Verification Report Bantry AGI
Transcript of Verification Report Bantry AGI
+1 (604) 353-0264 • www.brightspot.co • [email protected]
AltaGas Processing Partnership
AltaGas Bantry Acid Gas Injection Project Verification Report
March 9, 2017
+1 (604) 353-0264 • www.brightspot.co • [email protected]
Statement of Verification
March 9, 2017
Alberta Environment and Parks
12th Floor, Baker Centre
10025 – 106 Street�
Edmonton, Alberta T5J 1G4
Introduction
AltaGas Processing Partnership (“The Responsible Party”) engaged Brightspot Climate Inc. (Brightspot
Climate) to review the greenhouse gas (GHG) emission reduction and removal project, AltaGas Bantry
Acid Gas Injection Project (“The Project”). The Project was developed in accordance with the
Quantification Protocol for Acid Gas Injection, Version 1, May 2008 (“The Protocol”).
The Responsible Party’s “GHG Assertion” consists of the Offset Project Plan, Offset Project Report and
supporting documentation. The GHG Assertion covers the reporting period January 1, 2016 –
December 31, 2016 and states an emission reduction and removal claim of 42,407 tonnes CO2e over
this period.
The emission reduction and removal claim consists exclusively of 2016 vintage credits.
The Responsible Party is responsible for the preparation and presentation of the information within the
GHG Assertion. Our responsibility as the verifier is to express an opinion as to whether the GHG
Assertion is materially correct, in accordance with approved Protocol, the Specified Gas Emitters
Regulation (Alta. Reg.139, 2007) (the “Regulation”), and the Alberta Environment and Parks Technical
Guidance for Offset Project Developers, Version 4.0, February 2014.
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 to provide positive, but not absolute assurance with respect to the
GHG Assertion.
The verification procedures that were performed through the course of the verification were developed
based on the results of a risk assessment that was completed during the verification planning stage.
These verification procedures are described in the Verification Plan. Certain verification procedures
included data sampling. The sampling type, sample size and the justification for the planned sampling
type and size are detailed in a Sampling Plan, which is included in the Verification Plan.
Conclusion
I believe our work provides a reasonable basis for my conclusion.
There are no unresolved discrepancies detected in the GHG Assertion.
Based on our review, it is my opinion at a reasonable level of assurance that the GHG Assertion is
materially correct and presented fairly in accordance with the relevant criteria.
Sincerely,
Aaron Schroeder, P.Eng.
Brightspot Climate Inc.
Vancouver, British Columbia
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Verification Summary
This Verification Report follows the standardized format prescribed in the Alberta Environment and
Parks guidance document, Section 5.2.1
Table 1: Verification Summary
Project Information:
Project Name: AltaGas Bantry Acid Gas Injection
Project
Geographic Boundary: AltaGas Bantry Processing Plant located
near Tilley, Alberta
LSD: 1/4-33-17-12 W4M (Processing Plant)
02-13-33-17 12 W4 (Injection Well)
Project Contact Information:
Stefan Dimic,
Commercial Representative, AltaGas Processing Partnership
1700, 355 4th Avenue SW Calgary, AB T2P 0J1
(p) 403-691-7031
(f) 403 691-7000
(w) www.altagas.ca
Alberta Offset System Criteria
Evaluated (see Verification
Activities):
The project must meet the eligibility criteria stated in Section 7 of the Specified Gas Emitters Regulation (SGER). In order to qualify, emission reductions must:
• 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.
Verification Objectives:
• issue a verification statement on whether the GHG assertion is without material discrepancy;
• issue a verification report that provides details of the verification activities; and
• complete the “confirmations” activities defined in the Alberta Environment and Parks Verification Guidance Document, Section 5.4, Table 26.
1 Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013. Alberta Environment and Parks.
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Verification Summary: There are no unresolved discrepancies detected in the GHG
Assertion.
Verification Team Members:
Lead Verifier: Aaron Schroeder, P.Eng.
Associate Verifier: Will Grundling, MSc.
Peer Reviewer: Nathan Muegge, P.Eng. Project Start Date: January 12, 2009
Credit Start Date: January 12, 2009.
Credit Period: January 12, 2009 – December 31, 2016
Offset Project Report Date: March 8, 2017
Expected Lifetime of Project: Acid gas injection (AGI) is expected to permanently replace the
Xergy SRU and tail gas incinerator.
Actual Emissions Reductions
Achieved: 2016: 42,407 tonnes CO2e
Other Environmental Attributes: The Project does not have any other environmental attributes,
credits or benefits.
Ownership:
AltaGas Processing Partnership (“The Proponent”) is the sole owner
of the Bantry Sour Gas Processing Plant (“The Plant”) and
maintains 100% ownership of the environmental attributes created
by the Project.
Project Registration:
Brightspot Climate is not aware of any other systems or registries
where the Project has been registered. The Responsible Party has
not disclosed registration of the Project on any other system or
registry.
Verification Report Date: March 9, 2017
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Introduction
This document contains the following six sections:
1. Verification Summary: as shown in Table 1 above.
2. Verification Report Introduction: this section defines the parties associated with this verification, a description of the project and the verification objective, scope and criteria applied to the verification. A list of the Responsible Party’s documents reviewed through the course of the verification is also provided in this section.
3. Verification Schedule: lists important verification activities and dates.
4. Verification Findings: this section includes a discussion of the results of each verification procedure and each qualitative and quantitative discrepancy identified as well as a summary of the total materiality of discrepancies.
5. Confirmations: a table provides details of the “confirmation” activities completed by the verifier, as required by Alberta Environment and Parks2.
6. Statements: Verification team biographies, Statement of Verification, Conflict of Interest statement and Statement of Qualifications.
The final Verification Plan is a separate document that was developed at the outset of the verification.
The Verification Plan includes a description of the final verification strategy, verification procedures and
sampling that was applied to the verification. The final Verification Plan is appended to this report.
Parties Associated with the Verification
ISO 14064-3 defines the following terms used in the context of a GHG verification:
GHG Assertion: a declaration or factual and objective statement made by the Responsible
Party.
