Orica Canada Inc. Nitrous Oxide Abatement from Nitric Acid Production Project NAP2

Transcription

1 Nitrous Oxide Abatement from Nitric Acid Production Project NAP2 Verification Report March 7, 2017 ICF Consulting Canada, Inc. 400 University Avenue, 17 th Floor Toronto, Ontario M5G 1S5

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3 Statement of Verification March 7, 2017 Executive Director Air and Climate Change Policy Branch Alberta Environment and Parks 12th Floor, Baker Centre Street NW Edmonton, Alberta T5J 1G4 Introduction Capital Power Corporation ( Capital Power ) engaged ICF Consulting Canada, Inc. ( ICF ) to review their GHG Assertion Alberta Offset System Greenhouse Gas Assertion of Emissions Reduction Credits and supporting evidence, covering the period January 1, 2016 December 31, 2016 ( GHG Assertion ). The GHG Assertion, dated January 18, 2017, specifies a claim for 232,848 tonnes CO 2 e over the aforementioned period, which resulted from a nitrous oxide abatement from nitric acid production offset project based on the Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production, October 2009, Version 1.0. The claim consists exclusively of 2016 vintage credits. The Party ( Orica ) is responsible for the preparation and presentation of the information within the GHG Assertion. Our responsibility is to express our opinion as to whether the GHG Assertion is materially correct, in accordance with Alberta Environment s approved quantification methodology Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production, October 2009, Version 1.0 ( Protocol ) for this project; the Specified Gas Emitters Regulation (Alberta Reg.139/2007) ( Regulation ), and the associated guidance documents. Scope We completed our review in accordance with the ISO Part 3: Greenhouse Gases: Specification with guidance for the validation and verification of greenhouse gas assertions (ISO, 2006). As such, we planned and performed our work in order to provide reasonable, but not absolute assurance with respect to the GHG Assertion. Our review criteria were based on the Protocol, the Regulation, and the associated guidance documents. We reviewed Orica Nitrous Oxide Abatement from Nitric Acid Production Offset Project Plan dated February 2015; GHG Assertion; and associated documentation. We developed the verification procedures based on the results of a risk assessment that we conducted during the planning stage. The verification procedures are identified in the Verification Plan and the details of any data sampling that was conducted are provided in the Sampling Plan (both plans are appended to the Verification Report). We believe our work provides a reasonable basis for our conclusion.

4 Conclusion One unresolved immaterial misstatement remains in the GHG Assertion as detailed in the Verification Report. Based on our review, it is our opinion to a reasonable level of assurance that the GHG emissions reductions contained in the GHG Assertion are materially correct and presented fairly in accordance with the relevant criteria. Selena Fraser, P.Eng. Professional Engineer, Ontario ( ) Lead Verifier ICF Consulting Canada, Inc. Ottawa, Ontario Duncan Rotherham Vice President and Managing Director ICF Consulting Canada, Inc. Toronto, Ontario

5 1. Verification Summary Lead Verifier: Associate Verifier: Internal Peer Reviewer: Selena Fraser. P.Eng. Sheldon Fernandes Julie Tartt Verification Timeframe: October 2016 to March 2017 Objective of the verification: Assurance being provided to: Standard being verified to: Verification criteria employed: Verification scope Gases: Reasonable assurance on GHG Assertion for Emissions Reductions Credits Alberta Environment and Parks ISO :2006 Specification with guidance for the validation and verification of greenhouse gas assertions Climate Change and Emissions Management Act Specified Gas Emitters Regulation (Alberta Regulation 139/2007) Technical Guidance for Offset Project Developers, Version 4.0, February 2013 Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013 Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production, October 2009, Version 1.0 Nitrous Oxide Project Title: Location: Project Start Date: May 12, 2012 Orica Nitric Acid Plant 2 Nitrous Oxide Abatement from Nitric Acid Production Township Road 221, Carseland, Alberta T0J 0M0 The site is 16 hectares and is 50 kilometres southeast of Calgary. Latitude: 23063N to 25296N/Longitude: 20033E to E ICF Page 1

6 Credit Start Date: May 15, 2012 Credit Duration Period: March 29, 2012 to March 29, 2020 Expected Lifetime of the Project: Actual Emissions Reductions/ Removals Achieved: Other Environmental Attributes: Project Registration: Project Activity: The Project is expected to continue under the approved protocol through the credit duration period with a possible 5- year extension. 232,848 tonnes CO 2 e None This particular Project meets the all Offset Requirements under the Climate Change and Emissions Management Act: Specified Gas Emitters Regulation in the following: The Project is based in Alberta; At the provincial level, Bill-3 Climate Change and Emissions Management Act and associated Specified Gas Emitters Regulation (SGER) impacts facilities that emit over 100,000 tonnes of greenhouse gases but exempts from reduction targets the industrial process emissions related to chemical reactions. The industrial process emissions from the Orica s NAP 1 and NAP 2 are exempt from the SGER reduction targets. Since the Project is exempt from targets it qualifies for the creation of Alberta-based Offset Credits; The Project actions were taken and occur after January 1, 2002; Actual measurements are used to quantify the emission reductions realized from the Project; therefore making the reductions both real and demonstrable; and Emission reductions are measured and quantifiable using continuous real time measurement; The Project site is owned and operated by Orica Canada Inc. Third party secondary catalyst suppliers have no claim to any reduction credits generated using their technology at Orica Canada s Carseland Site. ICF Page 2

7 Project Report Temporal Period: January 1, 2016 December 31, 2016 Verification Summary: One immaterial qualitative misstatement remains in the final GHG Assertion. Reasonable level assurance Verification Statement issued. ICF Page 3

8 Main Contact (Verifier) Main Contact (Reporting Company) Selena Fraser, P.Eng. Senior Associate, ICF Consulting Canada, Inc Somerset Street West, Ottawa, Ontario K2P 2G Jeff Zubach SHES Specialist P.O. Box 250 Carseland, Alberta T0J 0M0 (403) Project Information ( Orica ) has developed the necessary documentation detailing project activities to support their claim for emissions reductions to be registered on the Alberta Offset Registry under Alberta s Specified Gas Emitters Regulation. Orica has engaged ICF Consulting Canada, Inc. ( ICF ) to provide a third-party verification of the emissions reductions related to the project activities discussed herein. The quantification of the emissions reductions associated with the project is defined by Alberta Environment and Parks ( AEP ) Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production, October 2009, Version 1.0 ( the Protocol ). The Project Report describes the emissions reductions claim ( GHG Assertion ) made by Orica related to this project. The Orica Nitric Acid Plant 2 - Nitrous Oxide Abatement from Nitric Acid Production ( the Project ) covered by this verification engagement involves the creation of 2016 vintage emissions reductions achieved through the abatement of nitrous oxide generated from the production of nitric acid. The Project is located 50 kilometres southeast of Calgary. The NAP 2 plant began operation in 1998 to produce nitric acid (HNO3) and uses a GPN Mono Pressure Process which oxidizes ammonia on platinum-rhodium catalyst gauze and absorbs nitrogen oxide gases in water. The oxidation reaction of ammonia that takes place on the platinum-rhodium catalyst has a side reaction which produces N 2 O. The Project consists of the installation of a dedicated catalyst for N 2 O abatement in Orica s Nitric Acid Plant 2 (NAP 2) below the platinum-rhodium catalyst gauze to abate the nitrous oxide formed during oxidation of ammonia. The opportunity to generate emission reduction credits comes from ICF Page 4

9 the installation of this dedicated catalyst for the destruction of the N 2 O emitted to atmosphere from the tail gas stack. 1 owns the entire Project. This is the third year that ICF has been engaged by Orica for verification services pertaining to this Project. This document describes the terms and scope of this verification. It serves to communicate the findings of the verification. 3. Verification Procedures The scope of the verification was defined during the verification planning stage and is detailed in the Verification Plan, which is appended to this document. The Verification Plan also describes ICF s verification process that was executed through the course of the verification, and identifies the specific verification procedures that were planned and executed through the process. Procedure Date Verification Kick-Off Meeting October 25, 2016 Verification Procedures Conducted October 2016 February 2017 Site Visit October 25, 2016 Internal Peer Review March 6, 2017 Final Verification Report Issued March 7, Site Visit The site visit to Carseland was conducted by Selena Fraser, P.Eng. on October 25, The site visit was a key step in planning and executing the verification. During the course of the site tour, ICF interviewed key site operations personnel regarding the operations and data management for the Project. Orica staff interviewed included: Jeff Zubach, Orica SHES Specialist Ken Nguyen, Orica Engineer on Site Kevin Moon of Capital Power Corporation also attended the site visit. The site visit included a review of all GHG emissions sources in the Project to identify and categorize each one as well as a review of calculation workbooks, additionally documentation, 1 Section 2.3 of the Verification Plan (See attached appendices) provides further information about the Project s geographical location, infrastructure and activities, greenhouse gas sources, relevant greenhouse gases and reporting period. ICF Page 5

10 and process flow diagrams followed by physical observation of the Project. Subsequently, a review of metering and data management processes was discussed and observed on site, including a review of meter calibration/validation procedures and a review of meter maintenance tags. 3.2 Summary of Project Changes Major GHG emissions sources have been identified by the Party and are detailed in the Offset Project Plan. The quantification methodologies outlined in the Protocol have been used to calculate GHG emissions sources. There have been no changes to the offset project and baseline since the offset project start date. The uncertainty associated with the quantification methodologies applied was evaluated during Protocol development. The Project meets the data collection and project specific calculation requirements of the Protocol and therefore, the uncertainty associated with the quantification and resulting assertion meets AEP requirements. 3.3 Program Applicability Criteria The Project was assessed against the following program applicability criteria outlined in the Protocol, which includes the eligibility criteria specified in program guidance documents. This is described as a verification procedure in Section 4, Verification Findings, in this report. Protocol applicability criteria include: The abatement process is carried out under controlled conditions as demonstrated by a description of technology in use; The quantification of reductions achieved by the project is based on actual measurement and monitoring (except where indicated by the proper application of the protocol); The project must meet the requirements for offset eligibility as specified in the applicable regulation and guidance documents for the Alberta offset System; The project activity will not result in the shutdown of any existing N 2 O destruction or abatement facility or equipment in the plant; and The project activity shall not affect the level of nitric acid production. Offset program eligibility criteria include: Occur in Alberta; Result from actions not otherwise required by law and be beyond business as usual and sector common practices; Result from actions taken on or after January 1, 2002; Occur on or after January 1, 2002; Be real, demonstrable, quantifiable, and verifiable; Have clearly established ownership; and ICF Page 6

11 Be counted once for compliance purposes. 3.4 Verification Strategy The Verification Strategy applied to this verification was a predominantly substantive approach. The Verification Team designed and executed verification procedures that focused on review of original metered and measured data. The Party relies on certain controls for the quantification of emissions. ICF relied on the following controls and as such, tested the operational effectiveness of these controls as well as the data processed by these controls. Details of the verification procedures employed to conduct these tests are provided in Section 4 of this report. The N 2 O monitoring system samples directly from the stack, where the data is recorded on 10 second intervals and reported hourly to the Distributed Control System (DCS). This is captured from the plant historical data system, which is used for all plant data. The monitoring system is in accordance with the N 2 O Monitoring CEMS Code found in the Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production (October 2009). All relevant instrumentation to measure process parameters are calibrated on a routine basis. The signals generated by these instruments are acquired and logged electronically by the DCS. Each day the N 2 O meter is automatically zeroed and span checked. A Cylinder Gas Audit (CGA) using N 2 O is conducted at the start of each campaign run. The flow meter and temperature sensor are verified once per year during the RATA for the existing NOx meter. 3.5 Data Management and Control System Review The Verification Team developed a thorough knowledge of the data management and control systems utilized in the Project through the review of the Project Report, and interviews with key Project personnel. The data flow diagram shown on the following pages outlines the flow of Project data and the custody of control. ICF Page 7

12 , 2016 Vintage Project Sources Legend P1 Nitric Acid Plant (Burner Inlet to Stack) Key Parameter Gauze Temperature Acid Mass Flowrate Air Temp NH3 Temp Stack Temperature N2O concentration Stack Velocity BlueSource Registry/Buyer Emissions Operations/ Data Management Calculator Data Type Field Capture System 2 nd or 3 rd Party Source/Data (name) Other Data Sources Bolded Block Data source used for Outline: quantification in the Emissions Calculator 2¼ pt. line Automated transfer of data to Calculator Manual transfer of data to Calculator Emission Source Calculation Methodology Registry Total Monthly Acid Production Air Flow Air Pressure Air Mass Flowrate NH3 Flow NH3 Pressure DCS Controller NH3 Mass Flowrate Site Historian (Monthly Hourly Report) Automated Data Transfer of Average Gauze Temp, Acid Production, Average Air Flowrate, Average NH3 flowrate, Average Air/ NH3 Ratio, Stack Flowrate, N2O concentration and Stack Temperature. Excel Summary Spreadsheet (GHG Calculator) Yearly Hourly report Total Hours Operational / Yearly Average Emissions Source Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production Alberta SGER Offset Registry Stack Diameter Stack Volume Flow ICF Page 8

13 3.6 Party Documentation Reviewed - Baseline calibration, inspection, and measurement records: o Baseline RATA and CGA reports Project documentation: o Project Report o Project Plan o GHG Assertion o Waiver of Ownership of Credits from Johnson Matthey o AEP Signed Letter of Project Extension o Project Calculator (NAP2 N2O Project Baseline, 5 Campaign Data, Year 2014 Report - Rev 8.xlsx) o Interval Data (2016 N2O audit - NAP2 raw 2 min CEMS interval data.xlsx) Project calibration, inspection, and measurement records o 4 RATA reports (including stack temperature, stack velocity, and N 2 O concentration calibrations) o Temperature probe trip check report o Pressure transmitter calibration record o Orifice plate meter calibration record o Annubar calibration record o 3 FTIR Reports o 2 CGA reports ICF Page 9

14 4. Verification Findings 4.1 Verification Findings The Verification Team planned and completed the verification procedures described in the following tables. The procedures and findings related to each specific Project or Baseline emissions source variable used to quantify the GHG Assertion are provided in Table The procedures and findings related to the overall Project GHG Assertion are provided in Table Detailed descriptions of any misstatements identified by the Verification Team are provided in Table Table 4.1-1: Project and Baseline GHG Emissions Sources Findings Data Description Verification Procedure(s) B1 Nitric Acid Plant (Burner Inlet to Stack) Oxidation temperature Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The Health and Environmental Specialist (Jeff Zubach) confirmed how the oxidation temperature was measured during the baseline years (which is the same as how it is measured in the project), as well as how sensitive this parameter is to determine if the plant is running at optimum conditions or not. The oxidation temperature is measured by the temperature probe and recorded every 5-10sec interval in the DCS. The DCS provides the hourly average, which is then transferred automatically into an Excel spreadsheet for further calculations and reporting. This value is also used constantly by operations to run the Nitric Acid Plant (NAP). ICF Page 10

15 Data Description Oxidation Pressure Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The temperature probes are inspected on a gauze campaign basis. The accuracy of temperature probes is needed for plant operations, and therefore it is very important that the reading is accurate. Weekly inspections are made to observe current readings and response time, and check that all instruments are operating acceptably. This inspection verifies that required daily calibration has been performed and review results of daily inspection/calibration for possible system adjustment. Along with checking areas identified as troublesome and also checking the operation of flow, temperature, and pressure sensors. As oxidation temperature is used to determine acceptable data parameters and is not used in emissions calculations, calibration records were determined to be immaterial to baseline emissions data. The Health and Environmental Specialist (Jeff Zubach) confirmed how the oxidation pressure is measured. The oxidation pressure is measured by a pressure transmitter and recorded every 5-10sec interval in the DCS. The DCS then provides the hourly average, which is transferred automatically into an Excel spreadsheet for further calculations and reporting. ICF Page 11

16 Data Description Ammonia gas flow rate to the AOR Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The pressure transmitters are inspected on a gauze campaign basis and replaced if necessary. This inspection verifies that required daily calibration has been performed and review results of daily inspection/calibration for possible system adjustment. Along with checking areas identified as troublesome and also checking the operation of flow, temperature, and pressure sensors. As oxidation pressure is used to determine acceptable data parameters and is not used in emissions calculations, calibration records were determined to be immaterial to baseline emissions data. During the site visit, it was explained how the ammonia gas flowrate is measured by the orifice plate meter. The flow rate is recorded every 5-10sec interval in the DCS. The DCS then provides the hourly average, which is transferred automatically into an Excel spreadsheet for further calculations and reporting. ICF Page 12

17 Data Description Ammonia to air ratio Air Flow Rate Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings Weekly inspections are made for the ammonia orifice plate meters to observe current readings and response time, and check that all instruments are operating acceptably. This inspection verifies that required daily calibration has been performed and review results of daily calibration for possible system adjustment. Jeff Zubach, SHES Specialist for Orica Canada, confirmed that the earliest calibrations performed for NAP1 and NAP2 orifice plate meters were in 2016 (July 21 and March 14, 2016 respectively), and that the orifice plate meters in use in 2016 are original to each NAP. Immaterial misstatement detected: No calibration records provided for baseline ammonia gas flow orifice plate meters The Ammonia to air ratio is calculated in the GHG calculation spreadsheet prepared by the Party. Both input values are measured values compiled from the DCS. The Ammonia to Air ratio is calculated on an hourly basis. A statistical analysis is used applied to the data which then is used to normalize it. ICF reviewed the spreadsheet and calculations and developed a recalculation spreadsheet using raw data from the DCS. The air flowrate is measured by an annubar. The flow rate is recorded every 5-10sec interval in the DCS. The DCS then provides the hourly average, which is transferred automatically into an Excel spreadsheet for further calculations and reporting. ICF Page 13

