Dear Dr. Sugathapala,

First of all many congratulations on your approach of letting the stake holders air their views/ideas on the subject of air pollution with the ultimate goal of formulating a policy on air pollutions for the benefit of the people of Sri Lanka. Air pollution just like other pollutions can not be seen by the people unless and until the medical research reveal the causes of mortality of human beings due to different exposure levels. The approach should work because, this way you are going to crate awareness and educate us.
It is very important to generate the inventory of pollutants(as you have mentioned). You may have already done that. But, updating it based on the medical findings is also important. It may be that we in Sri Lanka being an island nation very close to south India could be vulnerable to cross broader pollution. Then the sources of (stationary or otherwise) from different sectors. The transfer mechanisms, modes of agglomeration from the original source based on the transport properties in the atmosphere need to considered prior to setting the standards. Will write more after doing bit of homework.

Thank you

kapila

Thanks Thusitha for your effort to take comments of the community for the new emission standards. I think this is also important as vehicle emission standards but I see lack of political will in this regard probably since it is not so visible as vehicles.
I am not sure how the industry based standards have been implemented successfully in other countries. However, I believe that the proposed 3-Tier approach is sensible starting with equipment. The next control is more appropriate to be imposed based on emission loads rather than the type of industry. It may bring in equity to the argument between the size of industry and industry specific emission factors since emission load is a product of industry size and emission factor.

Dear Dr Suagathapala & team,
First a big thanks goes to everyone who lead and work on this emission standard. No argument it is a timely requirement.

Dear All,
I am trying to elaborate the value adding part of this removing the ‘compliance’ lenses.

In current context industries (entities) do not think achieving a statutory requirement only as an oblige, but they believe it rather as a corporate value, without merely a compliance case. Sustainability reporting, corporate awards and various corporate competitions are not new to Sri Lankan case now. Some of local entities made global benchmarks in these awards.

Aligning with global trend on business reporting the GRI - Global Reporting Initiative plays the leading role supported with WRI, IPCC & WBCSD guidelines. EU and USEPA are the mostly accepted environmental guidelines in these schemes. However WRI speaks in two ways on emissions: Absolute & Specific.

Shall we also consider these facts also in our proposed scheme? Because, end of the day corporate also requires a value creation for ecological investments made. Also this will reduce double handling of work on reporting (in two different formats or units) for compliance and sustainability reporting.

Open for your comments please
Chalaka Fernando

I appreciate very much for the comments and suggestions. I hope that members from Central Environmental Authority (CEA) (and others) too contribute to the discussion and reply to the comments.

As I indicated earlier, one of the main difficulties we had in deriving locally acceptable emission standards for stationary sources is the lack of data on baseline emissions. Development of an emission inventory is a key element in Air Quality Management Programme. In fact, Monitoring Emissions of Power Plants and High Polluting Industries and Prepare and Maintain Emissions Inventory are two main strategies/activities in the Clean Air Action Plan 2015. I think the time is right now to review the progress and see whether these activities could be commenced / completed by 2015, as stipulated by the action plan and also to identify the revisions, if required. I hope that AirMAC could coordinate that, as the overall responsibility of implementing the Clean Air Action Plan lies with AirMAC.

I agree with Mr. Yalegama’s comment on the incorporation of emission load (representing the quantity of emission rather than emission concentration) into the standards. The Tier 2 in the proposed standards intend to specify the maximum permissible emissions from each process (and related equipment) of different industries identified as important. In some cases, the emission limits are specified under different capacity levels so that the concern of emission load is partly address. For example, in oil fired thermal power plants five capacity ranges are specified as (i) > 1 MWe, (ii) 1 – 3 MWe, (iii) 3 – 25 MWe, (iv) 25 – 100 MWe and (v) <100 MWe, each with different level emission standards (e.g. For smaller capacity ranges some of the pollutants are covered by a minimum stack height requirement than emission concentrations). Another way to incorporate the emission load is to have a phase-in strategy in implementing the standards, with large industries and processes are taken in the first stage. We are going to discuss this aspect in the next week.

Dear Dr. Sugathapala,

I congratulate you for enabling this important initiative and also the CEA for setting the platform for the emission standards of stationary sources in SL.
At this juncture, I consider the analogy of the Energy efficiency standards and labeling process where a typical “Market PUSH & PULL” strategy has been effectively utilized to work. In the absence of actual data and baseline values for the local case, a 3-tier approach, at the point of time is well suited. This will enable a creation of the inventory over a detailed spectrum which would in turn provide a sound baseline to initiate the process. This will also enable ironing out implementation issues, stakeholder concerns and also to understand the economic impacts of the whole process together with some breathing space for monitoring & evaluation which is extremely essential to the process. After reaching a reasonable steady state of operation, then the standard should move to a new Window where the issue of equity is to be addressed. This could then take the form of the pollution load based strategy. This procedure appears to me as more practical than “leap-frogging” to pollution load based scenario.

I have received several comments on emission standards for stationary sources in Sri Lanka, via CleanAirSLNet. On behalf of them, I'm posting their feedback in Clean Air Portal, and hope that they too register soon.

Following cmments are sent by Mr. Hemantha Withanage, Executive Director, Centre for Environmental Justice, Sri Lanka.

dear Dr Sugathapala,
Please see my response below

- Is there a need for implementing emission standards for stationary sources? (how do you rank this among other activities in the Air Quality Management in Sri Lanka?)
yes. I believe emission from power plants contribute to air quality deterioration in Colombo. However, I remember we had a discussion some time back that the SO2 level is very high in Colombo in certain times. As I remember no explanation was given.

I wonder whether the pollution coming from railway engines, ships also covered under mobile sources.

Is there a separate or similar air quality management for indoor air pollution. I believe you cannot make standards for house hold cooking stoves but may be you need to have the air quality management for health purposes.

- If yes, what are the key industries and processes to be included (in addition to those already in)?
the diesel and other thermal power in Colombo and some suburban's,
Coal power stations
Industries such as cement, oil refineries, metal recycling, textile( I recently visited one factory area which people complain about air pollution)
What about burning in open dumping yards.
Bakeries ( I have got many complaints before)
sugar processing industries such as Pelwatta
Brick kilns, tile factories make lot of pollution

- Are there industries and processes that are not (or less) important? Should these be removed from the list (or consider in a second phase of implementation)?

- Are the pollutants selected adequate? Are there pollutants to be added or removed?
How about PCBs

- Is three-tier approach rational? If not, any alternative approach?

this is fine with me.

best regards,

Hemantha

Following comments were sent by Dr. M.A.R.V. Fernando, Univerisity of Moratuwa.

Dear Thusita,

As informed you during our discussion on above subject I am very happy about this initiative. Considering the areas that you have indicated I wish to add a few more;
Timber and wood industries (Saw milling as well as Timber component manufacture - including toys and furniture).

Spray painting (both small scale garages and large scale industries including furniture where spray painting is practiced and pollutants such as thinner is released to the atmosphere.

Small scale and large scale incinerators.

Further I wish to emphasize that this initiative should not be just a red tape and block to industry and industrial development. Hand in hand with this initiative should go the other oart of providing a solution to the problem. If any industry is causing a pollution problem we must not only make them aware and realize that fact but also must provide them with the technology and facilities to overcome the same. Very often this can be achieved through parallel transfer of technology and in case it is not freely available this initiative should venture into necessary research and development activities as well. Important thing is not to harass the industries or block their development but assist them to develop properly.

Regards,

Dr M.A.R.V.Fernando

Following two set of comments were sent by Dr. Selie Fernando and Mr. Hemantha Withanage, especially in response to the comments posted earlier by Mr. Chalaka Fernando.

