Offset Project Plan Form: Project Developer: Tolko Industries Ltd. Prepared by: Blue Source Canada ULC. Date: January 30, 2019

Transcription

1 Project Plan Form: Project Developer: Tolko Industries Ltd. Prepared by: Blue Source Canada ULC Date: January 30, 2019 Version 2.0 Project Plan Template July 2018

2 Table of Contents 1.0 Contact Information Project Scope and Site Description Project Description Expected Lifetime of the Project Description of how the project will achieve GHG emission reductions/ removals Conditions Prior to Project Initiation Project technologies, products, services and the expected level of activity Protocol Relevant Approved Quantification Protocol Protocol Applicability Flexibility Mechanisms Risks Project Quantification Inventory or Sources and Sinks Justification for excluding sources and sinks Quantification of Sources and Sinks Baseline and Project Condition Baseline Condition Project Condition Quantification Plan Net Reductions Eligible Reductions Levied s Reductions Monitoring Plan Data Management System Data Management and QA/QC at Tolko Industries Data Management and QA/QC at Bluesource Back-up Procedures at Bluesource Document Retention Policy at Bluesource Project Developer Signature References Appendix A: Back-Up Procedures at Bluesource Appendix B: Document Retention Policies at Bluesource List of Figures Figure 1: Location of... 6 Figure 2: Tolko Slave Lake Project Site Plan... 7 Figure 3: GTS Biomass Energy System... 8 Figure 4: Sources and sinks for the project condition of biomass combustion to for energy production Figure 5: Data Flow Chart List of Tables Table 1: Project Contact Information... 4 Table 2: Project Information... 4 Page 2 of 25

3 Table 3: factors used for Table 4: Sample Monitoring Plan Table 5: Metering maintenance and calibration details Page 3 of 25

4 1.0 Contact Information Table 1: Project Contact Information Project Developer Contact Information Additional Contact Information Tolko Industries Ltd. Tolko Industries Ltd. Michael Towers Marc Fillion PO Box 39, th Street PO Box 39, th Street Vernon, British Columbia, V1T 6M1 Vernon, British Columbia, V1T 6M1 Phone: (250) Phone: (250) Authorized Project Contact (if applicable) Blue Source Canada ULC Justin Friesen 1605, 840-7th Avenue SW Calgary, AB, T2P 3G2 (403) (ext 301) Project Scope and Site Description Table 2: Project Information Project title Project purpose and objectives Activity start date crediting period (herein referred to as the Project ). The Project uses waste biomass to generate thermal energy that is required to heat the adjoining OSB mills dryers, log ponds, building and on-site steam generator. The opportunity for generating emissions offsets based on version 2.2 of the protocol exists for projects that avoid GHG emissions by diverting feedstock from landfills or open air combustion of harvest debris. The project began November 27, 2007, and is a result of actions taken on, or after, January 1, 2002 The project began November 27, 2007, and is a result of actions taken on, or after, January 1, Proponents for the Project intend to claim offsets for a period of 8 years, starting on January 1, 2015 and ending on December 31, After this period, the Project will be re-assessed for additionality and, as circumstances permit may apply for a 5-year crediting extension period. Page 4 of 25

