecessary burden on power utilities. Graded Action Plan will help in utilizing the
resources in effective manner and it will help in fine tuning the technology for local
conditions.

 Whereas, if the process of emission control in the country is completed in longer time
frame (10-15 years) and considering in first phase Thermal Power Plants located in
critically polluted areas, it will achieve tangible results in combating emissions and help in
developing indigenous manufacturing base, skilled manpower in the country which shall
take care of the local operating conditions.
 Review Report on new SO2 emission norms

The report was submitted to MOP in August, 2020.

After approval it was forwarded by MOP to MOEF&CC for consideration in

January, 2021.

Thereafter, MOEFF&CC notified G.S.R.243(E) dtd.31.03.2021 for categorization

of thermal power plant on the basis of their location.
 Review Report on new SO2 emission norms

MOEF&CC notification dated

31.03.2021
Thereafter, MOEFF&CC notified G.S.R.243(E) dtd.31.03.2021, that the emission compliance
would mean all the plant emission norms (2015) for PM/SO2/NOx are to be met by the specified
timeline as per Category, A,B or C, any deviation in the above norms beyond the timeline would
be liable for the levy of emission compensation (EC).

S.No. Category Location/ Area Timeline for Compliance

Non retiring Units Retiring Units
(1) (2) (3) (4) (5)
1 Category A Within 10 km radius of National Upto 31st December Upto 31st
Capital Region or cities having 2022 December 2022
million plus population.
2 Category B Within 10 km radius of Critically Upto 31st December Upto 31st
Polluted Areas or Non-attainment 2023 December 2025
cities.
3 Category C Other than those included in Upto 31st December Upto 31st
category A and B 2024 December 2025
 Review Report on new SO2 emission norms
Analysis of MOEF&CC notification dated 31.03.2021
 Presence of SO2 or NOx in the ambient air in the area has not been considered. It is well known
that there is issue of PM10 or PM2.5 in many cities but there may not be any issue regarding level
of SO2 or NOx.

 Thus ambient air quality (AQI) has not been made as the guiding factor for formulating the
categorization. On the other hand the area where ambient air quality is actually critical in terms of
SO2 or NOx level may not be located in cities/ areas as specified, there is a fair possibility that
these areas may fall under category C.

 Due to paucity of implementation time, any new technology which is being implemented in
category A shall be repeated in category B without seeing its performance in category A.
Therefore, sufficient time shall be required for fine tuning the performance of FGD already in
operation. However, there is not enough time in between timeline of category A and B.
 Review Report on new SO2 emission norms
Analysis of MOEF&CC notification dated 31.03.2021
 About 150 GW plus capacity of TPPs is under Category C (exact number of units and capacity
will be known only after completion of categorization work by a Task Force constituted for this
purpose) and sufficient time will be required so that they can modify the order seeing the
performance of FGD in category A.
 After commissioning of FGD system almost 2-3 years are required for stabilization. Thus
minimum 6 years’ time may be given from commissioning of TPP under Category A. Therefore
timeline for category C shall be 2028 (considering 3 years for stabilization and 3 year for
implementation).
 Further, there will be huge demand of FGD equipment in 2028 which may create crisis in the FGD
market in India. Therefore, it is suggested that all these units timeline may be spread in 2028,
2029, 2033 & 2034 according to their distance from million plus city/ critically polluted area/ Non
Attainment city or on the basis of SO2 level in ambient air. If distance is 11-40 km, 41-70 km, 71-
100 km and more than 100 km, timeline will be 2028, 2029, 2033 and 2034 respectively.
 This will help in understanding the performance of the emission control equipment, their
effectiveness and give a time for course of correction.
 An unworkable time schedule is creating market scarcity leading to import, jacked up prices
unnecessary burden on power utilities. The project cost for wet lime based FGD technology is
varying between rupees 0.39 crore to 1.10 crore per MW, which is quite high, around 2.8
times.
 Review Report on new SO2 emission norms
Realistic time for installatio
n
 Orders placed by a major central power utility as early as in 2018 for 30 FGD units for a total
capacity of 15 GW have on an average completed a time period of over 35 months, and some units
have completed more than 40 months since the award, and not a single FGD has been
commissioned so far.

