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1 JI MONITORING REPORT Monitoring Report: Catalytic Reduction of N 2 O inside the Ammonia Burners of the Nitric Acid Plant in Puławy Monitoring Report #6 Version 2 Project Catalytic Reduction of N 2 O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland Plant Design Capacity 900,000 t HNO 3 per year Location (GPS) N, E Date / Version of Monitoring Report Monitoring Period (Cf. JI Guidance on overlapping monitoring periods (13 th Meeting Report, Annex 13), Underlying PDD 15 March 2013 / Version 2 Line Baseline 8 th Project Campaign 9 th Project Campaign L L / L L / All Version 2 from 24 July 2008, validated and approved, amended by Annex No. 4 Revision of PDD emission projections document, version 2, 05 September 2011 (valid as per amendment to LoA: 13 January 2012); Extended monitoring plan of the current JI Handbook, Version 9, 11 February ITL-ID and Date of LoA PL , 21 July 2009 / amendment to LoA from 13 January presented by: Zakłady Azotowe Puławy S.A. Al. Tysiąclecia Państwa Polskiego Puławy Poland

2 Real Emission Reductions [tco 2 equ], all in th Project Campaign, total 9 th Project Campaign, total L ,126 94,014 L212 / 176,437 L ,260 43,851 L ,751 / Total 600, ,302 Total of Claimed Emission Reductions as Reported per MR #6 for all four lines [tco 2 equ], all in ,588 The annual production volume in 2012 was beyond the plant design production capacity of 900,000 thno 3. Only up to this volume credits for emission reductions may be claimed. A conservative discounting of emission reductions was implemented, thereby reducing the claims for production below the 900kt threshold. The conservative treatment procedure is as follows: Non-consideration of NAP for crediting at the last campaign at lines with the highest delta between applicable baseline EF and project EF (thus also the highest claims for emission reductions). This campaign is P9 at line 213 ( =7.93 tco 2 e/thno 3 ; for calculation of the delta). As a simplified and conservative approach, all NAP of P9 at line 213 (17,822 thno 3 shall be excluded from crediting (thus for this campaign no credits shall be claimed at all). The NAP for which emission reductions in 2012 are claimed for amounts to 899,988 thno 3 (<900kt HNO 3 threshold). Total of Claimed Emission Reductions from MR#1 to MR#6 for 2009 to 2012 Measured values, PDD estimations and as per revised LoA [tco 2equ] in 2009 in 2010 in 2011 In 2012 MR #1 591,396 / / / MR #2 1,077, ,276 / / MR #3 105,446 1,350,771 3,640 / MR #4 / 177, ,094 / MR #5 / / 765, ,978 MR #6 / / / 870,588 Total 1,774,503 1,828,209 1,743,706 1,772,566 PDD estimation 1,562,400 1,562,400 1,562,400 1,562,400 Revised LoA est. - 2,102,137 2,102,137 2,102,137 Differences between calculated emission reductions and PDD estimates are attributable to (a) an inaccurate/underrated estimation of plant baseline emissions and (b) a substantially higher abatement rate (emission reduction efficiency could be improved by installation of a second oxidation stage). The revised and valid LoA takes both effects into consideration. 2

3 Content 1 Monitoring Report #6, Puławy, Line Documentation structure and reference General project and monitoring information Monitoring results... 7 Annex I Baseline Emission Factor Line Annex II Project campaigns Line Monitoring Report #6, Puławy, Line Monitoring Period Documentation structure and reference General project and monitoring information Monitoring results...13 Annex I Baseline Emission Factor Line Annex II Project campaign Line Monitoring Report #6, Puławy, Line Documentation structure and reference General project and monitoring information Monitoring results...19 Annex I Baseline Emission Factor Line Annex II Project campaigns Line Monitoring Report #6, Puławy, Line Documentation structure and reference General project and monitoring information Monitoring results...25 Annex I Baseline Emission Factor Line Annex II Project campaign Line Parameter and Instrumentation Data Version Control of Monitoring Plan

4 1 Monitoring Report #6, Puławy, Line 211 By reference to the comprehensive and up-to-date monitoring plan, the monitoring report can be structured as a concise document, thus improving the usability of the content and supporting the transparency of the monitoring. Project, Line Catalytic Reduction of N 2 O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, line 211 Date / Version of Monitoring Report Monitoring Period Underlying PDD ITL-ID and Date of LoA Emission Reductions [tco 2 equ] 11 February 2013 / Version 1 8th Campaign (P8) 9th Campaign (P9) 08 May Oct Oct Dec 2012 Version 2 from 24 July 2008, validated and approved, amended by Annex No. 4 Revision of PDD emission projections document, version 2, 05 September 2011 (valid as per amendment to LoA: 13 January 2012); Extended monitoring plan of the current JI Handbook, Version 9, 11 February PL , 21 July 2009 / amendment to LoA from 13 January P8 156,126 P9 94,014 presented by: Zakłady Azotowe Puławy S.A. Al. Tysiąclecia Państwa Polskiego Puławy Poland 4

