CARGILL HIGH RIVER METHANE CAPTURE OFFSET PROJECT THIRD -PARTY VERIFICATION REPORT

REPORTING PERIOD : JANUARY 1, 2015– DECEMBER 31, 2015

Submitted to:

Blue Source ULC Suite 700, 717 th Avenue SW , AB T2P 3R5

Submitted by:

ClearSky Engineering Inc. 221 Drake Landing Lane, Suite 1 , AB T1S 2M4

April 5, 2016

TABLE OF CONTENTS

1. PROJECT SUMMARY INFORMATION ...... 1

2. VERIFICATION SUMMARY INFORMATION ...... 2

3. INTRODUCTION...... 2

4. OBJECTIVE ...... 3

5. SCOPE ...... 4

6. PROGRAM CRITERIA ...... 4

7. VERIFICATION STRATEGY ...... 4

8. VERIFICATION PLAN ...... 5 8.1. VERIFICATION PREPARATION & PLANNING ...... 5 8.2. SITE VISIT ...... 5 8.3. EMISSION REDUCTION QUANTIFICATION ASSESSMENT ...... 8 8.4. PROJECT DATA MANAGEMENT SYSTEM ...... 9 8.5. ISSUES IDENTIFIED DURING VERIFICATION ...... 10 9. SAMPLING PLAN ...... 12

10. VERIFICATION SCHEDULE ...... 12

11. VERIFICATION FINDINGS ...... 13

12. CONFIRMATIONS ...... 14

13. STATEMENT OF VERIFICATION ...... 15

REFERENCES ...... 17

APPENDIX A: STATEMENT OF QUALIFICATIONS ...... 18

APPENDIX B: CONFLICT OF INTEREST CHECKLIST ...... 21

APPENDIX C: PEER REVIEW ...... 24

APPENDIX D: VERIFICATION PLAN ...... 26

CARGILL HIGH RIVER METHANE CAPTURE PROJECT VERIFICATION REPORT FOR 2015 VINTAGE YEAR i

LIST OF TABLES

Table 1-1 Project Summary Information...... 1 Table 2-1 Verification Summary Information ...... 2 Table 8-1 Site Visit Attendees...... 5 Table 8-2 Automated vs Manual Data Collection ...... 10 Table 8-3 Verification Issue Log...... 11 Table 11-1 Final Summary of Unadjusted Differences (SUD) Table ...... 13

LIST OF FIGURES

Figure 3-1 Arial View of Cargill High River Methane Capture Project...... 3 Figure 8-1 Anaerobic Lagoon Covers ...... 6 Figure 8-2 Protocol Quantification Approach ...... 8

LIST OF ACRONYMS

Acronym Definition AEP Environment and Parks BOD Biological oxygen demand CH 4 Methane CO 2e Carbon dioxide equivalent GHG Greenhouse Gas GWP Global Warming Potential HHV Higher Heating Value PPE Personal Protective Equipment QA/QC Quality Assurance / Quality Control SCADA Supervisory Control and Data Acquisition SGER Specified Gas Emitters Regulation SS Sources/Sinks SUD Summary of Unadjusted Difference

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1. PROJECT SUMMARY INFORMATION

Table 1-1 Project Summary Information Project Title: Cargill High River Methane Capture Project Project Description: The Project captures biogas containing methane for fuel use that would have been released to the atmosphere from the anaerobic treatment of wastewater. Project Location: 472 Avenue & Hwy 2A North P.O. Bag 3850 High River, Alberta T1V 1P4 Latitude: 50.626979, Longitude: - 113.879085 Project Start Date: October, 2003 Credit Start Date: January 1, 2004 Credit Duration Period: January 1, 2004 - December 31, 2016 (extension granted to initial 8 year crediting period) Expected Lifetime of the Lifetime of the equipment, expected to be far in excess of the credit Project: duration period. Actual Emission Reductions / From January 1, 2015, to December 31, 2015, the project emission Removals Achieved: reductions are asserted to be 70,284 tonnes CO 2e. Applicable Quantification Alberta Environment, Quantification Protocol for Anaerobic Protocol: Treatment of Wastewater Projects, Version 1, March 2009 Other Environmental No other environmental attributes, credits, or benefits are being Attributes: sought or created by this Project. Project Registration: The project offset credits will be registered with the Alberta Emissions Offset Registry (AEOR) which tracks the creation, sale and retirement of credits. Ownership: Cargill Meat Solutions, A Division of Cargill Limited Project Activity: This activity meets all the eligibility criteria for the Alberta offset system as described in Section 1 of the Offset Project Report. Project Contacts: Authorized Project Contact Project Proponent Kelly Parker, B.Sc. Michael Bernardo Carbon Services Project Analyst Environmental Supervisor Blue Source Canada ULC Cargill Meat Solutions Suite 700 472 Avenue & Hwy 2A North 717-7th Avenue SW P.O. Bag 3850 Calgary, AB T2P 0Z3 High River, AB T1V 1P4 p: (403) 262-3026 p: (403) 652-4688 ext.482 e: [email protected] e: [email protected]

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2. VERIFICATION SUMMARY INFORMATION

Table 2-1 Verification Summary Information Objective: Develop a conclusion with a reasonable level of assurance as to whether the greenhouse gas emission reduction assertion is free from material misstatement, and is presented fairly in accordance with the Specified Gas Emitters Regulation (SGER) and the Alberta offset system program criteria. Summary: We have found the Offset Project Report for the Cargill High River Methane Capture Project, version 1.0, dated April 2016 and the 2015 GHG Emission Reduction Assertion to be reliable, complete, and in compliance with the requirements of the SGER and the Alberta offset system program criteria. Lead Verifier: Klym Bolechowsky, P.Eng. ClearSky Engineering Inc. p: (403) 982-5596 e: [email protected] w: www.ClearSkyEng.com Peer Reviewer: Kurt J. Hansen, M.Sc., P.Eng. Green Inc. p: (403) 398-3981 e: [email protected] Designated Signing Authority: Klym Bolechowsky, P.Eng. Verification Dates: The verification was carried out from November 20, 2015 – March 31, 2016, inclusive. Site Visit Date: December 3, 2015 Report Date: April 5, 2016

3. INTRODUCTION

ClearSky Engineering Inc. was engaged by Blue Source Canada ULC (Blue Source) to verify 2014 vintage year offset credits generated by the Cargill High River Methane Capture Project. The offset project was verified at a reasonable level assurance against the Quantification Protocol for Anaerobic Treatment of Wastewater Projects, Version 1.0, March 2009, the Offset Project Plan, v3.0, April, 2016, and the program requirements of the Specified Gas Emitters Regulation (SGER). Blue Source (the authorized project contact) prepared the offset project documentation and GHG Emission Reduction Assertion on behalf of the project proponent, Cargill Meat Solutions, A Division of Cargill Limited (Cargill).

The Project was implemented in October 2003 when the wastewater treatment lagoons were covered with a geo-membrane and a biogas capture system was installed to enable capture of the methane-rich biogas. After conditioning (water vapour removal & gas compression), the biogas is combusted in a facility boiler to produce steam for the meat processing plant. A flaring system was also installed to burn any unused biogas.

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The captured biogas displaces approximately 30% of the natural gas required by the meat processing plant. The generated carbon offsets are from the avoidance of methane emissions created through the combustion of fossil fuel in a boiler and the avoided fugitive release of methane from the anaerobic wastewater lagoons. In the baseline condition, the facility was emitting 100% of the biogas from the treatment lagoons to the atmosphere. The Project was subject to its second AEP Audit in 2012.

Figure 3-1 Arial View of Cargill High River Methane Capture Project

Source: Google Earth

The format of this report follows the structure outlined in Alberta Environment and Park’s (AEP) template for Offset Project Verification Reports, Version 2, February 2013.

4. OBJECTIVE

The objective of this verification is to develop a conclusion at a reasonable level of assurance as to whether the greenhouse gas emission reduction assertion is free from material misstatement, and is presented fairly in accordance with the SGER and the Alberta offset system program criteria. This verification was carried out in accordance with the following standards: • ISO 14064 Part 3 – Greenhouse Gases: Specification with guidance for the validation and verification of greenhouse gas assertions • Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January, 2013

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5. SCOPE

The scope of the verification is the GHG Emission Reduction Assertion presented in the Offset Project Report “Cargill High River Methane Capture Project”, v1.0, April 2016 for the period January 1, 2015 to December 31, 2015. Level of Assurance: Reasonable Materiality Threshold: 5%

6. PROGRAM CRITERIA

The verification involved executing verification procedures that assessed the Project and associated GHG assertion against the following criteria: • Climate Change and Emissions Management Act • Specified Gas Emitters Regulation • Quantification Protocol for Anaerobic Treatment of Wastewater Projects, Version 1.0, March 2009 * • Technical Guidance for Offset Project Developers, Version 4.0, February 2013 • Carbon Offset Emission Factors Handbook, Version 1.0, March 2015 • Template: Alberta Offset System, Offset Verification Report, Version 2, February 2013 • Template: Alberta Offset System, Offset Project Report, Version 3, February 2013 • Template: Alberta Offset System, Offset Project Plan, Version 3, February 2013

* The Protocol is currently under review to address known risks in the protocol. http://aep.alberta.ca/climate-change/guidelines-legislation/specified-gas-emitters- regulation/offset-credit-system-protocols.aspx

7. VERIFICATION STRATEGY

The verification strategy is a mixed approach of predominantly substantive procedures and some controls reliance: • Substantive Procedures were employed for biogas volume to boiler and flare, biogas parameters (pressure, temperature, methane content, HHV), and wastewater flow rates & BOD analysis results • Test of Controls by checking meter calibration reports

Verification Standard: ISO 14064 Part 3 – Greenhouse Gases: Specification with guidance for the validation and verification of greenhouse gas assertion

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8. VERIFICATION PLAN

The Final Verification Plan is provided in Appendix D. A description of the verification procedures executed is described below.

8.1. VERIFICATION PREPARATION & PLANNING A Statement of Qualifications for the verification team is included in Appendix A. The first task completed was a conflict check which is documented in the Conflict of Interest Checklist included in Appendix B of this report. A verification acceptance screening phase was completed to evaluate the client and the verification team. This is documented in the verification working papers. A date for the site visit was established and the following information was provided by Blue Source: • Updated Offset Project Plan • Draft Offset Project Report • Draft GHG emission reduction calculation spreadsheet • Supporting Documentation: o Records from plant SCADA system data historian (Proficy) o Wastewater treatment anaerobic process performance data o Biogas condition system equipment specs o Biogas analysis reports o Wastewater BOD analysis reports o Sludge press recycle manual records o Anaerobic effluent manual records o Lagoon venting manual records o Lagoon cover inspection reports

The Offset Project Report was reviewed in detail and checked against the AEP template for completeness. A risk assessment was completed and a Preliminary Verification Plan & Site Visit Agenda was developed and sent to Blue Source prior to the site visit (see Appendix D).

8.2. SITE VISIT The site visit occurred on December 3, 2015 with the following individuals in attendance:

Table 8-1 Site Visit Attendees Cargill Meat Solutions Blue Source Canada Verifier Michael Bernardo, Kelly Parker, B.Sc., Carbon Klym Bolechowsky, P.Eng., Environmental Supervisor Services Project Analyst Lead Verifier Chloe Wang, Environmental Supervisor Dale Paton, Environmental Superintendent

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The purpose of the site visit was to perform the following tasks: • Discuss the details of Project operation and performance in 2015 with operational personnel • Tour the Project site to corroborate the GHG sources/sinks, facility description and boundaries, and details of the calculation methodology described in the Project Plan; including review of: o Anaerobic wastewater treatment plant o Biogas capture system o Biogas conditioning equipment and electricity consumption o Biogas supply to plant boiler o Project propane consumption for flare pilot burner o Project monitoring and metering • Assess the reliability of the data used as input to the GHG offset calculations and the overall approach

An initial meeting was held with Michael Bernardo and Chloe Wang of Cargill along with Kelly Parker of Blue Source and the Lead Verifier. A series of questions were posed to Cargill staff to gain an understanding of the project and operation details in 2015 (see Preliminary Verification Plan & Site Visit Agenda, Appendix D). The project changes that occurred in 2015 include: • the vent tubes in the lagoon covers were removed and replaced with three manual vent valves per lagoon (six in total); • the wastewater effluent flow meter was replaced in August 2015; and • the biogas flare was re-located to accommodate installation of a new lagoon (in progress). A site tour was conducted (PPE requirements: CSA safety boots, hard hat, safety glasses) starting with the two anaerobic lagoons. Each lagoon is completely covered with a geo- membrane (80 mil high density polyethylene) to capture biogas (typically approx. 75% methane by volume).

