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V ERIFICATION R EPORT YARA U USIKAUPUNKI T2 N2O ABATEMENT PROJECT IN F INLAND (ITL

VERIFICATION REPORT

YARA UUSIKAUPUNKI T2 N2O ABATEMENT PROJECT IN FINLAND

(ITL Project ID: FI1000179)

Verification Period:

14 June 2009 to 31 May 2010

REPORT NO. 2011-0058

REVISION NO. 01

DET NORSKE VERITAS

DET NORSKE VERITAS

VERIFICATION REPORT

D ET N ORSKE V ERITAS V ERIFICATION R EPORT Date of first i ssue:  

Date of first issue:

 

Project No.:

DET NORSKE VERITAS CERTIFICATION AS

05

July 2010

PRJC-240804-2010-CCS-NOR

Recommended for approval

Approved by

Organisational unit:

Veritasveien 1,

Ole A. Flagstad

Ole A. Flagstad

Climate Change and Evnironmental Services

1322 HØVIK, Norway

Tel:

Fax: +47 67 57 99 11 http://www.dnv.com Org. No: NO 945 748 931 MVA

+47 67 57 99 00

Client:

Client ref.:

YARA Suomi Oy

 

Taisto Koivumäki

Summary:

 

Det Norske Veritas Certification AS (DNV) has performed the verification of the emission reductions reported for the “YARA Uusikaupunki T2 N2O abatement project in Finland” (ITL Project ID FI1000179, JI track 1) for the period 14 June 2009 to 31 May 2010.

In our opinion, the GHG emission reductions reported for the project in the monitoring report No. 01 (Version 02)) of 02 September 2010 are fairly stated. The monitoring report (MR) was updated to version 2 in response to clarification requests raised by DNV during verification.

The GHG emission reductions were calculated correctly on the basis of the approved CDM monitoring methodology AM0034 / version 3.4 (with some deviations as described in detail in section 3.3 of this report), AM0028 / version 4.2 (for monitoring of project emissions) and the monitoring plan contained in the Project Design Document of 07 April 2010.

Det Norske Veritas Certification AS is able to verify that the emission reductions from the “YARA Uusikaupunki T2 N2O abatement project in Finland” during the period 14 June 2009 to 31 May 2010 amount to 75 851 tonnes of CO 2 equivalent.

Report No.:

 

Subject Group:

 

2011-0058

Environment

 

Indexing terms

Report title:

 

Key words

Service Area

YARA Uusikaupunki T2 N2O abatement project in Finland

Climate Change Kyoto Protocol Validation Clean Development Mechanism

Verification

Market Sector

Process Industry

Work carried out by:

   

Rafi-ud-Din Khawaja, Trine Kopperud

No distribution without permission from the client or responsib le organisational unit the client or responsible organisational unit

Work verified by:

 

free distribution within DNV after 3 yearsWork ver ified by:  

Weidong Yang

Strictly confidentialWeidong Yang

 

Unrestricted distribution 

Date of this revision:

Rev. No.:

Number of pages:

13

January 2011

01

21

 

© 2002 Det Norske Veritas AS All rights reserved. This publication or parts thereof may not be reproduced or transmitted in any form or by any means, including photocopying or recording, without the prior written consent of Det Norske Veritas AS.

Head Office: Veritasvn. 1, N-1322 HØVIK, Norway

JI Verification Report Template, version 03, 2010-06-14

DET NORSKE VERITAS

Report No: 2011-0058, rev. 01

VERIFICATION REPORT

Table of Content

2011-0058, rev. 01 V ERIFICATION R EPORT Table of Content Page 1 INTRODUCTION 1 1.1 Objective

Page

1

INTRODUCTION

1

1.1

Objective

1

1.2

Scope

1

1.3

Description of the Project Activity

1

1.4

Methodology for Determining Emission Reductions

2

2

METHODOLOGY

3

2.1

Review of Documentation

4

2.2

Site Visits

5

2.2.1

Audit Programme

5

2.3

Assessment

7

2.4

Reporting of Findings

7

3

VERIFICATION FINDINGS

8

3.1

Remaining Issues, CARs, FARs from Previous Validation or Verification

8

3.2

Project Implementation

8

3.2.1

Project Implementation in accordance with the registered project design document

9

3.3

Completeness of Monitoring

9

3.4

Accuracy of Emission Reduction Calculations

11

3.5

Quality of Evidence to Determine Emission Reductions

12

3.6

Assessment of Monitoring Parameters

12

3.6.1

Historical data and permitted operating conditions

12

3.6.2

Determination of baseline emissions

12

3.6.3

Monitored data for project emissions within the project boundary

13

3.7

Management System and Quality Assurance

18

4

VERIFICATION STATEMENT

19

5

REFERENCES

20

Appendix A

Corrective action requests, clarification requests and forward action requests

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Abbreviations

AOR

AAU

CAR

CDM

CL

CO

CO 2 e

DFP

DNV

ERU

FAR

GHG

IPCC

JI

JISC

LoA

N 2 O

PDD

tCO 2 e

UNFCCC United Nations Framework Convention on Climate Change

Ammonia Oxidation Reactor Assigned Amount Unit Corrective Action Request Clean Development Mechanism Clarification request Carbon dioxide Carbon dioxide equivalent Designated Focal Point Det Norske Veritas Emission reduction units Forward Action Request Greenhouse gas(es) Intergovernmental Panel on Climate Change Joint Implementation Joint Implementation Supervisory Committee Letter of approval Nitrous oxide Project Design Document Tonnes of CO 2 equivalents

2

GWP Global Warming Potential

of approval Nitrous oxide Project Design Document Tonnes of CO 2 equivalents 2 GWP Global Warming

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1

INTRODUCTION

No: 2011-0058, rev. 01 V ERIFICATION R EPORT 1 INTRODUCTION YARA Suomi Oy has commissioned Det

YARA Suomi Oy has commissioned Det Norske Veritas Certification AS (DNV) to carry out the verification of the emission reductions reported for the “YARA Uusikaupunki T2 N2O abatement project in Finland” (the project) in the period 14 June 2009 to 31 May 2010. This report contains the findings from the verification and a verification statement for the certified emission reductions.

1.1 Objective

Verification is the periodic independent review and ex-post determination by an Accredited Independent Entity (AIE) of the monitored reductions in GHG emissions that have occurred as a result of a Joint Implementation (JI) track 1 project activity during a defined verification period.

The objective of this verification was to verify the emission reductions reported for the YARA Uusikaupunki T2 N2O abatement project in Finland” for the period 14 June 2009 to 31 May 2010. DNV is an Independent Entity accredited by the Joint Implementation Supervisory Committee (JISC) for all sectoral scopes.

1.2 Scope

The scope of the verification is:

To verify that actual monitoring systems and procedures are in compliance with the monitoring systems and procedures described in the monitoring plan.

To evaluate the GHG emission reduction data and express a conclusion with a reasonable level of assurance about whether the reported GHG emission reduction data is free from material misstatement.

To verify that reported GHG emission data is sufficiently supported by evidence.

The verification shall ensure that reported emission reductions are complete and accurate in order to be certified.

1.3 Description of the Project Activity

Project Parties: Finland (host) and France (investor country)

Title of project activity:

YARA

Uusikaupunki

T2

N2O

abatement

project

in

Finland

ITL Project ID: FI1000179 (track 1)

CDM baseline and monitoring methodology AM0034/ version 3.4 (with some deviations as described in section 3.3 of this report), AM0028/version 4.2 (for monitoring of project emissions) Project participants Yara Suomi, Kemphos Oy

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT Mechelininkatu 1a, Helsinki FI-00181, Finland YARA

Mechelininkatu 1a, Helsinki FI-00181, Finland

YARA International ASA, Oslo (Norway)

Bygdoy allé 2, Oslo 0257, Norway

N.serve Environmental Services GmbH (Germany)

Große Theaterstr. 14, 4. OG, Hamburg 20354, Germany

Location of the project activity: Uusikaupunki, Finland (Line T2)

Project’s crediting period: 01 June 2009 to 31 December 2012

Period verified in this verification: 14 June 2009 to 31 May 2010 The project activity involves the installation of a secondary N 2 O abatement catalyst (YARA 58 Y 1® catalyst), inside the ammonia oxidation reactor (burner) just beneath the precious metal catalyst gauze catalyst at YARA’s nitric acid plant at Uusikaupunki, Finland (Line T2). The De-N 2 O catalyst is selective and promotes the decomposition of N 2 O to nitrogen and oxygen. The expected average abatement performance of the secondary N 2 O abatement catalyst is around 85% (the emission reduction estimates in the PDD were made using abatement performance of 85%). The project activity started with full batch of catalyst installed (both primary and secondary) on 14 June 2009. The first monitoring period hence comprises of the first project campaign and is from 14 June 2009 to 31 May 2010.

