Catalytic Reduction of N O inside the Ammonia Burners of ... · emission levels typical for nitric...

JOINT IMPLEMENTATION PROJECT DESIGN DOCUMENT FORM - Version 01

Joint Implementation Supervisory Committee page 1

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JOINT IMPLEMENTATION PROJECT DESIGN DOCUMENT FORM Version 01 - in effect as of: 15 June 2006

Catalytic Reduction of N2O inside the Ammonia Burners of the

Nitric Acid Plant in Puławy

presented by

Zakłady Azotowe “Puławy” S.A.

Al. Tysiąclecia Państwa Polskiego 13

24 – 110 Puławy

Poland

Puławy, 3 June 2008




CONTENTS

A. General description of the project

B. Baseline

C. Duration of the project / crediting period

D. Monitoring plan

E. Estimation of greenhouse gas emission reductions

F. Environmental impacts

G. Stakeholders’ comments

Annexes

Annex 1: Contact information on project participants

Annex 2: Baseline information

Annex 3: Monitoring plan




SECTION A. General description of the project

A.1. Title of the project:

Catalytic Reduction of N2O inside the Ammonia Burners of the Nitric Acid Plant in Puławy, Poland

Version (Date): 1 (3 June 2008)

A.2. Description of the project:

Zakłady Azotowe “Puławy” S.A. operates a nitric acid production plant at the production site in Puławy, Poland. Nitric acid has been produced in Puławy since 1967, with no capacity changes since then. Nitric acid (HNO3) is one of the most important and quantitatively one of the top ten industrial chemicals. It is mainly used for the production of fertilizer, aside the manufacture of explosives and chemicals, such as isocyanates and adipic acid. The nitric acid from the Puławy plant is mainly used for fertilizer production.

Nitric Acid is produced through the oxidation of ammonia (NH3) on precious metal catalyst gauze in the ammonia burner of a nitric acid plant. During the production of nitric acid, nitrous oxide (N2O) is generated as an unintended by-product of the high temperature catalytic oxidation of ammonia. This waste N2O is typically released into the atmosphere, as it does not have any economic value or toxicity at emission levels typical for nitric acid manufacture.

This is also the case at the nitric acid plant in Puławy, where up to 891,000 tonnes nitric acid (calculated 100%) are produced annually. The plant comprises twelve oxidation reactors, of which three each feed one absorption process train. The tail gas leaves the four process trains through two stacks. A selective catalytic reduction system for NOx reduction is integrated into three of the four process trains to reduce NOx in the waste gas under the threshold value specified by Polish regulation and documented in the IPPC permission of the plant. Since there is no obligation for Puławy to decompose the N2O from the nitric acid plant so far, it is released to the atmosphere with an intensity of ca. 7 kg N2O per tonne nitric acid, leading to overall emissions of some 6,237 tonnes of N2O, equal to 1,933,470 tCO2e per year. This is common practice in the nitric acid industry.

The idea of the JI project is to introduce selective N2O decomposition catalyst right below the platinum gauze in the catalytic reactor as a secondary abatement measure. The baskets that hold the catalyst shall be installed in each reactor and charged with the N2O decomposition catalyst in October 2008, after a six months baseline measurement period. Estimated emission reductions amount to some 1.5 million tCO2e per year on average.

With no economic benefit from N2O abatement and the absence of any legal obligation, the emission reductions will only be realised when the investment and the ongoing costs for the secondary abatement can be financed by a JI project.




A.3. Project participants:

Party involved

Legal entity project participant

Please indicate if the Party involved

wishes to be considered as

project participant (Yes/No)

Poland (host) Zakłady Azotowe “Puławy” S.A. No

[To be defined]

First talks with potential buyers of ERUs are ongoing, the buyer will be named at the time of the first annual verification of emission reductions at the latest.

Poland has ratified the Kyoto Protocol on 13 December 2002.

A.4. Technical description of the project:

A.4.1. Location of the project:

The nitric acid plant and all the connected facilities are located at the production site in Puławy, in the Lublin Voivodeship. The nitric acid production is housed in the buildings G66 and G68. The exact address is:

Zaklady Azotowe “Puławy” S.A.

Al. Tysiąclecia Państwa Polskiego 13

24-110 Puławy

Poland

A.4.1.1. Host Party(ies):

The Host Party for the proposed project activity is Poland.

A.4.1.2. Region/State/Province etc.:

Lublin Voivodeship

A.4.1.3. City/Town/Community etc.:

Puławy




A.4.1.4. Detail of physical location, including information allowing the unique identification of the project (maximum one page):

The nitric acid production is housed in buildings G66 and G68. The following images give an overview.

Figure 1: Location of the city of Puławy Figure 2: Location of the plant in Puławy

Figure 3: View of the Nitric Acid Production Site

Coordinates:

51.4581 °N

21.9815 °E




A.4.2. Technology(ies) to be employed, or measures, operations or actions to be implemented by the project:

The nitric acid plant in Puławy consists of four independent production lines. Each line is fed by a cluster of three ammonia oxidation reactors, supplying NO gas to an absorption process train with four absorption columns. With secondary air added to the gas stream, NO oxidises to NO2 which is then available for the absorption in water and the reaction to nitric acid in the absorption columns. After leaving the absorption stage, the tail gas undergoes a selective catalytic reduction (SCR) of NOx residues with the help of ammonia in three of the four production lines. With an operating pressure of 4.9 barg in the oxidation reactors and 4.3 barg in the absorption stage, the nitric acid plant is counted among the Mono Medium/Medium (M/M) plant type. The following draft shows the principle layout.

Figure 4: Plan of the nitric acid plant

The four lines are each operated on campaigns which last around five to six months. At the end of a campaign, a line is halted for some days and the ammonia oxidation catalyst gauzes in its three reactors are replaced by new ones. The campaigns of the four lines are shifted against each other, so that there is always only just one line at a time which is halted while the other three continue with the production.

Figure 5: Shifted campaigns of the four production lines

5-6 months Replacement of catalyst in the three reactors

L211

L212

L214

L213

January July

Stack

SCR SCR SCR

Ammonia

oxidation

reactors

Absorption

columns

Line 1(L211)

Line 2(L212)

Line 3(L213)

Line 4(L214)

Stack

SCR SCR SCR

Ammonia

oxidation

reactors

Absorption

columns

Line 1(L211)

Line 2(L212)

Line 3(L213)

Line 4(L214)




Nitrous oxide (N2O) generation during the production of nitric acid is an unavoidable side reaction of the ammonia oxidation. Nitrogen oxidation steps under overall reducing conditions are considered to be potential sources of N2O.

1 Reactions that lead to the formation of N2O are undesirable in that they

decrease the conversion efficiency of NH3 and reduce the yield of the desired product NO. Thus, it is in the interest of the nitric acid producer to optimise the operating conditions in a way that as little N2O as possible is formed at the platinum gauze. The unavoidable amounts of N2O are typically vented to the atmosphere together with the waste gas stream.

The proposed project activity undertakes secondary N2O abatement by installing baskets inside each oxidation reactor and equipping them with the N2O decomposition catalyst right below the platinum gauze in the high temperature zone of the reactor (between 860 and 910 °C). With the help of the N2O decomposition catalyst, which is produced and under patent by BASF, N2O load in the combustion gas can be reduced from some 1000 – 1300 ppmv to under 250 ppmv, depending on technical conditions.

Figure 6: Scheme of reactor and basket with N2O decomposition catalyst

Secondary N2O abatement at M/M plants is a technology where some experience does already exist regarding its large scale application. However, secondary N2O abatement is not common practice in Poland nor is it currently required by Polish regulation. The first systems are to be installed these days with the help of JI financing (cf. Polish N2O abatement projects in the JISC pipeline

2). The installation of

N2O abatement systems is unusual not only because of lacking regulatory obligation and the high investment but also because of technical uncertainties like the possibility of reduced capacity due to pressure drops as result of the additional material layer in the gas stream.

