CO2 Capture from Prentiss2 for EOR, Project ID: 3482-7976 · CO2 Capture from Prentiss2 for EOR,...

CO2 Capture from Prentiss2 for EOR, Project ID: 3482-7976

April 2020

Version 3.0 Offset Verification Report Form

Verification Report for:


Proponent:

AlphaBow Energy Ltd.

Prepared by:

Amberg Environmental and Regulatory Consultants

Prepared for:


Version:

Final

Date:

April 2, 2020


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Table of Contents

1.0 Summary – Offset Project ...................................................................................... 3 2.0 Introduction ......................................................................................................... 5

2.1 Objective ............................................................................................................. 5 2.2 Scope .................................................................................................................. 5 2.3 Level of Assurance ................................................................................................ 5 2.4 Criteria ................................................................................................................ 5 2.5 Materiality ............................................................................................................ 5

3.0 Methodology ......................................................................................................... 5 3.1 Procedures ........................................................................................................... 6 3.2 Team ................................................................................................................... 8 3.3 Schedule .............................................................................................................. 9

4.0 Results ................................................................................................................ 9 4.1 Assessment of Internal Data Management and Controls ............................................. 9 4.2 Assessment of GHG Data and Information ................................................................ 9 4.3 Assessment against Criteria .................................................................................. 10 4.4 Evaluation of the GHG Assertion ............................................................................ 12 4.5 Summary of Findings ........................................................................................... 12 4.6 Opportunity for Improvement ............................................................................... 14

5.0 Closure .............................................................................................................. 14 5.1 Verification Statement ......................................................................................... 14 5.2 Limitation of Liability ........................................................................................... 14 5.3 Confirmations ..................................................................................................... 14

6.0 References ......................................................................................................... 14 Appendix A: Final Verification Plan and Sampling Plan ............................................................ 15 Appendix B: Statement of Qualifications................................................................................ 22 Appendix C: Findings and Issues .......................................................................................... 25 Appendix D: Statement of Verification .................................................................................. 29 Appendix E: Conflict of Interest Checklist .............................................................................. 32 Appendix F: Supplemental Diagrams/Tables/Figures ............................................................... 35

List of Tables

Table 1: Offset Criteria Assessment ...................................................................................... 10 Table 2: Summary of Findings ............................................................................................. 13 Table 3: Detailed Findings and Issues Log ............................................................................. 26


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1.0 Summary of Offset Project

Item Description

Project Title CO2 Capture from Prentiss2 for EOR

Project Description

The Project is an enhanced oil recovery

(EOR) operation that processes previously

vented industrial process CO2 from the

neighbouring MEGLobal ethylene glycol

plant for injection into oil wells.

Project Location

The CO2 Capture Site is located North East

of Red Deer, Alberta:

52.382969, -113.5986407

5-30-39-25 W4

The injection wells are located in the

Chigwell/Viking Field at 16-32-043-26 W4

and the Nelson Field at 08-24-042-26 W4.

Project Start Date January 1, 2006

Offset Start Date January 1, 2006

Offset Crediting Period January 1, 2006 to December 31, 2018

Offset Reporting Period January 1, 2017 to December 31, 2018

GHG Assertion (Actual Emission

Reductions/Sequestration Achieved)

2017: 12,642 tonnes

2018: 5,569 tonnes

Total: 18,211 tonnes

Government Approved Quantification

Protocol

Quantification Protocol for Enhanced Oil

Recovery, version 1, October 2007

Ownership AlphaBow Energy Ltd.

Project Activity

This activity meets the eligibility criteria

listed in the Quantification Protocol for

Enhanced Oil Recovery as described in

Section 2 of the Offset Project Plan.

Project Contact


Jay Kleinsasser, P.Eng.

1700, 222 – 3rd Ave SW

Calgary, AB T2P 0B4

(587) 393-6668

[email protected]

Verifier Klym Bolechowsky, P.Eng.

mailto:[email protected]


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ClearSky Engineering Inc.

1-221 Drake Landing Lane

Okotoks, AB T1S 2M4

(403) 982-5596

[email protected]

Verification Team Members

Lead Verifier: Klym Bolechowsky, P.Eng.

Completed CSA ISO 14064-3 training: July

29 - 31, 2013 - Certificate #0000432380

Peer Reviewer: Ashley Mathews, EIT

Completed ISO 14064-3 training: Feb. 7-8,

2017- Certificate #50064648-50067754

Designated Signing Authority Klym Bolechowsky, P.Eng.

Verification Strategy

The verification strategy is a mixed

approach of predominantly substantive

procedures and some controls reliance.

Verification Conclusion The verification conclusion is: Positive



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2.0 Introduction

Amberg Environmental and Regulatory Consultants (Amberg) was engaged by AlphaBow Energy

Ltd. (AlphaBow) to verify 2017 to 2018 vintage year offset credits generated by the CO2 Capture

from Prentiss2 for EOR Offset Project located North East of Red Deer, Alberta. The offset project

was verified at a reasonable level assurance against the flagged Quantification Protocol for

Enhanced Oil Recovery, version 1, October 2007, the Offset Project Plan and the program

requirements of the Alberta Emission Offset System. This is the first third-party verification

completed for this project by the verifier. Klym Bolechowsky of ClearSky Engineering Inc. was

subcontracted by Amberg in the role of Lead Verifier.