The emission reductions reported form the project for the period from 14 June 2009 to 31 May 2010 amount to 75 851 tonnes of CO 2 equivalents.

1.4 Methodology for Determining Emission Reductions

The emission reductions based on which ERUs will be issued for the project activity are determined by deducting the project-specific emission factor from the Benchmark Emission Factor and multiplying the result by the production output of 100% concentrated nitric acid over the period for which ERUs are claimed and the GWP of N 2 O, as follows:

ERU = (EF BM - EF n )/1000 x NAP x GWP N2O

(tCO 2 e)

Where:

ERU = emission reductions awardable to the project for the verification period (tCO 2 e) NAP = nitric acid production (100% concentrated) during the verification period (tHNO 3 ). EF BM = benchmark emission factor according to host country approval (kgN 2 O/tHNO 3 )* EF n = project emission factor for the defined verification period “n” (kgN2O/tHNO 3 ). GWP N2O = 310 tCO 2 e/tN 2 O *The applicable benchmark emission factors for N2O abatement projects in Finnish nitric acid plants were decided by the Designated Focal Point (DFP) of Finland on 07 April 2010 (as provided in the PDD) /2/ and are to be applied as follows:

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT 2009 2010 2011 2012 2.5 2.5

2009

2010

2011

2012

2.5

2.5

2.5

1.85

kg N 2 O/ t HNO 3

kg N 2 O/ t HNO 3

kg N 2 O/ t HNO 3

kg N 2 O/ t HNO 3

0.0025

0.0025

0.0025

0.00185

t N 2 O/ t HNO 3

t N 2 O/ t HNO 3

t N 2 O/ t HNO 3

t N 2 O/ t HNO 3

Thus, the scope of this verification includes verifying the project emission factor (EF n ) and the amount of nitric acid produced (of 100% concentrated) for the verification period from 14 June 2009 to 31 May 2010.

The total mass of N 2 O emissions in a verification period (PE n ) is calculated based on the

continuous measurement of the N 2 O concentration in the tail gas and the volume flow rate of the tail gas stream. The N 2 O mass-flow is calculated on the basis of the hourly average

results, in accordance with the following equation:

PE n =

x=vmp

NCSG x x VSG x x 10 -9 x M x

x=1

(tN 2 O)

The plant-specific project emission factor representing the average N 2 O emissions per tonne of nitric acid over the respective verification period is derived by dividing the total mass of N 2 O emissions by the total output of 100% concentrated nitric acid for that period. The average N 2 O emissions per metric ton of 100% concentrated nitric acid for the verification period (EFn) is calculated as follows:

EF n = (PE n / NAP n )

(tN 2 O/tHNO 3 )

Where:

PE

EF

n (tN 2 O/tHNO 3 ) NCSG x Hourly average concentration of N 2 O in the tail gas stream in each measurement time interval of 1 hour during the verification measurement period (vmp) (mgN 2 O/m 3 )

VSG x Hourly average tail gas volume flow rate in each measurement time interval of 1 hour

Total N 2 O emissions during the verification period (tN 2 O) Emissions factor used to calculate the emissions from the defined Verification Period

n

n

during

the verification measurement period (vmp) (m 3 /h)

NAP n

Nitric acid production during the Verification Period (tHNO 3 )

M x

Length of measurement interval x (hour)

x

Each measurement interval during the verification period (1 hour)

vmp

Verification measurement period

2

METHODOLOGY

The verification of the emission reductions has assessed all factors and issues that constitute the basis for emission reductions from the project. As the JI Supervisory Committee (JISC) has not yet formally endorsed the application of any materiality principle for verification of emission reductions from JI projects - implying that emphasis should be on the significant contributors to emission reductions - DNV has checked all factors and issues with the same emphasis.

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT Despite this, DNV has during its

Despite this, DNV has during its preparations identified the key reporting risks and used the assessment to determine to which extent the project operator’s control systems were adequate for mitigation of these key reporting risks. In addition, other areas that can have an impact on reported emission reductions have also undergone detailed audit testing. All relevant records of data from the automated measuring system for N 2 O (FTIR Gasmet CEMS model DX4000 Analyzer, the new Dr. Födisch MCA 04 Analyzer, and the Dr. Födisch FMD 99 Volume Flow Meter) and records from the production logs (from the Coriolis flow meter for flow and concentration measurements of the nitric acid production) have been examined and verified for the reporting period.

The JI project verification team members and the type of involvement for each team member are given in the following table:

Verification team

       

Type of involvement

 

Role

Last Name

First Name

Country

Administrative

Desk review

Site visit / Interviews

Reporting

Technical review

Expert input

Project manager

Khawaja

Rafi-ud-Din

Norway

         

Technical team leader (JI verifier)

Khawaja

Rafi-ud-Din

Norway

 

   

Sector expert

Kopperud

Trine

Norway

 

 

 

Technical reviewer

Yang

Weidong

USA

       

Duration of verification Preparations:

On-site verification:

Reporting, calculation checks and QA/QC: From 05 July 2010 to 13 January 2011

From 13 June 2010 to 30 June 2010

01and 02 July 2010

2.1 Review of Documentation

The basis for the verification has been the monitoring report No. 01, version 1 dated 17 June 2010, and the updated monitoring report No. 01, version 2 dated 02 September 2010 /1/, the project design document (PDD) /2/, the approved baseline and monitoring methodology AM0034 version 3.4 (with some deviations) /6/, the approved baseline and monitoring methodology AM0028 version 4.2 (for monitoring of project emissions) /7/, and the determination report of 08 April 2010 by TÜV SÜD Industrie Service GmbH /8/. The project operator has in addition supplied the verification team with procedures from its management system as well as other documentation and spreadsheets with all data necessary for verification of the emission reductions /3/ and /11/-/23/.

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT 2.2 Site Visits Detailed verification of

2.2 Site Visits

Detailed verification of all data contained in the monitoring report was performed during a site visit at Uusikaupunki, Finland on 01 and 02 July 2010. The on-site assessment involved:

(i)

Assessment of the implementation and operation of the JI project activity as per the registered PDD;

(ii)

Review

of

information

flows

for

generating,

aggregating

and

reporting

the

monitoring parameters;

 

(iii)

Interviews with relevant personnel to confirm that the operational and data collection procedures are implemented in accordance with the monitoring plan in the PDD;

(iv)

A cross-check between information provided in the monitoring report and data from other sources such as plant log books, inventories, purchase records or similar data sources;

(v)

A check of the monitoring equipments including calibrations performances and observations of monitoring practices against the requirements of the PDD and the selected methodology;

(vi)

Review of calculations and assumptions made in determining the GHG data and emission reductions;

(vii)

Identification of quality control and quality assurance procedures in place to prevent or identify and correct any errors or omissions in the reported monitoring parameters.

During the site visit, the following personnel were interviewed /24/ - /27/:

Name Tommi Hevonoja

Timo Stranius

Martin Stilkenbäumer

Volker Schmidt

Organization Position

YARA Suomi Oy

Production Manager/Local Project Manager for JI Project

Environmental Engineer

Monitoring /Verification Expert

YARA Suomi Oy

N.Serve

Services GmbH

N.Serve

Services GmbH

Environmental

Environmental

Monitoring /Verification Expert

2.2.1 Audit Programme

The following audit program was followed during the on-site audit of 01 and 02 July 2010:

Day 1: 01 July 2010

08.00 - 08.30 Opening Meeting

Introduction of auditor and representatives from the Plant and N.Serve

Schedule for the audit

The objective of the verification

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Introduction of Verification Process (DNV)

R EPORT Introduction of Verificat ion Process (DNV) 08.30 - 09.00 Project Implementation and Determination

08.30

- 09.00 Project Implementation and Determination

Follow up of previous findings from the determination report, LoAs, emissions prior to project implementation, benchmark EF and corresponding regulation etc.

Information on focus areas of the audit

09.00

– 12:30 Detailed checking of daily monitoring records and calculation spreadsheet

AOR data and transfer to excel sheets

-

Operating conditions and special events

Automated Monitoring System (AMS), data and information flow

- Hourly average values for NCSG and VSG and 5-second interval measurements

- Implementation of corrected values during down times

Nitric acid production logs and transfer to excel;

- Flow and Concentration of HNO3

- Plausibility checks of HNO3 production, shift and lab values (visit to laboratory)

Emissions reductions achieved compared to estimated in PDD

12.30

- 13.30 Lunch

13:30 - 15.30 Site Inspections, Monitoring Equipments & Data Collections, Storage, and Transfer

Interviews with JI Project Responsible personnel, operators and lab Personnel

Plant investigation

Detail checking of the Process control System and Automated Monitoring System (AMS)

Detail checking of 5 sec data and daily monitoring records and calculation

Transfer of data between various systems

Checking the monitoring management system

15:30 - 16.30 Follow-up of remaining issues for the day

16:30 – 17:00 Close-out meeting and presentation of findings

Day 2: 02 July 2010

08.30 – 10:30 Measurement system and their calibration

AOR instruments and their calibrations

Automated Monitoring System (AMS), N2O Analyzer, flow meter, and transmitters

QAL1, QAL2, AST and QAL3 reports

Calibration procedures

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Coriolis flow meter, calibrations

10.30 - 11.30

Checking documents:

flow meter, calibrations 10.30 - 11.30 Checking documents: Invoices catalyst; Maintenance reports; Procedures developed

Invoices catalyst;

Maintenance reports;

Procedures developed for the operation of the project

11:30 – 12:00 Follow-up of remaining issues for day 2

12:00 - 12:30 Close-out meeting and presentation of findings

2.3 Assessment

The data presented in the monitoring report was assessed by review of the detailed project documentation and production records, as well as by interviews with personnel at YARA Suomi Oy and N.Serve Environmental Services GmbH, by observation of established monitoring and reporting practices and by assessment of the reliability of the installed monitoring equipment. This has enabled the verification team to assess the accuracy and completeness of the reported monitoring results and to verify the correct application of the approved monitoring methodology AM0034 version 3.4 (with some deviations) and the determination of the reductions in N 2 O emissions.

2.4 Reporting of Findings

A corrective action request (CAR) is issued, where:

i. Non-conformities with the monitoring plan or methodology are found in monitoring and reporting, or if the evidence provided to prove conformity is insufficient;

ii. Mistakes have been made in applying assumptions, data or calculations of emission reductions which will impair the estimate of emission reductions;

iii. Issues identified in a FAR during validation to be verified during verification have not been resolved by the project participants.

A clarification request (CL) shall be raised if information is insufficient or not clear enough to

determine whether the applicable JI requirements have been met.

A forward action request (FAR) is issued for actions if the monitoring and reporting require

attention and/or adjustment for the next verification period.

The verification raised ten CLs and one FAR. The project participants adequately addressed the CLs raised and provided an updated monitoring report No. 01 (version 2 of 02 September 2010) /1/ and spreadsheets (version 2 of 02 September 2010) /3/. The adequateness of the actions undertaken to address the FAR will be assessed during the next verification.

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT 3 VERIFICATION FINDINGS This section summarises

3 VERIFICATION FINDINGS

This section summarises the findings from the verification of the emission reductions reported for the “YARA Uusikaupunki T2 N2O abatement project in Finland” for the period 14 June

2009 to 31 May 2010.

3.1 Remaining Issues, CARs, FARs from Previous Validation or

Verification

This is the first verification. There is only one remaining forward action request (FAR) raised during determination by the determination entity, TÜV SÜD Industrie Service GmbH, as follows:

FAR 1: It is necessary to present a LoA from the host Country and if applicable from

the investor country during first verification. The LoA from focal point of the host country Finland dated 23 June 2010 /9/ has been provided to DNV. Furthermore, the LoA from focal point of the investor country France dated 30 September 2010 /10/ has been provided. Therefore, this FAR from the determination report is closed.

3.2 Project Implementation

The project activity involves the installation of secondary N 2 O abatement catalyst technology (YARA 58 Y 1® catalyst system consisting of an additional base metal catalyst) inside the ammonia oxidation reactor, underneath the precious metal gauzes at YARA’s nitric acid plant at Uusikaupunki, Finland (for Line T2). DNV has reviewed the catalyst invoice of 23 April

2009 and its certificate of analysis of 08 May 2009 to confirm the delivery of YARA 58 Y 1®

catalyst to YARA Uusikaupunki T2 plant /11/. The full batch of catalyst (primary as well as secondary) was installed on 14 June 2009 during a shut down. It was expected that this catalyst would reduce approximately 85% of the N 2 O emissions on average over its lifetime. The observed efficiency during the project campaign after the installation of secondary N 2 O abatement catalyst was approximately 90% (refer to CL 10).

The nitric acid plant was designed by Uhde and the commercial nitric acid production started in 1981. The plant is a 6.5 bar medium/high pressure plant with an annual design production output of 193 200 tonnes of HNO3 (100% conc.). Depending on whether or not the plant is shut down for maintenance purposes or exchange of the primary catalyst gauze, YARA Uusikaupunki (for Line T2) runs the plant operation around 350 days per year.

For the purpose of monitoring the actual N2O emissions after installation of the abatement technology, YARA Uusikaupunki at Line T2 has installed and operates an Automated Monitoring System (AMS) according to EU standards (EN14181) /12/.

On-site training for operation, maintenance and calibration of the N 2 O analyzer was provided by the equipment supplier /18/. The effectiveness of training was checked by interviewing the key operators and observing the operations and further checked by reviewing personal training logs /24/ - /27/. The QAL3 procedure including periodical testing for zero point and span has been performed /19/. The JI related procedures, which include monitoring, recording and reporting, are being developed by YARA Suomi Oy in collaboration with N.Serve

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT Environmental Services GmbH (FAR 1). The

Environmental Services GmbH (FAR 1). The project has been implemented as per the procedures and requirements as stated in the PDD, version 5 of 07 April 2010 /2/.

3.2.1 Project Implementation in accordance with the registered project design

document

The project is fully implemented according to the description in the registered PDD. The verification team confirmed, through visual inspection that all physical features of the proposed JI project activity including data collection systems and storage have been implemented in accordance with the registered PDD. The project is completely operational which was confirmed by means of the on-site visit.

The monitoring plan was confirmed to be in accordance with the approved methodology AM0034 version 3.4 (with some deviations as described in this report) /6/, the approved baseline and monitoring methodology AM0028/version 4.2 (for monitoring of project emissions) /7/. It should be noted that deviations from AM0034 were already included in the PDD and thus this does not represent deviation from the monitoring plan in the PDD of 07 April 2010, these are described in the following section.

All parameters stated in the validated monitoring plan are monitored and reported appropriately. The monitoring methodologies and sustaining records are sufficient to enable verification of emission reductions.

The completeness of the monitoring was assessed through the confirmation of the following documents and records, and summarized in section 3.3 of this verification report.

3.3 Completeness of Monitoring

The monitoring of the project is complete and in accordance with the approved monitoring methodology AM0034 version 3.4 (with some deviations as explained below) /6/, AM0028 / version 4.2 (for monitoring of project emissions) /7/, and the monitoring plan in the project design document of 07 April 2010 /2/. It should be noted that deviations from AM0034 were already included in the PDD and thus this does not represent deviation from the monitoring plan in the PDD of 07 April 2010.

The main deviation from AM0034 is that the baseline is not established through continuous monitoring of N 2 O concentration and gas flow volume in the stack of the nitric acid plant for one complete campaign prior to project implementation. Further, permitted operating conditions are not determined from data gathered for at least the last five complete campaigns. Rather, the project uses a benchmark value for calculating the emission reductions for which ERUs are awarded. The project proponents will only receive ERUs as far as the project activity achieves emission levels below that benchmark value. All emission reductions achieved from the business-as-usual emission level down to the benchmark value result in freed assigned amount units (AAUs), which count towards the Finnish Kyoto target. If ERUs were issued for these, the equivalent amount of AAUs would have to be cancelled. The concept of a benchmark value is outlined in detail in section A.5 of the PDD /2/.