(1)
Dear Chalake Fernando,
I would appreciate your suggessions as It is very very valuable Idea and ecofriendly as well as feasible,value addition as well.I too suggest the same.

Dr Selie Fernando.

(2)

dear all,

I agree that this is one option we could consider. However, the law only gives mandatory options. To my understanding GRI is based on voluntary disclosure. How many industries will do that.

On the other hand mandatory standards and the enforcement is not very much successful in Sri Lanka. To my understand out of 70,000 industries only about 17,000 have obtain the Environmental Protection licenses. CEA has more than 500 cases which mostly about non compliance. They have 15 legal officers and spend over 2 million budget to deal with those issues annually. I would say EPL is half failure.

Same time mandatory vehicle emission standards also half failure. Everyday I see hundreds of vehicle in the road with thick black smoke. Mostly government vehicles busses and specially most expensive vehicles such as pajeros and Prados. People obtain license by bribing testing centers just because it is mandatory for annual license.

I would agree that both voluntary and mandatory standards are necessary. I think GRI is also based on third party monitoring and also consensus based process. How would this work in Sri Lanka?

best regards,

Hemantha

Following comments were sent by Dr. Suren Wijeyekoon, Univerisity of Moratuwa.

Dear list members,

Can someone clarify whether the proposed standards are in addition to current ambient air quality standards or are going to be APC standards replacing the existing general standards? The point is, we need to have secondary pollutants also monitored/controlled for health reasons.

- Is there a need for implementing emission standards for stationary sources? (how do you rank this among other activities in the Air Quality Management in Sri Lanka?)
Absolutely.

- If yes, what are the key industries and processes to be included (in addition to those already in)?
Are brick kilns, ceramic kilns etc. included under some other category?
Are industries with operations such as spray painting, sand blasting covered?
Open operations such as metal quarries and crushing plants ?
Waste oil and plastic recyclers?

- Are there industries and processes that are not (or less) important? Should these be removed from the list (or consider in a second phase of implementation)?
- Are the pollutants selected adequate? Are there pollutants to be added or removed?
In addition to PM10, PM4 and PM2.5 are used in ambient air quality standards. There are many pollutants but as monitoring is expensive, we may have to start with the above.

- Is three-tier approach rational? If not, any alternative approach?
The three tier approach is good for screening, but an industry may have to comply with 2 or all 3 tier standards if applicable.

Under tier 1, under fuel types, waste oil is not specified? Waste oil comes under hazardous waste though many are using it (illegally) as a fuel for furnaces and kilns.

Dr. Suren Wijeyekoon

Thank you all for the feedbacks. We have spent more than a week for the discussion on first topic, and need to move into the second one now. However, prior to posting the second topic for discussion (which is on implementation issues on the proposed standards), I’ll try to give answers to some queries.

I thank Prof Attalage for sharing the approach adopted in the Energy Efficiency Standards and Labelling (to be implemented by Sustainable Energy Authority-SEA). He also highlighted some aspects of stage wise or phase in approach in implementation, which will be the topic of discussion for the coming week. The need of more data on actual emissions / baseline values is highlighted again. We will be able to gather such data during the first stage of the implementation and thereby would be able to refine/revise the standards. This could also help to develop emission inventory.

Mr. Hemantha brought out a very important point – the SOx emissions. There have been concerns over high concentration of SOx in Colombo in certain time. In my opinion, this situation could be attributed to thermal power plants / standby generators using furnace oil, as the sulphur content of furnace oil (3.5%) is much higher than auto diesel (0.3%) and super diesel (0.05%). I have a feeling that, according to measurements of SOx concentrations in exhaust, some power generation facilities use furnace oil with even higher sulphur contents. The most effective way to control the SOx emission is to introduce more stringent fuel quality standards on sulphur content, as the use of exhaust gas treatment technology would be too costly, especially for small capacity facilities. So, in the emission standards, SOx emission levels are set based on the present level of sulphur content and the capacity level of power plants. For standby generators and oil power plants <25 MWe, the SOx is controlled by minimum stack height with uncontrolled emission level based on fuel quality (presently 6100 mg/Nm3). For oil power plants >25MWe, SOx concentration limits are specified (in two levels based on the plant capacity), which require employment of SOx control equipment. For Coal power plant too SOx emission limits are specified corresponding to 0.8% sulphur content for plants with capacity < 50 MWe and 0.4% sulphur content for larger plants.

Emission regulations for marine vessels have not been included in mobile emission standards, though it could be a major source of SOx emission in certain areas. With reference to the query on indoor air pollution, still we do not have standards for indoor air quality, though it has a major impact over health problems. In my understanding, Ministry of Environment/AirMAC has initiated some activities in that line.

The list of industries include in Tier 2 supposed to cover the major polluting industries / processes. Other industries / processes are to be covered through the standards at Tier 3 (general pollutant from equipment/processes) and some will cover through Tier 1, if they use equipment listed at that level (i.e. boilers, incinerators, standby generators and thermic-fluid heaters). For example, bakeries, brick kilns and tile factories are to be covered through standards in Tier 3 (which includes limits for PM, smoke/dust, NOx, SOx, CO, etc.). Timber and wood industries, waste oil and plastic recyclers too have to be covered under Tier 3. However, Non-metallic Mineral Processing Plants are included in Tier 2.

Spray painting / surface coating processes (involving emission of volatile organic compounds – VOCs) are not listed under Tier 2. One of the main reasons of this situation is the complex nature and characteristics of VOC emissions compared to other pollutants and processes considered in the standards. The control of VOC emissions in many processes and products is achieved by introducing standards to limit the content of VOC in raw materials / solvents. Prior to the development of such standards, the baseline data on VOC content in different raw materials and solvent usage in different industries should be collected. Till such time, the relevant industries could be requested to adopt appropriate techniques to control the generation and/or emissions of VOC to the ambient air. We have included a section on this issue in the emission standards document submitted to CEA so that they could act accordingly.

In terms of pollutants covered, PCBs are not covered, except for Dioxin/Furan, which is covered in Tier 3 as well as in Incinerators (Tier 1).

Under Tier 1, standards for power plant emissions do not specify waste oil (as a fuel) under a separate category. Firstly, it is not recommended to use waste oil as a fuel and therefore should be controlled by other means. Secondly, being oil, it is covered under “oil” and therefore should satisfy the combustion emission standards listed for oil based equipment.

With the above brief notes, the first discussion topic is concluded and I will post the next discussion topic soon. Yet, if anyone has comments or queries, please feel free to reply.

Dear All

With reference to the "Implementation of Emission Standards for Stationary Sources in Sri Lanka", I would like to present the discussion topic for this week.

As I have briefed in the document posted earlier, the proposed emission standards represent a very comprehensive one and intend to cover all the industries/processes and key pollutants. So successful implementation of such regulations would be a very challenging task. Prior to the implementation, several other essential aspects have to be addressed properly. These include (but not limited to) training / capacity enhancement of implementing staff, tools / equipment / instruments for emission measurement/ testing, awareness/education of all the stakeholders, establishment of monitoring and verification system, development of guidelines/information material for the industry, etc. Basically, the support from all the stakeholders is needed for implementation. Although the standards are mandatory requirement, incorporation of voluntary features could be a key factor for the success.

One of the major concerns raised is with reference to the present status of Vehicle Emission Testing Programme (VET). In VET, the tasks of emission testing and issue of the emission certificates are given to the private sector, while the responsibilities of overall management of the programme including monitoring, quality assurance, auditing, setting of standards, etc. lie with the government. Still the effective monitoring, quality control and auditing aspects are not in place, which leads to many issues. So, implementation of the proposed emission standards for stationary sources should look into the lessons learnt from VET programme.

