Apache Zama Battery 12 Enhanced Oil Recovery Project / #8806-0274 March 2018

Verification Report for: Apache Zama Battery 12 Enhanced Oil Recovery Project / #8806-0274

Proponent: Bluesource ULC.

Prepared by: RWDI Air Inc.

Prepared for: Paramount Resources Ltd.

Version: Final

Date: March 7, 2018 Apache Zama Battery 12 Enhanced Oil Recovery Project / #8806-0274 March 2018

Table of Contents 1.0 Summary – Offset Project ...... 4 1.1 Summary – Facility – not applicable ...... 7 2.0 Introduction ...... 9 2.1 Objective ...... 10 2.2 Scope ...... 10 2.3 Level of Assurance ...... 12 2.4 Criteria ...... 13 2.5 Materiality ...... 13 3.0 Methodology ...... 13 3.1 Procedures ...... 14 3.2 Team ...... 17 3.3 Schedule ...... 18 4.0 Results ...... 18 4.1 Assessment of Internal Data Management and Controls ...... 18 4.2 Assessment of GHG Data and Information ...... 19 4.3 Assessment against Criteria ...... 21 4.4 Evaluation of the GHG Assertion ...... 23 4.5 Summary of Findings ...... 23 4.6 Opportunity for Improvement ...... 29 5.0 Closure ...... 29 5.1 Verification Statement ...... 29 5.2 Limitation of Liability ...... 30 5.3 Confirmations ...... 30 6.0 References ...... 31 Appendix A: Final Verification Plan and Sampling Plan ...... 32 Appendix B: Statement of Qualifications...... 34 Appendix C: Findings and Issues ...... 36 Appendix D: Statement of Verification ...... 38 Appendix E: Conflict of Interest Checklist ...... 40 Appendix F: Supplemental Diagrams/Tables/Figures ...... 43

List of Tables Table 1: Detailed Scope ...... 11 Table 2: Verification Procedures ...... 15 Table 3: Recalculation of Emissions Reduction ...... 21 Table 4: Offset Criteria Assessment ...... 22 Table 5: Summary of Findings ...... 24 Table 6: Summary of Confirmations ...... 30 Table 7: Detailed Findings and Issues Log ...... 54 Instructions are in italics throughout and should not be deleted when report is complete. Some instructions are specific to the verification of facilities and for offset projects. The document is not restricted but do not alter the format, the layout, the headings or the overall ‘look and feel’ of the document. If if is more usefule to paste information outside of the text box, use the empty line just below the text box to drop text or tables int. This should not change the headings or the formats. There are several dropdown boxes in the document that must be completed. • Complete report in Verdana 10pt font (no italics).

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• After the report is complete, right click the table of contents and ‘update field’ which will update page numbers in Table of Contents. • If an instruction only applies to facilities or only applies to offsets indicate ‘not applicable’. • Appendix F is available for additional tables, diagrams etc.

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1.0 Summary – Offset Project

Item Description

Project Title Apache Zama Battery 12 Enhanced Oil Recovery Project Enter project title (must match the registry project title)

Project Description The Project involves the injection of acid gas from the Zama Gas Plant for Provide a brief description of the project permanent geological sequestration as part and baseline conditions. of an enhanced oil recovery (EOR) scheme. Prior to the Project, the acid gas from the plant was treated with a sulphur recovery Claus unit, and the tail gases were incinerated. Baseline emissions resulted from the combustion of the tail gas, venting of formation CO2 in the tail gas, and the use of fuel gas in the processes. The project results in GHG emissions reductions from the geological storage of carbon dioxide contained in the acid gas as part of the EOR.

Project Location The Zama Battery 12 Enhanced Oil Recovery Project is located approximately Include the latitude and longitude for each 875 km northwest of , . unique location or installation. Include legal land location if applicable and other Legal Land Location: 00/14-12-116-6W6 information identifying the unique location. Latitude: 59° 03' 57" N Longitude: 118° 52' 16" W

Project Start Date December 1, 2004 Enter the project start date.

Offset Start Date December 1, 2004 Enter the start date for offset credit generation.

Offset Crediting Period The initial Project crediting period was for 8 years, starting December 1, 2004 and Enter the offset crediting period, including ending November 30, 2012. On February the offset start date. Include day, month 12, 2013, Alberta Environment and Parks year. (AEP) (AESRD at the time) granted an extension period, from December 1, 2012 to November 30, 2017.

Reporting Period January 1, 2015 – November 30, 2017

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Enter the reporting period being verified.

GHG Assertion (Actual Emission GHG assertion is 23,790 Tonnes of carbon Reductions/Sequestration Achieved) dioxide equivalent (t CO2e) for the period of January 1, 2015 – November 30, 2017. Enter the actual emissions reductions / sequestration for the reporting period. Enter serial numbers if available

Protocol Quantification Protocol for Enhanced Oil Recovery – Streamlined, Version 1.0, Indicate the relevant protocol (if applicable) October 2007.

Ownership Paramount Resources Ltd. is the sole owner of the assets and project in the Zama oil Enter offset project owner. field.

Project Activity This project meets the requirements for offset eligibility as outlined in Section 3.1. State how the project activity meets the of the Technical Guidance for Offset Project eligibility requirements Developers version 4.0 (AEP. 2013). In particular: 1. The project occurs in Alberta. 2. Project actions are not required by law and are beyond business as usual and sector common practices1. 3. Actions taken on or after January 1, 2002. 4. The Project is real, demonstrable, and quantifiable – this was verified according to the appropriate verification standards and criteria. 5. Project has clear established ownership – Paramount Resources Ltd. is the owner and operator of the facility and EOR Project. 6. Project will be counted once for compliance purposes - The Project offset credits are serialized on the Alberta Emission Offset Registry (AEOR). Credits created have not been and will not be created, recorded or registered in more than one trading registry for the same time period.