18 Data Description Stack Temperature Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The annubar is calibrated on a gauze campaign basis using good practice techniques and manufacturer specifications. Weekly inspections are made to observe current readings and response time, and check that all instruments are operating acceptably. This inspection verifies that required daily calibration has been performed and review results of daily calibration for possible system adjustment. As the air flow rate is used to determine acceptable data parameters and is not used in emissions calculations, calibration records were determined to be immaterial to baseline emissions data. During the site visit, the site operators explained how the stack temperature was measured during the baseline years (which is the same as how it is measured in the project): the temperature is measured and recorded for every 5-10sec interval in the DCS. The DCS provides the hourly average, which is then transferred automatically into an Excel spreadsheet for further calculations and reporting. ICF Page 14

19 Data Description Stack Velocity Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The temperature probe is inspected on a regular basis according to manufacturer specs. The stack temperature is recorded every 5-10sec interval in the DCS. The DCS then provides the hourly average, which is transferred automatically into an excel spreadsheet for further calculations and reporting. Stack temperature calibration records were reviewed through Relative Accuracy Test Audit (RATA) reports (2 for each NAP over the baseline period). During the site visit, the site operators explained how the stack velocity was measured. The velocity is measured by the Flowsic 107 and recorded for every 5-10sec interval in the DCS. The DCS provides the hourly average, which is then transferred automatically into an Excel spreadsheet for further calculations and reporting. ICF Page 15

20 Data Description N 2 O Concentration level Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The flow measurement uses a Flowsic 107 that measures the gas velocities and volumetric flows in the stacks using an ultrasonic flow monitor. The probe is mounted in the stack at a 45-degree angle to the direction of flow. Ultrasonic transducers on both ends of the probe transmit sound pulses through the gas flow which analyses the specific wavelengths of the gas concentration. The monitor measures the time of flight in both directions of the pulses through the flowing gas. Stack flow rate calibration records were reviewed through RATA reports (2 for each NAP over the baseline period). The N 2 O concentration level is measured by the Analyzer Procal P-200. The monitoring system was installed prior to the baseline campaign run to measure and document the quantity of N 2 O produced prior to the installation of the N 2 O abatement catalyst, and for the life of the project. ICF Page 16

21 Data Description Operating hours Nitric acid production levels Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls; Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls; Findings The P-200 is calibrated and set up to measure an N 2 O Range of ppm. The monitoring system is in accordance with the N 2 O Monitoring CEMS Code Self-calibration is performed every morning at 8am - during calibration mode, zero and span gases are injected into the probe head. RATA reports and Cylinder Gas Audit (CGA) reports were reviewed in order to confirm calibration of the N 2 O concentration monitor for the baseline period. Operating hours are determined based on the time clock, the DCS, and the ammonia flow rate. If the flow rate is over 0 tnh3/h, the hour is accounted for as an operating hour for the baseline period. Operating hours are therefore calculated based on direct measurements of the ammonia flow rate parameter. Nitric Acid production is metered separately; nitric acid is a saleable product and thus the Party has a vested interest in ensuring the accuracy of its production. ICF Page 17

22 Data Description Verification Procedure(s) P1 Nitric Acid Plant (Burner Inlet to Stack) Oxidation temperature Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The Health and Environmental Specialist (Jeff Zubach) confirmed how the oxidation temperature was measured during the baseline years (which is the same as how it is measured in the project), as well as how sensitive this parameter is to determine if the plant is running at optimum conditions or not. The oxidation temperature is measured by the temperature probe and recorded every 5-10sec interval in the DCS. The DCS provides the hourly average, which is then transferred automatically into an Excel spreadsheet for further calculations and reporting. This value is also used constantly by operations to run the Nitric Acid Plant (NAP). ICF Page 18

23 Data Description Verification Procedure(s) Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency; Findings Samples of 5-10 sec interval data were requested for 3 random weeks of the year: the first week of February, first week of June, and second week of December. Monitoring and measurement equipment calculates the average of 5-10 sec interval data into 2 minute interval data points. These points are then transferred to the DCS which computes hourly averages. Orica provided 2 minute interval data, and this data was reviewed against the hourly average raw data for both NAP1 and NAP2. In order to achieve a confidence level of 95 with a confidence interval of 5 and a population of 263,520 (the number of 2 min intervals in a 366-day year), the sample size required is 385 data points. The analysis of 21 days' worth of 2 min interval data (15,120 data points) is therefore justified as it exceeds the minimum 385 point sample size. ICF Page 19

24 Data Description Oxidation Pressure Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The temperature probes are inspected on a gauze campaign basis. The accuracy of temperature probes is needed for plant operations, and therefore it is very important that the reading is accurate. Weekly inspections are made to observe current readings and response time, and check that all instruments are operating acceptably. This inspection verifies that required daily calibration has been performed and review results of daily inspection/calibration for possible system adjustment. Along with checking areas identified as troublesome and also checking the operation of flow, temperature, and pressure sensors. Temperature sensor calibration records were reviewed: NAP1 on July 27, 2016, and NAP2 and March 19, The Health and Environmental Specialist (Jeff Zubach) confirmed how the oxidation pressure is measured. The oxidation pressure is measured by a pressure transmitter and recorded every 5-10sec interval in the DCS. The DCS then provides the hourly average, which is transferred automatically into an Excel spreadsheet for further calculations and reporting. ICF Page 20

25 Data Description Verification Procedure(s) Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency; Observe meter verification (calibration) tags and reports during site tour. Findings Samples of 5-10 sec interval data were requested for 3 random weeks of the year: the first week of February, first week of June, and second week of December. Monitoring and measurement equipment calculates the average of 5-10 sec interval data into 2 minute interval data points. These points are then transferred to the DCS which computes hourly averages. Orica provided 2 minute interval data, and this data was reviewed against the hourly average raw data for both NAP1 and NAP2. In order to achieve a confidence level of 95 with a confidence interval of 5 and a population of 263,520 (the number of 2 min intervals in a 366-day year), the sample size required is 385 data points. The analysis of 21 days' worth of 2 min interval data (15,120 data points) is therefore justified as it exceeds the minimum 385 point sample size. The pressure transmitters are inspected on a gauze campaign basis and replaced if necessary. This inspection verifies that required daily calibration has been performed and review results of daily inspection/calibration for possible system adjustment. Along with checking areas identified as troublesome and also checking the operation of flow, temperature, and pressure sensors. A calibration record was reviewed for NAP2 dated March 17, ICF Page 21

26 Data Description Ammonia gas flow rate to the AOR Verification Procedure(s) Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency; Findings During the site visit, it was explained how the ammonia gas flowrate is measured by the orifice plate meter. The flow rate is recorded every 5-10sec interval in the DCS. The DCS then provides the hourly average, which is transferred automatically into an Excel spreadsheet for further calculations and reporting. Samples of 5-10 sec interval data were requested for 3 random weeks of the year: the first week of February, first week of June, and second week of December. Monitoring and measurement equipment calculates the average of 5-10 sec interval data into 2 minute interval data points. These points are then transferred to the DCS which computes hourly averages. Orica provided 2 minute interval data, and this data was reviewed against the hourly average raw data for both NAP1 and NAP2. In order to achieve a confidence level of 95 with a confidence interval of 5 and a population of 263,520 (the number of 2 min intervals in a 366-day year), the sample size required is 385 data points. The analysis of 21 days' worth of 2 min interval data (15,120 data points) is therefore justified as it exceeds the minimum 385 point sample size. ICF Page 22

27 Data Description Ammonia to air ratio Air Flow Rate Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The ammonia orifice plate meter is calibrated on a gauze campaign basis using good practice techniques and manufacturer specifications. Weekly inspections are made to observe current readings and response time, and check that all instruments are operating acceptably. This inspection verifies that required daily calibration has been performed and review results of daily calibration for possible system adjustment. Calibration records for orifice plate meters were reviewed, dated July 21, 2016 and March 14, 2016 for NAP1 and NAP2 respectively. The Ammonia to air ratio is calculated in the GHG calculation spreadsheet prepared by the Party. Both input values are measured values compiled from the DCS. The Ammonia to Air ratio is calculated on an hourly basis. A statistical analysis is used applied to the data which then is used to normalize it. ICF reviewed the spreadsheet and calculations and developed a recalculation spreadsheet using raw data from the DCS. The air flowrate is measured by an annubar. The flow rate is recorded every 5-10sec interval in the DCS. The DCS then provides the hourly average, which is transferred automatically into an Excel spreadsheet for further calculations and reporting. ICF Page 23

28 Data Description Verification Procedure(s) Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency; Observe meter verification (calibration) tags and reports during site tour. Findings Samples of 5-10 sec interval data were requested for 3 random weeks of the year: the first week of February, first week of June, and second week of December. Monitoring and measurement equipment calculates the average of 5-10 sec interval data into 2 minute interval data points. These points are then transferred to the DCS which computes hourly averages. Orica provided 2 minute interval data, and this data was reviewed against the hourly average raw data for both NAP1 and NAP2. In order to achieve a confidence level of 95 with a confidence interval of 5 and a population of 263,520 (the number of 2 min intervals in a 366-day year), the sample size required is 385 data points. The analysis of 21 days' worth of 2 min interval data (15,120 data points) is therefore justified as it exceeds the minimum 385 point sample size. No discrepancies were found. The annubar is calibrated on a gauze campaign basis using good practice techniques and manufacturer specifications. Weekly inspections are made to observe current readings and response time, and check that all instruments are operating acceptably. This inspection verifies that required daily calibration has been performed and review results of daily calibration for possible system adjustment. A calibration record was reviewed for NAP2 dated March 15, ICF Page 24

29 Data Description Stack Temperature Verification Procedure(s) Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency; Findings During the site visit, the site operators explained how the stack temperature was measured during the baseline years (which is the same as how it is measured in the project), the temperature is measured and recorded every 5-10sec interval in the DCS. The DCS provides the hourly average, which is then transferred automatically into an Excel spreadsheet for further calculations and reporting. Samples of 5-10 sec interval data were requested for 3 random weeks of the year: the first week of February, first week of June, and second week of December. Monitoring and measurement equipment calculates the average of 5-10 sec interval data into 2 minute interval data points. These points are then transferred to the DCS which computes hourly averages. Orica provided 2 minute interval data, and this data was reviewed against the hourly average raw data for both NAP1 and NAP2. In order to achieve a confidence level of 95 with a confidence interval of 5 and a population of 263,520 (the number of 2 min intervals in a 366-day year), the sample size required is 385 data points. The analysis of 21 days' worth of 2 min interval data (15,120 data points) is therefore justified as it exceeds the minimum 385 point sample size. ICF Page 25

30 Data Description Stack Velocity Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The temperature probe is inspected on a regular basis according to manufacturer specs. The stack temperature is recorded every 5-10sec interval in the DCS. The DCS then provides the hourly average, which is transferred automatically into an excel spreadsheet for further calculations and reporting. Stack temperature calibration records were provided appended to RATA reports (4 per NAP) and were reviewed. During the site visit, the site operators explained how the stack velocity was measured. The velocity is measured by the Flowsic 107 and recorded every 5-10sec interval in the DCS. The DCS provides the hourly average, which is then transferred automatically into an Excel spreadsheet for further calculations and reporting. ICF Page 26

31 Data Description Verification Procedure(s) Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency; Findings Samples of 5-10 sec interval data were requested for 3 random weeks of the year: the first week of February, first week of June, and second week of December. Monitoring and measurement equipment calculates the average of 5-10 sec interval data into 2 minute interval data points. These points are then transferred to the DCS which computes hourly averages. Orica provided 2 minute interval data, and this data was reviewed against the hourly average raw data for both NAP1 and NAP2. In order to achieve a confidence level of 95 with a confidence interval of 5 and a population of 263,520 (the number of 2 min intervals in a 366-day year), the sample size required is 385 data points. The analysis of 21 days' worth of 2 min interval data (15,120 data points) is therefore justified as it exceeds the minimum 385 point sample size. ICF Page 27

32 Data Description N 2 O Concentration level Verification Procedure(s) Observe meter verification (calibration) tags and reports during site tour. Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription; Findings The flow measurement uses a Flowsic 107 that measures the gas velocities and volumetric flows in the stacks using an ultrasonic flow monitor. The probe is mounted in the stack at a 45-degree angle to the direction of flow. Ultrasonic transducers on both ends of the probe transmit sound pulses through the gas flow which analyses the specific wavelengths of the gas concentration. The monitor measures the time of flight in both directions of the pulses through the flowing gas. Stack flow rate calibration records were provided appended to RATA reports (4 per NAP) and were reviewed. The N 2 O concentration level is measured by the Analyzer Procal P-200. The monitoring system was installed prior to the baseline campaign run to measure and document the quantity of N 2 O produced prior to the installation of the N 2 O abatement catalyst, and for the life of the project. ICF Page 28

33 Data Description Verification Procedure(s) Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency; Observe meter verification (calibration) tags and reports during site tour. Findings Samples of 5-10 sec interval data were requested for 3 random weeks of the year: the first week of February, first week of June, and second week of December. Monitoring and measurement equipment calculates the average of 5-10 sec interval data into 2 minute interval data points. These points are then transferred to the DCS which computes hourly averages. Orica provided 2 minute interval data, and this data was reviewed against the hourly average raw data for both NAP1 and NAP2. In order to achieve a confidence level of 95 with a confidence interval of 5 and a population of 263,520 (the number of 2 min intervals in a 366-day year), the sample size required is 385 data points. The analysis of 21 days' worth of 2 min interval data (15,120 data points) is therefore justified as it exceeds the minimum 385 point sample size. The P-200 is calibrated and set up to measure an N 2 O Range of ppm. The monitoring system is in accordance with the N 2 O Monitoring CEMS Code Self-calibration is performed every morning at 8am - during calibration mode, zero and span gases are injected into the probe head. RATA and CGA reports were reviewed and confirmed calibration of the N 2 O monitor (2 CGA reports for each NAP, 1 RATA report for NAP1, and 3 RATA reports for NAP2 for 2016). ICF Page 29

34 Data Description Operating hours Nitric acid production levels Verification Procedure(s) Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls; Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls; Findings Operating hours are determined based on the time clock, the DCS, and the ammonia flow rate. If the flow rate is over 500 tnh3/h, the hour is accounted for as an operating hour. Operating hours are therefore calculated based on direct measurements of the ammonia flow rate parameter. Nitric Acid production is metered separately; nitric acid is a saleable product and thus the Party has a vested interest in ensuring the accuracy of its production. Table 4.1-2: Project GHG Assertion Findings GHG Assertion Risk Category Changes at the Project Level Verification Procedure(s) Interview Project operations personnel regarding changes to equipment inventory or changes in operation that have occurred in the time period covered by the GHG Assertion Findings Site personnel confirmed that no operational changes occurred over the reporting period. Incomplete emission sources Compare Orica's OPP, OPR, GHG Assertion against the corresponding AEP templates, as applicable; GHG emission sources listed in the GHG Assertion and the Offset Project Plan (OPP) were compared; all reports include the same emissions sources as the Protocol. No deviations or flexibility mechanisms were applied. ICF Page 30

35 GHG Assertion Risk Category Verification Procedure(s) Review Orica's OPP for evidence of applicability for each requirement described by the Protocol; Findings ICF reviewed the applicability of each requirement described by the quantification Protocol: 1. The abatement process is carried out under controlled conditions as demonstrated by a description of technology in use; 2. The quantification of reductions achieved by the project is based on actual measurement and monitoring as indicated by the proper application of the protocol; 3. The project meets the requirements for offset eligibility as specified in the applicable regulation and guidance documents for the Alberta Offset System (see inherent risk further down in this table labelled "GHG Assertion must meet Offset Eligibility Criteria"). 4. The project activity does not result in the shutdown of any existing N 2 O destruction or abatement facility or equipment in the plant; 5. The project activity does not affect the level of nitric acid production; and 6. Continuous real-time measurements of N 2 O concentration and total gas volume flow have been carried out in the stack: a. Prior to the installation of the secondary catalyst for one campaign, and b. After the installation of the secondary catalyst throughout the project activity ICF Page 31

36 GHG Assertion Risk Category Continuity of reporting practices Verification Procedure(s) Interview Project operations personnel regarding changes to equipment inventory or changes in operation that have occurred in the time period covered by the GHG Assertion Compare emission sources in the current data summary Excel spreadsheet with those in previous years; Compare the quantification methodologies utilized for the current vintage credits against those used in previous vintage credits; Findings Completed during the site visit. Facility personnel provided an overview of the Facility during the opening meeting as well as a tour of the Facility. All emissions sources described are included in the GHG Assertion. Multiple shut downs occurred over the reporting period due to high inventory levels, primary catalyst change outs, power outages, and various maintenance procedures. No other changes have occurred in The shutdown periods were reflected in the data in the excel summary spreadsheet. The quantification of emission reduction credits generated from this project is completed in accordance with the Alberta Approved Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production (October 2009). Emissions sources are consistent with previous years. All calculations were checked and ICF developed a recalculation spreadsheet from raw data and calculations as prescribed in the protocol. Quantification methodologies are consistent with those used in previous years. ICF Page 32

37 GHG Assertion Risk Category Complexity of data systems Use of appropriate quantification methodologies Verification Procedure(s) Develop a data life cycle diagram, or data map for each major GHG emissions source and confirm with Project operations and GHG reporting personnel; Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls; Review quantification formulae and estimation calculations prescribed by the Protocol against those described in the OPP and utilized in the data summary Excel spreadsheet for each GHG emissions source; Calculate emissions reduction claim from original, secondparty or third-party data (including and not limited to an assessment of potential double counting of emissions from quantified emission sources, and an evaluation of the appropriateness of using a simple instead of weighted average) Findings ICF developed a data flow diagram for each major GHG emissions sources and production. ICF confirmed the accuracy with operations personnel during the site visit. The data control process for this project consists of electronic data capture and reporting, and manual calculations using Excel to determine total emission reductions realized. The quantification methods and formulas used to calculate the emission reductions were reviewed to ensure accuracy. Emissions quantification methods used by the Party were reviewed and were found to follow those widely accepted by the AEP Protocol, No flexibility mechanism applied. Emissions from each Source were recalculated based on the methodology prescribed in the Protocol from raw data files provided by Orica. ICF Page 33

38 GHG Assertion Risk Category Quantification accuracy Completeness of GHG Assertion Transcription of Final GHG Assertion Manual data entry processes Verification Procedure(s) Calculate emissions reduction claim from original, secondparty or third-party data (including and not limited to an assessment of potential double counting of emissions from quantified emission sources, and an evaluation of the appropriateness of using a simple instead of weighted average) Review GHG Assertion against guidance documents for completeness; Compare calculated values to those in the GHG Assertion for transcription accuracy; Compare calculated values to those in the GHG Assertion for transcription accuracy; Findings ICF developed an independent recalculation spreadsheet using raw data obtained from Orica. The final GHG assertion was reviewed for consistency and accuracy with the calculated emission reductions. Orica calculated values were compared to values found in the GHG Assertion. Orica calculated values were compared to the values found in the GHG Assertion. ICF Page 34

39 GHG Assertion Risk Category Planned or unplanned events Ownership Completeness of scope of greenhouse gases Verification Procedure(s) Interview Project operations personnel regarding changes to equipment inventory or changes in operation that have occurred in the time period covered by the GHG Assertion Interview Project operations personnel regarding ownership of emissions reduction credits. Through the site visit and understanding of the Project, evaluate any emissions sources or sinks that are not considered by the Protocol. Findings Shut down occurred on the following dates: - January plant shut down due to high product inventory - February 16 - plant tripped due to loose contact on compressor bearing temperature card - February 18 - CEMS meter fail - March plant shut down for gauze change out and due to high inventory, remained shut down to troubleshoot P-2604 and N 2 O abatement issues - April plant shut down due to loss of services from Agrium - April plant shut down to troubleshoot higher than normal N 2 O levels - warped catalyst basket allowing ammonia to bypass was determined to be the cause - July 30-Aug 1 - plant shut down due to condensate supply issue - August plant shut down for gauze change out and to repair catalyst basket - September plant shut down due to site power outage These changes are reflected in the Excel summary spreadsheet. owns and operates the plant and therefore has full ownership of the credits created. The site visit confirmed no unreported emissions sources or sinks. ICF Page 35

40 GHG Assertion Risk Category Assessment of Emission Factors and Other Parameters Verification Procedure(s) Compare emission factors used in calculations against reference documents cited in Protocol and Orica's OPP. Assess accuracy and relevance of data parameters (including but not limited to GWP's, densities, molecular weights, temperature, pressure or other parameters listed on the Protocol) through a review against reference documentation and/or recalculation Findings Emission factors used in calculations were compared to emission factors found in the Protocol and Orica's OPP. Data parameters used in calculations were compared to parameters found in the Protocol and Orica's OPP. Compared N 2 O molecular weight and standard volume to reference values (Perry's Chemical Engineers' Handbook). Verified that Orica uses temperature and pressure according to the IUPAC Current Standard, 0C and 100kPa, in compliance with the AEP quantification protocol. ICF Page 36

41 4.2 Misstatements One immaterial qualitative misstatement was identified in the GHG Assertion and supporting documentation. The misstatement section below summarizes the misstatements identified in the verification findings in Section 4.1. Table 4.2-1: Misstatements Misstatement Title No calibration records provided for baseline ammonia gas flow orifice plates Misstatement Description The Project Proponent did not provide calibration records for the baseline period for the ammonia gas flow orifice plate meters for NAP1 and NAP2. Jeff Zubach, SHES Specialist for Orica Canada, confirmed that the earliest calibrations performed for NAP1 and NAP2 orifice plate meters were in 2016 (July 21 and March 14, 2016 respectively), and that the orifice plate meters in use in 2016 are original to each NAP. Calibration records for both NAP1 and NAP2 in 2016 show that measurements of the meters were within specification. The ammonia gas flow is used as a parameter to determine the number of operating hours for each plant, and operating hours are a parameter used in emissions calculations. Orica was unable to provide ICF with evidence of calibration during the baseline period. However, calibration of the meters in 2016 was found to be within specification. As these meters are original to construction, it is ICF s conclusion that the meters have been within specification since construction, including for the baseline period. As a result, this qualitative misstatement is immaterial. 4.3 Materiality No material misstatements were identified in the GHG Assertion. One immaterial misstatement was identified in the GHG Assertion. There is no breach of materiality (greater than 5% of the total GHG Assertion). 4.4 Other Findings Through the course of the verification the data management systems and controls employed in the quantification of emissions reductions associated with the Project were reviewed, as detailed in Section 4.1 above. These systems were found to be effective in the calculation of the GHG Assertion. ICF Page 37

42 4.5 Confirmations The "Confirmations defined in Section 5.4 of the Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013 were completed. The results of this review were as follows. Offset project information across offset project documentation was reviewed and found to be consistent; Offset project location is included with the GHG Assertion; Quantification methodologies have been documented in the offset project documentation; Offset project contact, report dates, emission reduction numbers, etc. were included in project documentation; Process and data flow diagrams in the project documentation were reviewed during the site visit and found to be an accurate representation of Project operations. ICF Page 38

43 5. Verification Team Since 1969, ICF has been serving major corporations, all levels of government, and multilateral institutions. Globally, approximately 500 of our 5,000 employees are dedicated climate change specialists, with experience advising public and private-sector clients. ICF has earned a reputation in the field of climate change consulting for its analytical rigour, in-depth expertise, and technical integrity through scores of GHG emissions-related assignments over the past two decades. Over the past ten years, ICF Consulting Canada, Inc., a fully owned subsidiary of ICF, has established a GHG Verification Body and carried out hundreds of facility-level GHG verifications and verifications of emissions reductions projects. The Verification Body has developed the necessary internal controls to ensure qualified and competent staffing uphold the principles of the relevant standard while quality control processes are utilized to assure data integrity is maintained and safeguarded. ICF s clients choose ICF for its strong brand, technical expertise, and rigorous methodological approach. The Verification Team assigned to this verification consists of experienced GHG verifiers. Lead Verifier Selena Fraser, P.Eng. Selena is a registered Professional Engineer in the Province of Ontario. Selena has acted as Lead and Associate Verifier for a number of emission reduction (offset) projects under the Alberta-based Offset Credit System including projects pertaining to Acid Gas Injection, Enhanced Oil Recovery and Landfill Gas Combustion for energy. She has acted as Associate Verifier for a number of emission quantification and credit applications under the Alberta-based Emissions Trading Regulation (ETR), specifically in the power generation sector. She has also acted as Associate Verifier for a number of compliance exercises under Alberta s SGER in the power generation and oil and gas sectors. Associate Verifier Sheldon Fernandes Sheldon Fernandes holds a Bachelor of Applied Science in Systems Design Engineering with a Specialization in Environmental Engineering from the University of Waterloo. He has over 3 years of experience in GHG quantification, verification, and reporting. His offset project audit experience includes aerobic composting, wind generation, energy efficiency, and nitrous oxide abatement projects. He has provided verification services for over a dozen greenhouse gas compliance reports from facilities including natural gas processing, steam assisted gravity drainage, and linear operations under Alberta and British Columbia s greenhouse gas regulations. Sheldon has previous experience working with federal and provincial government agencies in Canada developing GHG and energy efficiency measurement and reporting tools. Internal Peer Reviewer Julie Tartt Julie Tartt has a Bachelor of Science degree in Environmental Sciences from the University of Guelph and has completed supplementary verification training, receiving a certificate of training for ISO Julie is the Manager of ICF s Verification Management System (VMS) and is also a Lead Verifier she led and managed the development of ICF s ANSI-accredited ISO ICF Page 39

44 14065 VMS. Note that while ICF no longer maintains the ISO accreditation, it still maintains its Verification Body. Julie has been working with ICF s Verification Body since 2010 and has worked on verifications under several regulatory reporting programs including British Columbia, Ontario, and Quebec s Greenhouse Gas Reporting Regulations, and Alberta s Specified Gas Emitters Regulation. Facility compliance reports verified have included natural gas pipeline and natural gas processing linear facility operations, coal mining, electricity generation, and cogeneration facilities. Emissions reduction project verifications have included wind electricity generation, landfill gas capture and utilization, aerobic composting, and tillage management projects. Additionally, she has provided verification services for organizations reporting to the Carbon Disclosure Project and The Climate Registry, as well as voluntary emissions reductions projects. Julie also has extensive experience managing and administering large, multi-client, carbon market modeling and analysis studies nationally and at the provincial level. Statement of Qualifications As the Lead Verifier / Designated Signing Authority and a Professional Engineer registered in the province of Ontario, I, Selena Fraser meet or exceed the required qualifications described in Section 18 of the Specified Gas Emitters Regulation, including the training requirements under ISO The information contained within this document and this statement of qualifications, is complete and correctly represents the qualifications of ICF and the members of the Verification Team described herein. Dated this seventh day of March, Selena Fraser, P.Eng. Professional Engineer, Ontario ( ) Lead Verifier / Designated Signing Authority ICF Consulting Canada, Inc. Ottawa, Ontario Duncan Rotherham Vice President and Managing Director ICF Consulting Canada, Inc. Toronto, Ontario ICF Page 40

