MRV IN TURKEY: FROM THEORY TO PRACTICE CEMENT SECTOR EXPERIENCE
Canan DERİNÖZ GENCEL
Head of Environment and Climate Change Department
Turkish Cement Manufacturers’ Association
COP 23, Bonn/Germany 14 November 2017
TURKISH CEMENT MANUFACTURERS’ ASSOCIATION- TCMA
Formal representative of the Turkish Cement Producers
Founded in 1957
Based in Ankara/Turkey
64 employees (R&D, laboratory analyses, certification and environment)
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• Links sector - government – public
• Local and international relations
• Issues: production, quality, training and technology
• Certification Body (environment & product quality)
TCMA Memberships/Memorandum of Understanding/Partners
1972 • European Cement Association
2009 • European Concrete Paving Association
2009 • Arab Union for Cement and Building Materials
2010 • Indian Cement Association
2011 • China Cement Association
2014 • European Cement Research Academy
2015 • Cement Sustainability Initiative (CSI)
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Turkish Cement Sector
1911
20.000 tons/year
2011
100th Anniversary
2016
80 Million tons/year
(Europe 1. World 4.)
72 plants
(54 integrated, 18 grinding)
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Share of Local Capital %81 Share of Foreign Capital %19 (French, Italian, German, Brazilian and Greek companies)
Turkish Cement Sector – Important Topics
Housing
Infrastructure
Energy Projects
Concrete Road
& Barriers
Climate Change
AF/ARM Utilization
Iran, Iraq, Syria
& S. Arabia
Environmental Liabilities
Technological Investments
Energy Efficiency
TCMA has a dedicated department for climate change and environment
MRV Scope
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Energy
Energy+ CO2 Fossil Fuels + O2
Proces- Calcination
Oxides + CO2 Raw Meal (Carbonates) + Energy
Raw Meal + Fuel
Clinker
Grinding
Cement
MRV Profile of Turkish Cement Sector
Total emissions generally >500.000 tons CO2 eq/year
Category C
Highest Tier required
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MRV Profile of Turkish Cement Sector
Standard Calculation
• Method A- input based
• Method B- output based
Mass Balance Calculation
(input and output is clear)
Continuous Measurement
(Calibrations, Annual Surveillance Tests)
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General Preference
Aim of MRV in Cement Sector
So simple:
Determine CO2 from fuels and calcination correctly and precisely
Verify your emissions
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Turkey’s MRV Pathway and the Cement Sector
2011
Start-up
2012 Monitoring regulation
2014
Revised monitoring regulation
2015
Verifier regulation
2017
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• Regulations in line with EU MRV Legislation (some exceptions, i.e. unreasonable costs) • Contributed to drafting legislation of the Turksih Ministry of Environment (MOE) • Sector completed duties in the legislation
Cement sector • Submitted monitoring plans • Monitoring emissions • Verifying emissions reports
Cement Sector Capacity Building- Trainings/Exercise
Trainings organized by TCMA
• 2008/2009 –CSI methods- sector filled out CSI forms for CO2 budgeting
• 2013- Monitoring Plans
• 2013-Emissions Calculations
• 2016-2017-Emissions Calculations (EU Experience)
• 2017-Emissions Calculations/Uncertainty (German Experience)
• 2017- Uncertainty Calculations (Dec, 2017)
Trainings organized by GIZ & MOE
• 2014- Monitoring Plans – as per the new regulation
• 2015-Emissions Calculations– as per the new regulation
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Capacity Building efforts for more than 10 years for the sector specialists
Cement Sector Capacity Building-Pilot Projects
GIZ Capacity Building Project – 1 Pilot Plant
The World Bank Partnership for Market Readiness Project, Turkey- 5 Pilot Plants
Sectoral participation to ‘Lessons Learnt’ Seminars
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Application of the Turkish MRV Regulation
EU started MRV with Phase I and Phase II (2005-2012)- learning period
Members states had flexibility for scope of monitoring plans and reporting in Phase I and Phase II
Turkish MRV is adoption of EU Phase III regulation (EU 601/2012 –
Monitoring and Reporting Regulations)
• Detailed
• Covers missing points in Phase I and II
• Provides harmonization in the EU
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Application of the Turkish MRV Regulation
•Turkish Ministry of Environment and Urbanization-Great ambition& performance to accomplish the new system – continuous dialogue with private sector
•Capacity Building Projetcs of the MOE (Detailed GIZ supported trainings/guidelines on monitoring plans/ emission reports/verification was very helpful)
•Transition period of 3 years for using lowest tiers provided room for adaptation to beginners (2015-2016-2017)
•Monitoring plan software provided harmonization
• Difficult and time consuming ‘learning by doing’ period and expected to continue
• Sector was familiar with CSI methodology but (EU adopted) MRV rules were different- thus need to change emissions reporting methods
• Text too complicated and detailed for EU legislation beginners
• Turkish translation of the monitoring plan software should have been in parallel to issue of the regulation (Companies that do not have English speaking staff could not use the MP template on time)
• Authorization of verifiers and verifier companies were delayed.
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Challenges: Transition Period ends in 2018
By 2018, highest Tiers will be used (Tier 3 and Tier 4)
Detailed Uncertainty calculations
Revision of measurement devices may be required
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Tier Maximum uncertainty to report quantity of fuel (t or m3)
1 7,5%
2 5,0 %
3 2,5 %
4 1,5 %
Challenges: Transition Period ends in 2018
Frequent analyses for process and fuel emissions and waste fuels (fossil and biomass) Higher precision Additional workforce (sampling etc.) and costs Representativeness of the samples
Rough estimate for number of analyses required by 2018
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Frequency Total Consumption*
Number of Analyses
Carbonates each 50.000 tons (CaCO3, MgCO3)
104 million ton 2000 -4000 analyses/year
Solid fuels each 20.000 ton (for lots containing higher amount, analyses of each lot)
8 million ton 400 -800 analyses/year
Waste Fuels
0.6 million ton
150-450 analyses/year
* TCMA Data- 2016
Challenges and Recommendations Use of Non Accredited Laboratories
Legislation requires accredited laboratories for analyses. Laboratories non accredited (e.g. cement plant laboratories) are allowed if accredited labs are;
technically not feasible
that the non-accredited laboratory meets requirements equivalent to ISO standard for accreditation of analysis laboratories (EN ISO/IEC 17025)
Issue of a formal guideline/technical paper on equivalency procedure and conditions for technical unfeasibility will be helpful for the industry
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Challenges and Recommendations
Emissions monitoring and reporting is not the job of environmental staff only- it is an integrated job.
More accredited laboratories are required
Conflict of interest definitions should be more clear
Number of experienced verifiers and verifier companies expected to increase in forthcoming years
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Cement sector has been working seriously to fulfill its MRV requirements and support of the Ministry for capacity building has always been very important for the sector
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