Determination Report

Transcription

1 Determination Report LANXESS Deutschland GmbH DETERMINATION OF Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen JI-Track 1 project in Germany REPORT NO February 15, 2008 TÜV SÜD Industrie Service GmbH Carbon Management Service Westendstr Munich GERMANY

2 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 2 of 17 Report No. Date of first issue Revision No. Date of this revision Certificate No Subject: Determination of a JI Track 1 project Accredited TÜV SÜD Unit: TÜV SÜD Industrie Service GmbH Certification Body climate and energy Westendstr. 199, D Munich Federal Republic of Germany Client: LANXESS Deutschland GmbH Industrial & Environmental Affairs D Leverkusen Federal Republic of Germany Project Title: TÜV SÜD Contract Partner: TÜV SÜD Industrie Service GmbH Carbon Management Service Westendstr. 199, D Munich Federal Republic of Germany Project Site(s): LANXESS Deutschland GmbH Industrial complex Krefeld-Uerdingen Alte Friedhofstraße, Gate 1, Building L25 D-7829 Krefeld Federal Republic of Germany Determination of the JI Track 1 project Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen Applied Methodology / Version: AM0021 version 2 Scope(s): 5 First Version: Date of issuance: Version No.: 1.0 This is submitted as JI Track 2 project and still public available on JISC website Assessment Team Leader: Nikolaus Kröger version: Date of issuance: Version No.: 2.0 This is submitted as JI Track 1 project Further Assessment Team Members: Thomas Kleiser Summary of the Determination Opinion: The Certification Body Climate and Energy of TÜV SÜD Industrie Service GmbH has been ordered by LANXESS Deutschland GmbH to determine the above mentioned JI project in Germany. The determination of this JI project has been performed by document reviews, interviews by and interviews at the office of the JI project owner. As result of this procedure, it can be confirmed that the submitted JI project documentation is in line with all requirements set by host country (Germany) for approving projects under JI Track 1. Regulations by any further participating Party that go beyond the German one would require a separate assessment. Hence TÜV SÜD can recommend this JI project for approval as JI - Track 1 project according to the German rules. Additionally the assessment team for this JI project reviewed the estimation of the projected emission reductions. We can confirm that the indicated amount of emission reductions of 3.290,813 tons CO 2e (to be issued as ERUs) in the intended first crediting period from (the first Commitment Period of the Kyoto Protocol lasts from ), resulting in annual average of estimated emission reductions of 822,703 tons CO 2e, represents a reasonable estimation using the assumptions given by the JI project documents.

3 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 3 of 17 Abbreviations AA ACM AIE AM AMS BAT Adipic Acid (AdOH) Approved Consolidated Methodology Accredited Independent Entity Approved Methodology Automated Monitoring System Best available technology reference value BImSchG Bundes-Imissionsschutz-Gesetz (German Federal Emissions Protection Law) CAR CR DEHSt DFP DNA DP EIA / EA EN ER ERU GHG JI JISC KP LANXESS LoE LoA LSP MP N/A NGO Corrective Action Request Clarification Request Deutsche Emissionshandelsstelle (Designated Focal Point for JI/CDM project implementation in Federal Republic of Germany) Designated Focal Point Designated National Authority Determination Protocol Environmental Impact Assessment / Environmental Assessment English Emission reduction Emission Reduction Unit Greenhouse gas(es) Global stakeholder process Joint Implementation Joint Implementation Supervisory Committee Kyoto Protocol LANXESS Deutschland GmbH Letter of Endorsement Letter of Approval Local stakeholder process Monitoring Plan not applicable Non Governmental Organisation Project Design Document

4 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page of 17 PI system PIP PP ProMechG SCR TD TÜV SÜD UNFCCC VVM PI system is a name of software which gathers, archives, and processes operational data from automation and control systems Project Implementation Plan Project Participant Projekt-Mechanismen-Gesetz (German Federal Law about projectrelated mechanism) Selective Catalytic Reduction Thermal Decomposition TÜV SÜD Industrie Service GmbH United Nations Framework Convention on Climate Change Validation and Verification Manual

5 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 5 of 17 Table of Contents Page 1 INTRODUCTION Objective Scope 6 2 METHODOLOGY Appointment of the Assessment Team Review of Documents Follow-up Interviews Resolution of Clarification and Corrective Action Requests Internal Quality Control 12 3 SUMMARY OF FINDINGS...13 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS DETERMINATION OPINION...17 Annex 1: Determination Protocol Annex 2: Information Reference List

6 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 6 of 17 1 INTRODUCTION 1.1 Objective The Determination objective is an independent assessment by a Third Party (Accredited Independent Entity = AIE) of a proposed project activity against all defined criteria set for the registration under the Joint Implementation (JI). Determination is part of the JI project cycle and will finally result in a conclusion by the executing AIE whether a project activity is valid and should be submitted for registration by the host country. The ultimate decision on the registration of a proposed JI-track1 project activity rests at the host Party. The project activity discussed by this Determination report has been submitted under the project title: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany. The private company LANXESS has commissioned TÜV SÜD Industrie Service GmbH to conduct a determination of the aforementioned JI project in Germany. At first the project was designed as Track 2 project thus the relevant requirements for JI track 2 projects as set by the JISC had to be assessed. In this context the project was published as JI Track 2 project on JI webpage (see: WHZ5NE9WSJ1X3HV6IDGWI/view.html) for a period of 30 days on from November 16, 2007 to December 15, Later on LANXESS decided to switch to JI Track 1 procedures. Under JI Track 1 requirements for the final approval are set by the involved DFP, mainly the DFP of the host country in this case the German DEHSt. The determination serves as a conformity test of the project design and is a requirement for all JI projects. In particular, the project s baseline, the monitoring plan (MP), and the project s compliance with host country criteria and general relevant UNFCCC criteria are validated in order to confirm that the project design as documented is sound and reasonable and meets the stated requirements and identified criteria. Determination is considered necessary to provide assurance to stakeholders of the quality of the project and its intended generation of emission reductions (in particular ERUs - in the first commitment period under the Kyoto Protocol). 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. 1.2 Scope The scope of any assessment is defined by the underlying legislation, regulation and guidance given by relevant entities or authorities. In the case of JI project activities the scope is set by: The Kyoto Protocol, in particular 12 Decision 2/CMP1 and Decision 3/CMP.1 (Marrakech Accords) Decisions by the JISC published under (for general guidance) Specific guidance by the JISC published under (for general guidance) The applied approved methodology

7 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 7 of 17 The technical environment of the project (technical scope) Internal and national standards on monitoring and QA/QC Technical guideline and information on best practice Additional requirements as set by DEHSt The determination is not meant to provide any consulting towards the client. However, stated requests for clarifications and/or corrective actions may provide input for improvement of the project design. Once TÜV SÜD receives a first version, it is made publicly available on the internet at TÜV SÜD s webpage. As the project first was defined as JI Track 2 project it also was published on JISC webpage. After changing to track 1 it has been furthermore published at the webpage of the Designated Focal Point DEHSt (see: CDM/ Lanxess,tem plateid=raw,property=publicationfile.pdf/_lanxess.pdf). Information on the first and on the final version is presented at page 1. The only purpose of a determination is its use during the registration process as part of the JI Track 1 project cycle. Hence, TÜV SÜD can not be held liable by any party for decisions made or not made based on the determination opinion, which will go beyond that purpose. TÜV SÜD has, based on the recommendations in the Validation and Verification Manual (see for further information employed a risk-based approach in the determination, focusing on the identification of significant risks for project implementation and the generation of emission reductions. In this particular case a project specific protocol associated to the special needs of the AM0021 had been developed and used. This report is based on the (version 2 of January 15, 2008). Initial versions of these documents were published in the context of the Global Stakeholder Process () on the website of (link see chapter ) and JISC. Potential stakeholders have been invited for commenting. According to CARs and CRs indicated in the audit process the client decided to revise the. The final versions for serves as the basis for the final conclusions presented herewith. Studying the existing documentation, it was obvious that the competence and capability of the validation team has to cover at least the following aspects: Knowledge of Kyoto Protocol and the Marrakech Accords Environmental and Social Impact Assessment Skills in environmental auditing (ISO 1001) Quality Assurance Technologies, processes and operation of adipic acid plants Baseline concepts Monitoring concepts Political, economical and technical random conditions in host country

8 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 8 of 17 2 METHODOLOGY The project assessment aims at being a risk based approach and is based on the methodology developed in the Validation and Verification Manual (for further information see an initiative of Designated and Applicant Entities, which aims to harmonize the approach and quality of all such assessments. In order to ensure transparency, a determination protocol was customised for the project. TÜV SÜD developed a cook-book for methodology-specific checklists and protocol based on the templates presented by the Validation and Verification Manual. The protocol shows, in a transparent manner, criteria (requirements), the discussion of each criterion by the assessment team and the results from validating the identified criteria. The Determination protocol serves the following purposes: It organises, details and clarifies the requirements a JI project is expected to meet; It ensures a transparent Determination process where the validator will document how a particular requirement has been validated and the result of the Determination. The Determination protocol consists for this project of three tables. The different columns in these tables are described in the figure below. The completed Determination protocol is enclosed in Annex 1 to this report. Determination Protocol Table 1: Conformity of Project Activity and Checklist Topic / Question The checklist is organised in sections following the arrangement of the applied version. Each section is then further subdivided. The lowest level constitutes a checklist question / criterion. Reference Comments in Gives reference to documents where the answer to the checklist question or item is found in case the comment refers to documents other than the. The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is further used to explain the conclusions reached. In some cases sub-checklist are applied indicating yes/no decisions on the compliance with the stated criterion. Any Request has to be substantiated within this column Conclusions are presented based on the assessment of the first version. This is either acceptable based on evidence provided (), or a Corrective Action Request (CAR) due to noncompliance with the checklist question (See below). Clarification Request (CR) is used when the Determination team has identified a need for further clarification. Conclusions are presented in the same manner based on the assessment of the final version.