5 Estimated emission reductions/ sequestration Unique site identifier Estimated total greenhouse gas emission reductions/ sequestration expected from the project in the offset crediting period is 420,000 tonnes of CO2e. Estimated annual greenhouse gas emission reductions/ sequestration expected from the project in the offset crediting period is 52,000 tonnes of CO2e. The project is located in Alberta. The Tolko Slave Lake OSB Mill (herein referred to as the OSB Mill ) is located 10km southeast of Slave Lake. LSD: W5 Latitude: o Is the project located in Alberta? Project boundary Longitude : o Yes The project covers approved Methane, dioxide, and Nitrous oxide greenhouse gases listed in the CCIR Schedule 1 (Province of Alberta, 2017). The physical boundary includes project sources and sinks as listed by the Protocol apply to the waste biomass system at the Athabasca mill including equipment involved in the transport of waste biomass to the boiler, and equipment load involved in the thermal heat transport system. Considerations have been made for functional equivalence with a natural gas fired system on site. The geographical boundary is restricted to the site bounds of the Athabasca mill. Transport of biomass to site is excluded, however, as per the Protocol design, upstream emissions associated with fuel extraction and processing and electricity generation are considered. The operational project boundary covers those operations under the authority and control of Tolko Industries Ltd. that occur at the Athabasca mill. Tolko s Mill is located 10km southeast of Slave Lake, Alberta (see Figure 1: Location of below). The Project is owned and operated by Tolko Industries Ltd. (Tolko). The physical boundary of the project is the bounds of the Tolko Slave Lake facility. The operational project boundary is the mills thermal energy system which combusts the biomass. The update to protocol version 2.2 has made emissions offsets generated from fuels covered under the carbon levy ineligible. 8. The Project quantifies, tracks and reports emissions from fossil fuels that are subject to the carbon levy (i.e. thermal energy displacement and natural gas consumption) but does not include these emissions as eligible emissions offsets. Page 5 of 25

6 Figure 1: Location of Ownership Tolko Industries Ltd. owns and operates the Athabasca Engineered Wood Plant. As such, direct emission reductions generated by the project, from the production of thermal energy from biomass, are owned solely by the Proponent. Bluesource Canada ULC, has the right to market and sell the emissions offsets on behalf of Tolko Industries Ltd. through contractual rights. These contracts and Plant ownership records will be made available to the verifier to demonstrate entitlement. 2.1 Project Description Expected Lifetime of the Project The Project is a commercial enterprise with no fixed end-date and is expected to continue for as long as the equipment is operational and commercially viable. This is expected to be well in excess of the credit duration period Description of how the project will achieve GHG emission reductions/ removals The project condition consists of the use of two GTS Energy Reciprocating Grade Combustion systems to combust biomass wastes and convert this into heat energy. Biomass waste is sourced from the adjoining wood products facility and mostly consists of waste forest mill residues including: bark and screen files. The production of heat energy from the biomass waste allows for fossil fuel displacement, directly reducing GHG emissions through this process. The opportunity for generating emissions offsets based on version 2.2 of the protocol exists for projects that avoid GHG emissions by diverting feedstock from landfills or open-air combustion of harvest debris. s offsets are no longer eligible to be created from reduction of levied fossil fuels. Page 6 of 25

7 A simplified site layout of the Tolko operation is included as Figure 2: Tolko Slave Lake Project Site Plan and a GTS Energy System Diagram as below Figure 3: GTS Biomass Energy System. With version 2.2 of the protocol being adjusted to align with the carbon levy, and the quantification of biogenic carbon, the credits Tolko annually produces will be impacted. Figure 2: Tolko Slave Lake Project Site Plan Page 7 of 25

8 Figure 3: GTS Biomass Energy System Conditions Prior to Project Initiation The Tolko Slave Lake OSB Mill is a new facility that began commissioning on November 26, The facility was closed in 2009 and then reopened in December Without the project the heat being produced by the OSB Mill would have been produced through the combustion of natural gas. As well, waste biomass feedstock would have been incinerated. This Project is a commercial enterprise with no fixed end-date and is expected to continue for as long as the equipment is operational and commercially viable. This is expected to be well in excess of the credit duration period of 8 years from January 1, 2015 to December 31, Project technologies, products, services and the expected level of activity The following section provides a description of project specific technologies, products and services that result from the implementation of biomass combustion at the Tolko Slave Lake OSB Mill. The project consists of the generation of thermal energy through GTS Energy s gasification technology which converts wood residues into syngas, a combustible fuel gas consisting primarily of hydrogen and carbon monoxide, which can be burned to generate heat and/or power in a variety of applications. Non-combustible ash is also produced in the process. Under normal circumstances the wood products facility creates waste wood material which is used as fuel. This fuel is ground up by the hogger and is conveyed directly to the GTS Energy system fuel surge bins, the stand-by wet bin or to a pile outside. During upset conditions with the hog supply, the wet fuel bin will start emptying its reserve to maintain the required fuel feed rate. The wet fuel bin has a hydraulic unit which controls three large cylinders, which alternate to shuffle fuel forward to a distribution screw and into an out-feed conveyor. This then leads into the GTS Energy system fuel feed conveyors. The GTS Energy Reciprocating Grate Combustion system uses a reciprocating grate to efficiently utilize biomass hog fuel. The inclined reciprocating grate pushes biomass feedstock down the length Page 8 of 25

9 of the grate through distinct drying, gasification, combustion and burn-out zones. These grates are high alloy material so air cooling is sufficient. The grates are divided in multiple sections of varying speeds and consist of several under-fire air zones which results in more complete combustion of the biomass. Altering the amount of time that the fuel spends on the grate prevents over burning dryer fuel and underutilizing wetter fuel. Ash is also produced through the gasification of biomass and is automatically discharged off the end of the grate into an ash conveying system. Hot combustion gasses at 1000 o C from each of the energy systems are sent to both the strand rotary drum dryer and the thermal oil heaters. The dryer system removes moisture from the wood strands from approximately 47% moisture to 12% moisture prior to application of the OSB resin. The thermal oil in the oil heaters is heated to 600 o C and is pumped to various process areas to provide heat; these areas include the press section, log pond heating, exhaust gas heating and building heat. 2.2 Protocol Relevant Approved Quantification Protocol The approved Protocol for use in the Project is the Quantification Protocol for Energy Generation from the Combustion of Biomass Waste, version 2.2, June 2018 (Alberta Climate Change Office, June 2018). ACCO released a memorandum on April 6, 2018 specifying protocols that have been updated and requirements for currently registered offset projects to update to the new protocols no later than January 1, The protocol updates were part of a process to align the offset system with the carbon levy. Accordingly, the Project s offset project plan has been updated to version 2.2 of the protocol, however, it is only applicable to Project reporting periods from January 1, 2019 onwards as specified by ACCO. As such, any Project credits generated for earlier reporting periods but submitted after January 1, 2019 will continue to use the previous offset project plan utilizing protocol version Protocol Applicability The following section provides the reasoning for the applicability of using the Quantification Protocol for the Energy Generation from the Combustion of Biomass Waste, version 2.2 (ACCO, 2018). Project developers must provide sufficient evidence to demonstrate that: 1. The energy produced from biomass is offsetting fossil fuel-generated energy (ACCO, 2018) Had the Project not been undertaken, thermal energy would have been generated through the combustion of natural gas. As such, the energy produced from biomass is offsetting fossil fuelgenerated energy. 2. Reductions achieved by the project are based on actual measurement and monitoring, as indicated by the proper application of this protocol (ACCO, 2018) The reductions achieved by the Project are based on direct measurements of the biomass usage as well as invoices for natural gas, propane, and diesel consumption. 3. The project meets the offset system eligibility criteria specified in the Competitiveness Incentive Regulation (CCIR), standard and guidance documents for the Alberta System (ACCO, 2018) The Project meets all of the requirements for offset eligibility as specified in the applicable regulation and guidance documents for the Alberta System, as discussed in Section 1.0. Page 9 of 25

10 2.2.3 Flexibility Mechanisms The Project has not used any flexibility mechanisms to date. The Protocol enables emissions offsets to be generated from landfill avoidance and open-air combustion in the baseline, which are also part of the flexibility options. To enable eligible emissions offsets for 2019 the Project may seek approval from ACCO to use one of these flexibility mechanisms. 2.3 Risks In the operation of any GHG offset project there are a number of inherent risks. Many of these risks are identified in the protocol. The Project operation and design ensures that all risks are identified and managed in order to avoid compromising the integrity of the Project. The primary risk associated to this Project is meter malfunction/ failure. A metering failure would result in the inability to correctly capture consumption data at the OSB Mill. This would produce uncertainties in the volume of biomass that has been combusted or the amount of fossil fuel consumed for the operation of equipment and facilities. To mitigate this risk regular maintenance checks and calibration of the meters are performed as outlined in Section 5.0. An additional project uncertainty is the energy content of biomass waste used for energy production. The energy content of biomass waste from the OSB Mill is not routinely measured. Therefore, an average energy content for the biomass waste has been provided by Tolko for use in the Project. 3.0 Project Quantification 3.1 Inventory or Sources and Sinks The Quantification Protocol for Energy Generation from Combustion of Biomass Waste, Version 2.2 (ACCO, 2018) contains a list of baseline and project sources and sinks (SSs) that were deemed applicable for projects developed according to the protocol. The SSs for the project are identified in Figure 4: Sources and sinks for the project condition of biomass combustion to for energy production, below. Page 10 of 25

11 Figure 4: Sources and sinks for the project condition of biomass combustion to for energy production Justification for excluding sources and sinks As stated in the Protocol: not all parameters are applicable to all biomass to energy generation projects. Those sources and sinks (SSs) that are not applicable will be excluded as their input variables will be zeros. As such, the project developer can exclude sources and sinks that are not applicable to their project with reasonable justification. The following SSs have been excluded from quantification: s under SS (B1/P1) Collection, Transfer and Transport of Biomass (levied) The collection, transfer and transportation of biomass are functionally equivalent in the project and baseline condition; i.e. biomass would have still been transported to the OSB Mill for processing. Therefore, emissions from this source have been excluded. s under SS (B15) Biomass Disposal As per the Protocol, incineration of biomass is an eligible disposal scenario up to January 1, As such, this source is no longer applicable to the Project and has been excluded from quantification. The Project may seek approval to include emission sources from biomass disposal through landfill avoidance or open-air combustion and if granted project documentation will reflect the inclusion of this emission source. Page 11 of 25

12 s under SS (B3/P3) Processing of Biomass (levied) The processing of biomass is functionally equivalent in the project and baseline conditions; i.e. biomass would have continued to be processed at the OSB Mill. Therefore, emissions from this source have been excluded. s under SS (B6) Displaced Off-site Electricity Generation Off-site No off-site electricity generation is displaced by the project; therefore, emissions from this source are not included in quantification. s under SS (B16) Displaced Off-site Heat Generation (levied) No off-site heat generation is displaced by the project; therefore, emissions from this source are excluded. s under SS (B13) Displaced On-site Electricity Generation No on-site electricity generation is displaced by the project; therefore, emissions from this source are not applicable. s under SS (B12) Facility Operation (levied) Electricity usage for the operation of the OSB Mill is functionally equivalent between the baseline and project. As such, emissions from this source are not included Quantification of Sources and Sinks The general methods of quantification for the required greenhouse gas calculations are as follows: Biomass Consumption (tonnes) Logs accepted at the OSB Mill are hauled to a mill scale where weight is recorded. Sample loads are set aside based on an intensity level as prescribed by AEP. Sample loads are then manually scaled by a certified scaler to determine conversions to m 3. These conversions are used to determine the m 3 of total deliveries. This value is reported to AEP on a monthly basis, and stumpage based on these volumes is paid to AEP quarterly. Biomass feedstock used in the GTS Energy systems is not measured directly. However, the tonnage of biomass hog fuel that is produced at the OSB Mill is measured. Each energy system s air pressure balance and O2% are continuously monitored for the combustion of flu gas. From this, the total cubic feet of airflow through each energy system can be inferred by calculation. In turn, the fuel heating value can be calculated and using the moisture content of the biomass, the biomass consumption tonnage is estimated. Diesel Consumption (litres) Monthly diesel consumption is metered and provided to the Proponent through monthly invoices for the project. Propane Consumption (litres) Monthly propane consumption is metered and provided to the Proponent through monthly invoices for the project. Page 12 of 25

13 Table 3: factors used for Parameter Natural gas combustion Natural Gas Extraction and Processing Diesel Combustion Diesel Production Biomass Combustion Propane Combustion Biogenic Relevant SS B12 B4, P4 P12 P4 CO kg/m kg/m kg/l kg/l CO 2 Source CH kg/m kg/m kg/l kg/l P kg / TJ P12 B20, P kg/l 0.84 tco 2/tonne fuel National Inventory, 2016 ( ), Table A6-34, wood fuel/ wood waste kg/l CH 4 Source IPCC Tier 1 Sources for Stationary Combustion N 2O kg/m kg/m kg/l kg/l 4 kg / TJ kg/l N 2O Source IPCC Tier 1 Sources for Stationary Combustion Page 13 of 25

14 3.2 Baseline and Project Condition Baseline Condition In the baseline scenario for the Project, biomass wastes would have previously been incinerated. The baseline scenario for the Project, as per the Protocol, is projected based on the assumed use of natural gas fuel for heat production. Functional equivalents are used to calculate effects. The baseline scenario uses a dynamic, projection baseline for calculating emissions. As a result of the Project, the OSB Mill produces heat energy through the combustion of biomass waste. The OSB Mill consumes all heat that is produced and as such, displaces thermal energy requirements that would have otherwise been sourced from fossil fuels Project Condition The GTS Biomass Energy System reduces the Plant s waste by utilizing offcuts other waste as fuel to displace a portion of the electricity load and process steam requirements through on-site generation. 3.3 Quantification Plan Net Reductions The following equations serve as the basis for calculating the emission reductions from the comparison of the baseline and project condition as per the Protocol: Reduction = s Baseline s Project s Baseline = sum of the emissions under the baseline condition. s Collection, Transfer and Transport of Biomass = emissions under SS (B1) (levied emissions no longer included) s Biomass Disposal = emissions under SS (B15) s Processing of Biomass = emissions under SS (B3) (partly covered under carbon levy, not entirely included) s Displaced Off-site Electricity Generation Off-site = emissions under SS (B6) s Displaced Off-site Heat Generation = emissions under SS (B16) (levied emissions no longer included) s Displaced On-site Electricity Generation = emissions under SS (B13) s Displaced On-Site Heat Generation = emissions under SS (B18) (levied emissions no longer included) s Facility Operation = emissions under SS (B12) (partly covered under carbon levy, not entirely included) s Fuel Extraction and Processing = emissions under SS (B4) s Project = sum of the emissions under the project condition. s Collection, Transfer and Transport of Biomass = emissions under SS (P1) (levied emissions, no longer included) s Biomass Processing = emissions under SS (P3) (partly covered under carbon levy, not entirely included) Page 14 of 25

15 s Facility Operation = emissions under SS (P12) (partly covered under carbon levy, not entirely included) s Combustion of Biomass and Fossil Fuels = emission under SS (P15) (partly covered under carbon levy, not entirely included) s Fuel Extraction and Processing = emission under SS (P4) SS B18 (Displaced On-Site Heat Generation) (levied emissions no longer included, quantified) Where, s of CO2 = Volume of Natural Gas (m 3 ) x EFNG-CO2 s of CH4 = Volume of Natural Gas (m 3 ) x EFNG-CH4 s of N2O = Volume of Natural Gas (m 3 ) x EFNG-N2O Volume of Natural Gas (m 3 ) = Volume of Natural Gas (GJ) / HHVNG (MJ/m 3 ) Volume of Natural Gas (GJ) = Biomass (tonnes) * LHVBiomass (GJ/tonne) Biomass (tonnes) = Biomass used in project for energy generation LHVBiomass (GJ/tonne) = lower heating value of biomass HHV (MJ/m 3 ) = higher heating value of natural gas EFNG-CO2/ EFNG-CH4/ EFNG-N2O = factor for natural gas combustion for CO2, CH4 and N2O (see Table 1.) SS B4 (Fuel Extraction and Processing) Where, s of CO2 = Volume of Natural Gas (m 3 ) x EFNGEP-CO2 s of CH4 = Volume of Natural Gas (m 3 ) x EFNGEP-CH4 s of N2O = Volume of Natural Gas (m 3 ) x EFNGEP-N2O Volume of Natural Gas (m 3 ) = Volume of Natural Gas (GJ) / HHVNG (MJ/m 3 ) Volume of Natural Gas (GJ) = Biomass (tonnes) * LHVBiomass (GJ/tonne) Biomass (tonnes) = Biomass used in project for energy generation LHVBiomass (GJ/tonne) = lower heating value of biomass HHV (MJ/m 3 ) = higher heating value of natural gas EFNGEP-CO2/ EFNGEP-CH4/ EFNGEP-N2O = factor for natural gas extraction and processing for CO2, CH4 and N2O (see Table 1.) SS B20 (Biogenic s) (Quantified, but not included) s of CO2 (Biogenic) = Mass Biofuel Combusted (Tonnes) x EFi-CO2 EFi-CO2 = CO2 s for Biomass Fuel (tco2/tonne fuel), (see Table 4: Sample Monitoring Plan) SS P12 (Facility Operation) (partly covered under carbon levy, emissions from levied fuels quantified by not included) Where, s of CO2 = Volume of Propane (litres) x EFP-CO2 + Volume of Diesel (litres) x EFD-CO2 s of CH4 = Volume of Propane (litres) x EFP-CH4 + Volume of Diesel (litres) x EFD-CO2 s of N2O = Volume of Propane (litres) x EFP-N2O + Volume of Diesel (litres) x EFD-CO2 Volume of Propane (litres) = volume of propane used for operation of gassifer Volume of Diesel (litres) = volume of propane used for site operation Page 15 of 25