Similar types of programmes may have been implemented in the regionally/internationally. Sharing of their experiences is also an important element in developing effective implementation strategy.

With the above brief remarks, I would like to get your comments and feedback on the following aspects:

(i) Potential barriers/challenges for successful implementation of the proposed emission standards,

(ii) Implementation strategy (including voluntary programmes / rewarding mechanism / recognition for better compliances - Emission Stars / penalties / Emission Certification fees / Monitoring mechanism / Mechanism for complaints from public and community organization)

(iii) Involvement of private sector in implementation:
(a) Not needed; wholly by CEA (or other government agencies)
(b) Needed; emission certification by independent private companies (say Emission Auditors accredited by CEA) or any other means.

(iv) Phases of implementation): Say starting with selected industries/large power plants and stage by stage inclusion of others.

(v) Regional/International experiences / best practices.

Following comments have been sent by Dr. Selie Fernando

Dear Thusitha Sugathapala,

I agree with your legislative text about the implementation of the standards for Sri Lanka, But we have to do it very comprehensive manner, as this is very costly (conversion of the industries into a green )there can be political influences and as I suggested in 2007 the dioxin law should be included to this as well, and there should be green carpet certificate too should be implemented, then the each industry has it's own green park around will be ecofriendly. Now the Holchim Lanka is a green industry likewise other industries too can be converted. I posted my legislative text on implementation of dioxin law too.

Dr Selie Fernando

Following cmments are sent by Mr. Hemantha Withanage, Executive Director, Centre for Environmental Justice, Sri Lanka.

Dear Dr Sugathapala,

I want to bring just one issue on sulphur. According to the EIA on Norochcholai it will bring only 0.65% Sulphur coal . However, there is a World bank document on the power generation in Sri Lanka justifying event 3% sulphur Coal for the same. I believe this is wrong. same time This bring the issue about having standards for the fuel itself not only for the emission. So I support having the stringent standards for fuel such as Coal, Diesel, furnace oil and burned oil which is the fuel for many industries.

I think this is the issue for vehicle emission too. Many countries have introduce Euro II . I remember we had this discussion some time ago. Can Airmac explain what is the Fuel standards we now have?

best regards,

Hemantha

Dear Hemantha

Thank you for bringing up the issues of Fuel Quality. I strongly believe that we now need some actions to improve the fuel quality in both liquid and solid fuels.

The proposed emission standards for coal power plants covers the SOx emissions equivalent to 0.4% Sulphur for plants with capacities greater than 50 MWe and 0.8% sulphur for plants with capacities less than 50 MWe. 3% sulphur content in coal is excessively high.

At present, our gasoline and auto diesel qualities are at the level of Euro 1 and super diesel is equivalent to Euro 2 (in terms of sulphur level). You may refer the attached document, which presents a comparison of auto fuel qualities in number of countries including SL.

regards

Thusitha

Following cmments are sent by Mr. Hemantha Withanage, Executive Director, Centre for Environmental Justice, Sri Lanka.

Dear Dr Sugathapala,

(i) Potential barriers/challenges for successful implementation of the proposed emission standards,

Like the EPL only few will be interested. As I wrote before out of 70,000 industries only 17,000 hve obtained the EPL. Lack of quality fuel. Official lethargy, corruption, lack of monitoring are big problems in Sri Lanka.
(ii) Implementation strategy (including voluntary programmes / rewarding mechanism / recognition for better compliances - Emission Stars / penalties / Emission Certification fees / Monitoring mechanism / Mechanism for complaints from public and community organization)
Perhaps introduce self monitoring with public disclosure of the report. US EPA has this system. Certainly green labels. But You may know that some products that has SLS standards are not upto the standards. certainly public complaints should be one way.

(iii) Involvement of private sector in implementation:
(a) Not needed; wholly by CEA (or other government agencies)
(b) Needed; emission certification by independent private companies (say Emission Auditors accredited by CEA) or any other means.
Our curent experience is Government has no proper mechanism. CEA is not so effective. Bringing private sector is not a solution too. This is mainly due to corruption. Perhaps establishing a oversight committee with academics and public, privet sector including CSOs could reduce the problems.
(iv) Phases of implementation: Say starting with selected industries/large power plants and stage by stage inclusion of others.

I suggest to start with large industries. Not in provincial basis but isladwide.
(v) Regional/International experiences / best practices

(i) Potential barriers/challenges for successful implementation of the proposed emission standards,

SME's will find it difficult to comply with all standards, due to lack of capacity, finances and use of old technology. For example a batchwise operated incinerator that is shut off before steady state is reached, cannot meet most of the stack emission levels.

(ii) Implementation strategy (including voluntary programmes / rewarding mechanism / recognition for better compliances - Emission Stars / penalties / Emission Certification fees / Monitoring mechanism / Mechanism for complaints from public and community organization)

In addition to voluntary mechanisms, the legally binding minimum limits are essential and should be enforced. EPL is the existing method of monitoring mechanism and should be strengthened.

(iii) Involvement of private sector in implementation:
(a) Not needed; wholly by CEA (or other government agencies)
(b) Needed; emission certification by independent private companies (say Emission Auditors accredited by CEA) or any other means.

CEA alone may find it difficult to monitor with the existing man power and facilities. Option b) is sensible, though subjected to limitations.

(iv) Phases of implementation): Say starting with selected industries/large power plants and stage by stage inclusion of others.

Large industries are easier to monitor but most pollution is caused by SME sector. Should implement for all allowing the SME sector to mature with the implementation system. We are already behind time in terms of enforcement of APC.

(v) Regional/International experiences / best practices.

Good lessons to learn but should understand the local environment.

Following cmments are sent by Mr. Anura Vidanagamag, ISB:

(i) Potential barriers/challenges for successful implementation of the proposed emission standards,

To setup emission standards, we should have a good cross section of existing emission levels of different industrial sectors. I doubt whether it is available except in few industries. Some time back ISB did a Boiler Study in DC Industry, there we measured emission levels in 50 odd factories. So that it is advisable to do a sample survey in different industrial sectors before we set the standards In VET program Air max measured the emission levels of existing vehicle fleet and then, introduced. Standards’ accordingly.

(ii) Implementation strategy (including voluntary programmes / rewarding mechanism / recognition for better compliances - Emission Stars / penalties / Emission Certification fees / Monitoring mechanism / Mechanism for complaints from public and community organization)

When it comes to implementation definitely it should be link with annual environmental license. Also it can be introduced low license fee for less emission industries.

CEA should have well organized monitoring programme together with qualified and reliable appointed agencies who can issue emission certificates.

(iii) Involvement of private sector in implementation:
(a) Not needed; wholly by CEA (or other government agencies)
(b) Needed; emission certification by independent private companies (say Emission Auditors accredited by CEA) or any other means.

Due to the scale of the project, CEA may needs private sector involvement for implementation. Even in present scenario, CEA has appointed accredited organization to measure the environmental parameters. what CEA should do is to train them to bring them into same platform. Also CEA should recommend reliable equipments.

(iv) Phases of implementation: Say starting with selected industries/large power plants and stage by stage inclusion of others.

I think implementation should start with large industrial sectors such as tea industry, garment industry etc. and also in power plants. But we have to think abut legal implication, when we are omitting some sectors

(v) Regional/International experiences / best practices.