Figure 8-1 Anaerobic Lagoon Covers and Manual Vent

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We viewed that biogas conditioning system for removal of water vapour and the two electric drive Delta blowers that compress the biogas for delivery via piping to the meat processing plant boiler. The biogas control panel was viewed displaying the flow rate and pressure to the boiler and flare. The monitored biogas temperature gauge was also observed. The nearby new meter for the lagoon effluent flow rate was viewed that had been replaced in August, 2015. We then went outside to view the lagoon covers and new manual vents (three per lagoon, six in total) that were installed in 2015 replacing the previous cover-mounted vents. The relocated biogas flare stack equipped with a propane fuelled pilot was viewed. The sludge press area was viewed and the new meter recording the sludge flowrate back to the lagoons. This monitoring point is important as it contributes to the calculated biological oxygen demand (BOD) removal from the lagoons in the baseline condition. To determine the BOD removal and subsequently the methane emissions (based on Protocol equation B7), the BOD concentration in the influent and effluent of the lagoons is sampled by plant operators three times per week and analyzed in the internal lab. The influent BOD is determined based on a composite sample, and the effluent BOD is determined based on a grab sample. The grab sample is sent monthly to an external lab for analysis. We entered the meat processing plant and viewed the 25 MMBtu/hr fire-tube boiler that combusts biogas approximately 90% of the time according to the stationary engineer. The fuel supply is manually switched to natural gas when biogas availability is low. The biogas has a lower methane content and therefore a lower heating value than commercial sales natural gas. The two other facility boilers combust natural gas fuel exclusively. We visited the on-site lab and a technician provided an overview of the internal BOD analysis process and calibration to lab standard prior to each test. The lab procedure followed is internal Cargill “ATP” procedure based on: Standard Methods for the Examination of Water and Waste Water, 22nd ed., American Public Health Association, Washington, DC, 2012, Method 5210 B. Samples of the biogas system monitoring manual records from 2015 were obtained for review (a scanned set of all of the 2015 records was later requested and obtained). Some of the project monitoring has been converted to electronic capture via the plant SCADA system and stored in a data historian called Proficy, however, some manual records are still collected by plant operators and transcribed for input to the GHG emission reduction calculations (see section 8.4, Data Management). A final meeting was held after the tour and final questions were posed to Cargill staff followed by a wrap-up meeting. The following tasks were completed after the site visit: • Follow-up data requests including: o Clarification of data inputs that were from manual records vs Proficy data historian o Copies of all manual records used as data inputs to GHG calculations • Phone and email communications to clarify information provided • Detailed review of the Project Report against the Project Plan

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• Discuss updates to the Offset Project Plan as a number of project changes have occurred since last version • Detailed review of GHG emission reduction calculations • Sampling of Project manual records for comparison to calculation inputs (see Sampling Plan, Appendix D) • Follow-up with Blue Source on any identified issues observed with calculations record sampling (see Table 8-1)

8.3. EMISSION REDUCTION QUANTIFICATION ASSESSMENT According to the Quantification Protocol for Anaerobic Treatment of Wastewater Projects , numerous GHG sources/sinks (SS) exist throughout the life cycle of a biogas capture project. The following baseline condition and project condition sources are required to be included in the GHG quantification effort:

Figure 8-2 Protocol Quantification Approach

Source: Quantification Protocol for Anaerobic Treatment of Wastewater Projects, Version 1.0, March 2009

Not all of the above sources/sinks (SS) are applicable to the project. This is documented in the Offset Project Plan and the rationale for the excluded SS was confirmed. The above equations reduce to:

Emission Reduction = Emissions Baseline – Emissions Project

Emissions Baseline = sum of the emissions under the baseline condition =

Emissions Fuel Extraction and Processing = emissions under SS (B1) +

Emissions Thermal Energy Generation = emissions under SS (B3) +

Emissions Anaerobic Wastewater Treatment Process = emissions under SS (B7)

Emissions Project = sum of the emissions under the project condition =

Emissions Fuel Extraction and Processing = emissions under SS (P1) +

Emissions Facility Thermal Energy Generation = emissions under SS (P3) +

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Emissions Biogas Venting = emissions under SS (P17) +

Emissions Biogas Conditioning = emissions under SS (P18) +

Emissions Biogas Flaring = emissions under SS (P19)

The baseline condition GHG calculations quantify emissions from the extraction and processing of natural gas that would have been combusted in absence of the project (B1), the combustion of the natural gas in the boilers (B3), and the methane emissions that would have occurred from the anaerobic wastewater treatment lagoons (B7). The project condition GHG calculations quantify emissions from the extraction and processing of propane flare pilot fuel (P1), the combustion of biogas in the boiler (P3), biogas venting (occasional due to excess biogas buildup in the lagoons and inefficiencies in the capture system) (P17), electrical consumption of the biogas conditioning equipment (P18), and biogas flaring (P19). The equation for each of the above SS is documented in the protocol and it was confirmed that the correct protocol equations and constants were applied in the GHG emission reduction calculations. The equations and units were checked for accuracy. The spreadsheets were checked thoroughly for correctly functioning links and formulas. The sources of the emission factors referenced in the calculations were checked and confirmed. The emission contributions by SS were reviewed in context to previous year’s values. In 2015, the largest contributors to the generated offset credits are ‘B7 Anaerobic Wastewater Treatment Process’ (86.9% of baseline emissions) and P17 Venting of Biogas (91.8% of project emissions) (see Contribution Analysis, Appendix D). Overall, the total offset credits generated decreased by 17.3% from 2014 largely due to an increase in venting emissions (and a new method to calculate venting emissions to address the larger manual vents that were installed in 2015), and an increase in flaring emissions.

8.4. PROJECT DATA MANAGEMENT SYSTEM The Project relies on a combination of manual and automated monitoring data for key parameters. The conversion of data recording from manual operator logs to the SCADA system is still in progress. This was initiated due to a finding in an AEP Audit conducted in 2012 by Millennium EMS Solutions Ltd noting numerous transcription errors due to the mainly manual data management system: Required Action: Cargill is to move to automated data management, in the meantime, the QA/QC level must be increased to mitigate the possibility of similar findings in the future. Please describe how the QA/QC procedure will be improved. Response: Cargill has included provision in its current capital expenditure plan for upgrading to automated data collection (i.e. tying meters into the SCADA system on- site). This will be completed by June 2013. Until this system is installed, Blue Source will move from crosschecking a sample of 10-20% of data to crosschecking 100% of data.

Source: email communication from Blue Source to AEP, Oct. 29, 2012

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The following is a summary of the project parameters that are monitored by the SCADA system and the outstanding parameters that were still recorded manually for all or part of 2015:

Table 8-2 Automated vs Manual Data Collection Plant SCADA System Manual Records (stored in Proficy Data Historian) Volume of Biogas to Boiler (as of Sept. Biogas Temperature: Jan 1 – Jan 31, 2015 2013) Volume of Biogas to Flare (as of Oct. 2013) Sludge Press Recycle: Jan 1 – Dec 31, 2015 Biogas Pressure (as of Feb. 2013) Lagoons Effluent Flowrate: Jan 1 – Dec 31, 2015 Lagoons Influent Flowrate (as of Nov. 2013) –

The manual records used in 2015 as inputs to the GHG calculations were checked during the verification according to the sampling plan (Appendix D). Kelly Parker, B.Sc. from Blue Source prepared the Project documentation and emission reduction calculations under the direction of Tooraj Moulai. Project Meters The list of key project meters and their maintenance and calibration requirements is provided in Table 4, page 51 of the Offset Project Plan. As noted in the Offset Project Plan, several of the project meters do not require calibration according to the manufacturer. These include the vortex meter for biogas flow rate to the boiler, the magnetic flow meters for the inlet and outlet flow rates from the anaerobic lagoons and the sludge press recycled wastewater. Emails from the manufacturers confirming this were provided. The flare thermal mass flow meter requires periodic calibration and the report of the most recent calibration completed on Sept. 24, 2012 was reviewed.