5 1.1 Documentation structure and reference The purpose of this monitoring report is to provide relevant information about GHG emission reductions achieved during the defined monitoring period. The monitoring report thus contains values of all parameters which have to be controlled according to the PDD, the applied methodology AM0034 and the current monitoring plan (JI handbook). It describes the implementation of all monitoring steps, referring to the handbook (monitoring schedule and protocol), and provides a summary of the calculations of emission reductions. This report has been prepared for verification of emission reductions at line 211 of Puławy plant. As basic documentation for verification it refers to: Approved baseline and monitoring methodology AM0034: Catalytic reduction of N2O inside the ammonia burner of nitric acid plants, version 3, which is used in the PDD. Project design document to the project in its validated version: Catalytic Reduction of N2O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, version 2, 24 July 2008, validated and approved, amended by Annex No. 4 "Revision of PDD emission projections" document, version 2, 05 September 2011 (valid as per amendment to LoA: 13 January 2012). Final determination report: DETERMINATION OF THE JI-PROJECT: Catalytic Reduction of N2O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, REPORT NO , 24 July Monitoring plan as an up-to-date documentation to the monitoring procedures and their implementation: JI Handbook (latest version, see page 1). Data handling protocol (Pulawy protocol) where continuous monitoring of the plant operation is documented. Extracted Durag AMS data and project calculation tool where relevant calculations are presented in a transparent way. Calibration report according EN14181 for L211 from November Monitoring Reports #1-5 in verified versions. 5

6 1.2 General project and monitoring information Project background Title of project activity: Catalytic Reduction of N 2 O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland Status of implementation: Table 1 below illustrates the project implementation at line 211 as of December Activity Date Baseline measurement period 11 June 2008 until 19 November 2008 Onsite validation June 2008 Abatement technology implementation & 21 November 10 December 2008 installation of new oxidation gauzes Onsite initial verification October 2008 First project campaign (P1) 10 December May 2009 Onsite first verification October 2009 Second project campaign (P2) 12 May November 2009 Abatement technology implementation, 30 November 2009 second stage Third project campaign (P3) 30 November May 2010 Onsite second verification June 2010 Fourth project campaign (P4) 18 May November 2010 L211 shutdown 28 November 06 December 2010 Onsite third verification March 2011 Fifth project campaign (P5) 06 December May 2011 L211 shutdown May 2011 Onsite fourth verification December 2011 Sixth project campaign (P6) 17 May Nov 2011 L211 shutdown November 2011 Seventh project campaign (P7) 30 Nov May 2012 L211 shutdown May 2012 Eighth project campaign (P8) 08 May 22 October 2012 L211 shutdown October 2012 Onsite fifth verification October 2012 Ninth project campaign (P9) 24 October 31 December 2012 Table 1: Status of implementation Applied methodology and monitoring plan Calculation of emission reductions is being realized on basis of the latest JI Handbook which constitutes an extended and amended/up-dated version to the monitoring section of the PDD. Methodological basis to the monitoring plan is approved methodology AM0034 (version 3). Quality of monitoring equipment was ensured by applying EN Where required, equipment was calibrated according to relevant national standards. Manufacturer specific quality and maintenance requirements have been implemented. For details please refer to section 5 below. 6

7 1.3 Monitoring results This monitoring report for line 211 covers the eighths and ninth project campaign (P8/P9). Humidity measurements show that the off-gas is dry (as per thresholds defined in Tool to determine the mass flow of a greenhouse gas in a gaseous stream (version 01) ). Thus the basis of measurements of VTG 211 as well as NCTG 211 is dry Analysis of baseline period The baseline EF for P8 and P9 (project campaign shorter than campaign length normal) was calculated according to applicable procedures. Please note amendment 1 in section 6 (Version control of monitoring plan) below Analysis of project campaign All acquired project campaign data was reviewed on consistency and correctness by crosschecking with data from the SCADA system. This procedure was undertaken by the Nitric Acid Plant Technologist as defined in the monitoring plan. The results have been internally approved by the Nitric Acid Department Manager. The use of default values follows AM0034 stipulations and further conservative approaches. For the latter, section 9.5 of the JI Handbook describes the applied special procedures to account for lacking/faulty NAP values. Process data Monitored parameters NCTG 211 Nitrous oxide concentration in tail gas during project campaign (mgn 2 O/m³) VTG 211 Volume flow of tail gas during project campaign (m³/h) TTG 211 Temperature of tail gas during project campaign ( C) Pressure of tail gas during project campaign (Pa) PTG 211 Statistical data processing To eliminate mavericks from the VTG 211 and NCTG 211 samples, data sets have been statistically analysed along AM0034 procedures (elimination of the 2.5% highest and lowest VTG 211 and NCTG 211 values). Gauze information Information on the gauze supplier and the oxidation catalyst composition have been gathered and compared to the normal gauze composition and supplier. Documents show that there are no respective changes. Calculated Parameters PE n Emissions of project campaign EF n Emission factor of project campaign For AMS down-time intervals the highest measured emission factor of the campaign has been applied. 7

8 Moving average emission factor The moving average emission factor (EF ma ) is calculated for the project campaigns and compared to the actual project emission factor of a campaign (EF n ). The higher of the two values is applied for the calculation of the project emissions. The minimum project emission factor (EF min ) is not applicable before the tenth campaign (P10). An overview of the results from calculations is provided in the Annex II. Operating parameters quality assurance and quality control Measurements and recordings of OT 211 and AFR 211 were conducted in compliance with the monitoring plan Procedure to account for lacking/faulty NAP values Both in baseline and project data analysis a conservative approach to account for faulty or eventually lacking NAP values is applied. It is applied as a rule that whenever during project campaigns a NAP value is faulty or lacking, a default value is applied as its replacement. This default value corresponds to the minimum value derived by a 95% confidence interval evaluation of all hourly NAP values during that project campaign. This procedure is conservative as it guarantees the consideration of a low emission/nap ratio for baseline and a high ratio for project calculation. The statistical component is equivalent to the evaluation procedure that is routinely applied to VTG and NCTG evaluation. It takes account of the rather unstable measurement values, notably mavericks Emission reductions Emissions reductions have been calculated as per methodology. For results see Annex II. No N 2 O emission legislation applying to nitric acid plants (EF reg ) has been introduced during baseline or project campaign. Thus the baseline is valid. 8