 These orders have been fairly distributed among five different major Indian vendors. The detailed
evaluation of the progress of above orders shall help in understanding the roadblocks and
estimating the existing capability of the EPC contractors in the country. Based on which a realistic
time schedule for installation of FGD for 180 GW installed capacity can be planned.
 Review Report on new SO2 emission norms
Analysis of MOEF&CC notification dated 31.03.2021
The environmental compensation (EC) max. per
N on-Compliant operation Environmental Compensation
unit of 20 paisa (Category A), 15paisa (Category beyond the Timeline (Rs. per Unit electricity generated)
B) and 10paisa (Category C) which shall be
Category A Category B Category C
levied for noncompliance beyond assigned time 0-180 days 0.10 0.07 0.05
limit , takes into the consideration that the 181-365 days 0.15 0.10 0.075
impact of thermal power plant emissions is 366 days and beyond 0.20 0.15 0.10
location specific.
The merchant plants which are not operating in pass through regime may have the option,
whether to go for the compliance or alternatively pay the EC
Non Compliant Environmental Compensation
Operation beyond the
Category A Category B Category C
timeline
Rs./Unit Rs. Cr* Rs./ Rs. Cr* Rs./Unit Rs. Cr*
Unit

0-180 days 0.1 13.0 0.07 9.1 0.05 6.5

181-365 days 0.15 20.0 0.1 13.3 0.075 10.0
One Year Delay Total 32.9 22.4 16.5
366 days and beyond 0.2 52.6 0.15 39.4 0.1 26.3
Two Year Delay Total 85.5 61.8 42.8
 Review Report on new SO2 emission norms
Analysis of MOEF&CC notification dated 31.03.2021
 It may be noted that CERC (Terms and Conditions of Tariff) Regulations, 2019 has provision for
additional capitalization for installation of additional equipment for meeting new emission norms/
standards. However, these regulations do not include pass through of penalty levied on generating
companies on account of the non – compliance of emission norms. Therefore, the entire penalty is
likely to be borne by TPP concerned.
 Environment compensation for a typical 500 MW unit operating at 60% PLF is calculated in
table. It can be seen from table that EC is increasing after six months and further increasing in 2 nd
year. Environment compensation is 13 cr. in 1st six months, 20 cr. in next six months and 52.6 cr.
in 2nd year for thermal plants under category A.
 The amount 33 cr in 1st year and 52.6 cr in 2nd year onwards is quite high compared to the profit of
a thermal power plant as EC will not be passed through in tariff instead may have to be borne by
generating utilities.
 Further, EC should not be made unending/perpetual. Instead it should be allowed for a limited
period beyond which the plant may be asked to shut down. Otherwise the definite purpose of EC
will be defeated.
 Review Report on new SO2 emission norms
Apprehension:
 It may be noted that CEA, representative of thermal generating utilities, equipment manufacturers
and suppliers/ vendors were not consulted during preparation of new environment norms 2015
about status/ requirement of the basic infrastructure for meeting SO2 norms by all TPP in one go
which might be the main reason for missing the target 2017 or 2022.
 The kind of infrastructure required for 180000 MW thermal capacity (470 units) can easily be
understood from Table where the requirement (in Metric Tonnes) of materials for a typical FGD
system for a 2x500 MW TPS is estimated.
Sl. No. Major Materials Materials Requirement
 Even after submitting
i Cement 25000
ii Structural Steel 15000
the ground reality, issue
iii Reinforcement steel 5750-6000 & challenges of FGD
iv Stainless steel & plates 350-400 implementation, CEA’s
v Aluminum 50-70 apprehension was
vi Casting and Forgings 200
undermined by not
vii Casting and Forgings special alloy / 50
Duplex stainless steel considering proposed
viii Tube & Pipes 600-800 graded action plan which
xi BQ Plates 30 may become the reason
x C276 clad/sheet for absorber 350-375 for missing target 2024
xi Titanium Gr2 for ducting 300-350
again.
 Review Report on new SO2 emission norms
Ambient Air Quality of Thermal Power Plants

 The data was analyzed for an installed capacity of 123324 MW by CEA and has been
tabulated as below. Plant capacity is categorized considering the maximum and average
value of SO2 levels in their vicinity.
 Thermal Power Plant capacity categorized considering the average value of SO 2 levels in
their vicinity.

SO2 Avg. 0-20 20.01-40 40.01-80 80.01-380 380.01-1600 >1600

(μg/m3)
Thermal 92256.5 27287.5 2940 840 0 0
Capacity
Percentage 74.8 22.12 2.38 0.68 0 0
 Review Report on new SO2 emission norms

Ambient Air Quality of Thermal Power Plants

 Thermal Power Plant capacity categorized considering mainly the maximum levels of SO 2
in their vicinity averaged over a period of one year.