8.5. ISSUES IDENTIFIED DURING VERIFICATION Based on the review of the GHG emission reduction calculations, Offset Project Report, and sampling of records, the following issues and discrepancies were identified and followed up on through the course of the verification:

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Table 8-3 Verification Issue Log # Type Description Status 1 qualitative Data quality issues with electronic records from See Findings – automated project monitoring system (Proficy) such as Table 11-1 negative values, outliers, and some long runs of duplicate values for the following project parameters: lagoon influent flow rate, biogas flow rate to boiler, biogas temperature & pressure, and biogas to flare flow rate. 2 qualitative Data quality issues with manual records such as See Findings – transcription errors, illegible writing for the following Table 11-1 project parameters: BOD, sludge press recycle, effluent, biogas analysis. 3 documentation Clearly state the data sources of emission reduction Addressed calculation inputs: automated vs manual entries in operator logs. 4 quantitative No lagoon venting recorded during Feb-May is suspect. Confirmed Please double-check venting logs. 5 quantitative Incorrect venting pipe ID of 12" should be 10". Addressed 6 quantitative Error in venting mass flow rate equation. Update Addressed calculation method for new manual vents installed in 2015. 7 documentation Some project meter changes need to be reflected in Addressed project documentation. 8 documentation General updates and editorial corrections required in Addressed project documentation. 9 quantitative Increase frequency of biogas moisture testing to assess See Findings – effect of moisture content on emission calculations (wet Table 11-1 biogas flow rate times dry-basis biogas analysis data).

It was noted that there is a of uncertainty in the venting emission calculations as a venting occurrence is recorded by operators performing as recorded in the Anaerobic Lagoon Pressure Relief Vent Monitoring Report. The need to initiate venting by manually opening a vent valve is indicated to the operators by the height of the lagoon covers. If cover heights become unsafe, and the biogas demand from the boiler cannot lower the cover height, then venting is initiated and the start and stop dates/times are recorded. Therefore, there is a human factor element involved. This uncertainty is acknowledged by the Protocol which states on page 38 for P17 Biogas Venting: “Venting emissions are not normally practical to measure, therefore estimation is reasonable.”. The venting calculation method was updated for the 2015 vintage year and the rather complex calculations based on Bernoulli’s theorem and friction losses were checked and confirmed. An uncertainty factor of 30% is applied and this adds conservativeness to the calculations.

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9. SAMPLING PLAN

The Final Sampling Plan is provided in Appendix D, section D.7.

10. VERIFICATION SCHEDULE

The verification schedule is summarized as follows: • Verification Planning: November 20, 2015 – December 2, 2015 • Project site visit: December 3, 2015 • Detailed Verification review: January 4 – March 29, 2016 • Peer Review: March 30-31, 2016 • Submit Peer-Reviewed Verification Report to Blue Source: March 31, 2016 • Address comments on the Verification Report: April 5, 2016

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11. VERIFICATION FINDINGS

Based on the verification review of the emission reduction offset credits generated for the 2015 vintage year, no evidence of material discrepancy was identified. The Project Report and associated GHG Assertion were found to be reliable, complete and in compliance with the requirements of the Specified Gas Emitters Regulation . Material Discrepancies • No evidence of qualitative or quantitative material discrepancies was identified. Immaterial Discrepancies • The following quantitative and qualitative immaterial discrepancies were identified:

Table 11-1 Final Summary of Unadjusted Differences (SUD) Table Issue Type Description Effect on GHG Log # Assertion

1 Qualitative A Corrective action identified in the AEP Audit of Indeterminate the Project in 2012 is partially complete. Transfer of data collection from manual to the SCADA system was due to be completed by June 2013. The following manual monitored parameters were outstanding in 2015:

• Lagoons Effluent Flowrate • Sludge Press Recycle • Biogas temperature – manual records used for Jan 2015 1 Qualitative Numerous data quality issues were identified in the Indeterminate project electronic records obtained from the SCADA system. This indicates improved internal QA/QC is needed on electronic records prior to verification to identify data outliers and duplicate records. 2 Qualitative Numerous instances of transcription errors were Indeterminate discovered in reviewing the records that were input manually. This indicates improved internal QA/QC is needed on manual records prior to verification as well the need for operators to write legibly when completing log sheets. 9 Quantitative Any residual moisture remaining in the biogas after Indeterminate at conditioning will affect the calculations that use the this time. biogas %CH 4 and HHV reported on a dry basis from the biogas analysis reports. Only a single analysis was completed in January 2016, indicating a small moisture content of 0.21% by volume.

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Opportunities for Improvement • The project venting emission calculation is complex and has inherent uncertainties. Consider reliable estimation methods such as: o Since the duration of each venting event is recorded, use this value and the measured biogas flow rate to the boilers (say a few days before and after each venting event) to estimate the volume of biogas vented; or o equip each vent outlet with a mechanical rotating vane cumulative rpm meter or other flow measurement device either temporarily to determine typical vent flow rates at different lagoon heights, or permanently.

12. CONFIRMATIONS

Confirmations are beyond the scope of the verification, but are activities AEP requires verifiers to perform during the verification. Confirmations determine whether the information reported in the greenhouse gas assertion are accurate. The following project information was confirmed: • consistency of offset project information across offset project documentation • offset project location and any applicable approvals information • offset project contact, report dates, emission reduction numbers • completeness and accuracy of process and data flow diagrams

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13. STATEMENT OF VERIFICATION

April 5, 2016 Alberta Environment and Parks (AEP) Climate Change Secretariat 12th Floor, Baker Centre 10025 – 106 Street , Alberta T5J 1G4 Scope ClearSky Engineering Inc. has reviewed the Greenhouse Gas (GHG) Emission Reduction Assertion prepared by Blue Source Canada ULC (authorized project contact) on behalf of Cargill Meat Solutions (project owner). The subject of the verification was the assertion of GHG emissions reductions associated with the Project for the period from January 1, 2015 to December 31, 2015 as described in “Cargill High River Methane Capture Project, Offset Project Report”, version 1.0, April 2016. The Project generates GHG offsets from the capture of biogas containing methane for fuel use that would have been released to the atmosphere from the anaerobic treatment of wastewater. Blue Source is responsible for the preparation and fair presentation of the information within the Offset Project Report and the GHG Assertion in accordance with the requirements of the Alberta offset system under the Specified Gas Emitters Regulation (SGER) . Cargill Meat Solutions is responsible for the operation of the Project and the implementation of Project data monitoring and collection controls to enable the preparation of GHG Assertions that are free from material misstatement. Our responsibility is to develop a conclusion with a reasonable level of assurance as to whether the GHG Assertion is free from material misstatement, and is fairly presented in accordance with the Quantification Protocol for Anaerobic Treatment of Wastewater Projects, March 2009, and the program requirements of the Alberta offset system under the SGER Methodology Our review was completed in accordance with ISO 14064 Part 3 – Greenhouse Gases: Specification with guidance for the validation and verification of greenhouse gas assertions , and AEP Technical Guidance. We planned and performed our work in order to provide reasonable assurance with respect to the GHG emission reduction information we reviewed. Our verification criteria were established based on guidelines approved by AEP. We believe our work efforts provide an acceptable basis for our conclusion. GHG Assertion The GHG Assertion states that for the period of January 1, 2015, to December 31, 2015, the Project resulted in GHG emission reductions of 70,284 tonnes CO 2e. Conclusion Based on our work, it is our opinion at a reasonable level of assurance that the GHG Assertion presented in the Offset Project Report, version 1.0, dated April 2016 prepared by Blue Source for the Cargill High River Methane Capture Project is materially correct and presented fairly and accurately in accordance with the SGER program criteria.