1 Emission reduction estimates are based on a government approved quantification protocol, which indicates that the activity is undertaken by less than 40% if the industry. Thus it is not considered to be common practice for the sector. Page 5 of 44 Apache Zama Battery 12 Enhanced Oil Recovery Project / #8806-0274 March 2018

7. The project is implemented according to a government-approved quantification protocol (as noted above).

Project Contact Project Developer: Enter contact name, company name, Trevor Dillabough mailing address, phone number and email Paramount Resources Ltd. address. 2800, 421 7th Ave SW , AB, T2P 2S5 Phone – (403) 817-5158 Email – [email protected] Project Proponent: Tooraj Moulai Bluesource Canada ULC 1605, 840 7th Ave SW Calgary, AB, T2P 3G2 Phone – (403) 262-3026 (ext 259) Email – [email protected]

Verifier RWDI AIR Inc. Verifier name, verifier’s company name, 1000, 736 8th Ave SW, address, phone number email etc. Calgary, AB, T2P 1H4 Phone – (403) 232-6771 Email - [email protected]

Verification Team Members Lead Verifier - Joyce Funk, M.Sc., P.Eng. RWDI AIR Inc. Include verification team members, roles, training, training dates and qualifications. Completed Greenhouse Gas Verification Using ISO 14064 Training, January 21-23, 2014, Certificate No. 0000447902. P.Eng. Member No: 77693, Expires: November 30, 2018 Peer Reviewer - Alena Saprykina, M.Sc. Senior Scientist, RWDI AIR Inc. Completed Greenhouse Gas Verification Using ISO 14064 Training, January 21-23, 2014, Certificate No. 0000448155. Project Manager – Candace Bell, M.Sc., RWDI AIR Inc.

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Supporting Verifier / Field Verifier – Jyotsna Kashyap, M.Sc., RWDI AIR Inc. Verifier in training – Thana Boonlert- Mounarath, EIT, RWDI AIR Inc.

Designated Signing Authority Joyce Funk, M.Sc., P.Eng. RWDI AIR Inc. Enter the designated signing authority for this verification.

Verification Strategy The strategy was to use almost entirely substantive testing in order to avoid relying Describe the verification strategy used for on the design and operating effectiveness the verification, including rationale for the of internal controls; however, controls- approach. Note, if a controls reliance is based testing was used to assess the used, provide justification for how the accuracy and completeness of primary project is able to support this approach. data, where original records were not available or not amenable to substantive testing, by inquiring about QA/QC procedures around the data.

1.1 Summary – Facility – not applicable

Item Description

Facility Name and Company Name List company name and facility name.

Facility Description Provide a brief description of the facility.

Baseline Emissions Intensity Description List the approved BEIA and the baseline years.

Reporter Contact Enter contact name, company name, mailing address, phone number and email address.

GHG Assertion

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Enter the actual emissions, production, emissions intensity and the reduction target being verified.

Verifier Verifier name, verifier’s company name, address, phone number email etc.

Verification Team Members Include verification team members, roles, training, training dates and qualifications.

Designated Signing Authority Enter the designated signing authority for this verification.

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2.0 Introduction Provide an introduction to the facility or project, the verification, and the background. For Offset Project: summary of offset project baseline, changes to the baseline since project start date and summary of changes at the project since the offset project start date or baseline period. For Facilities: Description of compliance or baseline report, facility/project boundary, facility identification information, GHG historical performance, summary of changes since the baseline or since the last compliance report.

RWDI AIR Inc. (RWDI) was retained by Bluesource Canada ULC (Bluesource) to provide third party verification services for the Apache Zama Battery 12 Enhanced Oil Recovery Project owned by Paramount Resources Ltd. and located in Zama City, Alberta. The subject of the verification is the assertion of GHG emissions reductions associated with the offset project for the period January 1, 2015 – November 30, 2017, for submission to the Alberta Emissions Offset Registry under the Carbon Competitiveness Incentive Regulation – Alberta Regulation 255/2017. Prior to the Project, acid gas from the Zama gas plant was treated with a sulphur recovery Claus unit, and the tail gases were incinerated. Baseline emissions mainly resulted from the combustion of the tail gas, venting of formation CO2 in the tail gas, and the use of fuel gas in the various Baseline processes. The Project involves the injection of acid gas from the gas plant for permanent geological sequestration as part of an EOR scheme. Project emissions mainly result from the use of compressors to aide in transporting the gas to the gas plant, flaring, and the use of fuel gas in the various Project processes. The acid gas that was previously being treated and incinerated, is being sequestered under the Project under the EOR scheme. This results in a reduction of emissions in the Project, with respect to the baseline. There are a number of changes in the reporting period, with respect to when the Project started. These include: 1. The Project owner, Apache Canada Ltd. was acquired by Paramount Resources Ltd. in 2017, and Paramount is now the sole owner. 2. There has been a decline in acid gas production from the gas plant. This resulted of lower amounts of “new” acid gas being injected for EOR production while recycled acid gas volumes have been relatively consistent enabling continued EOR operations. This resulted in a significant drop in emissions reductions during the reporting period. There has been significant reorganization at the gas plant and battery, eg. Plants 2 and 3 were merged to become Plant 4 at the gas plant, and there was a redistribution of equipment including compressors. 3. There has been a decline in acid gas production from the gas plant. This resulted of lower amounts of “new” acid gas being injected for EOR production while recycled acid gas volumes have been relatively consistent enabling continued EOR operations. This resulted in a significant drop in emissions reductions during the reporting period. 4. The grid electricity consumption factor used in calculating P12 and P14 has been updated from the Carbon Offset Emission Factors Handbook. 5. The method for obtaining compressor utilizations used in calculating P12 and P14 has been updated.

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6. Reference to B3a venting was removed from the reporting period since there were no venting emissions calculated in the baseline. 7. In previous reporting periods, multiple sales gas analyses were used to determine one average natural gas combustion emission factor. In this reporting period, the natural gas

combustion CO2 emission factor was determined over the 35 month reporting period; averages of daily factors were calculated for each month, and applied to the calculations for each month.

8. Previously, the solution gas combustion CO2 emission factor was based on one gas analysis report per year. For this reporting period, the emission factor was calculated based on daily acid gas analyses; daily average emission factors were calculated; these were averaged for each month, and the averaged monthly factors were applied to the calculations for each month. 9. An EOR allotment to the high and low pressure flares onsite at the conventional battery are accounted for. 10. An updated Sulphur Experts Sulphur Recovery Unit Simulation Report was obtained for the reporting period, dated Feb 2018. 11. Data from new dilution gas meters FQI-4110 and FQI-1530 were incorporated into the GHG calculations. 12. The hydrogen component in the tail gas has been included in determining the lower heating value (LHV) of the tail gas. 13. The 2007 International Panel on Climate Change (IPCC) updated Global Warming Potentials were used. 14. Shack heaters present at the injection sites were included into the emissions inventory.

2.1 Objective Describe the objective of the verification (should include expressing an opinion).

The objective of this verification was to provide an opinion with a reasonable level of assurance to AEP as to whether the greenhouse gas emissions reduction assertion is free from material misstatement, and is presented fairly in accordance with the program criteria.

2.2 Scope Define the scope in terms of: geographical, organizational, activities and processes, sources, sinks, categories and greenhouse gases included (considering the completeness of the inventory), GHG assertion time period. For offset verifications: include the serial range (i.e. XXXX-XXXX-XXX-XXX-XXX-XXX to XXXX- XXXX-XXX-XXX-XXX-XXX) if assigned (i.e. in the case of government verification a serial range will be available, otherwise not applicable). For Facilities: ensure all specified gases and source categories are evaluated. Include list of negligible emission sources and justification for Emission Performance Credits (EPCs). Include listing of end products.

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This verification assessed the operations and equipment associated with the Project as well as all calculations and supporting information used to quantify the GHG emissions reduction assertion for the period January 1, 2015 – November 30, 2017. The detailed scope is provided in Table 1.

Table 1: Detailed Scope

Scope Description

Geographical Scope The geographical scope for this verification was established as the Apache Zama Battery 12 Enhanced Oil Recovery Project, located approximately 875 km northwest of Edmonton, Alberta. Legal Land Location: 00/14-12-116-6W6 Latitude: 59° 03' 57" N Longitude: 118° 52' 16" W

Organization Scope Paramount Resources Ltd. is the sole owner of the Project.

Activities and Processes Operations/processes/equipment at the Project include: • Two electric compressors at the gas plant and three natural gas compressors at the battery compress a combined stream of acid gas that comes from the plant and the oil field. • The combined stream travels via pipeline to various sites for acid gas injection for the purpose of enhanced oil recovery. • In the case of planned or unplanned shutdowns, acid gas is flared through the EOR compressor flare at the battery, with dilution fuel gas mixed in. • EOR sources contribute to gas that is flared through the high and low pressure flares on site at the plant. • There are shack heaters at the injection well sites.

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Scope Description

Sources and Sinks, Categories Baseline Emissions: B2a Flaring at Capture Site - Emissions from the combustion of tail gas and make-up fuel gas that would go to incinerator under baseline conditions (hydrocarbon flaring). B13 Fuel Extraction and Processing - Emissions that would occur upstream of the facility under baseline conditions that are associated with the extraction and processing of the fuel gas that would be used by the incinerator under baseline conditions.

Project Emissions: P12 Injection Gas Transportation - Emissions associated with the operation of electric compressors that power the transportation of acid from the plant. P14 Injection Unit Operation - Emissions associated with the operation of natural gas compressors that power the acid gas injection process. P15 Flaring at Injection Site - Emissions associated with the operation of natural gas compressors that power the acid gas injection process. P21 Fuel Extraction and Processing - Emissions that occur upstream of the project that are associated with the extraction and processing of the fuel gas used by project- related equipment (compressors and flares).

Emissions Scope CO2, CH4, N2O included in assertion; however, we also consider any potential emissions of SF6, HFCs, and PFCs during our assessment of completeness.

GHG Assertion Time Period January 1, 2015 – November 30, 2017

2.3 Level of Assurance The verification was conducted to a reasonable level of assurance. Choose type of verification from the dropdown box above.

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Provide explanation on level of assurance.

Achieving the overall objective of this verification involved executing verification procedures designed to generate evidence that is sufficient and appropriate to provide a basis for our opinion with a reasonable level of assurance. Reasonable-level assurance is required by AEP for the purposes of the Carbon Competitiveness Incentive Regulation CCIR. It is a positive, but not absolute form of assurance that the responsible party’s greenhouse gas assertion is materially correct.

