Slave Lake Pulp – a division of West Fraser Mills Ltd ......Slave Lake Pulp – a division of West...

Slave Lake Pulp – a division of West Fraser Mills Ltd. Biomethanation with Power Generation Verification Report

June 1, 2017

ICF Consulting Canada, Inc. 400 University Avenue, 17th Floor Toronto, Ontario M5G 1S5

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Statement of Verification Issued in Ottawa, Ontario

June 1, 2017

Executive Director Air and Climate Change Policy Branch Alberta Environment and Parks 12th Floor, Baker Centre 10025 – 106 Street NW Edmonton, Alberta T5J 1G4

Introduction Slave Lake Pulp – a division of West Fraser Mills Ltd. (“SLP”) engaged ICF Consulting Canada, Inc. (“ICF”) to review their GHG Assertion – Alberta Offset System Greenhouse Gas Assertion of Emissions Reduction Credits and supporting evidence, covering the period January 1, 2016 to December 31, 2016 (“GHG Assertion”). The GHG Assertion, dated May 24, 2017, specifies a claim for 10,966 tonnes CO2e over the aforementioned period, which resulted from an offset project generating electricity from biogas emanating from wastewater processes, based on the Quantification Protocol for Anaerobic Treatment of Wastewater Projects, Version 1, March 2009. The claim consists exclusively of 2016 vintage credits.

The Responsible Party (SLP) is responsible for the preparation and presentation of the information within the GHG Assertion. Our responsibility is to express our opinion as to whether the GHG Assertion is materially correct, in accordance with Alberta Environment and Parks’ approved quantification methodology Quantification Protocol for Anaerobic Treatment of Wastewater Projects, Version 1, March 2009 (“Protocol”) for this project, the Specified Gas Emitters Regulation (Alberta Reg.139/2007) (“Regulation”), and the associated guidance documents.

Scope We completed our review in accordance with the ISO 14064 Part 3: Greenhouse Gases: Specification with guidance for the validation and verification of greenhouse gas assertions (ISO, 2006). As such, we planned and performed our work in order to provide positive, but not absolute assurance with respect to the GHG Assertion. Our review criteria were based on the Protocol, the Regulation, and the associated guidance documents. We reviewed the Offset Project Report (OPR), Offset Project Plan (OPP), and associated documents. We developed the verification procedures based on the results of a risk assessment that we conducted during the planning stage. The verification procedures are identified in the Verification Plan and the details of any data sampling that was conducted are provided in the Sampling Plan (both plans are appended to the Verification Report). We believe our work provides a reasonable basis for our conclusion.

Conclusion No unresolved misstatements remain in the GHG Assertion as detailed in the Verification Report.

Based on our review, it is our opinion to a reasonable level of assurance that the GHG emissions reductions contained in the GHG Assertion are materially correct and presented fairly in accordance with the relevant criteria.

Selena Fraser, P.Eng. Duncan Rotherham Professional Engineer, Ontario (100178627) Vice President and Managing Director Lead Verifier ICF Consulting Canada, Inc. ICF Consulting Canada, Inc. Toronto, Ontario Ottawa, Ontario

Verification Report Slave Lake Pulp – a division of West Fraser Mills Ltd. Biomethanation with Power Generation

1. Verification Summary

Lead Verifier: Selena Fraser, P.Eng.

Associate Verifier: Sheldon Fernandes

Internal Peer Reviewer: Julie Tartt

Verification Timeframe: March to May 2017

Site Visit Date: May 2, 2017

Objective of the verification: Reasonable assurance on GHG Assertion for Emissions Reductions Credits

Assurance being provided to: Alberta Environment and Parks

Standard being verified to: ISO 14064-3:2006 Specification with guidance for the validation and verification of greenhouse gas assertions

Verification criteria employed: Climate Change and Emissions Management Act Specified Gas Emitters Regulation (Alberta Regulation 139/2007) Technical Guidance for Offset Project Developers, Version 4.0, February 2013 Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013

Quantification Protocol for Anaerobic Treatment of Wastewater Projects, Version 1, March 2009

Verification scope – Gases: Carbon Dioxide, Methane, Nitrous Oxide

Project Title: Biomethanation with Power Generation

Location: Located 18km east of Slave Lake, Alberta; NE ¼ & SE ¼ of Section 22, Township 72, Range 4, West of Meridian 5

Project Start Date: September 17, 2014

Credit Start Date: January 1, 2016

Credit Duration Period: January 1, 2016 to December 31, 2023

Expected Lifetime of the Project: Lifetime of the mill

Actual Emissions Reductions/

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Verification Report Slave Lake Pulp – a division of West Fraser Mills Ltd. Biomethanation with Power Generation Removals Achieved: 10,966 tonnes CO2e

Other Environmental Attributes: Aspects of this project qualify for the Bioenergy Producer Program (BPP) and will generate credits/benefits outside of Alberta’s Carbon Offset System. In addition to electricity and natural gas reductions, the Biomethanation with Power Generation Project will reduce mill requirements for chemicals and also volume of secondary sludge produced thus offsetting downstream methane generation from land applied sludge.

Project Registration: N/A

Project Activity: The project activity meets all the eligibility criteria for the Alberta offset system:

• Actions and reductions occurred after January 1, 2002. • Results are real, demonstrable, and quantifiable. • Actions taken are not be required by law. • SLP ownership of the offsets is clearly established. • The project has not been counted toward any

compliance obligations or in relation to offsets on any other greenhouse gas registries.

• The project has been verified by a qualified independent third party.

• The project is located in Alberta.

Project Report Temporal Period: January 1, 2016 – December 31, 2016

Verification Summary: No material or immaterial misstatements were detected in

the final GHG Assertion.

Reasonable level assurance Verification Statement issued.

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Verification Report Slave Lake Pulp – a division of West Fraser Mills Ltd. Biomethanation with Power Generation Main Contact Sheldon Fernandes (Verifier) Associate, ICF Consulting Canada, Inc.

400 University Avenue, 17th Floor, Toronto, Ontario M5G 1S5 416.341.0045 [email protected]

Main Contact Megan DiJulio (Responsible Party) Environmental Specialist

Slave Lake Pulp – a division of West Fraser Mills Ltd. P.O. Box 1790 Slave Lake, Alberta T0G 2A0 780.849.7714 [email protected]

2. Project Information The project comprises the construction of an anaerobic digester for wastewater treatment for Slave Lake Pulp – a division of West Fraser Mills Ltd. (SLP). This digester produces biogas, which is combustible as a renewable electricity source, replacing grid electricity consumption. The digester’s processes also alleviate the load placed on the pre-existing aerobic wastewater treatment processes, further reducing grid electricity consumption. Finally, exhaust heat from the biogas gensets is used for pulp flash drying processes, displacing existing natural gas consumption for this process. Over the reporting year 2016, no exhaust heat was used for flash drying processes1.

SLP has developed the necessary documentation detailing project activities to support their claim for emissions reductions to be registered on the Alberta Offset Registry under Alberta’s Specified Gas Emitters Regulation. SLP has engaged ICF Consulting Canada, Inc. (“ICF”) to provide a third-party verification of the emissions reductions asserted by SLP related to the project activities discussed herein.

The quantification of the emissions reductions associated with the project is defined by Alberta Environment and Park’s (“AEP”) Quantification Protocol for Anaerobic Treatment of Wastewater Projects, Version 1.0, March 2009 (“the Protocol”) as well as an approval letter from AEP to SLP

1 Section 2.3 of the Verification Plan (See attached appendices) provides further information about the Project’s geographical location, infrastructure and activities, greenhouse gas sources, relevant greenhouse gases and reporting period.

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Verification Report Slave Lake Pulp – a division of West Fraser Mills Ltd. Biomethanation with Power Generation dated February 15, 2015. The Project Report describes the emissions reductions claim (“GHG Assertion”) made by SLP related to this project.

The Biomethanation with Power Generation Project (“the Project”) covered by this verification engagement involves the creation of 2016 vintage emissions reductions achieved through reduction of electricity consumption.

The Project is located 18km east of Slave Lake, Alberta.

This is the first time ICF has been engaged by SLP for verification services pertaining to this Project.

This document describes the terms and scope of this verification. It serves to communicate the findings of the verification.

3. Verification Procedures The scope of the verification was defined during the verification planning stage and is detailed in the Verification Plan, which is appended to this document. The Verification Plan also describes ICF’s verification process that was executed through the course of the verification, and identifies the specific verification procedures that were planned and executed through the process.

Procedure Date

Verification Kick-Off Meeting March 16, 2017

Verification Procedures Conducted March 2017 – May 2017

Site Visit May 2, 2017

Internal Peer Review May 31, 2017

Final Verification Report Issued June 1, 2017

3.1 Site Visit The site visit was conducted by Sheldon Fernandes on May 2, 2017.

The site visit was a key step in planning and executing the verification. During the course of the site tour, ICF interviewed key site operations personnel regarding the operations and data management for the Project.