The baseline condition is dynamic based on the volume of CO2 injected annually which would

have been vented in absence of the project.

2.1 Objective

The objective of this verification is to develop a conclusion at a reasonable level of assurance as

to whether the greenhouse gas emission reduction assertion is free from material

misstatement, and is presented fairly in accordance with the Technology Innovation and

Emissions Reduction (TIER) Regulation and the Alberta Emission Offset System.

2.2 Scope

The scope of the verification is the GHG Emission Reduction Assertion presented in the Offset

Project Report dated February 24, 2020 for the period January 1, 2017 to December 31, 2018.

The geographical scope is the CO2 Capture Site and associated well injection sites all located in

Alberta. The Offset Project Plan dated Feb. 24, 2020 for the period up to Dec. 31, 2018 is also

included in the scope of the verification.

2.3 Level of Assurance

The verification was conducted to a reasonable level of assurance. The verification was planned

and executed accordingly.

2.4 Criteria

Technology Innovation and Emissions Reduction (TIER) Regulation, Alberta Regulation

133/2019

Standard for Verification, Version 4.0, November 2019

Standard for Greenhouse Gas Emission Offset Project Developers, Version 3.0,

November 2019

Quantification Protocol for Enhanced Oil Recovery, Version 1, October 2007

Carbon Offset Emission Factors Handbook, Version 1.0, March 2015

2.5 Materiality

The materiality threshold is 5% of emission offsets generated as the project generates less than

500,000 tonnes of emissions offset credits.

3.0 Methodology

This verification was carried out in accordance with the following standards:

ISO 14064 Part 3 – Greenhouse Gases: Specification with guidance for the validation

and verification of greenhouse gas assertions


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ISO 14064 Part 2 – Greenhouse Gases: Specification with guidance at the project level

for quantification, monitoring and reporting of greenhouse gas emission reductions or

removal enhancements. Six principles:

1. Relevance: include all relevant GHG sources & sinks

2. Completeness: include all relevant emissions and removals

3. Consistency: enable meaningful comparisons in GHG related information

4. Accuracy: reduce bias and uncertainties as far as is practical

5. Transparency: disclose sufficient and appropriate GHG related information to

allow users to make decisions with reasonable confidence

6. Conservativeness: use conservative assumptions, values, and procedures to

ensure GHG emission reductions are not over estimated

3.1 Procedures

The first task completed was a conflict check which is documented in the Conflict of Interest

Checklist included in Appendix E of this report. A date for the site visit was established and the

following information was requested from AlphaBow:

Main Documents:

2017-2018 offset quantification files

Offset Project Report - “OPR CO2 Capture from Prentiss 2 for EOR 2017-2018 (Final

ver.7) (dated Feb 24, 2020)”

Offset Project Plan - “OPP V3 CO2 Capture from Prentiss 2 for EOR (Final ver.6) (dated

Feb 24, 2020)”.

Supporting Documents:

daily gas injection volumes

fuel consumption reports

gas analysis reports

electricity bills

Review on-site: calibration records for project meters

A risk assessment was completed:


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Risk Assessment

Line Item Attributes Inherent Risk Control Risk Detection Risk

Design

Verification Procedure

GHG Assertion

Level

Completeness Low – mature

project with

multiple

verification and a

reverification audit

from AEP

Medium – new staff

responsible for

offset quantification

Medium Conduct a site tour to view all

project sources/sinks

Accuracy

Baseline –

B3b Venting at

Capture Site

Occurrence Medium – major

contributor to

baseline emissions

Low – gas captured

and injected is

directly metered by

a calibrated device

Medium Review meter calibration

records and certificates

Check all emission factors

and unit conversions

Recalculate baseline

emissions

Completeness

Accuracy

Cut-off

Classification

Completeness

Accuracy

Cut-off

Occurrence

Project -

P12 Injection Gas

Transport

P16 Venting at

Injection Site

P12 Injection Gas

Transport

P20 Electricity

Consumption

P21 Fuel Extraction

/ Processing

Occurrence Medium –

multiple

contributors to

project emissions

Medium – sources

are spread out

geographically

Medium Check data for outliers and

anomalies

Check meter calibration

records

Review any noted corrections

to raw data

Recalculate significant

contributors to project

emissions


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The site visit occurred on November 14, 2019 with the following individuals in attendance at the

CO2 Capture Site:

Klym Bolechowsky, P.Eng., Lead Verifier, ClearSky Engineering Inc.