The Alberta Environment and Parks Technical Guidance Document extends this definition to
include the information included in the Baseline Emissions Inventory Application and the
Specified Gas Compliance Report.
GHG Project: activity or activities that alter the conditions identified in the baseline scenario,
which cause GHG emission reductions or GHG removal enhancements.
The GHG project that is the subject of this verification is the AltaGas Bantry Acid Gas Injection
Project, which will be referred to throughout this document as “the Project.”
ISO 14064-3 defines the following parties associated with the verification:
Responsible Party: person or persons responsible for the provision of the greenhouse gas
assertion and supporting GHG information.
The Responsible Party for this verification is AltaGas Processing Partnership.
2 See Section 5.4 of Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013. Alberta Environment and Parks.
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Intended User: individual or organization identified by those reporting GHG-related information
as being the one who relies on that information to make decisions.
The Intended User for this verification is Alberta Environment and Parks.
Verifier: competent and independent person, or persons, with responsibility for performing and
reporting on the verification process.
The verifier for this verification is Brightspot Climate Inc. The members of the verification team
are provided in section 3 of this document.
Principles
ISO 14064-3 defines four fundamental principles to conducting a greenhouse gas verification, namely
independence, ethical conduct, fair presentation and due professional care.
Brightspot Climate has implemented processes, including requiring appropriate training for all
verification team members, to ensure the application of these principles for this verification.
A final “Conflict of Interests Checklist” is included in Section 6 of this report.
Project Description
Blue Source Canada (Blue Source) has been working with AltaGas Processing Partnership (AltaGas) to
quantify and report the greenhouse gas emission reductions associated with acid gas injection at the
Bantry Acid Gas plant.
Blue Source and AltaGas have developed an Offset Project Plan (OPP) for each of the Projects, which
describes the emission reduction technologies that have been implemented. The OPP describes the
Projects, the methodologies applied to quantify the emission reduction and the processes for
measuring and monitoring GHG information.
The quantification of the emission reduction is the difference between emissions in the baseline and
project conditions.
A dynamic baseline is applied to quantify baseline emissions, that is, measured quantities during the
reporting period are used to estimate baseline emissions for the same period. This approach conforms
with the protocol approved by Alberta Environment and Parks. The baseline emission sources include
fuel extraction and processing (emission source “B9” in the OPP) and incineration (emission source
“B6” in the OPP).
Emission sources during the project period include fuel extraction and processing (emission source
“P12” in the OPP), acid gas dehydration and compression (emission source “P6” in the OPP) and upset
flaring (emission source “P8” in the OPP).
The emission reduction achieved between January 1, 2016 and December 31, 2016 (known as the
“reporting period”) will be reported and verified within the scope of this verification.
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Verification Details
Verification Parameters
Table 2: Verification Objectives, Criteria and Scope
Verification Objectives • issue a verification statement on whether the GHG assertion is without material discrepancy;
• issue a verification report that provides details of the verification activities; and
• complete the “confirmations” activities defined in the Alberta Environment and Parks Verification Guidance Document, Section 5.4, Table 26.
Criteria • Climate Change and Emissions Management Act
• Specified Gas Emitters Regulation (Alta. Reg.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 Acid Gas Injection, Version 1, May 2008
Scope Project Name: AltaGas Bantry Acid Gas Injection
Project
Geographic Boundary: AltaGas Bantry Processing Plant located
near Tilley, Alberta
LSD: 1/4-33-17-12 W4M (Processing Plant)
02-13-33-17 12 W4 (Injection Well)
Physical Operations: Capture and permanent sequestration of
the acid gas stream to reduce the quantity
of CO2 released to the atmosphere
Project condition includes compression,
transportation, and injection of acid gas
Baseline processes include flaring
Emission Sources: Natural Gas Combustion, Extraction and
Processing
Electricity Consumption
IPCC GHGs Emitted: CO2, CH4 and N2O
Reporting Period: January 1, 2016 – December 31, 2016
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Documents Reviewed
The following Responsible Party’s documents were reviewed through the course of the verification (only
the most recent version is listed in instances where multiple versions were reviewed):
• AltaGas Bantry GHG Calculator_2016_v5-2017-3-6.xlsx
• Bantry_AGI_FINAL_OPR_2016_v2_Ma-8-2017.pdf
• OPP_Bantry 2012.pdf
• Altagas_Bantry_multipleSamplePoints_2016-12-27.pdf
• Plant 2 Acid Gas 04-33-017-12-W4 – 2016-10-07 – GAS.pdf
• Plant 2 Sales used for Fuel Gas 04-33-017-12-W4 – 2016-10-07 – GAS (3).pdf
• Meter calibration reports (various)
• Bantry Meter Summary 2016 Volumes.xlsx
• Petrinex Volumetric For Bantry.pdf
• ESC2483 Blue Source AltaGasBantry 2016 DRAFT.pdf (SULSIM report)
Site Visit
The site visit was conducted on February 10, 2017 by Aaron Schroeder. The site visit included
observation of the emission sources, metering and data systems used for recording metered quantities.
The following Responsible Party staff were interviewed regarding various aspects of the Project.
• Terry Lait, Operator - AltaGas
• Rob Petersen, Operator - AltaGas
• Kelsey Lank, Carbon Solution Analyst – Blue Source Canada
• Tooraj Moulai, Carbon Solution Analyst – Blue Source Canada
Further details of the verification activities that were conducted on site, including observations and
inquiries, are provided in Table 4 of this report.
Verification Schedule
The verification was completed according to the schedule established between the Responsible Party
and the Verifier in the Verification Plan. The verification reached important milestones on the following
dates:
• Verification Kickoff Meeting: January 23, 2017
• Draft Verification Plan: February 10, 2017
• Site Visit: February 10, 2017
• Final GHG Assertion March 7, 2017
• Draft Verification Report : March 8, 2017
• Peer Review March 8, 2017
• Final Verification Report March 9, 2017
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Verification Findings
The results of the verification risk assessment provided the basis for the verification procedures. Table 3, below, provides a summary of the
verification procedures where discrepancies were detected. Table 4, which follows, provides a description of every verification procedure that
was completed.
