Professional Documents
Culture Documents
PRJ 176 8533
PRJ 176 8533
9238-1983
March 2018
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.
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Item Description
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Enter offset project owner.
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calculations are correct, and that
equipment used to measure nitrous oxide
(N2O) is functioning properly and recording
data accurately.
Item Description
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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
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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
2.4 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
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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.
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.
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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
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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.
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- 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.
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Table 1: Offset Criteria Assessment
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
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.
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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
Total Error
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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
5.3 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
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- 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
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Appendix A: Final Verification Plan and Sampling Plan
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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)
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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
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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.
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Appendix B: Statement of Qualifications
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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
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
Peer Reviewer
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First Name Last Name
Michael Coté
E-mail Address Phone Number
mcote@rubycanyoneng.com 1-970-241-9298
March 1, 2018
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
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
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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.
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.
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.
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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.
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Appendix C: Findings and Issues
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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.
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.
Page 30 of 45
Section 7.4.3 Metering
Maintenance and Calibration.
SSR B1/P1; qualitative.
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.
Page 32 of 45
YR2012 Revision 38.xlsx. SSR
B1/P1; qualitative.
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.
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.
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 #
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
tonnes
Other ) N/A
CO2eq
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
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.
Page 38 of 45
Orica Nitric Acid Plant 1 – Nitrous Oxide Abatement from Nitric Acid Production –
9238-1983
March 2018
Verifying Company
Name
Signature of Third
Party Verifier Date:
March 1,
2018
Last
First Name Name
Ronald Collings
Professional Phone
Designation E-mail Address Number
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
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 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
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.
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
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
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