FINAL JI DETERMINATION REPORT

Transcription

1 FINAL JI DETERMINATION REPORT GPN S.A. GPN GRAND QUEVILLY N8 N 2 O ABATEMENT PROJECT Report No: /265 Date: TÜV NORD CERT GmbH JI/CDM Certification Program Langemarckstraße, Essen, Germany Phone: Fax: S01-VA030-A1 Rev.1 /

2 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Date of first issue: Project No.: /265 Project type: Organisational unit: Client: JI Track 1 (Projet Domestique) JI Track 2 GPN S.A. TÜV NORD JI/CDM Certification Program Client ref.: Patrick Le Calvé Summary: positive determination opinion negative determination opinion GPN S.A. has commissioned the TÜV NORD JI/CDM Certification Program (CP) as a Third Party to determinate the project: GPN Qrand Quevilly N8 N 2O abatement with regard to the relevant requirements of the host country France and of the UNFCCC for JI project activities, as well as criteria for consistent project operations, monitoring and reporting. UNFCCC criteria refer to the Kyoto Protocol Article 6 criteria and the Guidelines for the implementation of Article 6 of the Kyoto Protocol as agreed in the Marrakech Accords. The review of the project design documentation and additional documents related to baseline and monitoring methodology have provided TÜV NORD JI/CDM CP with sufficient evidence to determinate the fulfilment of the stated criteria. Since the LoAs are pending, a final Determination Report can not be issued at this time. After provision and checking of the LoAs, TÜV-Nord will provide a Final Determination Report, Rev. 2. In detail the conclusions can be summarised as follows: - The project is in line with all relevant host country criteria (France) and all relevant UNFCCC requirements for JI. - The project additionality is sufficiently justified in the PDD, the monitoring plan is transparent and adequate. - The calculation of the project emission reductions is carried out in a transparent and conservative manner, so that the calculated emission reductions of 795,579 tco 2e are most likely to be achieved within the crediting period. The conclusions of this report show, that the project, as it was described in the project documentation, is in line with all criteria applicable for the determination PDD. Report No.: Subject Group: /265 Climate Protection Indexing terms Report title: GPN Grand Quevilly N8 N 2 O abatement project. Work carried out by: Mr. Rainer Winter Mr. Ulrich Walter Mr. Stefan Magenheim Mr. Khalid Doukkali Technical review by: Mr. Eric Krupp Final approval by: Mr. Eric Krupp Projet Domestique JI Track 1 Determination PDD No distribution without permission from the client or responsible organisational unit Limited distribution Date of this revision: Rev. No.: Number of pages: Unrestricted distribution Page 2 of 78

3 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Abbreviations AMS BAT BAU CA CAR CDM CH 4 CL CO 2 CO 2e CP DFP DRIRE DVM EB EIA ERU EU ETS FAR GHG IPCC JI JISC MEEDDAT N 2 O NCV PDD QC/QA UNFCCC VVM Automated Monitoring System Best available technology Business as usual Corrective Action Corrective Action Request Clean Development Mechanism Methane Clarification Request Carbon dioxide Carbon dioxide equivalent Certification Program Designated Focal Point Directions Régionales de l Industrie de la Recherche et de l Environnement Determination and Verification Manual /Draft) CDM Executive Board Environmental Impact Assessment Emission Reduction Unit European Union Emissions Trading Scheme Forward Action Request Greenhouse gas(es) Intergovernmental Panel on Climate Change Joint Implementation Joint Implementation Supervisory Committee Ministère de l Ecologie, de l Energie, du Développement durable et de la Mer, France Nitrous Oxide Net Calorific Value of Fuel Project Design Document Quality control/quality assurance United Nations Framework Convention on Climate Change Validation and Verification Manual Page 3 of 78

