Experiences of emission monitoring and reporting from installations of a Member State

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2 Experiences of emission monitoring and reporting from installations of a Member State Lisa Buchner German Emissions Trading Authority (DEHSt) Implementation of the EU ETS, TAIEX 27th of September, Zagreb

3 Outline National Compliance Forum Monitoring Plan - assistance for operators and experiences Emissions Report - assistance for operators and experiences 3

4 National Compliance Forum Aim: Accomplish a harmonized implementation and enforcement on national level Members: Representatives of competent authorities on federal State level and of the German Emission Trading Authority (DEHSt) Output: Guidance Documents and FAQ: information on monitoring and reporting in general and on interpretation/ implementation of MRG, i.e. discussing legal inaccuracies and loopholes and creating concrete examples to show operators how to put present legal requirements into practice 4

5 Monitoring Plan - Assistance for operators Exemplary activity-specific MP for Combustion Installation Exemplary MP can be used in Germany to set up an individual MP for the ETS trading period : helps ensuring a complete MP regarding requirements of the MRG 2007 facilitates and helps to adapt the MP to the individual installation; simplifies the compliance cycle and checks by verifiers, regional regulators and DEHSt. Exemplary MP is not intended to replace data and description of individual aspects of a combustion installation. Exemplary MP for CHP station Harry Heater indicates typical problems and solutions for CO2 Monitoring and Reporting. 5

6 Typical stationary combustion installation (CHP plant) CHP Harry Heater : Rated thermal input (capacity) 750 MW Annual Emissions > 500 kt CO 2 Category C installation (MRG) Highest tier levels are required for all major source streams Monitoring procedures refer to an existing management system of the operator 6

7 Important contents of the exemplary Monitoring Plan Version List Description of the installation and the activities carried out Information on the location and the distribution of responsibilities List of emission sources to be monitored List of fuel and material streams List of tiers to be applied Description of measuring devices for the determination of activity data Description of the sampling and analyzing process to define material-specific parameters List of non-accredited laboratories, analytic and quality assurance procedures Description of the continuous measuring procedure Description of procedures for data collection and administration, quality assurance and control Information on the further development of the monitoring plan 7

8 Relevant emission sources and fuel or material streams CHP station Harry Heater is a typical combustion installation Emission sources: 2 boilers with hard coal and biomass combustion (Σ 300 MW th ); 3 boilers with natural gas combustion (Σ 450 MW th ); Fuel or material streams: German hard coal (Ruhr Region) Imported hard coal (from various regions) Used wood (biomass) Ground limestone for FGD De-minimis source stream Natural Gas (H-type, L-type) 8

9 Emission sources to be monitored Activity 1: Combustion Fuel/ Material stream no. Type of Fuel/Material Anticipated annual volume of fuel/material stream [unit] Content of biogenic carbon [%] Anticipated fossil CO 2 emissions per year [t / a] Emission source no. 1 Hard coal from Germany (Ruhr region) 120,000 t 0 320,000 1, 2 2 Natural gas mixture H-type from 200,000,000 grid and L-type)from the Nm ³ Netherlands 0 392,000 (1,2,) 3, 4, 5 3 Imported hard coal 40,000 t 0 95,000 1, 2 4 Used wood 15,000 t , 2 5 Ground limestone 5,500 t 0 2,418 1, 2 9

10 Process flow diagram of CHP station Harry Heater Process flow diagram of CHP station Harry Heater 5 Truck scale Lime stone 4 Used wood Stock for used wood Natural gas: ultrasonic meter (USZ) with electronic volume correction (company) Natural gas: turbine meter (TRZ) with electronic volume correction (supplier) Natural gas for ignition firing (B1, B2) Natural gas as regular fuel (B3, B4, B5) Hard coal Silo for lime stone (FGD) Boiler 1 (B1) 100 MW th. Boiler 2 (B2) 200 MW th. Boiler 3 (B3) 200 MW th. Boiler 4 (B4) 150 MW th. Boiler 5 (K5) 100 MW th. 120 bar, 305 C Hard coal stock 120 bar, 495 C G G G 18 bar, 285 C G G Installation boundary Amount of hard coals: determined by Draft survey 3 4,8 bar, 150 C Installation boundary Amount of German hard coal (Ruhr region): determined by (Railroad) Track scale (supplier) 1 10