2.4 Criteria Outline the program criteria used and relevant supporting documentation (acts, regulations, protocols, standards, guidance documents, project documentation etc).

Generating sufficient and appropriate evidence to support our opinion involves executing verification procedures that assess the assertion against the following criteria: • Climate Change and Emissions Management Act; • Carbon Competitiveness Incentive Regulation – Alberta Regulation 255/2017; • Standard for Greenhouse Gas Emission Offset project developers – Version 1.0 – December, 2017; • Standard for Verification Carbon Competitiveness Incentive Regulation – Version 1.0 – December, 2017; • Quantification Protocol for Enhanced Oil Recovery - Streamlined – Version 1 – October, 2007; • Carbon Offset Emission Factors Handbook, Volume 1.0 (AEP, March 2015); and • ISO 14064 Greenhouse gases - Part 2: Specification with guidance at the project level for quantification, monitoring and reporting of greenhouse gas emission reductions or removal enhancement, ISO, April 2006 (ISO 14064-2)*. *Should any discrepancies exist between ISO and regulatory criteria, the regulatory criteria shall take precedence.

2.5 Materiality Define the materiality of the verification.

In accordance with AEP criteria, the threshold used to determine the materiality of combined misstatements on the overall assertion of 5% of total emissions reductions.

3.0 Methodology Statement that the verification is performed according to ISO 14064-3. Summary of the assessments/tests/reviews/evaluations that were conducted during the verification.

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The verification will be conducted in accordance with: • Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance – Version 1.0; • ISO 14064-3:2006 Greenhouse Gases Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions*; and, • ISO 14065:2013 Greenhouse Gases: Requirements for greenhouse gas validation and verification bodies for use in accreditation of other forms of recognition*. *Should any discrepancies exist between ISO and regulatory criteria, the regulatory criteria shall take precedence.

Verification Plan The final verification plan has been attached in Appendix A. In developing the plan, a verification strategy was established, a detailed risk assessment was carried out, and a sampling plan with accompanying verification procedures was developed. Some of the essential elements of the plan are presented in this section.

Verification Strategy The verification strategy shapes the overall approach of the verification by specifying the type of verification procedures to be used. It affects the verification and sampling plan by defining the level of testing that will be substantive versus the level that will be controls-based. Development of the verification strategy is informed by the output of the risk assessment process, which includes an assessment of the effectiveness of the responsible party’s data management systems and internal controls. For this verification, the strategy was to use almost entirely substantive testing in order to avoid relying on the design and operating effectiveness of internal controls; however, controls- based testing was used to assess: The accuracy and completeness of primary data, where original records were not available or not amenable to substantive testing, by inquiring about QA/QC procedures around the data.

3.1 Procedures Description of how the verification was conducted including: description of the nature, scale and complexity of the verification activity, confidence and completeness of the responsible party’s GHG information and assertion, assessment of GHG information system and its controls, assessment of GHG data and information, assessment of GHG information system and controls, assessment against criteria, evaluation of the GHG assertion. Describe steps of the verification including planning, assessment, site visit, off-site verification, and report preparation. Describe how the risk based approach was implemented in the sampling plan. Identify categories of risk including inherent risk, and detection risk (organization and verifier). Include the Verification Plan with the Sampling Plan in Appendix A. Paste the risk assessment table in this section.

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Verification procedures Verification procedures are described in detail in the Verification Plan with the Sampling Plan in Appendix A. This section describes how the verification strategy and verification plan were executed through two main components: A site visit; and, Desktop review These activities involved carrying out substantive and controls-based tests (i.e., verification procedures) as shown in Table 5A of the Verification Plan of Appendix A. Site Visit In accordance with Section 3.6.5 of AEP’s Technical Guidance for Greenhouse Gas Verifications at Reasonable Level Assurance – Version 1.0 – January, 2013, site visits are a mandatory component of verifications. The site visit was relied upon within the verification strategy to gain understanding of the plant’s operations, processes and equipment as well as the data management systems used to track the data used for the purposes of GHG reporting. One of the most important aspects of the site visit was to test the completeness of the GHG emissions inventory through inspection of emissions sources on-site. The site visit consisted of visiting the Paramount Zama City office, the Zama gas plant and Battery 12, and the Paramount Calgary office. The site visit was conducted by Jyotsna Kashyap and Thana Boonlert-Mounarath of RWDI on February 8 and 9, 2018 in Zama City, and February 22, 2018 in Calgary. RWDI coordinated the site visit directly with Paramount staff. The Field Operations Lead facilitated the office visit and site tour in Zama City, and a member of the Production Operations department coordinated the Calgary office visit. The detailed site visit notes are saved in Appendix F. Desktop Review As shown in Table 2, verification procedures executed during the desktop review were split into three categories: Emissions Estimates & Primary Data and Records and Data and Information Management & Controls. Table 2: Verification Procedures

Category Verification Procedures

Emissions Estimates & Primary Data and Assess completeness of the GHG inventory in Records terms of sources and sinks and appropriateness of inventory boundaries; Estimate or judge emissions for sources deemed to be negligible; Check that the methodologies used to estimate emissions are consistent with AEP technical guidance; Check that the methodologies used to estimate emissions are appropriate;

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Check that emissions calculations were performed correctly; Check the availability and reliability of primary data and records; Test the assertion through inquiry, observation, inspection, Re-performance, analytical procedures, re- calculation, tracing, and vouching; and, Test data for extreme high/low values, spurious values, values recorded during periods of sensor malfunction or downtime, and systematic abnormalities.