16 EFP-CO2/ EFP-CH4/ EFP-N2O = factor for propane combustion for CO2, CH4 and N2O (see Table 1.) EFD-CO2/ EFD-CH4/ EFD-N2O = factor for diesel combustion for CO2, CH4 and N2O (see Table 1.) SS P15 (Combustion of Biomass and Fossil Fuels) (partly covered under carbon levy, emissions from levied fuels quantified by not included) Where, s of CH4 = Biomass (GJ) x EFB-CH4 s of N2O = Biomass (GJ) x EFB-N2O Biomass (GJ) = Biomass (tonnes) * LHVBiomass (GJ/tonne) LHVBiomass (GJ/tonne) = Lower heating value of biomass EFB-CH4/ EFB-N2O = factor biomass combustion for CH4 and N2O (see Table 1.) SS P4 (Fuel Extraction and Processing) Where, s of CO2 = Volume of Propane Gas (m 3 ) x EFPEP-CO2 + Volume of Diesel (litres) x EFDP-CO2 s of CH4 = Volume of Propane Gas (m 3 ) x EFPEP-CH4 + Volume of Diesel (litres) x EFDP-CO2 s of N2O = Volume of Propane Gas (m 3 ) x EFPEP-N2O + Volume of Diesel (litres) x EFDP-CO2 Volume of Propane Gas (m 3 ) = volume of propane (litres) * Propane ideal liquid to gas ratio /1000 Volume of Propane (litres) = volume of propane used for operation of gassifer Volume of Diesel (litres) = volume of diesel used for site operation EFPEP-CO2/ EFPEP-CH4/ EFPEP-N2O = factor for natural gas extraction and processing for CO2, CH4 and N2O (see Table 1.) EFDP-CO2/ EFDP-CH4/ EFDP-N2O = factor for propane extraction and processing for CO2, CH4 and N2O (see Table 1.) SS P20 (Biogenic s) Where, s of CO2 (Biogenic) = Mass Biofuel Combusted (Tonnes) x EFi-CO2 EFi-CO2 = CO2 s for Biomass Fuel (tco2/tonne fuel), (see Table 4: Sample Monitoring Plan) Eligible Reductions s Baseline = sum of the emissions under the baseline condition. s Collection, Transfer and Transport of Biomass = s Fuel Extraction and Processing = emissions under SS (B4) s Project = sum of the emissions under the project condition. s Collection, Transfer and Transport of Biomass = s Facility Operation = emissions under SS (P12) (partly covered under carbon levy, not entirely included) s Combustion of Biomass and Fossil Fuels = emission under SS (P15) (partly covered under carbon levy, not entirely included) Page 16 of 25

