Download as pdf or txt
Download as pdf or txt
You are on page 1of 45

Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –

9238-1983
March 2018

Verification Report for:


Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid
Production – 9238-1983
Proponent:
Orica Canada Inc.

Prepared by:
Ruby Canyon Engineering, Inc.

Prepared for:
Orica Canada Inc.

Version:
Final

Date:
March 1, 2018
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018

Table of Contents
1.0 Summary – Offset Project .................................................................................... 3
1.1 Summary – Facility ....................................................................................................... 5
2.0 Introduction ....................................................................................................... 6
2.1 Objective ........................................................................................................... 6
2.2 Scope ................................................................................................................ 6
2.3 Level of Assurance .............................................................................................. 7
2.4 Criteria .............................................................................................................. 7
2.5 Materiality .......................................................................................................... 7
3.0 Methodology....................................................................................................... 8
3.1 Procedures ......................................................................................................... 8
3.2 Team ................................................................................................................ 9
3.3 Schedule............................................................................................................ 9
4.0 Results ............................................................................................................ 10
4.1 Assessment of Internal Data Management and Controls .......................................... 11
4.2 Assessment of GHG Data and Information ............................................................ 11
4.3 Assessment against Criteria ................................................................................ 12
4.4 Evaluation of the GHG Assertion .......................................................................... 14
4.5 Summary of Findings ......................................................................................... 14
4.6 Opportunity for Improvement ............................................................................. 16
5.0 Closure ............................................................................................................ 16
5.1 Verification Statement ....................................................................................... 16
5.2 Limitation of Liability ......................................................................................... 16
5.3 Confirmations ................................................................................................... 16
6.0 References ....................................................................................................... 17
Appendix A: Final Verification Plan and Sampling Plan ........................................................... 18
Appendix B: Statement of Qualifications .............................................................................. 22
Appendix C: Findings and Issues ........................................................................................ 28
Appendix D: Statement of Verification ................................................................................ 36
Appendix E: Conflict of Interest Checklist ............................................................................ 40
Appendix F: Supplemental Diagrams/Tables/Figures ............................................................. 43

List of Tables
Table 1: Offset Criteria Assessment .................................................................................... 13
Table 2: Summary of Findings ........................................................................................... 15
Table 3: Detailed Findings and Issues Log ........................................................................... 29
Instructions are in italics throughout and should not be deleted when report is complete.
Some instructions are specific to the verification of facilities and for offset projects. The
document is not restricted but do not alter the format, the layout, the headings or the overall
‘look and feel’ of the document. If if is more usefule to paste information outside of the text
box, use the empty line just below the text box to drop text or tables int. This should not
change the headings or the formats. There are several dropdown boxes in the document that
must be completed.
• Complete report in Verdana 10pt font (no italics).
• After the report is complete, right click the table of contents and ‘update field’ which will
update page numbers in Table of Contents.
• If an instruction only applies to facilities or only applies to offsets indicate ‘not applicable’.
• Appendix F is available for additional tables, diagrams etc.
Page 2 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018

1.0 Summary – Offset Project

Item Description

Project Title Orica Nitric Acid Plant 1 – Nitrous Oxide


Abatement from nitric Acid Production
Enter project title (must match the registry
project title)

Project Description The Nitrous Oxide Abatement Project


consists of the installation of a dedicated
Provide a brief description of the project
secondary catalyst in Orica's Nitric Acid
and baseline conditions.
Plant 1 (NAP 1) below the precious metal
catalyst gauze to abate the nitrous oxide
(N2O).

Project Location 264077 Township Road 221 Carseland,


Alberta T0J 0M0. The longitude and latitude
Include the latitude and longitude for each
are 20033E to 200730 E and 23063N to
unique location or installation. Include legal
25296N
land location if applicable and other
information identifying the unique location.

Project Start Date 15 May, 2008


Enter the project start date.

Offset Start Date 15 May, 2008


Enter the start date for offset credit
generation.

Offset Crediting Period 15 May 2008 to 31 December 2017


Enter the offset crediting period, including
the offset start date. Include day, month
year.

Reporting Period 1 January 2017 to 31 December 2017


Enter the reporting period being verified.

GHG Assertion (Actual Emission 285,748 tonnes CO2e


Reductions/Sequestration Achieved)
Enter the actual emissions reductions /
sequestration for the reporting period. Enter
serial numbers if available.

Protocol Quantification Protocol for Nitrous Oxide


Abatement from Nitric Acid Production,
Indicate the relevant protocol (if applicable)
October 2009, Version 1 (Protocol)

Ownership Orica Canada Inc.

Page 3 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
Enter offset project owner.

Project Activity The Project proponent installed a secondary


catalyst directly below the ammonia
State how the project activity meets the
oxidation reactor to abate N2O emissions.
eligibility requirements
See Table 1 for more details.

Project Contact Jeff Zubach


Enter contact name, company name, Orica Canada Inc.
mailing address, phone number and email
PO Box 250, Carseland, AB, Canada, T0J
address.
0M0
1-403-936-2228
Jeff.zubach@orica.com

Verifier Phillip Cunningham


Verifier name, verifier’s company name, Ruby Canyon Engineering, Inc.
address, phone number email etc.
743 Horizon Court, Suite 385 Grand
Junction, CO
1-970-241-9298 ext. 13

Verification Team Members Phillip Cunningham – Lead Verifier


Include verification team members, roles, Michael Coté – Senior Reviewer
training, training dates and qualifications.
Nina Pinette – Team Member
Zach Eyler – Team Member
See section 3.2 for details regarding
training, training dates and qualifications

Designated Signing Authority Ronald Collings


Enter the designated signing authority for Vice President of Ruby Canyon Engineering,
this verification. Inc. and P.E.

Verification Strategy RCE tailored the verification strategy,


including testing Orica Canada Inc. (Orica)
Describe the verification strategy used for
controls and substantive testing on
the verification, including rationale for the
evidence required for a Nitrous Oxide
approach. Note, if a controls reliance is
Abatement Project, to specific data
used, provide justification for how the
streams, controls and evidence available
project is able to support this approach.
for the offset project. The verification
strategy drives the verification plan and
consequently the sampling plan. The
verification team reviewed control
processes functioning within Orica’s
greenhouse gas assertion calculation and
quality assurance plan (QAP) as well as
performing substantive tests on original
data. Orica relies on controls analyzing data
and their QAP to ensure that all Protocol

Page 4 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
calculations are correct, and that
equipment used to measure nitrous oxide
(N2O) is functioning properly and recording
data accurately.

1.1 Summary – Facility

Item Description

Facility Name and Company Name Not applicable.


List company name and facility name.

Facility Description Not applicable.


Provide a brief description of the facility.

Baseline Emissions Intensity Not applicable.


Description
List the approved BEIA and the baseline
years.

Reporter Contact Not applicable.


Enter contact name, company name,
mailing address, phone number and email
address.

GHG Assertion Not applicable.


Enter the actual emissions, production,
emissions intensity and the reduction target
being verified.

Verifier Not applicable.


Verifier name, verifier’s company name,
address, phone number email etc.

Verification Team Members Not applicable.


Include verification team members, roles,
training, training dates and qualifications.

Designated Signing Authority Not applicable.


Enter the designated signing authority for
this verification.

Page 5 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
2.0 Introduction
Provide an introduction to the facility or project, the verification, and the background.
For Offset Project: summary of offset project baseline, changes to the baseline since project
start date and summary of changes at the project since the offset project start date or baseline
period.
For Facilities: Description of compliance or baseline report, facility/project boundary, facility
identification information, GHG historical performance, summary of changes since the baseline
or since the last compliance report.

The Orica plant produces low density prilled ammonium nitrate which is used in mining,
construction and logging industries. N2O is produced as a side reaction when ammonia
oxidation takes place on a platinum-rhodium catalyst gauze. During the Offset Project Baseline,
Orica did not use non-selective catalytic reduction to destroy NOx emissions. The Project
involves the installation of a continuous emissions monitoring system (CEMS) to measure N2O
emissions and the installation of a secondary abatement catalyst to destroy N2O. Prior to the
baseline sampling period, Orica used data from several historical campaigns to establish
allowable operating conditions of the plant. The Baseline sampling period commenced after the
installation of a PROCAL P-200 monitoring system which measures N2O emissions in the plant
stack. Orica calculated a Baseline emission factor to use throughout the Project’s lifetime. The
Project changed to a different type of secondary abatement catalyst in May of 2014. Alberta
Environment and Parks granted the Project a five-year extension in February of 2016.

2.1 Objective
Describe the objective of the verification (should include expressing an opinion).
The objective of verification activities was to ensure that the claimed GHG emission reductions
are materially correct and a fair representation of Project activities in accordance with the
Carbon Competiveness Incentive (CCI) regulation, Protocol and relevant guidance and
determine if the GHG assertion is materially correct to a reasonable level of assurance within a
materiality threshold of 5%. RCE’s goal was to confirm that the GHG emission reductions were
within scope, real, quantifiable, additional, verifiable, counted once, and under clear ownership.

2.2 Scope
Define the scope in terms of: geographical, organizational, activities and processes, sources,
sinks, categories and greenhouse gases included (considering the completeness of the
inventory), GHG assertion time period.
For offset verifications: include the serial range (i.e. XXXX-XXXX-XXX-XXX-XXX-XXX to XXXX-
XXXX-XXX-XXX-XXX-XXX) if assigned (i.e. in the case of government verification a serial range
will be available, otherwise not applicable).
For Facilities: ensure all specified gases and source categories are evaluated. Include list of
negligible emission sources and justification for Emission Performance Credits (EPCs). Include
listing of end products.
RCE used the following scope to verify the GHG assertion to a reasonable level of assurance:
• The organization boundaries and the GHG project and its baseline scenario includes Orica
Canada Inc.’s Carseland Nitric Acid Plant; the GHG project involves the installation of a

Page 6 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
secondary abatement catalyst to destroy N2O emissions. The Baseline scenario is the un-
controlled release of N2O to the atmosphere.
• The physical infrastructure, activities, technologies and processes of the GHG project include
the installation of a secondary abatement catalyst directly below the ammonia oxidation
reactor. The activities include the destruction of N2O by the secondary abatement catalyst. The
technologies and processes include the installation of a continuous emissions monitoring
system that directly measures the amount of N2O produced from ammonia oxidation.
• The GHG sources, sinks and/or reservoirs include the Nitric Acid Plant (Burner Inlet to Stack)
• The types of GHGs include N2O
• The time periods include January 1, 2017 – December 31, 2017

2.3 Level of Assurance


The verification was conducted to a reasonable level of assurance.
Choose type of verification from the dropdown box above.
Provide explanation on level of assurance.
The memorandum with the subject “Reminder on Third Party Verification and Audits
Requirements” states that “For the purposes of greenhouse gas verification in Alberta, Alberta
Environment and Water requires Third Party Verifiers to assess greenhouse gas assertions
against facility and project information to determine completeness, correctness and accuracy of
the assertion within 5% materiality”. Therefore, RCE performed the verification to a reasonable
level of assurance.

2.4 Criteria
Outline the program criteria used and relevant supporting documentation (acts, regulations,
protocols, standards, guidance documents, project documentation etc).
• Carbon Competitiveness Incentive regulation (Alberta Regulation 255/2017)
• Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production (October 2009)
• Standard for Greenhouse Gas Emission Offset Project Developers Carbon Competitiveness
Incentive Regulation Version 1.0 December 2017
• Standard for Verification Carbon Competitiveness Incentive Regulation Version 1.0 December
2017
• ISO 14064‐3 Specification with guidance for the validation and verification of greenhouse gas
assertions
• Orica Carseland Works Nitric Acid Plant 1 Nitrous Oxide Abatement from Nitric Acid Production
Offset Project Plan
• 2017 Offset Project Report for Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric
Acid Production for 1 January 2017 to 31 December 2017
• Alberta Offset System Greenhouse Gas Assertion of Emission Reduction Credits

2.5 Materiality
Define the materiality of the verification.
A +/‐5 p ercen t m a teria lity th resh old

Page 7 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
3.0 Methodology
Statement that the verification is performed according to ISO 14064-3.
Summary of the assessments/tests/reviews/evaluations that were conducted during the
verification.
RCE performed the verification according to ISO 14064-3. The verification team used a
combination of substantive and control tests to determine whether the Project Developer’s
systems were functioning. See section 4.1 for a detailed explanation of tests.

3.1 Procedures
Description of how the verification was conducted including: description of the nature, scale and
complexity of the verification activity, confidence and completeness of the responsible party’s
GHG information and assertion, assessment of GHG information system and its controls,
assessment of GHG data and information, assessment of GHG information system and controls,
assessment against criteria, evaluation of the GHG assertion.
Describe steps of the verification including planning, assessment, site visit, off-site verification,
and report preparation.
Describe how the risk based approach was implemented in the sampling plan. Identify
categories of risk including inherent risk, and detection risk (organization and verifier). Include
the Verification Plan with the Sampling Plan in Appendix A. Paste the risk assessment table in
this section.
- Description of the nature, scale and complexity of the verification activity
The goal of the verification was to confirm that the Project Proponent had met the
requirements set forth by Alberta Environment and Parks. The audit included a kick-off
meeting, site visit to Orica’s Nitric Acid Plant 1, document and calculation review, issuance
of a list of findings, and an exit meeting. The technologies in place to generate emission
reductions are not complex; however, the calculations of baseline and project emissions are
somewhat complex. The confirmation that project CEMS equipment is functioning properly is
not complex.

- Confidence and completeness of the responsible party’s GHG information and


assertion
This was RCE’s first verification of the Project and the team is not familiar with Orica’s data
management system and calculations. However, the Project has been operating for almost
10 years and has successfully completed all previous verifications. RCE had medium
confidence in the responsible party’s GHG information and assertion.

- Assessment of GHG information system and its controls


The Project Proponent tracks all relevant data using internal CEMS metering that is
calibrated and checked for accuracy on a routine basis. Data is recorded every 10 seconds
and aggregated hourly to the distributed control system (DCS). A quality assurance plan is
in place to outline effective management strategy for the safe, reliable, and effective
operating of the CEMS. The GHG assertion spreadsheet also uses formulas to ensure that
Protocol calculations are followed and that any data that does not fall within the Protocol
stipulated parameters is excluded from the data set. RCE reviewed these controls and
confirmed that they were operating properly.
Page 8 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018

- Assessment of GHG data and information


RCE reviewed raw data from January through August and re-calculated emission reductions
using the Protocol equations. RCE confirmed that the Project Proponent excluded data when
the plant operated outside the historical allowable operating conditions. The Project
Proponent used the correct Protocol stipulated equations and emission factors to calculate
emission reductions.

- Assessment of GHG information system and controls


See ‘Assessment of GHG information system and its controls’.

- Assessment against criteria


RCE reviewed information provided by Orica. There were several items that RCE was unable
to confirm from Appendix A N2O Meter (CEMS) Code. However, RCE determined that these
items were low risk and that a qualified verification statement could be issued.

- Evaluation of the GHG assertion


RCE re-calculated emission reductions based on the data provided by Orica. There was a
non-material difference between RCE’s and the Orica’s final emission reduction number.