4 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Table of Contents Page 1 OBJECTIVE / SCOPE GHG PROJECT DESCRIPTION Project Characteristics Involved Parties and Project Participants Project Location Technical Project Description METHODOLOGY AND DETERMINATION PDD SEQUENCE Determination PDD Steps Contract review Appointment of team members and technical reviewers Consideration of Public Stakeholder Comments Determination PDD Protocol Review of Documents Follow-up Interviews Project comparison Resolution of Clarification and Corrective Action Requests Definition Draft Determination PDD Final Determination PDD Technical review Final approval DETERMINATION FINDINGS DETERMINATION ASSESSMENT SUMMARY General Description of the Project Activity Participation Contribution to Sustainable Development PDD Editorial Aspects Technology to be Employed Type of Project Project Baseline, Additionality and Monitoring Plan Application of the Methodology Project Boundary Baseline Identification Calculation of GHG Emission Reductions Additionality Determination Monitoring Methodology Monitoring Plan Project Management Planning Crediting Period...6 Page 4 of 78

5 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project Environmental Impacts Comments by Local Stakeholders DETERMINATION OPINION REFERENCES...6 ANNEX 1: DETERMINATION PROTOCOL...6 ANNEX 2: ASSESSMENT OF BASELINE IDENTIFICATION...6 ANNEX 3: ASSESSMENT OF FINANCIAL PARAMETERS...6 ANNEX 4: ASSESSMENT OF BARRIER ANALYSIS...6 ANNEX 5: OUTCOME OF THE GSCP...6 ANNEX 6: APPLICATION OF NON APPROVED METHODOLOGIES REQUIREMENTS CHECKLIST...6 Page 5 of 78

6 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. 1 OBJECTIVE / SCOPE GPN S.A. has commissioned the TÜV NORD JI/CDM Certification Program (CP) to carry out the determination of the project: GPN Grand Quevilly N8 N 2 O abatement with regard to the relevant requirements for JI project activities. The purpose of a determination is to have an independent third party assess of the project design. In particular, the project's baseline, the monitoring plan (MP), and the project s compliance with relevant host country and UNFCCC criteria are determinated in order to confirm that the project design as documented is sound and reasonable and meets the stated requirements and identified criteria. Determination is seen as necessary to provide assurance to stakeholders of the quality of the project and its intended generation of emission reduction units (ERUs). UNFCCC criteria refer to the Kyoto Protocol Article 6 criteria and the Guidelines for the implementation of Article 6 of the Kyoto Protocol as agreed in the Marrakech Accords with regard to Track 1 JI project activities. 2 GHG PROJECT DESCRIPTION 2.1 Project Characteristics Essential data of the project is presented in the following Table 2-1. Table 2-1: Project Characteristics Item Data Project title GPN Grand Quevilly N8 N 2 O Abatement Project Project size Large Scale Small Scale Project Scope (according to UNFCCC sectoral scope numbers for JI) 1 Energy Industries (renewable- /non-renewable sources) 2 Energy distribution 3 Energy demand 4 Manufacturing industries 5 Chemical industry 6 Construction 7 Transport 8 Mining/Mineral production 9 Metal production 10 Fugitive emissions from fuels (solid, oil and gas) Fugitive emissions from production and consumption of 11 halocarbons and hexafluoride Page 6 of 78

7 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Item Data 12 Solvents use 13 Waste handling and disposal 14 Land-use, land-use change and forestry 15 Agriculture Applied Methodology Track 1 Crediting period Start of crediting period Project specific methodology (Projet Domestique Methodology) 2.2 Involved Parties and Project Participants The following parties to the Kyoto Protocol and project participants are involved in this project activity (Table 2-2). Table 2-2: Project Parties and project participants Characteristic Party Project Participant Host party France GPN S.A. Other involved party/ies Germany N.serve Environmental Services GmbH 2.3 Project Location The details of the project location are given in table 2-3: Table 2-3: No. Host Country Region Project Location Project Location France North West (Haute Normandie), Département: Seine- Maritime, Commune : Le Grand Quevilly (near Rouen) Project location address 30, rue de l lindustrielle - BP Grand Quevilly Cadex Plant Coordinates Latitude: N Longitude: E 2.4 Technical Project Description The project involves the installation of a tertiary N 2 O reduction catalyst of the nitric acid production plant of GPN N8. The emission reductions are a result of the catalytic decomposition of nitrous oxide. Nitrous oxide which is formed as by-product of the nitric acid production will be removed by a tertiary catalyst installed in the same tail 1 As per the published PDD (version 2) Page 7 of 78

