1. Present Preparedness and Constraints for the Implementation of New MoEF&CC Emission Norms vis-à-vis Expansion of Generation Capacity
Shiv Kumar Dube
Senior Fellow
TERI-The Energy and Resources Institute
Rohit Pathania
Programme Manager (Energy)
&
Soundaram Ramanathan
CSE-Center for Science and Environment
Centre for Science and Environment

2. Indian Power Scenario: Sector divide [1/2]MW
% of Total
State Sector
84,627
24.6%
Central Sector
103,761
30.2%
Private Sector
155,511
45.2%
Total
343,899
Source: Total Installed Capacity  (As on ) - Central Electricity Authority (CEA); Ministry of Power, GOI: August 24, 2018

3. Indian Power Scenario: Fuel type [2/2]MW
% of Total
Total Thermal
222,693
64.8%
                                             Coal
196,958
57.3%
                                             Gas
24,897
7.2%
                                             Oil
838
0.2%
Hydro (Renewable)
45,403
13.2%
Nuclear
6,780
2.0%
RES* (MNRE)
69,022
20.1%
Total
343,899
* Installed capacity in respect of RES (MNRE) as on
RES (Renewable Energy Sources) include Small Hydro Project, Biomass Gasifier, Biomass Power, Urban & Industrial Waste Power, Solar and Wind Energy: Source: Total Installed Capacity  (As on ) - Central Electricity Authority (CEA); Ministry of Power, GOI: August 24, 2018

4. The PLF in the country (Coal & Lignite based) from 2009-10 to 2018-19 is as under:
Year
PLF
Sector-wise PLF (%) %
Central
State
Private
77.5
85.5
70.9
83.9
75.1
85.1
66.7
80.7
73.3
82.1
68.0
69.5
69.9
79.2
65.6
64.1
65.60
76.10
59.10
62.10
64.46
73.96
59.83
60.58  
62.29
72.52
55.41
60.49
59.88
71.98
54.35
55.73
60.67
72.35
56.83
55.32 *
63.24
74.51
61.72
56.02
* Upto June 2018 (Provisional), Source : CEA

5. The annual growth in power generation during recent years is as under:
GROWTH IN CONVENTIONAL GENERATION (%)
GROWTH IN RENEWABLE GENERATION (%)
GROWTH IN TOTAL GENERATION (%)
2.7 -
6.6
5.56
8.11
4.01
6.04
8.43
5.64
6.47
5.69
4.72
23.97
5.80
3.95
23.48
5.23
 (Upto May 2018)*
1.92
14.95
2.80
* Upto June 2018 (Provisional), Source : CEA

6. Overall Growth rate recorded by 5.35 %
The Overall generation (Including generation from grid connected renewable sources) in the country has been increased from
1,110 BU during to
1,173 BU during the year ,
1,241 BU during and
1,306.6 BU during
The performance of Category wise generation during the year was as follows:-
Thermal Increased by       4.27 %
Hydro Reduced by            3.07 %
Nuclear Increased by       0.87 %
Bhutan Import  Increased by       %
Renewables Increased by   %

7. New Standards– Overview
Under CREPS, in 2003, industry had committed to improve its env. Performance (meeting 100mg/m3 particulate matter levels; SOx/NOx standards to be implemented by 2005/06), But made no progress
Meanwhile, ECs given since 2008 already require plants to meet tighter PM norms (at 50 mg/m3 for 500 MW size units) and space for FGD since 2003
New standards reasonable and much needed
mg/Nm3
Unit size
Installed before Dec 31st, 2003 *
Installed between and 2016 *
Installed Jan 1, onwards PM
All
100 50 30
SO2
<500MW
600 --
>=500MW
200
NOx
300 Hg
0.03 (>500 MW)
0.03
Existing plants – comply by Dec 22, 2017
Water Use:
OTC plants convert to CT;
CT plants to cut water use to 3.5 m3/MWh; New plants to use 2.5 m3/MWh
Centre for Science and Environment