1 See 2006 IPCC Guidelines for National Greenhouse Gas Inventories, p. 3.19

2 See http://ji.unfccc.int, accessed in December 2007

Ammonia + Air

NOx, N2, H2O




The more detailed analysis of alternative activities and barriers for the project implementation within the PDD will show that the project activity and the associated greenhouse gas emission reductions are additional to what would occur in the absence of the JI project.

A.4.3. Brief explanation of how the anthropogenic emissions of greenhouse gases by sources are to be reduced by the proposed JI project, including why the emission reductions would not occur in the absence of the proposed project, taking into account national and/or sectoral policies and circumstances:

The installation of the aforementioned technologies will effect substantive reductions of N2O emissions. Under a business as usual scenario, a reduction of the present emission level is not to be expected.

This is because

• no mandatory applicable legal and regulatory requirements to reduce nitrous oxide (N2O) from nitric acid production plants do presently exist in Poland;

• N2O reduction is not common practice at nitric acid plants in Poland and Europe;

• uncertainties accrue from a potential loss of production capacity in the nitric acid plant;

• N2O reduction measures require high investments and do not lead to any financial income or economic benefit.

With these reasons given, described in more detail below, the continuation of the current situation is the most plausible scenario. Only the income from a JI project may help to finance the investment into climate friendly N2O reduction measures.

A.4.3.1. Estimated amount of emission reductions over the crediting period:

Due to lacking country specific rules for the duration of JI projects in Poland, the 31 December 2012 has to be assumed as end date at this stage. However, as soon as Polish or international regulations allow for an extension of existing JI project beyond 2012, the project owner will apply for its prolongation. In this case, a seven years crediting period with the option for renewal shall apply, defining also the timing of the required baseline re-assessments according to AM0034.

With an annual production of up to 891,000 tons nitric acid, estimated specific emissions of 7 kgN2O/tHNO3 and an expected abatement efficiency of at least 80%, the following reduction amounts are expected.




Length of crediting period 4 years and 3 months, prolongation aspired

Year Estimate of annual emission reductions in tons of CO2e

2008 (Oct – Dec) 386,694

2009 1,546,776

2010 1,546,776

2011 1,546,776

2012 1,546,776

Total estimated reductions [tCO2e]

6,573,798

Annual average of estimated emission reductions [tCO2e]

1,546,776

A.5. Project approval by the Parties involved:

The Polish authority within the Ministry of Environment issued a letter of endorsement on 23 May 2008 on the basis of a project idea note. With the PDD at hand and the validation report from the Accredited Independent Entity (AIE), the project approval shall be applied for at the Polish Focal Point.




SECTION B. Baseline

B.1. Description and justification of the baseline chosen:

Summary

The Baseline Scenario is the continuation of the existing situation, as neither a financial incentive nor a legal obligation exist so far that would justify the considerable investment into and costs for N2O abatement measures.

This chapter describes the approach chosen to determine the baseline. It thus gives information about

• the regulatory background,

• the applicability of the underlying methodology (AM0034/Version 03),

• application of AM0028 for determination of the baseline scenario,

• the justification for the specific approach chosen for emission determination, including an explanation how the overstatement of baseline emissions is being excluded,

• a presentation of how permitted operating conditions are defined,

• determination of baseline emission factor,

• discussion of impact of regulations,

• discussion of campaign length,

• discussion of project emissions,

• discussion of composition of catalysts,

• the impact of regulations,

• discussion and calculation of project emission and emission reductions.

Elements of legal framework for baseline setting

Appendix B to the annex to decision 9/CMP.1 (JI Guidelines)

sets criteria for baseline setting and monitoring

Guidance on Criteria for Baseline Setting and Monitoring (JISC Guidance)

Published by the JI Supervisory Committee (JISC) at its fourth meeting

The JISC Guidance, in accordance with decision 10/CMP.1, offers two basic options for the establishment of a baseline:

1. Using an approved CDM baseline methodology;

2. Establishing a project specific baseline that is in accordance with Appendix B of the JI Guidelines with the option of using selected elements or combinations of approved CDM methodologies or tools, as appropriate.

is taken up within the




The UNFCCC provides an approved CDM methodology AM0034 “Catalytic reduction of N2O inside the ammonia burner of nitric acid plants”, that fits to the measures of the project at hand. However, minor deviations shall apply in the context of the baseline measurements: measurements at the four production lines in Puławy shall not be carried out during one campaign, but overlap two campaigns. Consistency and conservativeness shall be assured by below described measures. In addition, the rules for the change of the ammonia catalyst composition are adjusted (see accordant section below).

Applicability criteria of AM0034

All applicability criteria defined in AM0034 in its current version 3 are fulfilled, with one deviation regarding the baseline measurement (bold):

• The commercial production has begun before December 2005 and production capacity has not changed after 2005.

• The project won’t affect the level of nitric acid production.

• The project activity will not increase NOx emissions.

• There is no Non-Selective Catalytic (NSCR) installed at the plant.

• Operation of the secondary N2O catalyst installed under the project activity does not lead to any process emissions of greenhouse gases, directly or indirectly.

• Continuous real-time measurements of N2O concentration and total gas volume flow will be carried out in each line:

o Prior to the installation of the secondary catalyst for a period representing a typical campaign, but spanning parts of two campaigns

o After the installation of the secondary catalyst throughout the chosen crediting period

The intention not to carry out the baseline emission measurements during one single campaign (and with this to deviate from the AM0034 approach) is motivated by a shortening of the lead time before the secondary catalysts can be installed. The concept is described in more detail below.

Identification of the baseline

As stipulated in AM0034, the identification of the baseline scenario shall follow the instructions outlined in approved baseline methodology AM0028 “Catalytic N2O destruction in the tail gas of Nitric Acid Plants”. The 5 step approach applied here stems from AM0028, Version 4.1.

Step 1: Identification of technically feasible baseline scenario alternatives to the project activity

Step 1a: N2O destruction or abatement alternatives

Theoretical alternatives to the project are:

(a) Continuation of status quo 1 (plant with no N2O abatement facility)

(b) Utilization of N2O after recycling as feedstock for the plant or for other external uses

(c) Installation of N2O tertiary destruction technology

(d) Installation of non-Selective Catalytic Reduction (NDRC) DeNOx unit

(e) Installation of primary or secondary measures for N2O

(f) Switch to alternative production method with no ammonia oxidation process




Step 1b: NOx destruction alternatives

The theoretical alternatives to the project are:

(g) Continuation of status quo 2 (three SCR units)

(h) Continuation of the status quo including the planned retrofitting of production line 4 (214) with a Selective Catalytic Reduction (SCR) DeNOx unit by 2010

(i) Installation of new tertiary destruction technology that combines NOx and N2O destruction

(j) Installation of Non-Selective Catalytic Reduction (NSCR) DeNOx facility (=d)

Step 2: Elimination of alternatives that do not comply with legal or regulatory requirements

There are no regulatory requirements in Poland regarding N2O emissions. Thus, no restrictions apply to the alternative scenarios mentioned under Step 1a above.

NOx emissions to air at ZAP (Zaklady Azotowe Puławy), including emissions from HNO3 plant, are regulated by the IPPC Approval. NOx emissions from the nitric acid plant are permanently below the limits defined by the permit. Thus, no measures are required for the nitric acid plant.

However, with regard to the whole production site, NOx emissions shall be reduced by 2010 after the installation of a desulphurization facility at the power plant, which leads to slightly higher NOx emissions. In order to comply with Polish regulations for the maximum NOx concentration in air (not the limits defined in the IPPC approval), NOx emissions have to be reduced anywhere at the production site. The most economical and effective way of reducing NOx emissions at the production site is the installation of a fourth DeNOx unit at the nitric acid plant (line 4), which is planned for the year 2010.

Thus scenario (g), the continuation of status quo without any installation of a further DeNOx facility, is not a realistic alternative, however due to regulations that apply to the overall production site, not specifically the nitric acid plant.

All other alternatives do comply with relevant legal regulations.

