Parallel Session on Technical Annexes to the Gothenburg Protocol

1. Parallel Session on Technical Annexes to the Gothenburg Protocol Report to WGSR Tiziano PIGNATELLI EGTEI Co-Chairman UNECE Convention on Long-range Transboundary Air Pollution Geneva, WGS&R 46th Session 12-15 April, 2010

2. Character of the Parallel Session The Parallel Session was not to be considered as an EGTEI Meeting The discussion in the Parallel Session was purely technical and NOT a negotiation session. Single figures were NOT negotiable during the Parallel Sessions. The Parallel Session was aimed at providing the Delegations with all the technical elements useful for making a well pondered selection of options The experts represented themselves and NOT their countries The experts were invited to express a preference for an Option on ELVs to facilitate the further discussion in WGS&R “…. industry experts and representatives of non-governmental organizations were welcome to attend as observers” Geneva, WGS&R 46thSession 12-15 April, 2010

3. Introduction The following 3 options have been adopted in the work of EGTEI, corresponding to 3 different levels of ambitions Option 1: ELV1, demanding but technically feasible option with the objective of achieving a high level of reduction. ELV1 is based upon a value ranging between the lower and upper BAT AEL (where available), Option 2: ELV2, while technically demanding, pays greater attention to the costs of the measures for achieving reduction. ELV2 is based on the upper value of BAT AEL (where available), Option 3: ELV 3, represents current practices based on the current legislation in a number of Parties to the Convention. No preference was expressed by EGTEI because beyond its mandate Geneva, WGS&R 46th Session 12-15 April, 2010

4. Refineries About 25 participants (day 1) discussed the bubble concept and related ELV options The flexibility option bubble concept is generally accepted but a clear definition should be added. The new definition of bubble (combustion + processes) has been explained. This new definition makes the comparison unhelpful with bubble ELVs in the current GP (these include combustion installations larger than 50 MW) All ELV options on the table seem technically feasible, however feasibility accounts also for economical aspects and timescale Geneva, WGS&R 46th Session 12-15 April, 2010

5. Refineries Few experts expressed the impossibility to select an option Other few experts expressed their preference for option 2 Few experts stated that green field new plants may achieve option 1 but future refinery design might not be compatible. Some experts have introduced the distinction between new and existing installations, other experts did not agree One of the EECCA countries expressed difficulty about option 3 and proposed the introduction of different ELVs at different time horizons (even for new plants) Some experts have highlighted the need to consider ELVs in the perspective of emission ceilings. Geneva, WGS&R 46th Session 12-15 April, 2010

6. Refineries In table 1 annex V, the sentence « O2 reference: dry basis, 3 % for combustion ,15 % for gas turbines » has to be removed (it was a mistake) The bubble concept should be considered as an alternative to ELVs. Therefore one expert reminded the necessity to have consistency between the bubble ELV options and ELV options for LCP in refineries, claus plants and FCC. Geneva, WGS&R 46th Session 12-15 April, 2010

7. Refineries Claus plants Experts proposed to replace “Claus plants” by a more accurate wording as “Sulphur Recovery Units (SRU)” Few experts were in favour of option 2 for new SRU and for option 3 for existing SRU. FCC Few experts noted that option 2 is not consistent with the BREF One expert was in favour of option 1, for new FCC. For existing FCC, some experts preferred option 3 Geneva, WGS&R 46th Session 12-15 April, 2010

8. LCP About 20 participants in the meeting (day 2) Discussions on general issues Averaging periods (daily / monthly), new and existing, flexibility options, exceptions Discussions on option preferences Geneva, WGS&R 46th Session 12-15 April, 2010

9. LCP Averaging periods : Daily stricter than monthly, monthly more flexible (less exceptions needed) From a technical point of view, both are feasible Daily average refers to the existing GP as well as to the BAT AELs, while monthly average refers to EU proposed legislation Some experts were in favour of monthly average, few were in favour of daily average Monthly average could include all operating conditions while daily average only refers to standard continuous operating conditions Monthly average needs continuous monitoring Geneva, WGS&R 46th Session 12-15 April, 2010

10. LCP Exceptions : Some experts were in favour of 500 h/year (for emergency plants), few were in favour of a shorter period A distinction should be made between emergency and peak plants, few experts stated that in particular for LCP > 300 MW, exceptions should be made while other experts suggested to keep exceptions and boundaries of 1500 h/year Geneva, WGS&R 46th Session 12-15 April, 2010

11. LCP • Flexibility : • For some experts article 3 provides enough flexibility but some flexibility options have to be maintained : • Desulphurisation rates for indigenous fuel firing • Peak-hour plants for solid and liquid fuels • Plants using [only / mainly] gaseous fuel who have to resort exceptionally to the use of other fuels: Dust and Sulphur. On this issue, many experts are in favour of “only” especially if monthly averages are used. Geneva, WGS&R 46th Session 12-15 April, 2010