For the purpose of monitoring the actual N2O emissions after installation of the abatement technology, YARA Uusikaupunki has installed and operates an Automated Monitoring System (AMS) according to EU standards (EN14181) /12/. The sampling is carried out continuously using a multiple-point sampling tube optimized to the specific width and height

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT of the tail gas duct, and

of the tail gas duct, and the expected gas velocities in the tail gas. Temperature and pressure in the tail gas are measured continuously for calculation of the gas volume flow at standard conditions. The same has been confirmed by DNV during the on site visit of 01 and 02 July

2010.

From 14 June 2009 to 13 August 2009 a FTIR Gasmet CEMS model DX4000 Analyzer was installed as part of the AMS which was then replaced by the “new” Dr. Födisch MCA 04 Analyzer (installed 20 July 2009). At the same time (20 July 2009) the Dr. Födisch FMD 99 Volume Flow Meter was installed. It should be noted that both Dr. Födisch MCA 04 Analyzer and the Dr. Födisch FMD 99 Volume Flow Meter were taken into regular operation on 13 August 2009. Both N 2 O-Analyzers and the flow meter are QAL1 certified /13/ /14/ /15/ and have been tested and approved during the QAL2 performance test carried out in September 2009 /16/ /17/.

From project start until 13 August 2009, the stack gas volume flow was determined based on primary air measurements by application of correction factor. Primary Air data that was measured from 13 August 2009 to 11 October 2009 were compared with VSG (Stack gas velocity raw) values and a correction factor for the calculation was derived. This correction factor was applied to the primary air values measured for the period 14 June 2009 to 13 August 2009 in order to calculate VSG values for this period.

DNV has reviewed the calculations spreadsheets /20/ and the calculations were found to be correct and conservative; the source of the primary air data (from Honeywell PHD data acquisition and storage system as further explained below) was also confirmed during the site visit.

The Coriolis mass flow meter for measurement of Nitric Acid Production (NAP) at 100% concentration broke down on 18 August 2009. A Coriolis mass flow meter was fixed on 21 August 2009. Thus no NAP measurements were available for the period from 18 August 2009 to 21 August 2009. In this period the NAP values were determined based on Ammonia (NH 3 ) consumption figures by mass balance calculations. DNV has reviewed the calculations spreadsheets /3/ and the calculations were found to be correct and conservative; the source of data (from Honeywell PHD data acquisition and storage system as further explained below) was also confirmed during the site visit.

The YARA Uusikaupunki nitric acid plant is equipped with a Honeywell PHD data acquisition and storage system that collects and stores all the values for NCSG, VSG, TSG, PSG as well as different status signals of the AMS and, if applicable, a status signal from the nitric acid plants that defines whether or not the plant is in operation (the AOR temperature). The data is stored simultaneously on different hard disks to prevent the loss of data in case one hard disk fails. All main parameters stated in the monitoring plan are monitored and reported appropriately.

The monitoring values that are recorded and stored by Honeywell PHD data acquisition and storage system have been stated to be fully secured. The system provider has also confirmed the security of the data /21/ , see CL 2 as well.

During this verification, DNV had raised ten CLs and one FAR. All the CLs were addressed properly and DNV was provided with the revised monitoring report version 2 of 02 September 2010. However the FAR will be addressed and verified during the next

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VERIFICATION REPORT

ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT verification. The FAR does not have

verification. The FAR does not have any effect on the determination of the emissions reductions.

The monitoring methodologies and sustaining records were sufficient to enable verification of the reported emissions reductions.

3.4 Accuracy of Emission Reduction Calculations

The calculation of the emission reduction for the monitoring period was checked by the verification team and found to be correct. There is no uncertainty related to manual transfer of data used in the calculation of emission reduction since the YARA Uusikaupunki nitric acid plant is equipped with a Honeywell PHD data acquisition and storage system which records and stores all monitoring values for NCSG, VSG, TSG, PSG as well as status signals of the AMS. Data directly related to plant operation, such as oxidation temperature, oxidation pressure, ammonia flow rate, ammonia to air ratio and nitric acid production rate, is stored in the same data logging system.

There were no errors in the transfer of data from the Honeywell PHD data files to the excel spreadsheet for the calculation of emissions reductions. This was verified by comparing the values stored in the Honeywell PHD data storage system with the values reported in the spreadsheet during the on-site visit of 01 and 02 July 2010. The ERU calculation spreadsheet also includes the 5 second raw data /3/; however the emission reductions have been calculated based on hourly corrected data as per the PDD /2/.

As per the requirements of the PDD /2/, in the case of AMS downtime for any part of one hour, the hourly average value is calculated pro-rata from the remaining available data for the hour in question. If the remaining available data for that hour constitutes less than 2/3 of the hour (less than 40 minutes), that hour is considered missing and substitute values are applied.

As per the requirements of the PDD, in the case of AMS downtime that constitutes of malfunction of the AMS leading to application of substitute values, missing data for the relevant hours is replaced with either a) the highest value measured during the whole of the relevant verification period or b) the highest value measured during the whole of the previous complete production campaign, whichever is the higher. Determination of these highest values is based on measurements during periods of standard AMS operation and recording after elimination of mavericks, applicable to hourly average values.

In the case of equipment downtime due to routine calibration, measurement values for the relevant hours are substituted by the last valid measured hourly average values before the calibration or maintenance.

By review of the ERU calculation spreadsheet /3/, DNV confirms that the values during AMS downtime have been corrected as per the above requirements.

Any NCSG and VSG data sets recorded at times when the plant was shut down are automatically excluded from the calculation of EF n . The number of operating hours (OH n ) is reduced accordingly. It has been confirmed by DNV as well that the data sets containing values during shut down of the plant are not regarded as AMS downtimes.

DNV has also confirmed correct implementation of QAL 2 correction factors and correct volume flow normalization procedures (refer to CL 3 and CL 5 as in Appendix A of this verification report).

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT The emission reductions in this monitoring

The emission reductions in this monitoring period is 75 851 tonnes of CO 2 equivalents in the period from 14 June 2009 to 31 May 2010 (i.e. 355 days). The yearly expected emission reductions according to the registered PDD averaged over the period from 2009 to 2012 is 49 705 tonnes of CO 2 equivalents (or maximum 64 077 tonnes of CO 2 equivalents for years 2010 and 2011). This corresponds to emissions reductions of 51 105 tonnes of CO 2 equivalents (or 65 882 tonnes of CO 2 equivalents if considered maximum values for year 2010 and 2011) in 365 days; and hence the reported emission reduction is considerably higher than the expected. The higher than estimated emission reductions are attributed to better than expected abatement efficiency of the catalyst (refer to CL 10 for further details).

The primary catalyst was changed on 12 October 2009 and this monitoring period covers partially two project campaigns.

3.5 Quality of Evidence to Determine Emission Reductions

The main parameters are automatically collected by the Honeywell PHD data acquisition and storage system. All necessary documentation is collected, referenced and aggregated and is easily accessible in spreadsheets and by review of the stored data. Measurements are performed by calibrated equipment, and the key data can also be cross-checked via other sources, such as production log sheets and meters available in the operators control room or on-site. No assumptions are used that have any material influence on reported emission reductions. All actions performed at the computer station are logged and the log file is available for the verifier.

The Dr. Födisch MCA 04 analyzer needs to be calibrated regularly. The calibration (including zero and span checks) is conducted automatically on pre-defined time or could be triggered manually from the operating console.

All measuring and analytical instruments are calibrated as per the prescriptions in the registered PDD and as per the procedures used by the plant operators; the procedures are parts of the ISO 9001 Quality Management System.

3.6 Assessment of Monitoring Parameters

3.6.1 Historical data and permitted operating conditions

Since the project is using the benchmark emission factor approach this is not applicable.