Step 3: Elimination of baseline alternatives that face prohibitive barriers (barrier analysis)

Sub-step 3a and 3b:

The following baseline scenarios have to be excluded for general technical reasons or economical reasons:

(b) Alternative use of N2O at Puławy plant is neither technologically nor economically feasible.

(c/i) Currently there is neither a proven technique for tertiary N2O destruction nor for the combined NOx and N2O destruction available that would meet Puławy plant conditions, as the tail gas at Puławy plant has too low temperature.

(e) In the absence of JI-co-financing, the installation of N2O abatement technology is not feasible. N2O abatement technology is connected with substantial investment and operation costs.




(f) Nitric acid production in industrial facilities such as Puławy plant cannot be conducted without usage of ammonia oxidation process.

(d/j) NSCR cannot be considered state-of-the-art technology as it results in high secondary emission levels and high fuel consumption levels. As such it is not adequate to be included in a portfolio of measures for abatement of greenhouse gases. Besides NSCR requires high investments for necessary installation of additional expensive heat exchangers for heating and cooling and pipeline connection to a gas grid. This all makes a NSCR installation in contrast to an SCR installation economically very unattractive.

The only alternative that doesn’t face any barriers is the continuation of the status quo including the planned retrofitting of production line 4 (214) with a Selective Catalytic Reduction (SCR) DeNOx unit by 2010, i.e. the combination of scenarios (a) and (h) as baseline scenario.

Step 4: Identification of most economically attractive baseline scenario alternative

Installation and operation of the N2O decomposition catalyst does not generate any financial profit. Since this is the only alternative left after elimination of other alternatives in step 2 other than the continuation of status quo, the latter is the most economically attractive scenario.

Step 5: Re-assessment of Baseline Scenario in course of proposed project activity’s lifetime

Step 5a:

The adjustment or amendment of regulations concerning NOx emissions shall lead to a re-assessment of the baseline scenario and the respective emission factors. The above described planned installation of a fourth DeNOx unit at the nitric acid plant is part of the project and will not be considered as a case for baseline re-assessment.

Step 5b:

In case of introduction of either concentration or mass limits on N2O emissions, the baseline scenario would be re-assessed according to the AM0034 requirements under “Impact of regulations” described below.

Specific approach for determination of baseline emissions

In order to implement the project activity as soon as possible, the campaign specific baseline emission factor shall be derived by monitoring of both N2O concentration and gas volume flow over a production period that equals the HNO3 production volume of one campaign, but stretches across two actual campaigns. With this deviation from AM0034, the timing does only depend on the first date of availability of the monitoring system. As soon as this is in place, baseline measurements can begin, lasting for a period no longer than the average length of the previous five campaigns. After the baseline measurement period is terminated, the catalyst shall immediately be installed, so that emissions are reduced as soon as possible at all four lines. For each production line an individual baseline emission factor shall be determined. The following figure shows the approach for individual timing of the baseline measurement period for each single plant reactor.




Figure 7: Timing of baseline measurement period

In order not to overstate baseline emissions and adapt the AM0034 measures to ensure conservativeness of this approach, the following conditions shall apply:

• Limit campaign A to the average historic campaign length and

• limit the baseline measurement period to the average historic campaign length.

• Only in case campaign A does exceed the average historic campaign length, N2O values at the end of campaign A shall be eliminated.

This shall prevent the inclusion of the higher emission levels at the end of a campaign into the baseline emission factor.

Permitted operating conditions

In order to guarantee that there is no bias in the baseline value by establishment of special operating conditions during baseline measurements, the normal ranges of the operating conditions are to be determined and their compliance during measurements is to be controlled. The normal/permitted operating conditions are generated by use of the routinely logged data from the last five complete campaigns (operating condition campaigns).

The controlled parameters are the following:

(i) oxidation temperature

(ii) oxidation pressure

(iii) ammonia gas flow rate

(iv) air input flow rates

The ‘permitted range’ for oxidation temperature and pressure is determined using the logged historical data. The calculation method follows the statistical analysis outlined in AM0034.

Process parameters to be monitored are the following:

OTd, l Oxidation temperature for each day3 (°C)

OPd, l Oxidation pressure for each day (Pa)

OTnormal, l Normal range for oxidation temperature (°C)

OPnormal , l Normal range for oxidation pressure (Pa)

3 Using daily averages for oxidation temperature and pressure is a deviation from AM0034, where hourly data are

requested as first option. However, hourly data are not available here and the deviation is a minor one.

Campaigns

Baseline Monitoring

Begin of Baseline measurement period

End of Baseline measurement period. Installation of N2O mitigation catalyst

A B C




The permitted range is determined through a statistical analysis of the historical data as described in AM0034.

For the two other parameters the historical maximum value during the last five campaigns is identified.

Parameters to be determined:

AFRl Ammonia gas flow rate to the AOR (tNH3/h)

AFRmax, l Maximum ammonia gas flow rate to the AOR (tNH3/h)

AARl Ammonia to air ratio (%)

AARmax, l Maximum ammonia to air ratio (%)

All calculated data for the four parameters are within the specifications of the Puławy plant.

The derivation of the parameters and the results as well as the plant specifications are presented in Annex 2.

Determination of baseline emission factor

In compliance with AM0034 and along EN14181 stipulations, baseline emission factors will be calculated using AMS data of N2O concentration and tail gas volume flow during the baseline measurement period. The monitoring system provides 2-second data for the two parameters for a defined period of time. Error readings (e.g. downtime or malfunction) and extreme values will be automatically eliminated from the output data series by the monitoring system.

To exclude distortion by data mavericks and to guarantee conservativeness, the data series will be statistically evaluated. The statistical procedure will be applied to data obtained after eliminating data measured from periods in which the plant operated outside the permitted ranges. The following statistical evaluation will apply to both N2O concentration and gas volume flow for each production line:

a) Calculation of sample mean (x)

b) Calculation of sample standard deviation (s)

c) Calculation of 95 % confidence interval (equal to 1.96 times the standard deviation)

d) Elimination of all data that lie outside the 95% confidence interval

e) Calculation of new sample mean from the remaining values (volume of tail gas (VTG) and N2O concentration of tail gas (NCTG))

The formulae to derive the baseline emission factor are presented in section D.

In order to further ensure that operating conditions during the baseline monitoring period are representative of normal operating conditions, statistical tests should be performed to compare the average values of the permitted operating condition campaigns with the average values obtained during the baseline determination period. If it can be concluded with 95% confidence level, in any of the tests, that the two values are different, then the baseline determination should be repeated.

The baseline measurements are not valid and have to be repeated if the plant operates outside of the permitted range for more than 50% of the duration of the baseline campaign.

Impact of regulations

Should new N2O emission regulation apply to Puławy plant, no matter whether set through

• absolute emission caps,

• relative limits in relation to unit of output or




• threshold values for specific N2O mass flow in the stack,

the baseline factors of the project (EFBL) are always to be compared with the new plant specific emission factors that will be derived from the new regulatory level (EFreg).

The concrete derivation procedure is described in approved methodology AM0034. If the regulation based factor is lower than the baseline factor determined for the project, the regulatory limit shall serve as the new baseline factor. Observing the development of applicable regulations is part of the monitoring.

Composition of the ammonia oxidation catalyst

AM0034 sets strict requirements on the continuity of the ammonia oxidation catalyst composition: in case the composition in the baseline campaign is different from that in the historic campaigns, this has to be justified or the conservative IPCC standard factor is to be used. The latter is also the case when the composition changes from the baseline campaign to the project campaign without repeating baseline measurements.

These consequences are very strict and shall avoid the certification of emission reductions that are not caused by the installation of N2O decomposition technology but by increasing efficiency of the ammonia catalyst (which is deemed to be part of the baseline). However, this rule does also strongly interfere with common economically driven purchase decisions regarding ammonia catalysts offered in the market: Costs for the ammonia catalyst do highly depend on the used precious metals and are, besides the efficiency, decisive for the purchase of a specific product. Moreover, the rule does impede emission reductions: in case a new catalyst gauze composition promises a higher conversion efficiency and thus a lower nitrous oxide share in the tail gas, the plant operator will not buy and use this because of the restrictive consequences laid down in AM0034.