SLP staff interviewed included:

• Megan DiJulio, Environmental Specialist • Skyler Lovelace, Transportation Coordinator & Quality Specialist • Allison Moeller, Process Engineer • Francois Lavigne, Controller • Shannon Fehr, Engineering & Energy Superintendent

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• Tarek Aboul-Seoud, E&I Supervisor & Reliability Engineer • Jon Fontanet, Technical Support Analyst

The site visit included a review of all GHG emissions sources in the Project to identify and categorize each one as well as a review of calculation workbooks, additional documentation, and process flow diagrams followed by physical observation of the Project. Subsequently, a review of metering and data management processes was discussed and observed on site, including a review of meter calibration/validation procedures and a review of meter maintenance tags.

3.2 Summary of Project Changes Major GHG emissions sources have been identified by the Responsible Party and are detailed in the Offset Project Plan. The quantification methodologies outlined in the Protocol have been used to calculate GHG emissions sources, with the exception of source B7 – Anaerobic Wastewater Treatment Processes. As per a letter from AEP dated February 25, 2015, SLP is approved to exclude B7 – Anaerobic Wastewater Treatment Processes, and instead include B8 – Aerobic Treatment Wastewater Processes, for which a quantification methodology is not specified in the Protocol. ICF’s assessment of SLP’s quantification methodology is found in Section 4.4 Other Findings.

The uncertainty associated with the quantification methodologies applied was evaluated during Protocol development. The Project meets the data collection and project specific calculation requirements of the Protocol and therefore, the uncertainty associated with the quantification and resulting assertion meets AEP requirements.

3.3 Program Applicability Criteria The Project was assessed against the following program applicability criteria outlined in the Protocol, which includes the eligibility criteria specified in AEP guidance documents. This is described as a verification procedure in Section 4, Verification Findings, in this report.

Protocol applicability criteria include:

1. The project proponent must demonstrate that the baseline anaerobic wastewater treatment system (e.g. an uncovered lagoon or sludge pit) would have resulted in sufficiently anaerobic (oxygen-free) conditions to result in the formation of methane. For systems open to the atmosphere the project proponent should demonstrate that the baseline conditions were amenable to methane generation based on the depth of the treatment/storage unit, operational records showing a significant reduction in chemical oxygen demand in the unit, normal operating temperatures in the anaerobic treatment system and if applicable, the presence of a grease cap. For systems that are not enclosed or contained the average depth of the anaerobic system must be at least 1 metre deep;

2. For projects where methane production processes are enhanced through the addition of a heating source to create mesophilic or thermophilic conditions that were not

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previously present in the baseline anaerobic treatment unit, the anaerobic digestion facility must demonstrate reasonable diligence to manage the risk of fugitive emissions in keeping with the guidance provided in Appendix B as evidenced by an affirmation form the project develop and applicable records;

3. There must not be any applicable regulations that prescribe the project facility to install a biogas capture system to prevent the venting of methane emissions from wastewater treatment operations;

4. In project configurations where sedimentation in the anaerobic treatment unit results in a material reduction in chemical oxygen demand available for anaerobic digestion by microbes (and therefore an over estimate of the baseline methane generation potential of the wastewater), the project proponent must provide records of organic matter (sediments) removed from the anaerobic treatment unit. The project proponent should account for sedimentation COD losses if sediments have been collected and removed from the anaerobic treatment unit at a frequency of once every two years or more often;

5. For Greenfield wastewater treatment facilities implemented as part of the design of new processing plants, the baseline condition is the flaring of all methane produced from the unit using an open flare with 96% efficiency, and the carbon offsets eligible from this project are the displaced electricity or thermal energy derived from fossil fuels or displaced natural gas in gas transmission systems.

6. The quantification of reductions achieved by the project is based on actual measurement and monitoring (except where indicated in the protocol) as indicated by the proper application of the protocol; and

7. The project must meet the requirements for offset eligibility as specified in the applicable regulation and guidance documents for the Alberta Offset System.

Offset program eligibility criteria include that the Project:

• Occur in Alberta; • Result from actions not otherwise required by law and be beyond business as usual

and sector common practices; • Result from actions taken on or after January 1, 2002; • Occur on or after January 1, 2002; • Be real, demonstrable, quantifiable, and verifiable; • Have clearly established ownership; and • Be counted once for compliance purposes.

3.4 Verification Strategy The Verification Strategy applied to this verification was a predominantly substantive approach. The Verification Team designed and executed verification procedures that focused on review of original metered and measured data.

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Verification Report Slave Lake Pulp – a division of West Fraser Mills Ltd. Biomethanation with Power Generation The Responsible Party relies on certain controls for the quantification of emissions. ICF relied on the calibration of meters as a control for accuracy of data and as such, ICF tested the operational effectiveness of these controls as well as the data processed by these controls. Details of the verification procedures employed to conduct these tests are provided in Section 4 of this report.

3.5 Data Management and Control System Review The Verification Team developed a thorough knowledge of the data management and control systems utilized in the Project through the review of the Project Report, observations during the site visit, and interviews with key Project personnel. The data flow diagram shown on the following pages outlines the flow of Project data and the custody of control.

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Verification Report Slave Lake Pulp – a division of West Fraser Mills Ltd.

Biomethanation with Power Generation

Slave Lake Pulp – Biomethanation with Power Generation Project – 2016 Vintage

Legend Aerobic Wastewater Treatment (P8, B8) Natural Gas Consumption (P1, P18, P19) Biogas Flaring (P19)

GHG

Emiss

ions

Ca

lcula

tor

Ope

ratio

ns/

Data

Man

agem

ent

Cate

gory

Aerobic Blowers

Electricity Usage

Variables/Parameters used to calculate GHG components

Emission Source

Variable/Parameter

Field/On-site CaptureSystem

Other Data System

2nd or 3rd Party Data

(name)

Manual transfer of

data

Electronic transfer of

data

CO2e: Electricity Usage, Reference Emission Factor

Electricity Meter

Wastewater

Volume FlowNitrogen Content

Historian / MOPS

Flow Meter

ALS Environmental

Report

Historian / MOPS

Environment Month End

Reports

N2O: Wastewater Volume, Nitrogen Content, Reference Emission Factors

Biogas Conditioning Equipment Flare Pilot

Natural Gas

Meter

Historian / MOPS

Natural Gas Consumption


Flare Manufacturer Daily Estimate

CO2, CH4, N2O: Natural Gas Consumption, Reference Emission Factors

Biogas Flare

Biogas Flared

Flare Meter

Historian / MOPS

Biogas Analyzer

Historian / MOPS

CO2, CH4, N2O: Biogas Flared, % CH4, Flare Destruction Efficiency, Reference CH4 HHV, Reference Emission Factors

% CH4

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Electricity Generation from Biogas (P22)Legend Diesel Consumption

(P1, P22)Biogas Venting (P17)GH

G Em

issio

ns

Calcu

lato

rO

pera

tions

/ Da

ta M

anag

emen

tCa

tego

ry

CO2, CH4, N2O: Biogas Volume, % CH4, Engine Destruction Efficiency, Reference CH4 HHV, Reference Emission Factors


Emission Source

Variable/Parameter


Other Data System


(name)

Manual transfer of

data


data

Gensets

Biogas Volume

Flow Meter

% CH4

Biogas Analyzer

Historian / MOPS

Historian / MOPS

Diesel Generator

Diesel Volume

Diesel Consumption

Log

CO2, CH4, N2O: Diesel Volume, Reference Emission Factors

Digester

Biogas Flow Rate and Time CH4%

Letter from SLP to AEP Monitoring

and Enforcement

Flow Meter

Historian / MOPS

Biogas Analyzer

Historian / MOPS

CH4: Biogas Flow Rate, Biogas Flow Time, CH4%, Reference Emission Factor

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Electricity Production (B18)LegendGH

G Em

issio

ns

Calcu

lato

rO

pera

tions

/ Da

ta M

anag

emen

tCa

tego

ry

CO2e: Mill Electricity Usage, Ancillaries Electricity Usage, Ancillaries Natural Gas Consumption, Biogas Volume, Biogas CH4%, Reference Emission Factor

Mill

Electricity Usage


Emission Source

Variable/Parameter


Other Data System


(name)

