2005 MRG stakeholder day Concerns and proposals of the downstream oil industry

1. 2005 MRG stakeholder dayConcerns 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. 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 14181 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. Emission factors • 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. 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 17025 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