11 Measuring devices for the determination of activity data Requested information: Location: Description of the measuring point (e.g. outside installation boundary on supplier s premises, draft surveyor at discharge dock etc.) Measuring function of the device (e.g. weighing, flow measurement etc.) Measuring device: Method, brand, type (e.g. track scale, ultrasonic meter etc.) Scope Typical use Uncertainty Calibration/Verification Last calibration/verification date Interval of calibration/verification Evidence of conformity with the accuracy requirements 11

12 Sampling and analyzing process to define material-specific parameters Requested information: Parameter concerned Data source: (e.g. main company lab, supplier s process GC) Description of Sampling procedure: Method (e.g. automatic/manual sampling etc.) Location (e.g. railway delivery point, In natural gas grid etc.) Frequency (e.g. all charges etc.) Standards (CEN, ISO etc.) Description of Analytic procedure: Method (e.g. Bomb calorimeter, Gas chromatography etc.) Standards (CEN, ISO etc.) Frequency (e.g. one analyses every 5,000 tonnes, continuous, etc.) Evidence of conformity with the accuracy requirements 12

13 Typical non-conformance in actual Monitoring Plans (1) Formal non-conformances: Missing, incomplete or non-transparent process flow diagram Missing annexes, although the operator refers to them in the MP Non-conformances referring to accuracy requirements Information of scope, uncertainty and calibration/verification of measurement devices are missing Sampling and analyses procedures are described insufficiently Evidences demonstrating that the operator meets the uncertainty thresholds for activity data and other parameters are missing 13

14 Typical non-conformance in actual Monitoring Plans (2) Missing information concerning the installation None or only insufficient revision of MP in case of increased capacity or significant change of an installation; Missing installation boundaries concerning ETS and non-ets installations or parts of installations (in case of multi-unit plants) complete description and allocation of source streams is problematic; Other Deviations between monitoring practices and descriptions in MP; No description of procedures to substitute missing data; Insufficient description of data management and control procedures. Emission reports are only as good as the underlying monitoring plans. 14

15 Emission Reporting in accordance with Section 8 Annex I MRG Required data in emission reports for the activity combustion: data identifying the installation; for all emission sources and/or source streams: chosen monitoring approach (calculation or CEMS), chosen tiers and method, activity data, emission factors, oxidation/conversion factors, total emissions; memo items: amount of biomass, CO2 emissions from biomass when CEMS are used, transferred CO2 and inherent CO2 as part of a fuel; temporary or permanent changes of tiers; any other changes in the installation with relevance to CO2 emissions. the Emissions Report is the Monitoring Plan in figures 15

16 Emissions report - Assistance for operators Tool for operators in order to facilitate emissions reporting, available on DEHSt websites: A server-based electronic reporting format (FMS - Form Management System) combined with an electronic signature (required both by the ETS installation and by the verifier) Software containing automatic checks (e.g. completeness, automatic calculation, comparison with data from previous years) reduces the potential for errors for ETS installation and increases the cost-effectiveness of report checking considerably on the part of DEHSt. 16

17 Source Stream Data Hard coal Germany (Ruhr region): Consumed fuel = 121,547.5 t NCV = GJ/t Emission factor = t/gj Oxidation factor = 1.0 Emissions 318, t CO 2 Verification statements 17

18 Typical non-conformances in actual Emission Reports (1) Missing and incorrect data: missing emission sources or source streams incorrect installation boundaries incorrect or implausible emission factors and NCVs information concerning (pure) biomass Inconsistent information: concerning Emissions Report compared to Monitoring Plan concerning Emissions Report and additional documents Reporting Errors can only be detected by comprehensive checks. 18

19 Typical non-conformances in actual Emission Reports (2) Do you notice potential errors? Light fuel oil - reported NCV GJ/t NCV according to DIN GJ/t (!) Hard coal EF analysis ,000t t/gj 40,000t t/gj Reported: 160,000t t/gj Correct weighted average: t/gj (!) operators and verifiers didn t notice! Reporting errors can cause considerable financial damage (sanctions)! 19

20 Impression of the Automated Data Checks in the data base Summary Result Green/yellow/red traffic light Detailed Results missing data missing/negative verification statement miscalculation significant deviations from historical data data for emission factor etc. beyond a typical range new fuels/materials fuels/materials with biogenic content... 20

21 Thank you very much for your attention. Lisa Buchner Internet: