ANWIL S.A. - Bureau Veritas

VERIFICATION REPORT 

ANWIL S.A. 

VERIFICATION OF THE 

N2O EMISSION REDUCTION 

PROJECT AT ZAKŁADY AZOTOWE 

ANWIL S.A. 

1 ST PERIODIC 

LINE A 19/07/2008 - 24/02/2009 

LINE B 17/05/2008 -10/01/2009 

REPORT NO. PL9000439 

REVISION NO. 07 

BUREAU VERITAS CERTIFICATION

BUREAU VERITAS CERTIFICATION 


Report No: PL9000439 

Date of first issue: Organizational unit: 

30 December 2009 Bureau Veritas Certification 

Holding SAS 

Client: 

Anwil S.A. 

Client ref.: 

Mr. Jaroslav Ptaszynsky 

Summary: 

Bureau Veritas Certification has made the verification of the “N2O emissions reduction project at Zakłady 

Azotowe Anwil S.A.” project of ANWIL S.A. located in Włocławek, Poland on the basis of UNFCCC criteria for 

the JI, as well as criteria given to provide for consistent project operations, monitoring and reporting, as well as 

the host country criteria under Track 1 procedure. 

The verification scope is defined as a periodic independent review and ex post determination by the Accredited 

Independent Entity of the monitored reductions in GHG emissions during defined verification period, and 

consisted of the following three phases: i) desk review of the Monitoring Report, Project Design Document and 

the baseline and monitoring plan; ii) follow-up interviews with project stakeholders; iii) resolution of outstanding 

issues and the issuance of the final verification report and opinion. The overall verification, from Contract 

Review to Verification Report & Opinion, was conducted using Bureau Veritas Certification internal procedures. 

The first output of the verification process is a list of Clarification Requests, Corrective Actions Requests, 

Forward Actions Requests (CL, CAR and FAR), presented in Appendix A. 

In summary, Bureau Veritas Certification confirms that the project is implemented as planned and described in 

validated and registered project design documents. Installed equipment being essential for generating 

emission reduction runs reliably and is calibrated appropriately. The monitoring system is in place and the 

project is generating GHG emission reductions. The GHG emission reduction is calculated without material 

misstatements. 

Our opinion relates to the project’s GHG emissions and resulting GHG emissions reductions reported and 

related to the valid and registered project baseline and monitoring, and its associated documents. Based on 

information seen and evaluated we confirm that the implementation of the project has resulted in 

573685 t CO2e reductions during periods from 19/07/2008 through 24/02/2009 and from 17/05/2008 through 

10/01/2009 on Line A and B respectively. 

Report No.: Subject Group: 

PL9000439 JI 

Project title: 

N2O emissions reduction project at Zakłady Azotowe 

Anwil S.A. 

Work carried out by: 

Team Leader : Nadiia Kaiun 

Team Member : Witold Dzugan 

Work verified by: 

Ivan Sokolov 

Date of this revision: 

28.02.2010 

Rev. No.: 

7 

Number of pages: 

80 

Indexing terms 

Climate Change, Kyoto Protocol, JI, Emission 

Reductions, Verification 

No distribution without permission from the 

Client or responsible organizational unit 

Limited distribution 

Unrestricted distribution 

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Abbreviations 


AIE 

BVCH 

Accredited Independent Entity 

Bureau Veritas Certification Holding SAS 

CAR Corrective Action Request 

CL Clarification Request 

CO2 Carbon Dioxide 

ERU Emission Reduction Unit 

FAR Forward Action Request 

GHG Green House Gas(es) 

IETA International Emissions Trading Association 

JI Joint Implementation 

JISC JI Supervisory Committee 

MoV Means of Verification 

MP Monitoring Plan 

PCF Prototype Carbon Fund 

PDD Project Design Document 

UNFCCC United Nations Framework Convention on Climate Change 

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Table of Contents Page 

1 INTRODUCTION ................................................................................................... 4 

1.1 Objective 4 

1.2 Scope 5 

1.3 GHG Project Description 5 

2 METHODOLOGY .................................................................................................. 8 

2.1 Review of Documents 12 

2.2 Follow-up Interviews 12 

2.3 Resolution of Clarification, Corrective and Forward Action 

Requests 12 

3 VERIFICATION FINDINGS ............................................................................ 13 

3.1 Remaining issues CAR’s, FAR’s from previous 

determination/verification 13 

3.2 Project Implementation 26 

3.3 Internal and External Data 27 

3.4 Environmental and Social Indicators 34 

3.5 Management and Operational System 34 

4 FIRST PERIODIC VERIFICATION FINDINGS .................................................. 37 

4.1 Completeness of Monitoring 37 

4.2 Accuracy of Emission Reduction Calculations 38 

4.3 Quality Evidence to Determine Emissions Reductions 39 

4.4 Management System and Quality Assurance 39 

5 PROJECT SCORECARD................................................................................. 42 

6 FIRST PERIODIC VERIFICATION STATEMENT ................................. 42 

7 REFERENCES ..................................................................................................... 43 

APPENDIX A: COMPANY JI PROJECT VERIFICATION PROTOCOL....................... 46 

APPENDIX B: VERIFICATION TEAM ............................................................................... 76 

APPENDIX C: DOCUMENTS CHECKED DURING VERIFICATION........................... 77 

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1 INTRODUCTION 


Anwil S.A. has commissioned Bureau Veritas Certification to verify the 

emissions reductions of its JI project " N2O emissions reduction project at 

Zakłady Azotowe Anwil S.A." (hereafter called “the project”) at Włocławek, 

Poland. 

This report summarizes the findings of the first periodic verification of the 

project, performed on the basis of criteria given to provide for consistent 

project operations, monitoring and reporting, and contains a statement for 

the verified emission reductions. 

The order includes first periodic verification of the project for the periods 

from 19/07/2008 through 24/02/2009 and from 17/05/2008 through 

10/01/2009 on Line A and B respectively. It is based on the Periodic 

Verification Report Template Version 3.0, December 2003, part of the 

Validation and Verification Manual (VVM) published by International 

Emission Trading Association (IETA). 

First periodic verification consisted of site-visit and a desk review of the 

project documents including PDD, monitoring plan, determination report, 

monitoring report and further documentation. 

First periodic verification has been performed with the account of findings 

and conclusions of the integral initial verification report No. 0085 dated 

26/08/2009. 

The results of the determination were documented by Det Norske Veritas 

Certification AS (DNV) in the report: “N2O emissions reduction project at 

Zakłady Azotowe Anwil S.A.” Report No. 2008-0013 dated February 1 st , 

2009 (See Section 7). The changed monitoring plan was determined 

during initial verification (TÜV Süddeutschland, No.0085). 

Project is approved by the Ministry of Environment in Poland and Office of 

Environmental Protection of Lichtenstein (Letters of approval are 

presented, see Section 7) and registered under Track 1. 

1.1 Objective 

Verification is the periodic independent review and ex post determination 

by the AIE of the monitored reductions in GHG emissions during defined 

verification period. 

The objective of verification can be divided in Initial Verification and 

Periodic Verification. 

Initial Verification: The objective of an initial verification is to verify that 

the project is implemented as planned, to confirm that the monitoring 

system is in place and fully functional, and to assure that the project will 

generate verifiable emission reductions. A separate initial verification 

prior to the project entering into regular operations is not a mandatory 

requirement. 

Periodic Verification: The objective of the periodic verification is to verify 

that actual monitoring systems and procedures are in compliance with the 

monitoring systems and procedures described in the monitoring plan; 

furthermore the periodic verification evaluates the GHG emission 

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reduction data and express a conclusion with a high, but not absolute, 

level of assurance about whether the reported GHG emission reduction 

data is free of material misstatements; and verifies that the reported GHG 

emission data is sufficiently supported by evidence, i.e. monitoring 

records. 

In general, verification follows UNFCCC criteria referring to the Kyoto 

Protocol criteria, the JI rules and modalities, and the subsequent 

decisions by the JISC, as well as the host country criteria. 

1.2 Scope 

Verification scope is defined as an independent and objective review and 

ex post determination by the Designated Operational Entity of the 

monitored reductions in GHG emissions. The verification is based on the 

submitted monitoring report and the determined project design document 

including the project’s baseline study and monitoring plan and other 

relevant documents. The information in these documents is reviewed 

against Kyoto Protocol requirements, UNFCCC rules and associated 

interpretations. Bureau Veritas Certification has, based on the 

recommendations in the Validation and Verification Manual employed a 

risk-based approach in the verification, focusing on the identification of 

significant risks of the project implementation and the generation of 

ERUs. 

The verification is not meant to provide any consulting towards the Client. 

However, stated requests for forward actions and/or corrective actions 

may provide input for improvement of the project monitoring towards 

reductions in the GHG emissions. 

The audit team has been provided with a Monitoring Report version 10 

dated 8 th of January 2010 and underlying data records, covering the 

periods from 19/07/2008 through 24/02/2009 inclusive and from 

17/05/2008 through 10/01/2009 inclusive on Line A and B respectively. 

1.3 GHG Project Description 

The purpose of the project is the reduction of nitrous oxide (N2O) 

emissions from the two nitric acid production lines A and B at the Nitrogen 

Works Anwil S.A. The Company is situated in Włocławek, Kujawsko- 

Pomorskie Voivodship, Poland. 

Basically, N2O formation is a result of unwanted chemical reactions that 

take place during the catalytic oxidation of ammonia which is the first 

stage in the nitric acid production process. Some part of the N2O is 

destroyed already in the ammonia oxidation reactor, while the non 

destroyed N2O is emitted with the tail gases. N2O is a high potential 

greenhouse gas with a green house warming potential (GWP) of 310. 

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Installation secondary N2O reduction catalyst underneath the primary 

catalyst precious metal catching and catalytic gauzes package in the 

ammonium burner was applied at two production lines A and B of Anwil 

plant. Secondary catalysts were installed in all 4 ammonia oxidation 

reactors of one production line A, and in all 4 ammonia oxidation reactors 

of another production line B. According to guarantees provided by major 

secondary catalyst supplier installation of the secondary catalysts allows 

more than 70% reduction of the N2O content in the tail gas. 

The secondary catalyst was placed in the appropriate support structure. 

The gap between the edge of the support structure and inside wall of the 

ammonia burner was sealed to prevent the process gas by-passing the 

secondary catalyst. In this way the technology ensures that all gases 

which pass through the primary catalyst also will pass through the 

secondary catalyst. 

Anwil production lines use a dual pressure technology, with 3.4-3.6 abs. 

bars in the ammonia oxidation process and 8.51 abs. bars at the 

absorption process. Nameplate capacity of the plant is 328,500 tonnes of 

nitric acid per line per year as defined in the PDD version 1.3. and 

Monitoring Report version 10. However the licensor (Grande Paroisse) 

designed the line to operate within the load range 70% - 110%. Therefore, 

the maximum capacity equals to 361,350 tonnes (365 days x 990 tonnes). 

The actual production capacity depends on the number of operational 

hours per year, during which nitric acid is produced and the production 

load used. The time length of the primary catalyst campaign in the 

ammonia oxidation reactors are based on the length of 5 previous 

historical campaigns, which in average is determined to as 214 days /18/. 

AMS installed at the operating plant is in compliance with the European 

norm EN14181, which assumes three levels of quality assurance of the 

measurement systems - QAL1, QAL2 and QAL3. The first level (QAL1) is 

assured and certified by the measurement equipment provider and it 

refers to the performance and accuracy of the system. The second level 

of quality assurance (QAL2) guarantees the correct installation of the 

AMS and its proper operation at the plant. The third level (QAL3) is aimed 

to guarantee the maintenance and regular proper functioning of the 

measurement equipment and the measurement data provided. 

N2O emissions monitoring system is installed in both nitric acid lines A 

and B. It consists of the measurement devices part and data processing 

and storage part. 

Monitoring system of N2O emission includes: 

• analyzer of N2O concentration in tail gases 

• ultrasonic flow meter for tail gases flow measurement, 

• pressure transmitter, 

• temperature transmitter, 

• Emission Computer – hardware and software dedicated for reports in 

environment protection. 

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Nitric acid production, ammonia flow and air flow including necessary 

temperature and pressure parameters are measured continuously. 

Analogue signals 4-20mA from measurement devices installed on the 

nitric acid production lines are recorded on a 1 second basis in the data 

logger, where these signals are digitalized to 4 byte signals. Analogue 

signals 4-20mA from the DCS system are recorded on a 1 second basis 

and sent to the data logger, where these signals are digitalized to 4 byte 

signals. All signals are then sent via converter to the emission computer, 

where these signals are stored. 

Data logger KX-6 collects measured data and processes them. All 

measurement data received from the data logger KX-06 are recorded on a 

1 second basis to the emission computer KE MIKROS hard disc. Data are 

further processed in the emission computer, where corrected nitric acid 

flow and tail gas flow are calculated. 

All KE MIKROS values are archived on the emission computer’s hard disc. 

All analogue values including measured values, operational conditions, 

corrected data and normalized parameters data are recorded by the KE 

MIKROS on a 1 second basis. These data are archived for several months 

but not less than 3 month. Due to the fact that this archive needs a lot of 

memory hourly averages are archived. Data overwriting process is 

controlled via special software which automatically overwrites oldest data 

in its memory after expiration of given period of time limited by a hard 

disc capacity. Hourly averages are archived in a paper form and also 

electronically in an Excel file on separate computer and it is possible to 

store them also on a CD-Rom. It is possible to access data stored on the 

emission computer hard disc. 

All data necessary for the CO2 emission reductions calculation is 

collected in the Maintenance Technician/ Maintenance Engineer 

Department. Maintenance Technician/Maintenance Engineer is performing 

reports on daily and monthly basis, which are send to Vertis for 

performing final calculations. 

Maintenance technician/maintenance engineer coordinates the process of 

checking and calibration of instruments according to previously accepted 

schedule. In case of inefficient instrument, immediately the information is 

handed over to Specialist Company ordering them to take some activities 

that make the instrument operating properly. This fact, on 1st shift, is 

notified by maintenance technician from AR-22 Dept, and on other shifts it 

is done by shift coordinator from A-2 Plant. Maintenance 

technician/maintenance engineer from Department AR-22 inspects 

received instrument after service that has been done according to 

established agreements and reports all these activities in suitable sheet. 

