NOTE ON METHODOLOGY OF CPCB FOR CLASSIFICATION
OF SECTORS INTO RED, ORANGE, GREEN, WHITE
CATEGORIES
1.0 BACKGROUND
Considering the Government of India’s National Green Hydrogen Mission, a need is felt to
classify the sectors- standalone production of hydrogen and integrated production of
ammonia using hydrogen, by various technologies such as electrolysis, pyrolysis, etc. In
order to understand the available production technologies and their environmental concerns,
it is desirable to have a stakeholder consultation for assessment of Pollution Index. A brief
about the classification methodology is discussed in subsequent paragraphs.
2.0 INTRODUCTION TO CLASSIFICATION OF SECTORS
Categorisation of sectors into Red, Orange and Green Category was initiated during 1989 by
MoEF for Doon Vally Uttrakhand. Subsequently, CPCB classified sectors, on the basis of
pollution index (PI) which is a function of water pollution, air pollution, and hazardous waste
generation during 2016. The concept of classification of industries into red, orange, green and
white categories, is based on the “Precautionary Principle”, which focus on potential of
industries to pollute the environment. After the mitigation measures, the pollution level
reduces, however classification is done based on the actual pollution generation from the
process.
3.0 METHODOLOGY FOR CLASSIFICATION
CPCB has prepared revised methodology for classification of sectors during 2023. The
revised methodology was placed in public domain and based on the receipt of more than 700
comments, CPCB is in process of finalization of revised methodology for assessment of PI
and accordingly the classification of sectors. As per the revised methodology, the potential of
three pollutant groups, namely, water pollutant, air pollutant and waste pollutant (which are
hazardous/toxic/infectious/bulk in nature), which have been given scores out of 100, each.
Slabs are assigned for selection of pollutant groups respectively for water, air, and waste
depending on quality and quantity of generation. Score can be decided based on dominant
pollutants in the pollutant groups and quantity as detailed in Table-I, Table-II and Table-III.
These scores are used for computation of pollution index for deciding the category of sector.
The scoring methodology is based on the pollution potential during generation and not at the
end of pipe/ after treatment considering the fact that all pollutants need to be treated and
disposed as per the provisions/rules notified under the Water (Prevention and Control of
Pollution) Act, 1974, the Air (Prevention and Control of Pollution) Act, 1981 and the
Environment (Protection) Act, 1986 and as amended.
The details of scoring criteria for PIW for “water pollutant,” PIA for “air pollutant” and PIH for
“waste generating sector” are as follows:
i. Scoring criteria for Water Pollutant “PIW”
Water pollution score consider the potential water pollution load from any sector in terms of
characteristics and quantity of untreated trade effluent (wastewater). The “trade effluent”
includes any liquid, gaseous or solid substance which is discharged from any premises used
for carrying on any [industry, operation or process, or treatment and disposal system], other
than domestic sewage.
The water pollutant score (PIW) is the addition of three sub-scores which are based on organic
content in terms of oxygen demand of wastewater (W1), potential of other pollutants (W2)
and quantum of wastewater (W3). The weightages of W1, W2 and W3 in the water pollution
score are 35%, 30% and 35%, respectively.
Proportionate higher scores are assigned to the sectors generating trade effluent of high BOD
and/or high COD, heavy metals/toxic compounds, and large volume of wastewater. The
scores are assigned considering the potential for causing damage to the environment. It may
be noted that for sectors generating industrial effluent, dominant quantity of trade effluent is
considered in score W3 (W3-1 to W3-5). Whereas, for sectors generating huge volume of
sewage effluent such as railway stations, STPs, residential building projects, airports etc., the
separate scores W3 (W3-6 to W3-10) are assigned. The term used, “Sewage effluent” means
effluent from any sewerage system or sewage disposal works and includes sullage from open
drains. The scoring criteria for water polluting sectors are given in Table-I.
