How Are Environmental Management Norms Set Under PERMENLHK P.15/2019?

Indonesia's thermal power sector faces stringent environmental controls under Peraturan Menteri Lingkungan Hidup dan Kehutanan Nomor P.15/MENLHK/SETJEN/KUM.1/4/2019, which establishes comprehensive emission quality standards for thermal power generation facilities. This regulation, enacted on April 5, 2019 and effective from April 23, 2019, represents a critical framework for controlling air pollution from the country's expanding power generation infrastructure.

Regulatory Foundation and Legal Authority

PERMENLHK P.15/2019 implements Article 20 paragraphs (2)(e) and (5) of Law No. 32 of 2009 concerning Environmental Protection and Management. The regulation recognizes that thermal power plants have significant potential to cause air pollution, necessitating systematic emission control measures. This ministerial regulation establishes both emission quality standard limits and mandatory emission monitoring obligations for business operators managing thermal power generation facilities.

The regulation encompasses nine categories of thermal power plants: coal-fired power plants (PLTU), gas turbine power plants (PLTG), combined cycle power plants (PLTGU), diesel power plants (PLTD), gas engine power plants (PLTMG), geothermal power plants (PLTP), biomass power plants (PLTBm), waste-to-energy power plants (PLTSa), and mixed-fuel power plants. This comprehensive coverage ensures that virtually all forms of thermal electricity generation fall under standardized environmental controls.

Core Definitions and Technical Framework

Pasal 1: Key Terminology

The regulation provides detailed definitions for 21 technical terms that form the foundation of the emission control system:

"Pembangkit Listrik Tenaga Termal adalah suatu kegiatan yang memproduksi tenaga listrik dengan menggunakan bahan bakar padat, cair, gas, campuran antara padat, cair, dan/atau gas, atau uap panas bumi."

This definition establishes thermal power generation as any activity producing electricity using solid, liquid, or gaseous fuels, fuel mixtures, or geothermal steam. The regulation distinguishes between different plant types based on their combustion technology and fuel sources.

"Baku Mutu Emisi adalah ukuran batas atau kadar maksimum dan/atau beban Emisi maksimum yang diperbolehkan masuk atau dimasukkan ke dalam udara ambien."

Emission quality standards represent the maximum concentration limits or emission loads permitted to enter ambient air. These standards apply to both primary pollutants measured in concentration (mg/Nm³) and emission loads calculated over operational periods.

"Sistem Pemantauan Emisi secara terus-menerus (Continuous Emissions Monitoring System) yang selanjutnya disingkat CEMS adalah suatu alat yang bertujuan untuk mengukur kadar suatu parameter Emisi dan laju alir melalui pengukuran secara terus menerus."

CEMS technology enables real-time monitoring of emission parameters and flow rates, providing continuous data on plant compliance status. This automated monitoring system represents a significant advancement over periodic manual sampling approaches.

Emission Standards and Compliance Requirements

Pasal 2: Regulatory Objectives and Scope

"Peraturan Menteri ini bertujuan untuk memberikan batasan Baku Mutu Emisi dan kewajiban melakukan pemantauan Emisi kepada penanggung jawab usaha dan/atau kegiatan yang mengoperasikan Pembangkit Listrik Tenaga Termal."

The regulation establishes two primary obligations: meeting specific emission quality standards and conducting systematic emission monitoring. These requirements apply to all operators managing thermal power generation facilities regardless of ownership structure or operational scale.

Pasal 3: Universal Compliance Obligations

"Setiap penanggung jawab usaha dan/atau kegiatan sebagaimana dimaksud dalam Pasal 2 ayat (1) wajib memenuhi ketentuan Baku Mutu Emisi."

All operators must comply with emission standards for both production processes and supporting machinery operations. The regulation differentiates between primary emission sources (boilers, turbines, combustion chambers) and auxiliary equipment (generators, pumps, compressors), applying appropriate standards to each category.