3.2 Team
List verification team members including peer reviewer(s).
Describe the qualifications and training of the team members and peer reviewer(s) including
dates of training and certifications.
For Offsets: fill in the sample Statement of Qualification provided and included in Appendix B.
For Facilities: include the Statement of Qualifications from the facility compliance form in
Appendix B.
For all members, see Appendix F.
Phillip Cunningham, Environmental Scientist and Lead Verifier
Michael Cote, President and Peer Reviewer
Nina Pinette, Environmental Scientist and Team Member
Zach Eyler, Vice President and Team Member
Ron Collings, Professional Engineer and Designated Signing Authority

3.3 Schedule
Provide a list or table of verification activities and dates. Indicate when the verification was
completed.
August 31, 2017: Signed verification service agreement
October 11, 2017: RCE’s Internal Auditor completed a Project Conflict of Interest (COI) form
to identify any potential conflict with the Project or Project developer. The COI assessment
revealed no conflicts of interest.

Page 9 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
October 13, 2017: RCE held a verification kick‐off meeting with the client via conference
call. During the kick‐off meeting RCE reviewed the verification objectives and process, the
verification schedule, and requested the verification background documents.
October 20, 2017: RCE developed a risk‐based desktop verification and sampling plan based
upon the strategic review and risk assessment. The verification and sampling plan revolved
around assessing the GHG management system in place, information control systems,
appropriate application of emissions factors, identifying project boundaries, and the cross
checking of GHG calculations and the QA/QC procedures used to assure data quality. The
verification plan and sampling plan were used throughout the verification and revised as
necessary based upon additional perceived risks. The verification and sampling plan was
sent to client prior to the site visit.
October 24, 2017: During the site visit RCE performed key personnel interviews, reviewed
Orica’s database management system, observed the on-site GHG management systems,
data gathering, monitoring, and handling practices and observed the equipment in place to
measure all relevant parameters.
October 20, 2017 – February 23, 2018: RCE performed a risk‐based desktop review of the
submitted verification documents. The desktop review included an assessment of the GHG
calculation methods and inputs, completeness of source documentation, evidence of
ownership, GHG management and monitoring systems, project qualification relative to start
date, evidence of the project activity following the project plan, and company record
retention practices.
February 5 - 23, 2018: RCE submitted summary of findings that included requests for
corrective actions, additional documentation and clarifications.
February 26, 2018: Orica addressed all times and RCE closed the summary of findings
February 26, 2018: RCE developed the Verification Report.
February 26, 2018: RCE’s independent peer reviewer conducted a review of the verification
sampling, verification report and statement.
March 2, 2018: RCE held an exit meeting with the client.

4.0 Results
Add introduction to results section here, if desired.
RCE conducted a risk-based analysis of the Project Proponent’s GHG assertion including a
strategic review of the Project data and evidence. Based upon the processes and procedures
and the evidence collected, RCE concludes that the Project Proponent’s emission reductions
resulting from the destruction of N2O during the reporting period January 1, 2017 through
December 31, 2017 can be considered:
• In conformance with ISO 14064‐3 Specification with guidance for the validation and
verification of greenhouse gas assertions,
• In conformance with the Quantification Protocol for Nitrous Oxide Abatement from Nitric
Acid Production (October 2009) with the following exceptions,
o RCE was unable to review information regarding the CEMS installation for the Nitric
Acid Plant 1 flow meter and N2O analyzer.
o RCE was unable to confirm that all requirements regarding equipment installation
and specification listed in Appendix A have been met by the Project Proponent.
o The Project Proponent is not recording stack pressure according to Table 2.4

Page 10 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
o The parameter AFRmax is not used to demonstrate permitted operating conditions
o The parameter AIFRmax is not used to demonstrate permitted operating conditions
• Without material discrepancy, and
• Verified to a reasonable level of assurance.

4.1 Assessment of Internal Data Management and Controls


Provide a summary the information system(s) and its controls for sources of potential errors.
Include information on the selection and management of data, process for collecting and
consolidating data, data accuracy systems, design and maintenance of the GHG system, the
systems and processes that support the GHG information system and results from previous
assessments if applicable.
The plant staff have operated a centralized automated data control system for stack emissions
since 2002 and are qualified and experienced. A PROCAL P-200 measures N2O concentration
directly from the stack. A Flowsic 107 is an ultrasonic flow monitor that measures gas velocities
and volumetric flows. Flow data and N2O concentration are recorded in 5-10 second intervals
and a distributed control system aggregates both measurements into hourly average values.
The Project Proponent applies missing data substitution using methods in the Alberta
Continuous Emissions Monitoring System (CEMS) Code 1998. Orica reviews data for any
anomalies to determine whether there are any sources for potential errors in the data set. The
data accuracy is tested each campaign by third parties carrying out relative accuracy test audits
(RATAs) on all relevant equipment. Orica also performs cylinder gas audits (CGAs) at the
beginning of each campaign to confirm that the N2O analyzer is reading correctly. The purpose
of the design and maintenance of the GHG system is to meet Protocol and Alberta CEMS code
requirements.

4.2 Assessment of GHG Data and Information


Provide a summary of the information found during the verification of the GHG data and a
summary of the GHG Assertion that was assessed.
For Facilities: Confirm that the quantification methodologies that were used in the compliance
report are the same as those reported in the BEIA.
For Offset Projects: Confirm that the quantification methodologies that were used by the project
proponent are the same as those described in the project plan. Indicate which quantification
methodologies were used by the project proponent.
RCE reviewed Orica’s GHG assertion including the data processes and procedures used to
calculate the Baseline and Project emission factors. Orica is claiming 285,748 GHG emission
reductions (tonnes CO2e) for the 2017 vintage year. Orica followed the same quantification
methodologies that are described in the project plan. RCE confirmed that Orica used the
quantification approaches listed in section 2.5.1 of the Protocol including the equations listed in
Table 2.4: Quantification Procedures with the following exceptions:
- Stack pressure is not being measured by the CEMS
- AFRmax (Maximum ammonia gas flow rate to the AOR) is not calculated. However,
ammonia gas flow rate to the AOR is measured.
- AIFRmax (Maximum ammonia to air ratio) is not calculated. However, the ammonia to air
ratio is measured.

Page 11 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
- Neither AFRmax or AIFRmax are being used to monitor and demonstrate permitted
operating conditions.
RCE is reasonably assured that these exceptions do not have a material impact on the GHG
assertion. RCE re-calculated emission reductions excluding data points above the AFRmax and
AIFRmax and determined that there is no difference in emission reductions.
RCE reviewed Orica’s GHG assertion and confirmed that the Project Proponent used the correct
emission factors and equations from the Protocol to calculate GHG emission reductions.

4.3 Assessment against Criteria


Provide a description of how eligibility criteria is met or not met.
For Offset Project: Complete Table 1 to indicate if the GHG Assertion conforms to the
Regulation and Standard for Greenhouse Gas Emission Offset Project Developers eligibility
criteria.
For Facilities: Delete Table 1 and Indicate if verification criteria are met or not met and explain.

Page 12 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
Table 1: Offset Criteria Assessment

Offset Eligibility Assessment


Criteria

Reduction or Orica Canada Inc.’s Carseland Works is located at Township


sequestration road 221 Carseland, Alberta T0J 0M0
occurs in Alberta

Result from actions The SGER requires facilities to reduce their emission intensity
not required by but exempts industrial process emissions. N2O emissions are
Law at the time the classified as industrial process emissions and there is currently
action is taken no reduction target set under the SGER.