Besides, AM0034 does not define what a change in composition is. It seems questionable why minor changes of some percent of the share of a specific precious metal should lead to such fierce consequences.

The plant operator is and will in the future be in the situation that the catalyst gauze composition may slightly change with the purpose of achieving the best compromise between price and ammonia oxidation efficiency. The catalyst gauzes are delivered by large and well-established suppliers, providing gauze compositions which are considered as common practice in the industry, including the precious metals platinum, palladium and rhodium. Names of suppliers and exact gauze composition are kept confidential but will be available for verification by the Accredited Independent Entity (AIE).

The AM0034 rules for changes of the catalyst gauze composition shall be eased in the following way: Composition changes shall be possible without any consequences when the changes do not exceed

• +/- 10% for the platinum share,

• +/- 10% for the palladium share,

• +/- 3% for the rhodium share.

In case of higher changes, the AM0034 rules under the section “Composition of the ammonia oxidation catalyst” shall apply.

Campaign length

AM0034 specifies: „In order to take into account the variations in campaign length and its influence on N2O emission levels, the historic campaign lengths and the baseline campaign length are to be determined and compared to the project campaign length”. While the planned project activity will control this influence in principle, there is a deviation in the procedure, linked to the special design of the baseline monitoring period.




Historic campaign length

The average historic campaign length (CLnormal, l), defined as the average campaign length of the historic campaigns used to define the normal operating conditions (the previous five campaigns), will be used as a cap on the length of the first campaign of the baseline measurements (campaign ‘A’ in Figure 7) as well as the length of the overall baseline period. Campaign length is hereby defined as amount of HNO3 produced, not in terms of time.

Baseline measurement period

As described above, there is a deviation from the strict campaign concept of AM0034 with regard to the baseline measurement, reflected also in the terminology. The PDD at hand refers to a baseline measurement period and not to a baseline campaign.

Appropriate measures taken to avoid an overstatement of baseline emissions are presented above.

Project emissions and emission reductions

Over the duration of the project activity, N2O concentration and gas volume flow in the tail gas of the nitric acid plant as well as the temperature and pressure of ammonia gas flow and ammonia-to-air ratio will be measured continuously.

Estimation of campaign-specific project emissions

The monitoring system is to be installed using the guidance document EN 14181 and will provide separate readings for N2O concentration and gas volume flow for a defined period of time (every hour of operation, i.e. an average of the measuring values of the past 60 minutes). Error readings (e.g. downtime or malfunction) and extreme values are automatically eliminated from the output data series by the monitoring system. Next, the same statistical evaluation that was applied to the baseline data series is to be applied to the project data series:

a) Calculation of sample mean (x)

b) Calculation of sample standard deviation (s)

c) Calculation of 95 % confidence interval (equal to 1.96 times the standard deviation)

d) Elimination of all data that lie outside the 95% confidence interval

e) Calculation of new sample mean from the remaining values

Accordant variables, formulae and the determination of the campaign specific emission factor (EFn) are presented in the monitoring section of the PDD.

All calculations will be carried out in an appropriate Excel file where all relevant values from the AMS and the process control system will be listed.

Derivation of a moving average emission factor

In order to take into account possible long-term emissions trends over the duration of the project activity and to take a conservative approach a moving average emission factor (EFma) will be estimated.




If this emission factor is higher than the campaign specific factor, it shall also serve as the valid parameter for the calculation of emission reductions in the respective campaign. Otherwise the campaign specific factor shall serve for this purpose. This relation is expressed in a special set of equations shown in section D.

Minimum project emission factor

A campaign-specific emission factor shall be used to cap any potential long-term trend towards decreasing N2O emissions that may result from a potential built up of platinum deposits. After the first ten campaigns of the crediting period of the project, the lowest EFn observed during those campaigns will be adopted as a minimum (EFmin). If any of the later project campaigns results in a EFn that is lower than EFmin, the calculation of the emission reductions for that particular campaign shall used EFmin and not EFn. The accordant measures to compare emission factors are part of the monitoring.

Project campaign length

a. Longer project campaign

If the length of an individual project campaign CLn is longer than or equal to the average historic campaign length CLnormal then all N2O values measured during the baseline period can be used for the calculation of campaign specific EFn.

b. Shorter project campaign

If CLn is shorter than CLnormal, EFBL will be recalculated by eliminating those N2O values that were obtained during the production of nitric acid beyond the CLn (in an adequate manner, i.e. the last tonnes produced at the end of the first campaign of the baseline period) from the calculation of EFBL.

c. Treatment of first project period

The first period will be a shorter period as it is supposed to begin at a time throughout a running production campaign (campaign ‘C’ in Figure 7) and will only last till the end of that campaign. For this campaign, the recalculation shown above under b. shall apply. This is very conservative, as this leads to a comparison between baseline emissions at the beginning of a campaign with project emissions at the end of a campaign.

Leakage

No leakage calculation is required.

Emission reductions

The emission reductions for the project activity over a specific period are determined by deducting the period-specific emission factor from the baseline emission factor and multiplying the result by the production output of 100% concentrated nitric acid over the period and the GWP of N2O:

ONllplBLl GWPNAPEFEFER 2,, )( ××−= Formula 1

Where

ERl Emission reductions at line l of the project for the specific campaign (tCO2e)

NAPl Nitric acid production for the project campaign (tHNO3). The maximum value of NAP shall not exceed the design capacity.




EFBL,l Baseline emission factor of line l

EFp,l Emission factor used to calculate the emissions from this particular project campaign (i.e. the higher of EFma.n,l and EFn,l)

All data and parameters that are available for validation and are not part of the monitoring are presented in Annex 2.

B.2. Description of how the anthropogenic emissions of greenhouse gases by sources are reduced below those that would have occurred in the absence of the JI project:

For the demonstration of additionality, AM0034 refers to the latest version of the “Tool for demonstration and assessment of additionality” agreed by the Executive Board. This is also recommended as first option by the JISC guidance.

As the above presented baseline determination follows an identical approach to the latest version of the additionality tool, the results from its application shall be briefly summarised here.

Step 1. Identification of alternatives to the project activity consistent with current laws and regulations

In accordance to AM0034 provisions step 1 is being omitted. Procedure and results equal step 1 of the baseline description (cf. B.1.)

Step 2. Investment analysis

Sub-step 2a. Appropriate analysis method

As the project activity doesn’t generate any financial or economic benefit other than JI related income, simple cost analysis is applied.

Sub-step 2b. Simple cost analysis

The costs for the proposed project activity consist of the investment needed for the modification of the baskets and the repeating costs for the catalyst fillings (the catalyst has to be replaced around every two years). The specific costs for the catalyst shall not be disclosed here due to confidentiality reasons. However, according to the BREF, catalytic N2O decomposition in the oxidation reactor leads to additional production costs of some 0.98 to 1.20 EUR per tonne HNO3 produced

4. The N2O abatement does not

lead to any economic benefits other than JI related income.

Step 4. Common practice analysis

It is difficult to make a statement concerning the application of N2O abatement technologies in other plants in Poland and Europe, as information about the production practices is hardly accessible in the chemical industry. However, there is some indication which supports the project developer’s impression that application of secondary N2O abatement is very rare. According to the Fourth National Communication of Poland under the UNFCCC, specific N2O emissions of nitric acid production in Poland averaged at around 6.4 kgN2O per tonne nitric acid in 2003, with no reductions observed since at least

4 See BREF document for LVIC, European Commission, 2006, p. 125.




1997.5 This is well within the range what the IPPC BREF states as typical N2O emissions of medium

pressure plants without abatement technology. This indicates that in Poland no abatement technologies are implemented at nitric acid plants. In 2007, two JI projects were published in connection with N2O abatement measures at nitric acid plants

6, which also indicates the lacking implementation of this

technology without the incentive from JI. Even in Germany, no N2O abatement technologies were implemented so far in the six nitric acid plants.