9 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 9 of 17 As for this specific project the final was applying a different version of the methodology than the first one, a table 1a and a table 1b are presented reflecting the changes by the revision of the methodology. Determination Protocol Table 2: Resolution of Corrective Action and Clarification Requests Clarifications and corrective action requests Ref. to table 1 Summary of project owner response Determination team conclusion If the conclusions from table 1 are either a Corrective Action Request or a Clarification Request, these should be listed in this section. Reference to the checklist question number in Table 1 where the Corrective Action Request or Clarification Request is explained. The responses given by the client or other project participants during the communications with the Determination team should be summarised in this section. This section should summarise the Determination team s responses and final conclusions. The conclusions should also be included in Table 1, under. In case of a denial of the project activity more detailed information on this decision will be presented in table 3. Determination Protocol Table 3: Unresolved Corrective Action and Clarification Requests Clarifications and corrective action requests If the final conclusions from table 2 results in a denial the referenced request should be listed in this section. Id. of CAR/CR 1 Identifier of the Request. Explanation of the Conclusion for Denial This section should present a detail explanation, why the project is finally considered not to be in compliance with a criterion.

10 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 10 of Appointment of the Assessment Team According to the technical scopes and experiences in the sectoral or national business environment TÜV SÜD has composed a project team in accordance with the appointment rules of the TÜV SÜD certification body climate and energy. The composition of an assessment team has to be approved by the Certification Body ensuring that the required skills are covered by the team. The Certification Body TÜV SÜD operates four qualification levels for team members that are assigned by formal appointment rules: Assessment Team Leader (ATL) Greenhouse Gas Auditor (GHG-A) Greenhouse Gas Auditor Trainee (T) Experts (E) It is required that the sectoral scope linked to the methodology has to be covered by the assessment team. The Determination team was consisting of the following experts (the responsible Assessment Team Leader in written in bold letters): Name Qualification Coverage of technical scope Coverage of sectoral expertise Host country experience Nikolaus Kröger ATL Thomas Kleiser ATL Nikolaus Kröger is environmental engineer and expert for emissions monitoring and quality assurance at the department TÜV SÜD Carbon Management Service. He is located in the TÜV SÜD Hamburg office and is also engaged as personally accredited verifier in the EU-ETS serving the Northern German market. Being ghg auditor for sectoral scopes 1,, 5, 8, 9, 10, 11, 12, 13 and assessment team leader for CDM and JI projects he has already been involved in many CDM/JI activities with a special focus on industrial non-co2 projects. Constitutive on 13 years experience at the department Environmental Service he verified many metallurgical plants, refineries, chemical plants, waste treatment and power plants and process engineering in many types of facilities. One of his former focal points had been implementation and calibration of complex automated Environment- Data-Systems. Thomas Kleiser is head of division CDM and JI at TÜV SÜD Industrie Service GmbH. In this position he is responsible for validation, verification and certifications processes for GHG mitigation projects as well as trainings for internal auditors. As assessment team leader he already conducted numerous validations and verifications of CDM and JI projects. Before entering this department he worked as expert on air quality measurements and emissions inventories as well as on environmental auditing within the environmental branch of the company. Reflecting on earlier projects he is familiar with political, economical and technical random conditions in the host country.

11 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 11 of Review of Documents The project developer submitted a as well as additional background documents related to the design, baseline and monitoring. The first version submitted by the client and additional background documents related to the project design and baseline were reviewed as initial step of the Determination process. A complete list of all documents and proofs reviewed is attached as annex 2 to this report. 2.3 Follow-up Interviews In the period of November 15-16, 2007 TÜV SÜD performed interviews on-site with project stakeholders to confirm selected information and to resolve issues identified in the first document review. The table below provides a list of all persons interviewed in the context of this on-site visit. Name Mr Bernd Kaletta, PhD Mr Karl-Heinz Mix, PhD Organisation LANXESS Deutschland GmbH, Industrial & Environmental Affairs LANXESS Deutschland GmbH, plant manager and head of production, Manufacturing LXS- SCP Mr Jürgen Kadelka, PhD LANXESS Deutschland GmbH, head of manufacturing, LXS-BU-SCP Mr Thomas Hellmich LANXESS Deutschland GmbH, head of technology, LXS-SCP-BLAA Mr Stefan Hudl Mr Davids-Vahsen Mr Markus Rothe LANXESS Deutschland GmbH, assistant to works manager, LXS-SCP-AA LANXESS Deutschland GmbH, foreman adipic acid plant, LXP-SCP-BLAA FutureCamp GmbH, project manager ghgemission trading and climate protection projects, consultant

12 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 12 of Resolution of Clarification and Corrective Action Requests The objective of this phase of the Determination is to resolve the requests for corrective actions and clarifications and any other outstanding issues which needed to be clarified for TÜV SÜD s positive conclusion on the project design. The Corrective Action Requests and Clarification Requests raised by TÜV SÜD were resolved during communication between the client and TÜV SÜD. To guarantee the transparency of the Determination process, the concerns raised and responses that have been given are summarised in chapter 3 below and documented in more detail in the Determination protocol in annex Internal Quality Control As final step of a Determination the Determination report and the protocol have to undergo and internal quality control procedure by the Certification Body climate and energy, i.e. each report has to be approved either by the head of the certification body or his deputy. In case one of these two persons is part of the assessment team approval can only be given by the other one. It rests at the decision of TÜV SÜD s Certification Body whether a project will be submitted for requesting registration by the DFP (DEHSt) or not.

13 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 13 of 17 3 SUMMARY OF FINDINGS As informed above all findings are summarized in table 2 of the attached Determination protocol. In total the assessment team expressed Corrective Action Requests and 2 Clarification Requests. As described in the current are at the LANXESS-operated adipic acid plant at the industrial park in Krefeld-Uerdingen two types of decomposition facilities installed: - Selective Catalytic Reduction: The share of NOx in the lowly charged waste gas stream, which does not contain N2O, is decomposed in the selective catalytic reduction facility - Thermal Decomposition of N2O: The highly charged waste gas stream, containing NOx and N2O, runs through the thermal decomposition facility, where both fractions are almost completely decomposed. Activity at the thermal decomposition facility had to be interrupted for planned maintenance measures or unplanned failures. On these occasions where the thermal facility is at a shutdown, the waste gas from the adipic acid production entirely runs through the selective catalytic reduction to decompose the NOx share. As the catalytic reduction is not able to decompose the N2O fraction in the waste gas, the N2O is released to the atmosphere. The project participant LANXESS plans to install a further, redundant, thermal decomposition facility to decompose the residual N2O amounts accruing due to shutdown times of the existing thermal decomposition plant. It is planned to operate the redundant thermal decomposition facility in parallel mode to shorten response time. As the proposed project activity comprises the additional decomposition of N2O from an existing adipic acid production plant, it fits into the coverage of the approved CDM methodology AM0021 Baseline/Monitoring Methodology for decomposition of N2O from existing adipic acid production plants. The project design follows in principle AM0021, whereas some elements of the methodology have to be adjusted due to project specific conditions. As the aforementioned methodology provides for an approach of decomposition of N2O assuming no decomposition has taken place previous to the project activity, the baseline setting has to be adjusted. Considering the fact that the by far largest share of N2O emissions from the adipic acid production is already decomposed by the existing thermal decomposition facility, the baseline scenario has to be capped at a level that reflects the average historical share of decomposed N2O in the overall N2O generation. It is obviously that the baseline scenario will be the continuation of the situation and plausible to view of TÜV SÜD assessment team that the baseline emissions are the generated emissions representing the historic, state-of-the-art decomposition of N2O at the present existing adipic acid plant. The starting point for identification of historic adipic acid production during shut-down times of the decomposition facility had been identified by log-book entries where consumption of ammonia in SCR > 10 Nm³/h and consumption of natural gas in thermal decomposition facility < 500 Nm³/h at the same time. The justification of the baseline chosen, the identification and derivation of the baseline scenario, the developing of the historical emission factor N2O and derivation of the accordant parameters are technical plausible and arithmetically correct submitted. Nonetheless several fundamental issues had to been clarified during TÜV SÜD s on-site mission at November 15-16, CAR1 and CAR2 are related to an outstanding documentation of the facility s operational and management structure and facility s responsibilities and institutional arrangements for data collection and archiving. LANXESS submitted an overview of the facility s responsibilities and institutional arrangements for the monitoring process. The whole monitoring process will be put under the responsibility of the adipic acid Plant-Manager. The details of the operational and management structure finally will be generated before operation of the redundant thermal decomposition facility. Further LANXESS stated the Head of Technology is responsible for of all data collection activities. To en-

14 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 1 of 17 sure availability of data in case of malfunctions regarding the PI system, relevant parameters are listed in the shift book too. The Head of Production is responsible for the shift book. The AA Plant- Manager is responsible for the calculation and declaration of emission reductions. A fundamental key finding with first edition in was the PP s approach for monitoring of the flow rates at the stack of the redundant thermal decomposition plant. Common industrial standard for flow measurement is the use of continuously measuring flow meters in the chimney behind the waste gas abatement unit. Flow meters are available in a large diversity of types regarding to any special flanking parameters e.g. temperature, moisture and acidity of waste gas. Differing from the aforementioned common standard LANXESS preferred to estimate the waste gas flow rate based on the derivation of an ideal combustion and stoichiometric complete conversion. Nonetheless that the presented derivation of flow rate was plausible and mathematical correct arranged, TÜV SÜD annotated that this evaluation, which set up on the derivation of an ideal combustion and stoichiometric complete conversion, is just a theoretical approach. With CAR3 the assessment team mentioned that the uncertainty of the aforementioned theoretic derivation is not determined. In the first edition LANXESS showed that the list of parameters follows in principle needs and suggestion with regard to requirements of AM0021. LANXESS and TÜV SÜD had been aware that such deviations are unavoidable related to the fact that the project addresses an already existing abatement unit and an additional redundant abatement unit which had to be integrated. Hence AM0021 is published for a single unit the environment of required parameters needed to be adjusted. Expressively JI allows such deviations if they are explained adequate. To sight of TÜV SÜD assessment team the fulfils these requirements in principle. Nonetheless the assessment team did not follow the presented derivation of waste gas flow and its presented determination before the thermal decomposition facilities by accumulating different input flows. The PP s argument that a measurement of waste gas behind the thermal decomposition facility is not applicable due to project specific technical reasons and that the main reasons for this methodology deviation are the large diameter of the stack and the expected influence of pressure drop in the thermal decomposition facilities was not accepted by TÜV SÜD. CAR3 requested for further explanation and precise calculation about the uncertainty of flow rate approach and hard proofs for calculations of uncertainty. Parallel a discussion about an alternative measurement strategy for this project was stipulated. To increase accuracy of the N2O emissions monitoring results and decrease uncertainties LANXESS changes the measurement strategy of project emissions as follows: The quantity of N2O not destroyed in the thermal decomposition facilities is calculated by constantly monitoring the flow and the N2O concentration of the waste gas, where both parameters are measured behind the thermal decomposition facilities. The list of parameters is updated in the revised in chapter D with regard to requirements of AM0021. According to these changes the figure in chapter B.3, showing the project boundary, and information about Quality control (QC) and quality assurance (QA) procedures of the parameters in chapter D.2 and Annex 3 are adjusted. To view of the assessment team the discussion about this issue is settled. Ongoing with CAR a request about EIA was started. Due to the fact, that the PP stated that negative environmental impacts are not expected significant and that no EIA had been undertaken it was necessary to explain the requirements for EIA in this specific situation. Following this request LANXESS adjusted in chapter F.1. of the revised as follows: According to the licensing notice for the already existing thermal decomposition plant it is stated, that negative environmental impacts from the installation of the thermal decomposition plant are not expectable. As the project activity is the installation of a redundant facility with the same technology, located at the same site as the already existing thermal decomposition facility, negative environmental impacts are not expectable as well. To view of TÜV SÜD team this issue is settled. Two minor finding had been discussed with CRs. With CR1 the assessment team tried to clarify the adjustment from 200 to 2005 in case of installed capacity and the fact that the PP stated that the project refers to the capacity as installed by the end of LANXESS stated that the installed ca-