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Klym Bolechowsky, P.Eng. Principal, Lead Verifier ClearSky Engineering Inc. Okotoks, Alberta

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REFERENCES

Blue Source Canada ULC, “Cargill High River Methane Capture Project, Offset Project Report”, version 1.0, ‘Cargill WWT OPR_v1.0_03262016.docx’, April 2016 Blue Source Canada ULC, “Cargill High River Methane Capture Project, Offset Project Plan”, Final Report, version 3.0, ‘Cargill OPP_v3.0_03262016.docx’, April 2016 Blue Source Canada ULC, “GHG Emission Reduction Calculator”, ‘Cargill_WWT_VY2015_v0.10_20160324.xlsx’ AEP, “Carbon Offset Emission Factors Handbook”, Version 1.0, March 2015 AEP, “Quantification Protocol for Anaerobic Treatment of Wastewater Projects”, March 2009 AEP, “Technical Guidance for Offset Project Developers”, Version 4.0, February 2013. AEP, “Template: Alberta Offset System, Offset Verification Report”, Version 2, February 2013 AEP, “Template: Alberta Offset System, Offset Project Report”, Version 3, February 2013 AEP, “Template: Alberta Offset System, Offset Project Plan”, Version 3, February 2013 AEP, Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance. Version 1.0, January 2013 Government of Alberta, Climate Change and Emissions Management Act , 2003 Government of Alberta, Specified Gas Emitters Regulation , 2007 ISO, “ISO 14064 Part 3 – Greenhouse Gases: Specification with guidance for the validation and verification of greenhouse gas assertions”, 2006

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APPENDIX A: STATEMENT OF QUALIFICATIONS

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Statement of Qualifications

The statement of Qualification must demonstrate that the qualifications of the third party verifier meets or exceed the qualifications stated in Section 18 of the Specified Gas Emitters Regulation (SGER) . The qualification requirements as stated in Section 18 are provided below along with our qualifications addressing each:

SGER Requirements for Third Party ClearSky Engineering Inc. Qualifications Verifiers 18 (1) A person is eligible to be a third party The Lead Verifier, Klym Bolechowsky, P.Eng., auditor under this Regulation if the person is a Professional Engineer registered with (a) is APEGA under the Engineering and Geoscience (i) registered as Professions Act , with technical expertise (A) a professional engineer under the related to the project sector. Engineering, Geological and Geophysical Professions Act, or The Verification Report will be peer reviewed (B) a chartered accountant under the by Kurt J. Hansen, M.Sc., P.Eng., a Regulated Accounting Profession Act, Professional Engineer registered with APEGA under the Engineering and Geoscience (ii) a member of a profession that has Professions Act substantially similar competence and practice requirements as a profession referred to in subclause (i) (A) in a province or territory of Canada, or (B) approved by the director, in a jurisdiction outside of Canada,

(b) has technical knowledge of (i) specified gas emission quantification (i) specified gas emission quantification methodologies: The Lead Verifier, Klym methodologies, Bolechowsky, P.Eng., of ClearSky (ii) audit practices, and Engineering Inc. has detailed technical (iii) any other matters considered relevant by knowledge of GHG emission quantification the director, methodologies, the Alberta GHG Offset and System, and verification experience related to (c) has any other qualifications that the wind-powered electricity generation. Relevant director considers necessary. experience includes:

• Alberta Environment Audit of GHG Offset projects, 2010: 3 wind farms, 1 landfill gas capture project • Offset Project Verification of Wind Energy Offset Project 2009-2013 • CCEMC Validation of Renewable Energy GHG Offset Project, 2011 • SGER Compliance Report Verification Reviews for Gas Plants, Refinery, 2008-14 • Alberta Environment Audit of 4 major electricity generation facilities which included participation of the Auditor General of Alberta, 2008

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(ii) audit & assurance practices: Klym Bolechowsky is intimately familiar with audit and assurance practices in accordance with ISO 14064 Part 3. He has his Certificate of Completion for the CSA GHG Verification Using ISO 14064 three day training course. Klym was retained by SAIT Polytechnic as a subject matter expert to develop a 40 hour ISO 14064 GHG Quantification & Verification training course to prepare participants for ISO certification. Course development was completed June 2011. He has presented papers on GHG verification procedures at recent conferences including the Air & Waste Management Association conference in Calgary on June 24, 2010 and the EPA Emission Inventory Conference in Baltimore, MD, Apr. 15, 2009. He has worked on two AEP SGER Audits, one in collaboration with Grant Thornton Chartered Accountants who provided valuable insight into audit and assurance procedures for GHG verification work. (2) A person is not eligible to be a third party The verifier is eligible to conduct a verification auditor for a facility if review for the offset project as defined by the (a) that person is the person responsible for regulation and can demonstrate freedom from the facility or is a director, officer or any conflict of interest related to Blue Source employee of the person responsible for the and Cargill as documented in the Conflict of facility or of an affiliate, within the meaning Interest Checklist, Appendix B. of section 2 of the Business Corporations Act, of the person responsible, or (b) the person is an employee or agent of the Government.

Signed: ______Date: April 5, 2016

Klym Bolechowsky, P.Eng. Principal, Lead Verifier ClearSky Engineering Inc.

City, Province: Okotoks, Alberta

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APPENDIX B: CONFLICT OF INTEREST CHECKLIST

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Question Yes No

1. Can the verifying organization or the verification team members directly benefit from a financial interest in the Project Developer or the Project Developer’s Project?

For example: • Owning share of the Project Developer; √ • Having a close business relationship with the Project Developer; • Contingent fees relating to the results of the engagement; • Potential employment with the Project Developer; or • Undue concern about the possibility of losing the verification or other fees from the Project Developer.

2. Can the verifying organization or verification team members be in a position of assessing their own work?

For example: • Provided greenhouse gas consultation services to the project; • Provided validation for the project √ • If providing non-greenhouse gas work for the company, consideration needs to be given as to how potential and perceived conflict of interests can be managed. • A member of the verification team was previously employed with the company

3. Does the verifying organization or a member of the verification team, or a person in the chain of command for the verification, promote or be perceived to promote, a project developer's position or opinion to the point that objectivity may, or may be perceived to be, compromised?

For example: √ • Dealing in, or being a promoter of, greenhouse gas credits on behalf of a project developer; or • Acting as an advocate on behalf of the project developer in litigation or in resolving disputes with third parties.

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Question Yes No

4. Is one or more of the verification team too sympathetic to the project developer's interests by virtue of a close relationship with a project developer, its directors, officer or employees?

For example:

• A person on the verification team has a close personal relationship √ with a person who is in a senior greenhouse gas compilation role at the project developer; or

• The verification team or a person of influence on the verification team has accepted significant gifts or hospitality from the project developer.