Emission standards vary based on fuel type (coal, oil, natural gas), plant capacity, and technology employed. For example, coal-fired PLTU facilities face different limits than gas-fired PLTG operations, reflecting the distinct pollution profiles of these technologies. The regulation includes specific standards for conventional pollutants (SO₂, NOₓ, particulate matter, CO) and toxic substances (mercury, hydrogen chloride, hydrogen fluoride).

Monitoring and Reporting Framework

Continuous Emission Monitoring Systems (CEMS)

The regulation mandates CEMS installation for larger facilities and those using high-sulfur fuels. Specifically, CEMS requirements apply to:

• Gas engine plants with capacity ≥15 MW
• PLTU, PLTG, PLTGU, PLTD, PLTBm, and PLTSa with capacity ≥25 MW
• Facilities <25 MW using fuels with sulfur content >2% and operating continuously

CEMS must monitor all primary emission parameters specified in the applicable emission standards, plus oxygen (O₂) levels and flow rates. For coal-fired facilities, CEMS must additionally monitor mercury (Hg) and carbon dioxide (CO₂) emissions, supporting both air quality and climate change reporting obligations.

Manual Monitoring Requirements

Facilities not subject to CEMS requirements must conduct manual emission monitoring at prescribed intervals:

• Every 6 months for production process emissions
• Annually for auxiliary generators between 500 kW and 3 MW capacity
• Every 6 months for auxiliary generators exceeding 3 MW capacity

Manual monitoring must employ isokinetic sampling methods for particulate matter and flow rate measurements, ensuring representative sampling under varying operational conditions. Testing must be conducted by laboratories holding registration identification from the Ministry, and results must include specific documentation such as oxygen-corrected concentration values, flow rate measurements, and photographic evidence of sampling activities.

Emission Calculation Methodologies

Emission Load Calculations

The regulation provides standardized formulas for calculating daily and annual emission loads:

Daily emission load: E = Cav × Q × 0.0036 × (Op Hours)

Where:
- E = Daily emission load (kg/day)
- Cav = Average daily concentration (mg/Nm³)
- Q = Volumetric emission flow rate (m³/second)
- 0.0036 = Conversion factor from mg/second to kg/hour
- Op Hours = Operating hours per day

Annual emission load: E(tahunan, P) = Σⁿᵢ₌₁ E

This methodology enables operators to track cumulative emissions over time and demonstrate compliance with both concentration and load-based standards.

Combustion Efficiency Performance

The regulation includes provisions for calculating combustion efficiency based on CO₂ and CO measurements:

Efficiency (η) = CO₂ / (CO₂ + CO) × 100%

This simple metric provides operators with real-time feedback on combustion performance, linking environmental compliance with operational efficiency. Higher combustion efficiency typically correlates with lower emissions of incomplete combustion products.

Data Management and Quality Assurance

CEMS Quality Control Procedures

Operators must maintain comprehensive quality control and quality assurance programs for CEMS equipment, including:

• Operating CEMS according to manufacturer specifications
• Ensuring all components function properly
• Calibrating equipment according to specified schedules and procedures
• Maintaining detailed records of calibration, maintenance, and repairs

CEMS data validity requires that daily averages consist of at least 75% valid hourly readings. This threshold balances the need for continuous coverage with realistic allowances for maintenance and calibration activities.

Record Retention Requirements

All emission monitoring data and supporting documentation must be retained for at least 5 years from the date generated. This extended retention period supports long-term trend analysis, regulatory audits, and enforcement proceedings when compliance violations occur.

Abnormal Operating Conditions and Emergencies

Definition and Allowable Exceedances

"Keadaan Darurat adalah kondisi yang memerlukan tindakan secara cepat, tepat, dan terkoordinasi terhadap sistem peralatan atau proses yang di luar kondisi normal atau karena alasan keselamatan."

The regulation recognizes that temporary exceedances may occur during abnormal conditions such as power supply disruptions, startup/shutdown procedures, or pollution control equipment malfunctions. Facilities using CEMS may exceed emission standards for up to 5% of daily readings during a reporting period when abnormal conditions occur.