15 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 15 of 17 pacity of the AA plant was in year 200 above the licensed capacity. In year 2005 the former true installed capacity had been licensed by the authorities subsequent. It had to be noted that the measure is the installed and not the authorized capacity. Like this there is - in technical sense - no deviation from 200 to TÜV SÜD team crosschecked this statement and settled this issue. Further on TÜV SÜD assessment team noted that the approved methodology AM0021 does not require special common standards e.g. standards as described in European Norm EN1181. Although the monitoring system is not installed yet the PP confirmed contracting a provider for the required Automated Measuring System (AMS) and that for the planned AMS the European Norm EN1181 will be taken into account. With CR2 the assessment team requested for a current explanation if or if not (and if for which parameters) the EN1181 would be taken into account. LANXESS clarified that parts of the monitoring system will be configured in dependence on the requirements of the latest applicable European standards and norms (EN1181) and that the following parameters are concerned: 1) Infra-Red analyzer in the chimney of thermal decomposition facility 1, 2) Infra-Red analyzer in the chimney of thermal decomposition facility 2 and 3) Infra-Red analyzer in selective catalytic reduction plant. Regarding to the fact that AM0021 does not require standards e.g. like EN1181 to view of the assessment team this issue is settled. Nonetheless it will be necessary for the PP to watch out for future changes of legal framework in the host country. For any further detail about submitted CR or CAR please refer to Annex 1 Table 2 Resolution of Corrective Action and Clarification Requests of the Determination report.

16 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 16 of 17 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS TÜV SÜD published the project documents on the internet at TÜV SÜD s own website and JISC website and invited comments by Parties, stakeholders and non-governmental organisations during a period of 30 days. The following table presents all key information on this process: webpage: and 3HV6IDGWI/view.html Starting date of the global stakeholder consultation process: Comment submitted by: Issues raised: none none Response by TÜV SÜD: none

17 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Page 17 of 17 5 DETERMINATION OPINION TÜV SÜD has performed a determination of the following proposed JI Track 1 project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany An analysis as provided by the applied methodology demonstrates that the proposed project activity is not a likely baseline scenario. Emission reductions attributable to the project are hence additional to any that would occur in the absence of the project activity. Given that the project is implemented as designed, the project is likely to achieve the estimated amount of emission reductions as specified within the final version. TÜV SÜD has performed the determination of the JI Track 1 project on the basis of all currently valid and relevant JI criteria of the host country Germany. The review of the JI Track 1 project design documentation and the subsequent follow-up interviews have provided TÜV SÜD with sufficient evidence to determine the fulfillment of stated criteria. It has been verified that the requirements of the Letter of Support of German DNF (DEHSt) have been considered in the JI Track 1 project documentation. The German DFP DEHSt stated already on May 10, 2007 with reference number E a general signal of acceptance as JI project under certain conditions and pointed out that the project will might meet the requirements of 5 ProMechG and further t stated that a 5 para.2 ProMechGconform investor country had to been named. Apart of this requirement, TÜV SÜD can recommend this JI project for acceptance as JI Track 1 project according to the German rules. Additionally the assessment team for this JI project reviewed the estimation of the projected emission reductions. We can confirm that the indicated amount of emission reductions of 3.290,813 tons CO 2e (to be issued as ERUs) in the intended first crediting period from (the first Commitment Period of the Kyoto Protocol lasts from ), resulting in annual average of estimated emission reductions of 822,703 tons CO 2e, represents a reasonable estimation using the assumptions given by the JI project documents. The determination is based on the information made available to us and the engagement conditions detailed in this report. The determination has been performed using a risk-based approach as described above. The only purpose of the report is its use during the registration process as JI Track 1 project in Germany. Hence, TÜV SÜD cannot be held liable by any party for decisions made or not made based on the determination opinion, which will go beyond that purpose. This report had been submitted on basis of the latest publicly available regulations in the host country. This excludes assertive any mandatory requirement which will be appointed belated. Munich, February 15, 2008 Hamburg, February 15, 2008 Werner Betzenbichler Head of the Certification Body Climate and Energy Nikolaus Kröger Assessment Team Leader

18 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Annex 1: Determination Protocol

19 Number of Pages: 5 A. General description of project activity A.1. Title of the project activity A.1.1. Does the used project title clearly enable to identify the unique JI activity? A.1.2. Are there any indication concerning the revision number and the date of the revision? A.1.3. Is this consistent with the time line of the project s history? The project title clearly enables the identification of the JI activity. No second JI activity exists with a similar title or at the same site. The revision number and the date of the issuance of this revision is correctly indicated v.1 submitted November 08, 2007, it does. A.2. Description of the project activity A.2.1. Is the description delivering a transparent overview of the project activities? A.2.2. What proofs are available demonstrating that the project description is in compliance with the actual situation or planning? A.2.3. Is the information provided by these proofs consistent with the information provided by the? A.2.. Is all information presented consistent with details provided by further chapters of the?, 7, it is. For to demonstrate that the project is in compliance with the actual situation or planning LANXESS submitted to TÜV SÜD assessment team a project implementation schedule., it is. Nevertheless there is a common risk during implementation which is not under responsible of LANXESS., it is. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-1

20 Number of Pages: 5 A.3. Project participants A.3.1. Is the form required for the indication of project participants correctly applied? A.3.2. Is the participation of the listed entities or Parties confirmed by each one of them? A.3.3. Is all information on participants / Parties provided in consistency with details provided by further chapters of the (in particular annex 1)? A.. Technical description of the project activity, it is. The participation of the listed entities or Parties confirmed by each one of them was not confirmed at the moment of on-site mission. LANXESS stated that an Investor is not defined yet, nevertheless it s confirmed that the future investor country will be one of those which in compliance with the requirements of the German Pro- MechG. The host country is Germany., it is. Please refer to A A..1. Location of the project activity A Does the information provided on the location of the project activity allow for a clear identification of the site(s)? A How is it ensured and/or demonstrated, It s ensured that the LANXESS can implement the project at this that the project proponents can implement site. LANXESS is owner of ground, production facilities and technical the project at this site (ownership, licenses, know-how. contracts etc.)? A..2. Technology(ies) to be employed, or measures, operations or actions to be implemented by the project activity, it does A Does the technical design of the project, it does. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-2

21 Number of Pages: 5 activity reflect current good practices? A Does the description of the technology to be applied provide sufficient and transparent input/ information to evaluate its impact on the greenhouse gas balance? A Does the implementation of the project activity require any technology transfer from annex-i-countries to the host country(ies)? A..2.. Is the technology implemented by the project activity environmentally safe? A Is the information provided in compliance with actual situation or planning? A Does the project use state of the art technology and / or does the technology result in a significantly better performance than any commonly used technologies in the host country? A Is the project technology likely to be substituted by other or more efficient technologies within the project period? A Does the project require extensive initial training and maintenance efforts in order, it does No, it doesn t. it is. The planed thermal decomposition plant will be a copy of an already existing thermal decomposition plant. The already existing plant meets all requirements of federal german environmental legislation., it does., it does. The project use state of the art technology and result in a significantly better performance than any commonly used technologies in Germany. So far we know there doesn t exist any other redundant thermal decomposition plant. Not likely as it is expected to reduce 99% of produced N2O. Extensive training is required in the context of monitoring. This had been confirmed by LANXESS during on-site mission. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-3

22 Number of Pages: 5 to be carried out as scheduled during the project period? A Is information available on the demand and requirements for training and maintenance? A Is a schedule available for the implementation of the project and are there any risks for delays?, 7 As obviously the new redundant decomposition plant is just a copy of an already existing in close nearness. The AA plant s staff LANXESS owns all necessary know-how and experience because of the operation of an already existing is current available similar sister installation. Because of this fact no additional note about required training had been introduced into. The current state of training and maintenance efforts fulfils the requirements. LANXESS confirmed that experienced instrument technician are employed in this project and that plant employees and responsible person for monitoring received intensive training., it does. Any responsible foreman of a shift ensures that the existing qualification matrix will be accomplished in periodic sequences., it does. For to demonstrate that the project is in compliance with the actual situation or planning LANXESS submitted to TÜV SÜD assessment team a project implementation schedule. A..3. Brief Explanation of how the anthropogenic emissions of greenhouse gases by sources are to be reduced by the proposed JI project, including why the emission reduction would not occur in the absence of the proposed project, taking into account national and/or sectoral policies and circumstances A Is there a brief explanation of how the anthropogenic emissions of greenhouse gases by sources are to be reduced by the proposed JI project, including why the emission reduction would not occur in the absence of the proposed project, taking, it is. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-