8. New Standards – Overview
New Indian Standards is in line with the global standards.
In fact, China has introduced even tighter standards for metro and highly polluted areas (PM:10 mg/Nm3, SO2 35 mg/Nm3 and NOx 50mg/Nm3)
Global comparison
mg/Nm3 PM
SO2
NOx
China 10 35 50
Japan
 Permit
200
USA
14.5
100
110 EU 30
Centre for Science and Environment

9. New Standards – Benefits
Reduction in pollution (BAU vs. New norms) assuming generation in as per CEA’s draft Electricity policy, December 2016
Water use – 85% reduction – largely due to conversion of OTC to CT
PM emissions – 65%
SOx – over 85%
NOx – almost 70%
*Emissions in lakh tonnes
Centre for Science and Environment

10. Power Sector – Concerns
Power Sector cited challenges – roots to three major reasons
Technology – unsuitable for Indian coal
Tariff recovery/investments – very high investments leading to significant tariff increment
Timelines – too stringent
- Many still in denial mode – don’t need the standards
Centre for Science and Environment

11. Technology
Pollution control technology – mature; sufficient global supply
ESP
Vast majority needs fine tuning/minor ESP up-gradations,
Only 13 GW need to add field
SO2
FGD – only for larger units
Other units – low cost solutions like DSI, partial FGD etc.
NOx
Existing boilers – burner modification, low NOx burners, combustion optimization
SCR/SNCR is not necessary for existing power stations
Centre for Science and Environment

12. Emission Control Technology Costs
Technology required
Approx. cost
ESP up gradation
Rs 5–15 lakh/MW
Partial FGD
Rs 25–30 lakh/MW
FGD
Rs 50–60 lakh/MW
De-NOx
Rs 10–15 lakh/MW
SCR/SNCR
Rs 20–25 lakh/MW
Based on estimates provided by leading global suppliers (GE-Alstom, Mitsubishi, Doosan, Andritz etc)
Investment needed by a plant would depend upon applicable norm, existing pollution control technology and actual emissions level
Accordingly, investment may range from:
Rs lac/MW for older plants
~ Rs 50 lac/MW for small and mid-life units (assuming partial FGD); lower if cheaper De-SOx alternatives
Rs 50 – 60 lacs for most over 500MW, post-2008 units (FGD needed, but little expenditure on PM and De-NOx).
SCR/SNCR is not needed for existing capacity.
Centre for Science and Environment

13. Tariff Impact
APP has claimed tariff impact of Rs /unit - Far exceeds estimates provided by global suppliers
CEA’s latest Estimates of tariff impact - Phase in-plan, December, 2016
ESP up-gradation - 9 paisa/kWh
FGD installation - 32 paisa/kWh
NOx control - 7 paisa/kWh
CSE has requested ERCs to independently collect estimates of CAPEX, tariff impact and timelines. Meanwhile our survey of ERC shows:
Karnataka, UP and Haryana ERCs have indicated tariff impact ranging between 20 – 30 paisa per unit
CEA/ERC REVISED COSTS ARE LOWER THAN THEIR PRIOR ESTIMATES (40-90 paisa per unit) AND IN LINE WITH CSE ESTIMATES (20 to 30 paisa per unit)
Industry in the process of clarifying if ERCs will approve these investments for cost recovery – MoP – recently given a clarification
CERC representative conveyed CAPEX approval is not a problem - Permitted under ‘Change of Law’ provisions under both Section 62 (Cost Plus) and Section 63 (Competitive Bids) of Electricity Act.
Industry/CERC seeking benchmark costs from CEA
Delay may impact financing from banks/markets.
Centre for Science and Environment

14. Tariff Impact Emerging benchmarks - FGD Source: CSE Survey, 2018
Centre for Science and Environment

15. Issues - Timelines
Timelines were achievable when the norms were announced
But little progress – pre-execution work such as technology identification and tariff application could have been done – undertaken only now
Meeting PM, NOx, water use norms still possible given procurement time of less than 6 months.
installation can be done during scheduled shut down or need less than 1 month shut down
FGD construction could take up to 24 months.
Technology
Construction time
Downtime
Electrostatic precipitator (ESP)
~ 3–6 months
~ 20–30 days
Flue gas desulphurization (FGD)
~ 18–24 months
~ 30–90 days
Selective Catalyst Reduction
~ 5 months
~ 30 days
Selective Non-Catalyst Reduction
~ 4 months
~ 7 days
Low NOx burner, OFA etc.
~ 1 month
~ 15–20 days
Centre for Science and Environment

