1、Technical Session II : steel works, coke ovens, sintering plants and power plantsJean-Pierre DebruxellesTechnical DirectorEUROFER“Stakeholder Day on the EU Monitoring and reporting Guidelines”Cologne, 12 May 20051Technical Session II : steel works, coke ovens, sintering plants and power plantsPresen
2、tationI. Introductory remarksII. Process related emissions and export gasesIII. The integrated route (BF-BOF)IV. The electrical route (EAF)V. Transversal aspects (accuracy, flexibility, cost-effectiveness, uncertainties, tier thresholds)VI. Conclusions and recommendations2Technical Session II : stee
3、l works, coke ovens, sintering plants and power plantsa) Questions about the ongoing procedure leading to the revision of those guidelines (time line)b) Consistency with other legal texts (ET directive and NAP guidance)1. I. Introductory remarks3Technical Session II : steel works, coke ovens, sinter
4、ing plants and power plants1. I. a) Time line June 200613.10.2003 and 25.10.2003January 2004June 05 Dec 2006Commission + Consortium revising the MRG (ann I.1)Adoption ofthe ETDirective + OJAdoption of-The MRG - The NAP GuidanceReport from MSs = f(MRG) art.21 Deadline for revised MRGProposal for an a
5、mending Directive (art.30)+2nd NAPsVerification2005March 2006Art 5/6 : Permit = f(MRG) Art 24 : opt in for new gases = f(MRG) request from a MS or CEC initiative to adapt the MRG 4Technical Session II : steel works, coke ovens, sintering plants and power plants1. I. a) Time line The Commission will
6、review (the MRG) by 31 December 2006, taking into account experiences with the application of the Annexes and any revisions to Directive 2003/87/EC, with a view to any revised Annexes taking effect from 1 January 2008.“A competent authority may require the operator to change its monitoring methodolo
7、gy for the next reporting period if the reporting installations monitoring methodologies are no longer in conformity with the rules laid down in these guidelines. A competent authority may also require the operator to change its monitoring methodology for the next reporting period if the monitoring
8、methodology under the permit has been updated in accordance with a review to be undertaken before each period referred to in Article 11(2) of the Directive.” 5Technical Session II : steel works, coke ovens, sintering plants and power plants1. I. a) Time line : questions for clarification1. The secon
9、d NAP will be submitted by MSs to the Commission on 30 June 06 to cover the period 08-12: what about the “measures planned to monitor and report emissions in accordance with the MRG” in the installations permit (only the existing MRG is binding at the moment)? 2. What will happen for installations c
10、overed by a valid permit (art 5 and 6) after 1.1.08? An intermediary revision whereas the reporting period is already ongoing?3. What about the opt-in for new GHG ? Will the revised MRG include provisions for those GHG? Only after 2012 ? 6Technical Session II : steel works, coke ovens, sintering pla
11、nts and power plants1. I. b) Consistency with other legal texts:The Communication (COM(2003) 830) on NAP guidance implementation of the criteria listed in Annex III to ET Directive) was adopted on 7 January 2004.The MRG adopted three weeks later (29 January 2004) could not take this NAP guidance int
12、o account properly in particular as far as integrated steel plants are concerned.The revision offers the possibility to correct this situation!7Technical Session II : steel works, coke ovens, sintering plants and power plants1. II. Process related emissions and export gases (1/3)Nothing prohibits in
13、 the ET Directive a Member State to allocate allowances to the operator of the installation transferring the waste gas.The NAP guidance has stated:“Where a waste gas from a production process is used as a fuel by another operator, the distribution of allowances between the two installations is a mat
14、ter for Member States to decide. a Member State may choose to allocate allowances to the operator of the installation transferring the waste gas” 8Technical Session II : steel works, coke ovens, sintering plants and power plants1. II. Process related emissions and export gases (2/3)Our proposals: Ch
15、apter 4.1.: Boundaries (page 8), 1) All emissions from an installation shall be assigned to that installation, regardless of exports of heat or electricity or exports of waste gases (in the meaning of item 92 of COM (2003) 830) to other installations. Emissions associated with the production of heat
16、 or electricity or emissions associated with the combustion of waste gas imported from other installations shall be assigned either to the importing or to the transferring installation depending on the allocation method of the corresponding allowances 9Technical Session II : steel works, coke ovens,
17、 sintering plants and power plants1. II. Process related emissions and export gases (3/3)Our proposals: Chapter 4.2.2.1.2.: “Transferred CO2” (p. 11)2) “CO2 being transferred to an installation as part of a mixed fuel (such as blast furnace gas or coke oven gas) shall be included in the emission fac
18、tor for that fuel. Thereby, the emissions corresponding to the transferred fuel/gas will be monitored and reported by the operator of the installation who will be allocated the corresponding allowances according to the method of allocation chosen by the Member State (Cf. item 92 of COM (2003) 830).”