17 s Fuel Extraction and Processing = emission under SS (P4) Levied s Reductions s Baseline = sum of the emissions under the baseline condition. s Collection, Transfer and Transport of Biomass = s Displaced On-Site Heat Generation = emissions under SS (B18) s Project = sum of the emissions under the project condition. s Collection, Transfer and Transport of Biomass = s Facility Operation = emissions under SS (P12) (partly covered under carbon levy, not entirely included) s Combustion of Biomass and Fossil Fuels = emission under SS (P15) (partly covered under carbon levy, not entirely included) s Fuel Extraction and Processing = emission under SS (P4) 3.4 Monitoring Plan Table 4 below outlines details of the key parameters that will be monitored and how data will be collected for the Project. Parameter Table 4: Sample Monitoring Plan Source/sink identifier and name SS P12 Facility Operation SS P4 Fuel Extraction and Processing (quantified, not included) SS P15 Combustion of Biomass (levied fuel emissions quantified but not included) SS P12 Facility Operation (levied fuel emissions quantified but not included) SS P4 Fuel Extraction and Processing SS B18 Displaced On Site Heat Energy (quantified, not included) SS B4 Fuel Extraction and Processing Data parameter Propane Consumption Total Feedstock Use Diesel Consumption Natural Gas Consumption Estimation, modeling, measurement or calculation approaches Direct metering Estimated Direct metering Calculation Data unit litres tonnes litres m 3 Sources/Origin Propane invoices from Bluewave Energy Amount of biomass feedstock sourced by Tolko for combustion Diesel invoices from PetroCanada Amount of natural gas that would have been combusted in absence of the project, calculated through project biomass feedstock use Page 17 of 25

18 Location of Sampling Points On site Logging Truck Scale, Hog fuel scale On site On site Monitoring frequency Monthly Continuous Monthly Monthly Description and justification of monitoring method Most accurate method for determining parameter Most accurate method for determining parameter Most accurate method for determining parameter Most accurate method for determining parameter Uncertainty Unknown n/a Unknown Unknown 3.5 Data Management System Figure 5 provides a flow chart for manual and automated data that is entered into the Blue Source Calculator for offset emissions quantification. Figure 5: Data Flow Chart 3.6 Data Management and QA/QC at Tolko Industries In general, the data control process employed for this Project consists of manual or electronic data capture and reporting, and manual entry of monthly total or average values into a Quantification Calculator developed by Blue Source Canada ULC ( Bluesource ). There are two data streams involved in this project: Electronic data captured and reported by the continuous metering systems; Manual data entry of all other parameters. All GTS Energy control system parameters and data are monitored and recorded by the on-site PLC system. This data is stored by both the Galaxy Historian and DGS data collection systems. The Galaxy Historian system polls the data at a regular interval (generally ever 10 seconds) and stores this information when the value changes. The DGS system polls the data every 30 seconds. The Page 18 of 25

19 full detail is retained for 2 weeks and is then condensed to hourly periods for the key performance indicator (KPI) hourly reports. The KPI hourly data is maintained for at least the current year. Detailed data can be restored from backups if necessary. Data is backed up every night at multiple locations including the Slave Lake Office, Head Office and at an offsite storage location. All electrical and control system employees have access to the PLC control systems. These staff can edit the code which generates the values and can therefore calibrate the instruments that collect the data, when necessary. Once the data has been collected, it can only be modified by a specific request from operations. The Galaxy Historian data can only be modified with extreme effort by a controls group employee. The DGS data can be modified by Valley West personnel and by controls group employees who have query access to the DGS Athabasca database. Propane and diesel consumption are metered by Bluewave Energy and PetroCanada respectively, and provided to the Proponent through monthly invoices. Additionally, Table 5 provides the details and calibration for each parameter (where applicable). Table 5: Metering maintenance and calibration details Project Specific Data Meter ID Meter Model Maintenance Schedule Calibration Schedule Accuracy Rating Logging Truck Scale PLE S/N FLE S/N Western M2000D Every 6 months Every 6 months +/-0.10% Propane Consumptio n Bluewave Energy (supplier) Third Party Meter Third Party Meter Third Party Meter Third Party Meter Diesel Consumptio n PetroCanada (supplier) Third Party Meter Third Party Meter Third Party Meter Third Party Meter 3.7 Data Management and QA/QC at Bluesource Bluesource holds itself to the highest professional and ethical standards. Staff all have experience in working on GHG projects and/or training in the use of ISO Junior staff members are mentored closely until their level of competence is deemed sufficient for them to work more independently. This experience and training helps to ensure that errors and omissions are minimised, and that project documentation is compiled in accordance with the principles of relevance, completeness, consistency, accuracy, transparency and conservativeness. Bluesource operates a rigorous internal QA/QC process that is built around the principle of senior review (i.e. calculations and reports are checked by experienced staff members prior to being released). The quantification calculator, for example, will be checked for: Transcription errors/omissions Correctly functioning links/formulas in spreadsheets Correct and transparent referencing of data sources Justification of assumptions Page 19 of 25

