1. 2005 MRG stakeholder day Concerns and proposals of the downstream oil industry
J-F. Larivé, CONCAWE

2. Main issues What is a source? Uncertainty level and tier approach
Metering equipment
Emission factors
FCC coke
Lab accreditation
Verification

3. The concept of source should not be interpreted
What is a source?
A physical point where CO2 is emitted
a fundamental building block of the overall CO2 emission calculation for an installation such as a complete fuel system
The concept of source should not be interpreted
in a restrictive way

4. Uncertainty level and tier approach
We support the principle of a tier approach
Aim should be to link uncertainty to magnitude of emissions
Two major criticisms of Commission’s proposed approach
Tier structure is arbitrary and unnecessarily restrictive
Does not appropriately reflect either technical feasibility or cost issues
Uncertainty for a source depends on the installation it is part of
Leads to unreasonable and unjustified requirements for relatively small sources that have only a minor contribution to the total
No consideration of contribution of a source to total installation makes it difficult to determine optimum path towards improvement
The KEMA approach proposes equal treatment of all sources but
does not adequately address the issue of achieving desired global uncertainty at minimum cost
Still results in very stringent requirements for relatively minor sources

5. Uncertainty level and tier approach
The CONCAWE approach: linking tiers to global uncertainty target
Combined uncertainty can be lower than that of some individual sources
Overall uncertainty targets can be met without meeting current tier requirements on all sources
In certain cases lower than target uncertainty could be achieved
Reducing uncertainty does not reduce emissions!
It therefore does not have an environmental benefit
MRG should provide option to deviate from standard tiers as long as compliance with overall uncertainty can be established
- Would allow operators to concentrate efforts onto the really important sources
- Would give refiner maximum flexibility to implement
- Would provide a clear path towards cost-effective improvement

6. Metering equipment
In-field accuracy and precision are different from manufacturer’s data
Operators should be able to select the most appropriate equipment type, calibration and maintenance protocols as long as they can be demonstrated to be fit for purpose
Dialogue between permitting/competent authority and operator
ISO specified for CEM’s does not allow calibration via a standard sample that are not adapted to refineries
This is the only practical or feasible method for refinery flue gas analysers
This requirement should be therefore be reconsidered
Operator should instead demonstrate quality of calibration process

7. Use of standard emission factors should not be mandated
Refinery fuels are not commercial products
Their composition varies, particularly fuel gas
Generic or national emission factors are always less accurate than locally derived ones either regularly measured or even inferred from local experience
Use of standard emission factors should not be mandated

8. The FCC tiers should be reversed
FCC coke
The tier hierarchy proposed by the Guidelines appears to have been misconceived. The regenerator stoichiometric balance is likely to give more precise results
The FCC tiers should be reversed

9. Laboratory accreditation to EN ISO 17025
Sound management of refinery labs is guaranteed by their QMS and EMS
Technical competence is ensured through use of international analytical standards and regular inter-lab comparison programmes
Refinery labs deliver CoQ’s for all commercial products including sensitive ones such as jet fuel
Use of an external lab for gas samples is impractical or may lead to further deterioration of accuracy
The requirement for EN ISO accreditation
Should be waived when equivalent practices can be demonstrated

10. Verification
Establishing monitoring protocols (e.g. calibration, frequency of sampling) are matters to resolve between operator and competent authority
Verification should assess compliance with agreed protocols
Not the validity of the protocol itself

11. Concluding remarks
The aim of the EU ETS is to decrease CO2 emissions in a cost-effective manner
The current monitoring and reporting guidelines are based on sound principles
They, however, need to
Better recognise the diverse reality of installations
Be less dogmatic and more result-oriented
Leave maximum flexibility to each installation to achieve a target level of uncertainty
Be more attentive to costs and cost-effectiveness