Operators must document all abnormal conditions within 3×24 hours of occurrence, including the incident date, affected equipment, root cause, community complaints received, and corrective actions taken. This reporting requirement ensures regulatory awareness of operational issues while maintaining pressure for swift resolution.

Transitional Provisions and Implementation Timeline

Legacy Facility Requirements

Operators of coal-fired thermal power plants commissioned before the regulation's effective date receive transition periods for full compliance:

• 3 years to install CEMS and meet mercury (Hg) and CO₂ emission standards
• 2 years to integrate emission monitoring results into the Ministry's online reporting system

These extended timelines acknowledge the significant capital investments and technical modifications required for existing facilities while establishing clear endpoints for achieving full regulatory compliance.

Regulatory Matrix: Emission Standards Summary

Note: All concentrations measured at standard conditions (25°C, 1 atmosphere) with oxygen correction factors applied.

Compliance Matrix: Monitoring Requirements

BME = Baku Mutu Emisi (emission quality standards applicable to specific plant type)

Technical Analysis: Regulatory Stringency and Implementation Challenges

The emission standards established under PERMENLHK P.15/2019 represent a significant tightening compared to previous regulations. For coal-fired power plants, SO₂ limits decreased from 550 mg/Nm³ to 200 mg/Nm³ (64% reduction), while NOₓ limits dropped from 650 mg/Nm³ to 250 mg/Nm³ (62% reduction). These stringent standards align Indonesia more closely with international best practices for thermal power plant emissions control.

However, environmental advocacy organizations have criticized the standards as still insufficient compared to developed country requirements. Greenpeace Indonesia specifically noted that the revised emission standards remain weaker than those applied in countries with mature environmental regulatory frameworks, potentially allowing continued adverse health impacts in communities surrounding power plants.

The CEMS mandate for larger facilities represents a substantial technological upgrade for Indonesia's power sector. Continuous monitoring systems provide regulatory authorities with near real-time compliance data, enabling rapid identification of operational problems and enforcement actions when needed. The electronic reporting requirements further enhance regulatory oversight capabilities while reducing administrative burdens associated with paper-based reporting systems.

Implementation challenges include the significant capital costs of pollution control equipment retrofits for existing facilities, technical capacity requirements for operating and maintaining sophisticated CEMS equipment, and the need for expanded laboratory infrastructure to support manual monitoring requirements for smaller facilities. The regulation's success will depend heavily on sustained regulatory oversight, adequate enforcement resources, and continued technical assistance to operators navigating these new compliance obligations.

Conclusion

PERMENLHK P.15/2019 establishes a comprehensive and technically sophisticated framework for controlling air emissions from Indonesia's thermal power generation sector. The regulation's combination of specific emission standards differentiated by plant type and fuel, mandatory continuous monitoring for larger facilities, standardized calculation methodologies, and robust data management requirements creates a foundation for meaningful environmental protection.

The regulation's effectiveness will ultimately depend on rigorous implementation and enforcement by regulatory authorities, industry commitment to compliance despite significant costs, and continued evolution of standards to reflect advancing pollution control technologies and scientific understanding of environmental health impacts. As Indonesia continues expanding its power generation capacity to support economic development, this regulatory framework provides essential guardrails ensuring that growth occurs within environmental sustainability boundaries.

For thermal power plant operators, the regulation demands systematic attention to emission control equipment maintenance, comprehensive monitoring programs, detailed record-keeping, and proactive management of operational conditions to minimize compliance risks. The transition periods provided for existing facilities acknowledge implementation challenges while establishing clear expectations that all thermal power generation must eventually meet modern environmental standards.

Official Source: Peraturan Menteri LHK No. 15 Tahun 2019 - BPK RI

Status: Active since April 23, 2019
Berita Negara: No. 455/2019, 56 pages
Legal Basis: UU No. 32/2009 (Environmental Protection and Management)

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