20 Use of, and compliance with, most up-to-date versions of protocols, technical guidance, etc. In addition, the Project Plan and Project Report will also be senior-reviewed for errors, omissions, clarity, etc. Issues are recorded in Bluesource sqa/qc checklist for the project (and, as necessary, embedded into the reviewed version of the documents and/or calculator) and these will be corrected before these are sent to the third-party verifier. Staff sign an Attestation of Quality Assurance and Quality Control to document that the QA/QC process was followed. This QA/QC process is kept under constant review Back-up Procedures at Bluesource Electronic data is backed up by Bluesource s IT service provider, Calitso. A copy of this back-up procedure is provided as Appendix A Document Retention Policy at Bluesource Bluesource operates a documentation retention policy, which all staff must abide by as a condition of their employment. A copy of this document retention policy is provided as Appendix B. Page 20 of 25

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22 5.0 References CARBON COMPETITIVENESS INCENTIVE REGULATION, CLIMATE CHANGE AND EMISSIONS MANAGEMENT ACT, Alberta Regulation 255/2017, Updated November 20, 2018 ACCO, June Quantification Protocol for Energy Generation from the Combustion of Biomass Waste (version 2.2). [pdf] Edmonton, Alberta: Alberta Climate Change Office AESRD, (version 1.0). [pdf] Edmonton, Alberta: Alberta Environment and Sustainable Resource Development. Environment Canada, National Inventory Report : Greenhouse Gas Sources and Sinks in Canada: Part 2. [pdf] Pollutant Inventories and Reporting Division. Available at: < Government of Alberta. (July 2018). Standard for Greenhouse Gas Project Developers, version 2.0. Edmonton. Page 22 of 25

23 Appendix A: Back-Up Procedures at Bluesource Page 23 of 25

24 Backup Procedure Prepared For: Blue Source Objective To minimize interruptions to business by insuring that operation can be restored in case of Loss of any amount of information due to accidental or malicious deletion; Failure of one or more computers or components such as a hard disk drive; or A disaster resulting in loss of the entire infrastructure, or loss of access to it. Backup Procedure 1. Backup Rotation Rotation is continues and automatic in accordance with retention specified in item 2. All off-site data is stored in Canada at a SSAE 16, CSAE 3416 and ISA3402 certified data center. 2. Retention 30 days of continuous data change, and nightly system state is off site in data center. Data is stored both on-site and off-site Data can be restored as far as 30 days back from on-site and off-site backups 3. Backup Schedule Data backup Full backup is scheduled to run nightly at 8:00PM Image Backup (Entire server backup) Disaster Recovery Backup Scheduled to run nightly at 3am Off site storage All off-site data is stored in Canada at a SSAE 16, CSAE 3416 and ISA3402 certified data center.

25 Appendix B: Document Retention Policies at Bluesource Page 24 of 25

26 Last Revision: August 2, 2017 Document Retention Policy, version All documents relevant to Projects will be kept, in at least electronic format, and where possible, in hardcopy format, for a. At least 10 years beyond the last year in which credits are created (e.g. a project that creates credits between will have all records kept until at least 2028), or b. As required by the Project Program whichever period is longer. 2. Hard copy documents will be kept in project folders in our Blue Source Canada head office location, which is currently Suite 1605, th Av SW, Calgary, AB, T2P 3G2. All electronic documents will be saved to the appropriate project folder on the Calgary Server ( S:\ drive ). 3. The S:\ drive will be backed up in accordance with Blue Source s IT Backup Procedure, which may change from time to time. 4. Blue Source s preference is to keep all documents in electronic form, wherever possible. 5. All employees will comply with this policy as a condition of their employment. Yvan Champagne President, Blue Source Canada ULC