Petrus Resources Pneumatic Device Offset Project

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Petrus Resources Pneumatic Device Offset Project July 2020 Version 3.0 Project Plan Template January 2020 Offset Project Plan Form: Petrus Resources Pneumatic Device Offset Project Project Developer: Petrus Resources Ltd. Prepared by: Petrus Resources Ltd. Date: July 3, 2020

Transcript of Petrus Resources Pneumatic Device Offset Project

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Petrus Resources Pneumatic Device Offset Project July 2020

Version 3.0 Project Plan Template – January 2020

Offset Project Plan Form:

Petrus Resources Pneumatic Device Offset Project

Project Developer:

Petrus Resources Ltd.

Prepared by:

Petrus Resources Ltd.

Date:

July 3, 2020

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Table of Contents

1.0 Contact Information .............................................................................................. 3 2.0 Project Scope and Site Description .......................................................................... 3

2.1 Project Description ................................................................................................ 5 2.2 Protocol ............................................................................................................... 9 2.3 Risks ................................................................................................................. 12

3.0 Project Quantification .......................................................................................... 15 3.1 Inventory or Sources and Sinks ............................................................................ 15

3.1.1 Data Collection ................................................................................................... 18 3.2 Baseline and Project Condition .............................................................................. 18 3.3 Quantification Plan .............................................................................................. 22

3.3.1 Project Component #1 – Pneumatic Device Electrification......................................... 24 3.3.2 Project Component #2 – Pneumatic Controller High to Low Conversions .................... 26 3.3.3 Project Component #3 – Vent Gas Capture ............................................................ 30

3.4 Monitoring Plan ................................................................................................... 33 3.5 Data Management System.................................................................................... 50

4.0 Project Developer Signature ................................................................................. 53 5.0 References ......................................................................................................... 53 Appendix A: Supporting Information ..................................................................................... 54

List of Tables

Table 1: Project Contact Information ...................................................................................... 3 Table 2: Project Information .................................................................................................. 3 Figure 1: Baseline pressure controller ..................................................................................... 7 Figure 2: Project pressure controller ....................................................................................... 7 Figure 3: Baseline Level Controller ......................................................................................... 8 Table 3: Protocol Criteria and Project Eligibility ...................................................................... 10 Table 4: Risk Matrix ............................................................................................................ 13 Table 5: Inventory or Sources and Sinks ............................................................................... 15 Figure 4: Baseline process flow diagram, "Quantification Protocol for Greenhouse Gas Emission

Reductions from Pneumatic Devices”, January 25, 2017 ........................................... 19 Figure 5: Project process flow diagram, "Quantification Protocol for Greenhouse Gas Emission

Reductions from Pneumatic Devices”, January 25, 2017 ........................................... 20 Table 6: Quantified Sources and Sinks .................................................................................. 23 Table 7: Discount rate determination for instrument air projects, as per Appendix A of the Protocol

......................................................................................................................... 30 Table 8: Monitoring plan and data sources for pump electrification ........................................... 35 Table 9: Monitoring plan and data sources for level controllers high to low conversions ............... 38 Table 10: Monitoring plan and data sources for vent gas capture ............................................. 43 Table 11: Sample Monitoring Plan ........................................................................................ 49

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1.0 Contact Information

Table 1: Project Contact Information

Project Developer Contact Information Additional Contact Information

Petrus Resources

NA

Robert (Bob) Caughlin

240, 4 Ave SW

Calgary, Alberta, T2P 4H4

(587) 216 - 1141

petrusresources.com

[email protected]

Authorized Project Contact (if applicable)

Modern West Advisory Inc.

Zainab Dadashi

600 - 505 2nd Street SW

Calgary AB T2P 1N8

(403) 400-7106

modernwestadvisory.com

[email protected]

2.0 Project Scope and Site Description

Table 2: Project Information

Project title Petrus Resources Pneumatic Device Offset Project

Project purpose and objectives

Purpose of this project is to quantify greenhouse gas (GHG) emission reductions resulting from direct reduction of natural gas (methane) venting from pneumatic devices. This project reduces the vented gas by

converting those devices either through a lower-vent equivalent, electrification or pneumatic vent gas capture and destruction. Petrus Resources Pneumatic Device Offset Project has Three components:

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1) Pneumatic Pump Electrification – Includes the installation of solar pumps instead of gas driven pneumatic chemical injection pumps at greenfield facilities.

2) Pneumatic Controller High to Low and High to no-bleed Conversions – Involves the conversion of high bleed pneumatic controllers (including level controllers, pressure controllers and transducers) at brownfield facilities to low bleed devices and/or removing high bleed devices and replacing them with a control valve to control the pressure manually or

to bypass the high-bleed device in the system.

3) Vent Gas Capture System Installations - Pneumatic vent gas capture projects redirect vented gas via the installation of piping to a point of destruction.

Each subproject will reduce or avoid the release of greenhouse gas emissions throughout the Proponent’s asset portfolio. They eliminate or reduce methane and carbon dioxide which would have been vented from pneumatically driven devices had the project not occurred.

Field data will be aggregated for all project components and reported in one annual assertion. Carbon offset credits are generated in accordance with the Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices (V 2.0 January 2017).

Activity start date Activity start date of the first subproject is February 20, 2015.

Different sub-projects have different activity start dates. All the relevant

information is submitted to the registry via the aggregated planning and reporting sheets.

Offset crediting period

The expected offset crediting period is from the day the project documents are submitted to the registry (April 27, 2020) until the end of Dec 31, 2022.

Estimated emission reductions/ sequestration

The estimated total greenhouse gas emission reductions from the Project are as follows:

April 27, 2020 – December 31, 2020 9,000 tonnes of CO2e

December 31, 2020– December 31, 2021 17,000 tonnes of CO2e

December 31, 2021 – December 31, 2022 17,000 tonnes of CO2e

Total for crediting period 43,000 tonnes of CO2e

Unique site identifier Different sub-projects have different locations. All the relevant

information is submitted to the registry via the aggregated planning and reporting sheets

Is the project located in Alberta?

Yes. The project is located in Alberta.

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Do the emission reductions occur in Alberta?

Yes. The emission Reductions occur in Alberta.

Project boundary The Project boundary includes the pneumatic device itself, as well as the fuel gas supplied to the device, and/or any electricity consumption.

The pneumatic device may be located on a single wellsite, oil or gas batteries, satellite, within a compressor building or dehydration building etc. The legal land location of each device is tracked within the Project

inventory.

Ownership Petrus Resources Ltd. owns and operates the facilities at which the Project is implemented and asserts that it has ownership of the emissions reductions. Furthermore, no emission reductions associated with the Project have been registered under any other emissions trading

scheme.

2.1 Project Description

Oil and gas extraction involves drilling wells into hydrocarbon production zones and then flowing the raw production up the well and into processing facilities. Pneumatic devices are needed in the production facilities to deliver the oil and gas products to various destinations.

This Project will achieve greenhouse gas emission reduction through the combination of the electrification of pneumatic chemical injection pumps via solar power system, the conversion of high bleed pneumatic controllers to low bleed devices, and vent gas capture off pneumatic

chemical injection pumps. Petrus Resources Pneumatic Device Offset Project’s three components are discussed below.

Project Component #1 - Pneumatic Devices Electrification

Chemical Injection pumps are electrified in the project condition at greenfield facilities, using solar powered systems. Chemical injection pumps are used where different chemicals (e.g. corrosion inhibitor) are pumped into the production stream early in the production process, to prevent adverse conditions in the production network such as freezing and corrosion. Typically, these chemical injection pumps use pneumatic pressure supplied by a fuel gas line to actuate the pump, then the fuel gas is vented to the atmosphere.

The primary component of the vented fuel gas used to drive chemical injection pumps is methane which is a potent GHG with a GWP of 25 times that of carbon dioxide [1]. Efforts to

decrease this venting result from actuating the same pumps using electric energy instead of pneumatic gas. In the baseline scenario, all these pumps use pneumatic pressure supplied by a fuel gas, whereas the project scenario is where these devices use electricity to operate. Baseline and project conditions at the sites can be easily compared as only the drive source has been converted, while device operations have remained the same.

The Project Proponent installed two electric pumps at one new site in Alberta. Both pumps are

using solar power resulting in zero emissions. As mentioned in the protocol, gas-driven chemical injection pumps vent on a per stroke basis and this is the metric for establishing functional equivalence. To estimate the volume of gas displaced, which is used to calculate the emission reductions resulting from the installations of electric pumps, strokes count will be obtained using one of the approaches below:

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• Project Proponent will use metered stroke counts based on stroke counters installed

on the pumps (where stroke counter on the device is available)

• Project Proponent will estimate the stroke counts based on the metered volume of

chemicals injected as allowed in Appendix C of the Protocol (where stroke counter on

the device is not available)

Make and model of these pumps are taken into account and the Project Proponent collects an inventory of all equipment according to the protocol requirements. Emission factors for these pumps are gathered based on their manufacturer specifications, as required by the Protocol.

Current make and models of the electric pumps include:

• General Magnetic International, 300-2M-910A-001

Texsteam 5100 pneumatic pump model is considered to be the baseline pump model as this model (and equivalent models) contribute to more than 90% of the current pneumatic pump inventory.

To estimate the emissions during the offset crediting period, the following parameters are taken into account:

• Pump make and model (in the baseline and project condition)

• Pump plunger size

• Pump stroke length

• Injection pressure

• Pump stroke count (annual estimations)

• Methane and carbon dioxide composition in fuel gas

The expected lifetime of these electric pumps is 10 years according to the Eco-Efficiency Handbook [1].

Project Component #2 - Pneumatic Controller High to Low / High to no-bleed Conversions

Producing wells are typically connected to separators used for separating various gaseous and liquid components of well fluids. Operators use pneumatic instruments/controllers connected to separators in oil and gas facilities to measure process variables such as pressure and temperature and transmit signals to the final control elements. Pneumatic controllers in this project include pressure and level controllers and transducers. Pressure controllers use sensors

that get a pressure signal from the process gas and output a corresponding pneumatic pressure signal from the supplied instrument gas that is then used to operate the final control element. Level controllers use sensors to detect liquid levels or the interface of liquid/liquid or liquid/gas, and then use relays to provide control and action.

The baseline for pressure controllers includes high-bleed Fisher 4150 and 4160 series and Dynaflo 4000 series. It is expected that the Project Proponent will convert 79 of their pressure

controllers at their facilities, over the offset crediting period. These devices will be converted to the low-bleed Fisher C1 pressure controllers or replaced by a valve that is operated manually (high to no conversion). The C1 nozzle and beam and flapper assembly is designed to reduce the continuous air flow through the nozzle, thus reducing the vented flow rate. The Project Proponent’s Fisher 4150/4160 that are planned to be converted, emit on average 1.5 m3/hr and when retrofitted to a Fisher C1, the emission factor is reduced to 0.2 m3/hr.

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Figure 1: Baseline pressure controller

Figure 2: Project pressure controller

The baseline level controllers’ make and model is typically Fisher L2 at the Project Proponent facilities and the project level controllers are expected to be Fisher L2-LG and L2-LL. It is expected that the Project Proponent will convert 120 of their level controllers at their facilities, over the offset crediting period. These devices will all be converted to the low-bleed Fisher L2-LG/LL level controllers. Fisher L2-LG/LL relay is purpose built for a Liquid-Gas/Liquid-Liquid Interface in a separator which eliminates transient emissions. For this controller, the gain has been customized to appropriately widen the span of the vessel to save gas by reducing the frequency of the dump cycles for a given rate of liquid production. It is important to note that

the crisp performance of the original relay has been preserved as well as the expected ruggedness and reliability.

The Project Proponent’s Fisher L2 that are planned to be converted, emit on average 0.88 m3/hr and when retrofitted to an L2-LL and L2-LG relay, the emission factor is reduced to 0.1 m3/hr.

Baseline transducer make and model is typically i2P-100 at the Project Proponent facilities which will be converted to low bleed model i2P-100LB or removed. It is expected that the Project Proponent will convert 16-30 transducers at their facilities, over the offset crediting period. Fisher i2P-100 and i2P-100LB emit on average 0.4 m3/hr and 0.1 m3/hr, respectively.

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Figure 3: Baseline Level Controller

Similar to pumps, the project and baseline are functionally equivalent in that the rate of change of the oil and gas process control measures is unaffected and independent of the Project activity. The conversion maintains functional equivalence by enabling the same operating conditions to persist on site. The new equipment is supplied by the same gas pressure as the previous high-bleed device and is able to output the same level of activity as previously experienced on site.

