Transcript Monitoring & Reporting Guidelines remarks on Reporting, Uncertainties, CEMs Chris Dekkers Directorate of Climate Change & Industry Ministry of Environment (VROM) 7-11-2015

Monitoring & Reporting Guidelines
remarks on
Reporting, Uncertainties, CEMs
Chris Dekkers
Directorate of Climate Change & Industry
Ministry of Environment (VROM)
7-11-2015
Definitions in M&R Guidelines
Definitions & Principles not sufficiently precise for
translation into national legislation-regulation:
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Level of assurance: what level of assurance obliged by the verifier?
Materiality: the exact and precise definition of what is required?
Monitoring methodology: QA and QC part of the permit?
Legal requirements not clearly and consistently formulated and not
sufficiently precise in legal sense
Precise criteria lacking: “technically not feasible” , “economically
not justified”
Difference Uncertainty – Accuracy - Precision not clearly explained
How to use “cost effectiveness” in practical situations?
How to use principles of Good Governance in practical situations?
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Uncertainty Aspects
VROM initiated two studies by KEMA:
Assess uncertainty approach in M&R
Guidelines and propose solutions
Current
practice
Practicability
Practical
Assess
of TIER approach
experiences
improvements to be made
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Current Practices
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Required tier achievable in Power Plants and
in general: industries buying fuels from
outside
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Problems arise in sectors generating their
own fuels: refineries, production of base
chemicals, coke in steel manufacturing
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Current practice built on technical
assumptions on uncertainties
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Sectors with own fuels
Major differences between various refineries,
chemical plants and steel producing plants:
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Uncertainties directly related to type of internal produced fuel,
variations in these fuels and number of measure points
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Uncertainties often installation specific, depending on the number
and type of processes
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Tiers reported based on assumed uncertainties of various meters
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Uncertainties of meters rarely tested for wear & tear: reported
uncertainties have an “artificial” element
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Leads to following Questions:
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Uncertainties of meters rarely tested for wear & tear:
Should we require that:
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real world uncertainties be measured?
measured values be used?
reported uncertainties be demonstrated?
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If so, how?
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When is uncertainty acceptable and when should
further investments in new meters be justified?
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How can we make concept of cost effectiveness
applicable in real world situations?
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On what basis does Competent Authority decide that
further improvements are justified?
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Other observations
Requirements on verification are not sufficiently clear and
defined in legal terms
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What level of assurance is to be provided by the verifier, what does it
imply and what is the basis for that?
Accreditation: should MS have their own accreditation schemes or
should there be common standards and procedures?
How does the requirement of accreditation comply with the draft
directive on services?
In category C installations all sources to be measured with
highest tier. This may result to odd decisions
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How to decide for which situation highest tier for all sources is justified when not? De-minimis criterion not always applicable
How to assess uncertainty and further improvements in complex
installations?
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