8 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. gas reactor as the separate De-NOX catalyst. The nitrous oxide would otherwise be emitted within the tail gas of the nitric acid plant to the atmosphere. The key parameters of the project are given in table 2-4: Table 2-4: Technical data of the project Parameter Unit Value Ammonia Oxidation Reactor Manufacturer - GPN S.A. Diameter mm 6000 Start of commercial production - July 2009 Operating conditions as per specifications (trip point values) - Temperature (min/max): C Pressure (min/max): MPa Ammonia to Air ratio (max) Vol.-% 11 Ammonia Oxidation Catalyst Manufacturer - Johnson Matthey Composition: - Pt/Rd/Pd Absorber Design capacity per day t/d (100 %) 1,500 Annual operation (design) days 350 Tertiary Catalyst Manufacturer - GPN S.A. Design efficiency N 2 O reduction % 95 Design efficiency NO x reduction % >80 Capacities of substituted plants Oissel t/a (metric) 297,500 N5 t/a (metric) 119,000 N6 t/a (metric) 119,000 N 2 O Analyzer (stack) Manufacturer - FT Fine Tech Type - ANAFIN 5000 ORBITAL AIT Measurement Principle - FTIR Stack volume flow rate measurement Manufacturer - Sick Maihak GmbH Type - FLOWSIC 100 Measurement Principle - Ultrasonic Page 8 of 78

9 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. 3 METHODOLOGY AND DETERMINATION PDD SEQUENCE 3.1 Determination PDD Steps The determination of the project consisted of the following steps: Contract review Appointment of team members and technical reviewers Publication of the project design document (PDD) A desk review of the PDD /PDD/ supporting documents Determination planning, On-Site assessment, submitted by the client and additional Background investigation and follow-up interviews with personnel of the project developer and its contractors, Draft determination reporting Resolution of corrective actions (if any) Final determination reporting Technical review Final approval of the determination. The sequence of the determination is given in the table 3.1 below: Table 3.1: Determination PDD sequence Topic Time Assignment of determination Submission of PDD for global stakeholder commenting process On-site visit to Draft reporting finalised Final reporting finalised - Technical review on final reporting finalised - Page 9 of 78

10 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. 3.2 Contract review To assure that the project falls within the scopes for which accreditation is held, the necessary competences to carry out the verification can be provided, Impartiality issues are clear and in line with the JI accreditation requirements a contract review was carried out before the contract was signed. 3.3 Appointment of team members and technical reviewers On the basis of a competence analysis and individual availabilities a determination team, consistent of one team leader and 4 additional team members, were appointed. Furthermore also the personnel for the technical review and the final approval were determined. The list of involved personnel, the tasks assigned and the qualification status are summarized in the table 3-2 below. Table 3-2: Involved Personnel Name Company Function 1) Qualification Status 2) Sectoral competence Technical competence Host country Competence Controlling competence Mr. Ms. R. Winter TÜV NORD CERT, Germany TL SA Mr. Ms. U. Walter TÜV NORD CERT, Germany TM TE Mr. Ms. S. Magenheim TÜV NORD Systems, Germany TM TE Mr. Ms. K. Doukkali TÜV NORD CERT, Germany TM TE Mr. Ms. E. Krupp TÜV NORD CERT, Germany TR, FA SA 1) TL : Team Leader; TM : Team Member, TR: Technical review; FA: Final approval 2) GHG Auditor Status: A : Assessor; E : Expert; SA: Senior Assessor; T : Trainee; TE Technical Expert Page 10 of 78