To estimate the offsets generated during the crediting period, the following parameters are taken to account:

• Controller Make (baseline and project)

• Controller Model (baseline and project)

• Supply pressure

• Operating hours of the facility/controller

• Vent rate samples

The expected lifetime of the Fisher C1 pressure controllers, Fisher L2 liquid level controllers and Fisher i2p-100 transducers is in line with typical level controllers depending on process fluid and operating conditions, according to the Eco-Efficiency Handbook [1].

Project Component #3 – Vent Gas Capture

Vented gas from pneumatic devices can be captured and through piping get destroyed via many equipment. The Project Proponent is destroying vented gas from chemical injection pumps at their facility in their catalytic combustion devices (Catadyne Heaters) at 18 facilities. As per the Protocol applicability, these projects can occur at greenfield installations or brownfield sites.

In baseline condition, all venting from pneumatic chemical injection pumps (Texsteam 5100 or CVS 5100 which are functionally equivalent and have similar vent rates) was released to the atmosphere, where additional fuel gas was needed to maintain Catadyne heaters to keep building temperatures during colder periods. In the project condition, Catadyne heaters are powered with the vented gas from the pumps, eliminating both pneumatic vent and extra fuel gas in the baseline condition.

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The project and baseline emissions are calculated based on the approach explained in the protocol. To estimate the offset during the crediting period, the following parameters are taken to account:

• Operating hours of the combustion device

• Load of the combustion device

• Fuel consumption rate of the combustion device

• Destruction efficiency of the combustion device

• Methane and carbon dioxide composition in fuel gas

• Discount rate due to leaks (as described in Appendix A of the Protocol)

The install dates of vent gas capture systems included in the Project are from 2015. As such, it is expected that the service lifetimes of the project activities will exceed that of the credit duration period.

2.2 Protocol

This project quantifies the emission reductions using the approved Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices (V 2.0 January 2017), “the Protocol” [2].

The quantification protocol is written for any operator in the oil and gas industry where natural

gas is used to provide pneumatic power for automated process control and operational devices. The Protocol scope covers all three project components in this project as described below:

Project Component #1 - Pneumatic Devices Electrification

This project type is directly identified in “Protocol Scope 1.1.3”. Solar powered devices are applicable for both greenfield and brownfield facilities.

Project Component #2 - Pneumatic Controller High to Low Conversions

This project type is directly identified in “Protocol Scope 1.1.1”. The conversion of high vent controllers to a low vent controller reduces the vent rate by use of newer technologies which perform the same control function while reducing the natural gas or fuel gas consuming and venting.

The conversion of high to no-bleed devices is not explicitly mentioned in the protocol. Petrus Resources requested Climate Implementation and Compliance Branch of Alberta Environment and Parks to allow for a deviation from the protocol to consider high to no-bleed conversion an eligible project type for offset generation. AEP approved the deviation request under some terms and conditions. Both the deviation request and AEP response letter are included in Appendix A of this project plan.

Project Component #3 – Vent Gas Capture

This project type is identified in “Protocol Scope 1.1.4”. Catalytic combustion device is one of the eligible destruction systems from vented gas coming from pneumatic devices.

Table 3 below shows how the project will meet the quantification protocol requirements:

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Table 3: Protocol Criteria and Project Eligibility

Protocol Criteria Project Eligibility

1. Pneumatic or electric devices in the project condition perform the same effective process control or operational function as in the baseline condition. This requirement considers changing throughput or production declines.

This means the specific frequency of control interventions, volume of methanol injected, or other activity, may change in time, but safe and reliable operation is maintained. This implies that at a minimum:

a) low and non-vent devices are effective

replacements based on manufacturer specifications,

b) vent gas capture systems are installed in a manner which allows relief of vent backpressure to maintain functionality of pneumatic devices

a) The low bleed pneumatic controllers that were installed for the Project provide the same level of service and same function as was provided by the previous high bleed controllers. The low bleed

controllers were selected to ensure that each new controller is an effective replacement, as specified in manufacturer technical documentation. Solar pumps perform functionally equivalent to the pneumatic pumps in the baseline condition.

b) Vent gas capture systems in the Project are installed in a manner which allow relief of vent backpressure to maintain functionality of device.

2. The protocol is applicable to methane vent reduction projects. Reduction of propane venting and/or conversion from propane to methane is not contemplated in this protocol.

The project activities eliminate or reduce methane vent emissions from pneumatic devices.

3. For the purposes of this protocol, “conversions” are considered to occur at brownfield sites with existing equipment being replaced and “installs” are considered to occur at greenfield sites where no equipment existed prior to the implementation of the project. This

must be demonstrated by process flow diagrams and/or accounting records, work orders, invoices or other vendor/third party documentation/evidence.

All three project components are in accordance with Table 1 in section “1.2 Protocol Applicability” of the protocol. The Project consist of installs at the Project Proponent’s greenfield facilities and conversion at brownfield facilities.

4. The Project Proponent must inspect and maintain pneumatic devices as part of regular operations for high to low, compressed air and vent gas capture projects. This must be performed annually by performing operator site visits to ensure that pneumatic devices do not excessively vent. Operators must keep records demonstrating the maintenance and

inspection activities of facilities. If pneumatic device inspection is not performed according to suggested monitoring frequencies, volumes must be reduced using a Discount Factor. This factor is developed in detail in Appendix A. If

Not applicable to the Project Component #1- Pneumatic Device Electrification. For Project Component #2 and #3 all sub projects will have annual inspections and maintained, otherwise as described in Section 3.3 of the Protocol, Project developer will use a Discount Factor.

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pneumatic device inspection becomes required by regulation the offset project must inspect and maintain pneumatic devices as per the

requirements of the relevant regulation.

5.To facilitate verification and allow for changes, the proponent will develop an inventory of devices. Any changes to the inventory (i.e., devices removed) will impact

net offsets claimed as illustrated in Appendix B.

The inventory will be maintained annually and adjusted if project conditions change over time. Aggregated Project Planning Sheets also help maintain the inventory

of current and future sub-projects which is submitted to the registry.

The Project Proponent will make use of Protocol Flexibility Mechanism #1:

Mechanism #1: Project Proponents can quantify and aggregate multiple conversions or installs under one project plan. The entire quantification method should apply to each conversion to ensure accuracy.

The Project Proponent is using this flexibility mechanism to aggregate the installation of solar pumps, conversion of pneumatic controllers, and installation of vent gas capture system for the crediting period from April 27, 2020 until December 31, 2022. The Project Proponent has the

current inventory of all devices that are eligible for offset generation. Any future new installs or any conversion will be submitted to the registry within the acceptable timeframe. The Project Proponent will ensure the emission reductions quantification will be in line with protocol requirements.

The Proponent may or may not make use of Protocol Flexibility Mechanism #3 and Mechanism #4:

Mechanism #3: Site-specific and make and model-specific emission factors may be substituted for the generic emission factors indicated in this protocol document. The methodology for generation of these emission factors must be sufficiently robust to ensure accuracy. See Appendix C of the Protocol.

Mechanism #4: Options are presented in Section 2.0 and in Section 4.1 for proponents to determine emissions related to baseline and project activity for certain project types. Preferential order of methods is presented in Section 2.0 for proponents who have the ability to quantify emissions with more accuracy.

The following discussions explains how the Proponent is using flexibility mechanisms #3 and

#4.

Project Component #1 – Pneumatic Pump Electrification

The Project Proponent’s use of Flexibility Mechanism #4 will result in more accurate emission reduction assertions because device specific venting rates, from manufacturer specifications are used. These specific vent rates are reported for different injection pressures and are reported

per volume of chemical injected. As stated in the Protocol’s appendix C:

The pump emission factor is referenced from manufacturer specifications. At a given supply pressure and injection pressure, a pump will consume and vent a known volume of gas for each stroke or volume of chemical injected. In the absence of a known stroke count, Project

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Proponents can use the volume of chemical injected to determine the volume of gas vented in the baseline, as per Flexibility Mechanism 4.

The Project Proponent is using Projection Based Baseline Type which are claimed to be the most accurate because they measure pump activity and project this to the baseline (as per protocol). The Protocol says that reliable projections can be made on the volume of natural gas that would have been released in the absence of the project based on the pump stroke count (or volume of injected chemicals) in the project condition.

Project Component #2 – Pneumatic Controller High to Low Conversions

the Project Proponent is using historical benchmarks, where possible. A historical benchmark in the protocol is defined as using vent measurements from devices prior to the conversion. Where the historical benchmark approach is not available due to lack of field measurements, the protocol vent rates are used based on manufacturer specifications according to

representative sample of similar sites (constructed by the Proponent after Jan1, 2012).

The Project Proponent will be using either the Historic Benchmark or Performance Standard Baseline Type for level controllers baseline emissions estimates depending on the availability of vent measurements prior to conversion.

Project Component #3 – Vent Gas Capture

The Projection Based approach to baseline quantification will be used. Projection based baselines for vent gas capture from pumps at greenfield/brownfield sites are the most accurate because they measure actual emission activity and project this to the baseline. Reliable projections can be made on the volume of natural gas that would have been released in the absence of the project based on the volume of gas captured in the project.

No flagged protocol is used in the Project.

One deviation request is included in the Project. The deviation request is related to the second component of the offset project, conversion of high bleed pneumatic controllers at brownfield facilities to low-bleed or no-bleed devices. In Section 1.1.1 of the protocol, converting high-bleed pneumatic controllers to low-bleed devices is described as an eligible project type. However, in some cases the project proponent may remove a high-bleed device and replace it with a control valve to control the pressure manually or to bypass the high-bleed device in the system. This will result in a no-bleed replacement for the high-bleed device. The project proponent requested for this type of conversion to be considered an eligible project for generating carbon offsets and received an approval from AEP to use this conversion in the offset project. The deviation request letter and the response letter are included in Appendix A.

Only one protocol, Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices (V 2.0 January 2017), is used in the Project.

2.3 Risks

Table 4 below shows all the risks associated with this emission offset project:

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Table 4: Risk Matrix

Risk Identification Level of Risk

Mitigation/Management Strategy

Technical Risks

Lack of maintenance Low Performance and upkeep of the electrical motor and solar array have been added to the overall maintenance of the facility. Field personnel are trained to assess and maintain the efficiency of

the motor and solar panels.

Lack of uninterrupted

electrical energy source

Low Planning for the solar array accounts for the electrical demand of the pneumatic conversion/installations. Solar panel maintenance has also been added to the facility maintenance procedure to ensure that they are operating at optimal efficiency.

When the solar array is not operating (i.e. night) the solar powered devices will run on battery power. The solar array will be used to charge the battery backup during the day; producing more energy than is consumed by the

pneumatic conversions/installations.

Failure to store enough energy in the battery backup for use during times of low or no solar power generation

Low The amount of battery backup has been designed to provide the pneumatic conversions/installations with enough electricity to operate without recharging for several days should the solar array experience suboptimal

charging conditions. In addition, improvements to automation by the technology provider will warn the proponent if the battery backup is low at a particular site, allowing them sufficient time to troubleshoot the issue.

If the electrical power fails, the pump stops and the current volume of injected chemicals (and therefore the stroke count) is retained in the controller memory. Once power is restored the pump restarts measuring the volume of chemicals from the volume at the time the pump was stopped.

Decommissioning of

conversion equipment which could affect the amount of emissions reduction the project can potentially generate

Low The decommissioning of the

conversion/installation equipment is not expected as all equipment has been operating for less than a year and maintains a usable life span far beyond the crediting period defined herein.

Data collection risk Low All data required to complete the emission reduction quantification is collected in the field by operations personal. Data collection will rely on direct metering and measurement to the extent possible. Data will be transferred

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electronically between systems wherever possible to reduce transcription errors. Data management is done through several redundant

systems that have local storage both on and offsite providing for robust data as processes and personnel change through time.

Devices existing in the Proponent’s project are

taken offline

Moderate If a well is shut in and no longer producing, the relevant pneumatic devices affected will no

longer generate offset credits.

Equipment failure Low

An equipment failure could cause excessive vents and downtime. This risk is mitigated by selecting proven technology and robust controller devices from reliable equipment manufacturers.

Offset project additionality

None

All three components of the offset project are additional as the projects are not required by regulation until the end of offset crediting period, i.e., December 31, 2022. No project level additionality assessment is required for this project, since the applicable

Protocol considers the additionality requirement for this project type.

Other emission offset projects

None

There are no other emission offset projects on the subproject locations of the current offset project.

More than one emission offset projects at a site

Low

There is a risk of offset credits being double counted when more than one offset project type exists on one location. However, the risk of double counting offset credits is low as each subproject in this offset project is clearly identified with a serial number and each subproject is only included in one of the project

components identified in this project plan.