In case when repair is impracticable, the instrument is subjected to be out 

of service. Lacks of measured values are pointed with comment in 

Consolidated data report which is pass on to Project Consultant. 

In case of failure one of the stations from EMISJA System for recording of 

selected process measurements, redundant enables second station to 

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collect data and storage them. There is possibility to fill lacking data from 

another station after end of campaign. In case of failure both of stations, 

any other PC with installed OPC Server can work as OPC Server. 

As a result estimated project risks are limited and minimized. 

The separate treatment of the two nitric acid lines and overlapping of the 

monitoring periods are allowed by the clarification issued Joint 

Implementation Supervisory Committee on its 13 th Meeting: “Clarification 

regarding overlapping monitoring periods under the verification procedure 

under the Joint Implementation Supervisory Committee.” 

The Project meets all the requirements set out by the clarification: 

1. The Project is composed of clearly identifiable components for which 

emission reductions or enhancements of removals are calculated 

independently; 

2. Monitoring is performed independently for each of these components, 

i.e. the data/parameters monitored for one component are not dependent 

on/effect data/parameters (to be) monitored for another component; 

3. The monitoring plan ensures that monitoring is performed for all 

components and that in these cases all the requirements of the JI 

guidelines and further guidance by the JISC regarding monitoring are met. 

2 METHODOLOGY 

The verification is as a desk review and field visit including discussions 

and interviews with selected experts and stakeholders. 

In order to ensure transparency, a verification protocol was customized 

for the project, according to the Validation and Verification Manual 

(IETA/PCF) a verification protocol is used as part of the verification (see 

Section 7). The protocol shows, in a transparent manner, criteria 

(requirements), means of verification and the results from verifying the 

identified criteria. The verification protocol serves the following purposes: 

It organises, details and clarifies the requirements the project is expected 

to meet; and 

It ensures a transparent verification process where the verifier will 

document how a particular requirement has been verified and the result of 

the verification; 

The verification protocol consists of one table under Initial Verification 

checklist and four tables under Periodic verification checklist. The 

different columns in these tables are described in Figure 1. 

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The overall verification, from Contract Review to Verification Report & 

Opinion, was conducted using Bureau Veritas Certification procedures. 

The completed verification protocol is enclosed in Appendix A to this 

report. 

Initial Verification Protocol Table 1 

Objective Reference Comments Conclusion (CARs/FARs) 

The requirements the 

project must meet 

Gives reference to 

where the 

requirement is 

found. 

Description of 

circumstances and 

further comments 

on the conclusion 

This is either acceptable based on 

evidence provided (OK), or a 

Corrective Action Request (CAR) 

of risk or non-compliance of the 

stated requirements. Forward 

Action Request (FAR) indicates 

essential risks for further periodic 

verifications. 

Periodic Verification Checklist Protocol Table 2: Data Management System/Controls 

Identification of potential 

reporting risk 

The project operator’s data 

management system/controls 

are assessed to identify 

reporting risks and to assess 

the data management 

system’s/control’s ability to 

mitigate reporting risks. The 

GHG data management 

system/controls are assessed 

against the expectations 

detailed in the table. 

Identification, 

assessment and testing 

of management controls 

A score is assigned as 

follows: 

• Full - all bestpractice 

expectations are 

implemented. 

• Partial - a 

proportion of the 

best practice 

expectations is 

implemented 

• Limited - this 

should be given if 

little or none of 

the system 

component is in 

place. 

Areas of residual risks 

Description of circumstances and further 

commendation to the conclusion. This is 

either acceptable based on evidence 

provided (OK), or a Corrective Action 

Request (CAR) of risk or non compliance 

with stated requirements. The corrective 

action requests are numbered and 

presented to the client in the verification 

report. The Initial Verification has 

additional Forward Action Requests 

(FAR). FAR indicates essential risks for 

further periodic verifications. 

Periodic Verification Protocol Table 3: GHG calculation procedures and management control 

testing 

Identification of potential 

reporting risk 

Identify and list potential reporting 

risks based on an assessment of 

the emission estimation 

procedures, i.e. 

� the calculation methods, 

� raw data collection and 

sources of supporting 

Identification, assessment and 

testing of management controls 

Identify the key controls for each area 

with potential reporting risks. Assess 

the adequacy of the key controls and 

eventually test that the key controls are 

actually in operation. 

Internal controls include (not 

exhaustive): 


Identify areas of residual 

risks, i.e. areas of 

potential reporting risks 

where there are no 

adequate management 

controls to mitigate 

potential reporting risks 

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documentation, 

� reports/databases/informat 

ion systems from which 

data is obtained. 

Identify key source data. Examples 

of source data include metering 

records, process monitors, 

operational logs, 

laboratory/analytical data, 

accounting records, utility data and 

vendor data. Check appropriate 

calibration and maintenance of 

equipment, and assess the likely 

accuracy of data supplied. 

Focus on those risks that impact 

the accuracy, completeness and 

consistency of the reported data. 

Risks are weakness in the GHG 

calculation systems and may 

include: 

� manual transfer of 

data/manual calculations, 

� unclear origins of data, 

� accuracy due to 

technological limitations, 

� lack of appropriate data 

protection measures? For 

example, protected 

calculation cells in 

spreadsheets and/or 

password restrictions. 


� Understanding of 

responsibilities and roles 

� Reporting, reviewing and 

formal management 

approval of data; 

� Procedures for ensuring 

data completeness, 

conformance with reporting 

guidelines, maintenance of 

data trails etc. 

� Controls to ensure the 

arithmetical accuracy of the 

GHG data generated and 

accounting records e.g. 

internal audits, and 

checking/ review 

procedures; 

� Controls over the computer 

information systems; 

� Review processes for 

identification and 

understanding of key 

process parameters and 

implementation of calibration 

maintenance regimes 

� Comparing and analysing 

the GHG data with previous 

periods, targets and 

benchmarks. 

When testing the specific internal 

controls, the following questions are 

considered: 

1. Is the control designed properly to 

ensure that it would either prevent 

or detect and correct any 

significant misstatements? 

2. To what extent have the internal 

controls been implemented 

according to their design; 

3. To what extent have the internal 

controls (if existing) functioned 

properly (policies and procedures 

have been followed) throughout 

the period? 

4. How does management assess 

the internal control as reliable? 

Areas where data 

accuracy, completeness 

and consistency could be 

improved are highlighted. 

Periodic Verification Protocol Table 4: Detailed audit testing of residual risk areas and random 

testing 

Areas of residual Additional verification Conclusions and Areas Requiring 

10




risks testing performed Improvement 

(including Forward Action Requests) 

List the residual areas 

of risks (Table 2 where 

detailed audit testing 

is necessary. 

In addition, other 

material areas may be 

selected for detailed 

audit testing. 

The additional verification 

testing performed is described. 

Testing may include: 

1. Sample cross checking of 

manual transfers of data 

2. Recalculation 

3. Spreadsheet ‘walk 

throughs’ to check links 

and equations 

4. Inspection of calibration 

and maintenance records 

for key equipment 

� Check sampling 

analysis results 

� Discussions with 

process engineers 

who have detailed 

knowledge of process 

uncertainty/error 

bands. 

Having investigated the residual risks, the 

conclusions should be noted here. Errors and 

uncertainties should be highlighted. 

Errors and uncertainty can be due to a 

number of reasons: 

� Calculation errors. These may be due 

to inaccurate manual transposition, 

use of inappropriate emission factors 

or assumptions etc. 

� Lack of clarity in the monitoring plan. 

This could lead to inconsistent 

approaches to calculations or scope 

of reported data. 

� Technological limitations. There may 

be inherent uncertainties (error 

bands) associated with the methods 

used to measure emissions e.g. use 

of particular equipment such as 

meters. 

� Lack of source data. Data for some 

sources may not be cost effective or 

practical to collect. This may result in 

the use of default data which has 

been derived based on certain 

assumptions/conditions and which 

will therefore have varying 

applicability in different situations. 

The second two categories are explored with 

the site personnel, based on their knowledge 

and experience of the processes. High risk 

process parameters or source data (i.e. those 

with a significant influence on the reported 

data, such as meters) are reviewed for these 

uncertainties. 

Verification Protocol Table 5: Resolution of Corrective Action and Clarification Requests 

Report clarifications 

and corrective action 

requests 

If the conclusions from 

the Verification are 

either a Corrective 

Action Request or a 

Clarification Request, 

these should be listed in 

this section. 

Ref. to checklist 

question in tables 

2/3 

Reference to the 

checklist question 

number in Tables 2, 3 

and 4 where the 

Corrective Action 

Request or 

Clarification Request 

is explained. 

Figure 1 Verification protocol tables 

Summary of project 

owner response 

The responses given 

by the Client or other 

project participants 

during the 

communications with 

the verification team 

should be summarized 

in this section. 

Verification conclusion 

This section should 

summarize the verification 

team’s responses and final 

conclusions. The 

conclusions should also be 

included in Tables 2, 3 and 

4, under “Final Conclusion”. 

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2.1 Review of Documents 

The Monitoring Report (MR) version 5 dated 11 of November 2009 submitted 

by Vertis Finance Kft. and additional background documents related to the 

project design and baseline, i.e. country Law, Project Design Document 

(PDD), applied methodology, Kyoto Protocol, Clarifications on Verification 

Requirements to be checked were reviewed. To address Bureau Veritas 

Certification corrective action and clarification requests, Vertis Finance 

Kft. revised the MR and resubmitted it on 8 th of January 2010 as version 

10. 

The verification findings presented in this report relate to the project as 

described in the PDD version 1.3 and Monitoring Report version 10. 

2.2 Follow-up Interviews 

On 09/12/2009 Bureau Veritas Certification performed interviews with 

project stakeholders to confirm selected information and to resolve issues 

identified in the document review. Representatives of Zakłady Azotowe 

Anwil S.A., developer were interviewed (see 7 References). The main 

topics of the interviews are summarized in Table 1. 

Table 1 Interview topics 

Interviewed organization Interview topics 

Zakłady Azotowe Anwil S.A. Organizational structure. 

Responsibilities and authorities. 

Training of personnel. 

Quality management procedures and technology. 

Implementation of equipment (records). 

Metering equipment control. 

Metering record keeping system, database. 

Social impacts. 

Environmental impacts. 

Consultant: 

Baseline methodology. 

Vertis Finance Kft. 

Monitoring plan. 

Monitoring report. 

Deviations from PDD. 

2.3 Resolution of Clarification, Corrective and Forward Action 

Requests 

The objective of this phase of the verification is to raise the requests for 

corrective actions and clarification and any other outstanding issues that 

needed to be clarified for Bureau Veritas Certification positive conclusion 

on the GHG emission reduction calculation. 

Findings established during the initial verification can either be seen as a 

non-fulfilment of criteria ensuring the proper implementation of a project 

or where a risk to deliver high quality emission reductions is identified. 

12




Corrective Action Requests (CAR) are issued, where: 

i) there is a clear deviation concerning the implementation of the project 

as defined by the PDD; 

ii) requirements set by the MP or qualifications in a verification opinion 

have not been met; or 

iii) there is a risk that the project would not be able to deliver (high 

quality) ERUs. 

Forward Action Requests (FAR) are issued, where: 

iv) the actual status requires a special focus on this item for the next 

consecutive verification, or 

v) an adjustment of the MP is recommended. 

The verification team may also use the term Clarification Request (CL), 

which would be where: 

vi) additional information is needed to fully clarify an issue. 

To guarantee the transparency of the verification process, the concerns 

raised are documented in more detail in the verification protocol in 

Appendix A. 

3 VERIFICATION FINDINGS 

In the following sections, the findings of the verification are stated. The 

verification findings for each verification subject are presented as follows: 

1) The findings from the desk review of the original project activity 

documents and the findings from interviews during the follow up visit are 

summarized. A more detailed record of these findings can be found in the 

Verification Protocol in Appendix A. 

2) The conclusions for verification subject are presented. 

In the final verification report, the discussions and the conclusions that 

followed the preliminary verification report and possible corrective action 

requests are encapsulated in this section. 

3.1 Remaining issues CAR’s, FAR’s from previous 

determination/verification 

One task of the verification is to check the remaining issues from the 

previous determination and verification or issues which are clearly defined 

for assessment in the PDD. The determination report prepared by Det 

Norske Veritas Certification AS (DNV) does not note any open issues. 

The Initial Verification Report prepared by TUV SUD, Reference No. 0085, 

dated 26/08/2009 notes the following open issues: 

Forward Action Request (FAR) 1 

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On the other hand, no analysis has not yet been done on the result of the 

baseline campaigns, including the study on “permitted operating range” 

and “baseline emission factor” (Please see 4) of FAR 2) Therefore, a 

verifier at the 1st periodic verification is expected to check the 

fundamental issue e.g. the effectiveness of the baseline campaign. 

Response 

Verification Team was provided with both the MR and the emission 

reduction model for production Line A and B. The model contains the raw 

data that Vertis receives from Anwil, so the validity of the data and the 

operating conditions permitted range in the model were checked and 

found satisfactory. 

Conclusion of verification team 

Issue is closed. 


A verifier at the subsequent 1st periodic verification should pay attention 

specially on the following issues; 

5) Annual Design Capacity is not clearly identified in PDD, i.e. not clear to 

know if the project proponent is talking about applicability conditions of 

AM0034 with “nameplate capacity” or “maximum capacity”. In addition, 

daily capacity multiplied by “365 days per year” to determine annual 

capacity could be an issue. And the determination report has just the 

identical description which looks to be copied & pasted from PDD. A 

verifier who conduct the first verification should pay attention on these 

issue as we currently do not know if it is approved by the host party or 

JISC (in case of track2). This can be one of key issues at periodic 

verifications in case “cap” of the amount of ERUs should be discussed in 

accordance with the applied methodology. 