11 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. 3.4 Consideration of Public Stakeholder Comments The draft PDD, as received from the project participants, was made publicly available on TÜV NORD Website during a 30 days period from to In case comments were received, they are taken into account during the determination process. The comments and the discussion of the same are documented in annex 5 of this report. 3.5 Determination PDD Protocol In order to ensure consideration of all relevant assessment criteria, a determination protocol is used. The protocol shows, in a transparent manner, criteria and requirements, means of determination and the results from pre-determination the identified criteria. The determination protocol reflects the generic JI Track 1 requirements projects have to meet as well as project specific issues as applicable. The determination protocol serves the following purposes: - It organises, details and clarifies the requirements that a JI project is expected to meet; - It ensures a transparent determination PDD process where the independent entity will document how a particular requirement has been validated and the result of the determination. The determination protocol as described in Figure 1. Determination Protocol Table A-1: Requirement checklist Checklist Item Determination PDD Team Comment Reference Draft Conclusion Final Conclusion The checklist items in Table A-1 are linked to the various requirements the project should meet. The checklist is organised in various sections. Each section is then further subdivided as per the requirements of the topic and the individual project activity. The section is used to elaborate and discuss the checklist item in detail. It includes the assessment of the determination team and how the assessment was carried out. Gives reference to the information source on which the assessmen t is based on Assessment based on evidence provided if the criterion is fulfilled (OK), or a CAR, CL or FAR (see below) is raised. The assessment refers to the draft determination stage. In case a corrective action or a clarification the final assessment at the final determination stage is given. Figure 1: Determination protocol tables The completed determination protocol is enclosed in Annex 1 to this report. Page 11 of 78

12 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. 3.6 Review of Documents The published PDD (version 2) and supporting background documents related to the project design and baseline were reviewed. Furthermore, the determination team used additional documentation by third parties like host party legislation, technical reports referring to the project design or to the basic conditions and technical data. 3.7 Follow-up Interviews The determination team has carried out interviews in order to assess the information included in the project documentation and to gain additional information regarding the compliance of the project with the relevant criteria applicable for JI (Projet Domestique). During determination the determination team has performed interviews to confirm the provided information and to resolve issues identified in the document review. The main topics of the interviews are summarized in table 3-3. Table 3-3: Interviewed persons and interview topics Interviewed Persons / Entities Project proponent representatives (GPN) Project consultant (N.Serve) Maintenance staff of AMS (SPIE) Interview topics - Chronological description of the project activity with documents of key steps of the implementation. - Implementation status - Technical details of the project realization, project feasibility, designing, operational life time, monitoring of the project - Host Government Approval - Approval procedures and status - Monitoring and measurement equipment and system. - Financial aspects - Crediting period - Project activity starting date - ERU allocation / ownership - Baseline assumptions - Additionality - Monitoring - Roles & responsibilities of the project participants w.r.t. project management, monitoring and reporting - National Legislation - Editorial issues of the PDD A comprehensive list of all interviewed persons is part of section 7 References. Page 12 of 78

13 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. 3.8 Project comparison The determination team has compared the proposed JI project activity with similar projects or technology that have similar or comparable characteristics and with similar projects in order to achieve additional information esp. regarding: Project technology Additionality issues Reasons for reviews, requests for reviews and rejections within the JI registration process. 3.9 Resolution of Clarification and Corrective Action Requests Definition A Corrective Action Request (CAR) will be established where: mistakes have been made in assumptions, application of the methodology or the project documentation which will have a direct influence the project results, the requirements deemed relevant for determination of the project with certain characteristics have not been met or there is a risk that the project would not be registered by the UNFCCC or that emission reductions would not be able to be verified and certified. A Clarification Request (CL) will be issued where information is insufficient, unclear or not transparent enough to establish whether a requirement is met. A Forward Action Request (FAR) will be issued when certain issues related to project implementation should be reviewed during the first determination ERU Draft Determination PDD After reviewing all relevant documents and taken all other relevant information into account, the determination team issues all findings in the course of a draft determination report and hands this report over to the project proponent in order to respond on the issues raised and to revise the project documentation accordingly. Page 13 of 78

14 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project Final Determination PDD The final determination starts after issuance of the proposed corrective action (CA) of the CARs, CLs and FARs by the project proponent. The project proponent has to reply on those and the requests are closed out by the determination team in case the response is assessed as sufficient. In case of raised FARs, in which action from the project personnel is requested, the project proponent has to respond on this, identifying the necessary actions to ensure that the topics raised in this finding are likely to be resolved at the latest during the first verification. The determination team has to assess whether the proposed action is adequate or not. In case the findings from CARs and CLs cannot be resolved by the project proponent or the proposed action related to the FARs raised cannot be assessed as adequate, no positive determination opinion can be issued by the determination team. The CAR(s) / CL(s) / FAR(s) are documented in chapter Technical review Before submission of the final determination report a technical review of the whole determination procedure is carried out. The technical reviewer is a competent GHG auditor being appointed for the scope this project falls under. The technical reviewer is not considered to be part of the verification team and thus not involved in the decision making process up to the technical review. As a result of the technical review process the determination opinion and the topic specific assessments as prepared by the determination team leader may be confirmed or revised. Furthermore reporting improvements might be achieved Final approval After successful technical review of the final report an overall (esp. procedural) assessment of the complete determination will be carried out by a senior assessor located in the accredited premises of TÜV NORD. Only after this step the request for registration can be started (in case of a positive determination opinion). Page 14 of 78