7 The industry’s criticism on the BAT values is explicitly

published in the IPPC BREF, showing that the uncertainty concerning the abatement technology due to limited experience and perceived technical and operational constraints is still an important barrier for the diversion of the technology.

8 All those issues lead to the conclusion that N2O destruction is currently not

common practice in the nitric acid industry.

With these reasons the continuation of the current situation is the most plausible scenario. Only the income from a JI project may help to finance the investment into climate friendly N2O reduction measures.

B.3. Description of how the definition of the project boundary is applied to the project:

Project boundaries are defined in accordance with AM0034. The spatial extent comprises the facility and equipment for the complete nitric acid production process from the inlet to the ammonia burner to the stack, including all compressors, tail gas expander turbines and NOx abatement equipment installed. The only greenhouse gas included is the N2O contained in the tail gas behind the absorption columns. For the baseline determination, monitoring of project emissions and calculation of emission reductions, each production line is treated separately.

5 See Ministry of Environment of Poland: Fourth National Communication under the UNFCCC, Warsaw 2006, p. 64.

Table 51 expresses specific emissions of nitric acid production as CO2eq (1,996.90) 6 „Anwil“ and „ZAT“, see archive of JI project database: http://ji.unfccc.int/JI_Projects/Verification/PDD/index.html

(accessed in March 2008) 7 See German Inventory Report for UNFCCC, April 2007, chapter 4.2.2 and 14.2.2.1.1

8 See BREF document for LVIC, European Commission, 2006, p. 140.




E05

K01

N01

B13, P12 - P13, F18 - F19

B05-B08,P01-P05,

B09-B11,P06-P09,

B12, P10 - P11, F16 - F17

L211

R01 R03R02

Ammonia/air mixture

E02

K02K03K04

C01T01

Nitrous gases

N02

L214

L213

L212

Stacks

Flue gas turbine

Nitric acid plant setup – line 211 (212, 213)

Reactors of ammonia oxidation

process, pressure = 0,49 MPa g,temperature = 860 – 910 °C

Absorption columns, pressure = 0,43 MPa g

R04

SCR reactor

Figure 8: Line specific flow diagram for project boundary of lines 211, 212 and 213

E05

K01

N02

B13, P12M - P13M, F18M - F19

B05-B08,P01-P05,

B09-B11,P06-P09,

B12, P10 - P11, F16 - F17

L214

R01 R03R02

Ammonia/air mixture

E02

K02K03K04

C01T01

Nitrous gases

N01

L211

L212

L213

R1M

R2M

Stacks

Flue gas turbine

Nitric acid plant setup – line 214

Reactors of ammonia oxidation process, pressure = 0,49 MPa g,

temperature = 860 – 910 °C

Absorption columns, pressure = 0,43 MPa g

Figure 9: Line specific flow diagram for project boundary of line 214




Source Gas Included? Justification

CO2 Excluded

CH4 Excluded

The project does not lead to any change in CO2 or CH4 emissions, therefore these are not included.

Ba

se

lin

e

Nitric Acid Plant (Burner Inlet to Stack)

N2O Included

CO2 Excluded

CH4 Excluded

The project does not lead to any change in CO2 or CH4 emissions Nitric Acid Plant (Burner Inlet to

Stack) N2O Included

CO2 Excluded

CH4 Excluded

Pro

jec

t A

cti

vit

y

Leakage emissions from production, transport, operation and decommissioning of the catalyst N2O Excluded

No leakage emissions are expected.

Table 1: Overview of emission sources included or excluded from the project boundary

B.4. Further baseline information, including the date of baseline setting and the name(s) of the person(s)/entity(ies) setting the baseline:

Date of baseline setting: 20 May 2008 (to be amended with concrete measurement results by the end of 2008)

The baseline setting was defined and documented by Zakłady Azotowe “Puławy” S.A. (Poland), BASF SE (Germany) and FutureCamp GmbH (Germany).

SECTION C. Duration of the project / crediting period

C.1. Starting date of the project:

The project begins with the modification of the baskets and the installation of the N2O catalyst. This shall take place after the finalization of the baseline measurements at each line, which is expected for September and October 2008. As starting date of the project, the 20 September 2008 is indicated.

C.2. Expected operational lifetime of the project:

The project consists of the operation of secondary N2O catalysts within the oxidation reactors at the four production lines of the Puławy nitric acid plant. The catalyst fillings are expected to be replaced around every two years to maintain the N2O destruction efficiency. The baskets can be replaced in case of any damage. With this, there is no technically defined limit on the operational lifetime of the project’s equipment. The possible operational lifetime of the project is linked to the operational lifetime of the nitric acid plant, which is technically not limited.

The project activity is expected to operate beyond 2012.




C.3. Length of the crediting period:

The starting date of the crediting period shall be the date the first emission reductions are generated by the JI project, which is expected to be the 30 September 2008. The crediting period shall extend beyond 2012 subject to the approval by the Polish Focal Point. In case of a prolongation of the project beyond 2012, a seven years crediting period with the option for renewal shall apply, defining also the timing of the required baseline re-assessments according to AM0034.




SECTION D. Monitoring plan

D.1. Description of monitoring plan chosen:

According to decision 10/CMP.1, paragraph 4(a), methodologies for monitoring approved by the CDM Executive Board may be applied also for JI projects. As discussed in section B.1., the procedure for the proposed project does basically follow the official methodology AM0034, which contains both a baseline and a monitoring methodology. The AM0034 monitoring methodology shall be applied for the project at hand, taking into consideration the element of the cross-campaign baseline measurement period.

An automated measuring system (AMS) will be installed using the guidance document EN 14181 and will provide separate readings for N2O concentration and gas volume flow continuously, generating average values for every 60 minutes of operation. Error readings (e.g. downtime or malfunction) and extreme values are automatically eliminated from the output data series by the monitoring system. Besides these two parameters, the temperature and pressure of the tail gas are recorded in the AMS.

Statistical evaluation will be applied to the project data series for N2O concentration and gas volume flow in order to eliminate mavericks from downtime or malfunction of the monitoring system.

The measurement and calculation of N2O emissions will be carried out for each production line individually. This is expressed by the index ‘l’ at the accordant parameters in the following sections. As the campaigns at the four lines are shifted against each other, this will lead to divergent monitoring periods for the four lines. However, the results of the monitoring will be reported within one single report, exactly stating the reported campaigns (campaign number, start/end date) for each line.

The following sections describe the parameters which have to be monitored in order to determine project emissions and baseline emissions.




D.1.1. Option 1 – Monitoring of the emissions in the project scenario and the baseline scenario:

D.1.1.1. Data to be collected in order to monitor emissions from the project, and how these data will be archived:

ID number (Please use numbers to ease cross-referencing to D.2.)

Data variable Source of data Data unit Measured (m), calculated (c), estimated (e)

Recording frequency

Proportion of data to be monitored

How will the data be archived? (electronic/ paper)

Comment

P.1 NCTGl N2O analyser ABB Infrared Photometer URAS26

mgN2O/m³ (converted from ppmv)

M Every 2 seconds

100% The data output from the analyser will be processed using data processing system from DURAG GmbH. All Information will be stored in electronic records for at least 2 years.

P.2 VTGl Gas volume flow metering using electronic differential pressure transmitters from different manufacturers at the four lines.

m³/h M Every 2 seconds

100% The data output form the analyser will be processed using data processing system from DURAG GmbH. The information will be stored in




electronic records for at least 2 years.

P.3 OHl Production log (SCADA system)

Hours M Daily, compiled for entire campaign

100% Plant manager records the hours of full operation of the plant during a campaign. The information will be stored in electronic records and paper for at least 2 years.

P.4 NAPl Vortex flow meter Foxboro / 83W, SCADA system

tHNO3 M Continuously 100% Total production over monitoring campaign. The information will be stored in electronic records for at least 2 years.

P.5 TTGl Resistance Thermometer

°C M Every 2 seconds

100% The information will be stored in electronic records for at least 2 years.