Jay Kleinsasser, P.Eng., Director of Production, AlphaBow

Marvin Wieler, Production Foreman, AlphaBow

The purpose of the site visit was to perform the following tasks:

Review the details of project operation and performance in 2017-2018 with operating

personnel

Tour the project site to corroborate the GHG sources/sinks, facility description and

boundaries, and details of the calculation methodology described in the Project Plan;

including review of:

capture site equipment and metering

injection site equipment and metering

confirm project boundaries

Assess the reliability of the data used as input to the GHG offset calculations and the

overall approach

An initial meeting was held to get on overview of the CO2 capture site process. This was

followed by an inspection of the capture site to view the process equipment, project meters,

and gas sample location. The process was viewed starting with the gas inlet flange,

dehydrators, and compressors. The plant HMI system was viewed and meter calibration

records were reviewed. This was followed by a visit to the pump station located at 4-17-41-24

W4 and the CO2 injection sites located at the following oil & gas field batteries:

8-24-42-26 W4, 14-13-42-26 W4.

The following tasks were completed after the site visit:

Follow-up data requests including CO2 injection volumes reported to Petrinex

Recalculation of baseline and project emissions

Phone and email communications to clarify information provided

Detailed review of the Offset Project Report against the Offset Project Plan

Detailed review of GHG emission reduction calculations

Meeting at AlphaBow Calgary office on Dec. 3, 2019 to review initial findings

3.2 Team

Lead Verifier and Designated Signing Authority: Klym Bolechowsky, P.Eng.

Completed CSA ISO 14064-3 training: July 29 - 31, 2013 - Certificate #0000432380

Peer Reviewer: Ashley Mathew, EIT

Completed CSA ISO 14064-3 training: February 7-8, 2017- Certificate #50064648-50067754

Klym Bolechowsky, P.Eng. – Lead Verifier

Mr. Klym Bolechowsky, as Project Manager and Lead Verifier, will be the main contact with

AlphaBow. Klym is a registered Professional Engineer in the province of Alberta and is an

experienced third-party verifier having completed numerous verification projects under the CCIR

and SGER. He has his Certificate of Completion for the CSA GHG Verification Using ISO 14064

three day training course. He has twenty years of experience in the air quality field both as a


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consultant and in industry. Klym has completed over 100 GHG verifications in Alberta, BC, and

SK.

Association of Professional Engineers and Geoscientists of Alberta (APEGA) member #: 95630

ClearSky Engineering Inc. APEGGA Permit to Practice: P11255

Ashley Mathew, EIT – Peer Reviewer

Ms. Mathew is an Environmental Engineer and has undertaken CSA training in the use of the

ISO 14064-3 standard. She has six years of experience in the Environmental and Regulatory

field. She has participated in the peer review of several verifications of compliance reports and

offset projects and has knowledge and experience in GHG calculations. She has also

participated in several on-site verifications. Through other consulting work, she has gained

knowledge of metering systems and operational controls. As Peer Reviewer, Ms. Mathew will

review the subject matter to be audited, ensure the testing of the validity of findings developed,

and check for accuracy and completeness.


Amberg Corp. APEGA Permit to Practice: P8926

3.3 Schedule

Kick-Off Meeting: November 4, 2019

Site Visit: November 14, 2019

Meeting in Calgary: December 3, 2019

Draft Verification Report: December 12, 2019

Peer Review: December 16, 2019; revised April 2, 2020

Final Verification Report: December 17, 2019; revisions up to April 2, 2020

4.0 Results

4.1 Assessment of Internal Data Management and Controls

The project relies on electronic data capture for project monitoring and daily production reports

of CO2 injection gas received and vented volumes.

The list of meters measuring the above parameters and their maintenance and calibration

requirements is provided in Table 7 of the Offset Project Plan. The meter calibration records

and certificates of calibration were reviewed and confirmed to be within manufacturer

specifications.

4.2 Assessment of GHG Data and Information

The Quantification Protocol lists the sources/sinks (SS) that may be applicable to a project of

this type. The following baseline (B) condition and project (P) condition SS’s were included in

the GHG emission reduction quantification for the project.

Emission Reduction = EmissionsBaseline – EmissionsProject

EmissionsBaseline = sum of the emissions under the baseline condition

= Emissions from B3b Capture Vent


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EmissionsProject = sum of the emissions under the project condition

= Emissions from P3b Venting at Capture Site

+ Emissions from P7b Gas Processing

+ Emissions from P12 Injection Gas Transport

+ Emissions from P16 Venting at Injection Site

+ Emissions from P12 Injection Gas Transport

+ Emissions from P20 Electricity Consumption

+ Emissions from P21 Fuel Extraction / Processing

The equations for each of the above SS’s are documented in the Protocol and it was confirmed

that the correct Protocol equations and constants were applied in the GHG emission reduction

calculations. The quantification methodologies used by the project proponent are the same as

those described in the Offset Project Plan. The Protocol includes the density of CO2 and CH4 at

standard temperature and pressure (0°C and 1 atmosphere) which were corrected to project

meter reference conditions (15°C and 101.3 kPa) by AlphaBow (see Finding 19-10). The

equations and units were checked for accuracy. The annual offset calculation spreadsheets

were checked thoroughly for correctly functioning links and formulas, and unit conversions.

The sources of the emission factors referenced in the calculations were checked and confirmed.