15 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. 4 DETERMINATION FINDINGS In the following table the findings from the desk review of the published PDD, visits, interviews and supporting documents are summarised: Table 4-1: Summary of CARs, CLs and FARs issued Determination topic 1) No. of CAR No. of CL No. of FAR General description of project activity (A) - Project boundaries - Participation requirements - Technology to be employed - Contribution to sustainable development Project baseline (B) - Baseline Methodology - Baseline scenario determination - Additionality determination - Calculation of GHG emission reductions Project emissions Baseline emissions - Leakage Duration of the Project / Crediting Period (C) Monitoring Methodology (D) - Monitoring of Project emissions Baseline emissions Leakage Sustainable development indicators / environmental impacts Project management planning Estimation of greenhouse gas emission reductions (E) Environmental impacts (F) Stakeholder Comments (G) SUM The letters in brackets refer to the determination protocol Page 15 of 78

16 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. The following tables include all raised CARs, CLs and FARs. For an in depth evaluation of all determination items it should be referred to the determination protocols (see Annex 1). The findings of determination process are summarized in the tables below. Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the No letters of approval have been provided so far. context (e.g. section) Corrective Action #1 This section shall be filled by The LoA can only be obtained once a preliminary determination report is available. The French DFP requires a preliminary the PP. It shall address the corrective action taken in details. determination report to be submitted for processing the LoA issuance request. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox To be checked during the first periodic verification Appropriate action was taken A1 Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding It needs to be clarified that the nitric acid production capacity is Describe the finding in unambiguous style; address the 1500 t HNO 3 /d and the stated value of t reflects the 110 % context (e.g. section) value. Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. A2 An amendment has been made to the PDD now reflecting the nominal capacity of the plant being 1500 thno3 (100% conc.) per day (Section A.2, page 1); the resulting changes to annual production quantities were also made. OK. The PDD states clearly a capacity of production of HNO 3 of 1,500 t per day. Page 16 of 78

17 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Finding: Conclusion Tick the appropriate checkbox A2 To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the On page 43/44 the first column should be translated to English. context (e.g. section) Corrective Action #1 This section shall be filled by the PP. It shall address the corrective Has been amended in the PDD. action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox A3 OK. The first column was translated in English. To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the The coordinates of the plant location are missing in the PDD. context (e.g. section) Corrective Action #1 This section shall be filled by the PP. It shall address the corrective Coordinates have been added in section A action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. A4 OK. The coordinates are included in the corresponding section of the PDD Page 17 of 78

18 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Finding: Conclusion Tick the appropriate checkbox A4 To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding The information regarding the name of the organisation given in Describe the finding in unambiguous style; address the Annex 1 is not in line with A.3. The name given in A.3. is GPN S.A., context (e.g. section) in Annex 1 is GPN N8 Nitric acid plant (France) Corrective Action #1 This section shall be filled by A revised PDD was send per on the PP. It shall address the corrective action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox A5 OK. The name of the Organisation in Annex 1 is mentioned according the information given in Chapter A.3. To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the B.4. The discussion of the alternatives c) and d) is missing in chapter context (e.g. section) Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. B1 A discussion of these scenarios has been included in section B.4 (Step 1). Page 18 of 78