12. LCP Options : Each option is technically feasible Few experts were in favour of option 1 especially for NOx and dust, some experts were in favour of option 2 which is in line with the EU proposed legislation In few cases, like existing biomass plants for SO2, all options were unpreferred by the experts In few cases, like gaseous fuels or pulverised lignite for SO2, some experts expressed preference for option 3 Geneva, WGS&R 46th Session 12-15 April, 2010

13. LCP Options : For low calorific gases and combustion plants in refineries, option 3 for dust, in the revised Protocol, was preferred by some experts. Few experts were in favour of option 2 for combustion plants in refineries Many experts expressed the need to rename « coal and lignite » by « coal , lignite and other solid fuels » Geneva, WGS&R 46th Session 12-15 April, 2010

14. General issue Definition of existing plants, in the revised GP, can lead to a mismatch between associated ELVs of current “new” and revised “existing plants” Geneva, WGS&R 46th Session 12-15 April, 2010

15. Gas turbines Few experts were in favour of option 1, some experts were in favour of option 2 Upcoming new fuels such as H2, which have higher NOx emissions, can be covered by flexibility of article 3, according to some experts. Geneva, WGS&R 46th Session 12-15 April, 2010

16. Sulphur content of gasoil Experts proposed to upgrade the definition of gasoil, in the revised GP, with the latest definition available in the EU legislation, The definition of the ELV < 0.1 % needs to be better qualified in legal terms (number of digits) Geneva, WGS&R 46th Session 12-15 April, 2010

17. Petrol distribution and storage Experts highlighted that this issue is higly complex and sensitive for EECCA countries Experts did not express any preference about options Geneva, WGS&R 46th Session 12-15 April, 2010

18. Cement production Some experts expressed their preference for not distinguishing new and existing installations for NOx Some experts preferred option 2 For dust, some experts expressed their preferences for option 2, some others for option 3, and one expert for option 1 Experts expressed their satisfaction with the monitoring description included in the revised annexes Geneva, WGS&R 46th Session 12-15 April, 2010

19. Lime production For dust, some experts expressed their preferences for option 2, and one expert for option 3 Experts expressed the need to include the O2 reference content in the table Experts expressed the need to include thresholds as a footnote, one expert proposed the thresholds to be in line with the existing EU regulation. Geneva, WGS&R 46th Session 12-15 April, 2010

20. Glass production For dust, few experts proposed to refer to the new BREF, currently under discussion Some experts expressed their preferences for option 2 and one expert for option 1, for new plants. Geneva, WGS&R 46th Session 12-15 April, 2010

21. Iron and steel production About 18 participants in the meeting (day 3) NOx, sinter plants Some experts expressed the need to take updated information on BAT into consideration, even if updated BAT AELs are higher than ELVs in the current GP Some experts expressed the preference to have « over a substantial period of time » more clearly defined, while few experts suggested to keep this expression as it is in BREF. Some experts expressed their preferences to keep « daily averaging period » like in the current GP Some experts expressed their preferences to keep the ELV of the current GP (option 3)  Geneva, WGS&R 46th Session 12-15 April, 2010

22. Iron and steel production Dust Some experts expressed their preferences for option 2, few were for option 1, for electric furnaces, one expert was for option 1, when fabric filters can be used Experts expressed the need to add a reference O2 content Experts expressed their preferences to keep the foot note b, concerning averaging period, as daily average Geneva, WGS&R 46th Session 12-15 April, 2010

23. Iron founderies Experts suggested not to include hot and cold rolling mills in the iron foundries sector Some experts expressed their preferences for option 2 and one expert for option 1, for new plants Experts expressed the need to add a reference O2 content Geneva, WGS&R 46th Session 12-15 April, 2010

24. Non ferrous metal production Experts suggested to change the approach based upon dust reduction techniques to an approach based upon types of metal and processes In the current approach, they did not express any preference on options Experts expressed the need to add a reference O2 content Experts suggested to eliminate the first two sentences of the foot note which are already included in article 3 (flexibility) Geneva, WGS&R 46th Session 12-15 April, 2010

25. Pulp production Some experts expressed their preferences for option 2 and few experts for option 1 Experts suggested to use the O2 content of 6 % to be in line with other sectors (solid fuels in LCP) Geneva, WGS&R 46th Session 12-15 April, 2010

26. Waste incineration Some experts suggested to have a clearer definition of wastes, waste incineration, as well as to have clarifications on inclusion of co-incineration in waste incineration sector One expert suggested the need to eliminate any threshold (hourly treated waste) in this sector to be in line with the EU legislation One expert suggested the need to seek consistency in ELVs with the Aarhus Protocol Some experts expressed their preferences for option 3 and one expert for option 1 Geneva, WGS&R 46th Session 12-15 April, 2010

27. Conclusions Items highlighted in the discussions for consideration of WGSR Flexibility in terms of time scale for EECCA countries Milestone approach for EECCA countries would be helpful to facilitate their active involvement in the Gothenburg Protocol ratification process The participation of EECCA countries in the technical sessions should be encouraged through all possible ways Accurate cost data from all the Parties are considered essential for the whole process. Geneva, WGS&R 46th Session 12-15 April, 2010