Baseline and project emissions were recalculation for confirmation.

4.3 Assessment against Criteria

Table 1: Offset Criteria Assessment

Offset Eligibility

Criteria

Assessment

Reduction or

sequestration occurs in

Alberta

Satisfactory - the Project is physically located North East

of Red Deer, Alberta.

Result from actions not

required by Law at the

time the action is taken

Satisfactory - the Project is not required by law.

Result from Actions

taken on or after

January 1, 2002 and

occur on or after January

1, 2002

Satisfactory - the Project began operation after this date.

Reduction or

sequestrations is real

and demonstrable

Satisfactory - the Project has been verified according to

the verification criteria, listed in Section 2.4 of this report.

Quantifiable and

measureable

Satisfactory – the Project has an Offset Project Plan

describing quantification and measurement per the

Quantification Protocol.

The specified gas

emissions that were

Satisfactory


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reduced or the carbon

dioxide that was

sequestered must not

have had an effect on

the determination of a

regulated facility’s total

regulated emissions

under section 13(3) or

(4).


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4.4 Evaluation of the GHG Assertion

The verification assessment is that the GHG Assertion meets the requirements of the

Technology Innovation and Emissions Reduction (TIER) Regulation.

Based on the verification review of the calculated emission reduction offset credits, no evidence

of material discrepancies were identified. The Offset Project Plan, Offset Project Report, and

GHG Assertion were found to be reliable, complete and in compliance with the requirements of

the TIER.

4.5 Summary of Findings


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Table 2: Summary of Unresolved Findings

Result

#

Type Summary Description of Finding Source Category or

Source/Sink

Understatement

/Overstatement

Tonnes CO2

eq % net

Tonnes

CO2 eq %

absolute

19-01 quantitative Completeness – Gas Analyses

The protocol requires quarterly gas composition

measurements at a minimum. This requirement was not

met for: 2017, the first three quarters of 2018.

unknown unknown unknown

19-04 quantitative Accuracy – Wet Gas vs. Dry Composition

The volume of gas vented at the inlet is a wet gas stream.

The CO2 and CH4 content of the gas is determined by gas

compositional analysis on a dry basis. This introduces

inaccuracy in the calculation of CO2 and CH4 content in the

wet gas stream as the mole fractions to not account for the

H2O in the gas. AlphaBow acknowledges the inaccuracy,

however, this is mitigated by the fact that this vented

volume is reported in both the baseline condition (B3b) and

the project condition (P3b) so there is not quantitative

impact.

none 0.0 0.0 %

19-05 qualitative Transparency – Process Flow Diagram

The process flow diagram in the Offset Project Plan does not

clearly identify the project meter tags and gas analysis

sample locations.

n/a n/a n/a

19-06 qualitative Transparency – Offset Calculation Files

The summary of baseline and project emissions in the 2017

and 2018 calculation files are incorrectly labelled as 2019.

n/a n/a n/a

19-08 qualitative Transparency – Revisions

Revisions to project documents were not clearly identified.

AlphaBow should adopt a consistent and clear file naming

convention.

n/a n/a n/a

Total Error 0.0 tonnes

0.0 %

0.0 tonnes

0.0 %

Note: A positive value represents a quantitative overstatement, a negative value represents a quantitative understatement.


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4.6 Opportunity for Improvement

Instances of transcription errors of CO2 volumes from the monthly production reports would be

reduced by linking directly to the monthly totals in the spreadsheet formulae.

5.0 Closure

5.1 Verification Statement

The verification conclusion is:

Positive

5.2 Limitation of Liability

Due to the inherent limitations in any internal control structure, it is possible that fraud, error,

or non-compliance with laws and regulations may occur and not be detected. Further, the

verification was not designed to detect all weaknesses or errors in internal controls so far as

they relate to the requirements set out above as the verification has not been performed

continuously throughout the period and the procedures performed on the relevant internal

controls were on a test basis. Any projection of the evaluation of control procedures to future

periods is subject to the risk that the procedures may become inadequate because of changes

in conditions, or that the degree of compliance with them may deteriorate.

5.3 Confirmations

Confirmations are required by the ACCO to ensure that required data and information in offset

project plans and reports are completed and accurate. The following is a list of confirmations

completed by the verifier:

Formatting issues in the Offset Project Report

Correct entry of administrative fields such as facility codes and legal locations

Offset Project Report is provided and consists of the required components

Simplified process flow diagram

Project report information details as required

6.0 References

AEP. 2015. Carbon Offset Emission Factors Handbook, Version 1.0.

AEP. 2007. Quantification Protocol for Enhanced Oil Recovery, Version 1.0.

Government of Alberta. 2019. Standard for Greenhouse Gas Emission Offset Project

Developers, Version 3.0.

Government of Alberta. 2019. Standard for Validation, Verification and Audit, Version 4.0.

Government of Alberta. 2019. Technology Innovation and Emissions Reduction (TIER)

Regulation, Alberta Regulation 133/2019.