P.6 PTGl Probe (part of gas volume flow meter)

Pa M Every 2 seconds

100% The information will be stored in electronic records for at least 2 years.

P.7 GSproject, l Delivery Note Each campaign 100% The information will be stored in




paper for at least 2 years.

P.8 GCproject, l Monitored 100% To be obtained during the project campaign. The information will be stored in paper for at least 2 years.




D.1.1.2. Description of formulae used to estimate project emissions (for each gas, source etc.; emissions in units of CO2 equivalent):

Project emissions are determined by calculating the mean values for N2O concentration and gas flow and multiply those with the number of operating hours. Statistical analysis will be applied to both N2O concentration and gas volume flow. All calculations are conducted line-wise.

Formula for the line-wise calculation of project emissions for a campaign:

9, 10−

×××= lllln OHNCTGVTGPE Formula 2

Where:

PEn, l Total N2O emissions for the nth project campaign of line l (tN2O)

VTGl Mean tail gas volume flow rate for the project campaign of line l (m3/h)

NCTGl Mean concentration of N2O in the tail gas for the project campaign of line l (mgN2O/m3)

OH l Number of hours of operation of line l in the specific project campaign (h)

From the project emissions and the accordant nitric acid production in the monitored campaign, the specific campaign emission factor is calculated:

lnlnln NAPPEEF ,,, /= Formula 3

Where:

EFn, l Project N2O emission factor of line l (tN2O/tHNO3)

NAPn, l Nitric acid production during the project period of line l (tHNO3)




D.1.1.3. Relevant data necessary for determining the baseline of anthropogenic emissions of greenhouse gases by sources within the project boundary, and how such data will be collected and archived:



Recording frequency



Comment

B.1 NCTGBP,l N2O analyser ABB Infrared Photometer URAS26

mgN2O/m³ (converted from ppmv

M Every 2 seconds

100% The data output form the analyser will be processed using data processing system from DURAG GmbH. The information will be stored in electronic records for the entire crediting period.




B.2 VTGBP,l Gas volume flow metering using electronic differential pressure transmitters from different manufacturers at the four lines.

m³/h M Every 2 seconds

100% The data output form the analyser will be processed using data processing system from DURAG GmbH. The information will be stored in electronic records for the entire crediting period.

B.3 OHBP,l Production log (SCADA system)

Hours M Daily, compiled for entire campaign

100% Plant manager records the hours of full operation of the plant during a campaign. The information will be stored in electronic records and paper for the entire crediting period.

B.4 NAPBP,l Vortex flow meter Foxboro / 83W, SCADA system

tHNO3 M Continuously 100% The information will be stored in electronic records and paper for the entire crediting period.




B.5 TTGl Resistance thermometer

°C M Every 2 seconds

100% The information will be stored in electronic records and paper for at least 2 years.

B.6 PTGl Probe (part of gas volume flow meter)

Pa M Every 2 seconds


B.7 UNCl Calculation of the combined uncertainty of the applied monitoring equipment

% C Once after monitoring system is commissioned

100% The information will be stored in electronic records and paper for the duration of the project activity.

B.8 CL1BL,l Calculated from nitric acid production data

tHNO3 C After end of period


B.9 PLBL,l Calculated from nitric acid production data

tHNO3 C After end of period





B.10 GSBL, l Delivery note 100% To be obtained during the baseline period. The information will be stored in electronic records and paper for the crediting period.

B.11 GCBL, l Monitored 100% To be obtained during the baseline period. The information will be stored in electronic records and paper for the crediting period.

B.12 EFreg Monitored Updated when new regulations come into force

100%




D.1.1.4. Description of formulae used to estimate baseline emissions (for each gas, source etc.; emissions in units of CO2 equivalent):

The average mass of N2O emissions per hour is estimated as product of the NCTG and VTG. The N2O emissions per period are estimates product of N2O emission per hour and the total number of complete hours of the period using the following equation:

9,,,, 10−

×××= lBPlBPlBPlBP OHNCTGVTGBE Formula 4

Where:

BEBP, l Total N2O emissions during the baseline measurement period of line l (tN2O)

NCTGBP, l Mean concentration of N2O in the tail gas during the baseline measurement period of line l (mgN2O/m³)

OHBP, l Operating hours of the baseline monitoring period of line l (h)

VTGBP, l Mean gas volume flow rate of tail gas in the baseline measurement period of line l (m3/h)

The line specific baseline emission factor representing the average N2O emissions per tonne of nitric acid over one full period is derived by dividing the total mass of N2O emissions by the total output of 100% concentrated nitric acid for that period. The overall uncertainty of the monitoring system shall also be determined and the measurement error will be expressed as a percentage (UNC). The N2O emission factor per tonne of nitric acid produced in the baseline period (EFBL,l) shall then be reduced by the estimated percentage error as follows:

−×=

1001

,

,

,l

lBP

lBP

lBL

UNC

NAP

BEEF Formula 5

Where:

EFBL, l Baseline N2O emission factor of line l (tN2O/tHNO3)

NAPBP, l Nitric acid production during the baseline period of line l (tHNO3)

UNCl Overall uncertainty of the monitoring system of line l (%), calculated as the combined uncertainty of the applied monitoring equipment




In the absence of any national or regional regulations for N2O emissions, the resulting EFBL will be used as the baseline emission factor.

In case of new regulations limiting N2O emissions of the Puławy plant, the corresponding plant-specific emission factor cap (max. allowed kgN2O/tHNO3) will be taken into account. If the regulatory level is lower than the baseline factor determined for the project, the regulatory limit shall serve as the new baseline emission factor (EFreg), that is:

If EFBL, l > EFreg, the baseline N2O emission factor shall be EFreg for all calculations. EFreg is the emission limit set by newly introduced policies or regulations (tN2O/tHNO3).

D. 1.2. Option 2 – Direct monitoring of emission reductions from the project (values should be consistent with those in section E.):

Not applicable.

D.1.2.1. Data to be collected in order to monitor emission reductions from the project, and how these data will be archived:



Recording frequency



Comment

Not applicable.

D.1.2.2. Description of formulae used to calculate emission reductions from the project (for each gas, source etc.; emissions/emission reductions in units of CO2 equivalent):

Not applicable.

D.1.3. Treatment of leakage in the monitoring plan:

No leakage emissions do accrue.




D.1.3.1. If applicable, please describe the data and information that will be collected in order to monitor leakage effects of the project:



Recording frequency



Comment

Not applicable.

D.1.3.2. Description of formulae used to estimate leakage (for each gas, source etc.; emissions in units of CO2 equivalent):

Not applicable.

D.1.4. Description of formulae used to estimate emission reductions for the project (for each gas, source etc.; emissions/emission reductions in units of CO2 equivalent):

In order to take into account possible long-term emissions trends over the duration of the project activity and to take a conservative approach a moving average emission factor (EFma) will be estimated. It shall be calculated at the end of a campaign (n) of a line (l) as follows:

EFma,n,l = (EF1, l + EF2, l + ... + EFn ,l) / nl (tN2O/HNO3) Formula 6

This process is repeated for each period so that a moving average is established over time, becoming more representative and precise with each additional period.

To calculate the total emission reductions achieved in a campaign in formula below, the higher of the two values EFma and EFn shall be applied as the emission factor relevant for the particular campaign to be used to calculate emissions reductions (EFp). Thus:




If EFma,n,l > EFn,l then EFp,l = EFma,n,l

If EFma,n,l < EFn,l then EFp,l = EFn,l Formula 7

Where:

EFn, l Emission factor calculated for a specific project campaign n (tN2O/HNO3)

EFma,n, l Moving average emission factor after nth period, including the current period (tN2O/HNO3)

nl Number of periods to date of line l

EFp, l Emission factor that will be applied to calculate the emissions reductions from this specific period, i.e. the higher of EFma,n, l and EFn, l (tN2O/HNO3)

As an additional measure to guarantee the conservativeness of the calculation, a minimal emission factor is being introduced.