Table 3: Verification Findings Summary
Activity Data / Inventory
Component Description Discrepancy Description
Discrepancy
Type
Discrepancy
Magnitude
There are no unresolved discrepancies detected in the GHG Assertion.
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Table 4: Findings of Verification Procedures
Activity Data / Inventory Component Description
Verification Procedures Verification Findings
PROTOCOL APPLICABILITY REQUIREMENTS
1. The project results from
emissions that otherwise
would have been released
to the atmosphere.
Substantive test: Review project schematics
and interview facility operators to determine
if baseline scenario described in the Offset
Project Plan is applicable.
The baseline condition for the Project was the continued use of the
Xergy SRU that had been in operation at the site since 2002.
Although this system was challenging to operate, it was achieving
the required sulphur recovery. This baseline scenario meets the
requirements of the Protocol.
No discrepancies detected.
2. Where capture and
injection operations are
separate, emissions at the
source are reported
separately.
Not applicable for this project.
3. The acid gas injection
scheme has obtained
approval from the Alberta
Energy Regulator under
Directive 051.
Substantive test: Review the operation’s
approval to operate an AGI scheme under
Directive 051.
The acid gas injection scheme has an approval to operate an AGI
scheme, as evidenced by project documentation.
No discrepancies detected.
4. Metering of injected
gas volumes occurs as
near as possible to
injection well.
Substantive test: Interview site operators
and metering diagram during site visit
regarding the location of the injection meter.
Metering of acid gas injected occurs at the injection wellhead as
confirmed during the site visit.
No discrepancies detected.
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Activity Data / Inventory Component Description
Verification Procedures Verification Findings
5. The acid gas injection
project must occur at a
facility that commenced
commercial operations
prior to July 1, 2007.
Substantive test: Confirm that commercial
operations began at the facility prior to July
1, 2007 by interviewing plant operators
during the site visit.
Commercial operations began at the AltaGas Bantry facility before
January 1, 2007, as confirmed with site operation personnel during
the site visit.
No discrepancies detected.
6. Consolidation of
multiple gas streams at
the capture facility should
have sufficient
transparency in the data
to attribute emissions to
each originating facility.
Substantive test: Review reported GHG
information to trace emissions data back to
each source of inlet gas at the capture
facility.
Reported GHG information has sufficient transparency to
disaggregate the information and trace emissions back to specific
inlet gas streams.
No discrepancies detected.
Substantive test: interview site operators
during site visit to determine if inlet gas
originates from facilities that are regulated
under SGER.
The Bantry facility is not receiving inlet gas from any other facility, as
confirmed during the site visit.
No discrepancies detected.
7. The emission reduction
quantification is based on
actual measurements.
Substantive test: Review source of
quantitative data used in the emission
reduction quantification and compare to
protocol requirements for measurement type
and frequency.
Modeled and actual measurements are used to quantify emissions
in the baseline condition.
Actual measurements are used to quantify all emission sources in
the project condition except electricity consumption of auxiliary
equipment and heaters, which each account for small proportions
of the total emissions in the project condition.
All parameters meet the monitoring requirements of the Protocol.
No discrepancies detected.
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Activity Data / Inventory Component Description
Verification Procedures Verification Findings
8. The project must meet
the eligibility criteria stated
in section 7 of the
Specified Gas Emitters
Regulation (these are the
requirements of the
Alberta Offset System)
Substantive test: Review the evidence
provided by the Responsible Party related to
the requirements of the Alberta Offset
System.
Occurs in Alberta – The AltaGas Bantry facility is located near
Tilley, Alberta, as confirmed during the site visit.
Actions not otherwise required by law – confirmed that acid gas
injection is not a required activity.
Actions taken on or after January 1, 2002 – commissioning of
the acid gas injection facility occurred in 2009, as confirmed by
project documentation.
Real, demonstrable, quantifiable – the verification procedures
confirmed that the emission reductions in the assertion meet these
requirements. The specific verification procedures supporting this
conclusion include observation during the site visits, review of
supporting meter calibration reports and documentation and the
recalculation of the emission reduction.
Clearly established ownership – AltaGas Bantry is owned by the
Responsible Party, as shown on the AltaGas website and asserted
by the Responsible Party.
Counted once for compliance purposes – The Responsible Party
provided a Statutory Declaration that the emission reduction will be
registered only in the Alberta Offset System.
No discrepancies detected.
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Activity Data / Inventory Component Description
Verification Procedures Verification Findings
PROTOCOL FLEXIBILITY
Project developers may
use an alternate sulphur
recovery process, but
must justify the method
for calculating baseline
emissions from this
alternate technology.
Substantive test: Review the justification for
the baseline calculation method for the
baseline technology and compare to
protocol requirements.
The baseline condition for the Project was the continued use of the
Xergy SRU that had been in operation at the site since 2002.
Although this system was challenging to operate, it was achieving
the required sulphur recovery. This baseline scenario meets the
requirements of the Protocol.
No discrepancies detected.
QUANTIFICATION DATA
Sulphur recovery unit –
estimated monthly run
time, tail gas composition,
tail gas volume
Substantive test: Analyze SULSIM model
inputs, comparing input values to plant
operational values.
The model input data was reviewed. The 2016 gas composition
and gas flow rates matched the data used in the emission
reduction quantification.
No discrepancies detected.
Substantive test: Assess accuracy of
transcription of SULSIM model results to
quantities applied in emission reduction
quantification.
The SULSIM model results were correctly transcribed into the
emission reduction quantification.
No discrepancies detected.
Gas volumes – acid gas
injection, flare, flare fuel
Controls test: Review meter calibration
documentation for each meter used in
emission reduction quantification.
Meter calibration reports were available for all gas meters used in
the emission reduction quantification. All meter reports indicated
that meters were operating within manufacturer specifications
through the course of the reporting period.
No discrepancies detected.
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Activity Data / Inventory Component Description
Verification Procedures Verification Findings
Gas compositions – plant
fuel gas, acid gas
Substantive test: Review gas composition
reports for invalid results and compare
transcription of results into the emission
reduction quantification.
All gas compositions were found to be valid results and correctly
transcribed into the emission reduction quantification.
No discrepancies detected.