6) Though both PDD and Determination Report state that “permitted 

operating ranges have been determined using the ranges stipulated in the 

operating manual”, applicable values are not found in the operating 

manual. And they were actually determined considering historic monthly 

records, design documents and the operating manual, in accordance with 

the result of interviews at the on-site visit. As clarification on ways how 

they actually determined is being requested by the verification team, there 

is a possibility of having changes on them in general. (Please see CR 9) 

7) Flexibility of the choice of the primary catalyst stated in PDD is one of 

the major deviations from AM0034 however the determination report never 

discusses this issue and thus how they accepted is unknown to the 

verifier. And currently unknown if it will be approved by the host party or 

JISC (in case of track 2). The comparison required by AM0034 of the 

operating conditions between permitted operating ranges and the result of 

14




baseline campaign is missing both in PDD and the determination report. 

And the data treatment in case of “AMS down time” is also missing. What 

a verifier can do at periodic verifications will be to work on the 

assumption that these issues are applied without having deviation from 

the applied methodology. 

Response 

PDD on its page 7 defines the nameplate capacity at the level 328,500 

tHNO3 per line per year. This value is established in accordance with the 

methodology AM0034, which says on this issue following: 

By nameplate (design) implies the total yearly capacity (considering 365 

days of operation per year) as per the documentation of the plant 

technology provider (such as the Operation Manual). 

Daily production capacity of one Anwil GP nitric acid plant has been 

increased from 990 tHNO3 up to 1,100 tHNO3 and thus nameplate 

capacity calculated according to the methodology is 328,500 tHNO3. 

(before the capacity upgrade) or 401,500 tHNO3 (updated capacity). 

6) Permitted range of the operating conditions has been defined based on 

the plant operation manual, as it is stated in the PDD. Historic data on 

operating conditions are available as daily averages in the paper format 

only. There are no hourly averages available and they are not considered 

by the project proponents as transparent enough for purpose of the JI 

project. It is not possible to establish permitted range of operating 

conditions based on daily averages which eliminate minimums and 

maximums occurring during a day operation. Because of this reason 

project proponents have decided to choose the option B, i.e. 

establishment of the permitted range of the operating conditions based on 

the plant operation manual. 

7) This approach has been approved by the Host Party via act of the 

project Track I registration following the publication of the determination 

report. Relevant study has been provided to verification team. 


Evidencing documents were seen and found satisfactory. 


A comprehensive list of all measuring equipment used as raw data for 

calculating the emission reduction would be elaborated to help both the 

plant owner and a verifier. This list would include specific information e.g. 

ID number, manufacture, type, serial number, applicable parameter 

specified by the methodology, measurement ranges, required calibration 

15




frequency and the status of calibration (last/next planned) and references 

to applicable procedures, etc. 

Response 

The list of all measuring equipment involved in JI Project was prepared in 

Polish and English. This list has been provided to verification team. 


Evidencing documents were seen and found satisfactory. 


The measured data of N2O Analyzer installed at Line A were abnormal for 

nearly 1 month from starting the baseline campaign on 15th October 2007 

to 7th November 2007. Please make sure that “AMS downtime” mentioned 

in the 2nd last page of the methodology will be applied in the 

determination of baseline emissions. But AMS downtime shall not be 

limited to this period only. If other abnormalities, e.g. significant deviation 

found at Zero/Span checks are found, AMS downtime shall be applied for 

applicable weeks. 

Response 

N2O analyzer emission data for the relevant period have been treated in 

accordance with the PDD, this is clearly defined in the emission 

reductions model. 




Not mandatory but a diagram of data flow would be developed for both the 

project proponent and a verifier, to illustrate how each element of 

monitoring system interchanges, process and store the data measured. 

Or, please provide any other verifiable way. Because data in an Excel file 

as the last processed data are not really “raw”. E.g. N2O concentration at 

Line A were fixed at 2,479 mgN2O/m3 from the starting baseline 

campaign on 15 th October 2007 to 31st October 2007, and were fixed at 

2,463 mgN2O/m3 from 1st November to 7th November 2007. Though 

these data are obviously processed results, it is not easy to find out how 

and on which unit. 

16



Response 


Anwil follows in replacement of the data during periods of the AMS 

malfunction applicable Polish regulation, when data for giver period of 

time are replaced by an average value of time period preceding the AMS 

malfunction period. If the AMS is down e.g. for 2 hours, than these 2 hour 

data are calculated of average of 2 last measured hours before the AMS 

went down. But this approach is not applied on the emission data used for 

calculation of emission reductions, because AMS downtime data there are 

marked and replaced according to the PDD by using the IPPC default 

factor 4.5 kgN2O/tHNO3. 

Conclusion of the Verification Team 

Necessary data were checked and found satisfactory. 


The responsibilities are not so clearly described in the PDD, e.g. which 

function is responsible for punctual calibration, which function is to be 

communicated or to be reported in case of trouble/malfunction on 

monitoring system or on data, etc. As a trouble or abnormality can be 

result in financial loss in case of JI project, key responsibilities and 

important communication channel are to be identified specifically as 

possible, e.g. in an organization chart. 

Response 

This JI responsibilities chart has been provided to verification team. 




Not clear at a moment although this also depends on the necessity. 

However e.g. out of tolerance found at calibration on monitoring 

equipment, significant deviation found at Zero/Span check, malfunction on 

JI monitoring, abnormal data recorded can be subjects in advance, based 

on results of risk assessment. Therefore it is necessary to develop trouble 

shooting procedures, which can be developed e.g. in connection with 

reporting procedures, in order not loosing ERs because of no adequate 

treatment or late reporting. 

Response 

17




The troubleshooting procedures have been provided in the document 

“Instrukcija KA-IJ-09-08-02” to verification team. 


Evidencing document was checked and found satisfactory. 


The description in the table at D.2. in PDD are not so specific compared 

to the description stated in the applied methodology, e.g. spare parts, 

how to minimize downtime, what is “vendor specifications” about regular 

calibrations, etc.. This issue also depends on risks/possible 

consequences like FAR 7. Therefore it is necessary to develop a so called 

data handling protocol, which does summarize the single procedures and 

routines with relevance to the quality of emission reductions. 

Response 

Data handling protocol has been provided to verification team. Data 

handling is part of the KA-IJ-09.08.02 document. 




Maintenance Logs other than calibration would be developed. When bad 

result is assumed to be found at calibration, the measured data for whole 

period since the last successful calibration might have to be lost if we can 

not identify exact day or time when a trouble took place. In such cases, 

maintenance logs in which trouble and/or repair are recorded could 

minimize the loss of emission reductions. 

Response 

The maintenance log exists in form of the QAL3 manual and has been 

provided for review to verification team. 

Conclusion of the Verification Team. 

Document was checked and found satisfactory. 


18




Vertis Finance Kft is going to develop both calculation and Monitoring 

Report. However, since Monitoring Report had not yet been developed 

and even the determination of baseline emissions had not yet been done, 

it was not possible to assess actual processing. 

Response 

Both the monitoring report and the emission reductions model have been 

provided to verification team for purpose of the first periodic verification. 


Evidencing documents were checked and found satisfactory. 


PDD describe the same wordings as one stated in the methodology, e.g. 

“electronic and paper for at least 2 years after end of the crediting 

period.” There is a concern because such retention period is much longer 

than ordinary procedures and applicable records is various. E.g. 

evidences of gauze composition like purchasing documents could be the 

one which must be retained for many years as one of baseline records. 

And missing just a part of baseline records could crucially affect on the 

result of subsequent verifications. This also depends on risks however 

more specific procedures would be developed. 

Response 

Project data in Anwil are stored as described in the PDD. The subsequent 

evidences were provided to verification team during first periodic 

verification. 


Necessary documents were checked and found satisfactory. 


No specific activities are planned to be internal audit and management 

review for the monitoring activities and results of JI project. This kind of 

cross checking done by a personnel other than one who has an immediate 

responsibility is recommended in general, but not mandatory. 

Response 

19




Anwil has included the JI project into its internal audit schedule. This 

document has been provided to verification team. 




1. KROHNE installation and operating instructions sheet provided 

describes the OPTIMASS mass flow meter family consists of several mass 

flow meters. It should be indicated which meter exactly was used during 

the baseline campaign in order to check the specifications of that 

particular mass flow meter. As the density meter was replaced to the 

current concentration meter at the line A, please identify the date of 

replacement too if it was after starting baseline campaign at Line B. 

2. Please submit copies of commissioning reports to demonstrate 

successful installation of newly installed monitoring equipment, or to 

identify any issues discussed at the completion of the installation as well 

as to demonstrate such open issues have successfully been settled 

without making significant affection on measured data. 

Response 

Refractometer installation protocol has been provided to verification team. 

Conclusion of Verification Team 



Calibration records of measurement de vices of oxidation temperature TT, 

oxidation pressure (PT), flow meters (FT), nitric acid density meter (DT) 

and nitric acid concentration meter (DY) from 2007 onwards have been 

submitted. There is a need to give some additional explanation to the 

following: 

1. DT 2201A - please clarify the action taken on 14.11.08. 

2. PT 2202A -provide clarification on the long period of time between 

dismantling of the device and reinstallation (14.08.07-03.09.07, 31.10.07- 

09.11.07). Furthermore it should be clarified if an available backup device 

were served for tail gas pressure measurements at that time. 

3. PT 2202B provide clarifications on the long period of time between 

dismantling of the device and reinstallation (19.10.07-02.11.07). 

Furthermore it should be clarified if an available backup device were 

served for tail gas pressure measurements at that time. 

4. T 2285 7-A- please explain the actions taken on 14.11.08. 

20




5. TT 2202A, TT2202B - provide clarifications on the long period of time 

between dismantling of the device and reinstallation (29/30.05.07- 

22.06.07). 

Response 

Requested documents have been provided to Verification Team. 

Conclusion 

The calibration records and additional documents were provided to 

verification team and found satisfactory. 


Though EN14181 requires maintaining a control chart, e.g. Shewhart 

Chart or CUSUM, Shewhart Chart was still being developed. As a control 

chart is a kind of real time monitoring tool, it is theoretically too late to 

make after finishing campaigns. 

Response 

Anwil was preparing Shewart charts from beginning of installation of the 

monitoring system, i.e. several months before start of baseline campaigns 

on Lines A and B. These charts have been provided to verification team. 




Shewart charts with span check diagram: 

1. There is no date identification; furthermore unit on the y-axis is not 

clear as no translation to English has been submitted (days, weeks?) 

2. The diagrams in Shewhart control chart for span point show several 

values which were measured outside of the control limits (e.g. Line B in 

“Shewart_Span_1_3rdQ_4thQ_2007.pdf”, etc.). The conservative 

subtraction of identified uncertainties from the appropriate measured 

values has to be ensured in order to assure credibility of measured data. 

The same diagram for line A shows so many values outside of the control 

limits that it is obviously that with so many mavericks throughout this part 

of baseline the measured data cannot be considered as credible. Please 

clarify how the measured data for line A for the presented period is 

handled. 

Shewart charts with zero check diagram: 

3. Please clarify the choice of the control limits -+/- 40 ppm. 

21




General: 

4. Please clarify the lack of calibration data in some Shewart charts, such 

as Shewart_Span_1_3rdQ_4thQ_2007.pdf (if the unit at y -axis is “weeks” 

- about 6 weeks) etc. where the calibration data for line A is missing, etc. 

Please clarify how the credibility and reliability of the data measured in 

those periods can be assured. 

3. Copies of monthly records of Zero/Span checks for Line A in October, 

November 2007 and in February 2008, and for Line B in February, March 

and April 2008 have not been submitted (there are only Shewart chart 

available for the 3rd and 4thQ of 2007 and Jan_Feb_March combined in 

one chart without any identification of the explicit dates as indicated by 

issue 1 of this FAR). 

5. QAL3 manual (English version) should be provided. 

Response 

Baseline campaign on Line A started in week 42 in 2007 and continued 

until week 18 of 2008. 

During this time there was only one occurrence of the violation of the 

upper control limit in the weeks 47 and 48 of 2007. Violation of the control 

limits, which occurred prior to the baseline campaign were handled via 

sending the analyzer to the manufacturer for repair. 

After return from the repair the analyzer was installed again on October 8, 

2007 on the Line A from beginning of the baseline campaign. After one 

week of the operation the control limits violation occurred again. Anwil 

has on December 3, 2007 carried out functional tests after telephone 

consultations from manufacturer’s service. They permitted to estimate the 

influence of external conditions on readings of analyzers. Functional test 

carried out on the analyzer S/N 760501 confirmed proper functioning of 

the device. 

Baseline campaign on Line B started in week 38 of 2007 and continued 

until week 14 of 2008. 

During this time there was only one occurrence of slight violation of the 

upper control limit in the week 50 of 2007. Anwil has on December 3, 

2007 carried out functional tests after telephone consultations from 

manufacturer’s service. They permitted to estimate the influence of 

external conditions on readings of analyzers. Functional test carried out 

on the analyzer S/N 760502 confirmed smaller differences of readings on 

the line B. 

Explanation of Shewart charts in relation to Line A. 

During the time from week 40 to week 46 of 2007 the N2O analyzer, due 

to its performance in the campaign preceding the baseline campaign, was 

in the repair at the manufacturer. These occurrences have no impact on 

the baseline campaign. Performance of the analyzer during the baseline 

campaign after return from the repair is described above. Anwil has 

already purchased back-up analyzer to mitigate any risk of loss of data 

due to malfunction of the N2O analyzer. 

22




QAL3 document required under this FAR has been provided to verification 

team. 


Necessary documents were checked and found satisfactory. 


Following documentation and explanation should be provided: 

1. Nitric acid production reports for the historic campaigns as well as 

HNO3 production report for the line B for baseline 

2. A HNO3 production report for the line A for baseline shows the total 

production to be 268.128 tHNO3. However calculation model uses a figure 

of 205 959 tHNO3 produced during the baseline. The same with project 

campaign: calculation model with 209 907 tHNO3 vs. production report 

with 211.100 tHNO3. Please clarify this inconsistencies and provide 

additional evidence if necessary. 