Table I: Scoring Criteria for Water Polluting Sector
Water
Pollutant Description Score
Group
Score W1: Score based on the oxygen demand of wastewater
(Maximum of the following scores to be considered)
W1-1 BOD ≥ 5,000 mg/l or COD ≥ 10,000 mg/l 35
W1-2 1000 ≤ BOD < 5,000 mg/l or 5000 ≤ COD < 10,000 mg/l 30
W1-3 500 ≤ BOD < 1,000 mg/l or 1000 ≤ COD < 5,000 mg/l 25
W1-4 100 ≤ BOD < 500 mg/l or 250 ≤ COD < 1,000 mg/l 20
W1-5 10 ≤ BOD < 100 mg/l or 50 ≤ COD < 250 mg/l 10
Score W2: Score based on other pollutants in the wastewater
(Maximum of the following scores to be considered)
W2-1 Pollutants like pesticides, heavy metals, and toxic compounds: 30
(Aluminium, Anionic detergents, Barium, Chloramines, Copper, Fluoride,
Total residual chlorine, Iron, Manganese, Mineral oil, Phenolic
compounds, Selenium, Silver, Sulphide, Cadmium, Cyanide, Lead, Zinc,
Mercury, Tin, Vanadium, Antimony, Benzene, Benzo-a-pyrene,
Molybdenum, Nickel, Phosphates, Polychlorinated biphenyls, Polynuclear
aromatic hydrocarbons, Arsenic, Total/Hexavalent Chromium,
Trichloroethane, Trichloroethylene, Adsorbable Organic Halogens (AOx),
Pesticides compounds, Residual antibiotic, Radioactive materials, etc.)
W2-2 Pollutants like Nitrate Nitrogen, Nitrate, Ammonical Nitrogen, Total 25
Kjeldahl Nitrogen (TKN), Oil & grease, pH<5.5 or > 9
W2-3 Pollutants mainly in terms of inorganic dissolved solids and associated 20
other impurities due to process e.g. wastewater generated from DM water
rejects, boiler blowdowns, brine solution rejects, fresh-water RO rejects,
etc.
W2-4 Pollutants mainly in terms of inorganic dissolved solids e.g. wastewater 15
from cooling towers, cooling-re-circulation processes, etc.
Score W3: Score based on quantity of wastewater generated
A. For sectors generating Industrial Trade effluent (Maximum score to be considered)
W3-1 Wastewater ≥ 500 KLD 35
W3-2 100 KLD ≤ Wastewater < 500 KLD 30
W3-3 50 KLD ≤ Wastewater < 100 KLD 25
W3-4 10 KLD ≤ Wastewater < 50 KLD 20
W3-5 Wastewater < 10 KLD 15
B. For sectors such as STPs, building projects, etc. generating/handling only high-volume
Sewage (Maximum score to be considered)
W3-6 Sewage ≥ 5,000 KLD 35
W3-7 2,000 KLD ≤ Sewage < 5,000 KLD 30
W3-8 500 KLD ≤ Sewage < 2,000 KLD 25
W3-9 100 KLD ≤ Sewage < 500 KLD 20
W3-10 Sewage < 100 KLD 15
Water Pollutant Score (PIW) = W1+W2+W3
ii. Scoring criteria for air pollutant “PIA”:
Air pollution score consider the potential air pollution load from any sector in terms of
characteristics of emissions and its quantum/scale in terms of quantity of fuel. The air
pollutant score is based on generation of emission. The “air pollutant” means any solid,
liquid, or gaseous substance (including noise) present in the atmosphere in such concentration
as may be or tend to be injurious to human beings or other living creatures or plants or
property or environment.
The air pollution score (PIA) is the addition of three sub-scores which are based on the type of
pollutants in emissions (A1), work zone emission/fugitive emissions & odour nuisance (A2),
and fuel type & quantity (A3). The weightages of A1, A2 and A3 in air pollution score are
35%, 30% and 35%, respectively.
Proportionate higher scores are assigned to the sectors generating emissions with hazardous
air pollutants, process-based fugitive emissions and using solid/liquid fuels, as such
pollutants have higher potential to damage the environment.
The California Air Resources Board defines fugitive emissions as “Emissions not caught by a
capture system which are often due to equipment leaks, evaporative processes and
windblown disturbances.” The fugitive emissions from any process having acid mist, VOCs,
etc. are given higher weightage (score A2=30) as compared to the fugitive emissions of inert
material (score A2=25). Sectors having persistent foul odour issue, will get score A2=20.
Sectors/units using solid/liquid fuel will get higher score-A3, compared to the sectors using
cleaner gaseous fuel or electricity. The scoring criteria for air polluting sectors are given at
Table-II.