3.6.2 Determination of baseline emissions

As per the requirements of AM0034, the baseline scenario relevant for the calculation of emission reductions eligible for issuance of ERUs is not determined based on measured emissions during the baseline campaign. Instead a set of specific benchmark values were implemented by the Finnish DFP (national Environmental Protection Department of the Finnish Ministry of the Environment) on 7 th April 2010 /22/ as to serve as the baseline emission factors for N 2 O abatement projects in Finnish nitric acid plants. The below table displays the applicable benchmark values serving as baseline emission factors for determination of ERU relevant emission reductions:

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Report No: 2011-0058, rev. 01

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT 2009 2010 2011 2012 2.5 kg

2009

2010

2011

2012

2.5 kg N 2 O/ t HNO 3

2.5 kg N 2 O/ t HNO 3

2.5 kg N 2 O/ t HNO 3

1.85 kg N 2 O/ t HNO 3

Table: Applicable JI project benchmark emissions factors for Finnish nitric acid plants

As per the PDD version 5 of 07 April 2010, Yara Uusikaupunki has been reporting calculated N 2 O emissions based on random spot checks to the local environmental authorities. Between 2004 and 2008, yearly N 2 O emissions ranged between 650 (min) and 2308 (max) tN 2 O. Based on the annual nitric acid production between 2004 and 2008, pre-project emissions factors have been calculated to range between 3.3 (min) and 11.6 (max) kgN 2 O/tHNO 3 . Hence the use of the benchmark emission factors as listed in the table above is conservative.

3.6.3 Monitored data for project emissions within the project boundary

The Project Emission Factor is assessed based on the N 2 O concentration (NCSG n ) and off-gas volume flow (VSG n ) measurements that are corrected based on QAL 2 correction factors and normalized measurements and is calculated as EF n based on NAP n value (refer to section 1.4 above).

As per section D.1.1 of the PDD/2/, the following data has been assessed in detail:

Data variable

Tag. No.

Reported value for the project period

Assessment /Observation

NCSG n Hourly average N 2 O concentration in the tail gas

Tag

No. for

Hourly average values (in mgN 2 O/Nm 3 ) have been used in PE n calculation (refer to section 1.4 of this verification report).

Data from Gasmet FTIR DX 4000 analyzer

Gasmet FTIR

was used from 14 June 2009 to 13 August

DX

4000

2009.

analyzer is not

available since the unit is off

Dr. Födisch MCA04 Analyzer was installed on 13 August 2009 and date from this analyzer has been used until the end of this monitoring period.

This parameter is continuously measured at a frequency of every 5 seconds as per the PDD.

 

line

now

ILO.T2-

QI9302.OU2

(Dr. Födisch)

 

The maximum reported value, NCSG max is =

Both Analyzers are in compliance with the requirements of EN14181 and have valid approval for QAL1 and QAL2 /13/ /15/ /16/

/17/.

312.04

mgN 2 O/Nm 3

The QAL 2 correction factor for the Gasmet FTIR DX 4000 Analyzer is 0.920. The QAL 2 correction factor for the Dr. Födisch MCA 04 Analyzer is 1.0009. DNV confirms correct implementation of these correction factors in the monitored values towards ERU calculations /3/.

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DET NORSKE VERITAS

Report No: 2011-0058, rev. 01

VERIFICATION REPORT

ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT       Calibrations are performed
     

Calibrations are performed regularly according to vendor’s specifications. QAL2, AST and QAL3 measures are applied according to EN14181 /19/.

VSG n Hourly average volume flow rate of the tail gas

ILO.T2-

Nm 3 /h

The VSG values from the start of the verification period until 13 August 2009 were calculated based on primary air measurements. The calculations and the sourced data have been checked by DNV (see section 3.3 for details).

This parameter was monitored by Dr. Födisch FMD 99 Volume Flow Meter from 13 August 2009 until the end of this verification period.

FI9400.MES

Hourly average values (in Nm 3 /h) have been used in PE n calculation (refer to section 1.4 of this verification report).

 

The maximum reported value, VSG max is = 89 650 Nm 3 /h

This parameter is continuously measured at a frequency of every 5 seconds as per the PDD.

The equipment is in compliance with the requirements of EN14181 has valid QAL1

 

and

QAL2 reports /15/ /17/. Volume flow

measurements are normalized by parallel

temperature and pressure measurements in

the

stack by parameters TSG (temp.) and

PSG. The normalization procedures have been checked and confirmed by DNV (see

CL

3).

The QAL 2 correction factor for the Dr. Födisch FMD 99 for stack gas flow is 0.994

/17/.

 

For

calculation of normalized stack gas flow,

the

QAL2 corrected input data for flow,

temperature and pressure are used and the calculations are done by the following

formula:

 

VSG =

Flow*273.15/(273.15+TSG)*PSG/1013.25

Where:

 

VSG:

Stack gas flow in standard conditions [Nm³/h]

Flow:

Stack gas flow in stack conditions

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Report No: 2011-0058, rev. 01

VERIFICATION REPORT

ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT         [m³/h] TSG:
       

[m³/h]

TSG:

Stack gas temperature [°C]

PSG:

Stack gas pressure [mbar]

273.15:

Standard temperature [K]

1013.25:Standard pressure [mbar]

Calibrations are performed regularly according to vendor’s specifications. QAL2, AST and QAL3 measures are applied according to EN14181 /19/.

PE n Total amount of N 2 O emitted by project activity during verification period

calculated

98.510754

This value is calculated based on monitored data as per formula given in section 1.4 of this verification report.

tN 2 O

NAP n Metric tonnes of

T2-

137 278

The nitric acid produced during verification period is measured by the Coriolis flow meter, which does the flow and concentration measurements.

FI7244.MES

tHNO 3

100%

concentrated

Nitric Acid

 

Produced during

The HNO 3 mass flow and concentration is measured continuously. In addition the concentration measurement is checked during each shift at the plant laboratory. The lab and per shift concentration values have been found in accordance with the reported values. This has been check by DNV by comparing the values in the production logs with the reported values /23/. These values were further in accordance with the values stored on the data acquisition and storage system (Honeywell PHD data acquisition and storage system).

As per the PDD, NAP eligible for issuance of ERUs is capped at 199 608 tHNO 3 /year. For this first verification period from 14 June 2009 to 31 May 2010 (355 days) the relative cap is 141 145 tHNO 3 . Actual NAP is below the cap and thus eligible for issuance of ERUs.

verification

period

Calibrations are performed regularly according to vendor’s specifications.

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Report No: 2011-0058, rev. 01

VERIFICATION REPORT

ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT       Measurement frequency is
     

Measurement frequency is 30 sec or less, delivering hourly average values.

OTh

--

°C

This parameter is monitored by thermocouples inside the AOR. However, none of the data is needed to be monitored as per the monitoring plan in the PDD.

Oxidation

temperature

in the

ammonia

oxidation

DNV finds this reasonable since the project is using benchmark emissions factor approach for the baseline emission determination.

reactor

(AOR).

AFR Ammonia Flow rate to the ammonia oxidation reactor (AOR)

--

kgNH 3 /h

This parameter is monitored by the ammonia flow meter. However, none of the data is needed to be monitored as per the monitoring plan in the PDD.

DNV finds this reasonable since the project is using benchmark emissions factor approach for the baseline emission determination.

AIFR Ammonia to air ratio going into the ammonia oxidation reactor (AOR)

--

%

This parameter is monitored by the ammonia and air flow meters. However, none of the data is needed to be monitored as per the monitoring plan in the PDD.

DNV finds this reasonable since the project is using benchmark emissions factor approach for the baseline emission determination.

TSG

ILO.T2-

°C

This parameter was monitored by Dr. Födisch FMD 99 Volume Flow Meter from

Temperature of

TI9400.MES

tail gas

13

August 2009 until the end of this

verification period. This is not applicable from 14 June 2009 to 13 August 2009 since the VSG calculation is based on primary air flow measurements.

Same quality assurance procedures as for VSG n .

PSG Pressure of tail Gas

ILO.T2-

Pa

This parameter was monitored by Dr.

PI9400.MES

Födisch FMD 99 Volume Flow Meter from

13

August 2009 until the end of this

 

verification period. This is not applicable from 14 June 2009 to 13 August 2009 since the VSG calculation is based on primary air

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Report No: 2011-0058, rev. 01

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT       flow measurements. Same
     

flow measurements.

Same quality assurance procedures as for VSG n .