We may study the exiting standards and implementation mechanism in the regional countries and also in develop countries to minimize to possible failures in the project. In VET program we did all these things but still there are problems,

Following comments have been sent by Dr. Selie Fernando

Dear Dr Sugathapala,

I posted the legislative text for the implemntation on dioxin emission according to the Japanees standards and it found that the Sri Lanken biota is highly contaminated by dioxin and I am checking the air levels in NWP and human contamination and I have already posted the legislative text to the prof. Ajith de Alwis and please get that and include that too for this implementation procedure and if we start this phase wise will there be objections to proceed by the other groups ?We have to forward this legislative text to the HON MNISTER FOR THE IMPLEMENTATION AND BEFORE THAT WE HAVE TO DESIDE THE FINE FOR THE PENALTIES AND VIOLATORS AND maintananance and monitoring group,and issueing the certificates so on.I think you include the dioxins and pops part too for this implementation procedure.

Dr Selei Fernando.

Ayubowan!

In the Philippines, the legal framework that set up the Emission Standards for Stationary Sources is the Philippine Clean Air Act (1999), which I have tried to read on to share with you some interesting sections that might be of interest.

The act specifically identified the pollutants, maximum permissible limits of concentration and the method of analysis. You can view them through this link: http://www.chanrobles.com/philippinecleanairact.htm

Implementation after passing of the law in 1999:
Existing industries were allowed a grace period of eighteen (18) months for the establishment of an environmental management system and the installation of an appropriate air pollution control device

Emissions inventory from stationary sources conducted by the Environmental Management Bureau every three years

Self-Monitoring Report. - Each existing stationary source shall submit to the Bureau Regional Office where the facility is located a self-monitoring report of its emission rates, indicating the status of compliance with current standards.

Fines and Penalties: through the Pollution Adjudication Board (PAB), violators were imposed a fine of not more than One hundred thousand pesos (P100,000.00) (roughly equivalent to 220,000 Sri Lankan Rupees) for every day of violation against the owner or operator of a stationary source until such time that the standards have been complied with. The fines increased by at least ten percent (10%), every three (3) years to compensate for inflation. In addition, PAB order closure, suspension of development, construction, or operations until proper environmental safeguards are put in place. An establishment liable for a third offense shall suffer permanent closure immediately.

Emission Quotas. - The Bureau may allow each regional industrial center that is designated as a special airshed to allocate emission quotas to pollution sources within its jurisdiction that qualify under an environmental impact assessment system programmatic compliance program pursuant to the implementing rules and regulations of Presidential Decree No. 1586.

The following major industries are required to install continuous emission monitoring system (CEMS) for particulates and sulfur oxide emissions:
a. Fossil-fuel fired power plant (including NOx)
b. Petroleum refinery, petrochemical industries (including NOx)
c. Primary copper smelter (including NOx)
d. Steel plant, ferro-alloy production facility (particulates only)
e. Cement Plant (particulates only)

(Please note that I am still in the process of researching the extent to which this law has been enforced and the issues that arose.)

Following comments have been sent by Mr. Mahinda Werahera, Ministry of Environment

Dear Dr. Sugathapala

I appreciate your effort to address this timely topic
Following are my comments on the aspects mention in your letter.

i) We will face many barriers as usual. They are mainly due to financial ( So we have to think the sustainability of the programme and it links to aspect ii).
ii I think there should be a penalty system for the individuals and companies who do not meet the standards. However, we have to be very careful in introducing it as this is some what new tool to Sri Lanka and also we have to continue with our development ( So our challege is to determine the correct amount of penalty/tax and method while minimizing the administration and collecting cost).
iii) Emission certificate by independent body is neccesary as it develop government and private cooperation. In general, it will be economically efficient.
iv) Rather than trying to solve the problem at once, doing it through step by step path will create more room for learning by doing. On the other hand, this method facilitate to correct the mistakes easily if we make any mistake.
v) As usual, we have to learn from others so regional and international cooperation is a must.

Senarath Mahinda Werahera

Dear All

Thank you all for the comments and feedbacks. We have spent more than two weeks for the discussion on second topic related to implementation aspects of "Emission Standards for Stationary Sources in Sri Lanka", and I would like to get your comments/feedbacks on another aspect(s) under the next (third) topic. Prior to do so, I’ll try to summarize the discussion we had so far on the second topic, particularly on implementation aspects of the proposed standards.

In terms of challenges, it was highlighted that there exists a large number of industries and the present resources of the authorities in terms of finance, equipment, and trained staff would be a major hurdle for successful implementation of the program. Yet the development of emission standards for stationary sources is a necessity. An appropriate implementation strategy should be developed to address these issues. Step-wise implementation, starting from large industries / high polluting processes, is recommended. The need to involve private sector for emission certification, through sound quality control/auditing by the authorities, was also highlighted. In any case, training and capacity building of staff of the relevant stakeholders/authorities, as well as enhancement of resources for measurement and monitoring are required.

Lack of baseline emission data in the local context is also a key barrier as the relevancy of the set standards to the local industry depends on the present status of the sector too. Too stringent standards would hamper the practical implementation process. The levels of knowledge, capacity, expertise, finance and technology status in the present industry, particularly small industrial sectors, for responding to the emission standards could also be critical factors to be considered. They need adequate support and guidance to be in compliance with the set standards, and sufficient time period should be given in this regard. For each equipment / process, information on best available technologies, guidelines on design operation and maintenance for emission reduction should be developed and provided to the industry.

Some kind of rewarding mechanism for less polluting industries (e.g. green labeling) / penalties for high polluting industries could be devised to make the implementation more viable. The implementation process could be started with voluntary basis for a pre-determined time period and also the industries could be requested to report the emission levels on regular basis (self monitoring with reporting to the authorities and public disclosure of the report), prior to the enforcement. For gross polluting industries, continuous emission monitoring (CEM) together with quality assurance and quality control procedure for data quality should be specified.

Sharing of best practices from other countries would definitely help us not only to develop sound set of emission standards for stationary sources but also to devise effective implementation procedure. The information disclosed during the discussion on present air pollution control programs in Hong Kong and Philippines, together with that of some other countries would be very useful in implementing our standards.

With these brief remarks, we will move on to the next topic for discussion during the coming week or so. Yet, you could continue to provide your comments on the earlier topics too.

Thusitha Sugathapala

Dear All

With reference to the "Implementation of Emission Standards for Stationary Sources in Sri Lanka", Under the first topic we discussed the three-tier approach used in the proposed standards and also the type of industries / pollutants covered. In the second topic, the discussion is mainly on issues and strategies of implementation. The third topic proposed at the commencement of this discussion was as follows:

Third Topic: Appropriateness of concentration based standards (or per unit volume/mass) over load based standards (or per unit energy) and related issues on measuring techniques/equipment.

I would like to explain the above discussion topic for this week in more details.
An emission factor is a representative value that attempts to relate the quantity of a pollutant released to the atmosphere with an activity associated with the release of that pollutant. For stationary sources these factors are usually expressed as the weight of pollutant per unit volume (at normal or standard conditions of temperature and pressure: mg/Nm3) or sometime per unit weight (e.g. g/kg). Another approach is to express the emission factors in terms of weight per unit energy input, particularly for power plants (e.g. mg/MJ). In the proposed standards, the emission factors are mainly expressed in terms of weight of pollutant per unit volume. In this respect, please provide your comments on the following specific question:

(i) What is more appropriate for our standards: per unit volume basis or per unit energy input basis?