By help of this factor any potential long-term trend towards decreasing N2O emissions that may result from a potential built up of platinum deposits shall be capped. After the first ten campaigns of the crediting period of the project, the lowest EFn observed during those campaigns will be adopted as a minimum (EFmin). If any of the later project campaigns results in a EFn that is lower than EFmin, the calculation of the emission reductions for that particular campaign shall use EFmin and not EFn.

EFmin,l is equal to the lowest EFn,l observed during the first 10 periods of the project crediting period (tN2O/HNO3)

Emission reductions for the project activity over a specific project campaign are determined by deducting the campaign-specific emission factor (EFn) from the baseline emission factor (EFBL) and multiplying the result by the production output of 100% concentrated nitric acid over that very campaign period and the GWP of N2O:

ERl = (EFBL,l – EFp,l) * NAPl * GWPN2O (tCO2e) Formula 8

Where:

ERl Emission reductions of the project for the specific campaign of line l (tCO2e)

NAPl Nitric acid production for the project campaign of line l (tHNO3). The maximum value of NAP shall not exceed the design capacity.

EFBL, l Baseline emission factor of line l

EFp, l Emission factor used to calculate the emissions from this particular period (i.e. the higher of EFma,n,l, EFn, l and EFmin,l)

GWPN2O Global Warming Potential of N2O: 310.




D.1.5. Where applicable, in accordance with procedures as required by the host Party, information on the collection and archiving of information on the environmental impacts of the project:

The project does not have any environmental impact besides the saving of greenhouse gas emissions.

D.2. Quality control (QC) and quality assurance (QA) procedures undertaken for data monitored:

Data (Indicate table and ID number)

Uncertainty level of data (high/medium/low)

Explain QA/QC procedures planned for these data, or why such procedures are not necessary.

P.1 Low Regular calibrations according to vendor specifications and recognised industry standards (EN 14181). Staff will be trained in monitoring procedures and a reliable technical support infrastructure will be set up.

P.2 Low Regular calibrations according to vendor specifications and recognised industry standards (EN 14181). Staff will be trained in monitoring procedures and a reliable technical support infrastructure will be set up.

P.4 Low Production data can be checked for plausibility by a second measuring after the nitric acid storage

P.5 Low Regular calibrations according to vendor specifications and recognised industry standards (EN 14181).

P.6 Low Regular calibrations according to vendor specifications and recognised industry standards (EN 14181).

B.1 Low Regular calibrations according to vendor specifications and recognised industry standards (EN 14181). Staff will be trained in monitoring procedures and a reliable technical support infrastructure will be set up.

B.2 Low Regular calibrations according to vendor specifications and recognised industry standards (EN 14181). Staff will be trained in monitoring procedures and a reliable technical support infrastructure will be set up.

B.3 Low Included in evaluation by third party validator.

B.4 Low Production data can be checked for plausibility by a second measuring after the nitric acid storage

B.5 Low Regular calibrations according to vendor specifications and recognised industry standards (EN 14181).

B.6 Low Regular calibrations according to vendor specifications and recognised industry standards (EN 14181).




D.3. Please describe the operational and management structure that the project operator will apply in implementing the monitoring plan:

In order to ensure a reliable and transparent implementation of the monitoring plan, all staff which is in charge of tasks connected to data acquisition for the monitoring will be trained and instructed accordingly. At the time of PDD writing, a detailed concept with the designation of tasks has yet to be elaborated. This will be done in the form of an internal “JI handbook” prior to the start of the project activity and documented in the first monitoring report.

Annex 3 contains a document from the plant operator that describes the operational and management structure that will apply for the monitoring and reporting of emission reduction.

Zakłady Azotowe “Puławy” S.A. is certified according to ISO 9001:2000, ISO 14001:2004 and PN-N-18001:2004.

D.4. Name of person(s)/entity(ies) establishing the monitoring plan:

The monitoring plan was defined and documented by Zakłady Azotowe “Puławy” S.A., BASF SE and FutureCamp GmbH.

.




SECTION E. Estimation of greenhouse gas emission reductions

E.1. Estimated project emissions:

Due to lacking experience with the large scale application of secondary N2O destruction at atmospheric nitric acid plants, the following numbers are based on a rough estimation of what emission levels could be achieved with the catalyst installed.

Year Expected nitric acid production [tHNO3, 100%]

Estimated project emission factor [kgN2O/tHNO3]

Estimated project emissions [tN2O]

Estimated project emissions [tCO2e]

2008 (Oct – Dec) 222,750 1.4 312 96,674

2009 891,000 1.4 1,247 386,694

2010 891,000 1.4 1,247 386,694

2011 891,000 1.4 1,247 386,694

2012 891,000 1.4 1,247 386,694

Table 2: Estimated project emissions

E.2. Estimated leakage:

No leakage emissions do accrue.

E.3. The sum of E.1. and E.2.:

See E.1.

E.4. Estimated baseline emissions:

Year Expected nitric acid production [tHNO3, 100%]

Baseline emission factor [kgN2O/tHNO3]

Estimated baseline emissions [tN2O]

Estimated baseline emissions [tCO2e]

2008 (Oct – Dec) 222,750 7 1,559 483,368

2009 891,000 7 6,237 1,933,470

2010 891,000 7 6,237 1,933,470

2011 891,000 7 6,237 1,933,470

2012 891,000 7 6,237 1,933,470

Table 3: Estimated baseline emission




E.5. Difference between E.4. and E.3. representing the emission reductions of the project:

Year Emission reduction [tN2O]

Emission reduction [tCO2e]

2008 (Oct – Dec) 1,247 386,694

2009 4,990 1,546,776

2010 4,990 1,546,776

2011 4,990 1,546,776

2012 4,990 1,546,776

Total 21,207 6,573,798

Table 4: Estimated emission reductions

E.6. Table providing values obtained when applying formulae above:

The values obtained for the estimation of project emissions, baseline emissions and emission reductions are presented in the sections above.

SECTION F. Environmental impacts

No negative environmental impacts are expected to accrue from the implementation of the proposed project activity.

F.1. Documentation on the analysis of the environmental impacts of the project, including transboundary impacts, in accordance with procedures as determined by the host Party:

No environmental impacts are expected. No requirements regarding the analysis of environmental impacts are defined by law or by the competent authority.

F.2. If environmental impacts are considered significant by the project participants or the host Party, please provide conclusions and all references to supporting documentation of an environmental impact assessment undertaken in accordance with the procedures as required by the host Party:

Not applicable, as no environmental impacts were identified.

SECTION G. Stakeholders’ comments

G.1. Information on stakeholders’ comments on the project, as appropriate:

As the project activity is an invisible technical installation at the Puławy production site without any negative environmental or social impact, no stakeholders can be identified. A stakeholder consultation at the local level has not been carried out.




Annex 1

CONTACT INFORMATION ON PROJECT PARTICIPANTS

Organisation: Zakłady Azotowe “Puławy” S.A.

Street/P.O.Box: Al. Tysiąclecia Państwa Polskiego 13

Building:

City: Puławy

State/Region: Lublin Voivodeship

Postal code: 24 – 110

Country: Poland

Phone: +48 81 565 30 00

Fax: +48 81 565 28 56

E-mail: [email protected]

URL: http://www.zapulawy.com

Represented by: Krzysztof Dziuba

Title: Senior Technologist

Salutation: Mr.

Last name: Dziuba

Middle name:

First name: Krzysztof

Department: Strategy and Development Department

Phone (direct): +48 81 565 38 82

Fax (direct): +48 81 565 38 81

Mobile:

Personal e-mail: [email protected]




Annex 2

BASELINE INFORMATION

The following parameters are available at validation and serve for the determination of the permitted operating conditions:

Data / Parameter: AFRl

Data unit: kgNH3/h

Description: Ammonia gas flow rate to the AOR of line l

Source of data: Flow meters (metering points FFY2101, FFY2201, FFY2301, FFY2401)

Measurement procedures (if any):

Monitoring frequency: Continuously

QA/QC procedures to be applied:

Any comment: To be obtained from the operating condition campaign. The information will be stored in electronic records and paper for at least 2 years.

