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

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.

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 => 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.

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

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 M&R) 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

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 => 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).

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 => CEMBUREAU proposes to make calculations on the basis of fixed values

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 => adjustments should be allowed. once a year makes sense. any corrections should be documented.

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 => 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

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

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