45 Appendices Verification Plan Sampling Plan Conflict of Interest Checklist ICF Page 41

46 Verification Plan Nitrous Oxide Abatement from Nitric Acid Production NAP2 1 Introduction This document provides details on the verification scope and process that is planned to conduct a reasonable level verification of the 2016 Alberta Offset System greenhouse gas assertion of emission reduction credits (the GHG Assertion ) for the Nitrous Oxide Abatement from Nitric Acid Production NAP2, (the Project ). An overview of operations at the Project will be provided in the Verification Report. A Verification Risk Assessment was conducted during the verification planning stage; the results will be provided in Section 6 of this final Verification Plan. These results were used to inform the development of the verification procedures outlined in the Verification Findings Section of the Verification Report. Additionally, the results of the Risk Assessment informed the development of the Sampling Plan, which will be included in the Verification Report. The Verification and Sampling Plans will be updated through the course of the verification as additional information becomes available. The verification conclusion will be documented in the Verification Statement and the verification findings will be further described in the Verification Report. The Verification and Sampling Plans will be appended to the Verification Report to provide information related to the verification scope and process. 2 Verification Scope 2.1 Objective The primary objective of this verification engagement is to provide assurance to Alberta Environment and Parks ( AEP ) that the GHG Assertion is reliable, and of sufficient quality. 2.2 Parties and Users The person or organization that has overall control and responsibility for the GHG Project, as defined in Section 2.13 of ISO :2006, is the Project Proponent. For this verification, ( Orica ) is the Project Proponent. ICF Page 1

47 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 The person or persons responsible for the provision of the GHG Assertion and the supporting information, as defined in Section 2.24 of ISO :2006, is the Party. For this verification, Orica is also the Party. ICF Consulting Canada, Inc., the Verifier or ICF, has been engaged to provide a third-party verification of the GHG Assertion. The Lead Verifier and Associate Verifier comprise the ICF Verification Team. The Intended User is defined in Section 2.22 of ISO :2006 as the individual or organization identified by those reporting GHG-related information that relies on that information to make decisions. AEP is the Intended User of the information contained within the Verification Statement. 2.3 Scope The verification will be conducted in accordance with ISO : Specification with guidance for the validation and verification of greenhouse gas assertions. The Verification and Sampling Plans were developed based on the relevant criteria described in the following: Specified Gas Emitters Regulation, Alberta. Reg.139/2007 Climate Change and Emissions Management Act Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production, Version 1.0, October 2009 Technical Guidance for Offset Project Developers, v4.0, February 2013 Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013 The following table defines the scope elements specified for the Project. ICF Page 2

48 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Scope Element ISO Definition Project Specific Boundary The Project boundary, including legal, financial, operational and geographic boundaries Orica Canada Nitrous Oxide Abatement from Nitric Acid Production. Orica Canada Inc. s Carseland Works is located at Township Road 221 Carseland, Alberta, T0J 0M0 The site is 16 hectares and is 50 kilometers southeast of Calgary. Infrastructure and Activities GHG Sources GHG Types Reporting Period The physical infrastructure, activities, technologies and processes associated with the Project GHG sources to be included Types of GHGs to be included Vintage of credits to be included Latitude: 23063N to 25296N/ Longitude: 20033E to E Nitric Acid Production Baseline Emissions from Nitric Acid Plant (Burner Inlet to Stack) Project Emissions from Nitric Acid Plant (Burner Inlet to Stack) Nitrous Oxide (N 2 O) January 1, 2016 December 31, 2016 ICF Page 3

49 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 2.4 Materiality During the course of the verification, individual errors, omissions or misrepresentations (collectively referred to as misstatements) or the aggregate of these misstatements will be evaluated qualitatively and quantitatively. Materiality defines the level at which misstatements in the GHG Assertion or any underlying supporting information precludes the issuance of a reasonable level of assurance. The Lead Verifier is responsible for applying professional judgment to determine if qualitative misstatements could adversely affect the GHG Assertion and subsequently influence the decisions of the Intended User, in which case, the misstatements are deemed to be material. Quantitative misstatements will be calculated individually to determine the impact of the misstatement as a percentage of the GHG Assertion. All misstatements that are outstanding at the conclusion of the verification are documented in the Verification Report and classified on an individual basis as either material or immaterial. Materiality Threshold The materiality threshold is defined as 5% of the total reported emissions reductions in the GHG Assertion. Individual misstatements and the aggregate of individual misstatements will be analyzed to determine if the materiality threshold has been breached. Tolerable Error Threshold Tolerable error dictates the level of rigor applied to the verification at the emissions source level. Tolerable error for this verification will be set at half of materiality (2.5%) of the total GHG Assertion. ICF Page 4

50 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 2.5 Principles ISO defines six principles that should be upheld in the development of the GHG Assertion. These principles are intended to ensure a fair representation and a credible and balanced account of GHG-related information. The verification procedures developed and executed during the course of this verification will present evidence such that each of these principles is satisfied. Relevance Appropriate data sources are used to quantify, monitor, or estimate emissions sources. Appropriate minimum thresholds are used to justify the exclusion or the aggregation of minor GHG sources or the number of data points monitored. Completeness All emissions sources relevant to the Project are included within an identified source category. Consistency Uniform calculations are employed between reporting periods. Emissions calculations for each emissions source are calculated uniformly. If more accurate procedures and methodologies become available, documentation should be provided to justify the changes and show that all other principles are upheld. Accuracy Measurements and estimates are presented, without bias as far as is practical. Where sufficient accuracy is not possible or practical, measurements and estimates are used while maintaining the principles of conservativeness and transparency. Transparency Information is presented in an open, clear, factual, neutral and coherent manner that facilitates independent review. All assumptions are stated clearly and explicitly and all calculation methodologies and background material are clearly referenced. Conservativeness Appropriate parameters affecting the Project s emissions sources are utilized in the calculation of the GHG Assertion. When parameters or data sources are highly uncertain, the choice of parameter or data source utilized results in an underestimation of the GHG Assertion. Note that any error, underestimation or overestimation, would be evaluated as a potential material error. 2.6 Limitation of Liability Due to the complex nature of the operations within the Project and the inherent limitations of the verification procedures employed, it is possible that fraud, error, or non-compliance with laws, regulations, and relevant criteria may occur and not be detected. ICF Page 5

51 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 3 Verification Team The qualifications of the Verification Team and Internal Peer Reviewer are provided in the Statement of Qualifications Lead Verifier, Selena Fraser, P.Eng. The Lead Verifier is responsible for all activities conducted within the verification, including overseeing the development of the Verification and Sampling Plans and the execution of the verification procedures. The Lead Verifier is the lead author of the Verification Report and executes the Verification Statement at the conclusion of the engagement. Associate Verifier, Sheldon Fernandes The Associate Verifier works under the direction of the Lead Verifier to conduct the verification procedures. Internal Peer Reviewer 1, Julie Tartt The Internal Peer Reviewer is not a member of the Verification Team and does not participate in the verification until the draft Verification Report and draft Verification Statement have been prepared. The Internal Peer Reviewer conducts an internal assessment of the verification to ensure the verification procedures have been completed, the results of the verification have been thoroughly documented, any issues or misstatements have been investigated and the verification evidence is sufficient to reach the verification conclusion described in the Verification Statement. 1 Note: the Internal Peer Reviewer is not a member of the Verification Team, but is listed here to keep the list of personnel involved in the engagement in one place. ICF Page 6

52 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 4 Verification Process The ICF approach for conducting verification of a GHG Assertion follows the tasks outlined in the following diagram. Although these tasks are generally completed sequentially, the order may be modified according to circumstances such as scheduling and data availability. Pre-Engagement Approach Execution of Verification Completion 1. Selection of Lead Verifier 2. Initiate Conflict of Interest Procedure 3. Pre-Engagement Planning and Proposal Development 4. Contract Execution 5. Assess GHG Program & Revise VMS as Required 6. Initiate Verification Tracking 7. Selection of Verification Team 8. Communication with Project Proponent 9. Kick-off Meeting 10. Verification Risk Assessment 11. Draft Verification and Sampling Plan 12. Site Visit 13. Conduct Verification Procedures 14. Issue Clarification & Data Request 15. Revise & Finalize Verification and Sampling Plan 16. Address and Evaluate Outstanding Issues 17. Evaluate Evidence 18. Hold Verification Findings Meeting (if necessary) 19. Draft Verification Report & Statement 20. Internal Peer Review 21. Completion of COI Form 22. Issue Verification Report & Statement 23. Close Verification File 24. Develop and Issue Management Memo(s) 4.1 Pre-Engagement Prior to submitting a proposal to conduct this verification, the following pre-planning steps were taken: The results of any previous business engagements or verifications with the Project Proponent were reviewed to determine if any previous unresolved conflicts may preclude ICF from engaging in the verification; The Project Proponent s motivation for completing the verification was established; and A Conflict of Interest procedure was initiated that documents whether any perceived or real conflicts were found when considering threats due to: ICF Page 7