9 Annex I Baseline Emission Factor Line 211 Normal Campaign Length (CL n ): 108,162 thno 3 (see PDD). Campaign EF BL [kgn 2 O/tHNO 3 ] For P For P Comment Table AI.1: Applicable Baseline Emission Factors Baseline EF for P8 (shorter campaign length). See attached Excel file (Py_211_P8_BL_v1.xls), based on verified baseline tool from first verification (Py_211_P1_BLn_Verif1.xls). Baseline EF for P9 (shorter campaign length). See attached Excel file (Py_211_P9_BL_v1.xls), based on verified baseline tool from first verification Py_211_P1_BLn_Verif1.xls). Annex II Project campaigns Line 211 See attached Excel file (Py_211_P8_v1.xls; Py_211_P9_v2.xls). Campaign P8 P9 Period (Project campaign as presented for crediting, last day of crediting is 31 Dec. 2012) : : : :00 NAP 211 (t HNO 3 ) OH 211 (hours) Table AII.1: Key parameters of monitoring periods OH 211 where AMS was down (hours) EF default (highest value during campaign) (kg N 2 O/HNO 3 ) 100,306 3, ,800 1, Campaign Campaign Specific Emission Factor (EF n ) Moving Average Emission Factor (EF ma ) Final Project Emission Factor (EF p ) P P Table AII.2: Comparison between campaign specific EF and moving average EF Campaign Project Emissions (tn 2 O) Emission Reduction (tn 2 O) Emission Reduction (tco 2 e) P ,126 P ,014 Table AII.3: Project Emissions, Emission Reduction Date P8, :00/18:00 P9, general P9, :00 Table AII.4: Special events Special Events Strong recirculation of nitric acid in the absorption trains leads to substantially lower NAP production during these hours. As calculation of hourly EF on basis of these small NAP values is not representative, for these two hours the conservative default NAP has been used. Repairs of the damaged sealing in the secondary catalyst basket (causing N 2O bypassing the secondary catalyst) before start-up of the campaign result in a decrease of N 2O concentration, thereby re-establishing the high N 2O abatement rate that existed prior to the bypass situation. This is the main reason for the comparatively low project emissions during this campaign. Due to AST temperature measurement is not representative. From this there is also an indirect effect on VTG that is not conservative. The VTG value is thus also not representative and accordingly deleted from data integration. Furthermore the downtime EF is set. 9

10 2 Monitoring Report #6, Puławy, Line 212 By reference to the comprehensive and up-to-date monitoring plan, the monitoring report can be structured as a concise document, thus improving the usability of the content and supporting the transparency of the monitoring. Project, Line Catalytic Reduction of N 2 O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, line 212 Date / Version of Monitoring Report 11 February 2013 / Version 1 Monitoring Period 9 th Campaign (P9) 05 Sept Dec 2012 Underlying PDD ITL-ID and Date of LoA Version 2 from 24 July 2008, validated and approved, amended by Annex No. 4 Revision of PDD emission projections document, version 2, 05 September 2011 (valid as per amendment to LoA: 13 January 2012); Extended monitoring plan of the current JI Handbook, Version 9, 11 February PL , 21 July 2009 / amendment to LoA from 13 January Emission Reductions [tco 2 equ] P9 176,437 presented by: Zakłady Azotowe Puławy S.A. Al. Tysiąclecia Państwa Polskiego Puławy Poland 10

11 2.1 Documentation structure and reference The purpose of this monitoring report is to provide relevant information about GHG emission reductions achieved during the defined monitoring period. The monitoring report thus contains values of all parameters which have to be controlled according to the PDD, the applied methodology AM0034 and the current monitoring plan (JI handbook). It describes the implementation of all monitoring steps, referring to the handbook (monitoring schedule and protocol), and provides a summary of the calculations of emission reductions. This report has been prepared for verification of emission reductions at line 212 of Puławy plant. As basic documentation for verification it refers to: Approved baseline and monitoring methodology AM0034: Catalytic reduction of N2O inside the ammonia burner of nitric acid plants, version 3, which is used in the PDD. Project design document to the project in its validated version: Catalytic Reduction of N2O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, version 2, 24 July 2008, validated and approved, amended by Annex No. 4 Revision of PDD emission projections document, version 2, 05 September 2011 (valid as per amendment to LoA: 13 January 2012). Final Determination report: DETERMINATION OF THE JI-PROJECT: Catalytic Reduction of N2O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, REPORT NO , 24 July Monitoring plan as an up-to-date documentation to the monitoring procedures and their implementation: JI Handbook (latest version, see page 1). Data handling protocol (Pulawy protocol) where continuous monitoring of the plant operation is documented. Extracted Durag AMS data and project calculation tool where relevant calculations are presented in a transparent way. Calibration Report according EN14181 for L212 from November Monitoring Reports #1-5 in verified versions. 11