Result from Actions The Project began in May 2008 when Orica installed a Heraeus
taken on or after secondary N2O abatement catalyst beneath the primary catalyst
January 1, 2002 in Nitric Acid Plant 1 to abate N2O.
and occur on or
after January 1,
2002

Reduction or The installation of the N2O abatement technology combined with


sequestrations is CEMS data clearly shows that N2O destruction is real and
real and demonstrable.
demonstrable

Quantifiable and After the N2O analyzer was installed, a Baseline sampling period
measureable was carried out to measure the average N2O emissions from
nitric acid production. During the reporting period, Orica used a
CEMS to measure the amount of N2O emissions. The data
clearly indicates that the abatement technology is destroying
N2O.

Verified by a third The Verification Team including the Designated Signing


party verifier that Authority have met the requirements of Part 1 for the Standard
meets the for Verification.
requirements in
Part 1 for the
Standard for
Verification.

Page 13 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018

4.4 Evaluation of the GHG Assertion


The verification assessment is that the GHG Assertion meets the requirements of the Carbon
Competitiveness Incentive Regulation
Provide an assessment of the evidence collected during the verification. Determine if the data
and information available support the GHG assertion. Provide a conclusion on whether the
assertion meets the materiality requirements and the level of assurance agreed to at the
beginning of the verification process.
RCE conducted a risk‐based analysis of the Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement
from Nitric Acid Production GHG assertion including a strategic review of the Project data and
supporting documentation. During the verification processes, RCE reviewed the evidence
collected and provided:
• Orica Carseland Works Nitric Acid Plant 1 Nitrous Oxide Abatement from Nitric Acid
Production Offset Project Plan (March 03, 2016)
• Offset Project Report Form Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric
Acid Production (January 15, 2018)
• Alberta Offset System Greenhouse Gas Assertion of Emission Reduction Credits
• The GHG assertion calculation spreadsheet and associated data
• All relevant RATAs and CGAs for the Baseline sampling period and Project reporting period
RCE concludes that the assertion meets the materiality requirements and level of assurance
agreed upon at the beginning of the verification process.

4.5 Summary of Findings


Provide a summary of material and immaterial discrepancies expressed in tonnes and as net
and absolute error in Table 2. Include whether the discrepancy was an understatement or an
overstatement.
Include a more detailed description and log of results in Appendix C the “Issues Log”. This log
will include both resolved and unresolved issues from the verification. Unresolved issues should
be brought forward to Table 2.

Page 14 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production – 9238-1983
March 2018
Table 2: Summary of Findings
Number the finding with the year and provide a unique # for each finding.
Note: A detailed description of all material and immaterial findings should be provided in Table 3 of Appendix C.
Provide only a summary statement (1-4 sentences) for each unresolved immaterial finding and each material finding (resolved or
unresolved). If the finding is a resolved material finding, then put the tonnes net and absolute in the summary description column
and indicate n/a in the net and absolute columns. Do not include the tonnes in the total error calculation.
Indicate the type of error (qualitative or quantitative).
Indicate the Source Category (for facilities) or the Source/Sink (for offsets).
Indicate if the finding is an understatement or overstatement.
Provide both net and absolute error in tonnes of CO2 eq and as a % of the assertion.
Provide the total net error and the total absolute error in tonnes of CO2 eq and as a % of the assertion.

Res Type Summary Description of Finding Understateme Tonnes CO2 Tonnes CO2
ult Source Category or Source/Sink nt/Overstate eq % net eq %
# ment absolute

N/A No material or immaterial errors. All


findings were additional documentation
requests or clarifications.

Total Error

Page 15 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
4.6 Opportunity for Improvement
Provide feedback on the data management system and controls, transparency, completeness of
the inventory, additions to the quantification methodology document or diagrams, etc. Include
positive considerations and observations also.
Identify strengths and weaknesses that may help to improve the report/s for the current
facility, sector, and compliance program. Identify ways in which the project/facility could be
more easily verified.
This is the final verification per the Project Report.

5.0 Closure
5.1 Verification Statement
Include the signed verification statement in Appendix D.
Instructions to insert a pdf: 1. Click Insert>Object 2. In the Object dialog box click Create from
File and then click Browse. 3. Find the pdf you want to insert then click Insert. 4.Click OK.
For Offset Projects: fill in the sample Verification Statement provided, sign, scan and paste.
For Facilities: paste a signed version of the Verification Statement from the facility compliance
form. Include the conclusion on the GHG assertion and any qualification or limitations and the
level of assurance.
Provide the verification conclusion in the drop down box below.
The verification conclusion is:
Qualified

5.2 Limitation of Liability


Include signed Conflict of Interest Checklist in Appendix E.
For Offset Projects: fill in the sample Conflict of Interest Checklist provided, sign, scan and
paste.
For Facilities: paste the signed Conflict of Interest Checklist from the facility compliance form.
Insert limitation of liability statement and include information in an Appendix F if applicable.
See Appendix E

5.3 Confirmations
Document information confirmed, including any discrepancies or inconsistencies, as per the
Confirmations section in the Standard for Greenhouse Gas Verification.
Confirmations are beyond the scope of a greenhouse gas verification but are activities AESRD
requires verifiers to perform during the verification. Confirmations determine whether the
information reported in the greenhouse gas assertion are accurate (e.g., responsible party,
address, dates, title, consistency across documents, etc.). AESRD requires the following
information to be confirmed:
- Consistency of offset project information across offset project documentation
Page 16 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
- Offset project location and any applicable approvals information
- Methodology documents or procedures manual exist
- Offset project contact, report dates, emission reduction numbers, etc. (part of one above)
- Completeness and accuracy of process and data flow diagrams
RCE has confirmed the above line items.

6.0 References
Author. Year. Title. (no hyperlinks)
N/A

Page 17 of 45
Appendix A: Final Verification Plan and Sampling Plan

Page 18 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
Information to be included in the Verification Plan and Sampling Plan:
Revisions to the sampling plan
Date originally sent to Facility/project
Level of assurance agreed with the facility/project developer
Verification scope
Verification criteria
Amount and type of evidence (qualitative and quantitative) necessary to achieve the agreed
level of assurance
Methodologies for determining representative samples
Sampling Plan and Procedures
Risk Assessment: Risks of potential errors, omissions or misrepresentations that are identified
throughout the verification process including:
- Details of site visit
-offset/facility boundaries
- Methodologies, emissions factors and conversions used
- Comparability with the approved baseline
- Conformance to the program criteria
- Integrity for the responsible party’s data management system and control (organization chart,
GHGH management plan, personnel/consultant training, protocols used, control system
documentation, software/program documentation/certifications)
- Greenhouse gas data and information, including the type of evidence collected, verification
testing and crosschecking, inventory of emission sources
- Discussion of data management, (measurement, fuel sampling, calibration, consistent use
of standard conditions, data storage, procedures to fill missing data; procedures to repair
inconsistent data, adjustment of variables and factors)
- Other relevant information
Revisions to the sampling plan
October 16, 2017 – Created
October 20, 2017 – Updated for site visit
October 16, 2017 – February 23, 2018 – Desktop sampling
Date originally sent to Facility/project
October 20, 2017
Level of assurance agreed with the facility/project developer
Reasonable Level of Assurance
Verification/audit scope
N2O destruction from a secondary abatement catalyst located at Orica’s Nitric Acid Plant 1
located near Carseland, AB
Verification/audit criteria
Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production (October 2009)