23 Number of Pages: 5 into account national and/or sectoral policies and circumstances? A Is the explanation transparent, feasible and if based on calculations mathematical correct calculated?, it is. The explanation is transparent, feasible and mathematical correct calculated. A... Estimated amount of emission reductions over the chosen crediting period A...1. Is the form required for the indication of The uses the correct form in chapter A.. projected emission reductions correctly The total estimated reductions over the crediting period same as applied? the annual average of estimated emission reductions are clearly indicated. A...2. Are the figures provided consistent with other data presented in the? A..5. Project approval by the participants A Is the state of endorsement or approval by the host party clearly defined and a Letter of Endorsement (LoE), Letter of Approval (LoA) or any alternative statement of authorization available? A Is the state of endorsement or approval by any other parties e.g. investing parties clearly defined and a Letter of Endorsement (LoE), Letter of Approval (LoA) or any alternative statement of authorization, 7, 7 All figures which are presented in the are consistent with other data. A Letter of Endorsement (LoE) had been submitted by the DEHSt (Deutsche Emissionshandelsstelle = Designated Focal Point for JI/CDM project implementation in Federal Republic of Germany) on May 10, The DEHSt requires an investing party (investing country) which fulfils the mandatory of 5 Abs. 2 ProMechG. A Letter of Approval (LoA) is still outstanding and will be prepared first by DEHSt after receiving the project determination report. No, it doesn t. The investor or investor country is not defined yet. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-5

24 Number of Pages: 5 B. Baseline available? B.1. Description and justification of the baseline chosen B.1.1. Are reference number, version number, and title of the baseline and monitoring methodology clearly indicated? B.1.2. Is the applied version the most recent one and / or is this version still applicable? Reference number, version number, and title of the baseline and monitoring methodology are clearly indicated. The follows in principle the requirements of AM0021 version 02, whereas some elements of the methodology have to be adjusted due to project specific conditions. These adjustments are explained in later chapters of the protocol. For this methodology the referred version is the most recent one. Justification of the choice of the methodology and why it is applicable to the project activity B.1.3. Is the applied methodology considered the most appropriate one? AM0021 is solely addressing the destruction of nitrous oxide by thermal decomposition. Hence it is considered that AM0021 is the appropriate choice for this project activity. Integrate the required amount of sub-checklists on the applicability criteria as given by the applied methodology and comment on at least every line answered with No ; B.1.. Criterion 1: The applicability is limited to either catalytic or thermal decomposition of the N2O by-product of adipic acid production at existing production plants. Applicability checklist / No Criterion discussed in the? Compliance provable? Compliance verified? Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-6

25 Number of Pages: 5 B.1.5. Criterion 2: The project activity is spatially generic, being applicable across regions where the data (both related to baseline and project activity as well) exist to undertake the assessments. B.1.6. Criterion 3: The applicability is limited to for installed capacity that exists by the end of the year 200. Applicability checklist / No Criterion discussed in the? Compliance provable? Compliance verified?, 2 Applicability checklist / No Criterion discussed in the? Compliance provable? Compliance verified? No CR1 The project participant stated that for this JI project an adjustment is carried out. The project refers to the capacity as installed by the end of Clarification Request 1: It is necessary to explain the adjustment from 200 to 2005 in case of installed capacity B.2. Description of how the anthropogenic emissions of greenhouse gases by sources are reduced below those that would have occurred in the absence of the JI project The baseline scenario shall be identified using procedure for Identification of the baseline scenario described in the approved methodology AM0021 Baseline Methodology for decomposition of N2O from existing adipic acid plants version 01. Further all instructions for testing additionality conditions as adopted from the "Tool for the demonstration and assessment of additionality" version 03 should be discussed. B.2.1. Have all technically feasible baseline scenario alternatives (at least all scenarios listed under Technically feasible baseline scenario alternatives listed in AM0021 vers. 1 to the project activity are identified. The in Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-7

26 Number of Pages: 5 step 1a. Identified and credible alternatives) to the project activity been identified and discussed by the? Why can this list be considered as being complete? B.2.2. Does the project identify correctly and exclude those options not in line with regulatory or legal requirements? B.2.3. Have applicable regulatory or legal requirements been identified? B.2.. Does the include an appropriate discussion if and how any alternatives generate financial or economic benefits? (step 2. Investment analysis), 18, 19, 20, 21, 22, 23 discussed alternative scenarios. The only realistic and credible alternative scenarios to the project activity are a) The continuation of the current situation, where there will be no redundant installation of technology for the destruction of residual N2O or b) the proposed project activity undertaken without JI. The project identifies correctly and ex-cludes those options not in line with regulatory or legal requirements. Applicable regulatory or legal requirements such as e.g. such as BImSchG (Bundes-Immissionsschutzgesetz = German Federal Emission Protection Law) has been identified. Installations, which are subject to authorisation according to BImSchG and connecting regulations, have to fulfil different requirements. Concerning adipic acid plants, the emission of NOx have to be limited to a specific extend. A limitation of N2O emissions is not required. Nevertheless LANXESS has already installed a thermal decomposition plant to reduce N2O emissions based on a voluntary commitment. The residual share of N2O emissions is monitored and data are submitted to the German Federal Environmental Agency. Further flanking regulatory and/or legal requirements are the Best available technology reference value (BAT) and the IPCC Guidelines., it does. Simple cost analysis is applied for the project as the activity produces no relevant economic benefits other than JI related income. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-8

27 Number of Pages: 5 B.2.5. Is it transparently shown that at least one of the alternatives is not prevented by the identified barriers (step 3. Barrier analysis)? B.2.6. Does the include an appropriate discussion if and how any alternatives generate financial or economic benefits? (Step. Common practise analysis) B.2.7. In case of Option I: Is the least costly alternative clearly identified? B.2.8. In case of Option II: Is the most suitable financial indicator clearly identified? B.2.9. In case of Option II: Is the calculation of financial figures for this indicator correctly done for all remaining alternatives?, 9, 10, 15 It is not necessary to show barriers, because LANXESS follows step 2. Investment analysis., it is. The technology of thermal decomposition is well established and widely used. It is common practice in Germany same as in Europe to install waste gas treatment systems that not only decompose the NOx, but also to a certain extent the N2O in the waste gas stream. The European Commission takes up this topic within the scope of its Draft Reference Document on Best Available Techniques in the Large Volume Organic Chemical Industry, showing the extent to which European adipic acid producers decompose the accumulating nitrous oxide emissions. LANXESS stated to TÜV SÜD assessment team that so far no case is known where a thermal decomposition facility is applied in a redundant manner to destroy the portion of nitrous oxide that is usually vented due to inevitable shutdowns of the main decomposition facility. TÜV SÜD emphasizes that this is the crucial distinction in terms of considering common practice. The continuation of the recent situation is clearly identified as the least costly option. - Not applicable - Not applicable Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-9

28 Number of Pages: 5 B In case of Option II: Is the investment analysis presented in a transparent manner providing public available proofs for data? B In case of Option II: Is the sensitivity analysis evidencing the robustness of the financial attractiveness of the selected baseline scenario? B In case of Option II: Have reasonable variations been applied in critical assumptions? B In case of a re-assessment in the course of the project s lifetime: Are there any new or modified NOx-emission regulations, which may address the project baseline? B.2.1. In case of a re-assessment in the course of the project s lifetime: Have new base-line scenarios been properly discussed reflecting the altered situation? B In case of a re-assessment in the course of the project s lifetime: Are there any new or modified N2O-emission regulations, which may address the project baseline? B In case of a re-assessment in the course of the project s lifetime: Have new base-line scenarios been properly discussed reflecting the altered situation? - Not applicable - Not applicable - Not applicable - Not applicable - Not applicable - Not applicable - Not applicable Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-10

29 Number of Pages: 5 B.3. Description of how the definition of the project boundary is applied to the project Integrate the required amount of sub-checklists for sources and gases as given by the methodology applied and comment on at least every line answered with No B.3.1. Source: Waste stream exiting the stack of the Adipic Acid plant (Burner inlet to stack) Gas(es): N2O Type: Baseline Emissions and Project Emissions B.3.2. Do the spatial and technological boundaries as verified on-site comply with the discussion provided by / indication included to the?, 9, 10, 15,, 9, 10, 15 Boundary checklist / No Source and gas(es) discussed in the? Inclusion / exclusion justified? Explanation / Justification sufficient? Consistency with monitoring plan? The project boundaries comprise the adipic acid plant with its existing NOx and N2O decomposition facilities and the planned redundant N2O thermal decomposition facility. Within these boundaries, both, baseline and project emissions are measured and assessed. In detail the boundary includes: - Selective Catalytic Reduction plant - N2O decomposition plant I - N2O decomposition plant II (redundant), it does. The existing Selective Catalytic Reduction plant and the N2O decomposition plant was inspected during on-site mission. The location for the future construction of the new planed redundant N2O decomposition plant II was inspected too. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-11

30 Number of Pages: 5 B.. Further baseline information, including the date of baseline setting and the name(s) of the person(s)/entity(ies) setting the baseline: B..1. Are the name(s) of the person(s)/entity(ies) whom setting the baseline available? B..2. Is the date of baseline setting available? C. Duration of the project activity / crediting period C.1. Starting date of the project: C.1.1. Is the project s starting date clearly defined and reasonable? C.2. Expected operational lifetime of the project: C.2.1. Is the expected operational lifetime of the project clearly defined and reasonable?, they are. The baseline was developed by Mr Rothe of FutureCamp GmbH, it is. The date of baseline setting is November 11, The project starts with the construction works for the redundant thermal decomposition facility. Those shall not start before positive validation of the JI and receipt of a letter of approval (LoA) by the German authorities. The start of construction works is expected to be in August 2008., it is. The crediting period starts with the commissioning of the redundant thermal decomposition facility, which is expected to be in March The crediting period lasts from March 01, 2009 until December 31, 2012 (3 years and 10 months). In case German and/or international regulations will allow the continuation of existing JI projects beyond 2012, accordant measures shall be undertaken to prolong the crediting period. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-12