EF n Emissions factor calculated for project Verification Period n

Calculated

0.000718

This value is calculated based on monitored

tN2O/tHNO 3

data as per formula given in section 1.4 of this verification report.

The project emissions factor was originally estimated to be 0.00144 tN 2 O/tHNO 3 (1.44kgN 2 O/tHNO 3 ) on average at an expected abatement efficiency of 85% throughout the project lifetime. However, the actual abatement efficiency of around 90% has been observed during this monitoring period from 14 June 2009 to 31 May 2010 and the calculated value has been justified (refer to CL 10 for further details).

EF BM Benchmark (Baseline) N 2 O Emission Factor applicable for N 2 O abatement projects at Finish Nitric Acid Plants

-

2.5

The value has been applied as per the Finnish DFP (national Environmental Protection Department of the Finnish Ministry of the Environment) ruling of 7 th April 2010 /22/. The accuracy and conservative of the value applied has been discussed in section 3.6.2 above.

kgN 2 O/tHNO 3

(0.0025

tN 2 O/tHNO 3

EF reg

-

KgN 2 O/tHNO 3

There is no emission cap for N 2 O from nitric acid production set by government or local regulations.

Emission cap for N 2 O from nitric acid production set by government or local regulations.

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Report No: 2011-0058, rev. 01

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ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT 3.7 Management System and Quality Assurance

3.7 Management System and Quality Assurance

The project is following the operational and management structure as described in section D.3 of the PDD /2/. The JI project related team has been mentioned in the PDD and roles have been defined. The same has been confirmed by DNV during the site visit audit of 01 and 02 July 2010. However, Procedures for this JI project need to be developed and provided to DNV, as requested in the FAR 1.

For the periods of time when the acid values were not available, these have been calculated from NH 3 values by mass balance (refer to section 3.3 of this report). The plant operation has been evident by AOR operation through DCS system values. The calculations have been confirmed by DNV and found correct. However, such events need to be covered in the JI procedures for future verifications. In this regards, FAR 1 was raised and will be accessed in the future verification.

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Report No: 2011-0058, rev. 01

VERIFICATION REPORT

ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT 4 VERIFICATION STATEMENT Det Norske Veritas

4 VERIFICATION STATEMENT

Det Norske Veritas Certification AS (DNV) has performed the verification of the emission reductions that have been reported for the “YARA Uusikaupunki T2 N2O abatement project in Finland” (JI track 1) for the period 14 June 2009 to 31 May 2010.

The project participants are responsible for the collection of data in accordance with the monitoring plan and the reporting of GHG emissions reductions from the project.

It is DNV’s responsibility to express an independent verification statement on the reported GHG emission reductions from the project. DNV does not express any opinion on the selected baseline scenario or on the validated and registered PDD.

DNV conducted the verification on the basis of the CDM monitoring methodology AM0034 / version 3.4 (that was applied with some deviations as described in section 3.3 of this report), AM0028 / version 4.2 (for monitoring of project emissions), the monitoring plan contained in the registered Project Design Document of 07 April 2010 and the monitoring report No. 01 (Version 02)) dated 02 September 2010. The verification included i) checking whether the provisions of the monitoring methodology and the monitoring plan were consistently and appropriately applied and ii) the collection of evidence supporting the reported data.

DNV’s verification approach draws on an understanding of the risks associated with reporting of GHG emission data and the controls in place to mitigate these. DNV planned and performed the verification by obtaining evidence and other information and explanations that DNV considers necessary to give reasonable assurance that reported GHG emission reductions are fairly stated.

In our opinion the GHG emissions reductions of the “YARA Uusikaupunki T2 N2O abatement project in Finland” for the period 14 June 2009 to 31 May 2010 are fairly stated in the monitoring report No. 01 (Version 02)) dated 02 September 2010.

The GHG emission reductions were calculated correctly on the basis of the approved CDM baseline and monitoring methodology AM0034 / version 3.4 (that was applied with some deviations as described in this report), AM0028 / version 4.2 (for monitoring of project emissions) and the monitoring plan contained in the registered PDD of 07 April 2010.

Det Norske Veritas Certification AS is able to verify that the emission reductions from the “YARA Uusikaupunki T2 N2O abatement project in Finland” during the period 14 June 2009 to 31 May 2010 amount to 75 851 tonnes of CO 2 equivalent.

Oslo, 13 January 2011

851 tonnes of CO 2 equivalent. Oslo, 13 January 2011 Rafi-ud-Din Khawaja JI Verifier Oslo, Norway

Rafi-ud-Din Khawaja JI Verifier Oslo, Norway

January 2011 Rafi-ud-Din Khawaja JI Verifier Oslo, Norway Ole Andreas Flagstad Approver, Det Norske Veritas

Ole Andreas Flagstad Approver, Det Norske Veritas Certification AS

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DET NORSKE VERITAS

Report No: 2011-0058, rev. 01

VERIFICATION REPORT

5

REFERENCES

No: 2011-0058, rev. 01 V ERIFICATION R EPORT 5 REFERENCES Documents provided by the Project Participants

Documents provided by the Project Participants that relate directly to the GHG components of the project. These have been used as direct sources of evidence for the periodic verification conclusions, and are usually further checked through interviews with key personnel.

/1/

N.Serve Environmental Services GmbH, JI Monitoring Report No.01 for ‘‘YARA

/2/

Uusikaupunki T2 N2O abatement project in Finland’’ for the period 14 June 2009 to 31 May 2010, version 1 dated 17 June 2010; and the updated JI monitoring report No.01, version 2 dated 02 September 2010 N.Serve Environmental Services GmbH, Project design document (PDD) for ‘‘YARA

/3/

Uusikaupunki T2 N2O abatement project in Finland’’ Version 5 dated 07 April 2010 N.Serve Environmental Services GmbH, ERU calculation spreadsheets for the period 14 June 2009 to 31 May 2010 for ‘‘YARA Uusikaupunki T2 N2O abatement project in Finland’’ dated 16 June 2010 N.Serve Environmental Services GmbH, ERU revised calculation spreadsheets for the period 14 June 2009 to 31 May 2010 for ‘‘YARA Uusikaupunki T2 N2O abatement project in Finland’’ dated 02 September 2010

Background documents related to the design and/or methodologies employed in the design or other reference documents.

/4/

JI Supervisory Committee, Determination and verification manual, version 01 adopted

/5/

at JISC 19 JI Supervisory Committee, Guidance on criteria for baseline setting and monitoring,

/6/

version 02 adopted at JISC18 CDM approved baseline and monitoring methodology, AM0034 version 3.4

/7/

CDM approved baseline and monitoring methodology, AM0028/version 4.2 (for

/8/

monitoring of project emissions) TÜV SÜD Industrie Service GmbH, Determination Report of the JI Track-1 Project:

/9/

‘‘YARA Uusikaupunki T2 N2O abatement project in Finland’’ Report No. 600500341, dated 08 April 2010 LoA from the focal point of the host country Finland (Ref# YM/6/44/2010,

/10/

YM7/44/2010,YM 8/44/2010) dated 23 June 2010 LoA from the focal point of the investor country France (Ref# 10-0959 5E DNquater)

/11/

dated 30 September 2010 YARA 58 Y 1 catalyst invoice dated 23 April 2009 and certificate of analysis dated 08

/12/

May 2009 Automated Monitoring System (AMS) site acceptance protocol, dated 24 July 2009

/13/

Product Conformity Certificate (QAL1) for FTIR Gasmet CEMS model DX4000

/14/

Analyzer, dated 10 November 2008 QAL1 Certificate for Dr. Födisch MCA 04 Analyzer, dated 10 March 2010

/15/

QAL1 Certificate for Dr. Födisch FMD 99 Volume Flow Meter, dated 13 May 2008

/16/

Müller-BBM GmbH, Report on performance test and calibration of the automatic measuring system for N2O of the nitric acid plant (QAL2) for FTIR Gasmet CEMS

Page 20

DET NORSKE VERITAS

Report No: 2011-0058, rev. 01

VERIFICATION REPORT

ERITAS Report No: 2011-0058, rev. 01 V ERIFICATION R EPORT /17/ model DX4000 Analyzer at YARA