SO2 Max. 0-20 20.01-40 40.01-80 80.01-380 380.01-1600 >1600

(μg/m3)

Thermal 37870 43914 26310 15230 0 0

Capacity
Percentage 30.70 35.60 21.33 12.34 0 0

 As per the above data, immediate action may have to be considered for a capacity of about 12%.
 Review Report on new SO2 emission norms
The chemical equations:
Wet lime FGD technology
a.CaCO3(s) + SO2(g) → CaSO3(s) + CO2(g)
b.Ca(OH)2(s) + SO2(g) → CaSO3(s) + H2O(l)
c.CaSO3(aq) + 2H2O(l) + ½O2(g) → CaSO4·2H2O(s)
(Gypsum)
Dry Sorbent Injection (DSI) FGD technology
a. 2NaHCO3(s) + heat → Na2CO3(s) + H2O(g) + CO2(g)
b. Na2CO3(s) + SO2(g) +1/2(O2)→ Na2SO4(s) + CO2(g)
c. Na2CO3(s) + SO3(g) → Na2SO4(s) + CO2(g)
Seawater FGD technology
a. SO2(g) + H2O(l) + ½O2(g) → SO42−(aq) + 2H+
b. HCO3− + H+ → H2O(l) + CO2(g)
One mole CO2 is being generated by
absorption of one mole of SO2 in all
desulphurization process.
Additional 0.5% CO2 will be
produced to neutralize SO2. The coal
consumption is also expected to
increase up to 1 % (due to APC)
depending on the FGD technology and
Green House Gas (CO2) will be
released additionally due to increased
coal consumption.
Thus global warming and Climate
Change shall be worsen further with
the implementation of FGD.
The increased APC also reduces the
efficiency of power plants.
 Review Report on new SO2 emission norms

Implementation of FGD system randomly may causes followings:

i. Increase of CO2 emission
ii. Increase of water consumption
iii. Increase of auxiliary consumption thus burning more coal means further increasing CO2
emission.
iv. Increase of limestone consumption means more mining, more transportation, thus more
consumption of electricity and/or diesel. Therefore more coal burning and more dust pollution
& CO2 emission.
v. Increase of transportation of Gypsum byproduct thus, further increasing CO2 emission.
vi. Issue of low grade Gypsum disposal just like ash as no buyer for the same
vii. Finally increasing cost of electricity thus more burden on common person
 Review Report on new SO2 emission norms
Source Apportionment of Delhi NCR Region TERI report (2018)
 In a report prepared by TERI in 2018, the inventory of the various pollutant and their sources
was estimated for Delhi and NCR region which is considered as a highly polluted area in the
country.

 The results are contrary to the general perception that power plants are the major contributors
of pollution. The power plant contribution is only 26%, (567kt/yr) of the total industrial
pollutant load (2271kt/yr). Further, Power plants contribute a mere 6% of the total annual
pollutant (PM10, PM2.5, NOx, SO2, CO and NMVOC) load in NCR.
NCR Region
Transport Residential Agriculture Industries Power
kt/year Burning Plant
Transport 3306 33% NOx 60% 4% 3% 10% 15%
NMVOC 53% 22% 13% 2% 1%
Residential 2465 25%
CO 35% 34% 16% 12% 0.3%
Industries 1704 17% PM2.5 13% 25% 19% 24% 8%
Agriculture Burning 1306 13% PM10 7% 20% 17% 28% 7%
Power plant 567 6% SO2 0.5% 2% 1% 62% 33%

 Since then one of the major thermal power plant Badapur was closed down in the capital and
the emission contribution of thermal power plants would have dropped sizably.
 Review Report on new SO2 emission norms

IITD Draft Report (June 2021)

 The preliminary studies carried by IITD under CEA-IITD MOU was shared in the forum
attended by CEA Thermal division.

 In the IITD presentation, trends in emissions was analysed for few of the power plants. As per
the data presented for Jhajjar Power Plant (2x660MW) in which the FGD was commissioned
in 2019, the implementation of FGD has no impact on the ambient air quality of the plant.
 Review Report on new SO2 emission norms
AAQMS DATA -NTPC Dadri

Parameter Week

6th July – 13th- 19th 20th – 26th 27th July – 2nd 3rd- 9th Aug 10th -16th 17th-23rd 24th Aug- 31st Aug- 6th 7th -13th 14th-20th Sept
12th July July July Aug Aug Aug 30th Aug Sept Sept