Data and Information Management & Review the data management system to Controls assess whether it is reliable and transparent; Review the flow of data and information to assess whether it is validated, version controlled and backed-up; Assess whether monitoring instrumentation used to generate primary data is maintained and calibrated to an appropriate standard; Evaluate the appropriateness of the standards and procedures implemented and their ability to ensure the accuracy of the information provided; Review relevant quality assurance records; and, Assess retention of relevant data and information and availability of historical data.

Risk Assessment In the context of greenhouse gas assurance, risk assessments involve assessing the risk that the emissions report presented to the intended user (i.e., the assertion) contains material misstatements and/or has not been prepared in accordance with program criteria. RWDI uses a two-tiered risk assessment process: assertion-level risk assessment and source-level risk assessment. The results of our assertion-level risk assessment are presented below. Further details including the rationale for the assigned risk levels are provided in Table 2A of the Verification Plan that has been attached in Appendix A. Risk Category Risk Level Verification Risk Low Inherent Risk Medium Control Risk Medium Allowable Detection Risk Low

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Source Level Risk Assessment The second tier of RWDI’s risk assessment process is a source-level risk assessment. This step involves assigning a level of risk to each emissions source that has been included in the inventory in order to inform the design of an effective sampling plan and prioritize verification efforts. Assignment of risk levels is based on the following risk calculation: Risk = probability of misstatement x impact of misstatement For the purpose of the risk assessment, risk is a calculated value ranging from 1 to 15, probability is a value from 1 to 3 assigned based on the inherent and control risks affecting the source, and impact is a value from 1 to 5 assigned based on the source’s contribution to total emissions. The inherent and control risks affecting each source are determined based on a review of source contributions as well as the data management systems and controls related to each source. The results of the source-level risk assessment are presented in Table 4A of Appendix A. Further details, including rationales for the assigned risk levels, are provided in Tables 3A and 4A of the Verification Plan that has been attached in Appendix A. Sampling Plan Based on the risk assessment, the verification team designed an initial sampling plan that targeted areas of elevated risk. The initial sampling plan was modified as needed throughout the verification process when issues were identified or new information was obtained. The resulting final sampling plan, including details of the verification procedures carried out, is presented in Table 5A of the Verification Plan that has been attached in Appendix A. Reporting The verification report for the Apache Zama Battery 12 Enhanced Oil Recovery Project for the period January 1, 2015 – November 30, 2017 was performed using Draft Verification Template provided by AEP.

3.2 Team List verification team members including peer reviewer(s). Describe the qualifications and training of the team members and peer reviewer(s) including dates of training and certifications. For Offsets: fill in the sample Statement of Qualification provided and included in Appendix B. For Facilities: include the Statement of Qualifications from the facility compliance form in Appendix B.

Lead Verifier - Joyce Funk, M.Sc., P.Eng. RWDI AIR Inc. Completed Greenhouse Gas Verification Using ISO 14064 Training, January 21-23, 2014, Certificate No. 0000447902. P.Eng. Member No: 77693, Expires: November 30, 2018

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Peer Reviewer - Alena Saprykina, M.Sc. Senior Scientist, RWDI AIR Inc. Completed Greenhouse Gas Verification Using ISO 14064 Training, January 21-23, 2014, Certificate No. 0000448155. Project Manager – Candace Bell, M.Sc., RWDI AIR Inc. Supporting Verifier / Field Verifier – Jyotsna Kashyap, M.Sc., RWDI AIR Inc. Verifier in training – Thana Boonlert-Mounarath, EIT, RWDI AIR Inc.

Statement of qualification is included in Appendix B.

3.3 Schedule Provide a list or table of verification activities and dates. Indicate when the verification was completed.

The verification has been completed at the time of writing this report. Kickoff meeting with Bluesource – January 23, 2018 Initial Verification Plan sent to Bluesource – February 8, 2018 Conduct Site Visit in Zama City – February 8 - 9, 2018 Conduct Office Visit in Calgary – February 22, 2018 Verification – February 23 - March 1, 2018 Peer Review – March 4 - 5, 2018 Draft Report and Verification Statement – March 7, 2018 Final Report and Verification Statement – March 7, 2018

4.0 Results Add introduction to results section here, if desired.

Our assessment of the GHG information management system and the results of our independent recalculation of emissions are presented below. These sections are followed by a summary of the non-compliances and opportunities for improvement, as well as any other relevant limitations or uncertainties that were identified during the verification and remain unaddressed. A complete list of errors, omissions, misstatements or non-compliances identified during the verification is provided in the Issues Log in Appendix C.

4.1 Assessment of Internal Data Management and Controls Provide a summary the information system(s) and its controls for sources of potential errors. Include information on the selection and management of data, process for collecting and consolidating data, data accuracy systems, design and maintenance of the GHG system, the systems and processes that support the GHG information system and results from previous assessments if applicable.