Political Risk

Alberta Government requires that pneumatic devices be upgraded to

be electric or instrument air during the crediting period

Low There is currently no regulation or draft regulation requiring the conversion of pneumatic to zero emissions and it is not expected to be a

requirement under future regulations within the timeframe of carbon offsets eligibility.

Double counting of

emission offsets

Low A subproject could be included in another emission offset project, causing the emission offsets to be counted twice. The Aggregated

Project Planning sheet ensures that each subproject is tracked and monitored for double counting.

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3.0 Project Quantification

3.1 Inventory or Sources and Sinks

All the sources and/or sinks for project types that are eligible project activities under the Protocol are identified in table 3 and table 4 of the Protocol. For completeness, all those sink and sources are considered and are include in Table 5 below. This table provides all source and sinks under project and baseline conditions. Also, any inclusion or exclusion of these sources and sink are explained and justified.

Table 5: Inventory or Sources and Sinks

1. Identified SS 2. Baseline

3. Project 4. Include or Exclude

5. Justification for Exclusion

Upstream Sources and Sinks

P1 Raw Gas Production

N/A Related Exclude As per protocol: Excluded as the production of raw gas is not impacted by the implementation of the project and as such the baseline and the project conditions will be functionally equivalent.

B1 Raw Gas Production

Related N/A Exclude

P2 Raw Gas Transportation

N/A Related Exclude As per protocol: Excluded as the transportation of raw gas is not impacted by the implementation of the project and as such the baseline and the project conditions will be functionally equivalent.

B2 Raw Gas Transportation

Related N/A Exclude

P3 Raw Gas Processing

N/A Related Exclude As per protocol: Excluded as the processing of raw gas is not impacted by the implementation of the project and as such the baseline and the project conditions will be functionally equivalent.

B3 Raw Gas Processing

Related N/A Exclude

P5 Fuel Gas for Processing

N/A Related Exclude As per protocol: Excluded as the fuel gas for facility is not impacted by the implementation of the project and as such the baseline and the project conditions will be functionally equivalent.

B5 Fuel Gas for Processing

Related N/A Exclude

P6 Air Compression

N/A Controlled Not Relevant

No instrument air system in installed in this offset project.

P8 Process Control

Electricity

N/A Related Included The Project is powered by electric energy coming from renewable source (solar) and grid. Those pumps that are grid tied, have additional electricity emission compared to the baseline condition and are captured using

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suggested approach in the Protocol.

B9 Electricity Usage

Controlled N/A Exclude As per protocol: Existing air compression systems that are expanded to include pneumatic devices may have electricity emissions to account for in the baseline. The project air compressor and air management system will require electricity that is incremental to baseline electricity consumption, but these emissions are conservatively accounted in all project scenarios under this protocol and this source is therefore redundant and excluded.

P9 Fuel Extraction/ Processing

N/A Related Included The electric conversion uses all renewable energy and grid electricity and thus does not have any fuel related emissions. There is no additional fuel use as a result of level controller conversion either.

B10 Fuel Extraction/ Processing

Related N/A Exclude As per protocol: Fuel extraction and processing emissions may vary depending on the stage of processing or transportation of the gas. Emissions from fuel extraction and processing may not be relevant to the baseline condition. It is conservative to exclude baseline emissions

P10 Fuel Delivery N/A Related Exclude As per protocol: Excluded as the fuel delivery is not impacted by the implementation of the project and as such the baseline and the project conditions will be functionally equivalent.

B11 Fuel Delivery Related N/A Exclude

Onsite Sources and Sinks

P7 Project Vented Gas

N/A Controlled Included The first component of this Project includes replacing the pneumatic gas with electric energy resulting in no venting emissions.

The second component of the project includes converting high to low-bleed level controllers. There is vented gas in Project emissions for new low-bleed level controllers.

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B7 Baseline Vented Gas

Controlled N/A Included Included as baseline includes pneumatic pumps and controllers which vent natural gas into atmosphere.

B8 Uncaptured Fuel Gas

Controlled N/A Included Emissions reductions from installing or upgrading a vent gas capture and destruction system. Venting of gas results in tangible emissions in the baseline condition, destruction of vent gas has tangible emissions in the project condition.

P17 Vent Gas Capture

N/A Controlled Included

Downstream Sources and Sinks

P4 Processed Gas Distribution and Sale

N/A Related Exclude As per protocol: Excluded as the emissions from the distribution and sale of avoided vented gas is the sole responsibility of the end user. It is assumed the final use of this gas will be controlled combustion to produce carbon dioxide. Accountability of this gas is in the hands of end users.

B4 Processed Gas Distribution and Sale

Related N/A Exclude

Other Sources and Sinks

P11 Construction on Site

N/A Related Exclude As per protocol: Emissions from construction on site are not material for the baseline or project condition given the minimal construction on site typically required.

B12 Construction on Site

Related N/A Exclude

P12 Development of Site

N/A Related Exclude As per protocol: Emissions from development of site are not material for the baseline condition given the minimal development of site typically required.

B13 Development of Site

Related N/A Exclude As per protocol: Emissions from building of equipment are not material given the long project life and the minimal building equipment typically required.

P13 Building of Equipment

N/A Related Exclude As per protocol: Emissions from building of equipment are not material given the long project life and the minimal building equipment typically required.

B14 Building of Equipment

Related N/A Exclude As per protocol: Emissions from building of equipment are not material for the baseline given the

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minimal building equipment typically required.

P14 Testing of Equipment

N/A Related Exclude As per protocol: Emissions from testing of equipment are not material given the long project life and the minimal testing of equipment typically required.

P15 Transportation of Equipment

N/A Related Exclude As per protocol: Emissions from transportation of equipment are not material given the long project life and the minimal transportation of equipment typically required.

B15 Transportation of Equipment

Related N/A Exclude

P16 Site Decommissioning

N/A Related Exclude As per protocol: Emissions from decommissioning of site are not material given the long project life and the minimal decommissioning typically required.

B6 Site Decommissioning

Related N/A Exclude

The Project Proponent will track, monitor and quantify the baseline emissions using the following steps:

3.1.1 Data Collection

As further defined in the quantification plan in Section 3.3, all included sources and sinks are addressed and data tracking procedures are explained. Section 3.4 outlines the monitoring approach for measured sources and sinks. As explained in the following sections, there are

multiple data points required for this Project and each has its own data collection process. Several data point are collected once at the beginning of the Project (e.g., stroke length and piston diameter, controller make and model), while the ongoing and variable data points (e.g., stroke count and controller’s runtime hours) will be captured and tracked on a monthly basis to ensure consistent oversight of the data is occurring. The monthly data tracking will be accumulated and reviewed under the Quality Assurance/Quality Control measures defined in

Section 3.5.2.

3.2 Baseline and Project Condition

The baseline condition is defined as the release of natural gas from pneumatic instruments (pumps and controllers) at the Proponent’s oil and gas sites through gas pneumatic device activity. Natural gas that supplies pneumatic power primarily consists of methane, therefore in

baseline condition methane is the primary source of GHG emissions. Process flow diagram, similar to what has been included in the Protocol, for a typical baseline using natural gas to provide pressure to pneumatic devices is shown in Figure 4.

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Figure 4: Baseline process flow diagram, "Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices”, January 25, 2017

The project condition is defined as the continuation of oil and gas production at the sub-project sites with electric pumps, low bleed controllers, and vent gas capture that are zero/low vent devices providing the same process control and operational functions that were provided by their higher venting predecessors.

Project emissions are calculated based on the protocol requirements for all sub-projects and are

described below. Process flow diagram, similar to what has been included in the Protocol, for a typical project condition is shown in Figure 5.

Total estimated baseline and project emissions from the three project components are approximately 51,100 and 8,770 tonnes of CO2e respectively.

B1 Raw Gas

Production

B2 Raw Gas

Transportation

B3 Raw Gas

Processing

B4 Processed Gas Distribution

& Sale

B5 Fuel / Supply Gas for

Processes

Pneumatic Devices

B7 Baseline

Vented Gas

B8 Uncaptured

Fuel Gas

B9 Electricity

Usage

B12 Construction

on Site

B10 Fuel Extraction/ Processing

B11 Fuel

Delivery

B15 Transportation of

Equipment

B16 Commissioning

B6 Site

Decommissioning

B13 Development

of Site

B14 Building

Equipment Included sources/sinks

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Figure 5: Project process flow diagram, "Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices”, January 25, 2017

Details of the individual project component are discussed below.

Project Component #1 – Pneumatic Pump Electrification

The baseline condition for pneumatic pump electrification is defined as the release of natural gas from pneumatic chemical injection pumps at the Proponent’s oil and gas sites through gas

pneumatic device activity. As outlined in the Table 2 Description of Baseline Types in the Protocol, for pneumatic pump conversion:

Projection based baselines for the electrification are the most accurate because they measure the pump activity and project this to the baseline. Reliable projections can be

made on the volume of natural gas that would have been released in the absence of the project based on the pump stroke count in the project condition.

In accordance with the protocol, GHG emissions from chemical injection pumps that would occur from B7 Baseline Vented Gas, if the project was not carried out, is estimated to be 600

tonnes of CO2e over the crediting period.

Currently there are two solar powered methanol injection pumps at the Project Proponent facilities located at 13-18-39-8W5. Based on the Proponent’s development plan, there is no

P1 Raw Gas

Production

P2 Raw Gas

Transportation

P3 Raw Gas

Processing

P4 Processed Gas Distribution &

Sale

P5 Fuel / Supply Gas for

Facility

Pneumatic / Electric Devices

P6

Air Compression

P9 Fuel Extraction/ Processing

P11 Construction

on Site

P10 Fuel

Delivery

P14 Transportation of

Equipment

P15 Testing of Equipment

P16 Site

Decommissioning

P12 Development

of Site

P13 Building

Equipment

Air Compression

P7 Project Vented

Gas

P8 Process Control

Electricity

P17 Vent Gas Capture

Included sources/ sinks

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plan of installing new solar pumps over the crediting period1. To estimate the emissions during the offset crediting period, the following parameters are taken into account:

• Pump make and model (Project condition: General Magnetic International, 300-2M-

910A-001, Baseline condition: Texsteam 5100)

• Pump plunger size (Pumps are assumed to have a plunger size of 3/8”)

• Pump stroke length (Pumps are assumed to have a full stroke length)

• Injection pressure (the pressure which the liquid is pumped in the process)

• Stroke counts (if not available, volume of chemical injected)

• Methane and carbon dioxide composition in fuel gas

In the project condition, electric driven chemical injection pumps replace the pneumatically driven pumps. The actual pump mechanism is not changed to ensure functional equivalency. Maintaining functional equivalence while improving monitoring capabilities allow for the baseline condition to be accurately calculated regardless of changes to operating practices.

For the solar pumps, in the project condition, all the energy required to actuate the pump is generated from renewable solar energy and thus the emissions for operating the process controller is zero.

In accordance with the protocol, GHG emissions from chemical injection pumps that would occur from P7 Baseline Vented Gas, if the project was not carried out, is estimated to be zero

tonnes of CO2e over the crediting period.

Project Component #2 – Pneumatic Controller High to Low Conversions

The baseline condition for converting high- to low-bleed controllers is defined as the continued use of high-bleed devices, Fisher 4150 pressure controllers, Fisher L2 level controllers and i2P-100 transducers, with compressed natural gas that results in venting methane and carbon dioxide emissions into the atmosphere. Vented gas emissions at baseline conditions are quantified according to B7 emission source using either site-specific emission factors (if available) or vent rates provided in GPE PTAC level controller report [3] or protocol Appendix C (Table C2). This study has generated emission factors for Fisher L2 level controllers that are beyond the requirements of the Alberta Pneumatic Offset Protocol.

In accordance with the Protocol, GHG emissions from high-bleed controllers that would occur from B7 Baseline Vented Gas, if the project was not carried out, is estimated to be 49,000 tonnes of CO2e over the crediting period.

Based on the Proponent’s development plan, it is expected that 79 pressure controllers, 120 level controllers and 16 i2P transducers will be converted from 2019 until 2022. In the Project condition, 79 low bleed Fisher C1 (or fewer depending how many are replace by a valve), 120 low-bleed Fisher L2-LG level controllers and 16 i2P transducers with improved relay will be used at the Proponent’s facilities which will lead to vented gas emissions at the Project condition. Similar to Baseline calculations, vent rates provided in GPE PTAC level controller report [3], or site-specific emission factors (if available) or protocol Appendix C (Table C2) will be used to estimate Project emissions.

In accordance with the Protocol, GHG emissions from low-bleed pressure and level controllers at Project conditions from P7 Project Vented Gas is estimated to be 8,000 tonnes of CO2e over the crediting period.

1 This may change over the offset crediting period time and the Project Proponent will make sure that changes will be tracked according to the protocol’s requirement.