Page 19 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
Amount and type of evidence (qualitative and quantitative) necessary to achieve the
agreed level of assurance
RCE determined that the following qualitative and quantitative evidence was sufficient to
achieve the agreed level of assurance:
- The GHG assertion spreadsheet
- Eight months of raw data
- Total nitric acid production during the reporting period
- Total nitric acid production during the baseline sampling period
- All relative accuracy test audits and cylinder gas audits relevant to the reporting period
- All relative accuracy test audits and cylinder gas audits relevant to the baseline sampling
period
- Design specifications for monitoring and metering equipment
Methodologies for determining representative samples
RCE used statistical sampling because there is a large amount of data and controls to test. Data
includes:
- First eight months of raw data for the reporting period,
- the GHG assertion spreadsheet and
- all RATAs and CGAs for the Project reporting period and baseline sampling period.
Sampling Plan and Procedures
See appendix F
Risk Assessment: Risks of potential errors, omissions or misrepresentations that are
identified throughout the verification or audit process including:
- Details of site visit
Equipment installation including timing, physical location and CEMS requirements.
- offset/facility boundaries
Confirm only controlled SSRs are included in the Project.
- Methodologies, emissions factors and conversions used
Review and re-calculate baseline and project emission factors according to section 2.5 of the
Protocol and compare re-calculated emission reductions to the Responsible Party’s GHG
assertion.
- Comparability with the approved baseline
Review validated project plan.
- Conformance to the program criteria
Review RATAs and CGAs relevant to the reporting period and baseline.
- Integrity for the responsible party’s data management system and control
(organization chart, GHGH management plan, personnel/consultant training,
protocols used, control system documentation, software/program
documentation/certifications)
Review validated project plan, GHG project report and GHG assertion.
- Greenhouse gas data and information, including the type of evidence collected,
verification testing and crosschecking, inventory of emission sources

Page 20 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
Review and re-calculate baseline and project emission factors according to section 2.5 of the
Protocol and compare re-calculated emission reductions to the Responsible Party’s GHG
assertion.
- Discussion of data management, (measurement, fuel sampling, calibration,
consistent use of standard conditions, data storage, procedures to fill missing data;
procedures to repair inconsistent data, adjustment of variables and factors)
Review validated project plan, GHG project report and GHG assertion and any missing data
substitution applied to the Project reporting period or Baseline sampling period.
- Other relevant information
Included in the Verification Body’s working papers.

Page 21 of 45
Appendix B: Statement of Qualifications

Page 22 of 45
Sample Statement of Qualifications (SOQ)

Statement of Qualifications
Offset Report
Project Name Offset Project ID
Orica Nitric Acid Plant 1 – Nitrous
Oxide Abatement from nitric Acid
Production 9238-1983
Reporting Company Legal Name Report Type Reporting Period
Orica Canada Inc. Offset Report from 1 January 2017
31 December
to 2017
Signature of Third Party Verifier

I (Third Party Verifier), meet or exceed the qualifications of third


, Ronald Collings party
Third-party verifiers described in Section 29 of the Carbon Competitiveness Incentive Regulation.
Verifying Company Name
Ruby Canyon Engineering, Inc. Per:

Signature of Third Party Verifier Date


March 1, 2018

Training Received Under ISO 14064 Part 3


Ruby Canyon Engineering, Inc. is an accredited greenhouse gas validation and verification body under the American
National Standards Institute with accreditation ID# 0818 for ISO 14065.

First Name Last Name


Ronald Collings
Professional Designation E-mail Address Phone Number
Professional Engineer and Vice
President rcollings@rubycanyoneng.com 1-970-241-9298

Lead Verifier
Same as third party
☐ verifier??
First Name Last Name
Phillip Cunningham
Professional Designation E-mail Address Phone Number
Environmental Scientist pcunningham@rubycanyoneng.com 1-970-241-9298

Training Received Under ISO 14064 Part 3


Ruby Canyon Engineering, Inc. is an accredited greenhouse gas validation and verification body under the American
National Standards Institute with accreditation ID# 0818 for ISO 14065.

Peer Reviewer

Page 23 of 45
First Name Last Name
Michael Coté
E-mail Address Phone Number
mcote@rubycanyoneng.com 1-970-241-9298

Training Received Under ISO 14064 Part 3


Ruby Canyon Engineering, Inc. is an accredited greenhouse gas validation and verification body under the American
National Standards Institute with accreditation ID# 0818 for ISO 14065.

March 1, 2018

Director, Climate Change Secretariat


Alberta Environment and Sustainable Resource Development
12th Floor, Baker Centre
10025 – 106 Street
Edmonton, Alberta T5J 1G4

Designated Signing Authority: Ronald Collings P.E., Vice President and Senior
Engineer
Mr. Mr. Collings is a Registered Professional Engineer in Colorado, U.S.A., with specialized
knowledge in petroleum engineering and coal bed and coal mine methane recovery. Mr. Collings
has worked in various aspects of hydrocarbon exploration and production since 1976. He was a
Petroleum Engineer with Chevron Corporation for 18 years from 1981 to 1999, primarily in the
capacity of reservoir engineer, where he was responsible for oil and gas reservoir
characterization, modeling and simulation, improved oil recovery processes, reservoir
management, project economic risk assessment and petroleum reserves determination.

Since 1999, Mr. Collings has become a leading authority in coal mine methane resource and
reserves determination. His extensive background in the oil and gas and coal mining sectors
provides a unique understanding of how methane emissions can be economically reduced
through the appropriate implementation of technology in these two sectors. Mr. Collings is a
designated RCE lead verifier and has performed validations and verifications in the oil and gas,
transportation, power generation, and coal mine methane sectors. Mr. Collings received a
Bachelor of Science degree in Geology from the University of Utah in 1974 and a Master of
Science degree in Engineering from the University of Texas at Austin in 1982

Peer Reviewer: Michael Coté, President and Senior Environmental Engineer

Michael Coté is an experienced environmental engineer in the climate change industry with
skills in inventory analysis, baseline methodology development, project evaluation and
feasibility, emission reductions calculations, and validation/verification of greenhouse gas
(GHG) offset projects and corporate inventories. He has worked in various aspects of the
environmental and green energy industry for the past 23 years, from project identification,
feasibility and development, to verification and registration in various GHG programs. For the
past 10 years, Mr. Coté has specialized in voluntary and compliance carbon markets including

Page 24 of 45
the development and qualification of greenhouse gas (GHG) emission reduction projects and
corporate GHG inventories.

Beginning in 2005, Mr. Coté and partner Ronald Collings founded Ruby Canyon Engineering Inc.
(RCE), an organization dedicated to facilitating and qualifying GHG emission reduction projects
(primarily targeting methane-to-energy projects from vented and fugitive methane emission
sources) as well as providing corporate GHG inventory services. In addition, Mr. Coté led RCE’s
effort to receive its ANSI-accreditation as an ISO 14065 verification body in October 2009 and
has since managed RCE’s GHG validation and verification activities. Since receiving its
accreditation, RCE has completed over 200 GHG validation/verifications. Mr. Coté has authored
numerous GHG emissions baseline methodologies and project documents related to coal mine
methane projects that have been submitted to U.S. EPA, the United Nations Framework
Convention on Climate Change (UNFCCC), California Air Resources Board, Voluntary Carbon
Standard, and the American Carbon Registry. He earned his Bachelor of Science degree
(magma cum laude) in Environmental Science and Waste Management from Mesa State College
in 1997.

Lead Verifier: Phillip Cunningham, Environmental Scientist

Phillip Cunningham is an environmental scientist at Ruby Canyon Engineering. His involvement


at the company includes auditing a variety of carbon offset project types as well as greenhouse
gas (GHG) inventories under voluntary and mandatory reporting programs, assessing
spreadsheet functionality, and consulting. His recent activities include assisting with the
development of the U.S. EPA GHG national inventory for underground and surface coal mine
methane and abandoned mine methane emissions, evaluating the carbon neutrality of refuse
derived-waste-to-energy projects and consulting for a large fertilizer company.