3. A HNO3 production report for the line B for the baseline campaign A 

nitric acid production report for line B for production campaign shows 

amount of HNO3 produced 238.770 tHNO3 vs. calculation model with 

NAPP = 236.363 tHNO3. In this case inconsistency is not so big, however 

please clarify. 

Response 

Baseline campaign Line A 

Start campaign 12.X.2007 

End campaign 10.VII.2008 

Time this campaign (nitric acid production) from measurement: 269 265 

Mg. 

Time this campaign (nitric acid production) from production reports: 268 

128 Mg. 

From measurements production is 1 137 Mg higher than from production 

reports. 

Nitric acid output was corrected according to the level of nitric acid that 

was used for fertilizer production, after taking into account the real nitric 

acid level in storage tanks measured by levelmeasured device. The output 

that was corrected in this way represents production, shown by SAP 

system, taken for primary catalyst accounting. The document that confirm 

that way of accounting: gauzes campaign balance. 

Baseline campaign Line B 

Start campaign 14.IX.2007 

End campaign 10.V.2008 

23





Mg. 


272 Mg. 

From measurements production is 920 Mg less than from production 

reports. 


was used for fertilizer production, after taking into account the real l nitric 





First project campaign Line A 

Start campaign 19.VII.2008 

End campaign 24.II.2009 


Mg. 


100 Mg. 


reports. 







Electronic copies form the balance system for this campaign with the 

month values of nitric acid output from line A shown on that were 

presented to Verification Team 

First project campaign Line B 

Start campaign 17.V.2008 

End campaign 10.I.2009 


Mg. 


770 Mg. 


reports. 







24




Electronic copies form the balance system for this campaign with the 

month values of nitric acid output from line B shown on that were 

presented to Verification Team. 




From the table provided it is obviously that historical data for all relevant 

parameters are available for determining the operating conditions, 

furthermore parameters taken from the historical data are more 

conservative than operating manual. Please clarify why operating manual 

values are used to establish the permitted operating ranges instead of 

historic data. At the sheet provided there is an explanation of oxidation 

pressure change after installation of SCR units at the both production 

lines. However the explanation is not transparent, thus please clarify the 

intention of increasing the NOx values after SCRs installation as well as 

discuss possible influence of this action on baseline emission factor. 

Please justify your answer with evidence like engineering specifications or 

study about introduction of SCR DeNOx unit. 

Response 

Historical data on operating conditions are available as daily averages in 

the paper format only. There are no hourly averages available and they 

are not considered by the project proponents as transparent enough for 

purpose of the JI project. It is not possible to establish permitted range of 

operating conditions based on daily averages which eliminate minimums 

and maximums occurring during a day operation. Because of this reason 

project proponents have decided to choose the option B, i.e. 

establishment of the permitted range of the operating conditions based on 

the plant operation manual. 

In order to prove transparency and conservativeness employed in the 

Anwil’s approach project proponents have selected one month of each 

one historic campaign and performed analysis of this selected data. In 

case of establishment of the permitted range of operating conditions 

based on the analysis of historic data there would be actual slightly higher 

yield of ERUs (Line A +0.3% ERUs, Line B +7.7% ERUs) and thus 

approach of the project proponents can be considered as conservative 

and transparent. There is no increase of NOx emissions planned in Anwil. 



25





Excerpt of the IPPC permit for ANWIL nitric acid plant has been submitted 

and confirms the limit values to be for Line A 113 kgNO2/hour and Line B 

140 kgNO2/hour. As every IPPC permit has its validity, please indicate 

until when the permit is valid. 

Response 

Anwil IPPC permit has been issued in December 2006 and its validity is 

10 years, i.e. until December 2016. Relevant part of the IPPC permit has 

been provided to verification team. 



3.2 Project Implementation 

3.2.1 Discussion 

Installing secondary N2O reduction catalyst underneath the primary 

catalyst precious metal catching and catalytic gauzes package in the 

ammonium burner as a N2O abatement technology was applied at two 

production lines A and B of Anwil plant according to the Monitoring Plan, 

described in the PDD version 1.3. and Monitoring Report version 10. 

Secondary catalysts were installed in all 4 ammonia oxidation reactors of 

one production line A, and in all 4 ammonia oxidation reactors of another 

production line B. 

Anyway start date of project campaign for line A was 17 th of May 2008 

meanwhile the secondary catalyst was installed on 18 th of July 2008 and 

start date of project campaign for Line A was 14 th of July 2008 meanwhile 

the secondary catalyst was installed on 15 th of September 2008. 

3.2.2 Findings 

Corrective Action Request (CAR) 1 

Please provide evidence of project approval from the Lichtenstein side. 

Response 

Investor Party LoA issued by the Principality of Liechtenstein was 

provided to the verifier. 

Conclusion of the verification team 

26





Clarification Request (CL) 1 

Please clarify why start date of the project campaign is earlier than date 

of the secondary catalysts installation. 

Response 

Starts of project campaigns on both lines A and B as defined in the 

Monitoring report are same as dates of the secondary catalysts 

installation. 



3.2.3 Conclusion 

The project complies with the requirements. 

3.3 Internal and External Data 


The monitoring approach in the Monitoring Plan of the PDD version 1.3. 

requires monitoring and measurement of variables and parameters 

necessary to quantify the baseline emissions and project emissions in a 

conservative and transparent way. 

For the purpose of monitoring the emission reductions the following 

parameters are measured on both production lines A and B of ANWIL: 

• NH3 Flow; 

- flow; 

- pressure; 

- temperature; 

• Air flow; 

- flow; 

- pressure; 


• Nitric acid flow; 

- flow; 

- density; 


• N2O concentration in the tail gas ; 

• Volume of the tail gas flow; 

• Tail gas temperature; 

27



• Tail gas Pressure; 


Figure 2 below demonstrates structure of the monitoring system data 

processing including the central datalogger, data processing unit and 

control unit. 

Figure 2 Emission data processing system 

Baseline emission factor for emission reduction calculations for Line A 

and B has been established on the line-specific basis. Campaign used for 

baseline measurements on the Line A has been carried out from October 

12, 2007 through July 10, 2008 and for line B from September 14, 2007 

through May 9, 2008. Nitric acid production during this campaigns 

exceeded the historic nitric acid production established as an average 

production during 5 previous historic campaigns and thus baseline 

campaign length has been reduced in order not to exceed the historic 

length. Start and end of baseline campaign is thus September 14, 2007 

(start) and April 10, 2008 (end) and October 12, 2007 (start) and May 01, 

2008 (end) for line A and B respectively.. 

Monitoring system provides separate readings for N2O concentration and 

gas flow volume for every hour of operation as an average of the 

measured values for the previous 60 minutes. 

28




Measurement results can be distorted before and after periods of 

downtime or malfunction of the monitoring system and can lead to 

mavericks. To eliminate such extremes and to ensure a conservative 

approach, the following statistical evaluation is applied to the complete 

data series of N2O concentration as well as to the data series for gas 

volume flow. The statistical procedure is applied to data obtained after 

eliminating data measured for periods where the plant operated outside 

the permitted ranges: 

a) Calculate the sample mean (x) 

b) Calculate the sample standard deviation (s) 

c) Calculate the 95% confidence interval (equal to 1.96 times the standard 

deviation) 

d) Eliminate all data that lay outside the 95% confidence interval 

e) Calculate the new sample mean from the remaining values (volume of 

stack gas (VSG) and N2O concentration of stack gas (NCSG)) 

The average mass of N2O emissions per hour is estimated as product of 

the NCSG and VSG. 

The N2O emissions per campaign are estimates product of N2O emission 

per hour and the total number of complete hours of operation of the 

campaign using the following equation: 

BEBC = VSGBC * NCSGBC * 10-9 * OHBC (tN2O) 

The line specific baseline emissions factor representing the average N2O 

emissions per tone of nitric acid over one full campaign is derived by 

dividing the total mass of N2O emissions by the total output of 100% 

concentrated nitric acid during baseline campaign. 

The overall uncertainty of the monitoring system has been determined by 

the QAL2 report and the measurement error is expressed as a percentage 

(UNC), which was expressed in the following equation. 

EFBL = (BEBC / NAPBC) (1 – UNC/100) (tN2O/tHNO3) 

where: 

EFBL - Baseline N2O emissions factor (tN2O/tHNO3) 

BEBC - Total N2O emissions during the baseline campaign (tN2O) 

NCSGBC - Mean concentration of N2O in the stack gas during the 

baseline campaign (mgN2O/m3) 

OHBC - Operating hours of the baseline campaign (h) 

VSGBC - Mean gas volume flow rate at the stack in the baseline 

measurement period (m3/h) 

NAPBC - Nitric acid production during the baseline campaign (tHNO3) 

UNC - Overall uncertainty of the monitoring system (%), calculated as the 

combined uncertainty of the applied monitoring equipment. 

The average historic campaign length (CLnormal) defined as the average 

campaign length for the historic campaigns used to define operating 

29




condition (the previous five campaigns), has been used as a cap on the 

length of the baseline campaign. 

Same statistical evaluation that was applied to the baseline data series 

has been applied to 

the project data series: 

a) Calculate the sample mean (x) 

b) Calculate the sample standard deviation (s) 

c) Calculate the 95% confidence interval (equal to 1.96 times the standard 

deviation) 

d) Eliminate all data that lay outside the 95% confidence interval 

e) Calculate the new sample mean from the remaining values 

PEn = VSG * NCSG * 10-9 * OH (tN2O) 

where: 

VSG Mean stack gas volume flow rate for the project campaign (m3/h) 

NCSG Mean concentration of N2O in the stack gas for the project 

campaign 

(mgN2O/m3) 

PEn Total N2O emissions of the nth project campaign (tN2O) 

OH Is the number of hours of operation in the specific monitoring period 

(h) 

Because this campaign was first project campaign on Line A and B there 

has been no moving average emission factor established yet for this 

campaign. 

Because this campaign was first project campaign on Line A and B there 

has been no minimum average emission factor established yet for this 

campaign. This factor will be established after 10th project campaign. 

The emission reductions for the project activity during this campaign have 

been determined by deducting the campaign-specific emission factor from 

the baseline emission factor and multiplying the result by the production 

output of 100% concentrated nitric acid over the campaign period and the 

GWP of N2O: 

ER = (EFBL – EFP) * NAP *GWPN2O (tCO2e) 

where: 

Variable Definition 

ER Emission reductions of the project for the specific campaign (tCO2e) 

NAP Nitric acid production for the project campaign (tHNO3). The 

maximum value of NAP shall not exceed the design capacity. 

EFBL Baseline emissions factor (tN2O/tHNO3 ) 

EFP Emissions factor used to calculate the emissions from this particular 

campaign (i.e. the higher of EFma,n and EFn). 

30




The N2O concentration data should be converted from the ppmV units to 

the mg/Nm3 according to the methodology used in the project. 

Below is presented algorithm calculation concentration given in ppm into 

concentration given in mg/Nm3. 

C 

3 

mg / Nm 

44, 

013 

= C ppm ⋅ 

22, 

252 ; 

where: 

C 3 

mg / Nm - - concentration given in mg/Nm 3 , 

C ppm - - concentration given in volume ppm, 

- 44,1013 – molar mass N2O particle,* 

- 22,252 –molar specific volume, * 

* - according to ISO 11042-1 

Tail gas temperature and tail gas pressure are not needed for the 

conversion of the N2O concentration data from ppmV to mg/Nm3. But 

these data need to be monitored, because it is: 

• required by the methodology used 

• it is necessary to measure actual values in order to be able to 

correct them 

• it is necessary for application of QAL2 test regression lines, when 

normalized tail gas volume flow (STVFBC) is received and then QAL 2 

recalibration is applied. In order to be able to apply the QAL2 

recalibrations values need to be calculated back to their original 

counterparts by applying the inverse of the normalization, which uses 

the tail gas pressure and tail gas temperature values. Based on the 

QAL2 regression lines it is necessary to re-calibrate the tail gas 

pressure and tail gas temperature are re-calibrated and then the tail 

gas volume is normalized by using the tail gas pressure and tail gas 

temperature in the Emission Reduction Model. 

The Emission Reduction Model uses the normal pressure value 1,013.25 

hPa and the site pressure varies from 1,044 up to 1,055 hPa so in the 

calculations is used mean value 1,049.5. 

In Emission Reduction Model corrections were made in the following 

sections: 

- Baseline data Line A, 

- Baseline data Line B, 

31



- First proj. campaign LA, 

- First proj. campaign LB, 

- Sec. Project Campaign LA, 

- Sec. Project Campaign LB. 


The list of all monitoring equipment with the internal numbers, established 

due to the monitoring system of the plant and calibration dates is 

presented in the supporting document to MR version 10 – “Measuring 

devices specification list for Line A and Line B.” 



Please include in the updated Monitoring Report proper formulae for the 

conversion of the N2O concentration data from the ppmV units to the 

mg/Nm3 in the calculations of emission reductions. This data should be 

checked after each AST test during future verifications. 

Response 

An appropriate formula for conversion of the N2O concentration data from 

the ppmV units to the mg/Nm3 in the calculations of emission reductions 

was included in the updated Monitoring Report version 10. Results of the 

following AST tests will be applied in the proper way in the next 

Monitoring Reports. 


Issue will be closed during next verification. 


Please indicate all the monitoring parameters in the next monitoring 

report according to the PDD monitoring section D, or revise monitoring 

plan if different parameters are to be monitored. 

Response 

All the monitoring parameters will be indicated in the next monitoring 

report according to the PDD monitoring section D, or will be revised 

monitoring plan if different parameters are to be monitored. 


Issue will be closed during next verification. 

32





Please provide explanation for bigger production of Nitric Acid on Line B 

in comparison with Line A. 

Response 

Both lines A and B have different primary catalysts and thus also separate 

production schedule. It means that starts and ends of campaigns on both 

lines are different and thus different HNO3 production is business as 

usual, as can be seen also on the overview of 5 historic campaigns HNO3 

production in the Campaign_length worksheet of the emission reductions 

calculation model. 




Please provide reason of exceeding during baseline campaign the historic 

nitric acid production. 