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Project Component #3 – Vent Gas Capture

The baseline condition for this project component is where no vent gas capture occurs at the Project Proponent’s facilities, namely all venting from pneumatic pumps is directed to the atmosphere. For well sites that have buildings on site, additional fuel gas is needed and is supplied from wells to be used in the Catadyne heaters to warm up the internal building space during the cold weather. In the project condition, the previously vented gas from pumps are directed via piping to the Catadyne heater, eliminating the need for their supply fuel gas.

To estimate the baseline emissions for vent gas capture systems, the Projection Based, Option ‘1’ In Table 2: Description of Baseline Types on page 13 of the Protocol, has been used. As explained in the Protocol, projection-based baselines for vent gas capture from pumps at greenfield/brownfield sites are the most accurate because they measure actual emission activity and project this to the baseline. Reliable projections can be made on the volume of natural gas that would have been released in the absence of the project based on the volume of gas

captured in the project. In accordance with the protocol, GHG emissions from vent gas capture systems that would occur from B8 Uncaptured Fuel Gas, if the project was not carried out, is estimated to be equal to 1,500 tonnes of CO2e over the crediting period.

To determine the baseline emissions, the following parameters have been taken into account:

• Operation hours

• Load of the combustion device

• Fuel consumption rate of combustion device

• Methane and carbon dioxide composition in fuel gas

• Discount rate (as described in section 2.2)

To estimate the project emission for vent gas capture systems, the Project Proponent is following the approach that is described in the protocol. In accordance with the protocol, GHG emissions from vent gas capture systems that would occur from P17 Vent Gas Capture and P9 Fuel Extraction and Processing in the project condition is estimated to be 770 tonnes of CO2e over the crediting period.

Same parameters that were considered in the baseline condition are taken into account in the project condition. This is because the value of captured gas in the project condition is the same as the uncaptured vented gas in the baseline condition (i.e. Assuming all that is captured in the baseline condition is combusted in the project condition).

The install dates of vent gas capture systems included in the Project are from 2015. As such, it is expected that the service lifetimes of the project activities will exceed that of the credit

duration period.

3.3 Quantification Plan

The quantification of reductions of relevant sources of greenhouse gases has been completed according to the methods outlined in Section 3.1 of the Quantification Protocol for Greenhouse

Gas Emission Reductions from Pneumatic Devices” Version 2.0 (January 2017). As outlined previously, certain sources and sinks have been excluded where not applicable, and the remaining are presented in the Table 6 below:

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Table 6: Quantified Sources and Sinks

SS Related project/baseline activities

On Site SS

B7 Vented Fuel Gas

The quantity of gas vented in the baseline condition has a direct impact on the emissions reduction quantification for solar electrification (Project component #1), controller conversions (Project component #2), instrument air to instrument gas conversion projects (Project component #3).

B8 Uncaptured Fuel Gas

The quantity of gas vented in the baseline has a direct impact on the emissions reduction quantification for vent gas capture projects (Project component #4).

P7 Project Vented Gas

Pneumatic devices will vent greenhouse gases to the atmosphere as part of regular operations. This source will be zero when pneumatic devices are converted to instrument air (Project component #3) or solar-electric devices (Project component #1). The low or non-venting pneumatic devices in the project will reduce emissions as part of normal operations compared to high-venting pneumatic devices (Project component #2).

P17 Vent Gas Capture

The quantity of vent gas captured in the project will need to be tracked and has a direct impact on the emissions reduction quantification for vent gas capture projects.

Upstream Sources and Sinks

P8 Process Control Electricity

Electric pumps, valves or controllers can use grid electricity as part of regular operations. Electric controls will generate fewer emissions compared to venting pneumatic devices. This source will be zero when projects are converted to air or solar power.

P9 Fuel Extraction/ Processing

Each of the fuels used throughout the project will need to be sourced and processed. This will allow for the calculation of greenhouse gas emissions from the various processes involved in the production, refinement, and storage of the fuels. The total volumes of fuel for each of the sources / sinks in this project are considered in this source / sink. Types and quantities of fuels used would need to be tracked.

For each relevant SS above, quantification methods to be used to calculate the GHG emissions for the project and baseline are detailed. The methods are based on those provided in the

protocol. In addition, the method used to track each emission source and sink is explained in detail.

The Project Proponent will make use of Protocol Flexibility Mechanism #1 as mentioned in section 2.2. Various subprojects including the installation of solar electric pumps, conversion of high-bleed pneumatic controllers, and installation of vent gas capture equipment are aggregated under one project plan. The quantification method explained in the following

sections apply to all subprojects under each component of the offset project.

The project proponent may or may not make use of Protocol Flexibility Mechanism #3 and Mechanism #4 as mentioned in section 2.2. Project component #1, pneumatic pump electrification, may use the volume of chemical injected to determine the volume of gas vented in the baseline if pump stroke count is not available. As stated in the Protocol’s appendix C:

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The pump emission factor is referenced from manufacturer specifications. At a given supply pressure and injection pressure, a pump will consume and vent a known volume of gas for

each stroke or volume of chemical injected. In the absence of a known stroke count, Project Proponents can use the volume of chemical injected to determine the volume of gas vented in the baseline, as per Flexibility Mechanism 4.

For the project component #2, Pneumatic Controller High to Low Conversions, the Project Proponent is using historical benchmarks, where possible. A historical benchmark in the

protocol is defined as using vent measurements from devices prior to the conversion. Where the historical benchmark approach is not available due to lack of field measurements, the protocol vent rates are used based on manufacturer specifications according to representative sample of similar sites (constructed by the Proponent after Jan1, 2012). The Project Proponent will be using either the Historic Benchmark or Performance Standard Baseline Type for level controllers baseline emissions estimates depending on the availability of vent measurements prior to conversion.

For project component #3, vent gas capture, the Projection Based approach to baseline quantification will be used. Projection based baselines for vent gas capture from pumps at greenfield/brownfield sites are the most accurate because they measure actual emission activity and project this to the baseline. Reliable projections can be made on the volume of natural gas that would have been released in the absence of the project based on the volume of gas captured in the project.

Equation 1: Emissions Reduction Equation:

Emissions Reductions = Emissions Baseline - Emissions Project

3.3.1 Project Component #1 – Pneumatic Device Electrification

Emissions Baseline = [Emissions Baseline Vented Gas (SS B7)]

Emissions Project = [ Emissions Project Vented Gas (p7) + Emissions Fuel Extraction / Processing (P9) + Emissions

Process Control Electricity (P8)]

EMISSIONS BASELINE

Emissions Baseline = Emissions Baseline Vented Gas (SS B7) = Ʃj (Vented Gas Baseline, j * %CH4 *ρ CH4 /

1000) * GWPCH4 + Ʃj (Vented Gas Baseline, j * %CO2 * ρ CO2/1000)

Where:

Vented Gas Baseline = Strokes j * EF Pump Type j (for converting pumps to non-venting equivalents)

%CH4 – is the methane composition of the fuel gas [%]

ρCH4 – is the density of methane [kg/m3]

%CO2 – is the carbon dioxide composition of the fuel gas [%]

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ρ CO2 – is the density of carbon dioxide [kg/m3]

GWPCH4 – is the Global Warming Potential of methane as indicated in Table A of reference [4].

Strokes are quantified using the stroke counters on all current pumps. Emission Factors of the pumps are based on manufacturer specifications and depend on the following:

• Pump injection pressure2

• Pump plunger size

• Pump stroke length

In the absence of stroke counts, as allowed by the Protocol, the Project Proponent will use the volume of injected chemicals to calculate the vented gas.

Methane and carbon dioxide compositions are obtained from gas analysis performed on sites

where a subproject is located.

EMISSIONS PROJECT

Emissions Project = [ Emissions Project Vented Gas (p7) + Emissions Process Control Electricity (P8) + Emissions Fuel

Extraction / Processing (P9)]

Where:

Emissions Project Vented Gas (p7) = 0 (for all solar electric pumps)

Emissions Process Control Electricity (P8) = 0 (Solar electricity generation provide zero emission)

Emissions Fuel Extraction / Processing (P9) = 0 (for all electric pumps as there is no fuel combustion to generate power)

Since solar panels are used on site to generate electricity for electric pumps, no fuel is combusted in the project condition and therefore, zero emission is generated as a result of fuel combustion. The Project is powered by solar energy and does not have additional electricity emissions compared to the baseline condition.

Sample Calculation

Sample Input Data

• %CH4 = 90%

• ρCH4 = 0.678 [kg/m3]

• %CO2 = 1 %

• ρ CO2 = 1.86 [kg/m3]

• GWPCH4 = 25

• Pump injection pressure = 500 PSI

• Pump plunger size = 3/8" = 0.375 inch

• Pump stroke length = Full =1" = 1 inch

• Stroke count (provided by the meters on the pump) = 100,000

• Manufacturer emission factor @500 PSI & Stroke length of 1” & Plunger size of 3/8"

= 0.071 Scf NG/stroke

2 The Protocol suggests using actual injection pressures to find relevant emission factors. The Project Proponent, however, rounds down the pressures on 100 PSI intervals. The result is immaterial.

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Emissions Baseline = Emissions Baseline Vented Gas (SS B7)

Vented Gas Baseline = 0.071 scf/stroke * 100,000 stroke/month = 7,100 ft3 NG/month

Emissions Baseline = Emissions Baseline Vented Gas (SS B7) = Ʃj (Vented Gas Baseline, j * %CH4 *ρ CH4 /

1000) * GWPCH4 + Ʃj (Vented Gas Baseline, j * %CO2 * ρ CO2/1000)

Emissions Baseline = (7100 ft3 NG/month * 0.9 * 0.675 kg/m3 * 0.0283168 m3 / ft3 * 0.001 Ton/Kg ) * 25 + (7100 ft3 NG/month * 0.01 * 1.86 kg/m3 * 0.0283168 m3 / ft3 * 0.001

Ton/Kg ) = 3.06 + 0.004 = 3.06 T CO2e/month

Emissions Project Vented Gas (p7) = 0

Emissions Fuel Extraction / Processing (P9) = 0

Emissions Process Control Electricity (P8) = 0

Emissions Project = 0 + 0 + 0 =0 T CO2e/month

Emission Reduction = Sum Emissions Baseline – Sum Emissions Project = 3.06 - 0.00 =3.06 T CO2e/month

3.3.2 Project Component #2 – Pneumatic Controller High to Low

and High to no-bleed Conversions

Emissions Baseline = [Emissions Baseline Vented Gas (SS B7)]

Emissions Project = [ Emissions Project Vented Gas (P7) + Emissions Fuel Extraction / Processing (P9) + Emissions

Process Control Electricity (P8)]

EMISSIONS BASELINE

Emissions Baseline = Emissions Baseline Vented Gas = Ʃj (Vented Gas Baseline, j * %CH4 *ρ CH4 / 1000) *

GWPCH4 + Ʃj (Vented Gas Baseline, j * %CO2 * ρ CO2/1000)

Where:

Vented Gas Baseline = Op. Hrs.j * (Qbaseline, j)

Qbaseline, j = Q Direct measurements j

Or

Qbaseline, j = Q Average Controller type j

%CH4 – is the methane composition of the fuel gas [%]

ρ CH4 – is the density of methane [kg/m3]

%CO2 – is the carbon dioxide composition of the fuel gas [%]

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ρ CO2 – is the density of carbon dioxide [kg/m3]

GWPCH4 – Global Warming Potential of methane as indicated in Table A of reference [4]

Op. Hrs.j – is the operating hours [hrs]

Q Direct measurement– is the measured vent rate of high vent level controller [m3/hr]

Q Average Controller type j - is the average measurement sample of vent rate of high vent level controller [m3/hr]

The Project Proponent is using direct measurements of vent rates from pressure and level controllers with high vents prior to the conversions. In case the direct measurement of vent rates of high vent controllers is not available, average measurement sample of vent rate of high vent level controller will be used. These values will be used and get multiplied by the operating hours of the controllers to calculate the vented gas volumes in the baseline condition. Operating hours of the controllers are tracked by the flow meters installed on site.

Methane and carbon dioxide compositions are obtained from gas analysis performed on sites where a subproject is located.

