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Stakeholder Day on the EU-Monitoring and Reporting Guidelines Cologne 12 May 2005 MRG European Lime Contribution Yves de Lespinay www.eula.be Alf Wikander

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LIME SECTOR BASIC PROCESS UNDERSTANDING

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EMISSION CALCULATION & MEASUREMENTS LIME / DOLIME KILN INPUT: Limestone Air Energy OUTPUT: CO2 Lime (*) (*) Weighing systems behind the kiln is not typical

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EU (25) lime sector allocation 2005-2007 OVERVIEW 98 M tons consisting of: 2/3 = process emission = ca 1,2% of EU(25) NAPs 1/3 = combust. emission = ca 0,5% of EU(25) NAPs 2005-2007 LIME ALLOCATION FACTS

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LIME KILN CHOICE WITHIN 6 POSSIBLE TYPES KILN CHOICE DEPENDS ON Mineral deposit nature Fuels supply Final product Input granulometry Leading to various emissions levels

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LIME EMISSION FACTOR MATRIX: THE WAY FORWARD KILN TYPE FUEL MIX PRODUCT PROCESS CO2 COMBUSTION CO2 NO TECHNOLOGICAL REDUCTION POTENTIAL BUT -STABILITY- TECHNOLOGICAL REDUCTION POTENTIAL Proposal: To exclude process CO2 from trading, or 100% of free allocation needed for process CO2 2/3

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MRG IMPLEMENTATION ON THE GROUND First approach of MRG is negative, its understanding takes time, but after a costly exercise it becomes operational and accuracy takes place … but, certainly not customised for SMEs Systematic lime output measurement is not typical and technically difficult Lime output related to effective sales and invoices are accurate, easy to collect and to monitor Coal data sometimes is not reliable due to weather conditions

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MRG IMPLEMENTATION CONSEQUENCES Additional measurement tools put in place at source (as opposed to installation) Examples not required for usual operation but required to fulfill RMG accuracy demand - gas flow meter, 12.500 € each/source - weighing system, 10.000 to 20.000 € each/source Measurements frequences increased in comparison to usual industrial measurements New mandatory measurements > usual Administrative chain + written instructions + new software + training + reporting line + audit … SMEs outsourcing Laboratory accreditation acc. ISO 17025

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MRG COMPLIANCE IMPACT FOR SMEs Lime companies with 6 to 10 employees being very close to the threshold of 50 t lime/day (=ca. 23.000 t CO2/year) face the following difficulties: - Limited resources to understand complex regulation leading to external consultancy - Mandatory electronic applications for CO2 application and associated software skill led to external consultancy - Simple financial book keeping led to difficulties to determine mass of bougth fuels as opposed to fuels costs - No real market power to urge their fuels suppliers to conduct fuel analysis acc. ISO17.025 and deliver required details on uncertainties, procedures and sampling. For example, accredited lab are inexistant for coal in Finland - ETS compliance costs are estimated to reach a significative proportion of their total annual profit, and mandatory software to provide CO2 reports are considered as complex and costy as the application report

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MRG IMPLEMENTATION (1): PRODUCTION STAFF LINE INVOLVEMENT Typical data collection in one plant for fuels and limestone

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MRG IMPLEMENTATION (2): DEPARTMENTS IN CHARGE FOR FUELS Example of recording the fuel flow (solid, liquid, gas, others) not only one desk officer but 3 Dpts in charge

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COMBUSTION C02 CALCULATION FROM FUELS CO2 comb = [Qty Fuel x NCV] x Emis Fact x Oxidation Factor  MRG = Measurement / Batch For NCV (Net calorific Value) & Emission Factor Consideration: - Variation < 0,5% between measurement & standard value - Unjustified costs, standard procedure to operate the kiln is accurate enough Proposal: - To use an EU harmonised table as IPPC 1996 related to fuel invoices

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LIME PROCESS C02 CALCULATION CO2 process = Qty CaO x 0,785 (Emission factor) x 1 (Conversion factor) Quantity CaO = only with production of CO2 Measurements: residual CO2 + CO2 neutral material Emission factor CaCO3 x 0,440 Consideration: - Measurement and related calculations based on 2003 and 2004 data = variation < 0,2% CO2 - Unjustified costs Proposal: - To use an installation factor (stability range: 0.95 to 0.99)

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DOLIME PROCESS C02 CALCULATION CO2 process = Qty CaO.MgO x 0,913 (Emission factor) x 1 (conversion factor) same situation as CaO but different factor same proposal

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LIME SECTOR CONCLUSIONS ON MRG 2005-2007 VERSION CONSIDERATIONS Measurements and requested accuracy are out of proportion Mistakes are more likely in future production forecast than in CO2 emission determination

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LIME SECTOR CONCLUSIONS ON MRG REVIEW CONCRETE PROPOSALS Constant factors for a given installation due to its stability as opposed to existing measurement Harmonised fuel factors Emission matrix = range related to fuel mix, kiln type and product to be implemented at Member State level Process emission to receive 100% needed free allocation or be considered as a non tradable allocation Investigate compliance with threshold > 50 t lime/day

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Yves de Lespinay Alf Wikander www.eula.be Rue du Trône, 61 B-1050 Brussels +32.2.511.31.28 THANKS FOR YOUR ATTENTION

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