5. Is a member of the verification team or a person in the chain of command deterred from acting objectively and exercising professional skepticism by threats, actual or perceived, from the directors, officers or employees of the Project Developer?

For example:

• The threat of being replaced as a third party verifier due to a disagreement with the application of an greenhouse gas √ quantification protocol;

• Fees from the project developer represent a large percentage of the overall revenues of the verifying organization.

• The application of pressure to inappropriately reduce the extent of work performed in order to reduce or limit fees; or

• Threats of litigation from the project developer.

Signed: ______Date: April 5, 2016 Klym Bolechowsky, P.Eng. Principal, Lead Verifier ClearSky Engineering Inc.

City, Province: Okotoks, Alberta

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APPENDIX C: PEER REVIEW

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Green Inc. 612 Dalmeny Hill NW, Calgary, AB, T3A 1T6 ph +1 403.398.3981, cell +1 403.472.0406, [email protected]

5 April 2016

Klym Bolechowsky ClearSky Engineering Inc. 221 Drake Landing Lane, Suite 1 Okotoks, Alberta T1S 2M4

RE: GI Peer Review of ClearSky Third-Party Verification Report to Cargill; High River Methane Capture Offset Project; 2015 GHG Emission Offset Report by Blue Source Canada

Dear Klym,

Green Inc. (GI) has reviewed ClearSky 5 April 2016 verification report (and supporting information) on the subject matter and understands that a peer review is a required part of verification under the Alberta Specified Gas Emitters Regulation, and clearly understands that the review process requires that persons different from those who undertook the fieldwork perform a final evaluation of the evidence and conclusions of the verification team.

The peer review of GI did not discover any deficiencies in the verification approach and 5 April 2016 report statements and information regarding the Blue Source-asserted and Cargill-reported 2015 GHG emission offsets associated with the facility.

Should you require additional information please contact me.

Yours truly

Kurt J. Hansen, President, M.Sc., P. Eng. Green Inc., Calgary e-mail: [email protected]

APPENDIX D: VERIFICATION PLAN

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D. VERIFICATION PLAN

D.1. SCOPE & OBJECTIVES In accordance with the Specified Gas Emitters Regulation (SGER) , ClearSky Engineering Inc. has been engaged by Blue Source Canada ULC (Blue Source) to conduct a verification of the Cargill High River Methane Capture Project for the 2015 vintage year. Alberta Environment and Parks (AEP) has outlined the key requirements of the verification plan in their document entitled “Technical Guidance for Greenhouse Gas Verifications at Reasonable Level Assurance”, Version 1.0, Jan. 2013, and these elements are addressed in the following sections of this Verification Plan.

The objective of the verification is to provide AEP with assurance that the Offset Project Report accurately represents the greenhouse gas (GHG) emission reductions associated with the project and that the process is being carried out in accordance with the SGER and the Technical Guidance documents. The scope of the verification is offsets generated in 2015.

D.2 LEVEL OF ASSURANCE The verification will be conducted at a reasonable level of assurance per the requirement of the SGER.

D.3 MATERIALITY Quantitative discrepancies are considered material if they exceed 5% of the total reported GHG emission reductions or removals asserted.

D.4 VERIFICATION STANDARDS The verification process will be based on the following standard as required by the SGER: ISO 14064 Part 3 – Greenhouse Gases: Specification with guidance for the validation and verification of greenhouse gas assertions Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January, 2013

D.5 VERIFICATION CRITERIA Verification criteria are the benchmarks or comparison standards to which the verifier compares the GHG offset assertion and supporting evidence. The verification criteria for this review include: • Climate Change and Emissions Management Act • Specified Gas Emitters Regulation • Quantification Protocol for Anaerobic Treatment of Wastewater Projects, March 2008 • Technical Guidance for Offset Project Developers, Version 4.0, February 2013 • Carbon Offset Emission Factors Handbook, Version 1.0, March 2015 • Template: Alberta Offset System, Offset Verification Report, Version 2, February 2013

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• Template: Alberta Offset System, Offset Project Report, Version 3, February 2013 • Template: Alberta Offset System, Offset Project Plan, Version 3, February 2013

D.6 RISK ASSESSMENT A risk assessment identified areas where we will focus our efforts. Three categories of risk were assessed:

• Inherent Risk – the likelihood of a material error, omission, or misrepresentation because of inherent challenges in the subject matter

• Control Risk – the likelihood that the organization’s control procedures will fail to prevent, detect, or correct an error or omission

• Detection Risk – the risk that the procedures applied by the verifier do not detect a misstatement in the GHG assertion. There is an inverse relationship between the inherent and control risks, and the detection risk. If the inherent and control risks are high, the verifier must design and perform procedures that result in a low detection risk so that the overall verification risk is low.

The risk assessment was conducted during the planning stage and finalized during the execution phase of the verification and is summarized in the following table:

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Risk Assessment & Verification Procedures Line Item Attributes Inherent Risk Control Risk Detection Risk Verification Procedure Design GHG Assertion Completeness Medium – 1st Medium – manual Medium Conduct a site tour to view all Level Accuracy verification, and automated emission sources and compare Protocol is under records with inventory review due to identified risks. Detailed checking of manual records for transcription errors, check QA/QC procedures

Check all emission factors

Recalculate emission reductions Baseline - Fuel Occurrence Low – minor source Low – data collected Highest Check source of emission factors Extraction and Completeness determined by by SCADA system Processing (B1) Accuracy simple calculation and lab analysis Cut-off reports Classification Baseline - Thermal Occurrence Medium – Equiv. Low – data collected Higher Check lab analysis reports in Energy Generation Completeness natural gas volume by SCADA system detail and unit conversion (B3) Accuracy calculated based on and from lab analysis factors in calculations Cut-off well documented reports Classification parameters Baseline - Anaerobic Occurrence Medium – many Medium – mix of Medium Detailed review of manual BOD Wastewater Completeness parameters involved manual and records, manual sludge press Treatment Process Accuracy in calculation, some automated data recycle flow rates, manual (B7) Cut-off manual data collection effluent flow rates. Ensure that Classification collection, largest equations from the protocol are contributor to applied properly. Check year to baseline emissions. year variation. However, protocol acknowledges uncertainty.

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Project - Fuel Occurrence Low – insignificant Low – data collected Highest Check source of emission factors Extraction and Completeness source determined by SCADA system Processing (P1) Accuracy by simple and from lab analysis Cut-off calculation reports Classification Project – Facility Occurrence Medium – Low – data collected Higher Check lab analysis reports in Thermal Energy Completeness automated data by SCADA system detail and unit conversion Generation (P3) Accuracy capture of biogas and from lab analysis factors in calculations Cut-off volume, uncertainty reports Occurrence about final moisture content Project – Biogas Occurrence High –largest High - uncertainty Lowest Review daily venting reports, Venting (P17) Completeness contributor to due to human check calculation in detail. Accuracy project emissions, element to data Check year to year variation. Cut-off complicated collection Occurrence calculation Project – Biogas Occurrence Low – conditioning Medium – many Higher Check equipment list against Conditioning (P18) Completeness equipment is all pieces of equipment equipment in use during the site Accuracy electric and power involved makes visit. Cut-off ratings are changes harder to Occurrence documented detect Project – Biogas Occurrence Medium – Low – flow data Higher Review flow rates and check for Flaring (P19) Completeness automated data collection is outliers. Check pilot fuel Accuracy capture of flow rate automated emission calculation in detail. Cut-off but highly variable Occurrence source. Pilot fuel volume calculation based on limited data.