EMISSIONS PROJECT

Emissions Project = [ Emissions Project Vented Gas (p7) + Emissions Process Control Electricity (P8) + Emissions Fuel

Extraction / Processing (P9)]

For high to no-bleed conversions:

Emissions Project Vented Gas (p7) = 0

For high to low conversions:

Emissions Project Vented Gas (p7) = Ʃj (Vented Gas Project, j * %CH4 *ρ CH4 / 1000) * GWPCH4 + Ʃj

(Vented Gas Project, j * %CO2 * ρ CO2/1000)

Where:

Vented Gas Project = Op. Hrs.j * (Qproject, j)

Qproject, j = Q Direct measurements j

Or

Qproject, j = Q Average Controller type j

%CH4 – is the methane composition of the fuel gas [%]

ρCH4 – is the density of methane [kg/m3]

%CO2 – is the carbon dioxide composition of the fuel gas [%]

ρ CO2 – is the density of carbon dioxide [kg/m3]

GWPCH4 – Global Warming Potential of methane as indicated in Table A of reference [4].

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Op. Hrs.j – is the operating hours [hrs]

Q Direct measurements j - is the measured vent rate of low vent level controller [m3/hr]

Q Average Controller Type– is the average measurement sample of vent rate of low vent level controller [m3/hr]

The Project Proponent is using direct measurements of vent rates from pressure and level controllers with low vents after to the conversions. If not available, similar to baseline, average values will be used. These values will be used and get multiplied by the operating ours of the

controllers to calculate the vented gas volumes in the project condition. Operating hours of the controllers are tracked by the flow meters installed on site.

Methane and carbon dioxide compositions are obtained from gas analysis performed on sites where a subproject is located.

Emissions Process Control Electricity (P8) = 0

The P8 process control electricity is estimated to be zero as there is no electricity consumption by the pressure and level controllers in the project condition.

Emissions Fuel Extraction / Processing (P9) = Σj(Vol. Fuel i × EFi,CO2 / 1000) + Σj (Vol. Fuel i × EFi,CH4 / 1000) × GWPCH4 + Σj (Vol. Fuel i × EFi,N2O / 1000) × GWPN2O

Where:

Vol. Fuel i – Vented gas in project condition/ Vol. Fuel = Vented gas obtained in P7 Project

Vented Gas [m3]

EFi,CO2 - is the CO2 Emissions Factor for Extraction and Processing for each fuel, as indicated in Table 3 of the Handbook [5] [kg CO2/m

3]

EFi,CH4 - is the CH4 Emissions Factor for Extraction and Processing for each fuel, as indicated in Table 3 of the Handbook [5] [kg CO2/m

3]

EFi,N2O- is the N2O Emissions Factor for Extraction and Processing for each fuel, as indicated in Table 3 of the Handbook [5] [kg CO2/m

3]

GWP CH4/N2O – are global warming potentials of methane and nitrous oxide as indicated in Table A of reference [4]. Fuel volume will be obtained as explained in SS P7 above. Emission factors are obtained

from Carbon Offset Emission Factors Handbook [5].

Sample Calculation

Sample Input Data

• %CH4 = 90%

• ρ CH4 = 0.678 [kg/m3]

• %CO2 = 1 %

• ρ CO2 = 1.86 [kg/m3]

• GWPCH4 = 25

• GWPN2O = 298

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• Operating hours of controllers = 22 hours/d * 30 days/month = 660 hr/month

• Qbaseline = Q Direct Measurement before conversion= 31.1 scf/hr

• Qbaseline = Q Direct Measurement after conversion= 3.53 scf/hr

• EF Fuel, CO2 =2380 g CO2/m3

• EF Fuel, CH4 = 6.4 g CH4/m3

• EF Fuel, N2O =0.06 g N2O/m3

• EFi,CO2 (Natural Gas Extraction and Processing)=0.043+0.090 = 0.133 kg CO2/m3

• EFi,CH4 (Natural Gas Extraction and Processing)=0.0023 + 0.0003= 0.0025 kg CH4/m3

• EFi,N2O (Natural Gas Extraction and Processing)= 0.000004+0.000003 = 0.000007 kg N2O/m3

Emissions Baseline = Emissions Baseline Vented Gas (SS B7)

Vented Gas Baseline = Op. Hrs. * Qbaseline= 660 hr/month * 31.1 scf/hr = 20,526 scf/month

Emissions Baseline = Emissions Baseline Vented Gas = Vented Gas Baseline * %CH4 *ρ CH4 / 1000) * GWPCH4 + Vented Gas Baseline * %CO2 * ρ CO2/1000)

Emissions Baseline = (20,526 NG/month * 0.9 * 0.675 kg/m3 * 0.0283168 m3 / ft3 * 0.001 Ton/Kg ) * 25 + (20,526 NG/month * 0.01 * 1.86 kg/m3 * 0.0283168 m3 / ft3 * 0.001 Ton/Kg ) = 8.83 + 0.01 = 8.84 T CO2e/month

Emissions Project = Emissions Project Vented Gas (p7) + Emissions Fuel Extraction / Processing (P9) + Emissions Process Control Electricity (P8)

Emissions Project Vented Gas (p7) = Ʃj (Vented Gas Project, j * %CH4 *ρ CH4 / 1000) * GWPCH4 + Ʃj

(Vented Gas Project, j * %CO2 * ρ CO2/1000)

Vented Gas Project = Op. Hrs. * Qbaseline= 660 hr/month * 3.53 scf/hr = 2,329 scf/month

Emissions Project Vented Gas (p7) = (2,329 NG/month * 0.9 * 0.675 kg/m3 * 0.0283168 m3 / ft3 * 0.001 Ton/Kg ) * 25 + (2,329 NG/month * 0.01 * 1.86 kg/m3 * 0.0283168 m3 / ft3 *

0.001 Ton/Kg ) = 1.001 + 0.001 = 1.00 T CO2e/month

Emissions Process Control Electricity (P8) = 0

Emissions Fuel Extraction / Processing (P9) = Σj(Vol. Fuel i × EFi,CO2 / 1000) + Σj (Vol. Fuel i × EFi,CH4 / 1000) × GWPCH4 + Σj (Vol. Fuel i × EFi,N2O / 1000) × GWPN2O

Emissions Fuel Extraction / Processing (P9) = 2,329 m3/month * 0.133 kg CO2/m3 / 1000 + 2,329

m3/month * 0.0025 kg CH4/m3 /1,000 *25 GWPCH4 + 2,329 m3/month * 0.000007 kg

N2O/m3 /1,000 *298 GWPN2O = 0.013 T CO2e/month

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Emissions Project = 1.002 + 0.013 + 0 =1.015 T CO2e/month

Emission Reduction = Sum Emissions Baseline – Sum Emissions Project = 8.84 - 1.015 =7.825 T CO2e/month

3.3.3 Project Component #3 – Vent Gas Capture

Emissions Baseline = [Emissions Uncaptured Fuel Gas (SS B8)]

Emissions Project = [Emissions Vent Gas Capture(P17) + Emissions Fuel Extraction / Processing (P9)]

EMISSIONS Uncaptured Fuel GAS (SS B8)

Emissions Baseline = Emissions Uncaptured Fuel Gas (SS B8) = Captured Gas * (1-DR) * %CH4 *ρ CH4 /

1000) * GWPCH4 + Captured Gas* (1-DR) * %CO2 * ρ CO2/1000)

Where

Captured Gas = Op. Hours * Load * Fuel Con. Rate

Op. Hours – is operating hours of device based on continuous measurement of combustion device [hrs]

Load (%) - is one-time reading of %load of fuel combustion device [%]

Fuel Con. Rate – is fuel consumption rate based on manufacturer specification [kg/hr]

DR - Discount rate, determined by Table 7 below according to years since inspection

%CH4 – is the methane composition of the fuel gas [%]

ρCH4 – is the density of methane [kg/m3]

%CO2 – is the carbon dioxide composition of the fuel gas [%]

ρ CO2 – is the density of carbon dioxide [kg/m3]

GWPCH4 – Global Warming Potential of methane as indicated in Table A of reference [4].

The project proponent will track operating hours of the combustion device and use it in the calculation. Device load and fuel consumption rate are obtained from the combustion device

manufacturer specifications and device operating data.

Table 7: Discount rate determination for instrument air projects, as per Appendix A of the Protocol

Years since inspection Discount Rate (DR)

0 0

1 to 10 0.025 * Years since

inspection >10 0.25

EMISSIONS PROJECT

Emissions Project = [ Emissions Vent Gas Capture(P17) + Emissions Fuel Extraction / Processing (P9)]

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Emissions Vent Gas Capture (P17) = Captured Gas *DE* EF Fuel CO2 / 1,000,000 +

Captured Gas *DE* EF Fuel CH4 * GWPCH4/ 1,000,000 +

Captured Gas * EF Fuel N2O * GWPN2O / 1,000,000 +

Captured Gas * (1-DE) * GWPCH4 * %CH4 * ρCH4 / 1,000,000

Where

Captured Gas = Op. Hours * Load * Fuel Con. Rate

Op. Hours – is operating hours of device based on continuous measurement of combustion device [hrs]

Load (%) - is one-time reading of %load of fuel combustion device [%]

Fuel Con. Rate – is fuel consumption rate based on manufacturer specification [kg/hr]

DE - Destruction efficiency of combustion, as per manufacturer specifications, or 60% for Catadyne heaters as per pg. 62 in Appendix C of the Protocol

%CH4 – is the methane composition of the fuel gas [%]

ρCH4 – is the density of methane [kg/m3]

%CO2 – is the carbon dioxide composition of the fuel gas [%]

ρ CO2 – is the density of carbon dioxide [kg/m3]

GWPCH4 – Global Warming Potential of methane as indicated in Table A of reference [4]

EF Fuel - Emission factor for captured gas combustion, as per Table 5 of the Handbook [5]

[g/m3]

The project proponent will track operating hours of the combustion device and use it in the calculation. Device load and fuel consumption rate are obtained from the combustion device manufacturer specifications and device operating data.

Emissions Fuel Extraction / Processing (P9) = Σj(Vol. Fuel i × EFi,CO2 / 1000) + Σj (Vol. Fuel i × EFi,CH4 / 1000) × GWPCH4 + Σj (Vol. Fuel i × EFi,N2O / 1000) × GWPN2O

where

Vol. Fuel i - Fuel i Combusted in the Project / Vol. Fuel = Captured Gas obtained in P17 Vent gas capture [m3]

EFi,CO2 - is the CO2 Emissions Factor for Extraction and Processing for each fuel, as indicated in Table 3 of the Handbook [5] [kg CO2/m

3]

EFi,CH4 - is the CH4 Emissions Factor for Extraction and Processing for each fuel, as indicated

in Table 3 of the Handbook [5] [kg CH4/m3]

EFi,N2O- is the N2O Emissions Factor for Extraction and Processing for each fuel, as indicated in Table 3 of the Handbook [5] [kg N2O/m3]

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GWP CH4/N2O – Are global warming potentials of methane and nitrous oxide as indicated in Table A of reference [4]

Sample Calculation

Sample Input Data

• %CH4 = 90%

• ρCH4 = 0.678 [kg/m3]

• %CO2 = 1 %

• ρ CO2 = 1.86 [kg/m3]

• GWPCH4 = 25

• GWPN20 = 298

• Op. Hours =24 hours/d * 30 days/month = 720 hrs/month

• Load =52.5%

• Fuel Con. Rate =10.2 m3/d

• DE = 60%

• DR =0.025

• EF Fuel, CO2 =2380 g CO2/m3

• EF Fuel, CH4 = 6.4 g CH4/m3

• EF Fuel, N2O =0.06 g N2O/m3

• EFi,CO2 (Natural Gas Extraction and Processing)=0.043+0.090 = 0.133 kg CO2/m3

• EFi,CH4 (Natural Gas Extraction and Processing)=0.0023 + 0.0003= 0.0025 kg CH4/m3

• EFi,N2O (Natural Gas Extraction and Processing)= 0.000004+0.000003 = 0.000007 kg N2O/m3

• Captured Gas = 720 hrs/month * 52.5% * 10.2 m3/d / 24 hr/d = 160.65 m3/month

Emissions Baseline = Emissions Uncaptured Fuel Gas (B8) = Captured Gas * (1-DR) * %CH4 *ρ CH4 /

1000) * GWPCH4 + Captured Gas* (1-DR) * %CO2 * ρ CO2/1000

Emissions Uncaptured Fuel Gas (B8) = (160.65 m3/month * (1-0.025) *90% CH4 * 0.678 kg/m3 /1000) *25 GWPCH4 + (160.65 m3/month * (1-0.025) *1% CO2 * 1.86 kg/m3 /1000) = 2.389 T

CO2e/month

Emissions Project = [ Emissions Vent Gas Capture(P17) + Emissions Fuel Extraction / Processing (P9)]

Emissions Vent Gas Capture (P17) = Captured Gas *DE* EF Fuel CO2 / 1,000,000 +

Captured Gas *DE* EF Fuel CH4 * GWPCH4/ 1,000,000 +

Captured Gas * EF Fuel N2O * GWPN2O / 1,000,000 +

Captured Gas * (1-DE) * GWPCH4 * %CH4 * ρCH4 / 1,000,000

Emissions Vent Gas Capture (P17) =160.65 m3/month * 0.6 * 2380 g CO2/m3/1000000 + 160.65

m3/month * 0.6 * 6.4 kg CH4/m3 *25 GWPCH4/1,000,000 + 160.65 m3/month * 0.6 *0. 06 g

N2O/m3 *298 GWPN2O/1,000,000 + 160.65 m3/month *(1- 0.6) *25 GWPCH4 *90% CH4 * 0.678 kg/m3 /1000000 = 0.248 T CO2e/month

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Emissions Fuel Extraction / Processing (P9) = Σj(Vol. Fuel i × EFi,CO2 / 1000) + Σj (Vol. Fuel i × EFi,CH4 / 1000) × GWPCH4 + Σj (Vol. Fuel i × EFi,N2O / 1000) × GWPN2O

Emissions Fuel Extraction / Processing (P9) = 160.65 m3/month * 0.133 kg CO2/m3 / 1000 + 160.65

m3/month * 0.0025 kg CH4/m3 /1,000 *25 GWPCH4 + 160.65 m3/month * 0.000007 kg N2O/m3

/1,000 *298 GWPN2O = 0.032 T CO2e/month

Emissions Project =0.248 + 0.032 = 0.28 T CO2e/month

Emission Reduction = Sum Emissions Baseline – Sum Emissions Project = 2.389 - 0.28 =2.109 T CO2e/month

3.4 Monitoring Plan

The primary parameters used to calculate emission offsets from the Project are pumps emission rates, the volume of chemical injected (or stroke counts), injection pressures, the high and low bleed controller vent rates, facility and equipment operating hours, gas composition analyses, load, and fuel consumption rate and destruction efficiency of combustion devices.