/17/

model DX4000 Analyzer at YARA Uusikaupunki T2 N2O, dated 27 November 2009 (Calibrations and performance testing 18 September 2009 to 20 September 2009) Müller-BBM GmbH, Report on performance test and calibration of the automatic

/18/

measuring system for N2O of the nitric acid plant (QAL2) for Dr. Födisch MCA 04 Analyzer and the Dr. Födisch FMD 99 Volume Flow Meter at YARA Uusikaupunki N2O, dated 27 November 2009 (Calibrations and performance testing 18 September 2009 to 20 September 2009) Confirmation of training by Dr. Födisch for MCA 04 Analyzer, dated 24 July 2009

/19/

QAL3, Cusum Control Chart according to EN 14181 Version 1.0 from August 2009 to

/20/

April 2010 N.Serve Environmental Services GmbH, tail gas flow based on correlation between

Primary Air data and VSG (Stack gas velocity raw) values for the period 13 August 2009 to 11

/21/

October 2009 for ‘‘YARA Uusikaupunki T2 N2O abatement project in Finland’’ dated 02 September 2010 YARA UKI N2O Emission Reporting Technical Description, version 1.0

/22/

by Honeywell, designed 27 August 2010, updated 25 October 2010 Finnish DFP (national Environmental Protection Department of the Finnish Ministry of

/23/

the Environment), benchmark emission factors for Finnish nitric acid plants on 7 th April 2010 Nitric acid production logs from 14 June 2009 to 31 May 2010

Persons interviewed during the initial verification, or persons who contributed with other information that are not included in the documents listed above.

/24/

Tommi Hevonoja, YARA Suomi Oy, Production Manager/Local Project Manager for

/25/

JI Project Timo Stranius, YARA Suomi Oy, Environmental Engineer

/26/

Martin Stilkenbäumer, N.Serve Environmental Services GmbH, Monitoring

/27/

/Verification Expert Volker Schmidt, N.Serve Environmental Services GmbH, Monitoring /Verification Expert

- o0o -

Page 21

DET NORSKE VERITAS

APPENDIX A

CORRECTIVE ACTION REQUESTS, CLARIFICATION REQUESTS AND FORWARD ACTION REQUESTS

DET NORSKE VERITAS

Corrective action requests

CAR ID

Corrective action request

Response by Project Participants

DNV’s assessment of response by Project Participants

N/A

N/A

N/A

N/A

Clarification requests

CL ID

Clarification request

Response by Project Participants

DNV’s assessment of response by Project Participants

CL

1

The installation of new Dr. Fodisch MCA 04 Analyzer (at the time of installing Dr. Fodisch FMD 99 volume flow meter) on 13 July 2009 related documentation needed further explaining the reasoning for the change. It should be noted that the old analyzer is also still installed making parallel measurements and at the (Uusikaupunki T4) still the old analyzer model Gasmet type CX 4000 FTIR is being used without installing new analyzer.

YARA decided to install hot extractive emission monitoring systems for continuous measurements of stack emissions. Decision of choosing Dr.Födisch among other possibilities was done centrally within Yara YPO after several tests for equipment.

Also in TOPS4-01 (see attached document: Clip from TOPS4-01.doc) it is said that sample lines should be insulated or heat traced or continuously purged to keep temperature high.

The installation of new Dr. Fodisch MCA 04 Analyzer (at the time of installing Dr. Fodisch FMD 99 volume flow meter) on 13 July 2009 has been justified based on the explanations provided in project participant’s response.

 

DNV has also reviewed TOPS4-01 (see attached document: Clip from TOPS4-01.doc) and confirms its content which recommends the sampling lines to be insulated or heat traced or continuously purged to keep temperature high.

DNV also agrees that in long term old system can’t possibly handle hot gases.

 

The old system at Uusikaupunki T4 is also a hot extractive system and therefore justified and in line with the general decision to switch to hot extractive systems.

DNV also confirms that both systems (FTIR Gasmet CEMS model DX4000 and Dr. Födisch MCA04) are QAL1 and QAL2 tested.

This CL is closed.

CL

2

As per the MR, the monitoring values are recorded and stored by Mesto DNA InfoPlus.21 (version 6.0 /DNA

There was a mistake made in the MR, the DCS actually used at Uusikaupunki plants is Honeywell PHD, version 215

The DCS has been corrected to Honeywell PHD, version 215 in the updated MR Version 2 of 02 September 2010. DNV has also reviewed the ‘‘YARA UKI N2O Emission

DET NORSKE VERITAS

 

historian 6.1.2). Please clarify since this server is not mentioned in the PDD. However, as per the PDD, the data collection system is equipped with Honeywell PHD data acquisition system which is connected to PHD time series database and the oracle data base. The software/system provider has been stated to be Nicodex. The data collection system arrangements need to be clarified and

as stated in the PDD and not the Mesto DNA InfoPlus.21 (version 6.0 /DNA historian 6.1.2) as lined out in the MR. The MR was updated accordingly.

Reporting Technical Description, version 1.0’’ doc by Honeywell’’ for different access levels and data protection.

Different access levels and data protection are described in a statement from the system provider Honeywell:

YARA UKI N2O Emission Reporting

Further date flow was described and provided to DNV that is found by DNV to be as per the PDD as well.

This CL is closed.

Definition-1.0.doc

clearly stated in the MR.

In addition,

a letter from the system provider is needed explaining various access

The data flow is visualized in a simplified flow-sheet:

levels and confirming the system security in terms of data access.

N2O Data collection to Oracle.ppt

CL

3

Volume flow normalization procedures need to be explained and the same need to be stated in the updated MR.

Procedure for flow normalization Uusikaupunki T2 Procedure of application for QAL2 factors and stack gas flow normalization.pdf

Volume flow normalization procedures have provided along with the updated MR version 2 of 02 September 2010 and reviewed by DNV.

DNV confirms the accuracy of the procedures applied.

 
   

This CL is closed.

Updated MR provided (in track changes for better understanding)

CL

4

QAL1 certificate for the old Analyzer FTIR Gasmet CEMS model DX4000 need to be provided.

QAL1 Certificate (issued by MCERTS) provided:

Product Conformity Certificate (QAL1) for FTIR Gasmet CEMS model DX4000 Analyzer, dated 10 November 2008 issued by MCERTS has been provided to DNV and reviewed during this verification.

 

DX 4000 QAL1 certification.pdf

DET NORSKE VERITAS

     

This CL is closed.

CL

5

QAL 2 correction factors calculation procedures need to be explained and the same need to be included in the updated MR.

Procedure for application of correction factors provided Uusikaupunki T2 Procedure of application for QAL2 factors and stack gas flow normalization.pdf

DNV has been provided with the procedures for the

 

application of correction factors, updated calculation spreadsheets, and updated MR version 2 of 02 September

2010.

 

All these documents have been thoroughly reviewed

Updated MR provided (in track changes for better understanding)

towards this verification and DNV confirms the accuracy of the procedures applied.

This CL is closed.

CL

6

QAL 3 monthly span check higher range values have been observed deviating. This needs to be justified. It needs to be clarified if any adjustments have been made to the analyzer for these higher range deviations. Further any procedures related to QAL 3 zero and span checks need to be provided.

In addition, certificate for higher range (1500 ppm) needs to be provided since recent calibration gas certificate dated 16 April 2010 is for 1200 ppm range.

YARA only calibrated the low range of the analyzer so far. For the high range the calibration gas was only used to check the analyzer but the high range was not calibrated. During the service by the supplier (Dr. Födisch) no malfunction or abnormal high drift was observed and it was confirmed that the analyzer was operating normally in both ranges. (see service protocol: dr. födisch service

2.6.2010.pdf).

Since during the monitoring period the analyzer always worked in the lower range (as confirmed from the data during the monitoring and verification period) and since the only calibration was done for the lower range, higher observed values during monthly span checks could be disregarded.

 

Further since no adjustments were made, this would not have any impact on the data collected. This was further verified from review of the Wartungsprotokoll.pdf protocol that the analyzer was operating normally during both the ranges.

However during the monitoring period the analyzer always worked in the low range and the high range was never in use during this time.

DNV has also been provided with QAL 3 zero and span check procedures that have been reviewed and found OK.

 

For the future YARA will receive instructions from Dr. Födisch how to

Further, calibration gas certificate for 1500 ppm N 2 O have been provided to DNV, reviewed and found OK.