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Bluesource Canada is the project proponent that provides GHG consulting services and creates the emission calculation spreadsheet and Offset Project Report. Paramount is ultimately responsible for collection, storage and the data management of the primary data used for the GHG calculations. Eg. Paramount is responsible for tracking operations, activity data and measured data (e.g., metered gas volumes, gas compositions, compressor power and fuel usage). Paramount provides this information and other primary data to Bluesource for processing and use in GHG offset credit calculations. The outsourcing of the preparation of the GHG report results in less involvement by Paramount personnel in terms of defining the GHG inventory boundaries and verifying completeness and accuracy/relevance of primary data. There are certain risks associated with this team structure; with the change of Project ownership from Apache to Paramount Resources Ltd. in 2017, there is some additional risk due to different staff at Paramount taking over the responsibility of providing Bluesource with the primary data. However, Bluesource has consulted on the project since it started in 2004. Thus, the risk is managed with the experience and consistency from the Bluesource personnel. Acid gas and fuel gas volumes are metered onsite, and acid gas compositions are measured by gas chromatographs (GCs). There’s automatic data capture from the onsite meters and GCs, and the data is available in SCADA. The metered data from SCADA is transfered into Avocet (the data is compatible with Avocet, and the transfer occurs electronically). The GC data is sent by the field operators to Avocet support personnel and they enter it into Avocet. Production operations staff gathers the metered flow volumes and acid gas compositions from Avocet, and provide it to Bluesource. Sales gas analyses are obtained from TCPL; these compositions are also used for production accounting, and the production accounting staff share the data for the purpose of using it in the GHG reporting. Compressor utilization (i.e. % engine utilization) is tracked in Compressor Productivity Optimization (CPO) software; these data are available through the Productivity Optimizer Gas Emissions Detailed Report. CPO data in combination with runtime hours and Caterpillar engineering estimates result in final compressor energy usage. Irregular operations are tracked in flare spreadsheets onsite so there is a log of events in case the data need to be reviewed. QA/QC checks are in place at Paramount. Production operation staff checks the meter data that is dumped into Avocet, and also the GC data, which is sent from the field. The field operations lead checks the flare spreadsheets onsite and provide any additional information/clarification to Calgary staff who have questions about any anomalous data. There is a system to add notes when any bad data is identified or modified. Once Bluesource obtains all of the primary activity data, they transfer the data to the emissions calculator. Bluesource completes an internal senior staff review of data quality and accuracy in order to identify any transcription errors, omissions or calculation errors and maintains signed QA/QC records. Bluesource has its own internal QA/QC procedures. Overall, the GHG data management system is organized and mostly complete. Bluesource developed the GHG data management system since the projects started. Thus, the GHG data management system appears to be robust with the experience and consistency from the Bluesource personnel and the project participant.

4.2 Assessment of GHG Data and Information Provide a summary of the information found during the verification of the GHG data and a summary of the GHG Assertion that was assessed. For Facilities: Confirm that the quantification methodologies that were used in the compliance report are the same as those reported in the BEIA.

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For Offset Projects: Confirm that the quantification methodologies that were used by the project proponent are the same as those described in the project plan. Indicate which quantification methodologies were used by the project proponent.

One of the verification procedures carried out by the verification team was a recalculation of emissions for all emission sources. These recalculations were based on the quantification methodologies specified in the offset project plan and offset project report, and primary data obtained from Bluesource. This procedure did not directly test the appropriateness of the methodologies used by Bluesource or the quality (e.g., accuracy, completeness) of the primary data. This procedure was a test of the mechanics of the calculations completed by Bluesource (i.e., assuming that methodologies and input data are appropriate, have the calculations been completed correctly). The appropriateness of the calculation methodologies and the quality of the primary data were tested through other procedures as summarized in Table 2. Emissions were recalculated for the following sources: B2a Flaring at Capture Site, B13 Fuel Extraction and Processing, P21 Fuel Extraction and Processing, P12 Injection Gas Transportation, P14 Injection Unit Operation, P15 Flaring at Injection Site. After completing the recalculations, the verification team compared the recalculated results to those reported by Bluesource in their final submitted OPR and GHG quantification calculator. For each source, differences between the recalculated emissions and those calculated by Bluesource have been indicated in Table 3. The recalculated values were compared to the reported data in the final submitted OPR. There were no material differences found. The GHG calculations performed by Bluesource appear to be correct based on the recalculations. The detailed recalculations are saved in Appendix F.

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Table 3: Recalculation of Emissions Reduction

Reported Recalculated Emissions Percent Source Emissions (Tonnes) Difference (Tonnes)

CO2 CH4 N2O CO2e CO2e % B2a Flaring at Capture 52,997 1.39 1.24 53,400 53,398 <0.1% Site B13 Fuel Extraction 2,728 53.34 0.14 4,105 4,104 <0.1% and Processing P2 1 Fuel Extraction 1,365 26.69 0.07 2,054 2,054 <0.1% and Processing P12 Injection Gas 4,995 0.00 0.00 4,995 5,031 0.71% Transportation P14 Injection Unit 19,680 0.35 0.31 19,783 19,761 -0.11% Operation P15 Flaring at Injection 6,832 0.12 0.10 6,866 6,865 <0.1% Site Total Emissions 22,853 27.57 0.89 23,806 23,790 -0.07%2 Reductions

4.3 Assessment against Criteria Provide a description of how eligibility criteria is met or not met. For Offset Project: Complete Table 1 to indicate if the GHG Assertion conforms to the Regulation and Standard for Greenhouse Gas Emission Offset Project Developers eligibility criteria. For Facilities: Delete Table 1 and Indicate if verification criteria are met or not met and explain.

2 The % error in emissions reductions provided in this recalculation summary table accounts for the impacts from the various errors that have been presented in this table as being <0.1%; due to this, it does not match the net emissions reduction error presented below in Section 4.4 and Table 5. Page 21 of 44 Apache Zama Battery 12 Enhanced Oil Recovery Project / #8806-0274 March 2018

Table 4: Offset Criteria Assessment

Offset Eligibility Assessment Criteria

Reduction or The Project is located in Alberta, as described above in Section sequestration 1.0 of this report. occurs in Alberta

Result from actions The Project originates from voluntary action, i.e. the Project not required by activities are not required by law. The Project uses approved Law at the time the AEP quantification protocol, which indicates that the activity is action is taken undertaken by less than 40% of the industry and is therefore not considered to be sector common practice.