AGI injection compressor
electricity consumption
Substantive test: Compare transcription of
electricity consumption data into the
emission reduction quantification.
Electricity consumption data was correctly transcribed into the
emission reduction quantification.
No discrepancies detected.
AGI injection auxiliary
equipment electricity
consumption
Substantive test: Observe AGI auxiliary
equipment during site visit and compare to
equipment inventory in the Offset Project
Plan.
The inventory of auxiliary equipment for the acid gas injection
process in the project documentation is complete, based on
observations made during the site visit.
No discrepancies detected.
Substantive test: Analyze equipment
nameplate ratings and runtime assumptions
for appropriateness.
Equipment nameplate ratings and runtimes were compared to
equipment at a similar facility and found to be appropriate. Runtime
assumptions are appropriate based on a review of the gas plant
operating time for the reporting period.
No discrepancies detected.
Heaters – power rating,
number in service,
operating hours
Substantive test: Analyze equipment
nameplate ratings and runtime assumptions
for appropriateness.
Equipment nameplate ratings and runtimes were compared to
equipment at a similar facility and found to be appropriate. Runtime
assumptions are appropriate based on a review of the gas plant
operating time for the reporting period.
No discrepancies detected.
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Activity Data / Inventory Component Description
Verification Procedures Verification Findings
Emission factors – natural
gas combustion, natural
gas extraction and
processing, Alberta
electricity consumption
grid factor
Substantive test: Compare transcription of
emission factors into the emission reduction
quantification.
The emission factors used in the emission reduction quantification
were correctly transcribed from the Alberta Emission Factor
Handbook.
No discrepancies detected.
EMISSION REDUCTION QUANTIFICATION AND REPORT
Application of the
approved quantification
protocol
Substantive test: Compare the
methodologies described in the Responsible
Party’s Offset Project Plan to the
methodologies described in the approved
quantification protocol.
The verification team compared the methods described in the
Offset Project Plan to the methods described in the approved
Quantification Protocol.
The quantification methods described in the Responsible Party’s
Offset Project Plan adhere to the methods described in the
approved Quantification Protocol.
No discrepancies detected.
Substantive test: Recalculate the emission
reduction using original metered data.
The independent recalculation of the emission reduction resulted in
the same emission reduction quantity asserted by the Responsible
Party. Therefore, the approved Protocol quantification methods
were applied in the Responsible Party’s emission reduction
quantification.
No discrepancies detected.
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Activity Data / Inventory Component Description
Verification Procedures Verification Findings
Quantification of emission
reduction
Substantive test: Recalculate the emission
reduction using original metered data.
The independent recalculation of the emission reduction resulted in
the same emission reduction quantity asserted by the Responsible
Party. Therefore, the verification team concluded that no arithmetic
or calculation errors were made by the Responsible Party in the
emission reduction quantification.
No discrepancies detected.
Transcription of final
emission reduction into
Offset Project Report
Substantive test: Compare the final emission
reduction quantity reported by the
Responsible Party to the quantity reported in
the Offset Project Report. Also, compare
these quantities to the recalculated quantity
in previous verification procedures.
The emission reduction quantity was accurately transcribed into the
Offset Project Report.
No discrepancies detected.
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Additional Findings
The previous verification for this facility, which was conducted by ICF Consulting Canada, Inc., identified
a qualitative discrepancy related to the electricity grid consumption emission factor applied in the
emission reduction quantification. Recent (draft) guidance from AEP, which will be effective for the 2017
reporting period, indicates that projects may apply revised emission factors, provided all emission
factors referenced from a specific source are updated. It remains unclear if the emission factor
described above should be updated. The revised emission factor applied in the emission reduction
quantification results in a GHG assertion 665 tonnes CO2e greater than if the original emission factor,
which is defined in the Offset Project Plan, was applied (approximately 1.6% of the emission reduction
asserted).
Confirmations
Section 5.4 of the Alberta Environment and Parks Verification Technical Guidance document lists six
activities that are beyond the scope of a typical greenhouse gas verification, but are required by Alberta
Environment and Parks.
The “confirmations” refer to information contained in the Specified Gas Compliance Report (Excel
spreadsheet) submitted by the Responsible Party.
Table 5: Confirmation Findings
Confirmation Confirmation Findings
Consistency of offset project
information across offset
project documentation
Offset project information in the Offset Project Plan is consistent
with the information in the Offset Project Report. All information is
consistent with the requirements described in the relevant criteria.
Offset project location and
any applicable approvals
information
The project is located near Tilley, Alberta, as confirmed during the
site visit.
The acid gas injection scheme has an approval to operate an AGI
scheme, as evidenced by project documentation.
Methodology documents or
procedures manual exist
The Responsible Party has documented all relevant methodologies,
procedures and controls in the Offset Project Plan.
Offset project contact, report
dates, emission reduction
numbers, etc. (part of one
above)
The Offset Project Report was signed by the AltaGas Divisional Vice
President, Gas Commercial. The final emission reduction quantity
calculated by the Responsible Party was accurately transcribed into
the Offset Project Report.
Completeness and accuracy
of process and data flow
diagrams
The Responsible Party’s data flow chart, which is included in the
Offset Project Plan, accurately describes the data flows within the
project.
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Appendices
The following documents are appended to this report, as follows:
Peer Review Report
Statement of Qualifications
Conflict of Interest Statement
Final Verification Plan
Peer Review Report
Verification Activities Reviewed
Verification Process Comments
Verification Risk Assessment
The verification risk assessment identified all relevant emission sources described in the Quantification Methodology Document and site visit notes.
Verification activities were designed to mitigate the inherent and control risks defined during the risk assessment.
Data Sampling Data sampling was not used for this verification.
Verification Activities Working notes provide sufficient detail to demonstrate that all verification activities were completed through the course of the verification.
Issues raised during the verification
All questions and issues raised during the verification were sufficiently addressed by the Responsible Party.
Conflict of Interest An assessment for threats to independence was conducted before the verification began and after the verification was completed. No real or perceived conflicts of interest were identified.
Verification Conclusion
Verification Evidence Comments
Eligibility Evaluation Sufficient evidence supporting the eligibility of the project was provided by the Responsible Party.