Manual transfer of

data


data

Ancillaries


Electricity Meter

Historian / MOPS

Natural Gas

Meter

Electricity Usage

Electricity Meter

Historian / MOPS

Gensets

Biogas Volume

Flow Meter

% CH4

Biogas Analyzer

Historian / MOPS

Historian / MOPS

Historian / MOPS

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3.6 Responsible Party Documentation Reviewed - Electronic logs of electricity usage and generation

o Aerobic blowers A, B, C (2013-2014, 2016) o Total purchased (2016) o Anaerobic processes parasitic load (2016) o Power generation parasitic load (2016)

- Electronic logs of methane concentration of biogas (2016)

- Electronic logs of biogas generated (2016)

- Electronic logs of natural gas consumed o Natural gas to power generation (2016) o Total purchased (2016) and monthly HHV o Natural gas for biogas conditioning (2016)

- Specification of biogas flare indicating pilot flare volume and destruction efficiency

- Electronic logs of wastewater volume o Volume to reactors (2016) o Volume from reactors (2016)

- Weekly ALS reports of nitrogen content of wastewater (2016)

- Letter from SLP to AEP regarding venting incident in December 2016

- Letter from SLP to AEP stating specifications of anaerobic digester

- Electronic logs of biogas flared (2016)

- Electronic logs of diesel consumed in emergency generators (2016)

- Specifications of biogas gensets including destruction efficiency

- Calibration records: o Blowers A, B, C o Internal electricity meters o Internal natural gas meters o Internal biogas meters o Internal biogas flaring meters o Internal methane concentration of biogas meter

- Letter from AEP to SLP confirming acceptance of deviance from Protocol

- Letter from SLP to AEP requesting confirmation of calculation methodology for B8/P8

- Offset Project Calculator

- Offset Project Report

- GHG Assertion

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4. Verification Findings

4.1 Verification Findings The Verification Team planned and completed the verification procedures described in the following tables. The procedures and findings related to each specific Project or Baseline emissions source variable used to quantify the GHG Assertion are provided in Table 4.1-1. The procedures and findings related to the overall Project GHG Assertion are provided in Table 4.1-2.

Table 4.1-1: Project and Baseline GHG Emissions Sources Findings Data Description Verification Procedure(s) Findings

B1 - Fuel Extraction and Processing None See Findings for B3 below

B3 - Facility Thermal Energy Generation Natural gas volume used for heat generation for flash drying of pulp

Compare raw data records, invoices against data in the emissions calculation workbook for consistency;

N/A - no heat was utilized from biogas sources for the reporting period

Observe or interview Project operations personnel regarding the operation of data transfer systems during site tour, including manual data entry procedures and associated controls;


Observe meter verification (calibration) tags and reports.


B8, P8 - Aerobic Wastewater Treatment Processes Electricity consumption of aerobic treatment blowers


Compared electronic spreadsheet data for blowers A, B, and C against SLP emissions calculation workbook. No misstatements detected.

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Data Description Verification Procedure(s) Findings


Data for the blowers is transferred manually directly from MOPs to the SLP emissions calculation workbook. No misstatements detected.


Reviewed meter calibration records for blowers A, B, and C, all dated March 15, 2016. No misstatements detected.

Volume of wastewater treated aerobically


Compared electronic spreadsheet data for wastewater volume against SLP emissions calculation workbook. No misstatements detected.


Data for aerobic treatment is transferred manually directly from MOPs to the SLP emissions calculation workbook. No misstatements detected.

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As confirmed by on-site personnel, the wastewater volume flow meter is not calibrated regularly. However, ICF's opinion is that this does not qualify as a misstatement: - There is no methodology specified for B8 and P8 – Aerobic Wastewater Treatment Processes; - SLP uses a reasonable technical methodology from the API Compendium of Greenhouse Gas Emissions Methodologies for the Oil and Natural Gas Industry, August 2009; - ICF reviewed a letter from SLP to AEP dated June 30, 2016 requesting approval of the API quantification methodology for which SLP has not received a response; and - The lack of calibration applies to an emissions source that is immaterial within the scope of the Project. No misstatements detected.

Nitrogen content of aerobically treated wastewater


Compared electronic spreadsheet data for nitrogen content against SLP emissions calculation workbook. No misstatements detected.


Data for nitrogen content for aerobic treatment is transferred manually directly from ALS lab reports into the Month End Spreadsheet and then into the SLP emissions calculation workbook. No misstatements detected.

Review selection of sampling point of nitrogen in wastewater treatment processes

Nitrogen is sampled weekly by a third party, ALS Environmental. SLP has a vested interest in ensuring the accuracy of nitrogen data. No misstatements detected,

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Assess sampling procedures of nitrogen in wastewater treatment processes

Nitrogen is sampled weekly by a third party, ALS Environmental. SLP has a vested interest in ensuring the accuracy of nitrogen data. No misstatements detected,

B18 – Electricity Production Total electricity generated on site


Compared electronic spreadsheet data for total electricity generation against SLP emissions calculation workbook. No misstatements detected.

Plot electricity generation and consumption data to determine potential data anomalies

Electricity generation quantity is not linear over 2016, but is not expected to be. This generation is contingent on biogas, which depends on several parameters, including the activity level of biogas-generating bacteria in the anaerobic digester. No misstatements detected.


Reviewed meter calibration report reviewed dated March 15, 2016. No misstatements detected.

Onsite electricity parasitic load for aerobic processes


Compared electronic spreadsheet data for anaerobic process electrical load against SLP emissions calculation workbook. No misstatements detected.


Electrical load for anaerobic processes is consistent with seasonal changes (higher in winter months, lower in summer months). No misstatements detected.



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Onsite electricity parasitic load required for power generation


Compared electronic spreadsheet data for power generation electrical load against SLP emissions calculation workbook. No misstatements detected.


Electrical load for power generation is consistent with total power generation positive and negative spikes. No misstatements detected.



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Biogas volume captured


In March 2016, it was discovered that the original (H) meter for biogas flow was not compensating for temperature or pressure to standard temperature and pressure in Alberta (101.325 kPa, 15°C). Compensation using the ideal gas law was consequently undertaken for the majority of the data for the reporting period. The H meter was replaced by the J meter in September 2016, with persistent pressure compensation issues - data continued to be compensated using the ideal gas law. In March 2017, it was discovered that the pressure transmitter for the biogas flow meter was scaled incorrectly over the entirety of calendar year 2016. The data transfer from the transmitter to the DCS was set to read the correct range of 0-70 kPa. The data transfer from the DCS to MOPS (the historian) was set to read an incorrect range of 0-100 kPa. This was fixed retroactively to all the pressure transmitter data for 2016 (including the pressure data used for compensation purposes listed above). Both the H and J meters were sent back to factory for factory calibrations, and both meters passed factory calibrations as evidenced by calibration reports dated March 17, 2017 and March 30, 2017, respectively. Based on SLP's approach to compensation and calibration, no misstatements detected.


Compared electronic spreadsheet data for biogas generated against SLP emissions calculation workbook. No misstatements detected.

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Methane % of biogas volume


Reviewed meter calibration report reviewed dated October 7, 2016. No misstatements detected.


Compared electronic spreadsheet data for methane concentration against SLP emissions calculation workbook. No misstatements detected.

Natural gas volume consumed on site


Reviewed meter calibration report reviewed dated July 25, 2016. No misstatements detected.


Compared electronic spreadsheet data for natural gas consumed for power generation against SLP emissions calculation workbook. No misstatements detected.

Natural Gas Higher Heating Value


Compared electronic spreadsheet data for natural gas HHV against SLP emissions calculation workbook. No misstatements detected.

P1 - Fuel Extraction and Processing

None See Findings for P18, P19, and P22 below

P17 - Biogas Venting

Max Storage Volume of Bulk Volume Fermenter

Compare substantiating data sources to data used in emissions calculations

ICF reviewed a submission from SLP to AEP regarding construction of the project that specifies the max storage volume of the Bulk Volume Fermenter. No misstatements detected.

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Flow rate of biogas at a steady state


ICF reviewed a letter to the Monitoring and Enforcement division of AEP dated December 22, 2016, where SLP reported the time and flow rate over that time for venting biogas to atmosphere. These parameters were compared against the SLP emissions calculation workbook. No misstatements detected.


Time and flow rate are manually transcribed from the letter for AEP to the SLP emissions calculation workbook. No misstatements detected.


ICF reviewed a letter to the Monitoring and Enforcement division of AEP dated December 22, 2016, where SLP indicated that there is no flow meter on the vent, but that an estimate was made based on the flow rate through the scrubbers to the gensets. The modifications to the H and J biogas flow meters apply to this emissions source as described above. No misstatements detected.

Time that BVF is venting


ICF reviewed a letter to the Monitoring and Enforcement division of AEP dated December 22, 2016, where SLP reported the time and flow rate over that time for venting biogas to atmosphere. These parameters were compared against the SLP emissions calculation workbook. No misstatements detected.

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Time and flow rate are manually transcribed from the letter for AEP to the SLP emissions calculation workbook. No misstatements detected.

P18 - Biogas Conditioning

Natural gas volume for pilot and biogas conditioning equipment (glycol boilers)


Compared electronic spreadsheet data for biogas conditioning against SLP emissions calculation workbook. This meter encompasses pilot flare volumes, which are subtracted out in the emissions calculation spreadsheet. Pilot gas quantification is encompassed under Biogas Flaring below. No misstatements detected.


Data for biogas conditioning is transferred manually directly from MOPs to the SLP emissions calculation workbook. Pilot data is estimated within the emissions calculation workbook. No misstatements detected.


Reviewed meter calibration report reviewed dated July 25, 2016. No misstatements detected.

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P19 - Biogas Flaring

Biogas volume and pilot volume flared


In developing the SLP emissions calculation workbook for this Project for the reporting period, reporting personnel identified a drift in the flare (KURZ) meter starting in April 2016, and adjusted the data to better reflect approximate flow at the meter, using the average daily flow and complete runtime of the biogas meter to the gensets. This results in a more conservative estimate of overall emissions reductions. No misstatements detected.


Data for the biogas flare is transferred manually directly from MOPs to the SLP emissions calculation workbook. No misstatements detected.


Reviewed biogas flare meter calibration report dated May 17, 2016. As noted above, the meter passed calibration but meter data was adjusted, resulting in a conservative estimate of emissions reductions. No misstatements detected.

Destruction efficiency of biogas flare

Compare destruction efficiency with Reference Documentation

Reviewed destruction efficiency of biogas flare between ABUTEC spec sheet and SLP emissions calculation. No misstatements detected.

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P22 - Electricity Generation

Destruction efficiency of biogas engines

Compare destruction efficiency with Reference Documentation

ICF calculated the efficiency of the biogas gensets from manufacturer specifications and compared it against the efficiency used in the SLP emissions calculation workbook. No misstatements detected.

Diesel volume used for backup generators for electricity generation


SLP indicated that there are no specific invoices for diesel used in the back-up generators, and that diesel consumption for the back-up generators is from IVARA logs stating run time on the generators. Maintenance personnel log run time of the generators into IVARA and this is used to calculate diesel consumption based on manufacturer specs. ICF reviewed the IVARA log for 2016 diesel consumption. No misstatements detected.


Diesel consumption is transcribed from the IVARA electronic spreadsheet log to the SLP emissions calculation workbook. This represents a minimal source of emissions. No misstatements detected.

Table 4.1-2: Project GHG Assertion Findings GHG Assertion Risk Category Verification Procedure(s) Findings

Changes at the Project Level

Interview Project operations personnel regarding changes to equipment inventory, changes in operation, or any major events that have occurred in the time period covered by the GHG Assertion

SLP representatives on site confirmed that exhaust heat from the gensets was not used for flash drying over the reporting period. No misstatements detected.

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GHG Assertion Risk Category Verification Procedure(s) Findings

Incomplete emission sources

Compare OPP, OPR, GHG Assertion against the corresponding AEP templates, as applicable;

GHG emission sources listed in the GHG assertion and the OPP were compared; all reports include the same emissions sources as the Protocol. A flexibility mechanism was applied as approved by AEP to include emissions from Aerobic Treatment of Wastewater and exclude emissions from Anaerobic Treatment of Wastewater. No misstatements detected.

Review GHG Assertion against the Protocol for evidence of consistency in criteria and scope;

The project's GHG Assertion was reviewed against the scope and criteria for the Protocol to confirm consistency of criteria and scope. No misstatements detected.


SLP representatives on site confirmed that exhaust heat from the gensets was not used for flash drying over the reporting period. No misstatements detected.

Negligible sources

Through the site visit and understanding of the Project, observe emissions sources and evaluate those not considered by the Protocol.

No emissions sources identified on site that were not already considered in the Protocol and documented as part of the GHG emissions reductions calculations.

Evaluate the appropriateness and quantification of any negligible emissions sources;

No negligible sources identified.

Complexity of data systems

Develop a data life cycle diagram, or data map for each major GHG emissions source and confirm with Project operations and GHG reporting personnel;

ICF developed a data flow diagram for each major GHG emissions sources and production. ICF confirmed the accuracy with operations personnel during the site visit. No misstatements detected.

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Emissions quantification methods used by SLP were reviewed and were found to follow those widely accepted by the AEP Protocol. A flexibility mechanism was applied as approved by AEP to include emissions from Aerobic Treatment of Wastewater and exclude emissions from Anaerobic Treatment of Wastewater. No misstatements detected.

Use of appropriate quantification methodologies

Review quantification formulae and estimation calculations prescribed by the Protocol against those utilized in emissions calculation workbook for each GHG emissions source;

Emissions quantification methods used by SLP were reviewed and were found to follow those widely accepted by the AEP Protocol. A flexibility mechanism was applied as approved by AEP to include emissions from Aerobic Treatment of Wastewater and exclude emissions from Anaerobic Treatment of Wastewater. No misstatements detected.

Calculate emissions reduction claim from original, second-party or third-party data.

A comprehensive re-calculation of emissions was performed from raw SLP data. No misstatements detected.

Quantification accuracy


A comprehensive re-calculation of emissions was performed from raw SLP data. No misstatements detected.

Completeness of GHG Assertion

Review GHG Assertion against guidance documents for completeness;

The final GHG Assertion was reviewed for consistency and accuracy with the calculated emission reductions. No misstatements detected.

Transcription of Final GHG Assertion

Compare calculated values to those in the GHG Assertion for transcription accuracy;

SLP calculated values were compared to values found in the GHG Assertion. No misstatements detected.

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Applicability Criteria

Interview key Project personnel regarding the application of applicability criteria.

The protocol applicability criteria were reviewed. The majority of the criteria (1-5) do not apply to the Project: - the baseline condition was aerobic wastewater treatment - there was no generation of methane gas pre-project or the requirement to capture it - The Biometh Project is not a Greenfield wastewater treatment facility The remaining applicability criteria were reviewed: - The quantification of reductions achieved by the project is based on actual measurement and monitoring (except where indicated in the Protocol) as indicated by the proper application of the Protocol - The project meets the requirements for offset eligibility as specified in the applicable regulation and guidance documents for the Alberta Offset System. No misstatements detected.

Assessment of Emission Factors and Default Parameters

Compare emission factors used in calculations against reference documents.

Compared emission factors used in emissions calculation workbook with emission factors from the AEP Carbon Offset Emission Factors Handbook, Version 1.0, March 2015, the AEP Anaerobic Treatment of Wastewater Protocol, Version 1, March 2009, the IPCC Volume 2 Chapter 2 - Stationary Combustion, 2006, and the API Compendium, 2009. No misstatements detected.

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Confirmations

Complete confirmations outlined in Table 26 of AEP’s Technical Guidance for GHG Verification at Reasonable Level Assurance, v1.0, January 2013

The following information was confirmed over the course of the verification: - Consistency of offset project information across offset project documentation - Offset project location and any applicable approvals information - The existence of methodology documents - Offset project contact, report dates, emission reduction numbers - Completeness and accuracy of process and data flow diagrams No misstatements detected.

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4.2 Misstatements There were no misstatements detected in the final GHG Assertion.

4.3 Materiality No material misstatements were identified in the GHG Assertion. This does not result in a breach of materiality (greater than 5% of the total GHG Assertion).

4.4 Other Findings Through the course of the verification the data management systems and controls employed in the quantification of emissions reductions associated with the Project were reviewed, as detailed in Section 4.1 above. These systems were found to be effective in the calculation of the GHG Assertion.

The approaches to measurement and calculation used to quantify the emissions and production values in the Assertion are those deemed acceptable by AEP. The uncertainty associated with these accepted approaches have been deemed acceptable by AEP.

As per a letter from AEP to SLP dated February 25, 2015, SLP’s quantification excludes B7 and P7 – Anaerobic Wastewater Treatment Processes but includes B8 and P8 – Aerobic Wastewater Treatment Processes. AEP’s Protocol does not specify the quantification methodology for B8 and P8. As such, SLP’s quantification is from the American Petroleum Institute (API) Compendium of Greenhouse Gas Emissions Methodologies for the Oil and Natural Gas Industry, August 2009.

ICF’s review of emission sources determined that the flow meter for wastewater is not calibrated on a regular basis, nor is it industry practice to do so. ICF reviewed documentation and the conclusion ICF has come to is that this does not qualify as a misstatement:

• There is no methodology specified for B8 and P8 – Aerobic Wastewater Treatment Processes;

• SLP uses a reasonable technical methodology from the API Compendium of Greenhouse Gas Emissions Methodologies for the Oil and Natural Gas Industry, August 2009;

• ICF reviewed a letter from SLP to AEP dated June 30, 2016 requesting approval of the API quantification methodology for which SLP has not received a response; and

• The lack of calibration applies to an emissions source that is immaterial within the scope of the Project.