ISO. 2006. 14064 Part 2 – Greenhouse Gases: Specification with guidance at the project level

for quantification, monitoring and reporting of greenhouse gas emission reductions or removal

enhancements.

ISO. 2006. ISO 14064 Part 3 – Greenhouse Gases: Specification with guidance for the

validation and verification of greenhouse gas assertions.

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Appendix A: Final Verification Plan and Sampling Plan

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Scope & Objectives

Amberg Environmental and Regulatory Consultants (Amberg) was engaged by AlphaBow Energy

Ltd. (AlphaBow) to verify 2017 to 2018 vintage year offset credits generated by the CO2 Capture

from Prentiss2 for EOR Offset Project located North East of Red Deer, Alberta. The offset project

was verified at a reasonable level assurance against the flagged Quantification Protocol for

Enhanced Oil Recovery, version 1, October 2007, the Offset Project Plan and the program

requirements of the Alberta Emission Offset System. This is the first third-party verification

completed for this project by the verifier.

Alberta Environment and Parks (AEP) has described the key requirements of the verification

plan in their document entitled Standard for Verification, Version 4.0, and these elements are

addressed in the following sections of this Verification Plan. The first draft of the verification

plan was sent to the project developer on Nov. 4, 2019.

The objective of the verification is to provide AEP with assurance that the Offset Project Report

accurately represents the greenhouse gas (GHG) emission reductions associated with the

project and that the process is being carried out in accordance with TIER and the Quantification

Protocol for Enhanced Oil Recovery, Version 1.0.

The scope of the verification is the GHG Emission Reduction Assertion presented in the Offset

Project Report dated February 24, 2020 for the period January 1, 2017 to December 31, 2018.

The geographical scope is the CO2 Capture Site and associated well injection sites all located in

Alberta. The Offset Project Plan dated February 24, 2020 is also included in the scope of the

verification.

Level of Assurance

The verification will be conducted at a reasonable level of assurance.

Materiality

The materiality threshold is 5% of emission offsets generated as the project generates less

than 500,000 tonnes of emissions offset credits.

Verification Standards

This verification was carried out in accordance with the following standards:

ISO 14064 Part 3 – Greenhouse Gases: Specification with guidance for the validation

and verification of greenhouse gas assertions

ISO 14064 Part 2 – Greenhouse Gases: Specification with guidance at the project level

for quantification, monitoring and reporting of greenhouse gas emission reductions or

removal enhancements. Six principles:

1. Relevance: include all relevant GHG sources & sinks

2. Completeness: include all relevant emissions and removals

3. Consistency: enable meaningful comparisons in GHG related information

4. Accuracy: reduce bias and uncertainties as far as is practical

5. Transparency: disclose sufficient and appropriate GHG related information to

allow users to make decisions with reasonable confidence

6. Conservativeness: use conservative assumptions, values, and procedures to

ensure GHG emission reductions are not over estimated

Verification Criteria

The verification criteria include:

Technology Innovation and Emissions Reduction (TIER) Regulation, Alberta Regulation

133/2019

Standard for Verification, Version 4.0, November 2019

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Standard for Greenhouse Gas Emission Offset Project Developers, Version 3.0,

November 2019


Carbon Offset Emission Factors Handbook, Version 1.0, March 2015

Risk Assessment

A risk assessment identified areas of focus for the verification. Three categories of risk were

assessed:

1. Inherent Risk – the likelihood of a material error, omission, or misrepresentation

because of inherent challenges in the subject matter

2. Control Risk – the likelihood that the organization’s control procedures will fail to

prevent, detect, or correct an error or omission

3. Detection Risk – the risk that the procedures applied by the verifier do not detect a

misstatement in the GHG assertion. There is an inverse relationship between the

inherent and control risks, and the detection risk. If the inherent and control risks are

high, the verifier must design and perform procedures that result in a low detection risk

so that the overall verification risk is low.

The risk assessment was conducted during the planning stage and finalized during the

execution phase of the verification and is summarized in the following table:

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Risk Assessment

Line Item Attributes Inherent Risk Control Risk Detection Risk

Design

Verification Procedure

GHG Assertion

Level

Completeness Low – mature

project with

multiple

verification and a

reverification audit

from AEP

Medium – new staff

responsible for

offset quantification

Medium Conduct a site tour to view all

project sources/sinks

Accuracy

Baseline –

B3b Venting at

Capture Site

Occurrence Medium – major

contributor to

baseline emissions

Low – gas captured

and injected is

directly metered by

a calibrated device

Medium Review meter calibration

records and certificates

Check all emission factors

and unit conversions

Recalculate baseline

emissions

Completeness

Accuracy

Cut-off

Classification

Completeness

Accuracy

Cut-off

Occurrence

Project -

P12 Injection Gas

Transport

P16 Venting at

Injection Site

P12 Injection Gas

Transport

P20 Electricity

Consumption

P21 Fuel Extraction

/ Processing

Occurrence Medium –

multiple

contributors to

project emissions

Medium – sources

are spread out

geographically

Medium Check data for outliers and

anomalies

Check meter calibration

records

Review any noted corrections

to raw data

Recalculate significant

contributors to project

emissions

Completeness

Accuracy

Cut-off

Classification

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A contribution analysis was conducted to assess the relative contribution of each line item to

the overall GHG assertion. This was useful in the risk assessment phase to identify priority line

items.