He is an approved Lead Verifier for Landfill, Livestock, Ozone Depleting Substances, Coal Mine
Methane and Nitric Acid Production project protocols under the Climate Action Reserve; an Air
Resources Board (ARB) accredited Lead Verifier for Livestock, Ozone Depleting Substances and
Coal Mine Methane project verifications; has worked as Lead Verifier under The Climate
Registry verifying greenhouse gas emission inventories for local governments, universities, a
transportation company and a variety of other industrial sectors; and a Lead Verifier for carbon
offset projects and emissions inventories under the British Columbia offset regulation and
British Columbia Reporting Regulation.

Phillip Cunningham graduated from Colorado Mesa University with a B.S. in Environmental
Science & Technology in 2011. Prior to joining Ruby Canyon, Phillip worked for the Colorado
Department of Agriculture at the Palisade Insectary and as a research assistant for the City of
Grand Junction.

Team Member: Nina Pinette, Environmental Scientist

Nina Pinette is an environmental scientist at Ruby Canyon Engineering applying her experience
in technical research, data collection and analysis, and report writing to qualifying greenhouse
gas emission (GHG) reduction projects. Her recent activities at Ruby Canyon include work on
various carbon offset projects under both voluntary and compliance standards. Nina has
knowledge of GHG emissions regulations in the United States and Canada including the U.S.
EPA’s Mandatory GHG Reporting Rule, British Columbia’s Emission Offset Regulation, British
Columbia’s Greenhouse Gas Industrial Reporting and Control Act (GGIRCA) including the
Greenhouse Gas Emission Reporting Regulation and Greenhouse Gas Emission Control
Regulation, and California’s AB 32. She has contributed to EPA white papers on coal mine
methane and the EPA active coal mine methane and EPA abandoned coal mine methane
inventories and has coauthored Project Descriptions for coal mine methane offset projects for
the Voluntary Carbon Standard.
Page 25 of 45
Nina is a team member for RCE’s GHG validation and verification work in U.S. and Canadian
carbon markets. She is an accredited Lead Verifier for the California Air Resources Board (ARB)
for GHG Emissions Data Reports and Offset Project Data Reports under title 17 of the California
Code of Regulations. She is an ARB-accredited Lead Verifier and Project Specialist for livestock,
ozone depleting substances, and mine methane capture project verifications; a Lead Verifier for
Nitric Acid Production, Ozone Depleting Substances, Coal Mine Methane, Livestock, and Landfill
project protocols under the Climate Action Reserve (CAR); a lead verifier for projects under the
British Columbia offsets program; and a lead verifier for project verifications under the Verified
Carbon Standard (VCS). She is also a Lead Verifier for entity verifications for the British
Columbia Reporting Regulation, The Climate Registry, and the Massachusetts GHG Emissions
Reporting Program which include assessing GHG emissions from a variety of sources: industrial
processes, mining operations, landfills, electricity generation, and the transportation sector.
Nina is also an accredited verifier for the Airport Carbon Accreditation (ACA) program.

Nina received her B.S. in environmental science with a second major in political science from
Muhlenberg College in Allentown, Pennsylvania in 2009. Her studies included travel to
Bangladesh to study climate change and sustainable development and to Kenya to study
community conservation initiatives.

Team Member: Zach Eyler, Vice President


Zach serves as a Vice President for Ruby Canyon, utilizing his broad experience with
greenhouse gas (GHG) programs and renewable energy to assist on a variety of work including
GHG verifications, technical research and other client projects. In addition, he assists the
company in understanding GHG regulations and policies across North America and
internationally, using this knowledge to analyze potential new areas of growth. Specifically,
Zach is helping lead Ruby Canyon’s expansion into California’s AB 32 cap-and-trade program,
as well as new programs in Canada and Latin America. Zach also serves as Ruby Canyon’s
representative on a variety of GHG registry stakeholder groups that assist in the development
of high level protocol and verification standards for new GHG programs. Zach has completed a
wide range of verification work for projects across registries (ARB, PCT, CAR, TCR, ACR, VCS)
including coal mine methane, landfills, livestock, oil/gas, fuel switching, ODS, nitric acid
production, and GHG entity inventories. Zach is currently an accredited Lead Verifier for the
CAR, PCT and ACR programs. Zach is also an ARB accredited Lead Verifier and Project Specialist
for livestock, mine methane and ODS projects.
Prior to joining Ruby Canyon, Zach worked at Element Markets for four years where he
managed over 15 carbon offset projects, as well as conducting all GHG policy and regulatory
analysis to support the company’s trading activities and client relationships in the U.S. and
Canada. He also served as a company representative on carbon offset working groups including
the Coalition for Emission Reduction Policy (CERP) and the Canadian Industry Provincial Offsets
Group (IPOG).
He earned a Bachelor’s degree in Environmental Technology from NC State University in 2005
and a Master’s of Environmental Management from Duke University’s Nicholas School of the
Environment in 2008.
Summary
As the Designated Signing Authority and a Professional Engineer registered in the State of
Colorado, U.S.A., I, Ronald Collings meet or exceed the required qualifications described in
Section 18 of the Specified Gas Emitters Regulation, including the training requirements under
ISO 14064.
The information contained within this document and this statement of qualifications, is
complete and correctly represents the qualifications of Ruby Canyon Engineering Inc and the
members of the Verification Team described herein. Dated on this fourth day of December
2017.
Page 26 of 45
Ronald C. Collings, PE
Ruby Canyon Engineering, Inc.
743 Horizon Ct. Suite 385
Grand Junction, Colorado 81506
rcollings@rubycanyoneng.com

Page 27 of 45
Appendix C: Findings and Issues

Page 28 of 45
Table 3: Detailed Findings and Issues Log
Number the issue with the year and provide a unique # for the issue. If the issue resolved during the verification, indicate that in
the resolution column. If the issue is not resolved during the verification, or if the issue was material (whether resolved or not)
record it as a finding in Table 2 and provide a cross reference to the finding # in the resolution column.
Describe the issues investigated. State the verification criteria that are not met. Provide a description of how it is not met and
provide the evidence. Indicate the Source Category (for facilities) or the Source/Sink (for offsets).
Indicate if the finding is an understatement or overstatement.
Summarize information between verifier and client.
Provide a conclusion including % discrepancy, if applicable.
Item Description of the Issues Summary of information Resolution Conclusion
(YR- Investigated During the exchanged between verifier and (including %
##) Verification client discrepancy if
applicable)

YR-
##

18- Provide some form of evidence 3.1.1 - Meters are more than 1/2 Resolved N/A
01 showing that the location of the stack diameter from the exhaust
sampling site for flow and N2O point.
concentration meets the CEMS
3.1.2 - The Procal is an infrared
Code Alberta 1998 Section 3.1.1
beam across the stack.
to 3.1.3. Reference: Continuous
Emission Monitoring System 3.1.3 - Same flow meters that are
(CEMS) Code 1998. SSR B1/P1; used for measuring NOx. Cyclonic
qualitative. flow checked during manual
sampling.

18- Please provide the design See product documentation sent via Resolved N/A
02 specifications for the flow email
monitor/flow meter as well as the
product conformity certificate.
Reference: Continuous Emission
Monitoring System (CEMS) Code
1998 - Table 5 Flow Monitor
Design specifications. SSR
B1/P1; qualitative.

Page 29 of 45
18- Please provide the last RATAs of Documents were provided. Resolved N/A
03 2016 (the previous reporting
period). Reference: Continuous
Emission Monitoring System
(CEMS) Code 1998. SSR B1/P1;
qualitative.