12 2.2 General project and monitoring information Project background Title of project activity: Catalytic Reduction of N 2 O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland Status of implementation: Table 1 below illustrates the project implementation at line 212 as of December Activity Date Baseline measurement period 24 April October 2008 Onsite validation June 2008 Abatement technology implementation & November 2008 installation of new oxidation gauzes Onsite initial verification October 2008 First project campaign (P1) 25 November April 2009 Onsite first verification October 2009 Second project campaign (P2) 29 April October 2009 Third project campaign (P3) 03 November March 2010 Abatement technology implementation, 14 December 2009 second stage Onsite second verification June 2010 Fourth project campaign (P4) 08 April October 2010 L212 shutdown October 2010 Onsite third verification March 2011 Fifth project campaign (P5) 12 October March 2011 L212 shutdown March 2011 Sixth project campaign (P6) 30 March October 2011 L212 shutdown October 2011 Onsite fourth verification December 2011 Seventh project campaign (P7) 05 October March 2012 L212 shutdown March 2012 Eighth project campaign (P8) 13 March 01 September 2012 L212 shutdown September 2012 Ninth project campaign (P9) 05 September 31 December 2012 Onsite fifth verification October 2012 Table 1: Status of implementation Applied methodology and monitoring plan Calculation of emission reductions is being realized on basis of the latest JI Handbook which constitutes an extended and amended/up-dated version to the monitoring section of the PDD. Methodological basis to the monitoring plan is approved methodology AM0034 (version 3). Quality of monitoring equipment was ensured by applying EN Where required, equipment was calibrated according to relevant national standards. Manufacturer specific quality and maintenance requirements have been implemented. For details please refer to section 5 below. 12

13 2.3 Monitoring results This monitoring report for line 212 covers the ninth project campaign (P9). Humidity measurements show that the off-gas is dry (as per thresholds defined in Tool to determine the mass flow of a greenhouse gas in a gaseous stream (version 01) ). Thus the basis of measurements of VTG 212 as well as NCTG 212 is dry Analysis of baseline period The baseline EF for P9 (project campaign shorter than campaign length normal) was calculated according to applicable procedures. Please note amendment 1 in section 6 (Version control of monitoring plan) below Analysis of project campaign All acquired project campaign data was reviewed on consistency and correctness by crosschecking with data from the SCADA system. This procedure was undertaken by the Nitric Acid Plant Technologist as defined in the monitoring plan. The results have been internally approved by the Nitric Acid Department Manager. The use of default values follows AM0034 stipulations and further conservative approaches. For the latter, section 9.5 of the JI Handbook describes the applied special procedures to account for lacking/faulty NAP values. Process data Monitored parameters NCTG 212 Nitrous oxide concentration in tail gas during project campaign (mgn 2 O/m³) VTG 212 Volume flow of tail gas during project campaign (m³/h) TTG 212 Temperature of tail gas during project campaign ( C) Pressure of tail gas during project campaign (Pa) PTG 212 Statistical data processing To eliminate mavericks from the VTG 212 and NCTG 212 samples, data sets have been statistically analysed along AM0034 procedures (elimination of the 2.5% highest and lowest VTG 212 and NCTG 212 values). Gauze information Information on the gauze supplier and the oxidation catalyst composition have been gathered and compared to the normal gauze composition and supplier. Documents show that there are no respective changes. Calculated Parameters PE n Emissions of project campaign EF n Emission factor of project campaign For AMS down-time intervals the highest measured emission factor of the campaign has been applied. 13

14 Moving average emission factor The moving average emission factor (EF ma ) is calculated for the project campaigns and compared to the actual project emission factor of a campaign (EF n ). The higher of the two values is applied for the calculation of the project emissions. The minimum project emission factor (EF min ) is not applicable before the tenth campaign (P10). An overview of the results from calculations is provided in the Annex II. Operating parameters quality assurance and quality control Measurements and recordings of OT 212 and AFR 212 were conducted in compliance with the monitoring plan Procedure to account for lacking/faulty NAP values Both in baseline and project data analysis a conservative approach to account for faulty or eventually lacking NAP values is applied. It is applied as a rule that whenever during project campaigns a NAP value is faulty or lacking, a default value is applied as its replacement. This default value corresponds to the minimum value derived by a 95% confidence interval evaluation of all hourly NAP values during that project campaign. This procedure is conservative as it guarantees the consideration of a low emission/nap ratio for baseline and a high ratio for project calculation. The statistical component is equivalent to the evaluation procedure that is routinely applied to VTG and NCTG evaluation. It takes account of the rather unstable measurement values, notably mavericks Emission reductions Emissions reductions have been calculated as per methodology. For results see Annex II. No N 2 O emission legislation applying to nitric acid plants (EF reg ) has been introduced during baseline or project campaign. Thus the baseline is valid. 14