31 Number of Pages: 5 C.3. Length of the crediting period: C.3.1. Is the assumed crediting period clearly defined and reasonable? D. Monitoring plan D.1. Description of monitoring plan chosen: D Is it explained how the procedures provided in the methodology are applied by the proposed project activity?, 9, 10, 15, it is. The operational lifetime of the project is expected to be 30 years. The discussion under section D.1 is referencing all formulae and emissions in compliance with the applied methodology and the project boundaries as presented earlier in the. The description of monitoring plan chosen follows in principle AM0021, whereas some elements of the methodology have to be adjusted due to project specific conditions: Project emissions: The quantity of N2O by-passing the thermal decomposition facilities is not determined as in AM0021 (time of connection of the adipic acid plant with the thermal decomposition plant) but by constantly monitoring the flow and the concentration of the waste gas of the Selective Catalytic Reduction plant (SCR). Both parameters are measured before the SCR facility. The SCR has no effect on the share of N2O in the waste gas. The quantity of N2O not destroyed in the thermal decomposition facilities is calculated by constantly monitoring the flow and the N2O concentration of the waste gas. Waste gas flow is determined before the thermal decomposition facilities by adding different input flows, which are all measured. A measurement of the waste gas behind the thermal decomposition facility is not applicable due to project specific technical reasons. Main reasons are the large diameter of the Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-13

32 Number of Pages: 5 D Is every selection of options offered by the methodology correctly justified and is this justification in line with the situation verified on-site? D Is the operational and management structure clearly described and in compliance with the envisioned situation? stack and the expected influence of pressure drop in the thermal decomposition facilities.n2o concentration of the waste gas are measured behind the thermal decomposition facilities. CO2 emissions of the consumption of natural gas are derived by measuring natural gas consumption and multiplying it with a default net calorific value and emission factor. Baseline emissions: The baseline emissions regarding N2O are calculated by measuring the amount of adipic acid produced and multiplying it with the baseline N2O emission factor. Baseline emissions regarding CO2 from natural gas consumption are calculated by multiplying the amount of adipic acid produced with the baseline CO2 emission factor., it does. No, it doesn t. In the in its current version operational and management structure (function owner and their responsibilities) are not clearly described. Nonetheless it had to be noted that the technical description about quality control and quality assurance as shown in section D.2. fulfils the requirements. Corrective Action Request 1: It is necessary to describe clearly the facility s operational and management structure (function owner and their responsibilities). CAR1 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-1

33 Number of Pages: 5 D Are responsibilities and institutional arrangements for data collection and archiving clearly provided? D Does the monitoring plan provide current good monitoring practice? D Has the monitoring system installed? D Does the monitoring system installed following special common standards e.g. as described in European Norm EN1181 (200)? No, they aren t. In the in its current version responsibilities (function owner and their responsibilities) and institutional arrangements for data collection and archiving are not clearly provided. Corrective Action Request 2: It is necessary to provide clearly the facility s responsibilities and institutional arrangements for data collection and archiving (function owner and their responsibilities). CAR2 The monitoring plan provides current good monitoring practice. The monitoring system is not installed yet. TÜV SÜD assessment team noted that the approved methodology AM0021 does not require special common standards e.g. standards as described in European Norm EN1181. As mentioned above in item D.1.6. the monitoring system is not installed yet. Anyway the project participants confirmed contracting a provider for the required Automatic Measuring System (AMS). LANXESS confirmed that for the planned AMS the European Norm EN1181 (200) will be taken into account. Clarification Request 2: It is necessary to offer a current explanation if or if not (and if for which parameters) the aforementioned European Norm EN1181 (200) would be taken into account? CR2 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-15

34 Number of Pages: 5 D Are the requirements on the treatment of downtime of the AMS clearly reflected in the envisioned calculation routines? D If applicable: Does Annex 3 provide useful information enabling a better understanding of the envisioned monitoring provisions? The requirements on the treatment of downtime of the AMS are clearly reflected in the envisioned calculation routines. Where data in the automatic system are corrupted or missing whilst the plant is producing adipic acid (as shown, for example, by feedstock and production data) the missing data can be estimated by taking the lower of the average value for the parameter in question in the hour before the error arose or the hour immediately after the system came automatic again. If there is evidence to suggest that both of these values are un-representative, the average from the previous 2 hours will be used (for example, gas concentrations may be un-representative immediately before and immediately after a shut-down). The error will be recorded in the daily log sheet and the occurrence of the error will be investigated and rectified as soon as possible. If the automatic system is compromised for more than 2 hours, data will be manually recorded., it does. Annex 3 provides useful information enabling a better understanding of the envisioned monitoring provisions e.g. for net calorific value NCV NG and the emission factor EF NG D.1.1. Option 1 Monitoring of the emissions in the project scenario and the baseline scenario: D Data to be collected in order to monitor emissions from the project and how these data will be archived: D Is the list of parameters collected in order to monitor emissions from the project in chapter D.1.1. considered to be complete with regard to the requirements of the applied methodology?, 9, 10, 11, 12, The list of parameters follows in principle needs and suggestion with regard to requirements of AM0021 but it s important to note that several deviations to AM0021 seriously exist. Such deviations are unavoidable related to the fact that the project addresses an already existing abatement unit and an additional re- CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-16

35 Number of Pages: 5 13, 1, 15, 16 dundant abatement unit which had to be integrated. Hence AM0021 is published for a single unit the environment of required parameters needed to be adjusted. Expressively JI allows such deviations if they are explained adequate. To sight of TÜV SÜD assessment team the fulfils these requirements in principle. Nonetheless it s necessary to point above a CAR. Variances as stated in current are described as follows: Project emissions Related to the project emissions its to mention that the quantity of N2O by-passing the thermal decomposition facilities is not determined as in AM0021 but by monitoring the flow and the concentration of the waste gas of the Selective Catalytic Reduction plant (SCR). Both parameters concentration and flow - are measured at the entry of the SCR facility. The SCR has no effect on the share of N2O in the waste gas. The quantity of N2O which had not destroyed in the thermal decomposition facilities is calculated by constantly monitoring the flow and the N2O concentration of the waste gas. Waste gas flow is determined before the thermal decomposition facilities by adding different input flows, which are measured in total by addition. A measurement of the waste gas behind the thermal decomposition facility is not applicable due to project specific technical reasons. Main reasons for this methodology deviation are the large diameter of the chimney and the expected influence of pressure drop in the thermal decomposition facilities. N2O concentration of the waste gas is measured behind the thermal decomposition facilities. CO2 emissions of the consumption of natural gas are derived by measuring natural gas consumption and multiplying it with a de- Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-17

36 Number of Pages: 5 fault net calorific value and emission factor. Baseline emissions: The baseline emissions regarding N2O are calculated by measuring the amount of adipic acid produced and multiplying it with the baseline N2O emission factor. Baseline emissions regarding CO2 from natural gas consumption are calculated by multiplying the amount of adipic acid produced with the baseline CO2 emission factor. Calculations: The flow rate is captured on ideal combustion calculation at the gas flow entry of abatement unit. The following parameters are required for calculation Q_WGy - The waste gas flow in m³ per year FC_NG y - The consumption of natural gas per year Q_FA1 y - The input flow of fresh air to the waste gas pipe per year Q_FA2 y - The input flow of fresh air to the second firing chamber per year Q_W y - The input of water to the burner lance per year Q_Steam y - The input of steam to the burner lance per year Q_CA y - The input of compressed air to the burner lance per year The emissions due to project activity in a year y (PE y ) are the emissions due to the by-pass of the thermal decomposition facility 1 (TD 1) and the redundant thermal decomposition facility (TD 2) in the unlikely case that both facilities are shut down at the same time, the emissions of N2O not destroyed in thermal decomposition facility 1 and thermal decomposition facility 2 and the emissions due to natural gas use in thermal decomposition facility 1, thermal decomposition facility 2 and in selective catalytic reduc- Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-18

37 Number of Pages: 5 tion plant (SCR). The quantity of N2O not destroyed (ND_N 2 O y ) is obtained by constantly monitoring the flow (Q_GE) and the N2O concentration (N 2 O_GE) of the waste gas of both thermal decomposition processes. The concentration of the N2O is measured behind both thermal decomposition processes. The flow of the waste gas (Q_GE y ) is measured before the thermal decomposition facilities by adding the different input parameters. Corrective Action Request 3: The derivation of flow rate is plausible and mathematical correct arranged. To view of TÜV SÜD Assessment team it is however to annotate that the evaluation, which set up on the derivation of an ideal combustion and stoichiometric complete conversion, is just a theoretical approach. In the in current revision the real uncertainty of the aforementioned theoretic derivation is neither detailed demonstrated nor detailed calculated. It is necessary to add further explanation and precise calculation about the uncertainty of flow rate approach. It is necessary to add hard proofs for calculations of uncertainty or to discuss an alternative measurement strategy. In case of change of measurement strategy it is necessary to update the list of parameters with regard to the requirements of AM0021. It is necessary to point out existing deviation to AM0021. D Parameter Title: Q_GE TD1y Flow rate, 11, 12, Data Checklist Title in line with methodology? Data unit correctly expressed? / No See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-19

38 Number of Pages: 5 13, 1, 15, 16 Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? N/A No This parameter will be calculated from Q_WG TD1y, FC_NG TD1y, Q_FA1 TD1y, Q_FA2 TD1, Q_W TD1, Q_Steam TD1, Q_CA TD1 The value is to be verified later by the verifying entity. Please refer to D D Parameter Title: Q_WG TD1y Input flow of waste gas, 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-20

39 Number of Pages: 5 D Parameter Title: FC_NG TD1y Consumption of natural gas D Parameter Title: Q_FA1 TDy Input flow of fresh air to the waste gas pipe, 11, 12, 13, 1, 15, 16, 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D See CAR3 See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-21

40 Number of Pages: 5 D Parameter Title: Q_FA2 TD1y Input flow of fresh air to the second firing chamber D Parameter Title: Q_W TD12 Input of water to the burner lance, 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D See CAR3 See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-22

41 Number of Pages: 5 D Parameter Title: Q_Steam TD1 Input of steam to the burner lance D Parameter Title: Q_CA TD1 Input of compressed air to burner lance, 11, 12, 13, 1, 15, 16, 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D See CAR3 See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-23