See product documentation sent via Resolved N/A


Please provide evidence that the
18- email
temperature sensors meet the
04-
design specifications from Alberta
Continuous Emission Monitoring
System (CEMS) Code Table 6.
Temperature sensor design
specifications. Reference:
Continuous Emission Monitoring
System (CEMS) Code 1998 -
Table 6 Temperature Sensor
Design specifications. SSR
B1/P1; qualitative.

Please provide evidence that the Third party confirms this during
Resolved N/A
18- data acquisition system meets RATA testing.
05 the design specifications from the
Alberta Continuous Emission
Monitoring System (CEMS) Code
section 2.5 Specifications for the
Data Acquisition System.
Reference: Continuous Emission
Monitoring System (CEMS) Code
1998 - Section 2.5 Specifications
for the Data Acquisition System.
SSR B1/P1; qualitative.

18- Please provide evidence that the


06 N2O meter is automatically Resolved N/A
zeroed and span checked daily.
Reference: Offset Project Plan

Page 30 of 45
Section 7.4.3 Metering
Maintenance and Calibration.
SSR B1/P1; qualitative.

About the Relative Accuracy Test


18- Audit (RATA) Results, please No, oxides of nitrogen refer to NO Resolved N/A
07 clarify if "Oxides of Nitrogen" and NO2.
include nitrous oxide. Reference:
Relative Accuracy Test Audit and
Source Emission Survey - May
09, 2017 - pdf pg. 8. SSR B1/P1;
qualitative.

Please clarify why the


temperature, velocity and total
Resolved N/A
effluent flow rate wet values list
18- In the 1998 CEMS code Bias is only
Bias as "Not Applicable" in the
08 required to be calculated on the
RATA report. Reference: Relative
pollutant and/or diluent gas
Accuracy Test Audit and Source
analyzer.
Emission Survey - May 09, 2017
- pdf pg. 13. SSR B1/P1;
qualitative.

Appendix B: Stack Velocity Test


Results list velocity values tested
for stratification. Please clarify The conclusion of the study was that
Resolved N/A
18- what the conclusion of the study there was no stratification. The
09 was. The Alberta Continuous determination for stratification is a
Emission Monitoring System minimum of 9 points taken and if
(CEMS) Code section 3.2 there is a 10% difference from the
Representativeness states that average at any of the points then
"the sampling plane across the there is stratification. The greatest
stack or duct is considered difference seen at NAP1 was 3.04%
stratified if any of the calculated and NAP2 was 3.17%, thus no
values are greater than +/- stratification. This is confirmed by
10%". There are values in the

Page 31 of 45
data that are more than 10% the annual NOx RATA's which also
different from the average value. check for stratification
Reference: Offset Project Plan
Appendix B. SSR B1/P1;
qualitative.

The Offset Project Plan Appendix


D list Gauze runs 53, 54, 55, 56
18- and 57 as the Baseline Historical
10 Summary. However, the file Run 53 to 59 are used to
Resolved N/A
'NAP1 - 5 Year History, baseline demonstrate normal running as
and project Run 1 &2 &2 & collected in the Historical Data
YR2010 & YR2011 & YR2012 Sheet. Project report updated.
Revision 38.xlsx' on the 'Rollup'
tab included Gauze Run 58 and
59 in the 'Normal Values'
calculation. Please clarify if the
Project Plan is correct.
Reference: Offset Project Plan
Appendix D; NAP1 - 5 Year
History, baseline and project Run
1 & 2 & 3 & YR2010 & YR2011 &
YR2012 Revision 38.xlsx. SSR
B1/P1; qualitative.

Please clarify how the upper and


lower confidence limits for
18- normal operating parameters
Data gaps associated with gauze
were calculated. On the 'Calc UCL Resolved N/A
11 changes or downtime.
LCL' tab, the historical data
appears to have gaps and days
are missing from the data set.
For example, the 2007 fourth
quarter day for October,
November and December appear
to be missing one day each.
Reference: NAP1 - 5 Year
History, baseline and project Run
1 & 2 & 3 & YR2010 & YR2011 &

Page 32 of 45
YR2012 Revision 38.xlsx. SSR
B1/P1; qualitative.

Please clarify which documents in


the Drobox folders relate to the
18- initial installation and testing for Documents relating to installation Resolved N/A
12 the CEMS flow meter and N2O and testing were unavailable to
analyzer. Reference: Nitrous review; a qualified verification
Oxide Abatement from Nitric Acid statement will be issued.
Production Protocol Appendix A
N2O Meter (CEMS) Code. SSR
B1/P1; qualitative.

The Offset Project Plan Section


7.3 Quantification Plan states
Stack pressure is not a measured Resolved N/A
that in Step 1, the monitored
18- parameter. A constant pressure is
data includes stack pressure.
13 assumed in the calculations as per
However, in the chart that
Table 2.4 of the protocol. The
references monitored data that is
same pressure is used for baseline
stored in the historian, there is
and reporting periods. Since this
no indication that stack pressure
will be based on atmospheric
is included. Please clarify if stack
condition, it will average out over
pressure is recorded. If stack
time. Project Report updated.
pressure is not recorded, please
justify why it is not recorded.
Reference: Offset Project Plan
Section 7.3 Quantification Plan.
SSR B1/P1; qualitative.

Regarding the file 'NAP1 -N2O


abatement, baseline and project Resolved N/A
Orica did not use flowrates for
run 1 & 2 & 3 & YR2010 to
ammonia or air to establish
18- YR2017 Revision 38.xlsx' on the
allowable operating conditions due
14 'Baseline' tab; Column G (Data
to the large variation of the flow
Check 1 = OK) checks
rates and the risk of rejecting good
temperature and pressure for
operating data. Project Report
normal ranges but not ammonia
flow or air flow. Table 2.4 in the

Page 33 of 45
Protocol lists AFRmax (Maximum updated. A qualification will be
ammonia gas flow rate to AOR) added to the verification statement.
and AIFRmax (Maximum
ammonia to air ratio) as
parameters to demonstrate
permitted operating conditions.
Please clarify why Orica did not
include these as a check on
allowable operating conditions.
Reference: Nitrous Oxide
Abatement from Nitric Acid
Production Protocol Table 2.4.
SSR B1/P1; qualitative.

Regarding the file 'NAP1 -N2O


abatement, baseline and project
Resolved N/A
run 1 & 2 & 3 & YR2010 to
As noted in the text 'verified by acid
18- YR2017 Revision 38.xlsx' on the
production'. If there is missing
15 'Baseline' tab; cell G8. The note
data, but there is acid production,
states "Calculation changes to
Orica safely assumes the plant was
Reflect hours >0 on NH3 flow to
running.
reactor. Assume all missing data
the plant was running. Verified
by Acid production. Note: If
plant shutdown, minimum of 6
hours is needed to restart". Why
does Orica assume that the plant
is running if there is missing
data? Reference: Nitrous Oxide
Abatement from Nitric Acid
Production Protocol Table 2.4.
SSR B1/P1; qualitative.

Please clarify why missing data


substitution was not used for N2O Resolved N/A
Specific to your example, during the
18- and flow data in the baseline. timeframe mentioned the plant was
16 Example is October 3rd, 2007 not running (Gauze temperature

Page 34 of 45
starting at 9:00 a.m. for multiple 200 and lower). In general, the use
hours. Reference: Nitrous Oxide of the backfill procedure is a
Abatement from Nitric Acid judgement call by the personnel
Production Protocol Appendix A managing the project at the time.
N2O Meter (CEMS) Code 2.4.4 It is not mandatory to backfill
Backfilling and Substitution for missing data and the site has
Missing Data. SSR B1/P1; historically been hesitant to backfill
qualitative. data, especially if it is only a small
percentage of the entire data set.