15 Annex I Baseline Emission Factor Line 212 Normal Campaign Length (CL n ): 100,180 thno 3 (see PDD). Campaign EF BL [kgn 2 O/tHNO 3 ] For P Comment Table AI.1: Applicable Baseline Emission Factors Baseline EF for P9 (shorter campaign length). See attached Excel file (Py_212_P9_BL_v2.xls), based on verified baseline tool from first verification (Py_212_P1_BLn_Verif1.xls). Annex II Project campaign Line 212 See attached Excel file (Py_212_P9_v2.xls). Campaign P9 Period (Project campaign as presented for crediting, last day of crediting is 31 Dec. 2012) : :00 NAP 212 (t HNO 3 ) OH 212 (hours) Table AII.1: Key parameters of monitoring period OH 212 where AMS was down (hours) EF default (highest value during campaign) (kg N 2 O/HNO 3 ) 81,343 2, Campaign Campaign Specific Emission Factor (EF n ) Moving Average Emission Factor (EF ma ) Final Project Emission Factor (EF p ) P Table AII.2: Comparison between campaign specific EF and moving average EF Campaign Project Emissions (tn 2 O) Emission Reduction (tn 2 O) Emission Reduction (tco 2 e) P ,437 Table AII.3: Project Emissions, Emission Reduction Date P9, :00 P9, :00 Table AII.4: Special events Special Events For one hour the DURAG system records out of operation while in fact the hour was an operating hour. Operating data from DCS that is available proves this. For conservative treatment in the calculation tool, the hour is treated as a downtime hour. Thus the downtime EF applies. To account for the hourly production the conservative default value is set. Due to AST temperature measurement is not representative. From this there is also an indirect effect on VTG that is not conservative. The VTG value is thus also not representative and accordingly deleted from data integration. Furthermore the downtime EF is set. 15

16 3 Monitoring Report #6, Puławy, Line 213 By reference to the comprehensive and up-to-date monitoring plan, the monitoring report can be structured as a concise document, thus improving the usability of the content and supporting the transparency of the monitoring. Project, Line Catalytic Reduction of N 2 O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, line 213 Date / Version of Monitoring Report Monitoring Period Underlying PDD ITL-ID and Date of LoA Emission Reductions [tco2equ] 11 February 2013 / Version 1 8 th 13 Jun 2012 Campaign (P8) 02 Dec th 05 Dec 2012 Campaign (P9) 31 Dec 2012 Version 2 from 24 July 2008, validated and approved, amended by Annex No. 4 Revision of PDD emission projections document, version 2, 05 September 2011 (valid as per amendment to LoA: 13 January 2012); Extended monitoring plan of the current JI Handbook, Version 9, 11 February PL , 21 July 2009 / amendment to LoA from 13 January P8 251,260 P9 43,851 presented by: Zakłady Azotowe Puławy S.A. Al. Tysiąclecia Państwa Polskiego Puławy Poland 16

17 3.1 Documentation structure and reference The purpose of this monitoring report is to provide relevant information about GHG emission reductions achieved during the defined monitoring period. The monitoring report thus contains values of all parameters which have to be controlled according to the PDD, the applied methodology AM0034 and the current monitoring plan (JI handbook). It describes the implementation of all monitoring steps, referring to the handbook (monitoring schedule and protocol), and provides a summary of the calculations of emission reductions. This report has been prepared for verification of emission reductions at line 213 of Puławy plant. As basic documentation for verification it refers to: Approved baseline and monitoring methodology AM0034: Catalytic reduction of N2O inside the ammonia burner of nitric acid plants, version 3, which is used in the PDD. Project design document to the project in its validated version: Catalytic Reduction of N2O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, version 2, 24 July 2008, validated and approved, amended by Annex No. 4 Revision of PDD emission projections document, version 2, 05 September 2011 (valid as per amendment to LoA: 13 January 2012). Final Determination report: DETERMINATION OF THE JI-PROJECT: Catalytic Reduction of N2O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, REPORT NO , 24 July Monitoring plan as an up-to-date documentation to the monitoring procedures and their implementation: JI Handbook (latest version, see page 1). Data handling protocol (Pulawy protocol) where continuous monitoring of the plant operation is documented. Extracted Durag AMS data and project calculation tool where relevant calculations are presented in a transparent way. Calibration Report according EN14181 for L213 from November Monitoring Reports #1-5 in verified versions. 17

18 3.2 General project and monitoring information Project background Title of project activity: Catalytic Reduction of N 2 O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland Status of implementation: Table 1 below illustrates the project implementation at line 213 as of December Activity Date Baseline measurement period 22 April December 2008 Onsite validation June 2008 Abatement technology implementation & 14 December January 2009 installation of new oxidation gauzes Onsite initial verification October 2008 First project campaign (P1) 28 January March 2009 Onsite first verification October 2009 Second project campaign (P2) 18 March September 2009 Third project campaign (P3) 05 November May 2010 Abatement technology implementation, 10 January 2010 second stage Onsite second verification June 2010 Fourth project campaign (P4) 26 May December 2010 L213 shutdown December 2010 Onsite third verification March 2011 Fifth project campaign (P5) 07 December May 2011 L213 shutdown May 2011 Onsite fourth verification December 2011 Sixth project campaign (P6) 26 May December 2011 L213 shutdown December 2011 Seventh project campaign (P7) 27 December May 2012 L213 shutdown 28 May June 2012 Eighth project campaign (P8) 13 June December 2012 Onsite fifth verification October 2012 L213 shutdown December 2012 Ninth project campaign (P9) December 2012 Table 1: Status of implementation Applied methodology and monitoring plan Calculation of emission reductions is being realized on basis of the latest JI Handbook which constitutes an extended and amended/up-dated version to the monitoring section of the PDD. Methodological basis to the monitoring plan is approved methodology AM0034 (version 3). Quality of monitoring equipment was ensured by applying EN Where required, equipment was calibrated according to relevant national standards. Manufacturer specific quality and maintenance requirements have been implemented. For details please refer to section 5 below. 18