19、 10Technical Session II : steel works, coke ovens, sintering plants and power plants1. III. The integrated route (1/3)Our proposals: Mass balance approach and “bubble concept”a) It should be clarified that, for the sake of a sufficient accuracy the carbon mass balance approach extends across single
20、activities. b) The “bubble concept” should apply to an integrated steel plant c) There must be a possibility to aggregate the different activities : coke oven, metal ore roasting and sintering installations, production of pig iron and steel power plant processing the process-related gases 11Technica
21、l Session II : steel works, coke ovens, sintering plants and power plantsIII. The integrated route (2/3)Accuracy:Not possible to reach a satisfactory accuracy on the basis of the measurement of the particular material flow of every single activity. We suggest the following methodology:Apply the mass
22、 balance approach (already mentioned in the MRG) to all activities which will be summed up in an aggregated system (bubble concept). Irrespective of the ownership of the power plant this one has to be integrated into this aggregated system to ensure the highest accuracy. 12Technical Session II : ste
23、el works, coke ovens, sintering plants and power plantsIII. The integrated route (3/3)Calculations:For the calculation of the emissions of the aggregated system the interactions of the different installations within the system are not taken into account. The only issue is to monitor the inputs and o
24、utputs of the aggregated system.The equation for the mass balance approach remains the same, only taking into account modified boundaries:CO2-emissions t CO2 = ( (activity data input * carbon content input) (activity data products * carbon content products) (activity data export * carbon content exp
25、ort) (activity data stock changes * carbon content stock changes) * 3,664 13Technical Session II : steel works, coke ovens, sintering plants and power plantsIV. The electrical route (1/3)Simplification and clarification are needed to ensure a system much more coherent, straightforward and accurate.T
26、he current MRG would imply identified specific emission factors for each carbonaceous material which produces process related emissions in the EAF furnace (foaming graphite, anthracite, coke, electrode of graphite) plus combustion processes from natural gas. This evaluation will imply a high uncerta
27、inty itself.14Technical Session II : steel works, coke ovens, sintering plants and power plants1. IV. The electrical route (2/3)Proposals:1) Consider process related emissions as if they were combustion emissions (smelting occurring at almost 3000 C, materials used in the processs oxide themselves a
28、s in a real combustion. 2) Assumptions for each carbonaceous flows (Natural Gas, pig iron and HBI/DRI, solid coals, electrodes - made of pure C)3) Emission factors are those included in the National Inventory, as a national average, independently whether they are associated to combustion or to proce
29、ss. 15Technical Session II : steel works, coke ovens, sintering plants and power plantsIV. The electrical route (3/3)Proposals:4) Necessary simplification regarding the Carbon mass balance calculation : C contained in scrap, ferroalloys and final recarburants = C contained in steel + small amounts r
30、etained in dusts and slag. 5) No emissions associated to the recarburants finals additions6) No emissions associated to decarbonation of the very small fraction of the non-yet decarbonated part (de minimis rule)7) Applying the “bubble concept”. 16Technical Session II : steel works, coke ovens, sinte
31、ring plants and power plantsV. Transversal aspects (accuracy, flexibility, cost-effectiveness, uncertainties, tier thresholds)Annex I - section 10 ISO 17025:Accuracy is prejudiced by the requirements : in particular tier 3 requirement for net calorific value and emission factors to be measured in a
32、laboratory that is ISO17025 accredited!a)Internal flows: internal measurements of input/output materials and arising process gases/fuels are performed to a high degree of accuracy and at a sufficiently high frequency to fulfil critical process control and quality monitoring functions. A more flexibl