DET NORSKE VERITAS

   

calibrate both ranges.

 

Calibration gas certificate for 1500 ppm N2O provided: N2O 1500ppm.pdf

This CL is closed.

CL 7

Calibration certificates for the monitoring equipments related to the monitoring parameters in the PDD needs to be provided. In addition, list of equipments, their calibration frequencies and accuracy of values monitored need to be included in the MR.

N.serve will provide a table listing all relevant calibrations and calibration frequencies (NAP, NCSG, VSG, TSG, PSG, etc.). (MR Annex 4)

List of all relevant calibrations and calibration frequencies (NAP, NCSG, VSG, TSG, PSG, etc.) have been included in Annex 4 of the updated MR version 2 of 02 September 2010.

Calibration certificates are provided for the following:

Further, calibration certificates have been provided to DNV and reviewed during this verification. DNV confirms their validity and that the equipments were working within the specified error ranges.

NAP: Kalibrointipöytäkirja+T2-

The calibration frequency particularly for the mass flow meter is not clear. It is stated that annually or every two years the accuracy of the mass flow meter is checked against mass balance calculations and recommendations made by the responsible personnel to install new meters if needed. It is also stated that the mass flow meter at T2 plant is still in use for the past two years and the one installed at T4 is in use for past 6 years since it is made of Titanium.

It needs to be clarified that the values measured by the mass flow meters were plausible and the mass flow meter was measuring within its error

FE7244.pdf

Further these procedures are in accordance with the JI- project procedures that are currently being developed (refer to FAR 1 from this verification).

OTh: T2_TIZ5211_2.pdf AFR: T2-FI5230.pdf

Procedures to calibrate and ensure measurement reliability are included to general JI-project procedure (draft attached).: Päästökauppaan liittyvä tarkkailusuunnitelma.docx

This CL is closed.

DET NORSKE VERITAS

 

range.

   

Further, there have been no discussions with regards to accuracy/calibration of the transmitters associated with the mass flow meter. Therefore, procedures need to be defined for making such calibrations.

CL 8

It has been stated in the MR that from 14 June 2009 to 23 August 2009, the installed Coriolis flow meter

First of all it must be noted that the time period June 14 th to August 23 rd is not correct although this statement was mistakenly made in the MR. The actual time period for which obviously wrong measurement data can be seen in the raw data is June 14 th to August 13 th 2009. After having identified that the measurement data was simply not transferred into 100% concentration this missing step will be applied and the original data (transferred into 100%) will be used for the calculations instead of using numbers derived by the proposed approach for determination of substitute value. However, since during the time period 18.08.-21.08.2009 the coriolis flow meter delivered no results the proposed approach will be used for determination of substitute values in this case.

The MR has been corrected to include that the wrong measurement data (that was not transferred to 100% concentration) was from 14 June 2009 and 13 August

2009.

delivered implausible NAP measurements for which substitution was applied.

The substitute values were determined from the Ammonia consumption figures multiplied by an average conversion efficiency factor calculated from the HNO3 per input NH3 data from 21 August 2009 to 31 May 2010. If it is justified that this approach could be used without making any corrections as explained below, calibration certificates for the monitoring equipments that include NH3 flow meter, primary air flow meter and nitric acid mass flow meter need to be provided showing that they were properly calibrated, were

Furthermore in the updated spreadsheet of 02 September 2010 correct data (i.e. 100% concentration) has been extracted from the system and the calculations and MR have been updated accordingly. DNV has verified the correct NAP data during site visit of 01/02 June 2010.

DNV has also verified the calculation of missing NAP values from 18 August 2010 to 21 August 2010 based on Ammonia (NH 3 ) consumption figures by mass balance calculations.

Further, calibration certificates have been provided to DNV and reviewed during this verification. DNV confirms their validity and that the equipments were working within the specified error ranges.

QA procedures will be discussed in the future

DET NORSKE VERITAS

 

working within specified error ranges, and their calibrations were valid during that time.

The correct NAP data for the period 14.06.2009 – 13.08.2009 was extracted from the system and the calculations and MR were updated accordingly.

Calibration certificates are provided for NAP: Kalibrointipöytäkirja+T2-

verifications as further discussed below in FAR 1 from this verification.

This CL is closed.

It has been noted during data review during the site visit of 01and 02 July 2010 hat the reason for implausible NAP measurements for NAP prior to 23 August 2009 was that the actual concentration of the acid produced (which was around 60%) was taken as 100% without making adjustments for concentration and reported. This needs to be clarified and/or corrected. In addition, procedures need to be developed to avoid such mistakes in data handling and transfer in the future.

FE7244.pdf

AFR: T2-FI5230.pdf

QA steps for data extraction from the system will be included in the JI specific QA procedure which is under development (draft attached). Päästökauppaan liittyvä tarkkailusuunnitelma.docx

CL 9

It is not mentioned in the MR that the new project campaign started on 12 October 2009 with the change of new Gauzes. These events need to be described whether these occur at the start of the monitoring period or within the monitoring period. Furthermore, copies of the Gauze change evidences need to be provided to DNV.

MR is updated accordingly (MR Annex

Summary of events relevant for plant operation has been

3)

included in Annex 3 of the updated MR, version 2 of 02 September 2010.

Gauze invoices are provided Evidence of gauze changes (final settlement calculations, orders, invoices etc.). Documents vary from campaign to campaign due changes in internal delivery system and responsibilities between site/Yara Precious Metal Pool. Please note, that these financial documents including prices etc. has

Gauze invoices have been provided and reviewed by DNV to confirm the date of start of new project campaign on 12 October 2009.

This CL is closed.

DET NORSKE VERITAS

   

to be handled as classified! For further information, if needed, please contact Yara PMP (precious metal pool). See: T2 gauzes.pdf (Confidential!!!)

 

CL 10

The higher than 'estimated ERUs in the PDD' for the monitoring period from 14 June 2009 to 31 May 2010 needs to be justified. Clarification is needed in terms of what has resulted in more ERUs than estimated. Please note that the project emission as calculated in the PDD have reduced from around 87 048 tCO2 for year 2010 to around 30 539 tCO2 in around eleven and a half months of this monitoring period. Given that the acid production are lower (around 70%, 195000 tHNO3/year in the PDD v/s 137 277 tHNO3 in the monitoring period that is around eleven and a half month), the increase in ERUs seems to be linked with the flow (VSG) and concentration (NCSG) values.

The Determining AIE always insists on the use of conservative ERU calculations in the PDD, since so many projects (although generally not N 2 O) vastly overestimate the number of emissions they will reduce. With this in mind, the project participant is asked to provide evidence for sufficiently conservative estimated abatement efficiency, which in the case of YARA’s secondary catalyst is the supplier’s minimum guarantee of 80%. However, since the time of writing the Uusikaupunki T2 PDD at the beginning of 2009, subsequent installations of the secondary catalyst have shown excellent performance in many European plants. YARA has even increased its guaranteed minimum performance in many more recent quotes. In the case of Uusikaupunki T2, as with many other European plants, the efficiency has proven vastly better than expected, at just above 90%. This is the reason for the large difference between the conservative reduction estimates in

The project emissions factor originally estimated in the PDD was 0.00144 tN 2 O/tHNO 3 (1.44 kgN 2 O/tHNO 3 ) on average at an expected abatement efficiency of 85% throughout the project lifetime. This estimate was based on the pre-project emission factor of 9.6 kgN 2 O/tHNO 3 (0.0096 tN 2 O/tHNO 3 ) as per the PDD at an abatement efficiency of 85%.

The actual project emissions factor (EFn) has been established to be 0.0007176 tN 2 O/tHNO 3 (0.7176 kgN 2 O/tHNO 3 ) according to the methodology. Thus it implies that the abatement efficiency during this monitoring period from 14 June 2009 to 31 May 2010 is 92.5 %.

DNV confirms that the abatement efficiency established based on monitored values for flow (VSG) and concentration (NCSG) is higher than the estimated value in the PDD. DNV confirms that the value is correctly calculated.

 

This CL is closed.

DET NORSKE VERITAS

the PDD and the factual achievements at the plant during the project. Given the pre-project
the PDD and the factual achievements
at the plant during the project. Given
the pre-project emissions factor of