42 Number of Pages: 5 D Parameter Title: N2O _GE _1 TD1 N2O in gaseous effluent D Parameter Title: N2O _GE _2 TD1 N2O in gaseous effluent, 11, 12, 13, 1, 15, 16 3,, 5, 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? LANXESS installed a non-dispersive infra-red N2O analyzer (type Sick Maihak MC100). The value is to be verified later by the verifying entity. See CAR3 See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-2

43 Number of Pages: 5 D Parameter Title: Q_GE TD2y Flow rate (redundant thermal decomposition), 11, 12, 13, 1, 15, 16 Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? / No N/A No See CAR3 This parameter will be calculated from Q_WG TD2y, FC_NG TD2y, Q_FA1 TD2y, Q_FA2 TD2, Q_W TD2, Q_Steam TD2, Q_CA TD2 The value is to be verified later by the verifying entity. Please refer to D D Parameter Title: Q_WG TD2y Input flow of waste gas (redundant thermal decomposition), 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-25

44 Number of Pages: 5 D Parameter Title: FC_NG TD2y Consumption of natural gas (redundant thermal decomposition) D Parameter Title: Q_FA1 TD2 Input flow of fresh air to the waste gas (redundant thermal decomposition), 11, 12, 13, 1, 15, 16, 11, 12, 13, 1, 15, 16 Please refer to D Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D See CAR3 See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-26

45 Number of Pages: 5 D Parameter Title: Q_FA2 TD2y Input flow of fresh air to the second firing chamber (redundant thermal decomposition), 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D See CAR3 D Parameter Title: Q_W TD2 Input of water to the burner lance (redundant thermal decomposition), 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-27

46 Number of Pages: 5 D Parameter Title: Q_Steam TD2 Input of steam to the burner lance (redundant thermal decomposition), 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D See CAR3 D Parameter Title: Q_CA TD2 Input of compressed air to burner lance (redundant thermal decomposition), 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-28

47 Number of Pages: 5 D Parameter Title: N2O _GE _1 TD2 N2O in gaseous effluent (redundant thermal decomposition), 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. Please refer to D See CAR3 D Parameter Title: N2O _GE _2 TD2 N2O in gaseous effluent (redundant thermal decomposition), 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? LANXESS will install a non-dispersive infra-red N2O analyzer. Provider and type of the analyzer had not been decided by LANXESS at date of on-site mission. See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-29

48 Number of Pages: 5 Type and QAL1 certification is to be verified later by the verifying entity. Please refer to D D Parameter Title: Q_GE SCR Effluent gas, 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The effluent will be measured at entry of the SCR at measurement orifice with pressure differential transmitter. Provider and type of the pressure differential transmitter had not been decided by LANXESS at date of on-site mission. Type and QAL1 certification is to be verified later by the verifying entity. Please refer to D See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-30

49 Number of Pages: 5 D Parameter Title: N2O_GE SCR N2O in gaseous effluent D Parameter Title: Q_N2O_bypass N2O bypassing the thermal decomposition facility, 11, 12, 13, 1, 15, 16, 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? LANXESS will install a non-dispersive infra-red N2O analyzer. Provider and type of the analyzer had not been decided by LANXESS at date of on-site mission. Type and QAL1 certification is to be verified later by the verifying entity. Please refer to D Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? / No N/A No See CAR3 See CAR3 Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-31

50 Number of Pages: 5 D Parameter Title: FC_NG SCR Consumption of natural gas, 11, 12, 13, 1, 15, 16 This parameter will be calculated and is to be verified later by the verifying entity. Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? The value is to be verified later by the verifying entity. See CAR3 D Parameter Title: NCV NG Net caloric value, 11, 12, 13, 1, 15, 16 Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? The value is given in Annex 3. / No Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-32

51 Number of Pages: 5 D Parameter Title: EF NG Emissions factor, 11, 12, 13, 1, 15, 16 Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? The value is given in Annex 3. / No D Parameter Title: Q_NG CO2 emissions of natural gas consumption, 11, 12, 13, 1, 15, 16 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? N/A Has this value been verified? No Choice of data correctly justified? Measurement method correctly described? This value is calculated and shows the sum of CO2 emissions of natural gas consumption at SCR, TAL1 and the later redundant TAL2. The value is to be verified later by the verifying entity. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-33

52 Number of Pages: 5 D Description of formulae used to estimate project emissions (for each gas, source etc.; emissions in units of CO 2 equivalent D Are the formulae required for the determination of project emissions cor- The formulae required for the determination of project emissions, they are. rectly presented, enabling a complete identification of parameter to be used are correctly presented, enabling a complete identification of parameter to be used and monitored and / or monitored? D Are the formulae required for the derivation of a moving average emission factor correctly presented, enabling a complete identification of parameter to be used and / or monitored? D Are the formulae required for the determination of leakage emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? The formulae required for the derivation of a moving average emission factor are correctly presented enabling a complete identification of parameter to be used and monitored: Equation (1): The emissions due to project activity in a year y PEy Equation (2): The concentration of the N2O (behind both thermal decomposition processes) ND_N 2 O y Equation (3): The flow waste gas Q_GE y Equation (): The quantity of N2O bypassing the thermaöl decomposition facilities Q_N2O_bypass y Equation (5): The quantity of CO2 emissions due to natural gas combustion Q_NG y Besides natural gas, the facility also uses electricity and steam, leading to emissions outside the project boundaries and thus would count as leakage. As both electricity and steam are generated within facilities underlying the Emission Trading Scheme, associated emissions must not be considered, as this would lead to double counting. Same procedure is applied to steam produced within the thermal decomposition facilities and feed in a district heating system. Therefore consideration of leakage emissions is not applicable within this JI project. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-3

53 Number of Pages: 5 D Relevant data necessary for determining the baseline of anthropogenic emissions of greenhouse gases by sources within the project boundary, and how such data will be collected and achieved: D Is the list of parameters monitored in chapter D.1.3. considered to be complete with regard to the requirements of the applied methodology? D Is the data provided in this section in consistency with data as presented in other chapters of the?, it is. The baseline emissions regarding N2O are calculated by measuring the amount of adipic acid produced and multiplying it with the baseline N2O emission factor EF_N2O Baseline. Baseline emissions regarding CO2 from natural gas consumption are calculated by multiplying the amount of adipic acid produced with the baseline CO2 emission factor EF_NG Baseline The data provided in this section are in consistency with data as presented in other chapters of the? Integrate the required amount of sub-checklists for monitoring parameter and comment on any line answered with No D Parameter Title: Q_N2O_baseline Quantity of N2O emissions bypassing Monitoring Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Has this value for estimation been verified? Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-35

54 Number of Pages: 5 Q_N2O_baseline is required for calculation of EF_N2O baseline The data basis for calculation had been crosschecked during onsite mission based on production log sheets about adipic acid and associated relevant key parameters on hourly base from the years 2002 to D Parameter Title: P_AdOH Adipic acid produced Monitoring Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? N/A Has this value been verified? No Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? P_AdOH will calculated as sum of P_AdOH lorries P_AdOH big-bag This parameter will be used for future annual reporting. D Parameter Title: P_AdOH lorries Adipic acid filled in lorries Monitoring Checklist / No Title in line with methodology? Data unit correctly expressed? Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-36

55 Number of Pages: 5 Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? N/a Has this value been verified? No Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? This parameter will be used for future annual reporting. This parameter will be used for future annual reporting. D Parameter Title: P_AdOH big-bag Adipic acid filled in big-bags Monitoring Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? N/a Has this value been verified? No Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? This parameter will be used for future annual reporting. This pa- Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-37

56 Number of Pages: 5 rameter will be used for future annual reporting. D Parameter Title: EF_N2O Baseline Historical emission factor, 11, 12, 13, 1, 15, 16 Monitoring Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Has this value been verified? Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? The data basis for calculation had been crosschecked during onsite mission based on production log sheets about adipic acid and associated relevant key parameters on hourly base from the years 2002 to 2006.TÜV SÜD assessment team confirms the historical emission factor EF_N2O Baseline and its plausibility. The assessment team performed a detailed double check for year D Parameter Title: Q_NG_baseline CO2 emissions of natural gas used, 11, 12, Monitoring Checklist Title in line with methodology? Data unit correctly expressed? / No Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-38

57 Number of Pages: 5 13, 1, 15, 16 Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Has this value for estimation been verified? Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? Q_NG_baseline was calculated as product of adipic acid production and historical emission factor natural gas. The data basis for calculation had been crosschecked during onsite mission based on production log sheets about adipic acid and associated relevant key parameters and based on flow rate log sheets about natural gas consumption on hourly base from the years 2002 to 2006.TÜV SÜD assessment team crosschecked the plausibility of P_AdOH y and EF_NG baseline. D EF_NG Historical emission factor natural gas, 11, 12, 13, 1, 15, 16 Monitoring Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Has this value been verified? Measurement method correctly described? / No Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-39

58 Number of Pages: 5 Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? The data basis for calculation had been crosschecked during onsite mission based on flow rate log sheets about natural gas consumption on hourly base from the years 2002 to 2006.TÜV SÜD assessment team confirms the historical emission factor EF_NG Baseline and its plausibility. The assessment team performed a detailed double check for year D Description of formulae used to estimate baseline emissions (for each gas, source etc.; emissions in units of CO 2 equivalent) D Are the formulae required for the determination of baseline emissions cor- are correctly presented enabling a complete identification of pa- The formulae required for the determination of baseline emissions rectly presented, enabling a complete rameter to be used and monitored: identification of parameter to be used Equation (6): The Baseline emissions BE y and / or monitored? Equation (7): The quantity of N2O by-passing in the baseline Q_N 2 O_baseline y Equation (8): The amount of adipic acid produced P_AdOHy Equation (9): The CO2 emissions regarding the fuel input to operate the thermal decomposition processes Q_NG_baseline y D Are the formulae required for the determination of leakage emissions correctly presented, enabling a complete No leakage calculation is required. LANXESS shows plausible that besides natural gas, the facility also uses electricity and steam, leading to emissions outside the Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-0