33、e approach would be to allow industry, where appropriate, to use internally generated information, subject to inspection by the competent authority. 1.This would improve accuracy whilst avoiding the cost burden of accreditation. 17Technical Session II : steel works, coke ovens, sintering plants and
34、power plantsV. Transversal aspects (accuracy, flexibility, cost-effectiveness, uncertainties, tier thresholds)Annex I - section 10 ISO 17025:b) External flows:The majority of our international suppliers of coal and alloying additions cannot affirm that the analyses of their deliveries have been perf
35、ormed by an accredited laboratory. This means that the MRG requirements cannot be met. The steel companies should not be forced to commission an accredited laboratory to analyse control samples, for the reason that the efforts would be disproportionate because the alloying additions account only for
36、 very small fractions of CO2 (about 2 %). 18Technical Session II : steel works, coke ovens, sintering plants and power plantsV. Transversal aspects (accuracy, flexibility, cost-effectiveness, uncertainties, tier thresholds)Annex I - section 10 Standards:Where no applicable standards exist, procedure
37、s can be carried out where possible in accordance with draft standards or industry best practice guidelines. If certain materials are purchased by suppliers from abroad and it is not possible to assess the use of standards for calculating the carbon content the information of the supplier are consid
38、ered as sufficient as it is used for the invoice and company accountability.19Technical Session II : steel works, coke ovens, sintering plants and power plantsV. Transversal aspects (accuracy, flexibility, cost-effectiveness, uncertainties, tier thresholds)Cost-effectiveness de minimis rule - uncert
39、ainties:The cost of monitoring small emissions will be excessive. MRG should adapt the necessary flexibility (below a certain threshold). There should be a more detailed definition of “batch” including the necessary threshold when large amount of materials are procured in small batches (road trucks)
40、.The tier approach emphasises the accuracy of batch measurements without considering the combination of uncertainties with the size and number of batches (it treats 150000 tonnes coal procurement by ocean vessel like several thousands 20 tonnes trucks batches). 20Some data for a characteristic integ
41、rated facility (9 Mt CO2/year)Material Total use(Total C) Procurement method Measurement Size of batch Number of batchesCoking coal 2.10 Mt(1.70 Mt) Boat Tonnagemeasurement 30-120 kt 25BF coal 0.80 Mt(0.65 Mt) Boat Tonnagemeasurement 30-120 kt 10Anthracite 0.18 Mt(0.15 Mt) Boat Tonnagemeasurement 30
42、-50 kt 5Iron ores 7.50 Mt(2.0 kt) Boat Tonnagemeasurement 150-200 kt 40Natural gas 1300 TJ(20 kt) Pipe Flow meter ContinuousLimestone 0.80 Mt(0.10 Mt) Trucks Road scale 25 t 3200021Technical Session II : steel works, coke ovens, sintering plants and power plantsV. Transversal aspects (accuracy, flex
43、ibility, cost-effectiveness, uncertainties, tier thresholds)Net Calorific Values: In the context of the mass balance approach, there is no need to report the Net Calorific Values (NCV).NCV measurement is expansive and poorly accurate while carbon analysis is easy. Easier to compute 3.664 * Activity
44、data * Carbon contentthan3.664 * Activity data * NCV *(Carbon content/NCV) 22Technical Session II : steel works, coke ovens, sintering plants and power plantsVI. Conclusions and recommendations 1. Our proposals are aiming at a lower uncertainty and better accuracy without entailing excessive and unj
45、ustifiable administrative and analytical burdens. 2. It should be very explicit in the MRG that national competent authorities have discretion to apply pragmatic requirements so long as the underlying principles of completeness, consistency, transparency etc. are satisfied (case of emissions factors).3. A new evaluation of the MRG is desirable after the verification process will have take place (March 06). 23