The pump information is gathered at individual pump level and the emission factors are obtained manually from manufacturer specification. To complete the quantification of emission

reductions, the gas injection pressures are also considered.

For level and pressure controllers, pre and post conversions manufacturer specified vent rates are used. The operating hours of each controller are estimated based on facility production data and runtime hours. Facility production data (e.g. run time of the wells flowing) is tracked electronically on a continuous basis and provides sufficient means to estimate the operating hours of pneumatic controllers at each site. Where applicable, additional data, such as

downtime events and maintenance records, related to specific process units will be retrieved to better estimate operating hours at the controller level.

For vent gas capture systems, captured gas is estimated by knowing the load, fuel consumption rate and operating hours of Catadyne heaters. Gas composition analysis, which is used for all project types, are generally collected on an annual basis by a third-party lab for all sales gas and fuel gas streams. Copies of these analyses are provided to the Project Proponent and the lab maintains a database of records.

For the 1st project component, the calculation of baseline emissions under B7 and project emissions under P8 are performed by using the manufacturer vent rates for pumps, the volume of chemical injected or stroke counts, and injection pressure and the percent methane and CO2 in the instrument gas (fuel gas or sales gas) at each facility. The methane and CO2 % are

obtained from annual gas analyses at each site and this data is entered into the calculation spreadsheet annually. Strokes or volume of chemical injected as well as injection pressures are tracked at the pump level.

For the 2nd project component, the calculation of baseline emissions under B7 and project emissions under P7 are performed by using the direct vent rates for each controller, the operating hours of each facility, and the percent methane and CO2 in the instrument gas (fuel

gas or sales gas) at each facility. Similar to the first component, methane and CO2 % are obtained from annual gas analyses at each site and this data is entered into the calculation spreadsheet annually. Operating hours are tracked at the facility.

For the 3rd project component the calculation of baseline emissions under B8 and project emissions under P17 and P9 are performed by using the load, fuel consumption rate and

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operating hours of Catadyne heaters, and the percent methane and CO2 in the vented captured gas at each facility.

For both of the project components, prior to verification, the direct vent rates, operating hours,

and gas composition percentages, manufacturer vent rates, volume of chemicals and injection pressures and other project parameters are manually input into a summary spreadsheet to aggregate emission reductions for each reporting period.

The net GHG emission reductions are then calculated based on the difference between the baseline and project emissions.

Table 8 through Table 10 below describe how the parameters will be monitored in the Project. All measured parameters will be tracked and documented based on the Project Proponent Data Management System. For more on this system please refer to section 3.5 below.

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Project Component #1 – Pneumatic Pump Electrification

Table 8: Monitoring plan and data sources for pump electrification

SS Identifier

and Name

Parameter/

Variable Unit

Measured/

Estimated Method

Source /

Origin Frequency Uncertainty

Justify Measurement or

Estimation and Frequency

B7 Baseline

Vented Gas

Emissions Baseline Vented Gas = Ʃj (Vented Gas Baseline, j * %CH4 *ρ CH4 / 1000) * GWPCH4 + Ʃj (Vented Gas Baseline, j * %CO2 * ρ

CO2/1000)

Where Vented Gas

=Stroke Count * EF Pump Type j (for converting pumps to non-venting equivalents)

Or

=Volume of chemical injected * EF Pump Type j (for converting pumps to non-venting equivalents)

Emissions Baseline Vented Gas

tonnes of, CO2e

N/A N/A N/A N/A N/A

As per protocol: Quantity being

calculated in aggregate form as

fuel use is different for each site.

Volume of Vented Gas Emitted by Pneumatic Device / Vented Gas baseline

m3 Calculated

Method provided in equations above

N/A Per report N/A As per protocol: Intermediary quantity being calculated.

Pump Strokes / Strokes

- Measured Direct

measurement

Measured at

pump level Continuous

Direct measurement results in low uncertainty.

Continuous counting is the highest frequency of monitoring possible.

Volume of chemical injected

Litre or

M3 Measured

Direct

measurement

Measured at

pump level Continuous

Direct measurement results in low uncertainty.

Continuous counting is the highest frequency of monitoring possible.

Pump Emission Factor / EF Pump Type

SCF of

NG/Gallon

of

Chemical

Injected

Estimated

See Appendix

C,

Manufacturer’

s vent gas

per volume of

injected

See Appendix C,

Manufacturer’s

vent gas per

volume of

injected

chemicals table

Annual

Based on manufacturer specifications or published emission factors. Use of emission

Annual estimates in consideration of changes to injection pressure provide sufficient confidence in emission rates, and manufacturer specifications are conservative estimates.

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chemicals

table

factors from the Protocol or published values from manufacturer specifications results in low uncertainty.

Values were gathered from the Manufacturers specifications and compiled in a table based on pump specifications such as plunger size, stroke length and injection pressure.

Methane Composition in Vented Gas / % CH4

% Measured

Direct

measurement

from

accredited

references of

industry

standards

Direct samples

of fuel gas taken

annually by third

party.

Annual N/A

Fuel gas composition should remain relatively stable during steady-state operation. Estimating gas composition from accredited references provides a reasonable estimate when the more accurate method cannot be used.

Carbon Dioxide Composition in Vent Gas / % CO2

% Measured Direct

measurement

Direct samples of fuel gas taken annually by third party.

Annual N/A Fuel gas composition should remain relatively stable during steady-state operation.

Density of Methane / ρCH4

kg/m3 Estimated

Reference

value

correspondin

g to

conditions at

which

volumes are

reported

0.678 kg/m3

at STP

N/A N/A N/A

As per protocol: If this value is used all values must be adjusted for standard temperature and pressure (STP).

Density of Carbon Dioxide / ρCO2

kg/m3 Estimated

Reference

value

correspondin

g to

conditions at

N/A N/A N/A

As per protocol: If this value is used all values must be adjusted for standard temperature and pressure (STP).

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which

volumes are

reported

GWP CO2, CH4, N2O Global Warming Potential

Unitless Estimated

Provided in Carbon Offset Emission Factors Handbook

N/A N/A N/A

The Project Proponent uses the most current factors published in the Carbon Offset Emission Factors Handbook.

P8 Process control electricity

Emissions Electric Process Control = Electricity Process Control * EF Elec Supply / 1000

Emissions

Electric Process

Control

tonnes of

CO2e N/A N/A N/A N/A N/A

As per protocol: Quantity being calculated in aggregate form as fuel use is different for each site.

Total Quantity of Electricity Consumed for Control Functions / Electricity

Process Control

kWh Estimated/

Measured

Estimated based on equipment specifications. In the case of renewable electricity generation, the quantity of electricity consumed is not necessary since the emission factor, and emissions will be zero.

Equipment

specifications Per report N/A

Both methods are standard practice. Estimated parameter is standard practice and a conservative overestimation in absence of equipment measurement. If measurement has no impact on emissions, measurement is not necessary.

Emission Intensity Factor for Electricity Consumption / EF Elec Supply

Kg CO2e /

kWh Estimated

Provided in Carbon Offset Emission Factors Handbook

N/A N/A N/A

The Project Proponent uses the most current factors published in the Carbon Offset Emission Factors Handbook.

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Project Component #2 – Pneumatic Level Controller High to Low Conversions

Table 9: Monitoring plan and data sources for level controllers high to low conversions

SS

Identifier

and Name

Parameter/

Variable

Unit Measured/

Estimated

Method Source /

Origin

Frequency Uncertainty Justify Measurement or

Estimation and Frequency

B7

Baseline

Vented

Gas

Emissions Baseline Vented Gas = Ʃj (Vented Gas Baseline, j * %CH4 *ρ CH4 / 1000) * GWPCH4 + Ʃj (Vented Gas Baseline, j * %CO2 * ρ

CO2/1000)

Where Vented Gas

=Op. Hrs. j * Q Baseline j (for converting controllers to lower or non-venting controllers)

Q Baseline j

And Q Baseline, j

= Q Direct Measurement j (for controllers with direct measurement samples)

= Q Average Controller Type j (for controllers with average measurement samples)

= Q Manufacturer Specification j (for controller with no direct measurement or sample statistics)

Emissions Baseline Vented Gas

tonnes of, CO2e

N/A N/A N/A N/A N/A As per protocol: Quantity being

calculated.

Volume of Vented Gas Emitted by Pneumatic Device / Vented Gas baseline

m3 Calculated

Method provided in equations above

N/A Per report N/A As per protocol: Intermediary quantity being calculated.

Methane

Composition

in Vented Gas

/ % CH4

% Measured

Direct

measurement

from accredited

references of

industry

standards

Direct samples

of fuel gas taken

annually by third

party.

Annual N/A

Fuel gas composition should

remain relatively stable during

steady-state operation.

Estimating gas composition from

accredited references provides a

reasonable estimate when the

more accurate method cannot

be used.

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Carbon Dioxide Composition in Vent Gas / % CO2

% Measured Direct

measurement

Direct samples of fuel gas taken annually by third party.

Annual N/A Fuel gas composition should remain relatively stable during steady-state operation.

Density of

Methane /

ρCH4

kg/m3 Estimated

Reference

value

corresponding

to conditions at

which volumes

are reported

0.678 kg/m3 at

STP

N/A N/A N/A

As per protocol: If this value is

used all values must be adjusted

for standard temperature and

pressure (STP).

Density of Carbon Dioxide / ρCO2

kg/m3 Estimated

Reference

value

corresponding

to conditions at

which volumes

are reported

N/A N/A N/A

As per protocol: If this value is

used all values must be adjusted

for standard temperature and

pressure (STP).

Vent Rate of High Vent Control Device / Q baseline

m3 / hr

Measured

or

estimated

Direct

measurement N/A Per report N/A

As per protocol: Value is an

intermediate used for

subsequent calculations, based

on project type.

Measured Vent Rate of Control Device / Q Direct

Measurement

m3 / hr Measured Direct

measurement

Direct

measurement at

the controller

level

Once

Direct

measurement

results in low

uncertainty.

Direct measurement of vent rate

provides high confidence.

Operating Hours / Op. Hrs. j

hrs Measured Direct

measurement

Estimated based

on facility

production data

(gas sales or gas

production) and

Annual N/A Continuous operating time measurement is the highest level possible.

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other operating

records.

GWP CO2, CH4, N2O Global Warming Potential

Unitless Estimated

Provided in Carbon Offset Emission Factors Handbook

N/A N/A N/A

The Project Proponent uses the most current factors published in the Carbon Offset Emission Factors Handbook.

P7 Project Vented Gas

Emissions Project Vented Gas = Ʃj (Vented Gas Project, j * %CH4 *ρ CH4 / 1000) * GWPCH4 + Ʃj (Vented Gas Project, j * %CO2 * ρ

CO2/1000)

Where Vented Gas Project

=Op. Hrs. j * Q Project j (for converting controllers to lower or non-venting controllers)

Q Project j

= Q Direct Measurement j (for controllers with direct measurement samples)

= Q Average Controller Type j (for controllers with average measurement samples)

= Q Manufacturer Specification j (for controller with no direct measurement or sample statistics)

Emissions Vented Gas for Controlled Instruments

tonnes of,

CO2e N/A N/A N/A N/A N/A

As per protocol: Quantity being calculated in aggregate form as fuel use is different for each site.

