Chirag Bhimani

Independent Consultant , India


Chirag Bhimani worked with Gujarat Pollution Control Board (GPCB) from 1996 as an Assistant Environmental Engineer and was promoted to Deputy Environmental Engineer in 2002 and was lastly working at GPCB Head Office in Gandhinagar. He was the Divisional Head of Bhavnagar, Junagadh Palanpur and Porbandar Areas. He was the Nodal Officer for Preparation of Best Available Techniques Reference (BREF) Document at GPCB and was Convener for Continuous Online Monitoring System (CMS) & Pilot Emissions Trading Scheme too.

His key responsibilities at GPCB were to advise and implement strategies for the management of environmental issues impacting land, air, water and people including air pollution, water pollution, noise pollution and wastes. His work included to review, to make recommendations and to decide on the applications for statutory approvals such as Consent To Establish, Consent To Operate, Hazardous Waste Authorisation etc. and, where appropriate, to recommend conditions to be applied to the statutory approvals. He also reviewed, made recommendations and decided on the reports regarding environmental compliances and, where appropriate, recommended and initiated legal actions and/or punitive actions against the defaulters. He was responsible to evaluate, suggest solution and strategies for specific environmental problems.

The BREF Document is being prepared in collaboration with German Federal Environment Agency (UBA) and Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH which is first of its kind of effort in India for which Chirag was the Nodal Officer. He had independently created and was managing the BREF Information System (BIS) which has been applauded by the German counterparts.

His work as Convener for CMS was to strategise, develop and implement Continuous Online Monitoring Systems in Gujarat including the necessary infrastructure for Water Emissions, Air Emissions & Ambient Air Quality and the usage of this data for the pilot project on ETS. The major contributions have been for the preparation and development of CEMS Guidelines and Design of Format of Baseline Survey and its implementation. His major interest in the project was Market Design of ETS.

Chirag has changed his work profile since 2019 and now works as an Environmental Expert and Advisor in areas such as Enviro-Legal matters, Star Rating Program, BREF, CMS, ETS and other similar innovative approaches for pollution control and environment conservation. His interest also includes the National Clean Air Program (NCAP) and other such matters related to Air Quality and Emissions. He has close associations with Organisation for Economic Co-operation and Development (OECD), Paris and University of Chicago (UChicago).

Short description about presentation:

Industrial installations now require passive monitoring of fugitive emissions around the perimeter of their facilities. The current example is that of refineries which are living with new U.S. Environmental Protection Agency (EPA) Maximum Achievable Control Technology (MACT) requirements which necessitates monitoring of fugitive benzene emissions around the premises.

Passive monitors absorb many different air pollutants and can be deployed to detect “ambient air” concentrations (defined as the other side of the fence) at relatively low cost. Their use is rapidly expanding beyond refineries and beyond simple compliance monitoring because the communities around the installations demand more information regarding emissions from such facilities in their environment while on the other hand industry values low-cost but reliable and effective methods to identify problems early and demonstrate compliance and environmental stewardship.

As passive monitoring proves its utility in the refinery sector and becomes mainstream, more opportunities to utilize it for “next-generation compliance” could be forthcoming for other types of facilities too. Parallelly next generation air measurement technologies are making it easier to track air pollution leaks from pipes, seals, and other areas at industrial facilities. These new high-tech tools can be used to help determine where leaks are occurring and what chemicals are being released.

Challenges in Implementation of Fenceline Monitoring Program:
Although the goal of fenceline monitoring is to ensure facility emissions are fully characterized and to trigger action if elevated levels of emissions are observed at the fenceline but establishing a fenceline monitoring program presents the risks and challenges to the regulated community such as :
1. Related areas
2. Designing the monitoring network
3. Meteorological data
4. Corrective actions
5. Public reporting
6. Site-specific monitoring plans

Future of Fenceline Monitoring Concept:
When applied properly, passive fenceline monitoring has proven to be a low-cost, readily available, and reliable tool for assessing emissions at industrial installations so the reach of these types of tools is likely to expand beyond benzene monitoring at oil refineries. Therefore, many other large industrial facilities have cause to be interested in the process and lessons learned from implementing the refinery regulations.