Contribution Analysis

2017

2018

SSR CO2

(t CO2e)

CH4

(T CO2e)

N2O

(t CO2e)

CO2e

(t Co2e)

Total

(t CO2e)

% of Total Offset

2017 Baseline 20,520 187 20,707 100% of baseline

2017 Project 4,348 266 22 3,429 8,065 63.8%

Vent Inlet 412 4 416 3.3%

Vent Outlet 61 1 61 0.5%

Process Fuel Extraction

and processing 69 0 0 69 0.5%

Process Fuel Emission 5 2 0 7 0.1%

Process Elec 2,824 2,824 22.3%

Venting Pipeline 0 0 0.0%

Pipelin Elec 3 3 0.03%

Venting Upstream Facility59 139 198 1.6%

Venting Stock Tanks 0 0 0 0.0%

Venting Wells 0 0 0 0.0%

EOR Fuel gas (emission)3,500 2 18 3,520 27.8%

EOR Fuel gas (extraction

and process)243 119 4 365 2.9%

EOR Electrical Cons 602 602 4.8%

Net Emission Reductions 16,172 -79 -22 -3,429 12,642

CO2 Capture from Prentiss2 for EOR

SSR CO2

(t CO2e)

CH4

(T CO2e)

N2O

(t CO2e)

CO2e

(t Co2e)

Total

(t CO2e)

% of Total Offset

2018 Baseline 8,247 67 8,314 100% of baseline

2018 Project 1,620 103 6 1,016 2,745 49.3%

Vent Inlet 313 3 316 5.7%

Vent Outlet 109 1 110 2.0%

Process Fuel Extraction and

processing16 0 0 16 0.3%

Process Fuel Emission 1 1 0 2 0.0%

Process Elec 835 835 15.0%

Venting Pipeline 0 0 0.0%

Pipelin Elec 2 2 0.04%

Venting Upstream Facility9 62 70 1.3%

Venting Stock Tanks 0 0 0 0.0%

Venting Wells 0 0 0 0.0%

EOR Fuel gas (emission) 1,096 1 6 1,102 19.8%

EOR Fuel gas (extraction

and process) 76 37 1 114 2.1%

EOR Electrical Cons 178 178 3.2%

Net Emission Reductions 6,627 -36 -6 -1,016 5,569


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Sampling Plan

Based on the risk assessment and contribution analysis, the sampling plan was developed to

include review and sampling of all available data for the volume of CO2 gas stream captured, all

gas analyses, all electricity invoices, all venting records, all emission factors, representative

samples of lower contributors to project emissions, as well as recalculating baseline and project

emissions. This included recalculating the GHG Assertion, and assessing consistency with the

Project Plan, Protocol, and AEP guidance.

Verification Procedures

The subject matter pertaining to this verification is described in the Quantification Protocol for

Enhanced Oil Recovery. The verification will employ substantive procedures consisting of

analytical tests and tests of detail - inspection of facility, documents, and inquiry. The verification

procedures are described previously in the Risk Assessment table. The verification process will

also include the following procedures:

Confirmation of ownership of offset credits

Inspect the facility and interview project staff

Review raw data collected from project meters

Review the emission factors utilized in the calculations and compare to source

publications to ensure appropriate factors are utilized. Recalculate emission reductions.

Assess the data management system during the site visit

A thorough understanding of the GHG Offset Project drives the verification approach. The

verification process will commence with gaining an understanding of the entity, business and

industry by reviewing the Offset Project Report and background information provided. The review

of these items will then direct the area of focus for the site visit, and the assessment of the

GHG quantification method and accuracy of emission reduction calculations.

The review of the data management system will assess how the inputs to the offset credit

calculation are determined and will consist of discussions with project management and review

of project documentation and records. A description of the data management system and

controls is included in the main body of the verification report.

The objective of the verification is to provide reasonable assurance that the emission reduction

calculations are not materially misstated. A positive statement of verification will be issued if

there is sufficient and appropriate evidence to support the GHG assertion at a reasonable level

of assurance. A reasonable assurance conclusion is a positive factual statement that says the

GHG emission reduction assertion is correct.

Site Visit

The site visit was completed on November 14 at the AlphaBow CO2 Capture facility. Safety

requirements for the site visit include: Nomex coveralls, hard hat, safety glasses, CSA safety

boots.

Verification Report

A verification report will be prepared summarizing procedures and findings. Detailed

documentation of the verification process will be maintained and described in the final verification

report. The documentation will include a description of activities during the verification and a

description of any findings and observations. A Statement of Verification will be prepared and

signed by the Lead Verifier. A signed Conflict-of-Interest checklist and Statement of Qualification

will also be provided.