Volume of Vented Gas Emitted by Pneumatic Device / Vented Gas Project

m3 Calculated

Method provided in equations above

N/A Per report N/A As per protocol: Intermediary quantity being calculated.

Methane Composition in Vented Gas / % CH4

% Measured

Direct measurement from accredited references of industry standards

Direct samples

of fuel gas taken

annually by third

party.

Annual N/A

Fuel gas composition should remain relatively stable during steady-state operation. Estimating gas composition from accredited references provides a reasonable estimate when the more accurate method cannot be used.

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Carbon Dioxide Composition in Vent Gas / % CO2

% Measured Direct measurement

Direct samples

of fuel gas taken

annually by third

party.

Annual N/A Fuel gas composition should remain relatively stable during steady-state operation.

Density of Methane / ρCH4

kg/m3 Estimated

Reference value corresponding to conditions at which volumes are reported 0.678 kg/m3 at STP

N/A N/A N/A

As per protocol: If this value is used all values must be adjusted for standard temperature and pressure (STP).

Density of Carbon Dioxide / ρCO2

kg/m3 Estimated

Reference value corresponding to conditions at which volumes are reported

N/A N/A N/A

As per protocol: If this value is used all values must be adjusted for standard temperature and pressure (STP).

Vent Rate of Low Vent Control Device / Q project

m3 / hr

Measured

or

estimated

Direct measurement

N/A Per report N/A

As per protocol: Value is an intermediate used for subsequent calculations, based on project type.

Measured Vent Rate of Control Device / Q Direct

Measurement

m3 / hr Measured Direct measurement

Direct

measurement at

the controller

level

Once

Direct measurement results in low uncertainty.

Direct measurement of vent rate provides high confidence.

Operating Hours / Op. Hrs. j

hrs Measured Direct measurement

Estimated based

on facility

production data

(gas sales or

gas production)

and other

operating

records.

Annual N/A Continuous operating time measurement is the highest level possible.

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GWP CO2, CH4, N2O Global Warming Potential

Unitless Estimated

Provided in Carbon Offset Emission Factors Handbook

N/A N/A N/A

The Project Proponent uses the most current factors published in the Carbon Offset Emission Factors Handbook.

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Project Component #3 – Vent Gas Capture

Table 10: Monitoring plan and data sources for vent gas capture

SS Identifier

and Name

Parameter/

Variable

Unit Measured/

Estimated

Method Source /

Origin

Frequency Uncertainty Justify

Measurement or

Estimation and

Frequency

B8 Baseline

Vented Gas

Emissions Uncaptured Fuel Gas =Captured Gas * (1-DR) * %CH4 *ρ CH4 / 1000) * GWPCH4 + Captured Gas* (1-DR) * %CO2 * ρ CO2/1000)

Where

Captured Gas:

= Direct Metering

= Vent Gas (from B7)

= Op. Hours * Load * Fuel Con. Rate

Emissions

Uncaptured Fuel Gas

tonnes of, CO2e

N/A N/A N/A N/A N/A

As per protocol:

Quantity being

calculated.

Volume of Captured Gas Combusted /Captured Gas

m3 Calculated Method provided in equations above

For pumps,

existing high

vent

controllers,

and low vent

controllers:

measured from

P17 – Vent

Gas Capture

/“Captured

Gas”.

Continuous

metering or

estimated

once

N/A

As per protocol: Frequency of metering is highest level possible.

Discount Rate

due to Leaks /

DR

% Estimated See Appendix A Protocol Per report N/A See Appendix A.

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Methane

Composition in

Vented Gas / %

CH4

% Measured

Direct

measurement from

accredited

references of

industry standards

Direct samples

of fuel gas

taken annually

by third party.

Annual Low

Fuel gas composition

should remain

relatively stable

during steady-state

operation. Estimating

gas composition from

accredited references

provides a

reasonable estimate

when the more

accurate method

cannot be used.

Carbon Dioxide Composition in Vent Gas / % CO2

% Measured Direct

measurement

Direct samples of fuel gas taken annually by third party.

Annual Low

Fuel gas composition should remain relatively stable during steady-state operation.

Density of

Methane / ρCH4 kg/m3 Estimated

Reference value

corresponding to

conditions at which

volumes are

reported 0.678

kg/m3 at STP

N/A N/A Low

As per protocol: If

this value is used all

values must be

adjusted for standard

temperature and

pressure (STP).

Density of Carbon Dioxide / ρCO2

kg/m3 Estimated

Reference value

corresponding to

conditions at which

volumes are

reported

N/A N/A N/A

As per protocol: If

this value is used all

values must be

adjusted for standard

temperature and

pressure (STP).

Operating Hours / Op. Hrs. j

hrs Measured Direct

measurement

Estimated

based on

facility

production

data (gas sales

Annual

Low - Continuous tracking of site production hours represent highest level possible.

Continuous operating

time measurement is

the highest level

possible.

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or gas

production)

and other

operating

records.

Fuel Device Load/ Load

% Measured Direct measurement of fuel use device

Measured from

fuel use by the

device.

Once Low Reading from fuel

use device.

Fuel Consumption Rate/Fuel Con. Rate

Kg/hr Estimated

Referenced from manufacturer specifications

Manufacturer

specifications Once Low

Estimated parameter is a conservative overestimation in absence of equipment measurement

GWP CO2, CH4, N2O Global Warming Potential

Unitless Estimated Provided in Carbon Offset Emission Factors Handbook

N/A N/A N/A

The Project Proponent uses the most current factors published in the Carbon Offset Emission Factors Handbook.

P17 Vent Gas capture

Emissions Vent Gas Capture (P17) = Captured Gas *DE* EF Fuel CO2 / 1,000,000 +

Captured Gas *DE* EF Fuel CH4 * GWPCH4/ 1,000,000 +

Captured Gas * EF Fuel N2O * GWPN2O / 1,000,000 +

Captured Gas * (1-DE) * GWPCH4 * %CH4 * ρCH4 / 1,000,000

Where Captured Gas:

= Direct Metering

= Vent Gas (from P7)

= Op. Hours * Load * Fuel Con. Rate

Emissions Vent Gas Capture

tonnes

of, CO2e N/A N/A N/A N/A N/A

As per protocol: Quantity being calculated.

Volume of Captured Gas

m3 Calculated Method provided in equations above

For pumps,

existing high

Continuous

metering or N/A

As per protocol: Frequency of

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Combusted /Captured Gas

vent

controllers,

and low vent

controllers:

measured from

P17 – Vent

Gas Capture

/“Captured

Gas”.

estimated

once

metering is highest level possible.

Destruction Efficiency of Combustion Source / DE

% Estimated

Reference provided in Appendix C or manufacturer specification.

N/A Per report N/A

Must use the value in Appendix C unless proponent can provide project specific destruction efficiency.

CO2, CH4, N20 Emissions Factor for Vent Gas Capture Combustion / EF

Fuel CO2, CH4, N2O

g per

m3 Estimated

Provided in Carbon Offset Emission Factors Handbook, Fuel Combustion Related Emissions / “Producer Consumption (nonmarketable product)”

N/A Per report N/A

Must use most current factors published in the Carbon Offset Emission Factors Handbook.

Operating Hours / Op. Hrs. j

hrs Measured Direct measurement

Estimated

based on

facility

production

data (gas sales

or gas

production)

and other

operating

records.

Annual N/A

Continuous operating time measurement is the highest level possible.

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Fuel Device Load/ Load

% Measured Direct measurement of fuel use device

Measured from

fuel use by the

device.

Once Low Reading from fuel use device.

Fuel Consumption Rate/Fuel Con. Rate

Kg/hr Estimated

Referenced from manufacturer specifications

Manufacturer

specifications Once Low

Estimated parameter is a conservative overestimation in absence of equipment measurement

Methane Composition in Vented Gas / % CH4

% Measured

Direct measurement from accredited references of industry standards

Direct samples

of fuel gas

taken annually

by third party.

Annual N/A

Fuel gas composition should remain relatively stable during steady-state operation. Estimating gas composition from accredited references provides a reasonable estimate when the more accurate method cannot be used.

Density of Methane / ρCH4

kg/m3 Estimated

Reference value corresponding to conditions at which volumes are reported 0.678 kg/m3 at STP

N/A N/A N/A

As per protocol: If this value is used all values must be adjusted for standard temperature and pressure (STP).

GWP CO2, CH4, N2O Global Warming Potential

Unitless Estimated Provided in Carbon Offset Emission Factors Handbook

N/A N/A N/A

The Project Proponent uses the most current factors published in the Carbon Offset Emission Factors Handbook.

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P9 Fuel Extraction and

Processing

Emissions Fuel Extraction / Processing = Σj(Vol. Fuel i × EFi,CO2 / 1000) + Σj (Vol. Fuel i × EFi,CH4 / 1000) × GWPCH4 + Σj (Vol. Fuel i × EFi,N2O / 1000) × GWPN2O

Emissions Fuel

Extraction / Processing

tonnes

of, CO2e N/A N/A N/A N/A N/A

As per protocol: Quantity being calculated in aggregate form as fuel use is different for each site.

Volume of Fossil Fuel i Combusted in the Project /Vol. Fuel

L, m3 , or other

Measured

P17 Vent gas capture / “Captured Gas” and/or P7 Project Vented Gas / “Vented Gas Project”

P17 Vent gas capture / “Captured Gas” and/or P7 Project

Vented Gas /

“Vented Gas

Project”

Per report N/A

Calculated values are determined each reporting period.

EFi,CO2, CH4, N2O / CO2, CH4 , N2O Emissions Factor for Extraction and Processing for each fuel

kg CO2 per L, m3, or other

Estimated

Provided in Carbon Offset Emission Factors Handbook

N/A Annual N/A

Must use most current factors published in the Carbon Offset Emission Factors Handbook.

GWP CO2, CH4, N2O Global Warming Potential

Unitless Estimated

Provided in Carbon Offset Emission Factors Handbook

N/A N/A N/A

The Project Proponent uses the most current factors published in the Carbon Offset Emission Factors Handbook.

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Table 11: Sample Monitoring Plan

Parameter Monitoring Specifications

Source/sink identifier and name

B3 – Natural Gas Vented

Data parameter Volume of capture gas vented

Estimation, modeling, measurement or calculation approaches

Monitored

Data unit m3 at standard temperature and pressure (1 atm, 15 deg C)

Sources/Origin Direct metering of gas vented. Converted to STP condition

Sampling frequency

Continuous

Description and justification of monitoring

method

This is the most accurate method of measuring this parameter assuming that staff are correctly trained and equipment is correctly maintained

Uncertainty +/- 5 per cent based on meter accuracy

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3.5 Data Management System

The following describes the data collection systems in place for each data point in the Project. Appropriate data management system controls and quality assurance procedures will also be

explained in this section.

For each data point the following flow charts describe the manner with which data is collected and input into the project Emission Reduction Calculator (ERC). In the following flow charts cells that are filled with white color are the Project Proponent’s internal resource and those filled with green cells are provided by a third party.

EQUIPMENT INVENTORY

Current State – Baseline Data:

Future State – After Project Registration:

Petrus Resources field staff will collect all equipment inventory data (such as pump and controller

make, model, plunger size, stroke length, emission rates for controllers, etc.) from the field and

store them on Petrus Electronic Management System (EMS). These data points are primary inputs

to the Emission Reduction Calculator (ERC).

The process includes validating the list of locations and all relevant pneumatic devices inventory at

the Project Proponent sites. It is expected that every six months Petrus will review any new well-

sites and review changes. The data will be integrated into Petrus EMS as above.

The Project Proponent continues to streamline and improve their data collection practices. In the

future, Field Operation staff will work with the third-party environmental specialist completing

various data collection measures for the Proponent to ensure appropriate pump and controller

inventory information is collected on the required Project schedule.

INJECTION PRESSURES

Current/Future State – Before & After Project Registration:

Collected by Operators Nolan Severson,

Production Superintendent

Petrus Electronic Management System (EMS)

http://petrus-ems.com/ ERC

Collected by Operators Nolan Severson,

Production Superintendent

Petrus Electronic Management System (EMS)

http://petrus-ems.com/

ERC

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Injection pressures are collected daily in Operator’s Daily Log. Collected data is uploaded to Petrus

Field Data Capture & Reporting System, Production Manager Data Hub (http://petrus.prodman.ca)

and then manually input into ERC.