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A contribution analysis was conducted to assess the relative contribution of each line item to the overall GHG assertion. This was useful in the risk assessment phase to focus in on priority line items.

Contribution Analysis, 2015 TOTAL % of Total Baseline Emissions t CO2 t CH4 t N2O tCO2e (tCO2e) % of Baseline Offset B1 Fuel Extraction & Processing 901.36 17.62 0.05 1,356 1.2% 1.9% SS B3 Facility Thermal Energy Generation 13,338.82 0.25 0.22 13,412 11.9% 19.1% B7 Anaerobic Wastewater Treatment Process 3,908.86 97,722 86.9% 139.0% ALL 14,240 3,927 0.27 0 112,489 100.0%

TOTAL % of Total Project Emissions t CO2 t CH4 t N2O tCO2e (tCO2e) % of Project Offset P1 Fuel Extraction & Processing 0.89 0.02 0.00 1.34 0.0% 0.0% P3 Facility Thermal Energy Generation 93.21 0.16 2,378.16 5.6% 3.4% SS P17 Venting of Biogas 1,550.01 38,750.34 91.8% 55.1% P18 Biogas Conditioning 525.48 525.48 1.2% 0.7% P19 Biogas Flaring 37.09 20.25 0.02042 549.33 1.3% 0.8% ALL 38 1,663 0.18 525 42,205 100.0%

TOTAL Emissions Offset Credits Created t CO2 t CH4 t N2O tCO2e (tCO2e) ALL 14,202 2,263 0.09 -525 70,284 20.21% 80.50% 0.04% -0.75% 100.00%

D.7 SAMPLING PLAN Based on the risk assessment and contribution analysis, raw data and records for the following will be sampled: • Biogas methane content and HHV – 100% of lab analysis reports

• BOD IN , BOD OUT – 100% of manual records and check outliers • Effluent flow rate – 100% of manual records and analyze electronic records to identify outliers and duplicates • Sludge Press Recycle flow rate – 100% of manual records and analyze electronic records to identify outliers and duplicates • Biogas temperature – 100% of manual records and analyze electronic records to identify outliers and duplicates • Anaerobic Lagoon Pressure Relief Vent Monitoring Report – 100% of manual records • Any additional automated records from data historian – plot graphs and analyze records to identify outliers and duplicates

D.8 VERIFICATION PROCEDURES The subject matter pertaining to this verification is described in the Quantification Protocol for Anaerobic Treatment of Wastewater Projects . The verification will employ substantive procedures consisting of analytical tests and tests of detail - inspection of facility, documents, and inquiry. The verification procedures are described previously in the Risk Assessment table. The verification process will also include the following procedures:

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• Confirmation of ownership of offset credits • Inspect the facility and interview project staff • Obtain copies and review manual records for biogas system and wastewater treatment • Review the emission factors utilized in the calculations and compare to source publications to ensure appropriate factors are utilized. Recalculate emission reductions. • Assess the data management system during the site visit • Obtain copies of Blue Source QA/QC checklists Details on data storage procedures (hard copy and electronic) and record of on-site document retention time • Minimum experience requirements for operators in charge of the project and monitoring and evidence of competency (resume, education, training) A thorough understanding of the GHG Offset Project drives the verification approach. The verification process will commence with gaining an understanding of the entity, business and industry by reviewing the Offset Project Report and background information provided. The review of these items will then direct the area of focus for the site visit, and the assessment of the GHG quantification method and accuracy of emission reduction calculations. The review of the data management system will assess how the inputs to the offset credit calculation are determined and will consist of discussions with project management and review of project documentation and records. A description of the data management system and controls is included in the main body of the verification report.

The objective of the verification is to provide reasonable assurance that the emission reduction calculations are reasonable and not materially misstated. A positive statement of verification will be issued if there is sufficient and appropriate evidence to support the GHG assertion at a reasonable level of assurance. A reasonable assurance conclusion is a positive factual statement that says the GHG emission reduction assertion is correct.

D.9 SITE VISIT The site visit was completed on December 3, 2015 at the Cargill Meat Processing Plant located in High River, AB. Safety requirements for the site visit include: hard hat, semi sealed eyewear, CSA safety boots.

D.10 VERIFICATION REPORT A verification report will be prepared summarizing procedures and findings. Detailed documentation of the verification process will be maintained and described in the final verification report. The documentation will include a description of activities during the verification, notes on the methodology and calculation review, notes from the site visit, and a detailed description of any findings and observations. A Statement of Verification will be prepared and signed by the Lead Verifier. A signed Conflict-of-Interest checklist and Statement of Qualification will also be provided.

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D.11 VERIFICATION SCHEDULE The verification schedule is summarized as follows: • Verification Planning: November 20, 2015 – December 2, 2015 • Project site visit: December 3, 2015 • Detailed Verification review: January 4 – March 29, 2016 • Peer Review: March 30-31, 2016 • Submit Peer-Reviewed Verification Report to Blue Source: March 31, 2016 • Address comments on the Verification Report: April 5, 2016

D.12 VERIFICATION TEAM The verification team will include the following members: Klym Bolechowsky, P.Eng., ClearSky Engineering Inc. (Project Manager, Lead Verifier, Designated Signing Authority) Kurt Hansen, M.Sc., P.Eng., Green Inc. (Peer Reviewer)

Klym Bolechowsky, P.Eng. – Lead Verifier

Mr. Klym Bolechowsky, as Project Manager and Lead Verifier, will be the main contact with Blue Source & Cargill. Klym is a registered Professional Engineer in the province of Alberta and is an experienced Third-Party Verifier having completed numerous verification projects under the SGER. He has his Certificate of Completion for the CSA GHG Verification Using ISO 14064 three day training course. He has twenty years of experience in the air quality field both as a consultant and in industry. Prior to ClearSky Engineering Inc., he provided air quality consulting services at Levelton as the Manager of the Environmental Studies Group in the Environment & Energy Division. Some of his recent projects relevant to GHG offset project verification and biogas capture include: • 2009 AEP Audit of the Clover Bar Landfill Gas Capture Offset Project at the City of Edmonton Landfill Reference Contact : Renée Levesque, Environmental Portfolio Specialist, Capital Power Corporation, (403) 717-4607, [email protected] • 2009-2013 Annual GHG Offset Project Verification for Nexen Soderglen Wind Farm Reference Contact : Tom Rudd, Team Lead – Gas and Power Operations, Nexen Energy ULC, (403) 699- 4536, [email protected] • 2011, 2012 SGER Compliance Report Verification, Power Biomass Plant Reference Contact : Erwin Karst, Plant Manager, Whitecourt Power LP (780) 778- 3334, [email protected]