A document containing an extract from the proposed emission standards covering few equipment/sources is attached for you reference. Note that for smaller plants, the emission standards include minimum limit for stack height than concentration of pollutants. The second question is related to this approach:

(ii) Do you agree with using chimney height as the standard for emission regulation for small plants? (pls refer the attached document)

Performance tests for parameters/pollutants relevant to emission measurements shall be in accordance with standard test methods and procedures. In the proposed standards, a list of such methods specified by USEPA is included. The list is attached for you reference. Alternative methods could also be used, but prior approval should be obtained by CEA. Further, in case of continuous monitoring should also follow standard procedures, and performance specifications for a set of continuous emission monitoring systems (CEMS) are specified with the emission standards. Again, the methods are based on USEPA performance specifications, and alternative methods could be used with prior approval. The list of performance specifications for CEMS is also included in the above document attached. Note that the both emission estimating techniques and performance specifications for CEMS include very detailed procedures for accuracy of the data / measurements, and some may argue on the applicability on local context. Therefore the third question I would like to raise is:

(iii) Do you agree with using such internationally accepted emission measuring procedure as USEPA for Sri Lanka?

Note that adoption of such method and procedures may require some modifications to the present plants and equipment, especially in order to provide access to instrumentation and also to be in compliance with specifications given. Further, following aspects too could be addressed in your feedback.

(iv) Challenges in measuring emissions from stationary sources.
(v) Regional/International experiences / best practices.

As earlier, I am expecting your valuable comments and suggestions on the above aspects (and other related areas) of the implementation of emission standards for stationary sources in Sri Lanka.

Thusitha Sugathapala

Following comments were sent by Dr. Suren Wijeyekoon, Univerisity of Moratuwa.

Dear All,

Third Topic: Appropriateness of concentration based standards (or per unit volume/mass) over load based standards (or per unit energy) and related issues on measuring techniques/equipment.

(i) What is more appropriate for our standards: per unit volume basis or per unit energy input basis?

The problem in the local context is that many organizations do not have a monitoring and recording system to go for a load based standard. Except for power plants, we may not find many other units recording the energy produced. Per unit energy input could be for continuously operated units such as a power plants. I consider this more as a performance indicator than a pollution indicator (though it is a good one!).

A concentration based unit should be used (as most instruments measure this) for other emission units. Hope the necessary measures are there to prevent dilution as a means to meet the standard by increasing the excess air!

(ii) Do you agree with using chimney height as the standard for emission regulation for small plants? (pls refer the attached document)

Stack height is a means of achieving dispersion (dilution) and depending on the weather, the plume can reach the ground very quickly. Stack height should not be used as a means of AQM as it is the same effect as releasing of untreated wastewater to sea. Further there are many “mobile” incinerators used in Hospitals where there is no stack! Stack height should be used to ensure the residual pollution (after meeting standards) dispersed.

(iii) Do you agree with using such internationally accepted emission measuring procedure as USEPA for Sri Lanka?

Emission measurement is very expensive business and we don’t have the capacity to measure for example dioxin etc. It is again like vehicle emission that needs certain expertise to measure and control. Let us start with a simple implementable strategy and gradually go into USEPA level at the same time improving capacity at the local level so that the levels are achievable and we avoid another bribing cycle!

(iv) Challenges in measuring emissions from stationary sources.

Last week I was involved in measurement of emission from Hazardous Waste incinerator. According to operation protocol given, the waste is burnt even before the temperature reaches 500 C! Most batch incinerators have this problem and during this low temperature combustion, there is gross environmental abuse from emissions that could even damage the probes of the measuring instruments! The incinerators are heavily over loaded and operate only during the night due to public complains. Like vehicle emission, you need to understand the science of combustion to address this.

Suren Wijeyekoon
University of Moratuwa

Following comments were sent by Mr. Nuvan Jayaratne, Central Environment Authority (CEA).

(i) Regarding the source emission standard according to my point of view dilution is not a solution of the pollution. Stack height was introduced in case of small power plants with equation to calculate stack height. What is the base of that equation and is it a practical solution for the emission control from power plants?

(ii) Regarding the VOC emissions efficiency of the control measure was the standards. In case of large amount of VOC emissions, the considerable amount of VOC can be emitted into the atmosphere with control measure of around 90% efficient. What are the reasons to introduce efficiency based standards for VOC instead of Concentration base standard .Suggest to introduce concentration base standards for VOC emissions.

(iii) Regarding the fugitive emissions ( Eg. Stone Cursers, Lime kilns etc) how can we implement the concentration base standards. How can we measure the emissions? Where can we measure the concentrations? Because meteorological factors are directly affected to the dispersion of pollution.

Novan Jayaratne
CEA

Following comments were sent by Mr. Chalaka Fernando, Holcim (Lanka) Ltd

Dear Sir,

Good morning, pls find my reply, hope you can send to the team,

Thanks, Kind regards

Chalaka Fernando

Dear All,

By looking at this interesting e-communications, thought to share some of the ideas which came across experiences, practices and idea sharing among some of the emission experts. By selecting right 'form' can assure accurate reporting to add value to the user also reduces the 'grey' areas: Eg : diluted gas concentration reporting. My point is selecting the correct 'form' is essential not only by thinking Sri Lankan case but thinking global scenario and current business reporting practices, because current business context emission reporting is not merely a compliance but a valued added exercise on efficiency improving and societal responsibility.

Just some refreshing ideas!

Emissions can be measured as in three ways (I'll say forms)
1. Concentrated method(s)
1-a Absolute (no reference, as it is)
May used in air dispersion modeling to consider actual facts/trends
Used for absolute emission verification parameter with flow of the stack & temp

1-b Referenced method (commonly used, )
Standard 1: ps = 1013 [mbar], ts = 20 [°C] (293.15 [K]) USA (EPA)
Standard 2: ps = 1013 [mbar], ts = 25 [°C] (298.15 [K]) Mexico, Canada, …
Standard 3: ps = 1013 [mbar], ts = 0 [°C] (293.15 [K]) EU (DRI guidelines)

Oxygen reference also changes from : 7-11% upon the standard, EU - 10%, In this case an apple to apple comparison is possible, dilution cannot influence on the reading as well (because the fixed O2 conc plays the role of a justifier)
Supports on comparing local values with global figures

2. Absolute reporting
Commonly used in sustainability reporting - from GRI & WRI guidelines a must
Units tons/annum
A verified figure commonly used for reporting

3. Specific reporting (Efficiency Indicator method)
Commonly use as a KPI (key performance indicator) for the process
Changing the denominator to an output parameter
Commonly used by suppliers of equipment
Also the commonly used sustainability reporting form (mandate element of WRI/GRI guidelines)
Units ex: g NOx/ton -product, g NOx/kWh
This may implemented 'class' wise, other wise the parameter will not provide accurate message

Kind regards

Chalaka Fernando

Following comments were sent by Ms. Ramya Wanniarachchi, Ceylon
Electricity Board (CEB)

Dr. sugathapala,

My comments for 3rd posting are attached herewith.

Ramya Wanniarachchi

(i) What is more appropriate for our standards: per unit volume basis or per unit energy input basis?

If you could express in both ways it would be much better. Otherwise per unit energy input is more appropriate

(ii) Do you agree with using chimney height as the standard for emission regulation for small plants? (pls refer the attached document)

No. even for small plants standards has to be specified.

(iii) Do you agree with using such internationally accepted emission measuring procedure as USEPA for Sri Lanka?

Sri Lanka also can implement an internationally accepted procedure as these procedures have been tested before implementation rather than developing new procedures.

(iv) Challenges in measuring emissions from stationary sources.

It will not possible to get the required measurements from existing plants without making modifications. Financial assistance will have to be arranged for these plants carryout required modifications.

(iv) Regional/International experiences / best practices.

Proper awareness program has to be arranged with the Regional/International experiences / best practices before implementation of these standards.

Dear All

I would like to make the following clarifications on the reference conditions in specifying emission standards highlighted by Mr. Chalaka Fernando.