19 3.3 Monitoring results The monitoring report at hand covers the eighth and ninth project campaigns of line 213 (P8/P9). Humidity measurements show that the off-gas is dry (as per thresholds defined in Tool to determine the mass flow of a greenhouse gas in a gaseous stream (version 01) ). Thus the basis of measurements of VTG 213 as well as NCTG 213 is dry Analysis of baseline period The baseline EF for P8 and P9 (project campaign shorter than campaign length normal) was calculated according to applicable procedures. Please note amendment 1 in section 6 (Version control of monitoring plan) below Analysis of project campaigns All acquired project campaign data was reviewed on consistency and correctness by crosschecking with data from the SCADA system. This procedure was undertaken by the Nitric Acid Plant Technologist as defined in the monitoring plan. The results have been internally approved by the Nitric Acid Department Manager. The use of default values follows AM0034 stipulations and further conservative approaches. For the latter, section 9.5 of the JI Handbook describes the applied special procedures to account for lacking/faulty NAP values. Process data Monitored parameters NCTG 213 Nitrous oxide concentration in tail gas during project campaign (mgn 2 O/m³) VTG 213 Volume flow of tail gas during project campaign (m³/h) TTG 213 Temperature of tail gas during project campaign ( C) Pressure of tail gas during project campaign (Pa) PTG 213 Statistical data processing To eliminate mavericks from the VTG 213 and NCTG 213 samples, data sets have been statistically analysed along AM0034 procedures (elimination of the 2.5% highest and lowest VTG 213 and NCTG 213 values). Gauze information Information on the gauze supplier and the oxidation catalyst composition have been gathered and compared to the normal gauze composition and supplier. Documents show that there are no respective changes. Calculated Parameters PE n Emissions of project campaign EF n Emission factor of project campaign For AMS down-time intervals the highest measured emission factor of the campaign has been applied. 19

20 Moving average emission factor The moving average emission factor (EF ma ) is calculated for the project campaigns and compared to the actual project emission factor of a campaign (EF n ). The higher of the two values is applied for the calculation of the project emissions. The minimum project emission factor (EF min ) is not applicable before the tenth campaign (P10). An overview of the results from calculations is provided in the Annex II. Operating parameters quality assurance and quality control Measurements and recordings of OT 213 and AFR 213 were conducted in compliance with the monitoring plan Procedure to account for lacking/faulty NAP values Both in baseline and project data analysis a conservative approach to account for faulty or eventually lacking NAP values is applied. It is applied as a rule that whenever during project campaigns a NAP value is faulty or lacking, a default value is applied as its replacement. This default value corresponds to the minimum value derived by a 95% confidence interval evaluation of all hourly NAP values during that project campaign. This procedure is conservative as it guarantees the consideration of a low emission/nap ratio for baseline and a high ratio for project calculation. The statistical component is equivalent to the evaluation procedure that is routinely applied to VTG and NCTG evaluation. It takes account of the rather unstable measurement values, notably mavericks Emission reductions Emissions reductions have been calculated as per methodology. For results see Annex II. No N 2 O emission legislation applying to nitric acid plants (EF reg ) has been introduced during baseline or project campaign. Thus the baseline is valid. 20

21 Annex I Baseline Emission Factor Line 213 Normal Campaign Length (CL n ): 106,435 thno 3 (see PDD). EF BL [kgn 2 O/tHNO 3 ] For P For P Comment Baseline EF for P8 (shorter campaign length). See attached Excel file (Py_213_P8_BL_v1.xls), based on verified baseline tool from third verification (Py_213_P3_BLn_Verif3.xls). Baseline EF for P9 (shorter campaign length). See attached Excel file (Py_213_P9_BL_v1.xls), based on verified baseline tool from third verification (Py_213_P3_BLn_Verif3.xls). Table AI.1: Applicable Baseline Emission Factor Annex II Project campaigns Line 213 See attached Excel files (Py_213_P8_v2.xls; Py_213_P9_v2.xls). Campaign P8 P9 Period (Project campaign as presented for crediting, last day of crediting is 31 Dec. 2012) : : : :00 NAP 213 (t HNO 3 ) OH 213 (hours) Table AII.1: Key parameters of monitoring period OH 213 where AMS was down (hours) EF default (highest value during campaign) (kg N 2 O/HNO 3 ) 104,240 3, , Campaign Campaign Specific Emission Factor (EF n ) Moving Average Emission Factor (EF ma ) Final Project Emission Factor (EF p ) P P Table AII.2: Comparison between campaign specific EF and moving average EF Campaign Project Emissions (tn 2 O) Emission Reduction (tn 2 O) Emission Reduction (tco 2 e) P ,260 P9* ,851 Table AII.3: Project Emissions, Emission Reduction (*) For emission reductions from P9 no claims are made. On this see also discussion on page 2 of this report Date P8, :00 03:00 P8, :00 Table AII.4: Special events Special Events Shut down of NAP pump leads to indication of fault for production in DURAG (negative values may lead to fault indication). During these hours, the production volume was recirculated to the absorption columns. After the incident the production volume is increased. For calculation of hourly EF during the incident the conservative default NAP has been used. Due to AST temperature measurement is not representative. From this there is also an indirect effect on VTG that is not conservative. The VTG value is thus also not representative and accordingly deleted from data integration. Furthermore the downtime EF is set. 21