Response 

Historic HNO3 production established as average of 5 historic campaigns 

was higher due to favourable market situation requiring in the spring 2008 

higher production of fertilizers. Spring is the peak of the production 

season in the fertilizers industry. From the JI point of view this issue has 

been handled in accordance with the PDD, i.e. emission data measured 

after reaching the historic campaign length have not been included into 

the baseline emission factors calculations. 




Please provide explanation of the reason for occurring circumstances 

under which operating conditions during baseline measurements can be 

outside the permitted range. 

Response 

Operating conditions during the baseline campaigns had been outside the 

permitted range during start-up and shut-down periods. 


33






Please clarify why the last calibration date for pressure transmitter PT 

2211-2A on Line A is 15/07/2009 in the “Measurement devices 

specification list: Line A” while in the calibration record for this device last 

date of calibration is 15/07/2008. 

Response 

This was technical mistake. Last calibration date for pressure transmitter 

PT 2211-2A on Line A is 15/07/2008. Date was changed in the 

“Measurement devices specification list: Line A”. Changed document was 

provided to verification team. 





3.4 Environmental and Social Indicators 


Secondary catalysts which are installed in all ammonia oxidation reactors 

of both production lines A and B of the enterprise breaks down N2O 

formation during oxidation process on N2 and O2 and thus leads to 

decrease of harmful emissions. Since there is no regulation controlling 

N2O emission caps and the catalyst is not an essential part of the acid 

production process, the implementation of the Project is voluntary and 

functionally serves only environmental purposes. Project implementation 

will lead to improvement of ecological climate of the region, increase of 

payments to the budgets of all levels for social needs, prevention of 

reduction of working places and better working conditions at ANWIL. 


None 

3.4.3. Conclusion 

The project complies with the JI requirements as well as with the local 

requirements. 

3.5 Management and Operational System 

34





N2O emissions monitoring system is installed in both nitric acid lines A 

and B. It consists of the measurement devices part and data processing 

and storage part. Measuring instruments in accordance with process and 

technical project made on basis of accepted methodology AM0034. 

Monitoring system of N2O emission includes: 





• Emission Computer – hardware and software dedicated for reports in 

environment protection. 

Nitric acid production, ammonia flow and air flow including necessary 

temperature and pressure parameters are measured continuously. 

Analogue signals 4-20mA from measurement devices installed on the 

nitric acid production lines are recorded on a 1 second basis in the data 

logger, where these signals are digitalized to 4 byte signals. Analogue 

signals 4-20mA from the DCS system are recorded on a 1 second basis 

and sent to the data logger, where these signals are digitalized to 4 byte 

signals. All signals are then sent via converter to the emission computer, 

where these signals are stored. 

Data logger KX-6 collects measured data and processes them. All 

measurement data received from the data logger KX-06 are recorded on a 

1 second basis to the emission computer KE MIKROS hard disc. Data are 

further processed in the emission computer, where corrected nitric acid 

flow and tail gas flow are calculated according to the formulae, described 

in MR version 10, sections 5.14.1 and 5.14.2 are calculated. 

All KE MIKROS values are archived on the emission computer’s hard disc. 

All analogue values including measured values, operational conditions, 

corrected data and normalized parameters data are recorded by the KE 

MIKROS on a 1 second basis. These data are archived for several months 

but not less than 3 month. Due to the fact that this archive needs a lot of 

memory hourly averages are archived. Data overwriting process is 

controlled via special software which automatically overwrites oldest data 

in its memory after expiration of given period of time limited by a hard 

disc capacity. Hourly averages are archived in a paper form and also 

electronically in an Excel file on separate computer and it is possible to 

store them also on a CD-Rom. It is possible to access data stored on the 

emission computer hard disc. 

All data necessary for the CO2 emission reductions calculation is 

collected in the Maintenance Technician/ Maintenance Engineer 

Department. Maintenance Technician/Maintenance Engineer is performing 

reports on daily and monthly basis, which are send to Vertis for 


35




Maintenance technician/maintenance engineer coordinates the process of 

checking and calibration of instruments according to previously accepted 

schedule. In case of inefficient instrument, immediately the information is 

handed over to Specialist Company ordering them to take some activities 

that make the instrument operating properly. This fact, on 1st shift, is 

notified by maintenance technician from AR-22 Dept, and on other shifts it 

is done by shift coordinator from A-2 Plant. Maintenance 

technician/maintenance engineer from Department AR-22 inspects 

received instrument after service that has been done according to 

established agreements and reports all these activities in suitable sheet. 

In case when repair is impracticable, the instrument is subjected to be out 

of service. Lacks of measured values are pointed with comment in 

Consolidated data report which is pass on to Project Consultant. 







Clarification Request 3 CL (3) 

Please provide necessary information regarding reporting procedures in 

the Monitoring Report. 

Response 

Information on the reporting procedure has been added to the sections 

5.17 of the monitoring report. 




Please provide necessary information about responsibilities in the 

Monitoring Report. 

Response 

Information on the responsibilities has been added to the sections 5.18 of 

the monitoring report. 


36






The Monitoring Report and the Management and Operational Systems are 

eligible for reliable project monitoring. 

4 FIRST PERIODIC VERIFICATION FINDINGS 

4.1 Completeness of Monitoring 


The reporting procedures reflect the monitoring plan completely. It is 

confirmed that the monitoring report does comply with the monitoring 

methodology and PDD. 

All parameters were determined as prescribed. The complete data is 

stored electronically and documented. The necessary procedures have 

been defined in internal procedures. 

According to PDD version 1.3, emission reductions during 2008 

monitoring period were expected to be 637 097 t CO2 e and for 2009 

monitoring period are 725,186 t CO2 e for both lines A and B. According 

to Monitoring Report version 10 emission reductions achieved for project 

campaign Line A are 245,947 t CO2e, monitoring period 19 th July 2008– 

24 th of February 2009 and for Line B emission reductions achieved for 

project campaign are 327,738 t CO2e, monitoring period 17 th of May 2008 

– 10 January 2009. 



Please provide clarification how amounts of emission reduction 

calculations for 2008 for Line A and Line B and for 2009 for Line A and 

Line B were calculated. 

Response 

Estimates of ERU quantities contained in the PDD have been calculated 

using estimated project emission factors and applying this factor on 

estimated annual HNO3 production during the crediting period 2008-2012 

as required by the PDD format of the Section E. 

Assumptions used for calculation of annual ERUs estimates are defined in 

detail in the Annex 2 of the PDD. 


37






4.2 Accuracy of Emission Reduction Calculations 



The audit team confirms that emission reduction calculations have been 

performed according to the Monitoring Plan. 

The overall uncertainty was established due to the QAL2 test results, as 

required by EN14181. Level of uncertainty is expressed in the calculations 

of the Baseline emission factor and Project emission factor, which are 

provided in the Emission Reduction model for the Project. 

Some of the monitoring parameters that are used in the calculation of the 

baseline and project emissions are measured directly with the use of 

special equipment while others are estimated with the use of appropriate 

statistical approach, described in the Monitoring Report version 10. 

As required in the applicable norm EN14181: “The relation between the 

instrument readings of the recording measuring procedure and the 

quantity of the measuring objects has to be described by using a suitable 

convention method. The results have to be expressed by a regression 

analysis.” The general formula of the regression line, established in the 

EN14181 and used in the Calibration Report is: 

Y= a + bX 

where: 

X is the measured value of the instrument in mA 

Y is the value of the parameter being objective of the measurement 

a is a constant of the regression line 

b is the slope of the regression line 

After a comparative test the laboratory issued the old and new regression 

lines properties, namely “a” and “b” applying for all of the measured 

parameters that are subject to calibration as stated in the Calibration 

Report. 

The QAL2 corrections are based on the fact that the actual analog current 

outputs (in mA) of the measurement instruments are relevant for both, the 

old and new regression lines: 

Xo=Xn=X 

where: 

Xn: X new 

Yo: Y old 

This allows to derive a calibrating formula that gives us the corrected 

value of the measured physical parameters. The applied calibrating 

equation is: 

Yn=An + (Bn/Bo)*(Yo-Ao) 

38




The units returned by the AMS in “mgN2O/nm3” and “1000 nm3/h” stand 

for normalized cubic meters of the gas volume at normal gas conditions 

(0° C, 1 atm.). 


None. 



4.3 Quality Evidence to Determine Emissions Reductions 


Concerning verification the calculation of emission reductions is based on 

internal data. The origin of those data was explicitly checked. Further on, 

entering and processing of those data in the Emission Reduction Model 

for both Line A and B was checked where predefined algorithms compute 

the annual value of the emission reductions. All equations and algorithms 

used in the different workbook sheets were checked. Inspection of 

calibration and maintenance records for key equipment was performed for 

all relevant meters. 

Necessary procedures have been defined in internal procedures and 

additional internal documents relevant for the determination of the various 

parameters on daily basis. 


None 



4.4 Management System and Quality Assurance 


AMS installed at the operating plant is in compliance with the European 

norm EN14181 as required per Approved Methodology AM0028, which 

assumes three levels of quality assurance of the measurement systems - 

QAL1, QAL2 and QAL3. The first level (QAL1) is assured and certified by 

the measurement equipment provider and it refers to the performance and 

accuracy of the system. The second level of quality assurance (QAL2) 

guarantees the correct installation of the AMS and its proper operation at 

the plant. The third level (QAL3) is aimed to guarantee the maintenance 

and regular proper functioning of the measurement equipment and the 

measurement data provided. 

39




Measurement instruments are marked according to obligatory 

identification system. Instrumentation equipment is checked before 

installation. Maintenance technician/maintenance engineer from Dept AR- 

22 supervises the handling of instruments according to established 

agreements. The supervision is documented in special daily and monthly 

sheets and protocols. In case of inefficient instrument, immediately the 

information is handed over to Specialist Company ordering them to take 

some activities that make the instrument operating properly. This fact, on 

1st shift, is notified by maintenance technician from AR-22 Dept, and on 

other shifts it is done by shift coordinator from A-2 Plant. Maintenance 

technician/maintenance engineer from Dept AR-22 inspects received 

instrument after service that has been done according to established 

agreements and reports all these activities in suitable sheet. In case when 

repair is impracticable, the instrument is subjected to be out of service. 

Lack of measured values are pointed with comment in Consolidated data 

report which is pass on to Vertis. 






All the calibration procedures are performed according to the detailed 

calibration plan. On the date of verification, calibration records of the 

measuring and monitoring equipment have been verified on site. 

All measured data are collected to the emission computer KE MIKROS 

hard disc. Data are further processed in emission computer and hard disc 

of PC in AR 22 Department. Maintenance Technician/Maintenance 

Engineer from AR 22 Department is performing reports on daily and 

monthly basis. Data on monthly basis are send to Vertis for performing 

final calculations. 

For this monitoring period the names of the personnel involved is as 

follows: 

• Michal Czeszynsky ANWIL /Fertilizers Complex / AA Department 

• Piotr Nieznanski ANWIL / Fertilizers Complex / AR Department 

• Romuald Jancewicz ANWIL / Fertilizers Complex / A-2 Department 

• Bozena Balicka ANWIL / Fertilizers Complex / AR -22 

Department 

• Marcin Pasinski ANWIL / Fertilizers Complex /AR – 22 

Department 

• Jacek Mendelewski ANWIL / Fertilizers Complex / A-2 

Department 

• Pawel Slawinski ANWIL / Fertilizers Complex / A-21 

Department 

• Janusz Dzwonkowski ANWIL / Fertilizers Complex Department 

• Magdalena Soldacka ANWIL / Fertilizers Complex / A-2 Department 

40




Clarification Request CL (3) 


Please provide necessary information regarding reporting procedures in 

the Monitoring Report. 

Response 

Information on the reporting procedure has been added to the sections 

5.17 of the monitoring report. 



Clarification Request CL (4) 

Please provide necessary information about responsibilities in the 


Response 

Information on the responsibilities has been added to the sections 5.18 of 

the monitoring report. 



Clarification Request 5 CL(5) 

Please provide corrective and preventive actions procedure. 

Response 

Corrective and preventive actions procedure is provided in the document 

named Troubleshooting_Instrukcija_KA_IJ_090802.pdf. 




Please provide information concerning the internal audits. 

Response 

Protocol of the internal audit carried out in August 2009 is provided. 


41






5 PROJECT SCORECARD 

Risk Areas 

Completeness Source 

coverage/ 

boundary 

definition 

Accuracy Physical 

Measurement 

and Analysis 

Baseline 

Emissions 

Conclusions 

Project 

Emissions 


Calculated 

Emission 

Reductions 

� � � 

� � � 

Data 

calculations � � � 

Data 

management 

& reporting 

� � � 

Consistency Changes in 

the project � � � 

6 FIRST PERIODIC VERIFICATION STATEMENT 

Summary of findings and 

comments 

All relevant sources are covered 

by the monitoring plan and the 

boundaries of the project are 

defined correctly and 

transparently. 

State-of-the-art technology is 

applied in an appropriate manner. 

Appropriate backup solutions are 

provided. 

Emission reductions are 

calculated correctly 

Data management and reporting 

were found to be satisfying. 

Results are consistent to 

underlying raw data. 

Bureau Veritas Certification has performed a verification of the JI project 

“N2O emissions reduction project at Zakłady Azotowe Anwil S.A.”. The 

verification is based on the currently valid documentation of the United 

Nations Framework Convention on the Climate Change (UNFCCC). 

The management of the ANWIL is responsible for the preparation of the 

GHG emissions data and the reported GHG emissions reductions of the 

project on the basis set out within the project Monitoring and Verification 

Plan indicated in the final PDD version 1.3. The development and 

maintenance of records and reporting procedures in accordance with that 

plan, including the calculation and determination of GHG emission 

reductions from the project is the responsibility of the management of the 

project. 

Bureau Veritas Certification verified the Project Monitoring Report version 

10 for the reporting period as indicated below. Bureau Veritas 

42




Certification confirms that the project is implemented as planned and 

described in validated and registered project design documents. Installed 

equipment being essential for generating emission reduction runs reliably 

and is calibrated appropriately. The monitoring system is in place and the 

project is generating GHG emission reductions. 