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• 2008 – 2011 SGER Compliance Report Verification for Suncor Edmonton Refinery Reference Contact : Dan Burt, Climate Change Management Specialist, Suncor, (403) 296-5009, [email protected] • 2011 CCEMC Validation of Renewable Energy GHG Offset Project – Nexen Hand Hills Wind Power Project Reference Contact : Bryan Clake, President, Joss Wind Power Inc., (403) 984-9463, [email protected] • 2011 SGER Peer Review of Enhanced Oil Recovery Offset Project Verification

His additional verification experience includes: • 2009 Alberta Environment Audit of GHG Offset projects: three wind farms and a landfill gas capture project. • 2007 Alberta Environment Audit of four major electricity generation facilities which included participation of the Auditor General of Alberta • 2011 - 2014 GHG Compliance Report Verification for ENMAX Calgary Energy Centre Power Plant • 2012 - 2014 Baseline Application for ENMAX Crossfield Energy Centre • 2012 - 2014 SGER Compliance Report for Inter Pipeline Fund Cochrane Extraction Plant • 2012 - 2014 SGER Compliance Report Verification for Cancarb Carbon Black Plant, • 2012 - 2014 Baseline Application for Methanex Methanol Plant • 2011 - 2014 GHG Compliance Report Verification for City of Medicine Hat Power Plant • 2011 - 2013 GHG Compliance Report Verification for Canadian Fertilizers Ltd. including Baseline Restatement • 2009 - 2013 GHG Compliance Report Verification for Suncor Hanlan Robb Gas Plant including 2011 Baseline Restatement • 2010 - 2013 GHG Compliance Report Verification for Direct Energy’s Wildcat Hills Gas Plant • Developed a 40 hour ISO 14064 GHG Quantification & Verification training course for SAIT Polytechnic to prepare participants for ISO certification Klym has presented papers on GHG verification at the following recent conferences: • Air & Waste Management Association conference in Calgary on June 24, 2010: http://www.clearskyeng.com/docs/AWMA_GHG_Presentation.pdf • EPA Emission Inventory Conference in Baltimore, MD, April 15, 2009: Paper: http://www.epa.gov/ttn/chief/conference/ei18/session7/bolechowsky.pdf

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Presentation: http://www.epa.gov/ttn/chief/conference/ei18/session7/bolechowsky_pres.pdf

Association of Professional Engineers and Geoscientists of Alberta (APEGA) member #: 95630 ClearSky Engineering Inc. APEGGA Permit to Practice #: P11255

Kurt Hansen, M.Sc., P.Eng. – Peer Reviewer

Mr. Hansen is a Professional Engineer licensed in Alberta since 1977 who will serve as Senior Peer Reviewer due to his extensive environmental engineering and GHG verification experience. Kurt has 42 years of environmental service experience in environmental impact assessment (EIA/EA), air quality assessment, emission inventories and GHG verification including life cycle analysis. He has provided SGER Senior Peer Review Services to ClearSky Engineering Inc. for the past seven years. Kurt has provided inventorying, estimation (including sampling & material balancing) and forecasting of various types of emissions and wastes (regulatory listed substances (SGER, NPRI, ARET and NERM), SO 2, NO x, THC/VOC, PAHs and metal oxide emissions; GHGs; CFCs, HCFCs and halons; and oil and gas industry cartridge filters) to assist various industry and government clients in developing policies for air shed management, emission limits, GHG management, refrigerant recycling and waste specific management options, or undertake ambient air quality assessments by means of plume dispersion modelling and health and ecological risk assessments. He has provided estimation, forecasting, and verification of GHG emissions associated with current and proposed facilities in the power, oil sands, conventional oil and gas, petrochemical industries, and operating GHG emission offset projects (a composting facility and wind farm). He has also undertaken work related to critical reviews of reported emissions, parts of a technology verification protocol, life cycle analysis and annual verification reports required by the Alberta SGER. Recently, he has assisted an energy company with streamlining CEMS data collection, computations, digital reporting and quality assurance plans for two sour gas processing plants. He has also executed basic engineering design regarding municipal (and food processing) wastewater treatment plant designs.

D.13 PRELIMINARY VERIFICATION PLAN & SITE VISIT AGENDA

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Preliminary Verification Plan & Site Visit Agenda Cargill Methane Capture Project – 2015

Site Visit Date: Thursday, December 3, 2015 Location: Cargill Plant, High River, AB Start Time: 1:00 pm (or sooner depending on when FBB review is completed)

Objective: Assess the GHG Emission Reduction Assertion for consistency with the Specified Gas Emitters Regulation and the Offset Project Plan Scope: 2015 vintage year offset credits: Jan. 1, 2015 – Dec. 31, 2015 to be described in the Offset Project Report Verification Standard: ISO 14064-3 Level of Assurance: Reasonable

Attendees Verifier: Klym Bolechowsky, ClearSky Engineering Inc. Blue Source: Kelly Parker, Carbon Services Project Analyst Cargill: Dale Paton, Environmental Superintendent; Michael Bernardo, Environmental Supervisor; others

Introductions & Safety Orientation

Site Orientation & Operational Overview • Review schematic, site layout, and project boundaries • Overview of the project and the methane capture process • Overview of project GHG emission sources

Information Request (some to be completed after 2015 year-end) • 2015 Offset Project Report • 2015 GHG Emission Reduction Calculator • Project raw data, electronic records and scanned manual records, monthly inspection reports for the integrity of the lagoon covers and vents

Questions • Any significant project changes in 2015? • Any correspondence from Alberta Environment or Offset Registry? • Status of conversion from manual records to Proficy? Transition dates? • Did sediment removal occur in 2015? • Any residual moisture remaining in biogas after conditioning? Lab analysis for moisture content?

221 Drake Landing Lane, Suite 1 Tel: 403.982.5596 Okotoks, Alberta Email: [email protected] Canada T1S 2M4 www.ClearSkyEng.com

Site Tour • View methane capture system from inlet to outlets including lagoons, membrane, biogas conditioning system, boiler, sludge recycle • View flare and propane pilot fuel supply • View project meters/monitoring: biogas volume to boilers, biogas volume flared, biogas pressure & temp., wastewater flow rate in/out of lagoons, flow rate of sludge press wastewater, inlet BOD concentration • View lab, lab standard applied for project lab analyses

Data Management • Obtain 2015 calibration records or certificates for above meters • Overview of project data collection and flow to Cargill environmental staff and Blue Source • Training requirements for key personnel

GHG Emission Reduction Calculations • Blue Source provides overview of draft 2015 GHG calculator (or 2014 GHG calculator) and methods • Review key sections of the Offset Project Plan • Review any excluded sources/sinks deemed negligible

Verifier reviews notes for approx. ½ hour then wrap-up

221 Drake Landing Lane, Suite 1 Tel: 403.982.5596 Okotoks, Alberta Email: [email protected] Canada T1S 2M4 www.ClearSkyEng.com