In the proposed emission standards for stationary sources in Sri Lanka, following reference conditions are used:

(1) The common unit used for emission concentrations is mg/Nm3, in which the notation N means Normal, which implies that the volume is measured at the normal temperature and pressure conditions. The literature reveals that different values are used for normal temperature (such as 0°C, 20°C, 25°C), but the pressure is usually one atmosphere.

In the proposed standards for Sri Lanka, the normal pressure and temperature are specified as 0°C and one atmosphere (= 760 mmHg = 101.3 kPa).

(2) In practical measurement of emission concentrations in flue gases, in addition to the temperature and pressure, excess air and moisture content become important parameters to be considered. Therefore, it is a common practice to define the reference levels of these two parameters. Reference value for moisture content is taken as zero (i.e. dry flue gas). The level
of excess air is usually represented by % O2 level in the flue gas. For this parameter, specific value is not available as an international standard and different countries use different values in their emission standards, which also varies with the physical form of the fuels (i.e. solid, liquid or gas). In the proposed emission standards for Sri Lanka, the reference O2 levels are 3% for gaseous and oil fuels, and 6% for solid fuels. For incinerators, the reference O2 concentration is taken as 10%.

It is also noted that in some national emission standards for specific sources/pollutants, emission standards are specified with reference to % CO2 level, but this reference methodology is very rarely used.

kind regards

Thusitha Sugathapala

Dear All

This is with reference to the comment made by Ms. Ms. Ramya Wanniarachchi, Ceylon Electricity Board (CEB) on the unit of emission levels specified in the standards.

Ms Ramya recommends to use of both per volume basis and per unit energy basis (e.g. mg/Nm3 and mg/MJ), or else per unit energy basis (if only one unit is to be used). You too could comment on this.

This aspect was considered during the formulation of the standards and finally decided to use per unit volume basis, mainly because it is the most commonly employed unit in other countries. However, the standards also specifies the procedure to convert from per unit volume to per unit energy (through so called F factors in dry Nm3/MJ, for different fluids). You may find these values in the first document I posted (titled Emission Standards for Stationary Sources).

kind regards

Thusitha Sugathapala

Dear All

I would like to get your comments on two other important aspects (which I forgot to mention earlier) in the proposed emission standards:

(i) Emission standards for the case equipment using more than one fuel.

The proposed standards specify the following:
"In case of combustion plant or equipment utilizes more than one fuel, the emission standards shall be those correspond to the main fuel declared at the commissioning of that plant or equipment. Further, if there is a permanent shift in primary fuel subsequent to the commissioning of the plant or equipment, CEA should be duly informed on the change".

(ii) Capacity of the equipment to be considered for the emission standards

The proposed standards specify the following:
"The rated output capacity (denoted by C) referred in the emission standards shall be the total of the maximum rated capacities of the relevant equipment at a single site. In case of power plants MWe represents the total of the maximum rated electricity generation of the plant equipment/engines at a single site".

Pls give your comments on the above two aspects.

regards

Thusitha Sugathapala

Following comments have been sent by Dr. Selie Fernando

Dear Dr Sugathapala,

Now our question is first ,are we to take pre unite volume or per energy out put. As we dont have the basic data to our coutry we have to take the Thailand data for our stadards and Thailand is not a fully industrialized country and like Srilanken economy.Therefore please adheer to the Thailand standards and they have taken the per unite volume data base.

Cimney hieght shoud be a must. BecuaseIf you consider the body mass incinerators in mortuaries and the cemetries are produsing all the noxious gases including the dioxins but if we releases those into the high atmosphere the man's own inhalation air will be not polluted then. and those are the small industries the oven temperature should be maintain at 1000 oc then it is safe and dioxins will not be produced and there wont be any particulate matters.Therefore chimney hight and the temperature should be over 1000oc.

Dioxins assey can be done by using the mass negatine arrey spectophotometry and for the moment it is not available in Sri Lanka.And the USEPA methods are then feasible for Sri Lanka to maintain the quality of the measures.

Dr Selei Fernando

Compared to vehicle emissions, stationary sources are much less and the numbers are quite manageable. Therefore, it will be prudent to go deep into things such as selection of monitoring equipment, and get those standardised. The Government can include cost of such equipment in the licence fee it self, and monitor the emissions themselves, rather than depending on emitter data and third party auditors, as done in the vehicle emission testing.

It is also worthwile to implement the schem in stages, starting with power plants of capacities greater than 10MW, as the numbers are smaller. It will be quite easy to improve the system when we can pay undivided attention to few sources. Most implementation issues can be resolved when the chaos with larger number of smaller sources is absent.

Also, I noted that emissions are monitored per volume and per unit of energy and wonder why not measure it per unit of fuel consumed. Can someone knowledgeable explain why this approach is not considered ?

Following comments have been sent by Dr. Selie Fernando

Dear Dr Sugathapala,
,
I highly appreciate your standards measuring norms and I fully aggree with you and what about basal basic measurs for Sri Lanka , and are we to do the levels in each districs to take the idea about emision nature of the air in Sri Lanka.?And what about your tire model is confirmed to do the standards?Can you design the final legistative text which to be discussed in an open forum or in a round table conferance?

Dr Selei Fernando

Dear Dr. (Ms) Selei Fernando

Once the online-discussion is concluded, CEA will arrange a public seminar to discussion the Emission Standards, prior to to finalizing the legislation texts. We are also planning to arrange a round-table discussion (similar to the one we had on VET Programme). Further, there will be a webinar seminar at AirMAC/CleanAirSL on selected topics for which the resource personnel are international experts on the subject. We really appreciate for your continuous input on the discussion. There will be a public lecture arrange by IESL, information of which will be sent in due course.

regards

Thusitha Sugathapala

Dear All

This is with reference to the comments posted by Mr. Harsha Wickramasinghe, Sustainable Energy Authority.

(1) It is not correct to say that the Emission Standards for Stationary Sources are simpler in implementation than Vehicle Emission Testing. Though the number of vehicles in the active fleet is over 2.5 million, the categories of vehicles and the emission processes/pollutants are very limited. However, there is a large number of industrial establishments in Sri Lanka (More than 50,000) with much wider verities of equipment types, capacity ranges, fuel types, pollutant types and emission processes. So the complexity and resources requirements for implementation of Emission Standards for Stationary Sources outweigh the VET programme.

(2) I agree with the strategy of implementing the standards in stages. Yet a proper planning in selection and enforcement is required.

(3) Emission standards are usually presented in terms of concentrations (e.g. weight per unit volume) as the main goal of the activity is to reduce ambient air concentrations, which are essentially represented by concentrations (per unit volume / ppm). Relationship between the pollutants concentrations at the emission points / stacks and the ambient concentrations could be modelled. Further, there could be different emission processes (evaporative emissions, stack emissions) and different emission points/locations corresponding to a given fuel and then emissions per unit fuel input do not have much meaning.

regards

Thusitha Sugathapala

Thanks Thusitha for your effort to take comments on the new emission standards for Sri Lanka. The 150 page study by the Sri Lanka Energy Managers Association is very impressive, and extremely thorough.

While I haven't been able to sufficiently get up to speed on the Sri Lanka emission standards report, I did have one overriding question re. the study. It was not clear to me in my cursory review that the new standards were part of an overall air quality management strategy to meet the ambient air quality standards in the country. As you know, in the U.S. we have a clean air act that lays out the "big picture" on how to attain clean air. This involves both setting ambient air quality standards for each major pollutant, and then developing a "State Implementation Plan" (SIP) that lays out a strategy with legal rules, regulations, etc. to reach the clean air standard by a specified date in the Act.

A project I did a few years ago for the World Bank was to draft a suggested Clean Air Act for Bangladesh to help them incorporate their proposed reorganization of the air quality program into a long-term strategy for clean air.