Table II : Scoring criteria for air polluting sectors
Air
Pollutant Description Score
Group
Score A1: Score based on Process emissions (point source)
(Maximum of the following scores to be considered)
A1-1 Hazardous Air Pollutants (HAPs) and heavy metals: 35
HAPs (Phosgene, Benzene, Benzo(α)pyrene, Butadiene, Toluene Di-
isocyanate, Methylene-di-phenyl Di-isocyanate, Ethylene Oxide, Ethylene
Di Chloride, Acrylonitrile, Propylene Oxide), Dioxins & Furans,
Asbestos, Polycyclic Aromatic Hydrocarbons (PAHs), HCN, Cd, Th, Hg,
Sb, As, Pb, Co, Cr, Cu, Mn, Ni, V, etc.
A1-2 Halogens, acids, and pesticides-based pollutants: 30
H2S, HF, HBr, P2O5 as H3PO4, NH3, TOC, Cl, HCl, SO3, CH3Cl, Total
Fluoride, PM having pesticide compounds/other organic compounds, Acid
mist, etc.
A1-3 Pollutants due to combustion of fuel or due to process: 25
PM, CO2, CO, NOx, SO2, etc.
A1-4 Volatile Organic Compounds (VOCs): 20
Ethyl benzene, Styrene, Toluene, Xylene, Aromatics, Propylene Glycol,
Ethylene Glycol, etc.
Score A2: Score based on fugitive emissions and odour nuisance
(Maximum of the following scores to be considered)
A2-1 Fugitive emissions of Particulate Matter (PM), acid mist, VOCs, etc. from 30
process
A2-2 Fugitive emissions of Particulate Matter (PM), acid mist, VOCs, etc. due 25
to storage and handling, etc.
A2-3 Odour nuisance, including odour due to the use of binding gums, cements, 20
adhesives, enamels etc.
Score A3: Score based on quantity of fuel
(Maximum of the following scores to be considered)
Coal or liquid fuels
A3-1 Fuel consumption ≥ 24 TPD 35
A3-2 12 TPD ≤ Fuel consumption < 24 TPD 30
A3-3 Fuel consumption < 12 TPD 25
Biomass-based fuels
A3-4 Fuel consumption ≥ 48 TPD 25
A3-5 24 TPD ≤ Fuel consumption < 48 TPD 20
A3-6 Fuel consumption < 24 TPD 15
Cleaner/gaseous fuels, such as, PNG, CNG, LPG, Compressed Biogas
(CBG), propane, butane etc.
A3-7 Fuel consumption ≥ 120 TPD 20
A3-8 60 TPD ≤ Fuel consumption < 120 TPD 15
A3-9 Fuel consumption < 60 TPD 10
A3-10 Electricity 0
Air Pollutant Score (PIA) =A1+A2+A3
Note: In case, any sector/unit is using more than one type of fuel, the most polluting fuel category,
will be considered.
iii. Scoring criteria for industrial waste generating Sector “PI”
Industrial waste generating sectors are considered based on the generation of hazardous
waste/high volume low effect waste. As per the Hazardous and Other Wastes (Management
& Trans-boundary Movement) Rules, 2016, the “hazardous waste” means any waste which
by reason of characteristics such as physical, chemical, biological, reactive, toxic, flammable,
explosive or corrosive, causes danger or is likely to cause danger to health or environment,
whether alone or in contact with other wastes or substances and shall include waste as per the
Schedule I, Schedule II and Schedule III of the rule. Further, scores are also assigned to the
high-volume low effect wastes such as fly ash, phosphogypsum, red mud, jarosite, slags from
pyro-metallurgical operations, mine tailings and ore beneficiation rejects.
The score for waste comprises of two sub-scores H1 and H2. The H1 score is based on the
different type of hazardous waste which are generated during the process, and which required
to be managed/disposed through common facility OR based on the generation of high-volume
low effect waste/ HW like contaminated bags/ drums etc. The H2 score is based on the total
quantum of waste generated.