Verification Schedule

The verification schedule is summarized as follows:

Kick-Off Meeting: November 4, 2019

Site Visit: November 14, 2019

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Meeting in Calgary: December 3, 2019

Draft Verification Report: December 12, 2019

Peer Review: December 16, 2019; revised April 2, 2020

Final Verification Report: December 17, 2019; revisions up to April 2, 2020

Verification Team

The verification team will include the following members:

Klym Bolechowsky, P.Eng., ClearSky Engineering Inc. (Lead Verifier, Designated Signing

Authority)

Ashley Mathew, EIT (Peer Reviewer)

Klym Bolechowsky, P.Eng. – Lead Verifier

Mr. Klym Bolechowsky, as Project Manager and Lead Verifier, will be the main contact with

AlphaBow. Klym is a registered Professional Engineer in the province of Alberta and is an

experienced third-party verifier having completed numerous verification projects under the CCIR

and SGER. He has his Certificate of Completion for the CSA GHG Verification Using ISO 14064

three day training course. He has twenty years of experience in the air quality field both as a

consultant and in industry. Klym has completed over 100 GHG verifications in Alberta, BC, and

SK. Some of his recent projects relevant to the oil & gas industry include:

2013, 2015 – 2019 SGER / CCIR verification for Peyto Oldman Gas Plant

2012 - 2016 SGER compliance report verification for Inter Pipeline Cochrane Extraction

Plant

2016 – 2018 SGER & CCIR compliance report verification of Suncor Oil Sands, SAGD,

and Edmonton Refinery Facilities in association with Cheminfo Services Inc.

2016 Government Audit of Imperial Oil Kearl Oil Sands Project in association with

Cheminfo Services Inc.

Klym has presented papers on GHG verification at the following conferences:

Air & Waste Management Association conference in Calgary on June 24, 2010:

http://www.clearskyeng.com/docs/AWMA_GHG_Presentation.pdf

EPA Emission Inventory Conference in Baltimore, MD, April 15, 2009:

Paper: http://www.epa.gov/ttn/chief/conference/ei18/session7/bolechowsky.pdf

Presentation:

http://www.epa.gov/ttn/chief/conference/ei18/session7/bolechowsky_pres.pdf


ClearSky Engineering Inc. APEGGA Permit to Practice: P11255

Ashley Mathew, EIT – Peer Reviewer

Ms. Mathew is an Environmental Engineer and has undertaken CSA training in the use of the

ISO 14064-3 standard. She has six years of experience in the Environmental and Regulatory

field. She has participated in the peer review of several verifications of compliance reports and

offset projects and has knowledge and experience in GHG calculations. She has also

participated in several on-site verifications. Through other consulting work, she has gained

knowledge of metering systems and operational controls. As Peer Reviewer, Ms. Mathew will

review the subject matter to be audited, ensure the testing of the validity of findings developed,

and check for accuracy and completeness.


Amberg Corp. APEGA Permit to Practice: P8926

http://www.clearskyeng.com/docs/AWMA_GHG_Presentation.pdf

http://www.epa.gov/ttn/chief/conference/ei18/session7/bolechowsky.pdf

http://www.epa.gov/ttn/chief/conference/ei18/session7/bolechowsky_pres.pdf

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Appendix B: Statement of Qualifications

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Statement of Qualifications

Offset Report

Project Name Offset Project ID

CO2 Capture from Prentiss2 for EOR 3482-7976

Reporting Company Legal Name Report Type Reporting Period

AlphaBow Energy Ltd. Offset Project Report from

January 1, 2017 – December 31, 2018

to

Signature of Third Party Verifier

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

third-party verifiers described in Section 29 of the Carbon Competitiveness Incentive Regulation.

Verifying Company Name

Amberg Environmental and Regulatory Consultants Per:

Signature of Third Party Verifier Date

April 2, 2020

Training Received Under ISO 14064 Part 3

Certificate of Completion for the “CSA GHG Verification Using ISO 14064” three day training course, July 29-31, 2013. Certificate #0000432380

First Name Last Name

Klym Bolechowsky

Professional Designation E-mail Address Phone Number

P.Eng. [email protected] (403) 982-5596

Lead Verifier

☒ Same as third party

verifier??





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Peer Reviewer


Ashley Mathew

E-mail Address Phone Number

[email protected] (403) 247-3088


Completed ISO 14064-3 training: Feb. 7-8, 2017- Certificate #50064648-50067754


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Appendix C: Findings and Issues

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Table 3: Detailed Findings and Issues Log

Item

(YR-

##)

Description of the Issues Investigated

During the Verification

Summary of information

exchanged between verifier

and client

Resolution Conclusion

(including %

discrepancy if

applicable)

19-01 Completeness – Gas Analyses

The protocol requires quarterly gas

composition measurements at a minimum.

This requirement was not met for: 2017, the

first three quarters of 2018.

Gas analysis reports unresolved unknown

19-02 Completeness – Venting Volume

A volume of vented gas in May 2017 was not

included in the 2017 GHG emission reduction

calculations.