OPERATING HOURS

Controllers and Cata-Dyne heaters- Current/Future State – Before & After Project Registration:

Operating hours of each well, equipment and facility are recorded in Operator’s Daily Log. Collected

data is uploaded to Petrus Field Data Capture & Reporting System, Production Manager Data Hub

(http://petrus.prodman.ca) and then manually input into ERC.

STROKE COUNTER or VOLUME OF CHEMICALS INJECTED

Current/Future State – Before & After Project Registration:

Pneumatic pumps stroke count is tracked by pump stroke counter and recorded in Operator’s Daily

Log. In some cases, volume of injected chemical is tracked and recorded in Operator’s Daily Log.

Collected data is then uploaded to Petrus Field Data Capture & Reporting System, Production

Manager Data Hub (http://petrus.prodman.ca) and then manually input into ERC.

GAS ANALYSIS

Current/Future State – Before & After Project Registration:

Operator’s Daily Log Nolan Severson,

Production Superintendent

Field Data Capture & Reporting System

Production Manager Data Hub http://petrus.prodman.ca/

ERC

Operator’s Daily Log Nolan Severson,

Production Superintendent

Field Data Capture & Reporting System

Production Manager Data Hub http://petrus.prodman.ca/

ERC

Operator’s Daily Log Nolan Severson,

Production

Superintendent

Field Data Capture & Reporting System

Production Manager Data Hub http://petrus.prodman.ca/

ERC

Element Materials Technology Group

Analyses

Lab Database

Emailed to Relevant Petrus Employees

Matt Skanderup, Production Engineer

Lindsay Hatcher, Marketing & JV

ERC

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Gas analysis will be used to determine the composition of the fuel gas that would have been used

to supply pneumatic pumps and controllers that have been replaced. Fuel gas analysis are collected

from Element Materials Technology Group. The information is stored in lab database and sent to

Petrus Production Engineer. Gas analysis is then inputted into the ERC. This information is

expected to be collected on an annual basis per site and the most recent gas analysis will be used

in the ERC.

LEVEL CONTROLLERS BLEED RATES/EMISSION FACTORS

Current & Future State:

In case of any vent rate measurement in the field, data will be recorded by field operators and

uploaded to Petrus Field Data Capture & Reporting System, Production Manager Data Hub

(http://petrus.prodman.ca) and used in the ERC. In the absence of controller vent rate

measurements, manufacturer specific vent rates or average controller vent rates will be extracted

from the offset Protocol, Manual 15 or manufacturer’s manual by the third-party environmental

specialist and used in the ERC.

METER CALIBRATION

Current & Future State:

Meter calibration is performed by Pronghorn Controls and High Flo Oilfield Services at Petrus facilities and the records are kept in Petrus Ferrier Office.

Operator’s Daily Log Nolan Severson,

Production Superintendent

Field Data Capture & Reporting System

Production Manager Data Hub http://petrus.prodman.ca/

Calculated Emissions

Factor

ERC

Pronghorn Controls- Gas High Flo Oilfield Services- Liquids

Hard copies received by and filed in Ferrier office

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4.0 Project Developer Signature

I am a duly authorized corporate officer of the project developer mentioned above and have

personally examined and am familiar with the information submitted in this project plan. Based upon reasonable investigation, including my inquiry of those individuals responsible for obtaining the information, I hereby warrant that the submitted information is true, accurate and complete to the best of my knowledge and belief. I understand that any false statement made in the submitted information may result in de-registration of credits and may be punishable as a criminal offence in accordance with provincial or federal statutes.

The project developer has executed this offset project plan as of the 3rd day of July, 2020.

Project Title: Petrus Resources Pneumatic Device Offset Project

Signature: ________________________________________

Name: Robert Caughlin

Title: Manager, Drilling and Construction

5.0 References

[1] Petroleum Technology Alliance Canada, 2017, Upstream Oil & Gas ECO-EFFICIENCY

EQUIPMENT AND OPERATIONS HANDBOOK. Available online at: https://www.ptac.org/wp-content/uploads/2017/06/Canadian-Upstream-Oil-Gas-Eco-Efficiency-Equipment-and-Operations-Handbook-1.pdf

[2] Alberta Government, January 25, 2017, Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices, Version 2.0. Available online at: https://open.alberta.ca/publications/9781460131633

[3] GreenPath Energy Ltd., 2018, Level Controller Emission Study Fisher L2 And Improved Relays, Norriseal 1001a and EVS. Available online at https://auprf.ptac.org/wp-content/uploads/2018/10/Final-Report-Level-Controller-V8-20181003.pdf

[4] Alberta Government, November 2019, Standard for Completing Greenhouse Gas Compliance and Forecasting Reports, Version 2.4. available online at https://open.alberta.ca/dataset/56506b9e-4bbf-4497-8de2-8ec811b9548d/resource/affb59a6-

edf4-484c-84d4-c0093d64dbec/download/aep-standard-completing-ghg-compliance-forecasting-reports-v-24-2019-11.pdf

[5] Alberta Government, November 2019, Carbon Offset Emission Factors Handbook, Version 2.0. available online at https://open.alberta.ca/dataset/2a41f622-5ae4-4985-838f-497e6afd110c/resource/0ba7b3dc-0658-43dc-b977-4c9c35637f49/download/aep-carbon-offset-

emissions-factors-handbook-v-2-2019-11.pdf

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Appendix A: Supporting Information

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Protocol Deviation Letter

Emission Reduction from Pneumatic Devices

Petrus Resources Ltd.

Date: April 29, 2020

Submitted To: Barry Anderson – Director, Climate Implementation and Compliance Branch

Submitted by: Modern West Advisory Inc.

OFFSET PROJECT DESCRIPTION

Petrus Resources has started to implement an offset project to reduce Greenhouse Gas (GHG) emissions

from pneumatic devices. The offset project has three components including:

1. Electrification of pneumatic pumps

2. High-to-low and high-to-no vent pneumatic controller conversion

3. Vent Gas Capture from pneumatic pumps

The first component of the project includes the installation of solar electric pumps and conversion of gas

driven pneumatic chemical injection pumps to solar and grid-tied electric pumps at greenfield/brownfield

facilities.

The second component of the project includes the conversion of high-bleed pneumatic controllers at

brownfield facilities to low-bleed or no-bleed devices.

The third component of the project includes the installation of vent gas capture systems to capture and

combust vent gas emitted by pneumatic pumps.

This project quantifies emission reductions using the approved Quantification Protocol for Greenhouse

Gas Emission Reductions from Pneumatic Devices (Version 2.0, January 2017), “the Protocol”.

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DEVIATION REQUEST

The Project proponent is applying for a deviation from the quantification approach outlined in the

“Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices”.

Deviation from the protocol is related to the second component of the offset project, conversion of high

bleed pneumatic controllers at brownfield facilities to low-bleed or no-bleed devices. In Section 1.1.1 of

the protocol, converting high-bleed pneumatic controllers to low-bleed devices is described as an

eligible project type. However, in some cases the project proponent may remove a high-bleed device

and replace it with a control valve to control the pressure manually or to bypass the high-bleed device in

the system. This will result in a no-bleed replacement for the high-bleed device. The project proponent

requests for this type of conversion to be considered an eligible project for generating carbon offsets.

Precedent

The ACCO has previously granted this deviation to be eligible for offsets by converting high-bleed

devices to no-bleed devices by removing or bypassing high-bleed devices. The reference project is:

Peyto 2017 Aggregated Project for Methane Emission Reductions from Pneumatic Devices (#3395-2492).

This deviation was approved by the Alberta Climate Change Office in July 2019.

Should the Petrus deviation request be similarly granted, Petrus commits to the following project

adjustments:

• Collect and provide evidence to the verifier of device removal (e.g. a before and after photo, a

work order).

• Label the pipe with the serial number of the removed device. Use this serial number in the

aggregated project planning and reporting sheets.

Emissions Quantification

The project baseline emissions quantification is not affected by this deviation request. However, the

project emissions quantification is slightly changed.

In high-to-low conversion projects, the Protocol requires the project developers to estimate the project

vented gas (P7) using the following quantification approach:

𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠𝑃𝑟𝑜𝑗𝑒𝑐𝑡 𝑉𝑒𝑛𝑡𝑒𝑑 𝐺𝑎𝑠 =

∑ (𝑉𝑒𝑛𝑡𝑒𝑑 𝐺𝑎𝑠𝑃𝑟𝑜𝑗𝑒𝑐𝑡,𝑗 × %𝐶𝐻4 × 𝜌𝐶𝐻4 1000⁄𝑗

) × 𝐺𝑊𝑃𝐶𝐻4+

∑ (𝑉𝑒𝑛𝑡𝑒𝑑 𝐺𝑎𝑠𝑃𝑟𝑜𝑗𝑒𝑐𝑡,𝑗 × %𝐶𝑂2 × 𝜌𝐶𝑂2 1000⁄𝑗

)

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Where:

𝑉𝑒𝑛𝑡𝑒𝑑 𝐺𝑎𝑠𝑃𝑟𝑜𝑗𝑒𝑐𝑡 = 𝑂𝑝. 𝐻𝑟𝑠.𝑗∗ 𝑄𝑃𝑟𝑜𝑗𝑒𝑐𝑡,𝑗 (for converting controllers to lower or non-venting

controllers)

𝑄𝑃𝑟𝑜𝑗𝑒𝑐𝑡,𝑗

= 𝑄𝐷𝑖𝑟𝑒𝑐𝑡 𝑀𝑒𝑎𝑠𝑢𝑟𝑒𝑚𝑒𝑛𝑡 𝑗 (for controllers with direct measurement samples)

= 𝑄𝐴𝑣𝑒𝑟𝑎𝑔𝑒 𝐶𝑜𝑛𝑡𝑟𝑜𝑙𝑙𝑒𝑟 𝑇𝑦𝑝𝑒 𝑗 (for controllers with average measurement samples)

= 𝑄𝑀𝑎𝑛𝑢𝑓𝑎𝑐𝑡𝑢𝑟𝑒𝑟 𝑆𝑝𝑒𝑐𝑖𝑓𝑖𝑐𝑎𝑡𝑖𝑜𝑛 𝑗 (for controller with no direct measurement or sample statistics)

With the requested deviation, Q Project will be equal to zero as no high-vent device is used in the project.

Therefore, Emissions Project Vented Gas (P7) = 0. This request only pertains to high-bleed device removal, and

low-bleed device removal is not considered for offset generation.

The project proponent believes that high-bleed to no-bleed conversion requested by this deviation letter

can reduce venting emissions significantly without compromising the safety of the operations.

The project proponent submitted the offset project documents to the Alberta Carbon Registries on April

27, 2020 and is waiting for CSA approval. The project documents will be updated on the registry once an

approval is received for this deviation request.

The project proponent has started converting the high-bleed devices to no-bleed configurations in April

2020 and will keep records of the removal of high-bleed devices (e.g., photos of the device before and

after removal, serial number of the device that is removed, device location before removal, etc.) to

present to the project verifier at the time of project verification.

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IMPACT ON THE QUANTIFICATION (IF DEVIATION IS ACCEPTED BY CICB)

With the proposed deviation, the following quantification approach will be used by the Project Developer:

Sources and Sinks Parameter/Variable Unit Measured/Estimated Method Frequency Justify Measurement or

Estimation and Frequency

P7 – Project Vented

Gas

𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠𝑃𝑟𝑜𝑗𝑒𝑐𝑡 𝑉𝑒𝑛𝑡𝑒𝑑 𝐺𝑎𝑠 = 0

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EFFECT OF PROPOSED DEVIATION ON THE ADDITIONALITY OF THE PROJECT

The proposed deviation does not affect the additionality of the project. The GHG reductions associated

with the project are additional since the activities performed under the project are not required by

regulation or law. Further, the project involves activities beyond business-as-usual, as the project activities

have both financial and technical barriers.

CONSERVATIVENESS OF THE PROPOSED DEVIATIONS

The proposed deviation is conservative, because of the following reasons:

• Manufacturer vent rates are used to estimate baseline emissions. Manufacturer reported vent

rates are the most conservative vent rates that can be used in the quantification.

ALBERTA EMISSION OFFSET SYSTEM REQUIREMENTS

For an offset project to be eligible in the Alberta offset system, the following conditions must be met:

• Project start date after January 1, 2002.

• The Project must occur in Alberta.

• The project must result from actions not otherwise required by law and be beyond business as

usual and sector common practices.

• The project must be real, demonstrable, quantifiable, and verifiable.

• The project must have clearly established ownership.

• The project emission reductions must be counted once for compliance purposes.

All the criteria listed above are met in the offset project and the proposed deviations do not affect the

Alberta emission offset system requirements.

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