Sufficient and Appropriate Evidence
The evidence collected through the verification activities reduces the overall verification risk and supports the verification conclusion.
Discrepancy Analysis No unresolved discrepancies.
Verification Report All documentation required in the Verification Report is included and complete.
Based on the documentation reviewed during the peer review process, I believe the verification of the 2016 vintage verification for the abovementioned Project was completed in accordance with the ISO 14064-3 standard and the criteria established in the Alberta Environment and Parks document, ”Technical Guidance for Greenhouse Gas Verification at Reasonable Level of Assurance, Version 1.0 January 2013.” as well as the “Quantification Protocol for Acid Gas Injection, Version 1.0, May 2008.” Sincerely, Nathan Muegge, P.Eng. (p)
Responsible Party: AltaGas Processing Partnership
Project: AltaGas Bantry Acid Gas Injection Project
Date Peer Review Completed: March 9th, 2017
647.280.0410
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Statement of Qualifications
Lead Verifier Details
Lead Verifier Name: Aaron Schroeder
Professional Designation: Professional Engineer
Email: [email protected]
Phone Number: +1 (604) 353-0264
Verifying Company Name: Brightspot Climate Inc.
Lead Verifier Training
• GHG Verification - ISO 14064-3, Canadian Standards Association, 2012
• CCP 403 - GHG Validation and Verification, University of Toronto, 2016 (Instructor)
Verification Team Biographies
Lead Verifier: Aaron Schroeder, P.Eng. has eleven years of professional experience analyzing,
quantifying and auditing greenhouse gas emissions in North America. Mr. Schroeder’s hands on
experience conducting over 150 greenhouse gas verifications includes numerous engagements for
industrial facilities in power generation, oil and gas production and processing, natural gas pipelines and
a wide range of emission reduction projects in beef and dairy management, conservation cropping
(zero-tillage) and nitrogen fertilizer management, and renewable energy and waste management. Mr.
Schroeder is a sessional instructor at the University of Toronto’s School of Environment for professional
development. He instructs the school’s greenhouse gas quantification and verification courses.
Analytical Support: Will Grundling, MSc. will provide analytical support to the verification team through
the completion of the verification procedures and the development of the Verification Report. His
verification experience includes event inventories, Alberta’s SGER compliances, Ontario GHG Reporting
Regulation verifications, and Fed Cattle Aggregation and Vent Gas and Instrument Air offset projects.
Peer Reviewer: Chris Caners, P.Eng., will conduct an independent peer review of the verification. He
has completed over 100 greenhouse gas verifications of annual SGER compliance reports as Lead
Verifier or Technical Expert, including reports for several natural gas processing facilities.
Statement
I, Aaron Schroeder, meet or exceed the qualifications of third party auditors described in Section 18 of
the Specified Gas Emitters Regulation.
Signed: Date:
Aaron Schroeder, P.Eng.
Brightspot Climate Inc.
Vancouver, British Columbia
March 9, 2017
+1 (604) 353-0264 • www.brightspot.co • [email protected]
Conflict of Interest AltaGas Bantry Acid Gas Injection Project
Brightspot Climate monitored threats to independence throughout the duration of the project. The
following declaration affirms that:
1. The verifying organization or the verification team members do not financially benefit directly
from the Project Developer or the Project Developer’s Project.
2. The verifying organization or verification team members are not in a position of assessing their
own work.
3. The verifying organization, members of the verification team, or persons in the chain of
command for the verification do not promote, nor can be perceived to promote, the Project
Developer's position or opinion to the point that objectivity may, or may be perceived to be,
compromised.
4. No member of the verification team is too sympathetic to the Project Developer's interests by
virtue of a close relationship with the Project Developer, its directors, officer or employees.
5. No member of the verification team or person in the chain of command is deterred from acting
objectively and exercising professional skepticism by threats, actual or perceived, from the
directors, officers or employees of the Project Developer.
Date: March 9, 2017
Location: Vancouver, BC
Signed:
Aaron Schroeder
Lead Verifier. Brightspot Climate
+1 (604) 353-0264 • www.brightspot.co • [email protected]
AltaGas Processing Partnership
AltaGas Bantry Acid Gas Injection Project Verification Plan
February 10, 2017
Brightspot Climate Inc. – Verification Plan AltaGas Processing Partnership – AltaGas Bantry Acid Gas Injection Project
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Terminology
ISO 14064-2 defines the following terms used in the context of a GHG verification:
GHG Assertion: a declaration or factual and objective statement made by the Responsible
Party.
The Alberta Environment and Parks Technical Guidance Document1 extends this definition to
include the document that identifies the greenhouse gas emission reduction and/or removals
and offset credits being claimed by the offset project over a defined period.
Project: activity or activities that alter the conditions identified in the baseline scenario which
cause greenhouse gas emission reductions or greenhouse gas removal enhancements.
The GHG Assertion subject of this verification is for the AltaGas Bantry Acid Gas Injection
Project, which will be referred to throughout this document as “the Project”.
ISO 14064-2 defines the following parties associated with the verification:
Responsible Party: person or persons responsible for the provision of the greenhouse gas
assertion and supporting GHG information.
The Responsible Party for this verification is AltaGas Processing Partnership.
Intended User: individual or organization identified by those reporting GHG-related information
as being the one who relies on that information to make decisions.
The Intended User for this verification is Alberta Environment and Parks (AEP).
Verifier: competent and independent person, or persons, with the responsibility of performing
and reporting on the verification process.
The Verifier for this verification is Brightspot Climate Inc. (Brightspot Climate). The members of
the verification team are provided in section 3 of this document.
1 Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013. Alberta Environment and Parks.
Brightspot Climate Inc. – Verification Plan AltaGas Processing Partnership – AltaGas Bantry Acid Gas Injection Project
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Introduction
This document serves to communicate information between the parties associated with the
independent verification of the Offset Project Report for AltaGas Bantry Acid Gas Injection Project.
This document contains three sections:
1. The introduction, which defines the principles by which this verification will be conducted;
2. The GHG Assertion, which describes the subject matter of the verification; and
3. The Verification, which defines the verification parameters and the GHG inventory principles that
will be tested by the verification. This third section also provides information regarding the
verification team and any findings from previous verifications for this Project.