59 Number of Pages: 5 identification of parameter to be used and / or monitored? D Are the formulae required for the determination of emission reductions correctly presented? project boundaries and thus would count as leakage. As both electricity and steam are generated within facilities underlying the European Emission Trading Scheme (EU-ETS), associated emissions must not be considered, as this would lead to double counting. Same procedure is applied to steam produced within the thermal decomposition facilities and feed in a district heating system. Therefore consideration of leakage emissions is not applicable within this JI project. The formulae required for the determination of emission reductions are correctly presented: The ghg emission reductions of the project activity in a year are the baseline emissions of the adipic acid facility based on the historic emissions factor less the ghg emissions generated by the thermal decomposition facility 1, thermal decomposition facility 2 and selective catalytic reduction plant. Equation (10): Emission Reduction ER y D.2. Quality control (QC) and quality assurance (QA) procedures undertaken for data monitored: D.2.1. Are the approaches about quality control (QC) and quality assurance (QA) procedures undertaken for data being monitored are clearly described in the? D.2.2. Does the list of data being monitored (Indicate table and ID number) completed and correlates the list with data listed in other sections of the?, they are. The approaches about quality control and quality assurance procedures are clearly described., it does. The list of data, indicated table and ID number is completed and correlates with data listed in other sections of the. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-1

60 Number of Pages: 5 D.2.3. Are uncertainty levels for each data (high/medium/low) shown? D.2.. Are the QA/QC procedures planned for these data clearly explained or if not applicable is clearly explained why such procedures are not necessary?, they are. Uncertainty levels for each data are shown and categorised high, medium and low., they are. The QA/QC procedures are clearly explained. There are no deviations from common industrial practice. D.3. Description of the operational and management structure that the project operator will apply in implementing the monitoring plan: D.3.1. Are the operational and management structure that the project operator will apply in implementing the monitoring plan are clearly described?, they are. Data will be collected by a data acquisition system (PI system). Data from the process control system will be transferred to the server of the data acquisition system and stored tampa-resistant. Changes regarding the data will be logged automatically. For preparing the monitoring report, data are available at the server. The PI System is in compliance with the FDA regulations and regulations known as 21 CFR Part 11, which is concerned with the authenticity, integrity and confidentiality of electronic records and signatures. Computer systems must be validated to ensure the accuracy, reliability, and consistency of operations, and their ability to identify invalid or altered records. A key requirement for compliance is the ability of the system to create an audit trail, or audit management database. This database must provide a secure log of all attempts to access or log onto the system, together with the operations performed. For data which are not automatically recorded in the data acquisition system, a responsible proc- Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-2

61 Number of Pages: 5 D.3.2. Are the storage procedures of the monitoring data clearly described? ess engineer is in charge of all data collection activities., they are. Additional had to be noted that to ensure availability of data in case of malfunctions regarding the measurement of N2O in the waste gas stream of the selective catalytic reduction plant, the quantity of N2O by-passing can be determined by considering the following parameters: 1. Consumption of KA-oil 2. Consumption of ammonia in SCR 3. Consumption of natural gas in thermal decomposition facilities D.. Date of completion of the application of the baseline study and monitoring methodology and the name of the responsible person(s)/entity(ies) D..1. Is there any indication of a date when the baseline was determined?, 11, 12, 13, 1, there is. Historical emissions are the average N2O emissions during the years 2002 until 2006 and CO2 emissions regarding steam production by the decomposition process during the years 2002 until Using a period of five years provides a wide and representative data base. To exclude the possibility of manipulating the production process of increase the residual N2O emission, the year 2007 won t be included in the calculation. N2O emissions of the year 2006 were lower than N2O emissions in the years 2002 until To be conservative they are included in calculation of baseline emissions. The quality of data before the year 2002 is not adequate for baseline setting, because there were no requirements to monitor data in an adequate quality. In summary it can be ascertained that historic emissions during Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-3

62 Number of Pages: 5 D..2. D..3. D... Is this consistent with the time line of the history? Is the information on the person(s) / entity (ies) responsible for the application of the baseline and monitoring methodology provided consistent with the actual situation? Is information provided whether this person / entity is also considered a project participant? E. Estimation of greenhouse gas emission reduction E.1. Estimate project emissions: E.1.1. E.1.2. E.1.3. Are the GHG calculations documented in a complete and transparent manner? Is the data provided in this section consistent with data as presented in other chapters of the? Are the estimated project emissions transparent, feasible and mathematical the years 2002 until 2006 are a representative period which allows high accuracy and conservative baseline setting. All data sets of the years 2002 until 2006 had been submitted to TÜV SÜD assessment team for cross checking., it is. The information is consistent with the actual situation. The baseline estimate was prepared by FutureCamp GmbH. FutureCamp GmbH is no project participant and works as a consultant on contract for LANXESS. Information about the baseline setting entity is shown in section B.. of the. The calculation of the emission projections are presented in a transparent and complete manner. The data provided in this section is consistent with data as presented in other chapters of the., they are. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-

63 Number of Pages: 5 correct calculated? E.1.. Is the projection of estimated project emissions based on the same procedures as used for future monitoring? E.2. Estimated leakage: E.2.1. Is the estimated leakage transparent, feasible and mathematical correct calculated? E.2.2. Is the projection of estimated leakage based on the same procedures as used for future monitoring? E.3. The sum of E.1. and E.2.: E.3.1. Is the sum of E.1. and E.2. mathematically correct calculated? E.. Estimated baseline emissions: E..1. Are the estimated baseline emissions transparent, feasible and mathematically The projection is done by the same algorithms as used for later monitoring. As established in the approved methodology AM0021 the consideration of leakage emissions is not applicable. Leakage emissions comprise the emissions associated with the energy sources used to generate steam and electricity to operate the thermal decomposition plant. In this project leakage is not considered because the installations that supply steam and electricity to the already existing and planned redundant thermal decomposition plant are covered by the EU Emission Trading Scheme. To avoid double counting these emissions are not treated within this JI project. The projection is done by the same algorithms as used for later monitoring. Please refer to E As there are no leakage emissions (i.e. E.2. = 0), the sum of E.1. (estimated project emissions) and E.2. (estimated leakage) equals E.1. (estimated project emissions), they are. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-5

64 Number of Pages: 5 correct calculated? E..2. Is the projection based on the same procedures as used for future monitoring? The projection is done by the same algorithms as used for later monitoring. E.5. Difference between E.. and E.3. representing the emissions reductions of the project: E.5.1. Is the difference between E.. and E.3. mathematically correct calculated? E.6. Table providing values obtained when applying formulae above E.6.1. Will the project result in fewer GHG emissions than the baseline scenario? E.6.2. Is the form/table required for the indication of projected emission reductions correctly applied? E.6.3. Is the projection in line with the envisioned time schedule for the project s implementation and the indicated crediting period? E.6.. Is the data provided in this section in consistency with data as presented in other chapters of the? E.6.5. Are the obtained values for estimated project emissions, estimated leakage, estimated baseline emissions and estimated emissions reductions provided in the table of E.6. transparent, feasible and mathematical correct calculated when applying, it is. The project activity will result in emission reductions The form/table required for the indication of projected emission reductions is correctly applied. The projection is in line with the envisioned time schedule. The data provided in this section are in consistency with data as presented in other chapters of the?, they are. The obtained values in the table of E.6. are transparent, feasible and mathematical correct calculated. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-6

65 Number of Pages: 5 formulae submitted in section E.? F. Environmental impacts F.1. Documentation on the analysis of the environmental impacts, including transboundary impacts F.1.1. Has the analysis of the environmental impacts of the project activity been sufficiently described? F.1.2. F.1.3. Are there any Host Party requirements for an Environmental Impact Assessment (EIA), and if yes, has an EIA been approved? Will the project create any adverse environmental effects?, 18, 19, 20, 21, 22, 23, it has. The analysis of the environmental impacts of the project activity has been sufficiently described. The Project Participant stated that environmental impacts from the project activity are negligible due to the fact that the project activity comprises only the installation of a small additional facility at the industrial park in Krefeld without any additional land consumption, emissions of pollutants or use of hazardous material and the additional consumption of natural gas is negligible. TÜV SÜD assessment team shares the environmental impact analyse of LANXESS. The Project participants stated that negative environmental impacts are not expected significant and that an environmental impact assessment is not necessary. Nonetheless a justification related to mandatory requirements why an EIA had not been conducted is not published in. Corrective Action Request : Due to fact that no EIA had been undertaken it is necessary to explain the German requirements for EIA in this specific situation. If any EIA for the already existing thermal decomposition plant exists it is necessary to explain its validity and eligibility to the planned second thermal decomposition plant. No, it will not. Negative environmental impacts are not considered significant by CAR Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-7

66 Number of Pages: 5 CHECKLIS T TOPIC / QUESTION Ref. COMMENTS F.1.. Were transboundary environmental impacts identified in the analysis? the project participant. There were no transboundary environmental impacts. F.2. If environmental impacts are considered significant by the project participants or the host Party, please provide conclusions and all references to support documentation of an environmental impact assessment undertaken in accordance with the procedures as required by the host Party F.2.1. F.2.2. Have the identified environmental impacts been addressed in the project design sufficiently? Does the project comply with environmental legislation in the host country? G. Stakeholders comments, 10, 11 No environmental impacts had been identified. TÜV SÜD assessment team remarks that the project has a strong positive environmental impact, since the primary object of the project is reduction of N2O emissions., it does. The relevant project information are published at Nov. 15, 2007 on webpage of DEHSt (Deutsche Emissionshandelsstelle = Designated Focal Point for JI/CDM project implementation in Federal Republic of Germany): CDM/JI/JI Vali dierung/ji Validierung node.html? nnn=true G.1. Brief description how comments by local stakeholders have been invited and compiled G.1.1. Have relevant stakeholders been consulted? The PP stated that a stakeholder consultation is not applicable, as the project activity is to install a redundant facility with the same technology. Therefore it is a copy of the existing facility which is located at the same site as the already existing thermal decomposition facility. A stakeholder consultation in addition to the Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-8