53 Draft Verification Plan - Advocacy - Financial Interest - Familiarity/Sympathy - Intimidation - Self-Review - Incentives Following the acceptance of the proposal and signing of a contract for services, the Verification Team was selected. The Verification Team for this engagement comprises the individuals identified in Section Approach An extensive knowledge of the Project Proponent s business, the relevant industry, and the details of the Project itself are required to conduct a thorough verification that can lead to a conclusion. The initial information collected about the Project Proponent and the Project formed the basis of the preliminary draft Verification Plan. The development of this final Verification Plan is an iterative process; that is, the process will be completed several times through the course of the verification and the resulting plan will be updated as new information became available. There are three types of risk associated with the GHG Assertion defined in ISO : Inherent Risk Control Risk Detection Risk The process of designing the Verification Plan began with the development of Verification Risk Assessment for both the Project as well as the Project Proponent. The steps in this process included: Reviewing the GHG Assertion, and the methodologies employed by the Project; Reviewing information on the industry and the specific Project under review; Assessing the likelihood that a material misstatement might exist in the GHG Assertion, if no controls were used to prevent misstatements in the GHG Assertion (i.e., inherent risk); Assessing the control environment and the corporate governance process (i.e., control risk); and Reviewing each emissions source identified in the Project, and evaluating the contribution of each source to the GHG Assertion and the associated potential material misstatement for each. The results of the Verification Risk Assessment inform the development of the verification procedures, which will be documented in Section 5, Verification Findings, of the Verification Report. A summary of the Verification Risk Assessment will be provided in Section 6 of this final Verification Plan. The draft Verification Plan will be provided to the Project Proponent before proceeding with the verification. ICF Page 8

54 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 4.3 Execution of Verification With draft Verification and Sampling Plans in place, the verification procedures will be executed. This process involves collecting evidence, testing internal controls, conducting substantive testing, and developing a review file. Over the course of the verification, the draft Verification and Sampling Plans may change; the final Verification and Sampling Plans provided in the Verification Report reflect the verification parameters and procedures that were actually executed. Site Visit The site visit will be conducted by Selena Fraser, P.Eng on October 25, The site visit will be a key step in the planning and execution of the verification. During the course of the site tour, ICF will interview key site operations personnel regarding the operations and data management for the Project. Orica staff to be interviewed on-site include: Kevin Moon, Capital Power Jeff Zubach, Orica SHEC Specialist During the site visit all GHG emissions sources for the Project will be reviewed to ensure appropriate identification and categorization. A review of process flow and metering diagrams will be followed by physical observation of the Project. Health and Safety Requirements Personal protective equipment (including steel toed boots, hard hat, safety glasses, reflective vest or coat, long sleeves and pants) is required to attend the facility tour. All site visitors must be accompanied by an Orica site representative. Collecting Evidence and Review of Documentation Sufficiency and appropriateness are two interrelated concepts that are fundamental to the collection of verification evidence. The decision as to whether an adequate quantity (sufficiency) of evidence has been obtained is influenced by its quality (appropriateness). Through the execution of the verification procedures, as described in Section 7 of this final Verification Plan, the Verification Team will review three key forms of evidence including physical, documentary and testimonial: Management documentation: policies, programs, and procedures related to the collection, safeguarding, and management of the data supporting the GHG Assertion; Records: records comprise time-sensitive data, correspondence, and files including: the Offset Project Plan, calibration records, production records; Interviews: the interviews will provide information regarding operations and data management and will provide evidence to support the sufficiency of data controls; and Computer systems: data systems and data summary Excel spreadsheets used to capture and manage the GHG-related data and to calculate the GHG Assertion. ICF Page 9

55 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Testing and Assessment of Internal Controls The Verification Team will develop a sufficient understanding of the GHG information system and internal controls to determine whether the overall data management system is sound and if it supports the GHG Assertion. This assessment will seek to identify any weakness or gaps in the controls that pose a significant risk of not preventing or correcting problems with the quality of the data and examining it for sources of potential errors, omissions, and misrepresentations. It will incorporate an examination of three aspects of the Project Proponent s internal controls: (1) the control environment, (2) the data systems, and (3) the control and maintenance procedures. Assessment of Data Substantive testing procedures will be used to assess the reasonability and validity of the GHG Assertion. Both quantitative and qualitative analysis will be performed to achieve the desired level of assurance. The verification procedures conducted and ICF s associated findings are described in Section 5 of the Verification Report. The verification procedures include verification activities designed to: Review the Project boundary, including a review of the completeness of emissions sources identified; Review the Project data sources to ensure the GHG Assertion is calculated based on metered or estimated data that meets the requirements of the Quantification Protocol for Energy Efficiency Projects (2007); Re-calculate the GHG Assertion, which demonstrates transparency and accuracy; and Review the GHG Assertion to ensure the emissions reductions calculated by the Project Proponent have been accurately reported. Clarification and Data Request To facilitate information flow between the Verification Team and the Project Proponent, a consolidated request for additional information will be developed through the course of the verification and issued to the Project Proponent. This Clarification and Data Request will be used to document information requests and summarize the responses. It will also be used to document the Verification Team s assessment of each response. Developing a Review File A review file (the File ) comprised of documents, records, working papers and other evidence collected and created during the course of the review that support the review conclusions will be developed for this verification. This evidence stored in electronic format will serve to provide support for the verification conclusion, provide evidence that the verification was conducted in accordance with the criteria set forth in this document, and aid the Verifier in conducting current and future reviews. The File will include: The GHG Assertion and supporting documentation, as submitted to AEP; Decisions on the level of materiality and the results of the Verification Risk Assessment; ICF Page 10

56 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Documentation on the Project Proponent s internal controls; Descriptions of the controls assessment work and results; Documentation of the substantive testing procedures that were carried out and the results; Documentation of the confirmations outlined in Table 26 of Alberta Environment s Technical Guidance for GHG Verification at Reasonable Level Assurance, v1.0, January 2013; Copies of any correspondence with the Project Proponent or other parties relevant to the review; The Verification Team s working papers; The Clarification and Data Request with documented responses from the Project Proponent; and Client data (copies of relevant records, spreadsheets, and other data files). The File is the property of ICF and access to it is normally restricted to the Verifier and the Project Proponent. ICF will retain and safeguard the file for a minimum of seven years. 4.4 Completion This engagement will be formally closed after the verification has been executed and the Verification Report has been finalized. Preparing the Verification Report The purpose of the Verification Report is to document the verification findings. All misstatements are described and compared to the materiality threshold individually and in aggregate. The Verification Statement, which presents ICF s verification conclusion, is included in the Verification Report. Internal Peer Review Process Prior to releasing the Verification Report and Verification Statement, an internal review process is conducted by the Internal Peer Reviewer. This process ensures that: All steps identified as being required to complete the verification were completed; Any identified material or immaterial misstatements identified have been either: - corrected by the Project Proponent and reflected in the GHG Assertion; or - documented in the Verification Report, if misstatements persist at the conclusion of the verification. All required documentation detailing the verification process has been prepared, delivered, and retained. Closing the Engagement The verification engagement will be closed out upon delivery of the final Verification Report. ICF Page 11

57 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 5 Verification Schedule The following schedule is planned for the verification (subject to change with agreement between the Verifier and the Project Proponent). Description Scheduled Date Verification Kick-Off Meeting October 25, 2016 Draft Verification Plan to Project Proponent October 19, 2016 Site Visit October 25, 2016 Initial Clarification & Data Request January 28, 2017 Draft Verification Statement and Report February 24, 2017 Final Verification Statement and Report March 7, 2017 ICF Page 12

58 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 6 Verification Risk Assessment The process for completing a Verification Risk Assessment was described in Section 4.2. The following table describes the inherent and control risks analyzed by the Verification Team and the corresponding verification procedure(s) outlined in Section 5 of the Verification Report that have been designed to address these risks. Description of Inherent Risks Inherent Risk Evaluation B1 Nitric Acid Plant (Burner Inlet to Stack) Errors in measurement of the oxidation temperature probe. Errors in measurement of the oxidation pressure transmitter. Errors in measurement of the orifice plate measuring ammonia gas flow rate. Description of Control Risks Manual inspection of calibration overlooks calibration errors Manual inspection of calibration overlooks calibration errors Manual inspection of calibration overlooks calibration errors Control Risk Evaluation Verification Procedure(s) Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Observe meter verification (calibration) tags and reports during site tour Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Observe meter verification (calibration) tags and reports during site tour Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription ICF Page 13

59 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Errors in calculation of the NH3/Air ratio. Errors in measurement of the annubar monitoring air flow rate. Errors in measurement of the stack temperature probe. Errors in measurement of the stack velocity monitoring system. Manual inspection of calibration of equipment parameters used in calculation overlooks calibration errors Manual inspection of calibration overlooks calibration errors Manual inspection of calibration overlooks calibration errors Manual inspection of calibration overlooks calibration errors Observe meter verification (calibration) tags and reports during site tour Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Observe meter verification (calibration) tags and reports during site tour Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Observe meter verification (calibration) tags and reports during site tour Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription ICF Page 14