The verification procedures, including the sampling plan and the results of the verification risk
assessment, will be appended to this verification plan in the final verification report.
The Responsible Party developed the Project in accordance with the requirements of the Quantification
Protocol for Acid Gas Injection, Version 1, May 2008 (the Protocol).
Principles
ISO 14064-3 defines four fundamental principles to conducting a greenhouse gas verification, namely
independence, ethical conduct, fair presentation and due professional care.
Brightspot Climate has implemented processes, including mandatory training for all verification team
members, to ensure the application of these principles for this verification.
Regarding the principle of independence, Brightspot Climate assessed threats to independence prior to
initiating this verification. No real or perceived threats to independence were identified. Brightspot
Climate will continue to monitor for threats to independence throughout the course of this verification. A
final “Conflict of Interests Checklist” will be appended to the Verification Statement.
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GHG Assertion
Project Subject Matter
The Technical Guidance Document2 defines “subject matter” in Section 2.2.3.2 as follows:
“The subject matter for an offset project is the greenhouse gas emissions from the offset project
and baseline, including the total greenhouse gas emission reduction and/or removals achieved
by the offset project that can be appropriately evaluated against the program criteria.”
The subject matter for the Project is defined in the verification scope, which is described in Table 4.
GHG Assertion
The Responsible Party’s asserted emission reduction is provided in the following table:
Table 1: Baseline and Previous GHG Assertions
GHG Emission Reduction 2016: 42,407 tonnes CO2e
Source: AltaGas Bantry Acid Gas Injection Project 2016 Offset Project Report
Changes to Operations and Boundaries
This is the first year that Brightspot Climate has provided verification services for the Project.
Responsible Party’s Data Management Systems
Table 2, below, describes the data measurement, estimation and data storage locations for all GHG
information used by the Responsible Party to produce the GHG inventory. The final column in this table
describes the data storage location and the path (intermediate data transfer) prior to use in the GHG
inventory.
Table 2: GHG Inventory Data Management
Activity Data Description Measurement Type Data Storage Location / Path
Sulphur recovery unit –
estimated monthly run time, tail
gas composition, tail gas volume
Modeled in SULSIM SULSIM Report
>> Emission Reduction Quantification
Gas volumes – acid gas
injection, flare, flare fuel Metered
AltaGas Historian
>> AltaGas Production Accounting
>> Petrinex Reports
>> Emission Reduction Quantification
Gas compositions – plant fuel
gas, acid gas Measured
Maxxam Laboratories Reports
>> Emission Reduction Quantification
AGI injection compressor
electricity consumption Metered
Fortis Data Extract Report
>> Emission Reduction Quantification
2 Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013. Alberta Environment and Parks.
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Activity Data Description Measurement Type Data Storage Location / Path
AGI injection auxiliary equipment
electricity consumption Estimated
Nameplate readings, plant run time
>> Emission Reduction Quantification
Heaters – power rating, number
in service, operating hours Estimated
Nameplate readings, plant run time
>> Emission Reduction Quantification
Emission factors – natural gas
combustion, natural gas
extraction and processing,
Alberta electricity consumption
grid factor
Reference values Alberta Emission Factor Handbook
>> Emission Reduction Quantification
Responsible Party’s Control Environment
The following table describes the Responsible Party’s quality assurance controls applied to the GHG
information used to produce the GHG inventory. Note that the verification procedures may not rely
upon these controls to establish sufficient and appropriate evidence to support the GHG Assertion.
Table 3: Responsible Party Data Controls
Activity Data Description Responsible Party Controls
Gas volumes – acid gas injection, flare, flare fuel Responsible party conducts periodic meter
calibration.
Application of the approved quantification protocol
Responsible Party has developed an Offset
Project Plan that is intended to conform to the
requirements of the approved quantification
protocol.
Verification
Principles
ISO 14064-2 defines six principles that are fundamental to the fair accounting and reporting of GHG
information. The verification procedures will test that these principles have been upheld through the
Responsible Party’s inventory, accounting and reporting processes.
Section 3.2 – 3.6 of ISO 14064-1 defines these principles as follows:
Accuracy: reduce bias and uncertainty as far as practical
Completeness: include all relevant emission sources
Conservativeness: use conservative assumptions, values and procedures to ensure that GHG
emission reductions or removal enhancements are not over-estimated
Consistency: enable meaningful comparisons of reported emissions (from year to year or
between facilities or between companies)
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Relevance: select GHG sources, sinks and reservoirs, data and quantification methodologies
appropriate to the needs of the intended user
Transparency: disclose sufficient and appropriate GHG information to facilitate verification and
to allow intended users to make decisions with relative confidence
Verification Parameters
The verification will be conducted according to the parameters defined in the following table:
Table 4: Verification Parameters
Level of Assurance Reasonable assurance
Objectives
• issue a verification statement on whether the GHG
assertion is without material discrepancy;
• issue a verification report that provides details of the
verification activities; and
• complete the “confirmations” activities defined in the
Alberta Environment and Parks Guidance Document3,
Section 5.4, Table 26.
Criteria
• Climate Change and Emissions Management Act
• Specified Gas Emitters Regulation
• 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 Acid Gas Injection, Version 1,
May 2008
3 Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013. Alberta Environment and Parks.
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Scope
Project Name: AltaGas Bantry Acid Gas Injection
Project
Geographic Boundary: AltaGas Bantry Processing Plant located
near Tilley, Alberta
LSD: 1/4-33-17-12 W4M (Processing Plant)
02-13-33-17 12 W4 (Injection Well)
Physical Operations: Capture and permanent sequestration of
the acid gas stream to reduce the quantity
of CO2 released to the atmosphere
Project condition includes compression,
transportation, and injection of acid gas
Baseline processes include flaring
Emission Sources: Natural Gas Combustion, Extraction and
Processing
Electricity Consumption
IPCC GHGs Emitted: CO2, CH4 and N2O
Reporting Period: January 1, 2016 – December 31, 2016
Materiality Quantitative materiality threshold is 5% of asserted greenhouse gas
emission reduction
Tolerable Error Thresholds
An unqualified verification conclusion may be issued despite
immaterial quantitative discrepancies that do not exceed the
materiality threshold in aggregate (calculated as both net and gross
overall discrepancy).
