As is known, the monitoring plans prepared within the framework of the Legislation on the Monitoring and Reporting of Greenhouse Gas Emissions (Regulation on the Monitoring of Greenhouse Gas Emissions & Communique) were submitted to the Ministry’s approval by the end of September 2014. There are some issues to be considered in the preparation and control of the monitoring plans. Special monitoring rules applying to about twenty different sectors which carry out the activities listed in Annex-1 of the Regulation are specified in Annex-3 of the Communique. The aim of this paper is to raise awareness on special monitoring rules in the iron-steel sector and to guide for preparing a more accurate monitoring plan.
If the activities listed in Annex-1 of the Regulation are to be examined, it is seen that a classification can be made in the form of combustion of fuels and process activities. Therefore, it is important to pay attention to both types of activities when checking whether the facilities exceed the threshold values listed in the regulation. In addition, the facility must also pay attention to the sector specific rules and the scope of monitoring listed in Annex-3 of the Communique. In order to explain the situation better, an integrated iron-steel facility and monitoring plan will be discussed in the next section of the article.
After determining that the facility is within the scope, potential sources of CO2 that is in the Annex-3 of the Communique and that will be included within the scope of the monitoring plan should be determined. According to the Communique, the minimum resources that will be monitored in the monitoring plan include limestone calcination, dolomite and carbonated iron ore, raw materials like FeCO3, fuels (natural gas, coal and coke/including coking duff), process gases (coke oven gas, blast furnace gas and including basic oxygen furnace gas), residues used as input material including filtered dust caused by sinter facility, converters and blast-furnace, other fuels, washing of waste gas, reductive (coke, coal and plastics included) and consumption of graphite electrodes. Enterprises should include all of these source streams and emission sources in their monitoring plans if they are present at the facility. The “Special Monitoring Rules” specified in Annex-3 of the Communique should be followed for possible source streams specified by the facility. In this context, when we examine the related parts of the Communique (Annex-3, section 5 and 6), it is seen that the method to be followed in the iron-steel industry is the method of mass balance. The facility must calculate the emissions caused by process activities with this method (When carbon that were derived from fuel or input materials used in the facility, remains in production products or other product output). When calculating emission in mass balance method the total output amount of carbon is subtracted from the total input amount of carbon of the facility whose borders were drawn. Another point to consider here is the conversion of the calculated amount of carbon into carbon dioxide. For this purpose, the conversion rates specified in the Communique are used. In the method of mass balance, the whole of the enterprise can be designated as a single facility as facility boundaries. At this point, a great importance should be attached to the complete definition of source streams.
However, if enterprises wish (to be copatible with 22nd article and with 2nd and 4th section of Annex-2) they may choose to calculate combustion and process emissions individually by using the standard method, in a part of the source streams. In this case, the most important point to be considered is the complete identification of all source streams and the prevention of repeating counts. For example, while calculating with the mass balance method if a fuel source stream that is taken into account, is taken into account again when applying the standard method in a facility; the correct calculation could not be presented because it will be a duplicate count.
Another point that needs to be determined after the calculation method is to determine the stages. In this regard, enterprises determine the stages in which they should apply within the framework of Annex-2 of the Communique. In cases where the mass balance is used, the definition of the required levels for the calculation factors is stated in this section (M&R Communique, Annex-2 Section 3). For the necessary and applicable steps, 24th item of the Communique is examined. Here, the steps that should be followed by the enterprises are defined in determining the activity data and calculation factors. It is decided whether the necessary steps can be applied or not in accordance with the reasons listed here. If lower levels will be selected than the required level, relevant articles of the Communique should be presented with justifications and appropriate explanations.
How to determine the activity data and calculation factors related to source streams according to the level applied is another point to be considered. The paths specified in the 25, 26 and 27th articles of the Communique are followed related to the determination of the activity data. Facility data is determined by continuous measurement or inventory variation. Activity data is determined within the framework of the related items according to the method that will be selected. In order to determine the calculation factors, the 28th item of the Communique should be examined at first. The enterprise uses the default values or the values based on analysis to determine the calculation factors depending on the level. When calculation factors are set as the default, one of the values specified in 29th article of the Communique. In cases where national or international values will be used, the enterprise should use national values as a priority and should search for other options if it cannot reach these values. For analysis based calculation factors, actions must be taken within the framework of 30, 31, 32 and 33rd articles. Another point to consider is that laboratories used in the analysis should have been qualified by the Ministry according to the relevant standards.
Apart from these, points will be considered in the monitoring plan can be listed as measurement devices and uncertainty issues, nontechnical description of the facility, procedure (if inventory variation is practiced), if analysis are using for calculation factors; procedure for sampling and used laboratory, selection of the frequency of analysis, determination of responsibilities, procedures for data loss, risk analysis, uncertainty as additional document.
As a result, as shown in the above example, enterprises should identify their activities and follow the specific monitoring methods for these activities. In this way, they can prepare the monitoring plans in a complete and accurate way.