16. CPCB- Region wise FGD plan Section-V direction
FGD installation roadmap as identified in the CPCB notification.
Acceleration of timelines for plants in NCR but, overall plan is still back-loaded
Target Year SR WR ER NR
Total Capacity (GW)
Immediately
0.8
1.3 -
1.5
3.6
2018
0.5
2019
2.4
12.0
14.4
2020
5.8
8.7
1.2
6.7
22.3
2021
7.7
33.8
8.8
9.5
59.7
2022
14.7
22.2
17.3
8.2
62.2
No Comments
0.6
Total (GW)
31.4
66.9
27.3
37.8
163.4
Source: CPCB Directions, 2017
Centre for Science and Environment

17. CPCB- NOX control through LNB & OFA Section-V direction
NOX Control roadmap as identified in the CPCB notification.
No concrete action-plan for NOx control till 2022
Target Year SR WR ER NR
Total Capacity (GW)
2019 -
12.0
2022
31.4
66.9
27.3
25.8
151.4
Total (GW)
37.8
163.4
Source: CPCB Directions, 2017
Centre for Science and Environment

18. Status Assessment Uttar Pradesh Madhya Pradesh Delhi-NCR
State GENCO yet to initiate feasibility for other power plants -sole focus on FGD for Anpara D
Operation improvement needed for NOx, PM control
Uttar Pradesh
One FGD installed – 500MW
Tender floated for STPS in the state – no results yet
Most Companies yet to accept findings of company wide feasibility studies
Madhya Pradesh
2019 deadline given by CPCB
Only two power plants out of 13 potentially on track
Tenders incomplete for private GENCOS – wait and watch approach
State GENCOS yet to complete feasibility studies
Delhi-NCR
Centre for Science and Environment

19. Recent Developments
CSE advocated Direct Sorbent Injection (DSI) is feasible instead of FGD - tendering of NTPC – Dadri TPS.
Adani Power: Recovery of FGD costs - under "Change in Law" provisions of the PPA dated
Petition to install and operate FGD in units 7, 8, and 9; FGD cost approved - Rs Cr for 3X660 MW and Increased operating expenditure Rs/KWh, capacity power charges Rs/KWh.
MoP issued letter to CERC – Mechanism for Implementation of Environmental norms under “Change in Law” with clause.
Supreme Court Hearing:
MoEF&CC filed an affidavit - due to practical difficulties it is difficult to implement the norms in the desired time interval  
the Supreme Court asked further clarifications from the ministries
MoEF&CC submitted an affidavit saying specific compliance orders have been issued to TPPs. They have negotiated for reduction of compliance period with Ministry of Power from seven to five years.
February EPCA committee submits advisory report to the Supreme Court on this issue.
April Supreme Court ask MoEF&CC to submit implementation status; the MoEF&CC complied.
25 July 2018 – SC expresses unhappiness with timeline; asks for commitment from MoP after deliberation
Centre for Science and Environment

20. Constraints of the power sector
Centre for Science and Environment

21. Technical Incorrect Measurements
Emissions readings all over the place
CEMs systems unreliable – unit of measurement versus reporting; no calibration
Stack reports issued by third party laboratories incorrect
Consultants relying on incorrect measurements – incorrect technology suggestions
Proper water accounting absent in most plants
No focus on determining coal quality through ultimate analysis – most plants unaware of sulphur content in coal used by them
Centre for Science and Environment

22. Regulatory
In principle cost approval – some SERCs rejected petitions – difficult for power stations to spend significant amounts without assurance.
Technology selection capability – asking CEA referral – bottleneck being created – SERC capacity
Search for benchmark costs – will vary significantly with project
Monitoring oversight – joint effort of SERC and SPCB?
Lack of incentive – waiver for MoD good first step
Old power stations – worth the money?
Centre for Science and Environment

23. Thank you Shiv Kumar Dube Shivkumar.Dube@teri.res.in Rohit Pathania