Bureau Veritas Certification can confirm that the GHG emission reduction 

is calculated without material misstatements. Our opinion relates to the 

project’s GHG emissions and resulting GHG emissions reductions 

reported and related to the valid and registered project baseline and 

monitoring, and its associated documents. Based on the information we 

have seen and evaluated we confirm the following statement: 

Reporting period for Line A: From 19/07/2008 to 24/02/2009 . 

Emission Reductions : 245,947 t CO2 equivalents. 

Reporting period for Line B: From 17/05/2008 to 10/01/2009 . 


Reporting period for project Line A and Line B: From 17/05/2008 to 

24/02/2009 


7 REFERENCES 

Category 1 Documents: 

Documents provided by that relate directly to the GHG components of the 

project. 

/1/ Project Design Document, version 1.3 dated 2 of April 2009 

/2/ Monitoring Report version 5, dated 11 th of November 2009 

Determination Report by Det Norske Veritas Certification AS (DNV) 

/3/ 

dated 1 st of February 2009 

/4/ Monitoring Report version 6, dated 22 th of December 2009 

/5/ Monitoring Report version 7, dated 19 th of January 2010 

/6/ Monitoring Report version 8, dated 15 th of January 2010 

/7/ Monitoring Report version 10, dated 8 th of February 2010 

/8/ 

/9/ 

Letter of Approval of Ministry of Environment Poland, from 23 of 

January 2008. 

Annex to Letter of Approval of Ministry of Environment Poland, 

from 23 of January 2008, from 6 of February 2009. 

43



/10/ 

/11/ 

/12/ 


Letter of Approval of the Office of Environmental Protection of 

Lichtenstein from 18 of August 2009. 

Letter about project registration under Track 1 procedure in Poland 

of Ministry of Environment, dated 20 th of August 2009. 

Initial verification Report by TÜV Süddeutschland, No.0085 dated 

26 th of August 2009. 

Category 2 Documents: 

Background documents related to the design and/or methodologies 

employed in the design or other reference documents. 

Documents checked during the verification onsite are presented in 

/13/ 

Annex C 

Persons interviewed: 

List of persons interviewed during the verification or persons that 

contributed with other information that are not included in the documents 

listed above. 

/1/ 

/2/ 

/3/ 

/4/ 

/5/ 

/6/ 

/7/ 

/8/ 

/9/ 

/10/ 

Magdalena Ozimek Chemenko / Environment Protection 

Tadeusz Dembovski ANWIL / Prevention Manager 

Maria Stankiewicz ANWIL / HR 

Pawel Ziolkowski ANWIL / Utilities Complex 

Andrzej Wyslouch ANWIL / EMS & QMS 

Jaroslaw Ptaszynski ANWIL / Investment Dept. 

Michal Czeszynsky ANWIL /Fertilizers Complex / AA Department 

Piotr Nieznanski ANWIL / Fertilizers Complex / AR Department 

Romuald Jancewicz ANWIL / Fertilizers Complex / A-2 

Department 

Bozena Balicka ANWIL / Fertilizers Complex / AR -22 Department 

/11/ Marcin Pasinski ANWIL / Fertilizers Complex / AR -22 Department 

/12/ 

Jacek Mendelewski ANWIL / Fertilizers Complex / A-2 Department 

44




/13/ Pawel Slawinski ANWIL / Fertilizers Complex / A-21 Department 

/14/ Janusz Dzwonkowski ANWIL / Fertilizers Complex 

/15/ Magdalena Soldacka ANWIL / Fertilizers Complex / A-2 

Department 

/16/ 

Andrzej Spychalski ANWIL / Media Department 

45



APPENDIX A: COMPANY JI PROJECT VERIFICATION PROTOCOL 

Initial Verification Protocol Table 1 


Objective Reference Comments Conclusion 

(CARs/FARs) 

1. Opening Session 

1.1. Introduction to audits /7/ The intention and the target of the audit were illustrated to 

the participants of the audit. Participants at the audit were 

the following persons: 

Verification team: Ms. Nadiia Kaiun Lead Auditor, Bureau 

Veritas Poland, Mr. Witold Dzugan, Auditor, Bureau Veritas 

Poland. 

Zaklady Azotove ANWIL S.A.: 

Magdalena Ozimek Chemenko / Environment Protection 

Tadeusz Dembovski ANWIL / Prevention Manager 

Maria Stankiewicz ANWIL / HR 

Pawel Ziolkowski ANWIL / Utilities Complex 

Andrzej Wyslouch ANWIL / EMS & QMS 

Jaroslaw Ptaszynski ANWIL / Investment Dept. 

Michal Czeszynsky ANWIL /Fertilizers Complex / AA 

Department 

Piotr Nieznanski ANWIL / Fertilizers Complex / AR 

Department 

OK 

46





(CARs/FARs) 

1.2. Clarification of access 

to data archives, records, 

plans, drawings etc. 

1.3. Contractors for 

equipment and installation 

works 

Romuald Jancewicz ANWIL / Fertilizers Complex / A-2 

Department 

Bozena Balicka ANWIL / Fertilizers Complex / AR -22 

Department 

Marcin Pasinski ANWIL / Fertilizers Complex /AR – 22 

Department 

Jacek Mendelewski ANWIL / Fertilizers Complex / A-2 

Department 

Pawel Slawinski ANWIL / Fertilizers Complex / A-21 

Department 

Janusz Dzwonkowski ANWIL / Fertilizers Complex 

Department 

Magdalena Soldacka ANWIL / Fertilizers Complex / A-2 

Department 

/7/ The verification team got open access to all required plans, 

data, records, drawings and to all relevant facilities. 

/7/ Project has been implemented as defined in the PDD 

version 1.3 and the implementation is evidenced by 

statements of work completion (see list of verified 

documents). 

OK 

OK 

47





(CARs/FARs) 

1.4. Actual status of 

installation works 

2. Open issues indicated in 

validation report 

2.1. Missing steps to final 

approval 

3. Implementation of the 

project 

/7/ There are no deviations from the PDD made final at the 

JISC. 

/2/ Based on the validation report the verification team 

identified no missing steps. The project has been approved 

by both NFPs. The Letters of Approval were presented to 

the verification team. 

Corrective Action Request (CAR) 1 

Please provide evidence of approval from the Lichtenstein 

side. CAR1 

3.1. Physical components /2/ Installing secondary N2O reduction catalyst underneath the 

primary catalyst precious metal catching and catalytic 

gauzes package in the ammonium burner as a N2O 

abatement technology was applied at two production lines A 

and B of Anwil plant. Secondary catalysts were installed in 

all 4 ammonia oxidation reactors of one production line A, 

and in all 4 ammonia oxidation reactors of another 

production line B. 

Anyway start date of project campaign for line A was 17 th of 

May 2008 meanwhile the secondary catalyst was installed 

on 18 th of July 2008 and start date of project campaign for 

CL1 

48





(CARs/FARs) 

Line A was 14 th of July 2008 meanwhile the secondary 

catalyst was installed on 15 th of September 2008. 


Please clarify why start date of the project campaign is 

earlier than date of the secondary catalysts installation. 

3.2. Project boundaries /7/ Yes, the project boundaries are as defined in the PDD 

version 1.3. OK 

3.3 Emission reductions /2/ In the PDD version 1.3 the estimated amount of emission 

achieved 

reduction units is stated for each year during crediting 

period while actual amounts of emission reduction 

calculations in Monitoring Report were calculated for each 

campaign, for Line A and Line B, duration of which is 17 

May 2008 – 20 January 2009 and 14 th of July – 24 t h of 

February respectively. 


Please provide clarification how amounts of emission 

reduction calculations for 2008 for Line A and Line B and for 

2009 for Line A and Line B were calculated. 

CL2 

3.4. Monitoring and 

metering systems 

/7/ N2O emissions monitoring system is installed in two nitric 

acid lines A and B. It consists of the measurement devices 

part and data processing and storage part. Measuring 

instruments in accordance with process and technical 

project made on basis of accepted methodology AM0034. 

Monitoring system of N2O emission includes: OK 

49





(CARs/FARs) 





• Emission Computer – hardware and software dedicated for 

reports in environment protection. 

Nitric acid production, ammonia flow and air flow including 

necessary temperature and pressure parameters are 

measured continuously. 

Analogue signals 4-20mA from measurement devices 

installed on the nitric acid production lines are recorded on 

a 1 second basis in the data logger, where these signals are 

digitalized to 4 byte signals. Analogue signals 4-20mA from 

the DCS system are recorded on a 1 second basis and sent 

to the data logger, where these signals are digitalized to 4 

byte signals. All signals are then sent via converter to the 

emission computer, where these signals are stored. 

Data logger KX-6 collects measured data and processes 

them. All measurement data received from the data logger 

KX-06 are recorded on a 1 second basis to the emission 

computer KE MIKROS hard disc. Data are further processed 

in the emission computer, where corrected nitric acid flow 

and tail gas flow are calculated according to the formulae, 

described in MR version 10, sections 5.14.1 and 5.14.2 are 

calculated. 

50





(CARs/FARs) 

All KE MIKROS values are archived on the emission 

computer’s hard disc. 

All analogue values including measured values, operational 

conditions, corrected data and normalized parameters data 

are recorded by the KE MIKROS on a 1 second basis. These 

data are archived for several months but not less than 3 

month. Due to the fact that this archive needs a lot of 

memory hourly averages are archived. Data overwriting 

process is controlled via special software which 

automatically overwrites oldest data in its memory after 

expiration of given period of time limited by a hard disc 

capacity. Hourly averages are archived in a paper form and 

also electronically in an Excel file on separate computer and 

it is possible to store them also on a CD-Rom. It is possible 

to access data stored on the emission computer hard disc. 

3.5. Data uncertainty /7/ The overall uncertainty was established due to the QAL2 

test results, as required by EN14181. Level of uncertainty is 

expressed in the calculations of the Baseline emission 

factor and Project emission factor, which are provided in the 

Emission Reduction model for the Project. 

OK 

51





(CARs/FARs) 

3.6. Calibration and quality 

assurance 

3.7. Data acquisition and 

data processing systems 

/2/ AMS installed at the operating plant is in compliance with 

the European norm EN14181 as required per Approved 

Methodology AM0028, which assumes three levels of quality 

assurance of the measurement systems - QAL1, QAL2 and 

QAL3. 

All the calibration procedures are performed according to 

the detailed calibration plan. On the date of verification, 

calibration records of the measuring and monitoring 

equipment have been verified on site. The list of all 

monitoring equipment with the internal numbers, established 

due to the monitoring system of the plant and calibration 

dates is presented in the supporting document to MR 

version 10 - Measuring devices specification list for Line A 

and Line B. 


Please clarify why the last calibration date for pressure 

transmitter PT 2211-2A on Line A is 15/07/2009 in the 

“Measurement devices specification list: Line A” while in the 

calibration record for this device last date of calibration is 

15/07/2008. 

/7/ Analogue signals 4-20mA from measurement devices 

installed on the nitric acid production lines are recorded on 

a 1 second basis in the data logger, where these signals are 

digitalized to 4 byte signals. Analogue signals 4-20mA from 

the DCS system are recorded on a 1 second basis and sent 

to the data logger, where these signals are digitalized to 4 

CL10 

OK 

52





(CARs/FARs) 

3.8. Reporting procedures 

byte signals. All signals are then sent via converter to the 

emission computer, where these signals are stored. 

Data logger KX-6 collects measured data and processes 

them. All measurement data received from the data logger 

KX-06 are recorded on a 1 second basis to the emission 

computer KE MIKROS hard disc. Data are further processed 

in the emission computer, where corrected nitric acid flow 

and tail gas flow are calculated according to the formulae, 

described in MR version 10, sections 5.14.1 and 5.14.2 are 

calculated. 

All KE MIKROS values are archived on the emission 

computer’s hard disc. Binary values such as measurement 

devices’ operational status, corrected values, status of KE 

MIKROS and other parameters are archived in different part 

of the memory. 

/2/ Collecting and processing of measured data was clearly 

presented in the Monitoring Report version 10 meanwhile 

the status of reporting procedures was not clear. 


Please provide necessary information regarding reporting 

procedures in the Monitoring Report. 

CL3 

53





(CARs/FARs) 

3.9. Documented 

instructions 

3.10. Qualification and 

training 

/7/ Section 5 of the Monitoring Report version 10 Monitoring 

Plan (including software used) provides with the necessary 

information relating to the procedures for the monitoring and 

measurements. 

/7/ Training was provided by equipment producer. All the 

training plans and reports were presented to the verification 

team during site visit. 

3.11. Responsibilities /2/ Description of the system for management of emission 

reduction calculations was presented in a transparent and 

understandable way in the Monitoring Report version 10, 

anyway information regarding responsibilities of the 

departments within the monitoring system was not clear. 


Please provide necessary information about responsibilities 

in the Monitoring Report. 

3.12. Troubleshooting 

procedures 

/2/ Measurement instruments are marked according to 

obligatory identification system. Instrumentation equipment 

is checked before installation. Maintenance 

technician/maintenance engineer from Dept AR-22 

supervises the handling of instruments according to 

established agreements. The supervision is documented in 

special daily and monthly sheets and protocols. In case of 

inefficient instrument, immediately the information is handed 

OK 

OK 

CL4 

CL5 

54





(CARs/FARs) 

4. Internal Data 

4.1. Type and sources of 

internal data 

over to Specialist Company ordering them to take some 

activities that make the instrument operating properly. This 

fact, on 1st shift, is notified by maintenance technician from 

AR-22 Dept, and on other shifts it is done by shift 

coordinator from A-2 Plant. Maintenance 

technician/maintenance engineer from Dept AR-22 inspects 

received instrument after service that has been done 

according to established agreements and reports all these 

activities in suitable sheet. In case when repair is 

impracticable, the instrument is subjected to be out of 

service. Lack of measured values is pointed with comment 

in Consolidated data report which is pass on to Vertis. 

In case of failure one of the stations from EMISJA System 

for recording of selected process measurements, redundant 

enables second station to collect data and storage them. 

There is possibility to fill lacking data from another station 

after end of campaign. In case of failure both of stations, 

any other PC with installed OPC Server can work as OPC 

Server. 