The tolerable error threshold per issue in either the baseline or
project condition will be graduated as follows for emission sources:
• 2% for emission sources greater than 50% of total baseline
or project emissions;
• 5% for emission sources between 20% and 50% of total
baseline or project emissions; and
• 10% for emission source less than 20% of total baseline or
project emissions.
All discrepancies will be described in the Verification Report.
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Preliminary Verification
Schedule
Verification Kickoff Meeting: January 23, 2017
Draft Verification Plan: February 10, 2017
Site Visit: February 10, 2017
Draft Verification Report : February 28, 2017
Final Verification Report March 1, 2017
Findings from Previous Verifications
There was one qualitative misstatement from the previous verification report, as follows.
The emission factor used for quantification of emissions associated with electricity consumption
in the project condition was changed in the 2015 GHG Assertion. The emission factor has been
changed from 0.88 to 0.64 tCO2e/MWh to reflect the Carbon Offset Emission Factors
Handbook dated March 4, 2015.
The change accounts for an increase of approximately 1,613 tCO2e, or 2% of the total
Assertion in comparison to emission quantified with the electricity emission factor used in
previous reporting periods. Due to the ambiguity of the direction provided in the Memorandum,
this has been qualified as a qualitative misstatement. Emission factor reference sources for all
other parameters are consistent with the Offset Project Plan. No other emission factor reference
sources were updated to reflect the Carbon Offset Emission Factors Handbook.
Source: AltaGas Bantry Acid Gas Injection Project Verification Report, March 1, 2016
Verification Team
Aaron Schroeder, P.Eng., will be the Lead Verifier and Designated Signing Authority for this verification.
His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject
matter areas defined in the ISO 14064-3.
Will Grundling, MSc. will provide analytical support to the verification team through the completion of
the verification procedures and the development of the Verification Report. His verification experience
includes event inventories, Alberta’s SGER compliances, Ontario GHG Reporting Regulation
verifications, and Fed Cattle Aggregation and Vent Gas and Instrument Air offset projects.
Nathan Muegge, P.Eng., will conduct an independent peer review of the verification. Mr. Muegge has
completed over 30 greenhouse gas verifications of annual SGER compliance reports as Lead Verifier or
Technical Expert, including reports for several natural gas processing facilities.
Additional information regarding the qualifications of the verification team will be provided in a
Statement of Qualifications, which will be appended to the Statement of Verification.
Site Safety Requirements
Personnel conducting site visits are required to wear personal protective equipment including steel-toed
boots, Nomex coveralls, hard hat, safety glasses with side shields and gloves. A site orientation must
be completed before entering the site.
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Verification Risk Assessment and Verification Procedures
The Verification Risk Assessment was completed prior to issuing the draft version of this document.
Verification procedures were developed to reduce the overall verification risk to facilitate the objectives
of the verification. Each inherent and control risk is provided with the risk evaluation (high/medium/low).
The risk evaluation considers both the magnitude of the activity data or inventory component on the
overall GHG assertion as well as the probability that the risk will result in a discrepancy, as assessed by
the verifier.
In instances where a substantive approach is applied in the verification procedure (i.e. the procedure
tests the data, rather than the Responsible Party’s controls), the Responsible Party’s control is not
listed, but is denoted “N/A”; however, this does not imply that the Responsible Party does not have a
control in place.
Verification risk is defined as the risk of an incorrect verification conclusion. It can be calculated as the
product of the Project’s inherent risks, the Responsible Party’s control risks and the Verifier’s detection
risks. The verifier cannot affect the inherent risk or the control risk. Therefore, to reduce the overall
verification risk and reach the agreed level of assurance (defined in the verification scope), the verifier
must design verification procedures that reduce the detection risk.
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Table 5: Verification Risk Assessment Summary
Activity Data /
Inventory Component
Inherent Risk Control Risk Detection
Risk Design
Description of Verification Procedure
PROTOCOL APPLICABILITY REQUIREMENTS
1. The project results
from emissions that
otherwise would have
been released to the
atmosphere.
Relevance (high)
Baseline scenario may
not meet eligibility
requirements.
N/A (controls not
considered for
verification)
Low Substantive test: Review project schematics
and interview facility operators to determine if
baseline scenario described in the Offset
Project Plan is applicable.
2. Where capture and
injection operations are
separate, emissions at
the source are reported
separately.
N/A – this requirement does not apply to this project because the capture facility is not regulated under SGER.
3. The acid gas injection
scheme has obtained
approval from the
Alberta Energy Regulator
under Directive 051.
Relevance (low)
The operation may not
have approval to operate
under Directive 051.
N/A (controls not
considered for
verification)
Low Substantive test: Review the operation’s
approval to operate an AGI scheme under
Directive 051.
4. Metering of injected
gas volumes occurs as
near as possible to
injection well.
Accuracy (medium)
Metering may occur
upstream of the injection
well, which would not
account for fugitive or
venting emissions
downstream of the
meter.
N/A (controls not
considered for
verification)
Low Substantive test: Interview site operators and
metering diagram during site visit regarding
the location of the injection meter.
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Activity Data /
Inventory Component
Inherent Risk Control Risk Detection
Risk Design
Description of Verification Procedure
5. The acid gas injection
project must occur at a
facility that commenced
commercial operations
prior to July 1, 2007.
Relevance (high)
The facility may not be
eligible to create offsets if
commercial operations
began after July 1, 2007.
N/A (controls not
considered for
verification)
Low Substantive test: Confirm that commercial
operations began at the facility prior to July 1,
2007 by interviewing plant operators during
the site visit.
6. Consolidation of
multiple gas streams at
the capture facility
should have sufficient
transparency in the data
to attribute emissions to
each originating facility.
Transparency (medium)
Emissions data should
have sufficient
transparency to evaluate
eligibility of the project by
tracing data back to
each originating facility.
N/A (controls not
considered for
verification)
Low Substantive test: Review reported GHG
information to trace emissions data back to
each source of inlet gas at the capture facility.