Result from Actions The Project began operation on December 1, 2004, i.e. after taken on or after January 1, 2002. January 1, 2002 and occur on or after January 1, 2002

Reduction or The Project is creating real reductions that are not a result of sequestrations is shutdown, cessation of activity or drop in production levels. The real and Project reductions are demonstrable. demonstrable

Quantifiable and This Project and its emission reductions are quantifiable and measureable verifiable as outlined in this report.

Verified by a third The Project was verified by a qualified third-party verifier - party verifier that RWDI Air Inc. meets the requirements in Part 1 for the Standard for Verification.

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4.4 Evaluation of the GHG Assertion The verification assessment is that the GHG Assertion meets the requirements of the Carbon Competitiveness Incentive Regulation Provide an assessment of the evidence collected during the verification. Determine if the data and information available support the GHG assertion. Provide a conclusion on whether the assertion meets the materiality requirements and the level of assurance agreed to at the beginning of the verification process.

In forming our opinion for the final verification statement, the verification findings presented below were evaluated in the context of the evidence collected and generated during the verification process as a whole. To this end, the following factors were taken into consideration: The quantification methodologies, data and supporting documentation used for the offset project are appropriate and reasonably comprehensive and consistent. Paramount and Bluesource personnel were knowledgeable of operations and information management systems and demonstrated competency and care in their work. The net error of the quantitative issues identified is approximately (details for each error are provided in Section 4.5 of this report): Emission Reductions: understated by -0.15% + 0.09% = - 0.06 % The net error of the quantitative issues identified is approximately (details for each error are provided in the Findings Log in Appendix C): January 1, 2015 to November 30, 2017: Net error = - 0.06 % With these considerations in mind, it is our opinion that the non-compliances, opportunities for improvement, and other limitations or uncertainties presented below do not preclude a positive overall finding for this reasonable-level assurance engagement. Furthermore, it is our opinion that the evidence generated during the verification is appropriate and sufficient to support an overall positive finding with a reasonable level of assurance. The verification opinion and verification statement are presented in the following section.

4.5 Summary of Findings Provide a summary of material and immaterial discrepancies expressed in tonnes and as net and absolute error in Table 2. Include whether the discrepancy was an understatement or an overstatement. Include a more detailed description and log of results in Appendix C the “Issues Log”. This log will include both resolved and unresolved issues from the verification. Unresolved issues should be brought forward to Table 2.

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Table 5: Summary of Findings Number the finding with the year and provide a unique # for each finding. Note: A detailed description of all material and immaterial findings should be provided in Table 3 of Appendix C. Provide only a summary statement (1-4 sentences) for each unresolved immaterial finding and each material finding (resolved or unresolved). If the finding is a resolved material finding, then put the tonnes net and absolute in the summary description column and indicate n/a in the net and absolute columns. Do not include the tonnes in the total error calculation. Indicate the type of error (qualitative or quantitative). Indicate the Source Category (for facilities) or the Source/Sink (for offsets). Indicate if the finding is an understatement or overstatement. Provide both net and absolute error in tonnes of CO2 eq and as a % of the assertion. Provide the total net error and the total absolute error in tonnes of CO2 eq and as a % of the assertion.

Result Summary Description of Finding Understatement Tonnes CO2 eq Tonnes CO2 eq Type # Source Category or Source/Sink /Overstatement % net % absolute

The primary sales gas compositional data show small negative values for C7 and C8 components; the data should 15-17: not be included in the analyses. This Impact is less than the tolerable error3 (<0.1%), Accuracy #3 would impact sources B2a: Flaring at Opportunity for Improvement Capture Site, P14: Injection Unit Operation and P15: Flaring at Injection Site.

Daily gas compositions are time- weighted rather than being volume- 15-17: weighted; volume-weighting would be a Impact is less than the tolerable error (<0.1%), Accuracy #4 more accurate method, and could be a Opportunity for Improvement potential opportunity for improvement in the future. This would impact sources B2a: Flaring at Capture Site,

3 Tolerable error is defined in the Verification plan (Appendix A). Page 24 of 44 Apache Zama Battery 12 Enhanced Oil Recovery Project / #8806-0274 March 2018

P14: Injection Unit Operation and P15: Flaring at Injection Site.

CH4 and N2O emission factors for natural gas combustion (from Carbon Offset Emission Factors Handbook table 6, Industrial sources) are used for tail gas, solution gas and acid gas flaring. The CH4 and N2O natural gas 15-17: combustion emission factors may not N/A, Qualitative Discrepancy, Opportunity for Accuracy #5 be the most suitable for tail gas, Improvement solution gas and acid gas, since the different gases have different compositional analysis compared to natural gas. Flaring emission factors are also estimated differently than combustion emission factors.

For the source P12: Injection Gas Transportation, the power usage for compressors K220 and K240 in 2015 is extrapolated based on 2016 & 2017 data, using average HP and acid gas volumes, and an assumption of 24-hour Understatement run-time for the compressors. 15-17: of Project Accuracy Extrapolation using kWh and acid gas -0.15% 0.15% #7 Emissions would be a more realistic method, as it Reductions also accounts for the non-continuous runtime.

