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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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EU(25) = 550 lime kilns

Long rotary kiln

Pre-heater rotary kiln

Parallel flow Regenerative kiln

Annular shaft kiln

Mixed feed Normal shaft kiln

Other shaft kilns

KILN LIFE TIME

30 - 45 years

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