Clarification Request 5 CL(5) 

Please provide corrective and preventive actions procedure. 

/2/ For the purpose of monitoring the emission reductions the 

following parameters are measured on both production lines 

A and B of ANWIL: 

55





(CARs/FARs) 

• NH3 Flow; 

- flow; 

- pressure; 


• Air flow; 

- flow; 

- pressure; 


• Nitric acid flow; 

- flow; 

- density; 


• N2O concentration in the tail gas ; 

• Volume of the tail gas flow; 

• Tail gas temperature; 

• Tail gas Pressure; 


Please include in the updated Monitoring Report proper 

formulae for the conversion of the N2O concentration data 

from the ppmV units to the mg/Nm3 in the calculations of 

emission reductions. This data should be checked after 

each AST test during future verifications. 

FAR1 

56





(CARs/FARs) 

Forward Action Request (FAR)2 

Please indicate all the monitoring parameters in the next 

monitoring report according to the PDD monitoring section 

D, or revise monitoring plan if different parameters are to be 

monitored. 


Please provide explanation for bigger production of Nitric 

Acid on Line B in comparison with Line A. 


Please provide reason of exceeding during baseline 

campaign the historic nitric acid production 


Please provide explanation of the reason for occurring 

circumstances under which operating conditions during 

baseline measurements can be outside the permitted range. 

4.2. Data collection /7/ All measurement data received from the data logger KX-06 

are recorded on a 1 second basis to the emission computer 

KE MIKROS hard disc. Data are further processed in the 

emission computer. 

All data necessary for the CO2 emission reductions 

calculation is collected in the Maintenance Technician/ 

Maintenance Engineer Department. Maintenance 

Technician/Maintenance Engineer is performing reports on 

daily and monthly basis, which are send to Vertis for 


FAR2 

CL6 

CL7 

CL8 

OK 

57





(CARs/FARs) 

4.3. Quality assurance /7/ AMS installed at the operating plant is in compliance with 

the European norm EN14181 as required per Approved 

Methodology AM000028, which assumes three levels of 

quality assurance of the measurement systems - QAL1, 

QAL2 and QAL3. 

CO2 emission reductions calculations are performing on the 

basis of received monthly raw data from ANWIL, AR 22 

Department by Vertis in the Emission Reduction Model. 

All measured data are collected to the emission computer 

KE MIKROS hard disc. Data are further processed in 

emission computer and hard disc of PC in AR 22 

Department. Maintenance Technician/Maintenance Engineer 

from AR 22 Department is performing reports on daily and 

monthly basis, which are send to Vertis for performing final 

4.4. Significance and 

reporting risks 

calculations. 

/7/ Maintenance technician/maintenance engineer coordinates 

the process of checking and calibration of instruments 

according to previously accepted schedule. In case of 









OK 

OK 

58





(CARs/FARs) 


activities in suitable sheet. 

In case when repair is impracticable, the instrument is 

subjected to be out of service. Lack of measured values is 

pointed with comment in Consolidated data report which is 

pass on to Vertis. 

5. External Data 

5.1. Type and sources of 

external data 

/7/ See section 5 of the MR version 10. OK 

5.2. Access to external data /7/ See section 5 of the MR version 10. OK 

5.3. Quality assurance /7/ See section 5 of the MR version 10. OK 

5.4. Data uncertainty /7/ See section 5 of the MR version 10. OK 

5.5. Emergency procedures /7/ Maintenance technician/maintenance engineer coordinates 

the process of checking and calibration of instruments 

according to previously accepted schedule. In case of 







OK 

59





(CARs/FARs) 

6. Environmental and 

Social Indicators 

6.1. Implementation of 

measures 




activities in suitable sheet. 

In case when repair is impracticable, the instrument is 

subjected to be out of service. Lacks of measured values 

are pointed with comment in Consolidated data report which 

is pass on to Vertis. 

/7/ Secondary catalysts which are installed in all ammonia 

oxidation reactors of both production lines A and B of the 

enterprise breaks down N2O formation during oxidation 

process on N2 and O2 and thus leads to decrease of 

harmful emissions. 

6.2. Monitoring equipment /7/ See section 5 of the MR version 10 OK 

6.3. Quality assurance 

procedures 

/7/ See section 5.16 and section 6 of the MR version 10 OK 

6.4. External data /7/ See section 5 of the MR version 10 OK 

7. Management and 

Operational System 

OK 

60





(CARs/FARs) 

7.1. Documentation /7/ The company complies with all legal and statutory 

requirements of the Poland and the same were made 

available to the verification team. ANWIL has all the 

necessary permissions and licenses. 

7.2. Qualification and 

training 

/7/ See chapter 3.10. of this Table of this protocol OK 

7.3. Allocation of 

/7/ The responsibilities and authorities are described in the OK 

responsibilities 

Instruction on “Supervision the equipment for control, 

measurement and testing used in N2O reduction 

7.4. Emergency procedures /7/ 

installation” and for each individual in job descriptions as 

required statutorily. Persons working at sites are aware of 

their responsibilities, and relative records are maintained. 

See chapter 3.12 and 5.5. of this Table of this protocol 

OK 

7.5. Data archiving /7/ Data are archived in the paper and electronic forms and 

then stored in AR 22 Department. 

7.6. Monitoring report /7/ Data information is laid down in the monitoring report 

version 10. 

OK 

OK 

OK 

61





(CARs/FARs) 

7.7. Internal audits and 

management review 

/7/ All measured data are collected to the emission computer 

KE MIKROS hard disc. Data are further processed in 

emission computer and hard disc of PC in AR 22 

Department. Maintenance Technician/Maintenance Engineer 

from AR 22 Department is performing reports on daily and 

monthly basis. Data on monthly basis are send to Vertis for 



Please provide information on internal audits. 

CL9 

62



Periodic Verification Checklist Protocol Table 2: Data Management System/Controls 

Identification of 

potential reporting 

risk 

1. Defined 

organizational 

structure, 

responsibilities 

and competencies 

1.1. Position and 

roles 

1.2. 

Responsibilities 


assessment 

and testing of 

management 

controls 



Full For this monitoring period the names of the personnel involved is as follows: 

• Michal Czeszynsky ANWIL /Fertilizers Complex / AA Department 

• Piotr Nieznanski ANWIL / Fertilizers Complex / AR Department 

• Romuald Jancewicz ANWIL / Fertilizers Complex / A-2 Department 

• Bozena Balicka ANWIL / Fertilizers Complex / AR -22 Department 

• Marcin Pasinski ANWIL / Fertilizers Complex /AR – 22 Department 

• Jacek Mendelewski ANWIL / Fertilizers Complex / A-2 Department 

• Pawel Slawinski ANWIL / Fertilizers Complex / A-21 Department 

• Janusz Dzwonkowski ANWIL / Fertilizers Complex Department 

• Magdalena Soldacka ANWIL / Fertilizers Complex / A-2 Department 

Full Description of the system for management of emission reduction calculations was 

presented in a transparent and understandable way in the Monitoring Report version 

10, anyway information regarding responsibilities of the departments within the 

monitoring system was not clear. 


63





risk 

1.3. Competencies 

needed 

2. Conformance 

with monitoring 

plan 

2.1. Reporting 

procedures 

2.2. Necessary 

Changes 


assessment 

and testing of 

management 

controls 



Please provide necessary information about responsibilities in the Monitoring Report. 

Full The responsibilities and authorities are described in the Instruction on “Supervision 

the equipment for control, measurement and testing used in N2O reduction 

installation” and for each individual in job descriptions as required statutorily. 

Training needs were identified in advance and training was delivered that was 

checked onsite. 

Full The monitoring plan is as per the registered PDD version 1.3. The uploaded version 

of PDD version 1.3 is publicly available at the site: 

http://ji.unfccc.int/JI_Projects/DB/JWG3JX3FGBI7QCXQDCVS3IGQTQKLHV/PublicPD 

D/U2XMTZ2BQ439J17DAV3PNKWD7O3PXX/view.html 

where it was placed during determination process. 

The JI specific approach for this project was used in monitoring process. 

Full Implementation of the project was as per Monitoring Plan in the determined version 

1.3 of the PDD. 

3. Application of 

GHG determination 

methods 

3.1. Methods used Full The reporting procedures reflect the monitoring plan content. The calculation of the 

emission reduction is correct. 

64





risk 

3.2. 

Information/proces 

s flow 


assessment 

and testing of Areas of residual risks 

management 

controls 

Full See section 3.4 of the Table 1 of this protocol. 

3.3. Data transfer Full See section 3.4 of the Table 1 of this protocol. 


3.4. Data trails Full The necessary procedures have been defined in internal procedures and additional 

internal documents relevant for the determination of the all the parameters listed in 

the monitoring plan 

4. Identification 

and maintenance 

of key process 

parameters 

4.1. Identification 

of key parameters 

4.2. 

Calibration/mainte 

nance 

5. GHG 

Calculations 

Full The critical parameters for the determination of GHG emissions are the parameters 

listed in section D of the approved PDD version 1.3. 

Full The company maintains the elaborate calibration plan for each of the equipment. The 

audit team verified the status of all the equipment at the sites sampled for the audit 

and found them to be complying to the plan. 

65





risk 

5.1. Use of 

estimates and 

default data 

5.2. Guidance on 

checks and 

reviews 

5.3. Internal 

validation and 

verification 

5.4. Data protection 

measures 

5.5. IT systems Full 


assessment 

and testing of Areas of residual risks 

management 

controls 

Full See Section 6 of the Monitoring Report version 10 


Full All measured data are collected to the emission computer KE MIKROS hard disc. 

Data are further processed in emission computer and hard disc of PC in AR 22 

Department. Maintenance Technician/Maintenance Engineer from AR 22 Department 

is performing reports on daily and monthly basis. Data on monthly basis are send to 

Vertis for performing final calculations. 

Full Monitoring procedure for JI Project includes the responsibility and frequency for 

carrying out internal audits. 

Clarification Request 9 

Please provide information concerning the internal audits. 

Full The necessary procedures relating to Information technology are in place to provide 

necessary data security, and also prevent the unauthorized use of the same. 

Data is collected in electronic database. 

66




Periodic Verification Protocol Table 3: GHG calculation procedures and management control testing 

Identification of potential reporting 

risk 

Potential reporting risks based on an 

assessment of the emission estimation 

procedures can be expected in the 

following fields of action: 

� the calculation methods, 

� raw data collection and sources of 

supporting documentation, 

� reports/databases/information 

systems from which data is 

obtained. 

Key source data applicable to the project 

assessed are hereby: 

� metering records , 

� process monitors, 

� operational logs (metering 

records), 

� laboratory/analytical data (for 

energy content of fuels), 

� accounting records, 

Appropriate calibration and maintenance 

of equipment resulting in high accuracy of 

Identification, assessment and testing 


Regarding the potential reporting risks 

identified in the left column the following 

mitigation measures have been observed 

during the document review and the on 

site mission: 

Key source data for this parameter are: 

• meter reading. 

• Invoices and record for Fuels (and coal) 

for consumption and purchase. 

The metering equipments are installed 

appropriately in the enclosure panels and 

same are of reputed make. 

Calculation methods: 

The reporting procedures reflect the 

monitoring plan content and the 

calculation of the emission reduction is 

correct and also additionally deducting the 

project emissions caused by fossil fuel. 


The issue remaining is the way the data 

obtained is used to calculate the emission 

reduction in a conservative manner 

according to the approach prescribed in 

the PDD version 1.3 as well as the way 

data obtained is used to calculate the 

emissions reductions. 

67



Identification of potential reporting 

risk 

data supplied should be in place. 

It is hereby needed to focus on those 

risks that impact the accuracy, 

completeness and consistency of the 

reported data. Risks are weakness in the 

GHG calculation systems and may 

include: 

� manual transfer of data/manual 

calculations, 

� position of the metering 

equipment, 

� unclear origins of data, 

� accuracy due to technological 

limitations, 

� lack of appropriate data protection 

measures (for example, protected 

calculation cells in spreadsheets 

and/or password restrictions). 

Identification, assessment and testing 




68




Periodic Verification Protocol Table 4: Detailed audit testing of residual risk areas and random testing 

Areas of residual 

risks 

The issue 

remaining is the 

way the data 

obtained is used to 

calculate the 

emission reduction 

in a conservative 

manner according 

to the approach 

prescribed in the 

PDD. 

Additional verification 

testing performed 

There has been a 

complete check of data 

transferred from daily 

consumption and 

generation readings to 

the calculation tool. There 

was no error in such 

transfer. The correct 

installation of the 

metering equipment can 

be confirmed. 

Conclusions and Areas Requiring Improvement 

(including Forward Action Requests) 

Having investigated the residual risks, the audit team comes to the following 

conclusion: 

Immediate action is not needed with respect to the current emission reduction 

calculation. Those corrections have been considered during the verification 

process, so no residual risk is open. 

69



Verification Protocol Table 5: Resolution of Corrective Action and Clarification Requests 

Report clarifications and 

corrective action 

requests 

Corrective Action 

Request (CAR) 1 

Please provide 

evidence of approval 

from the Lichtenstein 

side. 

Forward Action 

Request (FAR) 1 

Please include in the 

updated Monitoring 

Report proper 

formulae for the 

conversion of the N2O 

concentration data 

from the ppmV units 

to the mg/Nm3 in the 

calculations of 

emission reductions. 

This data should be 

checked after each 

Ref. to 

checklist 

question 

in tables 

2/3 


Summary of project owner response Verification conclusion 

2.1. Investor Party LoA issued by the 

Principality of Liechtenstein is 

provided to the verifier. 

4.1. An appropriate formula for conversion 

of the N2O concentration data from 

the ppmV units to the mg/Nm3 in the 

calculations of emission reductions 

was included in the updated 

Monitoring Report version 10. Results 

of the following AST tests will be 

applied in the proper way in the next 

Monitoring Reports. 

Evidencing document was 

checked and found satisfactory. 


Issue will be closed during next 

verification. 

70





requests 

AST test during future 

verifications. 