22 4 Monitoring Report #6, Puławy, Line 214 By reference to the comprehensive and up-to-date monitoring plan, the monitoring report can be structured as a concise document, thus improving the usability of the content and supporting the transparency of the monitoring. Project, Line Catalytic Reduction of N 2 O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, line 214 Date / Version of Monitoring Report Monitoring Period Underlying PDD ITL-ID and Date of LoA 11 February 2013 / Version 1 8 th Campaign (P8) 14 Aug Dec 2012 Version 2 from 24 July 2008, validated and approved, amended by Annex No. 4 Revision of PDD emission projections document, version 2, 05 September 2011 (valid as per amendment to LoA: 13 January 2012); Extended monitoring plan of the current JI Handbook, Version 9, 11 February PL , 21 July 2009 / amendment to LoA from 13 January Emission Reductions [tco2equ] P8 192,751 presented by: Zakłady Azotowe Puławy S.A. Al. Tysiąclecia Państwa Polskiego Puławy Poland 22

23 4.1 Documentation structure and reference The purpose of this monitoring report is to provide relevant information about GHG emission reductions achieved during the defined monitoring period. The monitoring report thus contains values of all parameters which have to be controlled according to the PDD, the applied methodology AM0034 and the current monitoring plan (JI handbook). It describes the implementation of all monitoring steps, referring to the handbook (monitoring schedule and protocol), and provides a summary of the calculations of emission reductions. This report has been prepared for sixth verification of emission reductions at line 214 of Puławy plant. As basic documentation for verification it refers to: Approved baseline and monitoring methodology AM0034: Catalytic reduction of N2O inside the ammonia burner of nitric acid plants, version 3, which is used in the PDD. Project design document to the project in its validated version: Catalytic Reduction of N2O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, version 2, 24 July 2008, validated and approved, amended by Annex No. 4 Revision of PDD emission projections document, version 2, 05 September 2011 (valid as per amendment to LoA: 13 January 2012).. Final Determination report: DETERMINATION OF THE JI-PROJECT: Catalytic Reduction of N2O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland, REPORT NO , 24 July Monitoring plan as an up-to-date documentation to the monitoring procedures and their implementation: JI Handbook (latest version, see page 1). Data handling protocol (Pulawy protocol) where continuous monitoring of the plant operation is documented. Extracted Durag AMS data and project calculation tool where relevant calculations are presented in a transparent way. Calibration Report according EN14181 for L214 from November Monitoring Reports #1-5 in verified versions. 23

24 4.2 General project and monitoring information Project background Title of project activity: Catalytic Reduction of N 2 O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland Status of implementation: Table 1 below illustrates the project implementation at line 214 as of December Activity Date Baseline measurement period 22 April December 2008 Onsite validation June 2008 Abatement technology implementation & 09 December January 2009 installation of new oxidation gauzes Onsite initial verification October 2008 First project campaign (P1) 21 January 14 April 2009 Onsite first verification October 2009 Second project campaign (P2) 09 April December 2009 Abatement technology implementation, 09 December 2009 second stage Third project campaign (P3) 13 December June 2010 Onsite second verification 9 10 June 2010 Fourth project campaign (P4) 14 July January 2011 L214 shutdown January 2011 Onsite third verification March 2011 Fifth project campaign (P5) 05 January June 2011 L214 shutdown June 2011 Sixth project campaign (P6) 20 June February 2012 L214 shutdown February 2012 Seventh project campaign (P7) 08 February July 2012 L214 shutdown 31 July August 2012 Eighth project campaign (P8) 14 August December 2012 Onsite fifth verification October 2012 Table 1: Status of implementation Applied methodology and monitoring plan Calculation of emission reductions is being realized on basis of the latest JI Handbook which constitutes an extended and amended/up-dated version to the monitoring section of the PDD. Methodological basis to the monitoring plan is approved methodology AM0034 (version 3). Quality of monitoring equipment was ensured by applying EN Where required, equipment was calibrated according to relevant national standards. Manufacturer specific quality and maintenance requirements have been implemented. For details please refer to section 5 below. 24

25 4.3 Monitoring results This monitoring report for line 214 covers the eighth project campaign (P8). Humidity measurements show that the off-gas is dry (as per thresholds defined in Tool to determine the mass flow of a greenhouse gas in a gaseous stream (version 01) ). Thus the basis of measurements of VTG 214 as well as NCTG 214 is dry Analysis of baseline period The baseline EF for P8 (project campaign shorter than campaign length normal) was calculated according to applicable procedures. Please note amendment 1 in section 6 (Version control of monitoring plan) below Analysis of project campaigns All acquired project campaign data was reviewed on consistency and correctness by crosschecking with data from the SCADA system. This procedure was undertaken by the Nitric Acid Plant Technologist as defined in the monitoring plan. The results have been internally approved by the Nitric Acid Department Manager. The use of default values follows AM0034 stipulations and further conservative approaches. For the latter, section 9.5 of the JI Handbook describes the applied special procedures to account for lacking/faulty NAP values. Process data Monitored parameters NCTG 214 Nitrous oxide concentration in tail gas during project campaign (mgn 2 O/m³) VTG 214 Volume flow of tail gas during project campaign (m³/h) TTG 214 Temperature of tail gas during project campaign ( C) Pressure of tail gas during project campaign (Pa) PTG 214 Statistical data processing To eliminate mavericks from the VTG 214 and NCTG 214 samples, data sets have been statistically analysed along AM0034 procedures (elimination of the 2.5% highest and lowest VTG 214 and NCTG 214 values). Gauze information Information on the gauze supplier and the oxidation catalyst composition have been gathered and compared to the normal gauze composition and supplier. Documents show that there are no respective changes. Calculated Parameters PE n Emissions of project campaign EF n Emission factor of project campaign For AMS down-time intervals the highest measured emission factor of the campaign has been applied. 25

