EU ETS CO2 Monitoring Stakeholders day

1
EU ETS CO2 Monitoring Stakeholders
day MONITORING AND REPORTING GUIDELINES
By Ir. Claude Loréa, CEMBUREAU Technical
Director Cologne
2
INTRODUCTION

• The experience acquired by the European cement
  industry has shown that the monitoring and
  reporting principles defined in the Guidelines,
  are either technically not completely correct, or
  that their implementation would lead to
  unreasonably high costs.
• The cement industry has established methods for
  the detection of relevant production and energy
  consumption data, which have been in use for a
  long time and in respect of which extensive
  experience is therefore available.

3
TIER CONCEPT

• Dependent on the total volume of emissions from a
  plant. Subdivision into three groups (emissions
  of up to 50,000 t CO2/year, between 50,000 and
  500,000 t CO2/year and above 500,000 t CO2/year).
• High specific CO2 emissions of the clinker
  burning process gt almost all installations fall
  under Tier 3, none under Tier 1.
• Tier approach ambiguous and creates difficulties
  with national authorities when defining the
  reporting requirements.
• Creates implementation problems and leads to the
  fact that comparable installations are not always
  treated equally.

4
(No Transcript)
5
(No Transcript)
6
SAMPLING AND ANALYSIS MEASUREMENT ACCURACY

• As a general comment, high requirements that do
  not bring any additional know-how.
• Reference to accredited labs is superfluous (ISO
  17 025). Sufficient in-house experience. Avoid
  unnecessary testing.
• Accuracy requirements can frequently not be
  maintained during LT operations.
• Table 3 of the Guidelines ( 4.3.3.)

• OK for process emissions and solid fuels
• KO for waste fuels heterogeneity
• 10 overall uncertainty should be applied in all
  cases

7
LEGISLATION CONCERNING MONITORING REPORTING

• ET Directive, Art. 14 (1)
• The guidelines shall be based on the principles
  for monitoring and reporting set out in Annex IV.
• ET Directive, Annex IV (Principles MR)
• Accepted emission factors shall be used.
  Activity-specific emission factors are acceptable
  for all fuels. Default factors are acceptable for
  all fuels except non-commercial ones (waste fuels
  such as tyres and industrial process gases).
• Monitoring Reporting Guidelines 29/01/2004
• National implementation

8
USE OF EMISSIONS FACTORS INSTEAD OF MEASUREMENTS

• In conformity with Annex IV, determination of
  carbon content is only relevant for secondary
  fuels derived from waste.
• Secondary fuels
• if not sufficient data available gt determination
  of carbon content for every fuel on a annual
  basis on an average sample
• secondary fuels used in larger volumes collect
  data available and process information
  statistically
• plausibility tests, within the framework of
  verification
• in the medium term, determine statistically
  robust emission factors (standard values).

9
(No Transcript)
10
BIOMASS FRACTION

• No method available for the time being
• Methods described e.g. Netherlands are not
  adequate
• CEN TC 343 first tests show the method does not
  prove to work
• gt CEMBUREAU proposes to make calculations on the
  basis of fixed values

11
PROCESS EMISSIONS

• Emission factor
• specific standard emission factor.
• measured emission factors possible. Measurements
  performed by plant laboratories, possibly
  combined with periodic analysis by external
  accredited labs.
• Activity data
• whatever the calculation method used (input or
  output based) cross check is necessary gt
  adjustments should be allowed.
• once a year makes sense.
• any corrections should be documented.

12
CORRECTIONS FOR CKD AND BY- PASS DUST

• Assuming complete decarbonation leads to
  overestimation of CO2
• Required accuracy cannot be met and
  representativeness is poor in relation to
  activity data
• gt Simplified treatment of CKD is needed
• use of kiln feed/ Clinker factor for the input
  based method
• neglect CO2 emissions relating to CKD for the
  output based method

13
CONCLUSIONS

• Need to amend MRG correct technical errors and
  reduce (measurements) requirements in order to
  improve cost-efficiency  
• CEMBUREAU has developed recommendations based on
  the broadest possible application of established
  reporting methods, which have proven their worth
  over many years.
• This shall give operators of cement plant support
  and contribute to the definition of uniform
  reporting requirements while maintaining the
  necessary flexibility.
• MRG should be reliable, legally enforceable, but
  nevertheless practice-oriented CO2

14
www.cembureau.be