The desirable disposal method such as incineration, landfill after treatment, landfill etc.
signifies the potency of hazardous waste. In recent time, the utilization of hazardous waste as
per the Rule-9 of Hazardous and Other Wastes (Management & Trans-boundary Movement)
Rules, 2016, as alternate fuel and raw material in cement kilns, as recyclable hazardous waste
etc. has increased. The classification is based on the pollution potential due to generation of
such types of hazardous waste from any sector. The score for the quantum of hazardous waste
is total potential of generation of such hazardous waste by any sector., Score H1: Based on
potency of hazardous waste and score H2: Based on quantum of hazardous waste, are given
weightage of 30% and 70%, respectively. Considering the higher risk due to amount of
hazardous waste generated rather than its disposal method, more weightage is given to the
quantity. Overall waste generation score in case of waste generating sector will be PI H
=H1+H2. The scoring criteria for hazardous waste generating sectors are given at Table-III.
A separate scoring criterion has been included for sectors generating bio-medical waste. Bio-
medical waste means any waste, which is generated during the diagnosis, treatment or
immunisation of human beings or animals or research activities pertaining thereto or in the
production or testing of biological or in health camps, including the categories mentioned in
Schedule-I appended to the Bio-Medical Waste Management Rules, 2016. As any Health
Care Facilities (HCFs) generates all types of bio-medical waste (red, yellow, blue, and white)
and quantities of such wastes may vary considerably based on the type of facility/location of
facility (rural/urban), and other such factors. Therefore, scoring based on number of beds in a
healthcare facility is considered as sole criteria for assigning waste score (H: B-1 to B-7) as
tabulated in Table-III.
Least score of 25 is given to non-bedded healthcare facilities and maximum score of 100 is
given to facilities having more than 1,000 beds. Overall waste generation score in case of bio-
medical waste generating sector will be PIH.
Table III: Scoring criteria for waste generating Sectors
Waste
Pollutant Description Score
Group
A. Score for sectors generating hazardous waste
Score H1: Score based on the hazardous waste management/disposal method.
(Maximum of the following scores to be considered)
H1-1 Hazardous wastes which are flammable, ignitable, corrosive, oxidizing 30
toxic, etc. and requiring disposal through incineration
H1-2 Hazardous wastes which are reactive, capable of yielding another 25
material post disposal, etc. and requiring disposal in secured landfill
after stabilization/treatment
H1-3 Hazardous wastes which are requiring direct disposal in secured 20
landfill without stabilization
H1-4 High volume and low effect wastes, contaminated bags/ drums/ 10
containers etc.
Score H2: Score based on quantity of hazardous waste generation.
(Maximum of the following scores to be considered)
H2-1 Hazardous Waste ≥ 5000 TPA 70
H2-2 1000 TPA ≤ Hazardous Waste < 5000 TPA 50
H2-3 200 TPA ≤ Hazardous Waste < 1000 TPA 30
H2-4 10 TPA ≤ Hazardous Waste < 200 TPA 20
H2-5 Hazardous Waste < 10 TPA 10
B. Scores for the sectors generating bio-medical waste
B-1 No. of beds ≥ 1,000 100
B-2 500 ≤ No. of beds < 1,000 80
B-3 200 ≤ No. of beds < 500 60
B-4 50 ≤ No. of beds < 200 50
B-5 10 ≤ No. of beds < 50 40
B-6 No. of beds < 10 30
B-7 Non-bedded facility 25
For sectors generating hazardous waste PIH =H1+H2
For sectors generating bio-medical waste PIH =B
4.0 COMPUTATION OF CUMULATIVE POLLUTION INDEX AND CRITERIA
FOR DECIDING CATEGORY OF SECTOR
In the revised methodology of classification (2024), all three pollutant scores due to water, air
and industrial waste generation are taken into account while computing pollution index. The
formula for computing cumulative pollution index (PI) is as follows:
PI =i max + ( 100−i max ) ( )
i 2+ i3
200
Where, imax, is the maximum score among Water (PI W), Air (PIA), and Waste (PIH)
pollutant scores and i2 & i3 are the remaining pollutant scores.
The category of the sector will be decided based on the pollution index ranges given at
Table-IV.
Table IV: Ranges of Cumulative Pollution Index for different categories
Cumulative Pollution Index Category of industrial sector
(PI)
PI ≥ 80 Red
55 ≤ PI < 80 Orange
25 ≤ PI < 55 Green
PI < 25 White
All the sectors are classified broadly under four categories i.e., red, orange, green, and white.