19 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Finding: DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox B1 OK. The discussion of the scenarios c) and d) are now included in the PDD. Both scenarios were discussed sufficiently. To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding The discussion of leakage is not completely in line with the Describe the finding in unambiguous style; address the methodology. Furthermore the additional pressure loss due to the context (e.g. section) increased amount of catalyst should be discussed in this section. Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox B2 Amendments have been made to sections B.5 (under the barrier analysis, technical barriers, footnote 29) and B.6.1; also reference to steam being exported to other plants on the site has been deleted, because surplus steam is used for energy production instead of being fed into other production processes directly. Also, it was clarified that the applied methodology does not require any further leakage assessment if the tail gas temperature level is below 170 C which is the case at the N8 plant (see chapter 9 of the methodology). Although the tail gas temperature would already suffice for justifying the omission of a leakage assessment, the project proponent has decided to additionally address the fact that a heat recovery system is installed, in order to further confirm that no leakage assessment is required. OK. After correcting the PDD, the discussion of leakage is in line with the methodology and it is clarified, that no leakage assessment is necessary. To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Page 19 of 78

20 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Finding: Classification CAR CL FAR Description of finding In the PDD it has to be clarified how it can be assured that no ERUs Describe the finding in unambiguous style; address the will be issued for emission levels which do not go beyond the business as usual scenario which is defined by the Arrete context (e.g. section) Prefectoral of (2,47kgN 2 O/tHNO 3 - within 12 months). Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox B3 This issue has now been addressed in the section Data processing in case of malfunction of the abatement system in section B.6.1 OK. It was clarified in the PDD, that in the case where a regulatory limit was set by local authorities, this limit replaces the benchmark emission factor determined by the French DFP. Furthermore it must be proven during the verification to the satisfaction of the responsible AIE that no ERUs will be claimed for emission levels that exceed the new regulatory limit, which in this case is 2.47kgN 2 O/tHNO 3, It must therefore be proven at each verification that the plant s average emission levels for the past year did not exceed this regulatory limit. To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the Correspondingly the ER calculation has to be revised. The capacity value for Oissel needs to be corrected. context (e.g. section) Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. B4 This has been amended in accordance with the findings obtained during the on-site determination visit, namely the Arrete Prefectoral dated 3 rd March The nominal daily capacity is 850 thno 3 (100% conc) per day; assuming 350 days of annual production this allows 297,500 thno 3 of production output per year. Amendments have been made to PDD sections A.4.3 and B.6.3 OK. The PDD was corrected according to the annual production value stated in the Arrete Prefectoral. Page 20 of 78

21 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Finding: Conclusion Tick the appropriate checkbox B4 To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Technical data as per the list provided during the on-site visit needs Describe the finding in unambiguous style; address the to be backed up by corresponding evidences. context (e.g. section) Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox B5 Technical data where provided per on OK. Sufficient technical information were provided by the PP to prove the technical specification and trip points. The date of plant starting up was proved by a starting up certificate of GPN and Chemoproject /SUCN8/. To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the The Investment Cost Sheet is still pending. context (e.g. section) Corrective Action #1 This section shall be filled by the PP. It shall address the corrective The Investment Cost Sheet was sent per on action taken in details. DOE Assessment #1 The assessment shall encompass OK The figures included in the Data Cost Sheet are assessed as all open issues in annex A- appropriate, conservative and realistic, the calculation is 1. In case of non-closure, additional corrective action and comprehensible. On a basis of an ERU price of 9 a return of DOE assessments (#2, #3, etc.) invest is given at shall be added. Since no benchmark is predefined (according to the methodology), a further assessment of the IRR is not required. B6 Page 21 of 78

22 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Finding: Conclusion Tick the appropriate checkbox B6 To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the the technical aspects of the project implementation. Apart form the procedural aspects section C.1. should also reflect context (e.g. section) Corrective Action #1 This section shall be filled by A clarifying sentence has been added to section C.1.1. the PP. It shall address the corrective action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox C1 OK. The start-up of the N8-plant with an installed catalyst is referenced in section C.1.1 To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Regarding the AMS it should be made clear in the PDD whether the Describe the finding in unambiguous style; address the EN will be followed completely or if other eligible standards, like AFNOR XP X43-305, which are in line with the methodological context (e.g. section) requirements will be applied for this project activity. Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. D1 Additional information has been added to section B.7.2, chapter 3 therein. Page 22 of 78