Just a thought!

Regards,

Dave Calkins
Sierra Nevada Air Quality Group, LLC
Orinda, California, USA

Dear Dave

Thank you for the encouraging remarks on the proposed emission standards for stationary sources in Sri Lanka.

You have raised a very valid question on the overall air quality management (AQM) strategy in Sri Lanka. In fact, I have been planning to post the same item with the next discussion points.

Although there are a multitude of laws (more than hundred) with some provisions relating to environmental protection and management in Sri Lanka, the National Environmental Act (NEA) No. 47 of 1980 (amended by Act No. 56 of 1988 and Act No. 53 of 2000) was the first comprehensive legislation that deals exclusively with the subject. The coverage on air quality in the NEA is minimal and Sri Lanka does not have a Clean Air Act yet. However a strategy and action plan named the “Clean Air 2000 Action Plan” (CA2AP) was approved by the cabinet in 1993. CA2AP calls upon existing institutions dealing with urban air pollution control, to play different roles ranging from policy making to air quality monitoring, together with enforcing laws, ensuring regulatory compliance and undertaking research and development on technology for air pollution control. It allows the establishment of functional linkages between many institutions dealing with environmental management. CA2AP has been updated a number of times and present version is “Clean Air 2015 – Action Plan for AQM”. This document covers key elements in an overall AQM programme and contains a set of objectives, ambient air quality targets (for PM10, SO2 and NO2), strategies, actions, time frame, indicators and outcomes. However, many of the actions proposed have not been able to commence or complete as planned. The implementation of the proposed emission standards for stationary sources is one of the key activities identified in the Clean Air 2015 Action Plan. Another such activity already started is the Vehicle Emission Testing (VET) programme.

It is important to highlight at this juncture that the project on implementation of the emission standards for stationary sources was initiated by Central Environmental Authority (CEA) as their obligation to enforce such standards in relation to issuing of Environment Protection License (EPL) and Environment Impact Assessment (EIA).

Sri Lanka does have Ambient Air Quality Standards for PM10, PM2.5, SO2, NO2, O3 and CO (a copy of the standards is attached). Among these pollutants, Clean Air 2015 Action Plan has targets of PM10, SO2 and NO2. However, no specific relations for the impacts of the different actions on ambient air quality levels have been established. In fact, Sri Lanka does not have air quality modelling tools that are comprehensive enough to predict such relations. Few other critical gaps do exist in relation to overall AQM programme, including lack of effective institutional mechanism, lack of emission data/inventory and absence of a network of ambient air quality measuring stations. In particular, with reference to the institutional arrangements, CA2AP proposed a dedicated agency under Ministry of Environment to oversee the activities on AQM and subsequently the Air Resource Management Center (AirMAC) was established in 1994. However, AirMAC has not been able to get the formal status yet, which critically affected the implementation of the AQM actions identified under Clean Air 2015 Action Plan. Under this background, Clean Air Sri Lanka was established in 2004 to assist AirMAC (both operate at the same venue).

With the above background, it has become a necessity to formulate a Clean Air Act for Sri Lanka, as you pointed out correctly. This matter was taken up in the Ministry of Environment very recently and decided to initiate the formulation of the Act. A couple of days back, a funding source has been identified for the activity and hopefully we will be able to commence it in the immediate future.

kind regards

Thusitha Sugathapala
University of Moratuwa / Clean Air Sri Lanka

Dear All

As you are aware, we have discussed the "Implementation of Emission Standards for Stationary Sources in Sri Lanka" under three topics so far. Under the first topic we discussed the three-tier approach used in the proposed standards and also the type of industries / pollutants covered. In the second topic, the discussion is mainly on issues and strategies of implementation. The third topic is one appropriateness of concentration based standards (or per unit volume/mass) over load based standards (or per unit energy) and related issues on measuring techniques/equipment.

Now we are moving into the last topic of the discussion, for which the posting of Mr. Dave Calkins, Sierra Nevada Air Quality Group, California, USA has formed the platform. The main items, for which I would like to get your valuable comments, are highlighted below:

(1) Sri Lanka has Ambient Air Quality Standards covering the pollutants PM10, PM2.5, SO2, NO2, O3 and CO. Given your comments on the coverage of the pollutants included in the standards and the levels (maximum permissible values) specified (I have already attached the standards with the previous posting). You could also highlight the ambient air quality standards in other countries, especially in the region.

(2) The proposed emission standards cover several equipment (under Tier 1), industrial processes (under Tier 2), and about twenty pollutants (under Tier 3) including PM, dust, smoke, SOx, NOx, Fluorides, Dioxin/Furan, Ammonia, HCl, HF, Chlorine, Lead, Mercury, Zinc and other heavy metals, etc. Give your comments on the significance of the proposed emission standards for achieving the ambient air quality standards. Also provide your opinion on the compatibility of the two set of standards (and also the need for the compatibility). Also comments on the methodology/strategy to be adopted to harmonious the two set of standards.

(3) General comments or proposal on further activities needed for overall air quality management in Sri Lanka.

In addition to the above, following pls provide your inputs on the following technical aspects

(4) Best available emission control technologies / appropriate technologies for different pollutants / processes and associated issues (including costs).

regards

Thusitha

Dear All

On the request from Chemical Engineering Sectional Committee of Institute of Engineers Sri Lanka (IESL), I will be delivering a Public Lecture on "Proposed Emission Standards for Stationary Sources" on Tuesday the 17th August 2010 at 17.15 hrs at Wimalasurendra Auditorium, IESL, 120/15, Wijerama Mawatha, Colombo – 7.

All are welcome!

Your participation will make the event more fruitful as you are already aware of the key aspects of the standards.

Kind regards

Thusitha Sugathapala

Dear Dr. Sugathapala,

Thank you for emphasiing animportant aspect of teh link between the Ambient Air Quality and Stationaery sources. In fact I aso strongly believe that there should be an alignment of these two aspects for to have a meaningful implematation of both of these on a longterm perspective. It can not and should not be stand alone type. In this regard a well thought measurement and anaysis campaign should be envisaged. Further this pushes all of us to think seriously the modelling aspect.

As for the evolution of the study, strongly feel that the IAQ component should come into place. As of now, it focuses mainly on direct impact of cooking related indoor air pollution only. But there is a huge zone opeing up related to IAQ in commercial, office, school indoor environments especially with reference to Green Building Design & Certification. There is a quite a lot of constrains that are being emphasised especially w.r.t. type and quality of materials to be used for healthy and sustainable indoor environments. I thus focus your attention to consider this aspect during the evolution of this study

Good Luck

Rahula Attalage

Following comments have been sent by Dr. Selie Fernando

Dear Dr Sugathapala,

First we have to find out equipments for every test and the accepted methodologies for that and funds for the program and basal measurement of the air quality of Sri Lanka and designing a study to do so.
Shall I design the study for that and can you find a funding source for that ?

Thank you

Dr Selei Fernando.

Following comments have been sent by Mr. R P Samarakkody
Director, Waste Management Authority, Western Province.

Dear Mr. David and all,

I think that with your suggestion, we can do something to change the system. We have to have a "Clean Air Act", first. Then we can have National Level Action Plan and also in line with "Provincial Level Implementation Plans" as State Implementation Plans in US. We have 09 Provinces and this can be initiated with Western Province. All Local Authorities could be involved since Local Governance is a Provincial Activity. In Western Province we have 48 Local Authorities and at present, a comprehensive ambient air quality monitoring program was initiated with National Building Research Organization (NBRO) to monitor monthly exposure levels of ambient SO2 and NO2 levels to represent all four monsoons starting from 2008 at 114 locations representing all 48 Local Authorities. This study is a continuation of a program initiated by NBRO to monitor same parameters at 15 locations in Colombo and suburbs from 2002.