4.5 Confirmations The "Confirmations” defined in Section 5.4 of the Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013 were completed. The results of this review were as follows.

• Offset project information across offset project documentation was reviewed and found to be consistent;

• Offset project location is included with the GHG Assertion;

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• Quantification methodologies have been documented in the offset project documentation;

• Offset project contact, report dates, emission reduction numbers, etc. were included in project documentation;

• Process and data flow diagrams in the project documentation were reviewed during the site visit and found to be an accurate representation of Project operations

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5. Verification Team Since 1969, ICF has been serving major corporations, all levels of government, and multilateral institutions. Globally, approximately 500 of our 5,000 employees are dedicated climate change specialists, with experience advising public and private-sector clients. ICF has earned a reputation in the field of climate change consulting for its analytical rigour, in-depth expertise, and technical integrity through scores of GHG emissions-related assignments over the past two decades.

Over the past ten years, ICF Consulting Canada, Inc., a fully owned subsidiary of ICF, has established a GHG Verification Body and carried out hundreds of facility-level GHG verifications and verifications of emissions reductions projects. The Verification Body has developed the necessary internal controls to ensure qualified and competent staffing uphold the principles of the relevant standard while quality control processes are utilized to assure data integrity is maintained and safeguarded. ICF’s clients choose ICF for its strong brand, technical expertise, and rigorous methodological approach.

The Verification Team assigned to this verification consists of experienced GHG verifiers.

Lead Verifier – Selena Fraser, P.Eng. Selena is a registered Professional Engineer in the Province of Ontario. Selena has acted as Lead Verifier and Associate Verifier for a number of emission reduction (offset) projects under the Alberta-based Offset Credit System including projects pertaining to Acid Gas Injection, Enhanced Oil Recovery and Landfill Gas Combustion for energy. She has acted as Associate Verifier for a number of emission quantification and credit applications under the Alberta-based Emissions Trading Regulation (ETR), specifically in the power generation sector. She has also acted as Associate Verifier for a number of compliance exercises under Alberta’s SGER in the power generation and oil and gas sectors. Associate Verifier – Sheldon Fernandes Sheldon Fernandes holds a Bachelor of Applied Science in Systems Design Engineering with a Specialization in Environmental Engineering from the University of Waterloo. He has over 4 years of experience in GHG quantification, verification, and reporting. His offset project audit experience includes aerobic composting, wind generation, energy efficiency, and nitrous oxide abatement projects. He has provided verification services for over a dozen greenhouse gas compliance reports from facilities including natural gas processing, steam assisted gravity drainage, and linear operations under Alberta and British Columbia’s greenhouse gas regulations. Sheldon has previous experience working with federal and provincial government agencies in Canada developing GHG and energy efficiency measurement and reporting tools. Internal Peer Reviewer – Julie Tartt Guelph and has completed supplementary verification training, receiving a certificate of training for ISO 14064. Julie is the Manager of ICF’s Verification Management System (VMS) and is also a Lead Verifier – she led and managed the development of ICF’s ANSI-accredited ISO14065

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VMS2. She has considerable experience and expertise quantifying greenhouse gases through her work developing numerous GHG inventories, and verifying GHG emissions. Julie has been working with ICF’s Verification Body since 2010 and has worked on verifications under several regulatory reporting programs including British Columbia, Ontario, and Quebec’s Greenhouse Gas Reporting Regulations, and Alberta’s Specified Gas Emitters Regulation. Facility compliance reports verified have included natural gas pipeline and natural gas processing linear facility operations, coal mining, electricity generation, and cogeneration facilities. Emissions reduction project verifications have included wind electricity generation, landfill gas capture and utilization, aerobic composting, and tillage management projects. Additionally, she has provided verification services for organizations reporting to the Carbon Disclosure Project and The Climate Registry, as well as voluntary emissions reductions projects. Julie also has extensive experience managing and administering large, multi-client, carbon market modeling and analysis studies nationally and at the provincial level.

2 Note: As of August 2016, ICF no longer maintains an ANSI-accredited VMS.

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Statement of Qualifications As the Lead Verifier and a Professional Engineer registered in the province of Ontario, I, Selena Fraser meet or exceed the required qualifications described in Section 18 of the Specified Gas Emitters Regulation, including the training requirements under ISO 14064.

The information contained within this document and this statement of qualifications, is complete and correctly represents the qualifications of ICF and the members of the Verification Team described herein. Dated this first day of June, 2017.

Selena Fraser, P.Eng. Duncan Rotherham

Professional Engineer, Ontario (100178627) Vice President and Managing Director Lead Verifier ICF Consulting Canada, Inc. ICF Consulting Canada, Inc. Toronto, Ontario Ottawa, Ontario

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Appendices Verification Plan

Sampling Plan

Conflict of Interest Checklist

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Verification Plan Slave Lake Pulp – a division of West Fraser Mills Ltd., Biomethanation with Power Generation

1 Introduction This document provides details on the verification scope and process that is planned to conduct a reasonable level verification of the 2016 Alberta Offset System Greenhouse Gas Assertion Of Emission Reduction Credits (the “GHG Assertion”) for the Slave Lake Pulp – a division of West Fraser Mills Ltd. Biomethanation with Power Generation, (the “Project”). An overview of operations at the Project will be provided in the Verification Report.

A Verification Risk Assessment was conducted during the verification planning stage; the results will be provided in Section 6 of this final Verification Plan. These results were used to inform the development of the verification procedures outlined in the Verification Findings Section of the Verification Report. Additionally, the results of the Risk Assessment informed the development of the Sampling Plan, which will be included in the Verification Report.

The Verification and Sampling Plans will be updated through the course of the verification as additional information becomes available.

The verification conclusion will be documented in the Verification Statement and the verification findings will be further described in the Verification Report. The Verification and Sampling Plans will be appended to the Verification Report to provide information related to the verification scope and process.

2 Verification Scope

2.1 Objective The primary objective of this verification engagement is to provide assurance to Alberta Environment and Parks (“AEP”) that the GHG Assertion is reliable, and of sufficient quality.

2.2 Parties and Users The person or organization that has overall control and responsibility for the GHG Project, as defined in Section 2.13 of ISO 14064-2:2006, is the “Project Proponent”. For this verification, Slave Lake Pulp – a division of West Fraser Mills Ltd. (“Slave Lake”) is the Project Proponent.

The person or persons responsible for the provision of the GHG Assertion and the supporting information, as defined in Section 2.24 of ISO 14064-3:2006, is the “Responsible Party”. For this verification, Slave Lake Pulp – a division of West Fraser Mills Ltd. (“Slave Lake”) is also the Responsible Party.

Verification Plan Slave Lake Pulp – a division of West Fraser Mills Ltd. Biomethanation with Power Generation

ICF Consulting Canada, Inc., the “Verifier” or “ICF”, has been engaged to provide a third-party verification of the GHG Assertion. The Lead Verifier and Associate Verifier comprise the ICF “Verification Team”.

The “Intended User” is defined in Section 2.22 of ISO 14064-2:2006 as the individual or organization identified by those reporting GHG-related information that relies on that information to make decisions. AEP is the Intended User of the information contained within the Verification Statement.

2.3 Scope The verification will be conducted in accordance with ISO 14064-3: Specification with guidance for the validation and verification of greenhouse gas assertions.

The Verification and Sampling Plans were developed based on the relevant criteria described in the following:

• Climate Change and Emissions Management Act • Specified Gas Emitters Regulation, Alberta. Reg.139/2007 • Quantification Protocol for Anaerobic Treatment of Wastewater Projects, Version 1.0,

March 2009 • Technical Guidance for Offset Project Developers, v4.0, February 2013 • Offset Project Plan (Version 3, February 2013) • Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance,

Version 1.0, January 2013

The following table defines the scope elements specified for the Project.