67 Number of Pages: 5 CHECKLIS T TOPIC / QUESTION Ref. COMMENTS G.1.2. Have appropriate media been used to invite comments by local stakeholders? G.1.3. If a stakeholder consultation process is required by regulations/laws in the host country, has the stakeholder consultation process been carried out in accordance with such regulations/laws? G.1.. Is the undertaken stakeholder process that was carried out described in a complete and transparent manner? G.2. Summary of the comments received G.2.1. Is a summary of the received stakeholder comments provided? G.3. Report on how due account was taken of any comments received G.3.1. H. Annexes 1 3 Has due account been taken of any stakeholder comments received? H.1. Annex 1: Contact Information H.1.1. H.1.2. Is the information provided consistent with the one given under section A.3? Is the information on all private participants and directly involved Parties pre- publication within the JI stakeholder process is not planed. Not applicable, because no local stakeholder consultation had been carried out. Please refer to G.1.1. Not applicable, because no local stakeholder consultation had been carried out. Please refer to G.1.1. Not applicable, because no local stakeholder consultation had been carried out. Please refer to G.1.1. Not applicable, because no local stakeholder consultation had been carried out. Please refer to G.1.1. Not applicable, because no local stakeholder consultation had been carried out. Please refer to G.1.1., it is;, it is; Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-9

68 Number of Pages: 5 CHECKLIS T TOPIC / QUESTION Ref. COMMENTS sented? H.2. Annex 2: Baseline information H.2.1. H.2.2. If additional background information on baseline data is provided: Is this information consistent with data presented by other sections of the? Is the data provided verifiable? Has sufficient evidence been provided to the determination team? H.2.3. Does the additional information substantiate / support statements given in other sections of the? H.3. Annex 3: Monitoring information H.3.1. If additional background information on monitoring is provided: Is this information consistent with data presented in other sections of the?, it is;, it is. Sufficient evidence been has been provided to the determination team. Historical emissions are the average N2O emissions during the years 2002 until 2006 and CO2 emissions regarding steam production by the decomposition process during the years 2002 until Using a period of five years provides a wide and representative data base which allows high accuracy and conservative baseline setting. TÜV SÜD assessment team confirmed the value of the historical emission factor N20 (0,0298) and the value of the historical emission factor natural gas (0,1717)., it does;, it is; H.3.2. Is the information provided verifiable? Has, it is; Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-50

69 Number of Pages: 5 H.3.3. sufficient evidence been provided to the validation team? Do the additional information and / or documented procedures substantiate / support statements given in other sections of the?, it does; Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-51

70 Number of Pages: 5 Table 2 Resolution of Corrective Action and Clarification Requests Clarifications and corrective action requests by validation team Corrective Action Request 1: It is necessary to describe clearly the facility s operational and management structure (function owner and their responsibilities). Corrective Action Request 2: It is necessary to provide clearly the facility s responsibilities and institutional arrangements for data collection and archiving (function owner and their responsibilities). Corrective Action Request 3: The derivation of flow rate is plausible and mathematical correct arranged. To view of TÜV SÜD Assessment team it is however to annotate that the evaluation, which set up on the derivation of an ideal combustion and stoichiometric complete conversion, is just a theoretical approach. In the in current revision the real uncertainty of the aforementioned theoretic derivation is neither detailed demonstrated nor detailed calculated. It is necessary to add further explanation and precise calculation about the uncertainty of flow rate approach. It is necessary to add hard proofs for calcula- Ref. to table 1 Summary of project owner response Validation team conclusion D Adjusted in chapter D.3 of the The issue is solved. D Adjusted in chapter D.3 of the The issue is solved. D To increase accuracy of the N 2 O emissions monitoring results and decrease uncertainties the measurement strategy of project emissions is changed as follows: The quantity of N 2 O not destroyed in the thermal decomposition facilities is calculated by constantly monitoring the flow and the N 2 O concentration of the waste gas, where both parameters are measured behind the thermal decomposition facilities. The list of parameters is updated in chapter D with regard to requirements of AM0021. According to these changes the figure in chapter B.3, showing the project boundary, and information about Quality control (QC) and quality assurance (QA) procedures of the parameters in chapter D.2 and Annex 3 are adjusted. The issue is solved. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-52

71 Number of Pages: 5 tions of uncertainty or to discuss an alternative measurement strategy. In case of change of measurement strategy it is necessary to update the list of parameters with regard to the requirements of AM0021. It is necessary to point out existing deviation to AM0021 Corrective Action Request : Due to fact that no EIA had been undertaken it is necessary to explain the german federal requirements for EIA in this specific situation. If any EIA for the already existing thermal decomposition plant exist it is necessary to explain its validity and assignability to the planned second thermal decomposition plant. F.1.2. Adjusted in chapter F.1. in the as follows: According to the licensing notice ( /3618) for the already existing thermal decomposition plant it is stated, that negative environmental impacts from the installation of the thermal decomposition plant are not expectable. As the project activity is the installation of a redundant facility with the same technology, located at the same site as the already existing thermal decomposition facility, negative environmental impacts are not expectable as well. The issue is solved Clarification Request 1: It is necessary to explain the adjustment from 200 to 2005 in case of installed capacity. B.1.6 The installed capacity of the adipic acid plant was in year 200 above the licensed capacity. In year 2005 the former true installed capacity had been licensed by the authorities subsequent. It had to be noted that the measure is the installed and not the authorized capacity. Like this there is - in technical sense - no deviation from 200 to The issue is solved. Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-53

72 Number of Pages: 5 Clarification Request 2: It is necessary to offer a current explanation if or if not (and if for which parameters) the aforementioned European Norm EN1181 (200) would been taken into account? D Parts of the monitoring system will be configured in dependence on the requirements of the latest applicable European standards and norms (EN 1 181). Following parameters are concerned: 1. Infra-Red analyzer in the chimney of thermal decomposition facility 1 2. Infra-Red analyzer in the chimney of thermal decomposition facility 2 3. Infra-Red analyzer in selective catalytic reduction plant Table 3 Unresolved Corrective Action and Clarification Requests (in case of denials) Clarifications and / or corrective action requests by validation team Id. of CAR/CR Explanation of Conclusion for Denial Table 1 is applicable to AM0021 / project specific LANXESS adipic acid production Page A-5

73 Determination of the JI Track 1 Project: Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Germany Annex 2: Information Reference List

74 Report Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Federal Republic of Germany Page 1 of 2 Reference Document or Type of Information No. 1 UNFCCC homepage including the Joint Implementation section ji.unfccc.int 2 Approved methodology AM0021 / Version 02 3 Tool for the demonstration and assessment of additionality / Version 03 Project Design Document for JI project Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, dated November 08, 2007, as available 5 On-site interviews conducted on November 15-16, 2007 in Krefeld-Uerdingen, Federal Republic of Germany by auditing team of TÜV SÜD Verification team: Nikolaus Kröger TÜV SÜD, assessment team leader (on-site mission) Thomas Kleiser TÜV SÜD, technical expert (HQ based) Interviewed persons in Krefeld-Uerdingen, Federal Republic of Germany: Mr Bernd Kaletta, PhD LANXESS Deutschland GmbH, Industrial & Environmental Affairs, Mr Karl-Heinz Mix, PhD LANXESS Deutschland GmbH, plant manager and head of production, Manufacturing LXS-SCP Mr Jürgen Kadelka, PhD LANXESS Deutschland GmbH, head of manufacturing, LXS-BU-SCP Mr Thomas Hellmich LANXESS Deutschland GmbH, head of technology, LXS-SCP-BLAA Mr Stefan Hudl LANXESS Deutschland GmbH, assistant to works manager, LXS-SCP-AA Mr Davids-Vahsen LANXESS Deutschland GmbH, foreman adipic acid plant, LXP-SCP-BLAA Mr Markus Rothe FutureCamp GmbH, project manager ghg-emission trading and climate protection projects, consultant 6 LANXESS Deutschland GmbH homepage 7 Project implementation schedule, submitted by LANXESS November 15, Letter of Endorsement (LoE) had been submitted by the DEHSt (Deutsche Emissionshandelsstelle = Designated Focal Point for JI/CDM project implementation in Federal Republic of Germany)on May 10, Presentation of JI project LARA (Lachgasreduktionsanlage), project implementation, concept of abatement, technical schemes, discussion of shut down events compared to standard conditions etc., submitted by LANXESS, Dr. Kaletta at November 15, Presentation of adipic acid production, chemical process, history, capacity etc., submitted by LANXESS, Dr. Mix at November 15, Log sheets of adipic acid production and associated relevant key parameters on hourly base from the years 2002 to 2006, submitted by LANXESS at November 16, 2007 TÜV SÜD INDUSTRIE SERVICE GMBH

75 Report Redundant thermal decomposition of residual nitrous oxide (N2O) from the LANXESS adipic acid production in Krefeld-Uerdingen, Federal Republic of Germany Page 2 of 2 Reference Document or Type of Information No. 12 Log sheets of KA-Oil consumption on hourly base from the years 2002 to 2006, submitted by LANXESS at November 16, Log sheets of ammonia consumption on hourly base from the years 2002 to 2006, submitted by LANXESS at November 16, Log sheets of natural gas consumption on hourly base from the years 2002 to 2006, submitted by LANXESS at November 16, Evaluation study about exit flow rate on basis of entry flow rate including associated stoichiometric equations, submitted by LANXESS at November 16, N2O emissions resulting from adipic acid production average on monthly base from the years 2002 to 2006, submitted by LANXESS at November 16, project information on webpage of DEHSt (Deutsche Emissionshandelsstelle = Designated Focal Point for JI/CDM project implementation in Federal Republic of Germany), published at Nov. 15, CDM/JI/JI Validierung/JI Validierung node.html? nnn=true 18 ProMechG (Linking Flexible Mechanisms Act) of Federal Republic of Germany BImSchG (Clean Air Protection Act) of Federal Republic of Germany Reference Document on Best Available Techniques for the Manufacture of Large Volume Inorganic Chemicals Ammonia, Acids and Fertilisers, submitted December 2006 by the European Commission 21 Validation and Verification Manual, IETA/World Bank (PCF), // determination protocol (as background information) Revised IPCC Guidelines 23 IPCC Good Practice Guidance and Uncertainty Management Genehmigungsbescheid (License for operation), submitted bei Regierungspräsident Düsseldorf at February 27, 1991 TÜV SÜD INDUSTRIE SERVICE GMBH