In addition, Blue Category is introduced for essential environment services for management
of domestic waste, however its PI is calculated as per the above methodology.
The purpose of classification is to have uniform consent mechanism, defined routine
monitoring frequency by concerned SPCB/PCC, environmental protection plans etc.
Modified methodology also considers the variation in pollution potential due to various type
of activities and operations in a particular sector.
5.0 ASSESSMENT OF POLLUTION POTENTIAL/INDEX AND CATEGORY OF
STANDALONE PROJECTS GENERATING HYDROGEN AND AMMONIA
Electrolytic methods (electrolysis), when compared to thermochemical methods for
producing hydrogen are having high conversion efficiency. Further based on the source of
electricity, hydrogen is named as Green hydrogen if produced using renewal sources of
energy such as Wind, Solar, tidal etc. Using hydrogen generated through the electrolysis
using renewal sources and reacted with Nitrogen (Basic Heber’s Process) to produce
ammonia, termed as Green ammonia.
In order to understand the available production technologies and their environmental
concerns, it is desirable to have a stakeholder consultation. Following inputs (technology-
wise) will be helpful to assess the pollution index for such operations:
1. Type of technologies (commercially viable) for production of hydrogen to be used by
the plants to be established under National Green Hydrogen Mission.
a. None at present time. Commercial viability may be achieved with carbon
credit/ carbon tax coupled with government funding and incentives.
2. Brief about the production technology and variation based on the technologies in
terms of water requirement, power requirement, membrane used (its MOC and life).
a. For PEM Electrolyzer technology following parameters are applicable:
i. Water requirement ~10 litre/ kg of Hydrogen
ii. Power Requirements (complete plant) ~56kWh/kg of hydrogen
iii. Membrane MoC – PFSA; Membrane Life – Up to 10 years
3. Difference in production method of hydrogen by electrolysis and pyrolysis.
Electrolysis Pyrolysis
Feedstock Water Biomass/ NG/
Coal/etc.
Energy Source Electricity Thermal/ Heat
End-Product Hydrogen Hydrogen
By-Product Oxygen Bio Char/ Coke/
PyOil/ Syngas Other
forms of carbon
residues depending
upon feedstock used
Process Electrochemical Cell Process Reactor
4. Daily average production capacity ranges of such plants (Minimum and maximum
viable capacity (product-wise)).
a. Minimum capacity: ~350 kg/hr.
b. Maximum capacity: No bar
5. Daily average freshwater consumption (MLD/KLD) and its source. Variation in
quantity when using sea water/ river water.
a. 10 litre/ kg H2 with Demin water
b. ~14 litre/kg H2 with freshwater
6. Sea water desalination plant requirement, quantity of brine generation/KLD of sea
water.
7. Requirement of utilities like Cooling tower, chilling plant, DM Plant etc.
a. Utilities required:
i. Cooling Water
ii. Instrument Air
iii. Nitrogen
8. Daily average wastewater generation (MLD/KLD), from various streams/process
along with the characteristics of the wastewater. (Difference in characteristic of
wastewater during electrolysis and pyrolysis)
a. For PEM Electrolysis wastewater is ~5litre/kg of H2
9. Details of ETP (unit operations/process) for the treatment of wastewater.
a. For PEM electrolysis ETP is not required.
10. Daily average quantity of fuel used (solid/liquid/gaseous) for plant operations and its
details.
a. For PEM Electrolysis – None.
11. Details of generator sets used in the plant- capacities, fuel type etc.
a.
12. Type of catalyst used in the process for the production of hydrogen, ammonia.
a. In PEM electrolysis process, catalyst is not used.
13. Hazardous wastes generated from plant operations and their annual average quantity.
a. In PEM electrolysis process, hazardous waste is NOT generated.
14. Details of end-use of the product and storage quantity.
a. Green hydrogen can be used both as a fuel and as an energy carrier. Further,
GH2 can be used to generate other green molecules like ammonia, methanol,
SAF, etc. which can help decarbonize hard to abate sectors. Hydrogen as a fuel
can be used in H2 based IC engines, can be used as fuel in turbine driven
power plants as well as in fuel cells to generate electricity.
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