Substantive test: interview site operators
during site visit to determine if inlet gas
originates from facilities that are regulated
under SGER.
7. The emission
reduction quantification
is based on actual
measurements.
Accuracy (medium)
Estimates may be used
in place of
measurements in the
emission reduction
quantification.
N/A (controls not
considered for
verification)
Low Substantive test: Review source of
quantitative data used in the emission
reduction quantification and compare to
protocol requirements for measurement type
and frequency.
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Activity Data /
Inventory Component
Inherent Risk Control Risk Detection
Risk Design
Description of Verification Procedure
8. The project must
meet the eligibility criteria
stated in section 7 of the
Specified Gas Emitters
Regulation (these are the
requirements of the
Alberta Offset System)
Relevance (high)
Responsible Party may
not be able to
demonstrate that the
offset projects meets the
requirements of the
Alberta Offset System.
N/A (controls not
considered for
verification)
Low Substantive test: Review the evidence
provided by the Responsible Party related to
the requirements of the Alberta Offset
System.
PROTOCOL FLEXIBLITY
Project developers may
use an alternate sulphur
recovery process, but
must justify the method
for calculating baseline
emissions from this
alternate technology.
Relevance (high)
The method for
calculating the baseline
may not be meet the
protocol requirements.
N/A (controls not
considered for
verification)
Low Substantive test: Review the justification for
the baseline calculation method for the
baseline technology and compare to protocol
requirements.
QUANTIFICATION DATA
Sulphur recovery unit –
estimated monthly run
time, tail gas
composition, tail gas
volume
Accuracy (high)
Modeled values may not
represent site operations
or may not be accurately
applied to emission
reduction quantification.
N/A (controls not
considered for
verification)
Low Substantive test: Analyze SULSIM model
inputs, comparing input values to plant
operational values.
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Activity Data /
Inventory Component
Inherent Risk Control Risk Detection
Risk Design
Description of Verification Procedure
Substantive test: Assess accuracy of
transcription of SULSIM model results to
quantities applied in emission reduction
quantification.
Gas volumes – acid gas
injection, flare, flare fuel
Accuracy (high)
Metered quantity may be
inaccurate.
Responsible party
conducts periodic meter
calibration.
Meter calibration may be
incomplete or
undocumented (low risk).
Low Controls test: Review meter calibration
documentation for each meter used in
emission reduction quantification.
Gas compositions –
plant fuel gas, acid gas
Accuracy (high)
Gas composition analysis
received from
independent labs may
contain invalid results or
be incorrectly
transcribed.
N/A (controls not
considered for
verification)
Low Substantive test: Review gas composition
reports for invalid results and compare
transcription of results into the emission
reduction quantification.
AGI injection compressor
electricity consumption
Accuracy (medium)
Electrical consumption
quantities may be
incorrectly transcribed
from third party report.
N/A (controls not
considered for
verification)
Low Substantive test: Compare transcription of
electricity consumption data into the emission
reduction quantification.
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Activity Data /
Inventory Component
Inherent Risk Control Risk Detection
Risk Design
Description of Verification Procedure
AGI injection auxiliary
equipment electricity
consumption
Completeness (low)
Equipment inventory may
be incomplete.
N/A (controls not
considered for
verification)
Medium Substantive test: Observe AGI auxiliary
equipment during site visit and compare to
equipment inventory in the Offset Project
Plan.
Accuracy (low)
Assumed values for
estimating equipment
electricity consumption
may be inappropriate.
N/A (controls not
considered for
verification)
High Substantive test: Analyze equipment
nameplate ratings and runtime assumptions
for appropriateness.
Heaters – power rating,
number in service,
operating hours
Accuracy (low)
Assumed values for
estimating equipment
electricity or natural gas
consumption may be
inappropriate.
N/A (controls not
considered for
verification)
High Substantive test: Analyze equipment
nameplate ratings and runtime assumptions
for appropriateness.
Emission factors –
natural gas combustion,
natural gas extraction
and processing, Alberta
electricity consumption
grid factor
Accuracy (high)
Emission factors may not
have been accurately
transcribed into the
emission reduction
quantification
N/A (controls not
considered for
verification).
Low Substantive test: Compare transcription of
emission factors into the emission reduction
quantification.
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Activity Data /
Inventory Component
Inherent Risk Control Risk Detection
Risk Design
Description of Verification Procedure
EMISSION REDUCTION QUANTIFICATION AND REPORT
Application of the
approved quantification
protocol
Accuracy (high)
The project developer
may not have
implemented approved
quantification
methodologies or applied
additional
methodologies.
Responsible Party has
developed an Offset
Project Plan that is
intended to conform to
the requirements of the
approved quantification
protocol.
The protocol
requirements may not
have been implemented
correctly (medium)
Low Substantive test: compare the methodologies
described in the Responsible Party’s Offset
Project Plan to the methodologies described
in the approved quantification protocol.
Substantive test: Recalculate the emission
reduction using original metered data.
Quantification of
emission reduction
Accuracy (high)
Emission reduction
calculation may contain
arithmetic errors.
N/A (controls not
considered for
verification)
Low Substantive test: Recalculate the emission
reduction using original metered data.
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Activity Data /
Inventory Component
Inherent Risk Control Risk Detection
Risk Design
Description of Verification Procedure
Transcription of final
emission reduction into
Offset Project Report
Accuracy (high)
Final emission reduction
may not have been
transcribed accurately
from calculation
spreadsheets into the
Offset Project Report.
N/A (controls not
considered for
verification)
Low Substantive test: compare the final emission
reduction quantity reported by the
Responsible Party to the quantity reported in
the Offset Project Report. Also, compare
these quantities to the recalculated quantity in
previous verification procedures.
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Sampling Plan
The verification procedures that could apply sampling of the project data are listed in the following table.
The sampling size, the sampling methodology and their respective justifications are also described in the following table.
Table 6: Sampling Plan
Activity Data /
Inventory
Component
Detection
Risk
Design
Description of Verification
Procedure
Sampling Methodology and
Justification
Sample Size
Sampling was not used for any of the verification procedures in this verification.