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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
                                         1
LIME SECTOR BASIC PROCESS UNDERSTANDING




                                          2
 EMISSION CALCULATION & MEASUREMENTS


INPUT:   Limestone              Air                 Energy




                       LIME / DOLIME
                           KILN




OUTPUT:        CO2                                  Lime (*)

            (*) Weighing systems behind the kiln is not typical   3
          2005-2007 LIME ALLOCATION FACTS


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


                                                    4
   LIME KILN CHOICE WITHIN 6 POSSIBLE TYPES

  EU(25) = 550 lime kilns         KILN CHOICE DEPENDS ON
       Long rotary kiln

    Pre-heater rotary kiln        - Mineral deposit nature
Parallel flow Regenerative kiln   - Fuels supply
      Annular shaft kiln          - Final product
 Mixed feed Normal shaft kiln
                                  - Input granulometry
       Other shaft kilns

      KILN LIFE TIME              Leading to various emissions
     30 - 45 years                levels
                                                             5
     LIME EMISSION FACTOR MATRIX: THE WAY FORWARD

 PROCESS CO2                      KILN TYPE        COMBUSTION CO2

     NO                                            TECHNOLOGICAL
TECHNOLOGICAL                                        REDUCTION
  REDUCTION                                          POTENTIAL
  POTENTIAL                                        FUEL MIX
      BUT
  -STABILITY-

                              2/3
    PRODUCT
Proposal:
- To exclude process CO2 from trading, or
                                                               6
- 100% of free allocation needed for process CO2
           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
                                                            7
               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
                                                                           8
              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 CO 2/year)
 face the following difficulties:
  - Limited resources to understand complex regulation leading to external
  consultancy
  - Mandatory electronic applications for CO 2 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 CO 2 reports are
  considered as complex and costy as the application report
                                                                                  9
MRG IMPLEMENTATION (1): PRODUCTION STAFF LINE INVOLVEMENT

      Typical data collection in one plant for fuels and limestone




                                                                     10
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




                                                                          11
        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                                         12
                 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)
                                                                        13
              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




                                                                     14
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




                                                           15
     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
                                                           16
                     Yves de Lespinay
                        Alf Wikander


                       www.eula.be
                     Rue du Trône, 61
                     B-1050 Brussels
                     +32.2.511.31.28
THANKS
FOR YOUR ATTENTION

                                  17