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Scope Element ISO 14064-3 Definition Project Specific Boundary The Project boundary,

including legal, financial, operational and geographic boundaries

Slave Lake Pulp Biomethanation with Power Generation; Slave Lake Pulp is located approximately 18 km east of Slave Lake, Alberta in the Municipal District of Lesser Slave River #124 on provincial highway #2. The legal description of the developed site is NE ¼ & SE ¼ of Section 22, Township 72, Range 4, West of Meridian 5. Slave Lake Pulp owns sections 22 and 23-72-4-W5 Latitude: 55.24775; Longitude: -114.52375

Infrastructure and Activities

The physical infrastructure, activities, technologies and processes associated with the Project

The Biometh Project consists of the following actions: 1) Construction of a 120,000 m3 anaerobic digester (AD) where the mill’s wastewater will be diverted before going through the pre-existing activated sludge basins (ASB). This AD will produce methane and hydrogen sulfide rich gas that will be sent through one of two 550 m3 biological hydrogen sulfide scrubber tanks. Scrubbed biogas will either be diverted to the biogas incinerator as a waste, or if quality permits, to any of the three 3.02MW dual fuel Jenbacher Genset engines to produce electricity. 2) Where the ASB’s existing blowers have a high electrical demand the AD has very little. As the AD will be doing the majority of the wastewater treatment there will be much less of a demand on the ASB’s to treat the wastewater resulting in a reduced grid electricity demand. 3) Piping installations for the injection of any of the three Gensets exhausts (Direct Injection) into flash drying to offset natural gas usage in the pulp drying process.

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GHG Sources and Sinks

GHG sources to be included

• Baseline Emissions from natural gas consumption for pulp drying, grid electricity production, and electricity consumption for aerobic wastewater treatment processes

• Project Emissions from anaerobic wastewater treatment processes, aerobic wastewater treatment processes, biogas venting, biogas conditioning, biogas flaring, and electricity generation from biogas

GHG Types Types of GHGs to be included

• Carbon Dioxide (CO2) • Methane (CH4) • Nitrous Oxide (N2O)

Reporting Period Vintage of credits to be included

January 1, 2016 – December 31, 2016

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2.4 Materiality During the course of the verification, individual errors, omissions or misrepresentations (collectively referred to as misstatements) or the aggregate of these misstatements will be evaluated qualitatively and quantitatively.

Materiality defines the level at which misstatements in the GHG Assertion or any underlying supporting information precludes the issuance of a reasonable level of assurance.

The Lead Verifier is responsible for applying professional judgment to determine if qualitative misstatements could adversely affect the GHG Assertion and subsequently influence the decisions of the Intended User, in which case, the misstatements are deemed to be material.

Quantitative misstatements will be calculated individually to determine the impact of the misstatement as a percentage of the GHG Assertion.

All misstatements that are outstanding at the conclusion of the verification are documented in the Verification Report and classified on an individual basis as either material or immaterial.

Materiality Threshold The materiality threshold is defined as 5% of the total reported emissions reductions in the GHG Assertion. Individual misstatements and the aggregate of individual misstatements will be analyzed to determine if the materiality threshold has been breached.

Tolerable Error Threshold Tolerable error dictates the level of rigor applied to the verification at the emissions source level. Tolerable error for this verification will be set at half of materiality (2.5%) of the total GHG Assertion.

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2.5 Principles ISO 14064 defines six principles that should be upheld in the development of the GHG Assertion. These principles are intended to ensure a fair representation and a credible and balanced account of GHG-related information. The verification procedures developed and executed during the course of this verification will present evidence such that each of these principles is satisfied.

Relevance Appropriate data sources are used to quantify, monitor, or estimate emissions sources. Appropriate minimum thresholds are used to justify the exclusion or the aggregation of minor GHG sources or the number of data points monitored.

Completeness All emissions sources relevant to the Project are included within an identified source category.

Consistency Uniform calculations are employed between reporting periods. Emissions calculations for each emissions source are calculated uniformly. If more accurate procedures and methodologies become available, documentation should be provided to justify the changes and show that all other principles are upheld.

Accuracy Measurements and estimates are presented, without bias as far as is practical. Where sufficient accuracy is not possible or practical, measurements and estimates are used while maintaining the principles of conservativeness and transparency.

Transparency Information is presented in an open, clear, factual, neutral and coherent manner that facilitates independent review. All assumptions are stated clearly and explicitly and all calculation methodologies and background material are clearly referenced.

Conservativeness Appropriate parameters affecting the Project’s emissions sources are utilized in the calculation of the GHG Assertion. When parameters or data sources are highly uncertain, the choice of parameter or data source utilized results in an underestimation of the GHG Assertion. Note that any error, underestimation or overestimation, would be evaluated as a potential material error.

2.6 Limitation of Liability Due to the complex nature of the operations within the Project and the inherent limitations of the verification procedures employed, it is possible that fraud, error, or non-compliance with laws, regulations, and relevant criteria may occur and not be detected.

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3 Verification Team The qualifications of the Verification Team and Internal Peer Reviewer are provided in the Statement of Qualifications

Lead Verifier, Selena Fraser, P.Eng. The Lead Verifier is responsible for all activities conducted within the verification, including overseeing the development of the Verification and Sampling Plans and the execution of the verification procedures. The Lead Verifier is the lead author of the Verification Report and executes the Verification Statement at the conclusion of the engagement.

Associate Verifier, Sheldon Fernandes The Associate Verifier works under the direction of the Lead Verifier to conduct the verification procedures.

Internal Peer Reviewer1, Julie Tartt The Internal Peer Reviewer is not a member of the Verification Team and does not participate in the verification until the draft Verification Report and draft Verification Statement have been prepared. The Internal Peer Reviewer conducts an internal assessment of the verification to ensure the verification procedures have been completed, the results of the verification have been thoroughly documented, any issues or misstatements have been investigated and the verification evidence is sufficient to reach the verification conclusion described in the Verification Statement.

1 Note: the Internal Peer Reviewer is not a member of the Verification Team, but is listed here to keep the list of personnel involved in the engagement in one place.

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4 Verification Process The ICF approach for conducting verification of a GHG Assertion follows the tasks outlined in the following diagram. Although these tasks are generally completed sequentially, the order may be modified according to circumstances such as scheduling and data availability.

4.1 Pre-Engagement Prior to submitting a proposal to conduct this verification, the following pre-planning steps were taken:

• The results of any previous business engagements or verifications with the Project Proponent were reviewed to determine if any previous unresolved conflicts may preclude ICF from engaging in the verification;

• The Project Proponent’s motivation for completing the verification was established; and • A Conflict of Interest procedure was initiated that documents whether any perceived or

real conflicts were found when considering threats due to:

- Advocacy

- Financial Interest

- Familiarity/Sympathy

- Intimidation

- Self-Review

- Incentives

Pre-Engagement Approach Execution of

Verification Completion

1. Selection of Lead Verifier

2. Initiate Conflict of Interest Procedure

3. Pre-Engagement Planning and Proposal Development

4. Contract Execution

5. Assess GHG Program & Revise VMS as Required

6. Initiate Verification Tracking

7. Selection of Verification Team

8. Communication with Project Proponent

9. Kick-off Meeting 10. Verification Risk

Assessment

11. Draft Verification and Sampling Plan

12. Site Visit 13. Conduct

Verification Procedures

14. Issue Clarification & Data Request

15. Revise & Finalize Verification and Sampling Plan

16. Address and Evaluate Outstanding Issues

17. Evaluate Evidence 18. Hold Verification

Findings Meeting (if necessary)

19. Draft Verification Report & Statement

20. Internal Peer Review

21. Completion of COI Form

22. Issue Verification Report & Statement

23. Close Verification File

24. Develop and Issue Management Memo(s)

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Following the acceptance of the proposal and signing of a contract for services, the Verification Team was selected. The Verification Team for this engagement comprises the individuals identified in Section 3.

4.2 Approach An extensive knowledge of the Project Proponent’s business, the relevant industry, and the details of the Project itself are required to conduct a thorough verification that can lead to a conclusion. The initial information collected about the Project Proponent and the Project formed the basis of the preliminary draft Verification Plan. The development of this final Verification Plan is an iterative process; that is, the process will be completed several times through the course of the verification and the resulting plan will be updated as new information became available.

There are three types of risk associated with the GHG Assertion defined in ISO 14064-3:

• Inherent Risk • Control Risk • Detection Risk

The process of designing the Verification Plan began with the development of Verification Risk Assessment for both the Project as well as the Project Proponent. The steps in this process included:

• Reviewing the GHG Assertion, and the methodologies employed by the Project; • Reviewing information on the industry and the specific Project under review; • Assessing the likelihood that a material misstatement might exist in the GHG Assertion, if

no controls were used to prevent misstatements in the GHG Assertion (i.e., inherent risk); • Assessing the control environment and the corporate governance process (i.e., control

risk); and • Reviewing each emissions source identified in the Project, and evaluating the contribution

of each source to the GHG Assertion and the associated potential material misstatement for each.

The results of the Verification Risk Assessment inform the development of the verification procedures, which will be documented in Section 6 of this final Verification Plan. A summary of the Verification Risk Assessment will be provided in Section 6 of this final Verification Plan. The draft Verification Plan will be provided to the Project Proponent before proceeding with the verification.

