Technical Session III: Refineries

1

Technical Session III Refineries May 12
2005 Jochen Harnisch, Ecofys j.harnisch_at_ecofys.de

2

• Background information
• Stakeholder Day is part of Stakeholder
  Consultation
• Outcome will be documented (note taker) and
  considered for modifications of the MRG
• - List of key messages
• - List of key problems during implementation
• - List of key proposals for modification
• Revised Guideline expected to be adopted by the
  end of the year 2006

3
Overview

• 11 questionnaires 4 from industry associations
  and 7 from installations - and 2 position papers
  / other written comments received
• Comments on cross-cutting as well as on technical
  issues with focus on accuracy requirements

4
Comments Accuracy and Cost-Effectiveness I

• Accuracy requirements need to be balanced against
  cost effectiveness
• Clear definition of unreasonably high cost is
  needed to avoid misinterpretation by authorities
• Accuracy requirements for single sources should
  take contribution to total emissions into account

5
Comments Accuracy and Cost-Effectiveness II

• Current provisions require investment in new
  metering equipment without leading to an increase
  in data quality
• More flexibility is needed to include highly
  variable quality and composition of
  self-generated fuels cost-effectively as well as
  complexity of refinery processes
• Address total site uncertainty and leave more
  flexibility at source level

6
Comments Accuracy and Cost-Effectiveness III

• Allow refinery to be considered as unified
  installation
• EN ISO 17025 accreditation does not lead to
  improved accuracy, but to higher costs -gt allow
  alternative methods of quality assurance, e.g.
  laboratory practice equivalent to EN ISO 17025
• Allow use of proven industry practices when more
  accurate than MRG requirements

7
Stakeholder Presentation
8
Discussion

• Accuracy thresholds for the total site vs
  accuracy thresholds at tier level
• How to include proven industry practices as
  alternatives to tier provisions?
• Considering refineries as unified installations