Forward Action 

Request (FAR)2 

Please indicate all the 

monitoring parameters 

in the next monitoring 

report according to 

the PDD monitoring 

section D, or revise 

monitoring plan if 

different parameters 

are to be monitored. 


(CL) 1 

Please clarify why 

start date of the 

project campaign is 

earlier than date of 

the secondary 

Ref. to 

checklist 

question 

in tables 

2/3 



4.1. All the monitoring parameters will be 

indicated in the next monitoring report 

according to the PDD monitoring 

section D, or will be revised 

monitoring plan if different parameters 

are to be monitored. 

3.1. Starts of project campaigns on both 

lines A and B as defined in the 

Monitoring report are same as dates 

of the secondary catalysts installation. 

Issue will be closed during next 

verification. 


71





requests 

catalysts installation. 

Clarification 

(CL) 2 

Request 


clarification how 

amounts of emission 

reduction calculations 

for 2008 for Line A 

and Line B and for 

2009 for Line A and 

Line B were 

calculated. 

Clarification 

3 CL (3) 

Request 


necessary information 

regarding reporting 

procedures in the 


Ref. to 

checklist 

question 

in tables 

2/3 



3.4. Estimates of ERU quantities contained 

in the PDD have been calculated using 

estimated project emission factors and 

applying this factor on estimated 

annual HNO3 production during the 

crediting period 2008-2012 as 

required by the PDD format of the 

Section E. 

Assumptions used for calculation of 

annual ERUs estimates are defined in 

detail in the Annex 2 of the PDD. 

3.8. Information on the reporting procedure 

has been added to the sections 5.17 

of the monitoring report. 



Clarification Request 3.11. Information on the responsibilities has Issue is closed. 

72





requests 

4 CL (4) 


necessary information 

about responsibilities 

in the Monitoring 

Report. 


5 CL(5) 


corrective and 

preventive actions 

procedure. 


(CL) 6 


explanation for bigger 

production of Nitric 

Acid on Line B in 

comparison with Line 

A. 

Ref. to 

checklist 

question 

in tables 

2/3 



been added to the sections 5.18 of the 

monitoring report. 

3.12. Corrective and preventive actions 

procedure is provided in the document 

named 

Troubleshooting_Instrukcija_KA_IJ_09 

0802.pdf. 

4.1. Both lines A and B have different 

primary catalysts and thus also 

separate production schedule. It 

means that starts and ends of 

campaigns on both lines are different 

and thus different HNO3 production is 

business as usual, as can be seen 

also on the overview of 5 historic 

campaigns HNO3 production in the 

Campaign_length worksheet of the 



73





requests 


(CL) 7 

Please provide reason 

of exceeding during 

baseline campaign the 

historic nitric acid 

production 


(CL) 8 


explanation of the 

reason for occurring 

circumstances under 

which operating 

conditions during 

baseline 

Ref. to 

checklist 

question 

in tables 

2/3 



4.1. 

emission reductions calculation model. 

Historic HNO3 production established 

as average of 5 historic campaigns 

was higher due to favorable market 

situation requiring in the spring 2008 

higher production of fertilizers. Spring 

is the peak of the production season 

in the fertilizers industry. From the JI 

point of view this issue has been 

handled in accordance with the PDD, 

i.e. emission data measured after 

reaching the historic campaign length 

have not been included into the 

baseline emission factors calculations. 

4.1. Operating conditions during the 

baseline campaigns had been outside 

the permitted range during start-up 

and shut-down periods. 



74





requests 

measurements can be 

outside the permitted 

range. 


(CL) 9 


information on internal 

audits. 


(CL) 10 

Please clarify why the 

last calibration date 

for pressure 

transmitter PT 2211- 

2A on Line A is 

15/07/2009 in the 

“Measurement devices 

specification list: Line 

A” while in the 

calibration record for 

this device last date 

of calibration is 

15/07/2008. 

Ref. to 

checklist 

question 

in tables 

2/3 



7.7. Protocol of the internal audit carried 

out in August 2009 is provided. 

3.6. This was technical mistake. Last 

calibration date for pressure 

transmitter PT 2211-2A on Line A is 

15/07/2008. Date was changed in the 

“Measurement devices specification 

list: Line A”. Changed document was 

provided to verification team. 



75




APPENDIX B: VERIFICATION TEAM 

The verification team consists of the following personnel: 

Nadiia Kaiun, M.Sci. (environmental science) 

Team Leader, Lead Verifier 

Bureau Veritas Poland. 

She has graduated from National University of Kyiv-Mohyla 

Academy with the Master Degree in Environmental Science. She is 

a Lead auditor of Bureau Veritas Certification for Environment 

Management System (IRCA registered). She performed over 15 

audits since 2008. She has undergone intensive training on Clean 

Development Mechanism /Joint Implementation and she is involved 

in the validation of 7 JI projects. 

Witold Dzugan, M.Sci. (environmental engineering) 

Verifier 

Bureau Veritas Poland 

He has graduated from Technical University of Poznan with master 

degree in environmental engineering / HVAC. He is EMS / QMS 

lead auditor BVC Poland, EU ETS Verifier. He has 12 years of 

experience in EMS implementation and certification with approx. 

1000 man-days of EMS / QMS certification audits. EU ETS verifier 

since 2007. 

Report was reviewed by: 

Ivan G. Sokolov, Dr. Sci. (biology, microbiology) 

Bureau Veritas Certification Internal reviewe 

Bureau Veritas Ukraine HSE Department manager. 

He has over 25 years of experience in Research Institute in the 

field of biochemistry, biotechnology, and microbiology. He is a 

Lead auditor of Bureau Veritas Certification for Environment 

Management System (IRCA registered), Quality Management 

System (IRCA registered), Occupational Health and Safety 

Management System, and Food Safety Management System. He 

performed over 130 audits since 1999. Also he is Lead Tutor of the 

IRCA registered ISO 14000 EMS Lead Auditor Training Course, and 

Lead Tutor of the IRCA registered ISO 9000 QMS Lead Auditor 

Training Course. He has undergone intensive training on Clean 

Development Mechanism /Joint Implementation and he was/is 

involved in the determination/verification of 26 JI projects. 

76




APPENDIX C: DOCUMENTS CHECKED DURING VERIFICATION 

1. 

2. 

Results of the HNO3 production for 5 previous historical campaigns for 

Line A 

Results of the HNO3 production for 5 previous historical campaigns for 

Line B 

3. Results of the HNO3 production for baseline campaign for Line A 

4. Results of the HNO3 production for baseline campaign for Line B 

5. Results of the HNO3 production for project campaign for Line A 

6. Results of the HNO3 production for project campaign for Line B 

7. Result of the Internal Quality Audit SZJ*SZS* Nr. 3/ 2008 

The list of questions for audit of the monitoring system of N2O for 

8. auditing of Departments A-2, AR-22, dated 05/08/2009 

Installation and operating instructions for line B. Optimass. Coriolis 

mass flowmeters 

MFM 7050/7150 K 

MFC 050/051 F 

9. MFS 7000/7100 F 

10. Instruction for CORIMASS P class flow meters for Line B. Krohne. 

11. Refractometer installation protocol, enclosure Nr.11, dated 03/03/2009 

12. Malfunctions table. Clarifications of lacking measurements. 

13. N2O analyzer (SIDOR) data sheet. 

QAL 1 Certificate for Flowsic 100 USD gas volume flow meter, TÜF 

Rheinland Imissionsschutz und Energiesysteme GmbH, dated 

14. 08/05/2007. 

QAL 1 Certificate for SIDOR N2O analyzer, TÜF Nord Umweltshutz 

15. GmbH and Co. KG, dated 28/03/2007. 

QAL 2 Calibration report according EN 14181, AIRTEC, Project Nr. 

16. 1180310, dated 04/04/2008 for Line A 

QAL 2 Calibration report according EN 14181, AIRTEC, Project Nr. 

17. 1180310, dated 04/04/2008 for Line B 

18. Shewart_Span_1_3rdQ_4thQ_2007 

19. Shewart_Span_2_Jan_Feb_March_2008 

20. Shewart_Span_3_April_2008 

21. Shewart_Span_4_May_2008 

22. Shewart_Span_5_June_2008 

23. Shewart_Span_6_July_2008 

77



24. Shewart_Span_7_August_2008 

25. Shewart_Span_8_September_2008 

26. Shewart_Span_9_October_2008 

27. Shewart_Span_10_November_2008 

28. Shewart_Span_11_December_2008 

29. Shewart_Span_12_January_2009 


30. Shewart_Span_13_February_2009 

31. Shewart_Span_14_March_2009 

32. Shewart_Zero_1_September_2007 

33. Shewart_Zero_2_October_2007 

34. Shewart_Zero_3_November_2007 

35. Shewart_Zero_4_December_2007 

36. Shewart_Zero_5_January_2008 

37. Shewart_Zero_6_February_2008 

38. Shewart_Zero_7_March_2008 

39. Shewart_Zero_8_April_2008 

40. Shewart_Zero_9_May_2008 

41. Shewart_Zero_10_June_2008 

42. Shewart_Zero_11_July_2008 

43. Shewart_Zero_12_August_2008 

44. Shewart_Zero_13_September_2008 

45. Shewart_Zero_14_October_2008 

46. Shewart_Zero_15_November_2008 

47. Shewart_Zero_16_December_2008 

48. Shewart_Zero_17_January_2009 

49. Shewart_Zero_18_February_2009 

50. Shewart_Zero_19_March_2009 

51. Emission Reduction Model Calculations Line A, Excel File. 

52. Emission Reduction Model Calculations Line B, Excel File. 

Emission Reduction Model User Manual, compliant with AM0034 

53. version 03.2 

54. Schedule of the AST and QAL 2 test for ANWIL JI Project. 

IPCC permit, WSIR/DW 6-EB/6618/14/06, dated 15 

55. 

th of December 

2006. 

56. Operating Conditions. Plant Manual. 

57. Permitted operating ranges of the plant. 

Instrukcja SZJ, Supervision the equipment for control, Issue 2 

measurement and testing used in N2O reduction installation, Issue 2, 

KA-IJ-09.08.02. 

58. 

59. QAL 3 Manual. 

60. Calibration record for mass flow meter DT2201A. 

78




61. Calibration record for mass flow meter DT2201B. 

Calibration record for Refractometer for measuring N2O concentration 

62. DY2201 for Line A. 

63. Calibration record for Difference pressure transmitter FT2219A. 

64. Calibration record for Difference pressure transmitter FT2219B. 

Calibration record for Atmospheric pressure transmitter PT2202 for 

65. Line A. 

66. Calibration record for pressure transmitter PT2202A. 

67. Calibration record for pressure transmitter PT2202B. 

68. Calibration record for pressure transmitter PT2211_1A. 

69. Calibration record for pressure transmitter PT2211_1B. 

70. Calibration record for pressure transmitter PT2211_2A. 

71. Calibration record for pressure transmitter PT2211_2B. 


73. Calibration record for pressure transmitter PT2247B. 

74. Calibration record for „K” Thermocouple T2285-7A. 

75. Calibration record for „K” Thermocouple T2285-7B. 

76. Calibration record for „K” Thermocouple T2286_1A. 

77. Calibration record for „K” Thermocouple T2286_1B. 







84. Calibration record for temperature transmitter TT2202A. 

85. Calibration record for temperature transmitter TT2202B. 

86. Calibration record for temperature transmitter TT2211_1A. 

87. Calibration record for temperature transmitter TT2211_1B. 

88. Calibration record for temperature transmitter TT2211_2A. 

89. Calibration record for temperature transmitter TT2211_2B. 

90. JI project functional diagram. 

Standard EN 14181 – Stationary source emissions - Quality 

91. Assurance of Automated Measuring Systems. 

92. Act issued on May 11, 2001 “Law about measures”, Poland. 

Order of Minister of Environment dated 4 August 2003 on “Emission 

93. standards from installations”, Dz.U.no.163, pos.1584. 

Operating instruction for FLOWSIC 100 gas velocity and volume flow 

94. meter. 

Operating instruction for SIDOR. Extractive Multicomponent Gas 

95. Analyzer. 

96. Operating instruction for temperature transmitter, type APT-28. 

Operating instruction for pressure transmitters, type PR – 28, PR -50, 

97. PR – 54, PR – 50G. 

Maintenance instruction for pressure transmitters HD9408 and HD 

98. 9908. 

Project documentation. Monitoring system of N2O emissions in the A- 

99. 21 Department of Zakłady Azotowe Anwil S.A. 

79




List of articles published on the Anwil website as well as in Polish 

100. media about JI Project on Anwil. 

101. DIN EN ISO/IEC1 7025:2005 Certificate of the ARTEC Laboratory. 

Letter identification of measuring devices used in Fertilizer Complex in 

102. accordance with Polish Standard PN-89-42007. 

Consolidated data report, send by ANWIL to Vertis, dated February 

103. 2009. 

104. Daily inspection sheet. 

105. N2O Analyzer checking sheet. 

106. Inspection/ calibration protocol. 

107. Procedure AW-PJ/ PS-11 "Supervision of Records SZI and SZS". 

Annex 13 to the 13 

108. 

th Meeting of the Joint Implementation Supervisory 

Committee “Clarification regarding overlapping monitoring periods 

under the verification procedure under the Joint Implementation 

Supervisory Committee.”, version 1. 

109. Calibration record for difference pressure transmitter FT2211_1A. 

110. Calibration record for difference pressure transmitter FT2211_1B. 

111. Calibration record for difference pressure transmitter FT2211_2A. 

112. Calibration record for difference pressure transmitter FT2211_2B. 

113. Calibration record for difference pressure transmitter FT2219A. 

114. Calibration record for difference pressure transmitter FT2219B. 

115. Calibration record for difference pressure transmitter FTS2211_1A. 

116. Calibration record for difference pressure transmitter FTS2211_1B. 

117. Calibration record for difference pressure transmitter FTS2211_2A. 


Report on parallel comparison tests for automated measuring systems 

of Line A and B N2O reduction complex in ANWIL S.A. nitric acid 

119. plant, dated August 2009. 

120. Emission Reduction Model User Manual version 4. 

80

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