4.3 Execution of Verification With draft Verification and Sampling Plans in place, the verification procedures will be executed. This process involves collecting evidence, testing internal controls, conducting substantive testing, and developing a review file. Over the course of the verification, the draft Verification and

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Sampling Plans may change; the final Verification and Sampling Plans provided in the Verification Report reflect the verification parameters and procedures that were actually executed.

Site Visit The site visit will be conducted by Sheldon Fernandes on May 2 and 3, 2017.

The site visit will be a key step in the planning and execution of the verification. During the course of the site tour, ICF will interview key site operations personnel regarding the operations and data management for the Project.

Slave Lake staff to be interviewed on-site include:

• Megan DiJulio, Environmental Specialist • On-site operator or engineer • Control room operator • Instrumentation technician

During the site visit all GHG emissions sources for the Project will be reviewed to ensure appropriate identification and categorization. A review of process flow and metering diagrams will be followed by physical observation of the Project.

Health and Safety Requirements For the site visit, basic level personal protective equipment is required.

Collecting Evidence and Review of Documentation Sufficiency and appropriateness are two interrelated concepts that are fundamental to the collection of verification evidence. The decision as to whether an adequate quantity (sufficiency) of evidence has been obtained is influenced by its quality (appropriateness).

Through the execution of the verification procedures described in the Verification Report, the Verification Team will review three key forms of evidence including physical, documentary and testimonial:

• Management documentation: policies, programs, and procedures related to the collection, safeguarding, and management of the data supporting the GHG Assertion;

• Records: records comprise time-sensitive data, correspondence, and files including: the Offset Project Plan, calibration records, production records;

• Interviews: the interviews will provide information regarding operations and data management and will provide evidence to support the sufficiency of data controls; and

• Computer systems: data systems and proprietary data management software used to capture and manage the GHG-related data and to calculate the GHG Assertion.

Testing and Assessment of Internal Controls The Verification Team will develop a sufficient understanding of the GHG information system and internal controls to determine whether the overall data management system is sound and if it supports the GHG Assertion. This assessment will seek to identify any weakness or gaps in the controls that pose a significant risk of not preventing or correcting problems with the quality of the

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data and examining it for sources of potential errors, omissions, and misrepresentations. It will incorporate an examination of three aspects of the Project Proponent’s internal controls: (1) the control environment, (2) the data systems, and (3) the control and maintenance procedures.

Assessment of Data Substantive testing procedures will be used to assess the reasonability and validity of the GHG Assertion. Both quantitative and qualitative analysis will be performed to achieve the desired level of assurance. The verification procedures conducted and ICF’s associated findings are described in Section 4 of the Verification Report. The verification procedures include verification activities designed to:

• Review the Project boundary, including a review of the completeness of emissions sources identified;

• Review the Project data sources to ensure the GHG Assertion is calculated based on metered or estimated data that meets the requirements of the Quantification Protocol for Anaerobic Treatment of Wastewater Projects, Version 1.0, March 2009;

• Re-calculate the GHG Assertion, which demonstrates transparency and accuracy; and • Review the GHG Assertion to ensure the emissions reductions calculated by the Project

Proponent have been accurately reported.

Clarification and Data Request To facilitate information flow between the Verification Team and the Project Proponent, a consolidated request for additional information will be developed through the course of the verification and issued to the Project Proponent. This “Clarification and Data Request” will be used to document information requests and summarize the responses. It will also be used to document the Verification Team’s assessment of each response.

Developing a Review File A review file (the “File”) comprised of documents, records, working papers and other evidence collected and created during the course of the review that support the review conclusions will be developed for this verification. This evidence stored in hard copy and/or electronic format will serve to provide support for the verification conclusion, provide evidence that the verification was conducted in accordance with the criteria set forth in this document, and aid the Verifier in conducting current and future reviews.

The File will include:

• The GHG Assertion and supporting documentation, as submitted to AEP; • Decisions on the level of materiality and the results of the Verification Risk Assessment; • Documentation on the Project Proponent’s internal controls; • Descriptions of the controls assessment work and results; • Documentation of the substantive testing procedures that were carried out and the results; • Documentation of the confirmations outlined in Table 26 of AEP’s Technical Guidance for

GHG Verification at Reasonable Level Assurance, v1.0, January 2013;

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• Copies of any correspondence with the Project Proponent or other parties relevant to the review;

• The Verification Team’s working papers; • The Clarification and Data Request with documented responses from the Project

Proponent; and • Client data (copies of relevant records, spreadsheets, and other data files).

The File is the property of ICF and access to it is normally restricted to the Verifier and the Project Proponent. ICF will retain and safeguard the file for a minimum of seven years.

4.4 Completion This engagement will be formally closed after the verification has been executed and the Verification Report has been finalized.

Preparing the Verification Report The purpose of the Verification Report is to document the verification findings. All misstatements are described and compared to the materiality threshold individually and in aggregate. The Verification Statement with ICF’s verification conclusion is included in the Verification Report.

Internal Peer Review Process Prior to releasing the Verification Report and Verification Statement, an internal review process is conducted by the Internal Peer Reviewer. This process ensures that:

• All steps identified as being required to complete the verification were completed; • Any identified material or immaterial misstatements identified have been either:

- corrected by the Project Proponent and reflected in the GHG Assertion; or

- documented in the Verification Report, if misstatements persist at the conclusion of the verification.

• All required documentation detailing the verification process has been prepared, delivered, and retained.

Closing the Engagement The verification engagement will be closed out upon delivery of the final Verification Report.

5 Verification Schedule The following schedule is planned for the verification (subject to change with agreement between the Verifier and the Project Proponent).

Description Scheduled Date Verification Kick-Off Meeting April 11, 2017 Draft Verification Plan to Project Proponent April 18, 2017 Initial Clarification & Data Request April 21, 2017 Draft Verification Statement and Report May 12, 2017 Final Verification Statement and Report May 16, 2017

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6 Verification Risk Assessment The process for completing a Verification Risk Assessment was described in Section 4.2. The following table describes the inherent and control risks analyzed by the Verification Team and the corresponding verification procedure(s) outlined in Section 5 of the Verification Report that have been designed to address these risks.

Description of Inherent Risks

Inherent Risk Evaluation

Description of Control Risks

Control Risk Evaluation Verification Procedure(s)

B1 - Fuel Extraction and Processing Same as B3 N/A N/A None B3 - Facility Thermal Energy Generation Error in manual transfer of facility thermal generation natural gas consumption data to GHG calculator

Medium N/A N/A - ICF not relying on Responsible Party's controls




Natural gas meter for facility thermal generation is not calibrated and reading inaccurately

Medium Incomplete or undocumented calibration reports

High Observe meter verification (calibration) tags and reports.

B8 - Aerobic Wastewater Treatment Processes Error in manual transfer of aerobic wastewater treatment electricity use data to GHG calculator



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Electricity meter for aerobic wastewater treatment blowers is not calibrated and reading inaccurately



Error in manual transfer of data for volume of wastewater treated aerobically to GHG calculator





Meter for volume of aerobically treated wastewater is not calibrated and reading inaccurately



Error in manual transfer of nitrogen content data to GHG calculator





Sampling point for nitrogen content may be incorrectly chosen


Review selection of sampling point of nitrogen in wastewater treatment processes

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Sampling procedures for nitrogen content may be inconsistent and/or incomplete


Assess sampling procedures of nitrogen in wastewater treatment processes

B18 - Electricity Production Error in transcription of data entry of total electricity generated on site

High N/A High Compare raw data records, invoices against data in the emissions calculation workbook for consistency;

High N/A Medium Plot electricity generation and consumption data to determine potential data anomalies

Meter for total electricity generated on site may not provide accurate measurement of electricity generated

High Third party may not properly calibrate records


Error in transcription of data entry of anaerobic process parasitic electrical load



Meter for anaerobic parasitic electrical load may not provide accurate measurement of parasitic electrical load for anaerobic processes



Error in transcription of data entry for power generation parasitic electrical load


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Meter for power generation parasitic electrical load may not provide accurate measurement of parasitic electrical load for power generation



Meter for biogas generated may not provide accurate measurement of parasitic electrical load for power generation



Error in transcription of data entry for biogas volume captured


Meter may not provide accurate measurement of CH4% of biogas



Error in transcription of data entry for CH4%


Meter for natural gas consumed for power generation may not provide accurate measurement of natural gas consumption



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Error in transcription of data entry for natural gas consumed for power generation


High N/A Compare raw data records, invoices against data in the emissions calculation workbook for consistency;

P1 - Fuel Extraction and Processing Same as risks applicable to natural gas and diesel quantities in P18, P19, and P22

N/A N/A None

P8 - Aerobic Wastewater Treatment Processes Same as B8 P17 - Biogas Venting Max Storage Volume of Biogas Volume Fermenter (BVF) may be inaccurate

N/A N/A N/A - ICF not relying on Responsible Party's controls

Compare substantiating data sources to data used in emissions calculations

Error in manual transfer of data for flow rate of biogas at a steady state to GHG calculator





Meter for biogas flow volume is not calibrated and reading inaccurately



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Error in manual transfer of data for flow rate of biogas at a steady state to GHG calculator





P18 - Biogas Conditioning Error in manual transfer of biogas conditioning natural gas consumption data to GHG calculator





Natural gas meter for biogas conditioning is not calibrated and reading inaccurately



P19 - Biogas Flaring Error in manual transfer of biogas flaring natural gas and pilot consumption data to GHG calculator





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Meter for biogas flaring is not calibrated and reading inaccurately



Destruction efficiency of biogas flare (and pilot) may not be accurate

High N/A N/A Compare destruction efficiency with Reference Documentation

P22 – Electricity Generation Error in manual transfer of diesel volume used for electricity generation data to GHG calculator





Emission Offset Claim / Project Level

Normal operational changes at the Project may lead to significant changes in emissions during the reporting period.