60 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Errors in measurement of the N 2 O concentration monitoring system. Errors in monitoring operating hours Errors in monitoring production levels Manual inspection of calibration overlooks calibration errors Hard drive malfunction Hard drive malfunction P1 Nitric Acid Plant (Burner Inlet to Stack) Errors in measurement of the oxidation temperature probe. Manual inspection of calibration overlooks calibration errors Observe meter verification (calibration) tags and reports during site tour Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Observe meter verification (calibration) tags and reports during site tour Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency Observe meter verification (calibration) tags and reports during site tour ICF Page 15

61 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Errors in measurement of the oxidation pressure transmitter. Errors in measurement of the ammonia gas flow rate. Errors in calculation of the ammonia to air ratio. Errors in measurement of the annubar monitoring air flow rate. Manual inspection of calibration overlooks calibration errors Manual inspection of calibration overlooks calibration errors Manual inspection of calibration overlooks calibration errors Manual inspection of calibration overlooks calibration errors Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency Observe meter verification (calibration) tags and reports during site tour Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency Observe meter verification (calibration) tags and reports during site tour Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription ICF Page 16

62 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Errors in measurement of the stack temperature probe. Errors in measurement of the stack velocity monitoring system. Manual inspection of calibration overlooks calibration errors Manual inspection of calibration overlooks calibration errors Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency Observe meter verification (calibration) tags and reports during site tour Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency Observe meter verification (calibration) tags and reports during site tour Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency Observe meter verification (calibration) tags and reports during site tour ICF Page 17

63 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Errors in measurement of the N 2 O concentration monitoring system. Errors in monitoring operating hours Errors in monitoring production levels Manual inspection of calibration overlooks calibration errors Emission Offset Claim / Project Level Normal operational changes at the Project may lead to significant changes in emissions during the reporting period Completeness or Consistency of GHG inventory documentation Hard drive malfunction Hard drive malfunction Interview Project personnel responsible for quantifying emissions reductions regarding data metering and validation, data storage, data security, and any manual data entry or transcription Compare raw data records from the DCS Controller against data in the data summary Excel spreadsheet for consistency Observe meter verification (calibration) tags and reports during site tour Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls Interview Project operations personnel regarding changes to equipment inventory or changes in operation that have occurred in the time period covered by the GHG Assertion Compare Orica's OPP, OPR, GHG Assertion against the corresponding AEP templates, as applicable ICF Page 18

64 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Methodologies and calculations for reporting may have changed from previous periods Data used to quantify emissions is consolidated from several systems. Quantification of emissions within the GHG program requires the use of specific accepted methodologies. Low Review Orica's OPP for evidence of applicability for each requirement described by the Protocol Interview Project operations personnel regarding changes to equipment inventory or changes in operation that have occurred in the time period covered by the GHG Assertion Compare emission sources in the current data summary Excel spreadsheet with those in previous years Compare the quantification methodologies utilized for the current vintage credits against those used in previous vintage credits Develop a data life cycle diagram, or data map for each major GHG emissions source and confirm with Project operations and GHG reporting personnel Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls Review quantification formulae and estimation calculations prescribed by the Protocol against those described in the OPP and utilized in the data summary Excel spreadsheet for each GHG emissions source ICF Page 19

65 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Accepted quantification methodologies may not be correctly implemented. Quantification of emissions may contain arithmetic errors Information may be missing from the GHG Assertion. Information may be incorrectly transcribed into the final GHG Assertion Data is entered into a centralized data management system manually, which poses a risk of transcription error. A significant shutdown or turn-around occurred at the Project over the reporting period. Low Low Low Low Calculate emissions reduction claim from original, second-party or third-party data (including and not limited to an assessment of potential double counting of emissions from quantified emission sources, and an evaluation of the appropriatness of using a simple instead of weighted average) Calculate emissions reduction claim from original, second-party or third-party data (including and not limited to an assessment of potential double counting of emissions from quantified emission sources, and an evaluation of the appropriatness of using a simple instead of weighted average) Review GHG Assertion against guidance documents for completeness Compare calculated values to those in the GHG Assertion for transcription accuracy Compare calculated values to those in the GHG Assertion for transcription accuracy Interview Project operations personnel regarding changes to equipment inventory or changes in operation that have occurred in the time period covered by the GHG Assertion ICF Page 20

66 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 A change in the ownership structure of the Project has occurred since the prior reporting period or since crediting began. Less common greenhouse gases are emitted from the Project, and may not be included in the GHG Assertion. Quantification of emissions reductions requires the use of emission factors and several other parameters GHG Assertion must meet Offset Eligibility Criteria Low Interview Project operations personnel regarding ownership of emissions reduction credits Through the site visit and understanding of the Project, evaluate any emissions sources or sinks that are not considered by the Protocol Compare emission factors used in calculations against reference documents cited in Protocol and Orica's OPP Assess accuracy and relevance of data parameters (including but not limited to GWP's, densities, molecular weights, temperature, pressure or other parameters listed on the Protocol) through a review against reference documentation and/or recalculation Assess if and how the Project meets the Offset Eligibility Criterion as described in AEP's Technical Guidance for Offset Project Developers ICF Page 21

67 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 Information outlined in Table 26: Information Confirmed During the Verification of AEP's Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance (version 1.0, January 2013) are complete Complete confirmations outlined in Table 26 of AEP s Technical Guidance for GHG Verification at Reasonable Level Assurance, v1.0, January 2013 ICF Page 22

68 Verification Plan Nitrous Oxide from Nitric Acid Production NAP2 The detection risk is a measure of the risk that the verification procedures will fail to detect material misstatements, should such misstatements exist. The verification procedures will be developed to address inherent and control risks, while ensuring the level of detection risk is sufficiently low to reach a verification conclusion at a reasonable level of assurance. The results of the Verification Risk Assessment will be utilized by the Verification Team to develop the verification procedures, which are outlined in Section 5 of the Verification Report. ICF Page 23

69 Sampling Plan, Nitrous Oxide Abatement from Nitric Acid Production NAP2 The following sampling plan defines the methodology used to select data to be tested under verification procedures related to confirmation of data through sampling of substantiating evidence. All other procedures do not include sampling, as described in the Verification Report. Data Description Oxidation temperature Oxidation Pressure Ammonia gas flow rate to the AOR Verification Procedure(s) Compare raw data records from DCS Controller, against data in the data summary Excel spreadsheet for consistency. Data Reviewed (Sample Size, if appropriate) 2 minute raw interval data for 3 weeks in 2016: February 1 to 7 June 6 to 12, and December 12 to 18 Sampling Methodology Random sampling Air Flow Rate Stack Temperature Stack Velocity N 2 O Concentration level ICF Page 1

70 Conflict of Interest Checklist Question Yes No 1. Can the verifying organization or the Verification Team members directly benefit from a X financial interest in the Project Developer or the Project Developer s Project? For example: Owning shares of the Project Developer; Having a close business relationship with the Project Developer; Contingent fees relating to the results of the engagement; Potential employment with the Project Developer; or Undue concern about the possibility of losing the verification or other fees from the Project Developer. 2. Can the verifying organization or Verification Team members be in a position of X assessing their own work? For example: Provided GHG consultation services to the project; Provided validation for the project; If providing non-ghg work for the company, consideration needs to be given as to how potential and perceived conflicts of interest can be managed; A member of the verification team was previously employed with the company. 3. Does the verifying organization or a member of the Verification Team, or a person in the chain of command for the verification, promote or be perceived to promote, a Project X Developer's position or opinion to the point that objectivity may, or may be perceived to be, compromised? For example: Dealing in, or being a promoter of, GHG credits on behalf of a Project Developer; or Acting as an advocate on behalf of the Project Developer in litigation or in resolving disputes with third parties. 4. Is one or more of the Verification Team too sympathetic to the Project Developer's interests by virtue of a close relationship with a Project Developer, its directors, officer or employees? For example: A person on the Verification Team has a close personal relationship with a person who is in a senior GHG compilation role at the Project Developer; or The Verification Team or a person of influence on the Verification Team has accepted significant gifts or hospitality from the Project Developer. 5. Is a member of the Verification Team or a person in the chain of command deterred from acting objectively and exercising professional skepticism by threats, actual or perceived, from the directors, officers or employees of the Project Developer? For example: The threat of being replaced as a third party verifier due to a disagreement with the application of a GHG quantification protocol; Fees from the Project Developer represent a large percentage of the overall revenues of the verifying organization; The application of pressure to inappropriately reduce the extent of work performed in order to reduce or limit fees; or Threats of litigation from the Project Developer. X X

71 The declaration made in this statement is correct and truly represents ICF Consulting Canada, Inc. and the members of the Verification Team. Dated this seventh day of March Selena Fraser, P.Eng. Professional Engineer, Ontario ( ) Lead Verifier ICF Consulting Canada, Inc. Ottawa, Ontario Duncan Rotherham Vice President and Managing Director ICF Consulting Canada, Inc. Toronto, Ontario