23 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Finding: DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox D1 OK. It was clarified, that, according to the methodology, a fully compliance with the DIN is not required by the methodology. If the AMS can not fulfil the requirements of the QAL 1, the suitability will be proved by an independent laboratory with EN ISO/IEC accreditation. To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the framework. The monitoring plan should include the monitoring of the regulatory context (e.g. section) Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox D2 An addition was made to section B.7.1 by means of parameter P.13. OK. The Parameter: Emissions cap for N 2 O from nitric acid production set by government/local regulation was added to the Table 11: Data and parameters measured during the project activity. To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding The AMS needs further improvements / clarifications before the Describe the finding in unambiguous style; address the start of the crediting period (e.g. Location of the sampling point, context (e.g. section) Test gas specifications, QAL1, QAL 2, uncertainty assessment). Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. D3 The project proponents will address these requirements before the first verification. Page 23 of 78

24 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Finding: DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox D3 OK. These issues need to be clarified before start of the crediting period by the Project Proponents. To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the explanation in the PDD esp. with regard to the calibration curve. The concept of instrument correction factors needs further context (e.g. section) Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. E1 This issue has now been discussed via telephone between the N.serve monitoring expert Martin Stilkenbaeumer and the TUEV NORD monitoring expert Stefan Magenheim. The discussion was resolved to the satisfaction of Mr Magenheim and a basic summary has been provided by our monitoring expert below. Most of this information is already included in the PDD, but please inform us if anything more specific is needed. As part of the quality assurance concept for the AMS in this project a 3 rd party calibration test is performed initially and repeated every 3 years. This calibration test will be performed as described in the European norm EN as QAL2. QAL2 is a procedure for the determination of the calibration function and its variability. The QAL2 tests are performed on suitable AMS that have been correctly installed and commissioned on-site. QAL 2 tests are to be performed at least every 3 years according to EN but also after major changes to the plant or changes or repairs to the AMS, which will influence the results obtained significantly. A calibration function is established from the results of a number of parallel measurements performed with a Standard Reference Method (SRM). The variability of the measured values obtained with the AMS is then evaluated against the required uncertainty. According to EN14181, both the QAL 2 procedures and the SRM need to be conducted by an independent testing house or Page 24 of 78

25 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Finding: E1 laboratory which has to be accredited to EN ISO/IEC DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox A series of QAL2 specific reference measurements using a the SRM method as per EN will be carried out at the plant by an accredited testing house to ensure the AMS suitability, establish the calibration curve and test the variability of the measurements. The results of these SRM are available to the AIE as part of the verification process. The AMS calibration function as well as the total uncertainty of the AMS will be determined. The results will be applied in the project. The resulting calibration function or correction factor will be applied to the resulting hourly average values for N2O concentration and for Stack gas flow prior to the final calculation of emission reductions. OK. It was confirmed, that the correction factors (derived from the calibration curve of the QAL2 audit for all components of the AMS), will be applied to both VSG (tail gas volume flow rate) and NCSG (mean concentration of N 2 O in tail gas) data. To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the methodology. The application of the 90 % issuance factor is not in line with the context (e.g. section) Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. E2 The 90% issuance factor has now been taken into account in the formula for ERU calculation in section B.6.1. Table 1 in section A.4.3, table 9 in section B.6.4 and table 2 in Annex 4 have also been adjusted accordingly. OK. The issurance factor was applied to the calculation of ERUs in the formular on page 26 of the PDD. Page 25 of 78

26 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. Finding: Conclusion Tick the appropriate checkbox E2 To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Finding: Classification CAR CL FAR Description of finding Describe the finding in unambiguous style; address the Nitric acid production substituted can be accounted for. In the formula on page 24 it should be made clear that only the context (e.g. section) Corrective Action #1 This section shall be filled by the PP. It shall address the corrective action taken in details. DOE Assessment #1 The assessment shall encompass all open issues in annex A- 1. In case of non-closure, additional corrective action and DOE assessments (#2, #3, etc.) shall be added. Conclusion Tick the appropriate checkbox E3 This has been taken into account by making an addition to the mentioned formula (section B.6.1). OK. The parameter NAP n` refers to the Substituted nitric acid production during the Verification Period (thno 3 ) To be checked during the first periodic verification Appropriate action was taken Project documentation was corrected correspondingly Additional action should be taken The project complies with the requirements Page 26 of 78