26 Moving average emission factor The moving average emission factor (EF ma ) is calculated for the project campaigns and compared to the actual project emission factor of a campaign (EF n ). The higher of the two values is applied for the calculation of the project emissions. The minimum project emission factor (EF min ) is not applicable before the tenth campaign (P10). An overview of the results from calculations is provided in the Annex II. Operating parameters quality assurance and quality control Measurements and recordings of OT 214 and AFR 214 were conducted in compliance with the monitoring plan Procedure to account for lacking/faulty NAP values Both in baseline and project data analysis a conservative approach to account for faulty or eventually lacking NAP values is applied. It is applied as a rule that whenever during project campaigns a NAP value is faulty or lacking, a default value is applied as its replacement. This default value corresponds to the minimum value derived by a 95% confidence interval evaluation of all hourly NAP values during that project campaign. This procedure is conservative as it guarantees the consideration of a low emission/nap ratio for baseline and a high ratio for project calculation. The statistical component is equivalent to the evaluation procedure that is routinely applied to VTG and NCTG evaluation. It takes account of the rather unstable measurement values, notably mavericks Emission reductions Emissions reductions have been calculated as per methodology. For results see Annex II. No N 2 O emission legislation applying to nitric acid plants (EF reg ) has been introduced during baseline or project campaign. Thus the baseline is valid. 26

27 Annex I Baseline Emission Factor Line 214 Normal Campaign Length (CL n ): 107,923 thno 3 (see PDD). Campaign EF BL [kgn 2 O/tHNO 3 ] Comment For P Table AI.1: Applicable Baseline Emission Factor Baseline EF for P8 (shorter campaign length). See attached Excel file (Py_214_P8_BL_v2.xls), based on verified baseline tool from fifth verification (Py_214_P6_BLn_Verif5.xls). Annex II Project campaign Line 214 See attached Excel file (Py_214_P8_v2.xls) Campaign P8 Period (Project campaign as presented for crediting, last day of crediting is 31 Dec. 2012) : :00 NAP 214 (t HNO 3 ) Table AII.1: Key parameters of monitoring period OH 214 (hours) OH 214 where AMS was down (hours)* EF default (highest value during campaign) (kg N 2 O/HNO 3 ) 90,235 3, Campaign Campaign Specific Emission Factor (EF n ) Moving Average Emission Factor (EF ma ) Final Project Emission Factor (EF p ) P Table AII.2: Comparison between campaign specific EF and moving average EF Campaign Project Emissions (tn 2 O) Emission Reduction (tn 2 O) Emission Reduction (tco 2 e) P ,751 Table AII.3: Project Emissions, Emission Reduction Date P8, general P8, :00 P8, : :00 P8, : :00 Special Events Repairs of the damaged sealing in the secondary catalyst basket (causing N 2O bypassing the secondary catalyst) before start-up of the campaign result in a decrease of N 2O concentration, thereby re-establishing the high N 2O abatement rate that existed prior to the bypass situation. This is the main reason for the comparatively low project emissions during this campaign. Due to AST temperature measurement is not representative. From this there is also an indirect effect on VTG that is not conservative. The VTG value is thus also not representative and accordingly deleted from data integration. Furthermore the downtime EF is set. Leakage of gas from impulse tube (input to flow-meter) leads to incorrect (increased) measurement values for off-gas flow. In the calculation tool all VTG DURAG values for the time interval with drifting values have been erased from the value set. Furthermore the downtime EF is used for all respective hours. Low external temperature in conjunction with an insufficiently insulated impulse tube lead to incorrect (increased) measurement values for off-gas flow. A correct measurement of off-gas flow was restored after insulation of the tube. In the calculation tool all VTG DURAG values for the time interval with drifting values have been erased from the value set. Furthermore the downtime EF is used for all respective hours. 27

28 P8, : :00 P8, Table AII.4: Special events P8 started with a measurement range for NCTG of ppm. This range was switched back to the DURA standard range of ppm during P8 at the end of August Originally this switch was not reflected in the DURAG data processing. The following steps were implemented for a correct and conservative treatment of data: (a) DURAG data was especially recalculated to account for the switch. A first period of data was thus reprocessed on the basis of a ppm range while for the rest of the campaign the ppm range was set. Implementation of this in DURAG is documented in the revised parameter protocol for line 214. (b) As the timing of the switch-back in this second DURAG data run was slightly incorrect (applying the ppm range just until 29 August 2012, 6 p.m. while the switch-back actually was implemented only on 30 August 2012, 9 a.m.). Thus values between 29 August 2012, 7 p.m. and 30 August, 9 a.m. are not representative (DURAG considers the extended measurement range while instrument ma signals reflect the standard range). In order to guarantee a conservative treatment of NCTG values during this period, the downtime EF was generally set and all NCTG values deleted from the data analysis during this time interval. Commissioning of the SCR unit in Line 214 was scheduled for 14 November For safety reasons the operation of an SCR unit usually requires an inlet temperature higher than 180 C (see BREF LVIC AAF REFERENCE DOCUMENT DEC 2006, Section 3.4.9). As a consequence, the temperature of the off-gas was also increased from 40 to 90 C. However, the operation of an SCR unit does not further reduce N 2O emissions (see BREF LVIC AAF REFERENCE DOCUMENT DEC 2006, Section 3.4.9, cross-media effects). 28