Completeness or Consistency of GHG inventory documentation


Compare OPP, OPR, GHG Assertion against the corresponding AEP templates, as applicable;


Review GHG Assertion against the Protocol for evidence of consistency in criteria and scope;

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Negligible emission sources may not meet the definition and threshold for "negligible" or may have changed in magnitude from previous reporting periods.

Low N/A N/A - ICF not relying on Responsible Party's controls

Through the site visit and understanding of the Project, observe emissions sources and evaluate those not considered by the Protocol.

Low N/A N/A - ICF not relying on Responsible Party's controls

Evaluate the appropriateness and quantification of any negligible emissions sources;

Data used to quantify emissions is consolidated from several systems.


Develop a data life cycle diagram, or data map for each major GHG emissions source and confirm with Project operations and GHG reporting personnel;



Quantification of emissions within the GHG program requires the use of specific accepted methodologies.


Review quantification formulae and estimation calculations prescribed by the Protocol against those utilized in emissions calculation workbook for each GHG emissions source;

Accepted quantification methodologies may not be correctly implemented.



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Quantification of emissions may contain arithmetic errors Low N/A

N/A - ICF not relying on Responsible Party controls


Information may be missing from the GHG Assertion. Low N/A


Review GHG Assertion against guidance documents for completeness;

Information may be incorrectly transcribed into the final GHG Assertion

Low N/A N/A - ICF not relying on Responsible Party controls

Compare calculated values to those in the GHG Assertion for transcription accuracy;

The guidance document lists several eligibility criteria that should be met by the project

High N/A N/A - ICF not relying on Responsible Party controls

Interview key Project personnel regarding the application of applicability criteria.

Incorrect application of emission factors and default parameters used to quantify emission reductions

Medium N/A


Compare emission factors used in calculations against reference documents.

Information outlined in Table 26: Information Confirmed During the Verification of AEP's Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance (version 1.0, January 2013) are complete

Medium N/A

N/A - ICF not relying on Responsible Party controls Complete confirmations outlined in Table

26 of AEP’s Technical Guidance for GHG Verification at Reasonable Level Assurance, v1.0, January 2013

ICF Page 21


The detection risk is a measure of the risk that the verification procedures will fail to detect material misstatements, should such misstatements exist. The verification procedures will be developed to address inherent and control risks, while ensuring the level of detection risk is sufficiently low to reach a verification conclusion at a reasonable level of assurance.

The results of the Verification Risk Assessment will be utilized by the Verification Team to develop the verification procedures, which are outlined in Section 5 of the Verification Report.

ICF Page 22

ICF Page 1

Sampling Plan Slave Lake Pulp – a division of West Fraser Mills Ltd., Biomethanation with Power Generation

The following sampling plan defines the methodology used to select data to be tested under verification procedures related to confirmation of data through sampling of substantiating evidence. All other procedures do not include sampling, as described in the Verification Report.

Data Description Verification Procedure(s) Data Reviewed (Sample Size, if appropriate)

Sampling Methodology and Justification

Electricity consumption of aerobic treatment blowers


100% (all internal meter electricity consumption for blowers data)

All data reviewed

Volume of wastewater treated aerobically


100% (all internal meter wastewater volume data)

All data reviewed

Nitrogen content of aerobically treated wastewater


50% (22 of 44 N sample reports) 50% of all reports reviewed – minor emissions source, comparative analysis of all values shows little deviance between results

Total electricity generated on site


100% (all internal meter electricity generated data)

All data reviewed



Onsite electricity parasitic load for aerobic processes


100% (all internal meter electricity parasitic load for anaerobic processes data)

All data reviewed

Onsite electricity parasitic load required for power generation


100% (all internal meter electricity parasitic load for power generation data)

All data reviewed



100% (all internal meter methane composition data)

All data reviewed



100% (all 12 monthly natural gas consumption reports)

All data reviewed

Natural Gas Higher Heating Value


100% (all 12 monthly natural gas consumption reports)

All data reviewed

Flow rate of biogas at a steady state


100% (December 2016 biogas venting report)

All data reviewed

Time that BVF is venting Compare raw data records, invoices against data in the emissions calculation workbook for consistency;

100% (December 2016 biogas venting report)

All data reviewed

Natural gas volume for pilot and biogas conditioning equipment (glycol boilers)


100% (all internal meter natural gas for biogas conditioning data)

All data reviewed

ICF Page 2



Biogas volume and pilot volume flared


100% (all internal meter biogas flared data)

All data reviewed

Biogas volume used for electricity generation


100% (all internal meter biogas volume for electricity generation data)

All data reviewed

Diesel volume used for backup generators for electricity generation


100% (all log data for diesel consumption)

All data reviewed

Electricity consumption Observe meter verification (calibration) tags and reports during site tour.

All internal electricity meter calibration reports reviewed onsite

All calibration reports were reviewed

Electricity production Observe meter verification (calibration) tags and reports during site tour.

Internal electricity meter calibration report reviewed onsite

Calibration report reviewed


Observe meter verification (calibration) tags and reports during site tour.

All methane % meter calibration reports reviewed onsite




All internal natural gas meter calibration reports reviewed onsite


Biogas volume flared Observe meter verification (calibration) tags and reports during site tour.

Biogas flare meter calibration report reviewed onsite


Biogas volume used for electricity generation


Biogas flare meter calibration report reviewed


ICF Page 3

Conflict of Interest Checklist Question Yes No

1. Can the verifying organization or the Verification Team members directly benefit from a financial interest in the Project Developer or the Project Developer’s Project?

X

For example: • Owning shares of the Project Developer; • Having a close business relationship with the Project Developer; • Contingent fees relating to the results of the engagement; • Potential employment with the Project Developer; or • Undue concern about the possibility of losing the verification or other fees from the Project Developer. 2. Can the verifying organization or Verification Team members be in a position of assessing their own work?

X

For example: • Provided GHG consultation services to the project; • Provided validation for the project; • If providing non-GHG work for the company, consideration needs to be given as to how potential and perceived conflicts of interest can be managed; • A member of the verification team was previously employed with the company. 3. Does the verifying organization or a member of the Verification Team, or a person in the chain of command for the verification, promote or be perceived to promote, a Project Developer's position or opinion to the point that objectivity may, or may be perceived to be, compromised?

X

For example: • Dealing in, or being a promoter of, GHG credits on behalf of a Project Developer; or • Acting as an advocate on behalf of the Project Developer in litigation or in resolving disputes with third parties. 4. Is one or more of the Verification Team too sympathetic to the Project Developer's interests by virtue of a close relationship with a Project Developer, its directors, officer or employees?

X

For example: • A person on the Verification Team has a close personal relationship with a person who is in a senior GHG compilation role at the Project Developer; or • The Verification Team or a person of influence on the Verification Team has accepted significant gifts or hospitality from the Project Developer. 5. Is a member of the Verification Team or a person in the chain of command deterred from acting objectively and exercising professional skepticism by threats, actual or perceived, from the directors, officers or employees of the Project Developer?

X

For example: • The threat of being replaced as a third party verifier due to a disagreement with the application of a GHG quantification protocol; • Fees from the Project Developer represent a large percentage of the overall revenues of the verifying organization; • The application of pressure to inappropriately reduce the extent of work performed in order to reduce or limit fees; or • Threats of litigation from the Project Developer.

The declaration made in this statement is correct and truly represents ICF Consulting Canada, Inc. and the members of the Verification Team. Dated this first day of June, 2017.

Selena Fraser, P.Eng. Duncan Rotherham Professional Engineer, Ontario (100178627) Vice President and Managing Director Lead Verifier ICF Consulting Canada, Inc. ICF Consulting Canada, Inc. Toronto, Ontario Ottawa, Ontario

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