May 2017 production report

2017 GHG emission reduction

calculation file

resolved 0.0 tonnes

0.0 %

19-03 Completeness – Project Electricity

The annual GHG emissions associated with

electricity consumption at the injection sites

was quantified but missed in sum formulae

for total project emissions. This was corrected

by AlphaBow.


calculation file


calculation file

resolved 0.0 tonnes

0.0 %

19-04 Accuracy – Wet Gas vs. Dry Composition

The volume of gas vented at the inlet is a wet

gas stream. The CO2 and CH4 content of the

gas is determined by gas compositional

analysis on a dry basis. This introduces

inaccuracy in the calculation of CO2 and CH4

content in the wet gas stream as the mole

fractions to not account for the H2O in the

gas. AlphaBow acknowledges the inaccuracy,

however, this is mitigated by the fact that

this vented volume is reported in both the

baseline condition (B3b) and the project

condition (P3b) so there is no quantitative

impact. AlphaBow clarified that this stream is

2017 – 2018 production reports

Gas analysis reports

unresolved 0.0 tonnes

0.0 %

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not metered, the volume is estimated based

on the time venting and average productions

rates.

19-05 Transparency – Process Flow Diagram

The process flow diagram in the Offset Project

Plan does not clearly identify the project

meter tags and gas analysis sample locations.

Offset Project Report unresolved n/a

19-06 Transparency – Offset Calculation Files

The summary of baseline and project

emissions in the 2017 and 2018 calculation

files are incorrectly labelled as 2019.


calculation file


calculation file

unresolved n/a

19-07 Consistency – Gas Densities

The Protocol specifies the following densities

to be applied in the GHG emission reduction

calculations:

CO2 density = 1.98 kg/m3 at STP

CH4 density = 0.717 kg/m3 at STP


calculation file


calculation file

resolved n/a

The Protocol does not specify the standard

temperature & pressure (STP) conditions but

the above values apply for T = O°C, P = 1

atmosphere. This is inconsistent with the STP

conditions used by Canadian industry for

gases: T = 15°C, P = 1 atmosphere. The

values applied by AlphaBow are consistent

with STP conditions used by Canadian

industry:

CO2 density = 1.86 kg/m3 at STP (T = 15°C,

P = 1 atmosphere)

CH4 density = 0.679 kg/m3 at STP (T = 15°C,

P = 1 atmosphere)

Therefore, it is the opinion of the verifier that

AlphaBow does not need to submit a

deviation request to Alberta Environment in

this case.

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19-08 Transparency – Revisions

Revisions to project documents were not

clearly identified. AlphaBow should adopt a

consistent and clear file naming convention.

OPP and OPR files unresolved n/a

Note: A positive value represents a quantitative overstatement, a negative value represents a quantitative understatement.

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Appendix D: Statement of Verification


April 2020

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Statement of Verification

Associated TIER Submission

Offset Project Protocol Project ID #

CO2 Capture from Prentiss2 for

EOR

Quantification Protocol

Enhanced Oil Recovery,

Version 1, October 2007 3482-7976

Project Developer

Serial

Range Start

Report

Period


January 1, 2017

– December 31,

2018

Serial

Range End

Statement of Verification

GHG Assertion

Value Units

Total Baseline

Emissions 29,021

tonnes

CO2eq

Total Project

Emissions 10,810

tonnes

CO2eq

Other

tonnes

CO2eq

Net Reductions

18,211

Tonnes

CO2eq


April 2020

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Statement of

Assertion

For the period of January 1, 2017 to December 31, 2018, the Project

resulted in GHG emission reductions of 18,211 tonnes CO2e.

Responsibilities of Project Developer and Third Party Verifier

Our responsibility is to develop a conclusion with a reasonable level of assurance as to whether

the GHG Assertion is free from material misstatement, and is fairly presented in accordance with

the Quantification Protocol for Enhanced Oil Recovery, version 1.0, and the program

requirements of the Alberta Emission Offset System under the TIER system.

Conclusion

Based on our work, it is our opinion at a reasonable level of assurance that the GHG Assertion

presented in the Offset Project Report for the CO2 Capture from Prentiss2 for EOR Project is

materially correct and presented fairly and accurately in accordance with the TIER system

criteria.

Signature of Third Part Verifier

Verifying Company

Name


Signature of Third

Party Verifier Date:

April 2, 2020

First Name

Last

Name

Klym Bolechowsky

Professional

Designation E-mail Address Phone Number



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Appendix E: Conflict of Interest Checklist


April 2020

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Conflict of Interest Checklist

Associated TIER Submission

Offset Project Protocol



Project Developer Report Type

Report Period

AlphaBow Energy Ltd. Offset Project Report

January 1, 2017 to December 31, 2018

Checklist

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

1. The relationship between my firm and this reporting company poses unacceptable threat 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

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

False

4. My firm participated in some manner in the development or completion of the associated offset submission for this reporting company.

False

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

False

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


April 2020

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I , Klym Bolechowsky (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


Signature of Third Party Verifier Date

April 2, 2020


Klym

Bolechowsky




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Appendix F: Supplemental Diagrams/Tables/Figures

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Aerial view of the CO2 Capture Site

Source: Google Maps

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