Load (MW) 344 403 414 149 399 533 634 575 616 960 933

PM10.0
33.04 51.52 31.87 38.85 30.28 26.67 21.17 6.35 36.90 78.56 96.16
#DIV/0! #DIV/0! #DIV/0! #DIV/0! #DIV/0! #DIV/0! 22.04 24.52 48.99 110.51 138.38
41.44 58.55 37.16 48.01 32.91 28.40 21.03 19.9 43.06 94.58 123.35
PM2.5
14.75 21.35 14.32 15.82 14.89 12.65 8.56 5.38 17.65 36.94 44.51
#DIV/0! #DIV/0! #DIV/0! #DIV/0! #DIV/0! #DIV/0! 10.35 11.72 21.87 48.25 56.15
18.38 29.64 18.53 19.39 19.41 17.64 11.36 11.87 24.75 48.87 59.95
SOx
8.76 8.94 8.56 8.69 8.24 8.18 8.84 8.99 9.14 9.66 10.95
7.48 6.81 6.97 8.24 8.36 8.34 8.35 8.48 8.45 7.87 8.33
10.47 9.80 9.15 9.03 8.87 8.76 10.06 10.87 11.11 11.80 12.24
NOx
7.97 11.98 17.23 19.99 8.24 10.42 11.95 11.08 15.40 15.29 15.15
10.46 9.71 8.97 10.53 15.68 10.89 13.58 13.06 13.67 12.92 13.96
12.35 10.66 10.53 10.03 9.93 10.04 12.32 13.1 13.23 13.97 13.89

36
 Review Report on new SO2 emission norms
AAQMS DATA -NTPC Dadri

Parameter Week

21st-27th 28th Sept -4th Oct 5th Oct-11th Oct 12th -18th Oct 19th Oct -25th 26th Oct to 1st 2nd Nov to 8th 9th Nov to 15th
Sept Oct Nov Nov NOv
Load (MW) 486 451 577 546 270 219 0 0

PM10.0 76.59 119.73 125.50 145.87 161.2 178.7 248.0 207.4

102.17 178.16 219.51 231.58 279.0 289.3 371.4 282.7
95.55 171.13 193.69 219.00 242.4 301.5 382.8 283.3
PM2.5 33.23 50.58 59.02 73.77 84.1 101.6 132.4 117.1
40.06 67.47 91.99 109.30 124.1 145.6 195.3 165.8
42.92 67.45 74.47 115.80 120.1 169.2 203.4 164.2
SOx 10.39 10.32 11.17 11.03 11.0 7.8 10.5 11.9
8.30 9.65 11.15 13.37 19.8 14.8 13.4 8.3
12.35 12.65 9.71 9.71 10.8 11.0 11.5 8.2
NOx 12.50 21.39 19.52 20.56 14.5 17.0 23.2 26.1
13.86 13.34 18.19 17.56 18.8 17.1 18.0 20.2
13.85 13.98 8.82 4.16 4.0 8.8 8.9 13.5

37
 Review Report on new SO2 emission norms
AQI During Shutdown at Dadri
500
450 Load AQI
400
350
300
250
200
150
100
50
Source: NTPC Ltd.
0
1-Oct-20 16-Oct-20 31-Oct-20 15-Nov-20

 From the above AAQMS data trend it can be seen that, even after shutdown of all Coal fired units
on 29th October’20, Ambient Air Quality (AQI) is either in same condition or has deteriorated. It
shows no correlation of stack emission from Dadri plant and the Ambient Air Quality which
requires further analysis.
 Ambient Air Quality SOx/Nox During Shutdown
at Dadri (Contd.)
MW µg/ m3
1200 Load (MW) 40

SOx
35
1000 N Ox
30
800
25

600 20

15
400
10
200
5

0 0
27th Apr -3rd May 8th -14th Jun 20th – 26th Jul 31st Aug- 6th Sept 12th -18th Oct

Source: NTPC Ltd.

 From the above AAQMS data trend it can be seen that, the ambient levels of SOx and NOx
are well below 40µg/m3 which is very good. Even after shutdown of all Coal fired units on
29th October’20, NOx is either in same condition or has deteriorated. However, SOx level is
almost same.
 Review Report on new SO2 emission norms

Way Forward
 It is suggested that category C units timeline may be spread in four years i.e. 2028, 2029,
2033 & 2034 according to their distance from million plus city/critically polluted area/
Non Attainment city or on the basis of SO2 level in ambient air. This will help in
understanding the performance of the emission control equipment, their effectiveness and
give a time for course of correction.

 Study may be conducted on SO2-reduction against CO2 increase in flue gas emission by
FGD system including increase of pollution due to mining, transportation of limestone &
gypsum. Accordingly exemption may be given to few thermal power plants where SO2
level in ambient air is very less compared to permissible limit.

 A Task Force may be constituted compromising representative of MOP, MOEF&CC, NITI

Aayog, CEA, CPCB, Utilities/Contractors/Manufacturers, they may review the category or
create separate category for controlling SO2 emission from chimney for smooth
implementation of new environment norms considering phased manufacturing program of
FGD equipment under Atma Nirbhar Bharat.
Thank you