Similarly an Air Emission Inventory could be initiated at Local Authority level and in future considering point and mobile air emission sources and thereafter, a Provincial Implementation Plan could be initiated to bring down the air pollution levels of high pollution areas and maintain low pollution areas as it is with the assistance of respective Local Authorities.

This can be implemented in Sri Lanka nicely not like in Bangladesh, since provincial system has been introduced with the 13th amendment to the Sri Lankan Constitution in 1987.

What we have to understand at this stage is the individual organization's commitment to Better Air Quality.

Regards,

R P Samarakkody
Director,
Waste Management Authority, Western Province.

Dear Thusitha

Lot of thanks are due for your initiative in this page to create a dialogue on industrial emission standards. I think Central Environmental Authority received lot of foods for thought in implementing the emission standards including the interested parties/ individuals. I hope this will pave the way for developing a practical strategy for implementing the industrial emission standards.

Thanks and regards

Sugath Yalegama

Following comments have been sent by Dr. Selie Fernando

Dear Dr Sugathapala and the team,

I am greatful to read the suggestions made by you all to maesure the air in all local authotities in Sri Lanka and That is the must and first priority to give in this program and frist we implement the program and find the funding agency then we can proceed .I think we call for a round table conferance on this and I invite you to write the legislative text which to be discussed together and before that we call for a open symposium on this with international relevent delegates.

Dr Selei Fernando

Following cmments are sent by Mr. Hemantha Withanage, Executive Director, Centre for Environmental Justice, Sri Lanka.

Dear Samarakkody and all,

It is great if we can have a Clean air Act. But having the past experience it will take years.

regards,

Hemantha

Following cmments are sent by Prof. Priyantha Wijayatunga, ADB.

Dear Thusitha,
I am really sorry for not coming back on your request. Let me try to provide my comments on the following.

(i) What is more appropriate for our standards: per unit volume basis or per unit energy input basis?

I don't see a major issue of having one or the other. But I presume emission per unit weight (g/kg) is less complicated and easy to use.

(ii) Do you agree with using chimney height as the standard for emission regulation for small plants? (pls refer the attached document)

If the issue is localised impact of the emissions this seems to be ok since the emissions tend to get dispersed in a larger area (and hence less dense) when the stacks go higher. Probably this may need to be coupled with the fuel type used to ensure more polluting fuels have a higher stack sizes.

(iii) Do you agree with using such internationally accepted emission measuring procedure as USEPA for Sri Lanka?

Use of internationally accepted procedures for emission measurements will be associated with significant costs. Probably we can propose simplified procedures at the beginning and gradually elevate them into internationally accepted levels. We had a similar approach to CFL testing at the beginning but now we have better techniques with more sophisticated testing facilities.

(iv) Challenges in measuring emissions from stationary sources.

I feel the major challenge is no so much in measuring them (as long as the technology and the funding is is available) but monitoring these measurements and ensuring the accuracy of the information transmitted to the regulating body ( I presume the CEA). Also developing the capacity of the regulating body to continuously analyze this information and take action on the violators is a challenging task.

Priyantha Wijayatunga

Dear All

We have come to an end of very useful discussion on the Implementation of Emission Standards for Stationary Sources in Sri Lanka. I'm glad that Bill Farrell provided a set of very valuable comments as the closing comments of the discussion.

I would like to take this opportunity to thank you all for the contributions given during the discussion. Special thank should go to CAI-Asia for providing the opportunity and resources to conduct the discussion.

You may be aware that, as a continuation of the same activity, there is a webinar seminar scheduled to be conducted on 3rd September 2010 at the AirMAC. More details are given in the attached document.

kind regards

Thusitha

Dear All

This is to highlight some of the developments taken place in the last few weeks in relation to our discussion on Implementation of Emission Standards for Stationary Sources in Sri Lanka.

(1) We have successfully concluded the Webinar Seminar conducted on 3rd September 2010 at the Air Resource Management Center / CleanAir Sri Lanka under the KnowledgeAir Case Study of CAI-Asia. The resource persons of the events were Mr. David Calkins, Vice Chair International Affairs Committee, A&WMA and Dr. Miriam Lev-On, Chair International Affairs Committee, A&WMA. They made the presentations from USA, which were delivered to the audience in Sri Lanka on-line. The event was coordinated by Mr. Mike Co from CAI-Asia Center from Manila. The presentations were followed by question and answer session. The entire event ran perfectly, giving new experience for all of us. I would take this opportunity to appreciate all the contributors for their efforts.

(2) According to my understanding, CEA is planning to finalize the regulations for Emission Standards for Stationary Sources within six-month period. It is time now to form a working group representing key stakeholder institutions and experts for this purpose. I hope CEA would initiate this activity soon, as there are many aspects to be discussed and analysed prior to finalizing the standards. In particular, it is important to device a suitable procedure to adopt the three-tier approach proposed in the present draft standards in actual implementation by considering different categories of stationary sources and industrial processes.

(3) I had an opportunity to discuss the proposed emission standards for stationary sources with Dr. Mahesh Jayaweera, Department of Civil Engineering, University of Moratuwa, a leading person working in the environmental sector in Sri Lanka. He stressed on having information on actual emission values in local industries/processes prior to implementation of the standards. I’ll post brief coments sent by him on this subject for your information with the next posting.

Dr. Mahesh also pointed out a specific case of generation of electricity from MSW. The technologies included in the proposed standards do not cover this source and applicable standards would be that of Tier three: Pollutant Based Emission Standards, which employs more general values (except in the case where incineration is used for which a comprehensive set of standards is available). As several such plants have been proposed, inclusion of additional standards for MSW based power generation technologies may be useful for CEA in issuing EIA or EPL. I would like to get your opinion on this issue.

(4) Another activity to be conducted in the near future is one of the pre-event of BAQ2010, “Experiences in Developing and Implementing Stationary Source Emission Standards”, which is scheduled to be conducted on 8th Nov from 12:00 - 4:00 pm. This seminar is organized by Air and Waste Management Association (A&WMA) and CAI-Asia and the resource persons would be again Mr. David Calkins and Dr. Miriam Lev-On. This is again a very important activity as there would be participation from other countries in the region. It is important to highlight at this juncture on the fact that there exists wide differences in standards for stationary sources among different countries in the region, in terms of source categories covered, pollutants included and limits specified (in case of mobile sources, more uniformity could be seen). This emphasises the need of a regional level programme for sharing experiences and best practices related to emission control of stationary sources and harmonizing the relevant standards.

(5) Air Resource Management and International Relations Division of the Ministry of Environment and Natural Resources is about to commence a very significant activity related to the subject – development of a Clean Air Act in Sri Lanka. I hope that we would be able to conduct similar activities, such as interactive discussions in the Clean Air Portal and Webinar seminars, during the development of Clean Air Act too so that better stakeholder participations are employed.

Regards

Thusitha Sugathapala

Following comments are sent by Dr. Mahesh Jayaweera, Department of Civil Engineering, University of Moratuwa

Dear Thusitha,

Thank you sending this exhaustive report on the subject of formulation of
emission standards. However I think it is high time for you and the
committee to concentrate on the actual emission levels taking into
consideration the practical situations prevailing in the country. I believe
your 3 tire system but can not comment on anything until you come up with actual emission levels.

Please be therefore kind enough to come out with tangible, practical and
implementable set of standards so that I will comment on them for your
perusal.

Hope to recieve them soon.

Regards,

Mahesh