27 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project. 5 DETERMINATION ASSESSMENT SUMMARY The following paragraphs include the summary of the final determination assessments after all CARs and CRs are closed out. For details of the assessments pl. refer to the discussion of the validation findings in chapter 4 and the validation protocol (Annex 1). 5.1 General Description of the Project Activity Participation LOA The DFP of France will issue a LoA after submission of the Draft Determination Report. Hence the LoA is still outstanding. Project Participants The project participants are listed in section A.3 of the PDD and this information is consistent with the contact details provided in annex 1 of the PDD. No entities other than those approved or authorised to be project participants are listed or indicated in these sections of the PDD. For an in depth evaluation of these topics, please refer to section A.1 of the table A-1 of annex Contribution to Sustainable Development The contribution of the project activity to sustainable development of the host country has been confirmed by referencing the project activity in a specific Méthode pour les Projets Domestiques /mist/,/b-1/ for JI Track 1 projects, which refers directly to the applied tertiary N 2 O abatement technology. For an in depth evaluation of these topics, please refer to section A.2 and B.2 of the PDD. Page 27 of 78

28 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project PDD Editorial Aspects The PDD is in line with the structure and guidance specified in the decree set from March 2 nd 2007 issued by the Ministère de l écologie et du développement durable /B-5/. For an in depth evaluation of these topics, please refer to section A.3 of the table A-1 of the annex Technology to be Employed The description of the project as contained in the PDD is complete and accurate and it provides the reader with a clear understanding of the nature of the project activity. The technology and know-how used in the project activity is assessed to be environmentally safe and sound. For an in depth evaluation of these topics, please refer to section A.4 of the table A-1 of the annex 1 and chapter 2 of this validation report Type of Project The project qualifies as a Large Scale JI Track 1 Project, scope 5: Chemical Industry. The host country France fulfils the requirements for a Track 1 participation. 5.2 Project Baseline, Additionality and Monitoring Plan Application of the Methodology The project applies to a valid version of a French methodology for Projets Domestiques Catalytic reduction of N 2 O at nitric acid plants /B-2/, published by the Ministère de l Écologie, de l Énergie, du Développement durable et de la Mer (French Ministry of Ecology and Sustainable Development) /mist/. The project activity meets all applicability conditions of the applied methodology. Beyond this, the proposed project activity meets all the other possible requirements or stipulations mentioned in all sections of the selected methodology. Furthermore the project activity is not expected to result in significant emissions, related both to project and leakage, other than those listed in the methodology. Summarised it is assessed that the project applies a valid version of an approved methodology and the methodology is applicable to the project. For an in depth evaluation of these topics, please refer to section B.1 of the table A-1 of the annex 1. Page 28 of 78

29 Final Determination Report: GPN Grand Quevilly N8 N 2O abatement project Project Boundary The PDD correctly describes the project boundary including the physical delineation of the project activity (all parts of the Nitric Acid Plant N8) and the description of the emission sources and GHGs that are included in the project boundary for the purpose of calculating project and baseline emissions for this project activity. No emission sources which are impacted by the project activity but not addressed by the approved methodology have been identified during validation. For an in depth evaluation of these topics, please refer to section B.2 of the table A-1 of the annex Baseline Identification The PDD provides a transparent and verifiable description of the identified most plausible baseline scenario, including a description of the technology that would be employed and/or the activities that would take place in the absence of the proposed project activity. The procedure to identify the most plausible reference scenario derived from the methodology (para 3 of the methodology) has been applied correctly and is transparently and sufficiently documented in the PDD. The identification of possible alternatives of the project activity was carried out appropriately. Furthermore the PP has shown that all relevant policies and circumstances have been identified and correctly considered in the PDD in accordance with the guidance by the DFP. Summarised it can be assessed that the identified baseline scenario reasonably represents what would occur in the absence of the proposed project activity and the approved methodology used is applicable to the identified baseline scenario. For an in depth evaluation of these topics, please refer to the section B.3 of the Annex 1 as well as table A-2 of the Annex Calculation of GHG Emission Reductions The PDD applies steps and equations to calculate project emissions, baseline emissions, leakage and emission reductions as per the requirements of the methodology. For the calculation of the GHG emission reductions, the correct equations have been used reflecting the methodological choices. Furthermore all equations are applied correctly. Baseline Emissions: Page 29 of 78