Data / Parameter: AIFRl

Data unit: m3/h

Description: Air input flow rate of line l

Source of data: Flow meters (metering points FI2110, FI2210, FI2310, FI2410)




Any comment: To be obtained from operating condition campaign. The information will be stored in electronic records and paper for at least 2 years.

Data / Parameter: CLnormal, l

Data unit: tHNO3

Description: Normal campaign length of line l

Source of data: Calculated from nitric acid production data


Monitoring frequency: Prior to end of first campaign of baseline period


Any comment: Average historical campaign length during the operation condition campaigns




Data / Parameter: OTd,r,l

Data unit: °C

Description: Daily mean oxidation temperature of each of three oxidation reactors (r) of each line (l)

Source of data: Temperature measurement at each reactor at each line



QA/QC procedures:

Any comment: To be obtained from the operating condition campaigns. The information will be stored in electronic records and paper for at least 2 years.

Data / Parameter: OPd,l

Data unit: Pa

Description: Daily mean oxidation pressure at each line (l)

Source of data: Monitored




Any comment: To be obtained from the operating condition campaign. The information will be stored in electronic records and paper for at least 2 years.

Data / Parameter: GSnormal, l

Data unit:

Description: Normal gauze supplier for the operating condition campaigns of line l



Monitoring frequency: Each campaign


Any comment: To be obtained during the operating condition campaigns. The information will be stored in electronic records and paper for at least 2 years.

The information is confidential and will only be available at the plant for determination and verification procedures.




Data / Parameter: GCnormal, l

Data unit:

Description: Gauze composition during the operating condition campaigns of line l



Monitoring frequency: Each campaign


Any comment: To be obtained during the operating condition campaigns. The information will be stored in electronic records and paper for at least 2 years.

The information is confidential and will only be available at the plant for determination and verification procedures.

The tables below present the outcomes of the evaluation and statistical analysis of the data from the last five campaigns of each line.

Operating condition campaigns

Line 1 (L211)

Nr. Campaign period Total operating hours

Total HNO3 production

1. 05/01/2007 – 11/06/2007 3741 h 105,669 t

2. 22/07/2006 – 03/01/2007 3912 h 112,989 t

3. 31/01/2006 – 27/06/2006 3543 h 103,039 t

4. 18/08/2005 – 22/01/2006 3687 h 108,768 t

5. 16/02/2005 – 07/08/2005 4068 h 117,617 t

Average HNO3 production 109,616 t

Line 2 (L212)



1. 09/06/2007 – 19/11/2007 3923 h 103,178 t

2. 12/01/2006 – 08/06/2007 3515 h 95,066 t

3. 05/08/2006 – 10/01/2007 4163 h 114,041 t

4. 22/02/2006 – 25/07/2006 3660 h 102,159 t

5. 14/09/2005 – 20/02/2006 3593 h 101,112 t





Line 3 (L213)



1. 27/08/2007 – 07/02/2008 3908 h 107,848 t

2. 29/01/2007 – 24/07/2007 4153 h 119,086 t

3. 17/08/2006 – 28/01/2007 3906 h 112,662 t

4. 02/03/2006 – 06/08/2006 3502 h 101,780 t

5. 12/09/2005 – 28/02/2006 3758 h 107,760 t


Line 4 (L214)



1. 28/02/2007 – 01/09/2007 4398 h 116,581 t

2. 22/09/2006 – 27/02/2007 3791 h 102,807 t

3. 08/03/2006 – 20/09/2006 4015 h 107,498 t

4. 21/09/2005 – 06/03/2006 3691 h 103,990 t

5. 22/03/2005 – 19/09/2005 3923 h 111,046 t


Permitted operating conditions for the baseline measurement

Oxidation temperature: normal range [°C] Line

R01 R02 R03

Oxidation pressure: normal range [MPa]

Maximum ammonia gas flow rate [TNm³/h]

Maximum ammonia to air ratio

1 (L211) 878 – 894 878 – 896 881 – 894 0,364 – 0,396 10.59 11.11 %

2 (L212) 880 – 895 884 – 895 879 – 895 0,359 – 0,385 10.83 11.15 %

3 (L213) 885 – 896 880 – 894 879 – 895 0,366 – 0,390 10.56 10.80 %

4 (L214) 881 – 892 879 – 895 865 – 886 0,346 – 0,387 10.74 11.40 %

Plant specifications, taken from a chart included in the “Technology instruction for the process of production of nitric acid”:

• Ammonia input rate: 8072 kg/h

• Ammonia to air ratio: not defined

• Oxidation pressure: Max. 0.4 MPa (above atmosphere)

• Oxidation temperature: not defined (as this depends on ammonia to air ratio)




Annex 3

MONITORING PLAN

Monitoring is described in section D.

The following note from the plant operator describes the managements structure and procedures that shall apply in order to ensure high reliability and quality of baseline and project monitoring.

Organizational Structure

Relation between management structure and operational structure are as follows:

Ammonium-nitrate Department Manager from AGRO Division – responsible for the supervision of the

Automated Measurement System (AMS) and Emission Calculator for the measurements of emissions

and installation process parameters and responsible for the system generated data processing in special

calculation sheets. Collected data are transferred to the Strategy and Development Department.




Strategy and Development Department – analyzing data and prepares report according to requirements

of the procedures and responsible for assurance of the project execution according to the JI procedures

and according to PDD and other related to the task JI standards.

Finance Department are supporting the Strategy and Development Department by conducting a routine

consistency checks (accounting controls).

Strategy and Development Department will report to the President of the Board/ Management Board /

Supervisory Board as per progress of works and execution of the JI project. In case of necessity Strategy

and Development Department shall send a report for each period (it shall be basically the calculation

spreadsheet from AGRO Division) to the ERU owner and Validator.

Task Group for the N2O emission reduction project implementation in ZAP – can in any time be used as

support for the Strategy and Development Department in case of lack of personnel or changes.

ZAP shareholders shall obtain yearly report of the project execution from Board of Management, the

same as will be received by the Validator.

Downtime of Automated Measuring System

In the event that the monitoring system is down, the lowest between the conservative IPCC (4.5 kg

N2O/ton nitric acid) or the last measured value will be valid and applied for the downtime period for the

baseline emission factor, and the highest measured value in the campaign will be applied for the

downtime period for the campaign emission factor.

Calculation of Emission Reductions

The calculation of the Emission Reductions is done after each campaign by the Nitric Acid Plant

Technologist (AGRO Division) or Technology Specialist (Strategy and Development Department),

based on the campaign data, and validated by the Nitric Acid Plant Manager.

ZAP is responsible for the declaration of the Emission Reductions, at a frequency to be fixed later in the

project implementation.

Training

The operational procedures regarding management structure, responsibilities and training implemented

at the nitric acid plant fulfill standard Integrated Management System (ISO 9001:2000, ISO 14001:2004

and PN-N-18001:2004) – it has been additionally described in procedure P-05.01 „Documentation

supervision”, P-09.01, „Production Process Control” and P-18.01 „Training”.

There is a “Technology instruction for the process of production of nitric acid” number AN-3/T1,

“Working place instruction for operation of the steering room for nitric acid plant” number AN-3/K/S1,

“Working place instruction for operation of the turbines for nitric acid plant” number AN-3/K/S2,

“Working place instruction for operation of the boilers and reactors room for nitric acid plant” number

AAN-3/K/S3 and “Working place instruction for operation of the NOx absorption and cooling water

system for nitric acid plant” number AN-3/K/S4 and the changes introduced due to this project will be

done according to that procedure for the operation team.

The Instrumentation and Automation Company PiA-ZAP Sp. z o.o., which will be responsible for the

adjustments, calibration and operation of the N2O analyzer and the corresponding training will be done

in accordance with ISO-9000 Quality System certified by TUV Rheinland and the Quality Management

Certificate ISO 9000:2000 issued by UDT-CERT.

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