The Offset Project Plan under the


section 'Metering Maintenance
18- and Calibration' states that 'A Resolved N/A
Gauze runs are typically at least 8
17 Cylinder Gas Audit (CGA) using
months in length. Run #15 would
N2O will be conducted at the
have it's CGA and RATA in 2018.
start of each campaign run'.
There is no specification as to when
According to the Offset Project
in the gauze run the CGA and RATA
Report under the section 'Plant
needs to be completed if it is done it
Operations', there is three gauze
that time frame.
changes. There are CGAs in
February and August. Was there
a CGA for the Primary Gauze Run
#15? Also, for Gauze Run #14,
the gauze was changed at end of
April. Why did the CGA not take
place until August? Reference:
Offset Project Plan for Orica Nitric
Acid Plant 1 - Nitrous Oxide
Abatement from Nitric Acid
Production. SSR B1/P1;
qualitative.

Page 35 of 45
Appendix D: Statement of Verification

Page 36 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018

Statement of Verification
Associated SGER Submission
Offset Project Protocol Project ID #

Quantification Protocol for Nitrous


Oxide Abatement from Nitric Acid
Orica Nitric Acid Plant 1 – Nitrous Oxide Production, October 2009, Version
Abatement from nitric Acid Production 1 (Protocol) 9238-1983

Serial Report
Project Developer Range Start Period

1 January
2017 – 31
December
Orica Canada Inc. N/A 2017

Serial
Range End

N/A

Statement of Verification

GHG Assertion

Value Units

Total Baseline tonnes


402,745
Emissions) CO2eq

Total Project tonnes


116,997
Emissions ) CO2eq

tonnes
Other ) N/A
CO2eq

Net Reductions) 285,748 Tonnes CO2e

Page 37 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018

Statement of N/A
Assertion

Responsibilities of Project Developer and Third Party Verifier

Orica Canada Inc. was responsible for aggregating project documentation and calculating net
reductions. Ruby Canyon Engineering, Inc. was responsible for expressing an opinion on the
assertion being presented fairly and free of material errors.

Conclusion

(statement should be sufficiently detailed and refer to the correctness of the GHG assertion)
RCE concludes that the GHG assertion in the Alberta Offset System Greenhouse Gas Assertion of
Emission Reduction Credits is materially correct and is a fair representation of the Project
activities resulting from the reduction of N2O emissions.
The reporting period covers January 1, 2017 through December 1, 2017.
The Project can be considered in conformance with:
• Carbon Competitiveness Incentive regulation (Alberta Regulation 255/2017)
• Quantification Protocol for Nitrous Oxide Abatement from Nitric Acid Production (October
2009) with the following exceptions:
- Stack pressure is not being measured by the CEMS
- AFRmax (Maximum ammonia gas flow rate to the AOR) is not calculated. However, ammonia
gas flow rate to the AOR is measured.
- AIFRmax (Maximum ammonia to air ratio) is not calculated. However, the ammonia to air
ratio is measured.
- Neither AFRmax or AIFRmax are being used to monitor and demonstrate permitted operating
conditions.
• Standard for Greenhouse Gas Emission Offset Project Developers Carbon Competitiveness
Incentive Regulation Version 1.0 December 2017
• Standard for Verification Carbon Competitiveness Incentive Regulation Version 1.0 December
2017
• ISO 14064‐3 Specification with guidance for the validation and verification of greenhouse gas
assertions
RCE is reasonably assured that these exceptions do not have a material impact on the GHG
assertion.
RCE concludes to a reasonable level of assurance that the GHG assertion is without material
discrepancy or material changes in how the project was carried out compared to the offset
project plan.

Signature of Third Part Verifier

Page 38 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
Verifying Company
Name

Ruby Canyon Engineering, Inc. Per:

Signature of Third
Party Verifier Date:

March 1,
2018

Last
First Name Name

Ronald Collings

Professional Phone
Designation E-mail Address Number

Professional Engineer and Vice rcollings@rubycanyoneng.c 970-241-


President om 9298

Page 39 of 45
Appendix E: Conflict of Interest Checklist

Page 40 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018

Conflict of Interest Checklist


Associated SGER
Submission
Offset Project Protocol
Orica Nitric Acid Plant 1 – Quantification Protocol for Nitrous Oxide
Nitrous Oxide Abatement from Abatement from Nitric Acid Production, October
nitric Acid Production 2009, Version 1 (Protocol)
Report
Project Developer Report Type Period
1 January
2017 – 31
December
Orica Canada Inc. Offset Project Report 2017

Checklist
Respond either "True" or "False" to each of the following statements:

The relationship between my firm and this reporting company poses unacceptable threat
1.
to or compromises the impartiality of my firm. False

2. The finances and sources of income of my firm compromise the impartiality of my firm.
False

The personnel my firm has scheduled to participate in the verification may have an
3.
actual or potential conflict of interest. False

My firm participated in some manner in the development or completion of the associated


4.
offset submission for this reporting company. False

5. My firm provided greenhouse gas consultancy services to this reporting company.


False

My firm will use personnel that have, are, or will be engaged or previously employed by
6.
the reporting company. False

7. My firm will outsource the Statement of Verification for the associated offset submission.
False

8. My firm offers products or services that pose an unacceptable risk to impartiality.


False

Important: If you have checked "True" to any of the above, you may not fulfill the "independence" requirement for
third party verifiers. Please contact Alberta Environment and Parks for further instruction. If the potential conflict of
interest is a sufficient threat to impartiality (perceived or actual), or cannot be effectively managed, you Third Party
Verification Report will not be acceptable to Alberta Environment and Parks.

Signature of Third
Party Verifier

Page 41 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
I, Ronald Collings (Third Party Verifier), have personally examined and am familiar
with the information contained in this Conflict-of Interest Checklist, and can demonstrate freedom from any conflict of
interest related to the reporting company for which the verification was performed. I hereby warrant that the
information submitted in this Conflict-of Interest Checklist is true, accurate and complete to the best of my knowledge,
and that all matters affecting the validity of this Conflict-of-Interest Checklist have been fully disclosed. Impartiality
shall be monitored over the duration of the verification and any identified actual or potential conflict-of-interest
situations will be communicated to AEP directly.

Verifying Company Name


Ruby Canyon Engineering Per:
Signature of Third Party
Verifier Date
March
1, 2018

First Name Last Name


Ronald Collings
Phone
Professional Designation E-mail Address Number
Professional Engineer and 1-970-
Vice President rcollings@rubycanyoneng.com 241-9298

Page 42 of 45
Appendix F: Supplemental Diagrams/Tables/Figures

Page 43 of 45
The table below lists the sampling of project data and documents:

Activity Data / Inventory Detection Description of Sampling Methodology and Justification Sample
Component Risk Verification Size
Design Procedure

Relative Accuracy Test Reviewed All records; there are only two to three All
Audits (RATAs) documentation RATAs per reporting period. records
and confirm
Lower
equipment was
recording data
accurately

Cylinder Gas Audits Reviewed All records; there are only two to three All
(CGAs) documentation CGAs per reporting period. records
and confirm
Lower
equipment was
recording data
accurately

Daily Calibrations Reviewed RCE used statistical sampling because 3 months


calibrations for there is a large amount of data and
Higher
N2O and flow controls to test.
meter

Emission Reduction Review all A review of all equations is necessary to All


Calculation equations used generate a positive verification opinion; equations
Lower to calculate this is partially due to the nature of the
emission calculations.
reductions

Raw Data Use raw data RCE used statistical sampling because 8 months
as an input for there is a large amount of data and
Medium emission controls to test.
reduction
calculations.

Page 44 of 45
Page 45 of 45

You might also like