This error resulted in an underestimation of emissions reductions by 0.15%

Compressors K210, K430 and K420 are 15-17: Transparency / included in the source P14: Injection N/A, Opportunity for Improvement #8 Accuracy Unit Operation; however, it would be more appropriate to include them under the source P12: Injection Gas

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Transportation. They are located at Battery 12 (i.e. at LSD 14-12) and compress a combined stream of gas that comes from the field and the plant; this streams then goes to the injection sites which are located elsewhere (i.e. LSDs 11-25, 1-13, 4-36, 5-34, 14-32, 5-1).

For the source P14: Injection Unit Operation, the average LHV applied to natural gas heaters is based on LHVs for the entire year; since the heaters are only operational during winter Overstatement of 15-17: months, it would be more accurate to Accuracy Project Emissions 0.09% 0.09% #10 apply an average based on winter months only. Reductions

This error resulted in an overestimation of emissions reductions by 0.09%

Acid gas compositions are not normalized before being used in the 15-17: calculations; this could be a potential Accuracy N/A, Opportunity for Improvement #13 opportunity for improvement in the future. This would impact source P15: Flaring at Injection Site.

The Calculator refers to the ERCB, 15-17: Transparency rather than the AER in the B2a Flaring N/A, Opportunity for Improvement #14 and P15 Flaring tabs.

The Calculator has incorrect units 15-17: Transparency stated in cells I22 and J22 of the Data N/A, Opportunity for Improvement #15 Entry tab.

15-17: Transparency The Offset Project Plan (OPP) is out of N/A, Opportunity for Improvement #16 date and an update would be

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appropriate, for changes in methodology as well as large scale changes that have occurred at the plant and battery 12, eg. the merging of plant 2 and plant 3 to create plant 4, the rearrangement and renaming of compressors, etc.

The Offset Project Report refers to the Project as Apache Zama Battery 12 15-17: Enhanced Oil Recovery. However, the Transparency N/A, Opportunity for Improvement #17 Project Developer is now Paramount Resources Ltd.; the Project name should be updated for transparency.

It was noticed from the SULSUM report pdf diagram, representing the two stage Claus process, that there is an additional tail gas stream that recycles back to the acid gas SRU furnace. However, it appears that the estimated tail gas flow rate used in the emissions calculation includes the recycled portion 15-17: Transparency that is used in the acid gas furnace, N/A, Opportunity for Improvement #18 Thus, it appears that total volume of tail gas is accounted for.

This would be an OFI to segregate the emissions associated with the tail gas incineration and the tail gas used as fuel to combust the acid gas in the SRU furnace.

The formula used to determine the volume of tail gas that would have 15-17: Transparency been sent to incinerator is shown in Cell N/A, Opportunity for Improvement #19 I27, Tab of the calculator. This formula written in the emissions calculator does not match

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the reported calculations and formula listed in the OPR. However, the correct formula was used in the calculator.

Total Error -0.06% 0.24%

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4.6 Opportunity for Improvement Provide feedback on the data management system and controls, transparency, completeness of the inventory, additions to the quantification methodology document or diagrams, etc. Include positive considerations and observations also. Identify strengths and weaknesses that may help to improve the report/s for the current facility, sector, and compliance program. Identify ways in which the project/facility could be more easily verified.

Opportunities for improvement relate to the qualitative findings listed in [Result #3, 4, 5, 8, 13, 14, 15, 16, 17, 18 and 19 as per Section 4.5]. Overall, Paramount and Bluesource demonstrated competency in their work. All information required was provided promptly with detailed explanations. The GHG data management system is organized and mostly complete. Bluesource has developed the GHG data management system for all the Zama Battery 12 Enhanced Oil Recovery Offset Projects since the projects started. Thus, the GHG data management system appears to be robust with the experience and consistency from the Bluesource personnel and its project participants. The GHG calculation spreadsheet was organized and primary data and calculations were traceable. The GHG calculator spreadsheet is designed to reduce chances of error or corruption by color coding cells in the spreadsheet that require user input. Editing of cells can occur; however, the risk that edits occur in error is relatively low because access to the Calculator is limited to Bluesource staff who are familiar with its design. The outsourcing of the preparation of the GHG report results in less involvement by Paramount personnel in terms of defining the GHG inventory boundaries and verifying completeness and accuracy/relevance of primary data. There are certain risks associated with this team structure; with the change of Project ownership from Apache to Paramount Resources Ltd. in 2017, there is some additional risk due to different staff at Paramount taking over the responsibility of providing Bluesource with the primary data. However, since Bluesource has consulted on the project since it started in 2004, the risk is managed with the experience and consistency from the Bluesource personnel.

5.0 Closure 5.1 Verification Statement Include the signed verification statement in Appendix D. Instructions to insert a pdf: 1. Click Insert>Object 2. In the Object dialog box click Create from File and then click Browse. 3. Find the pdf you want to insert then click Insert. 4.Click OK. For Offset Projects: fill in the sample Verification Statement provided, sign, scan and paste. For Facilities: paste a signed version of the Verification Statement from the facility compliance form. Include the conclusion on the GHG assertion and any qualification or limitations and the level of assurance. Provide the verification conclusion in the drop down box below. The verification conclusion is: Positive The verification statement is included in Appendix D.

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5.2 Limitation of Liability Include signed Conflict of Interest Checklist in Appendix E. For Offset Projects: fill in the sample Conflict of Interest Checklist provided, sign, scan and paste. For Facilities: paste the signed Conflict of Interest Checklist from the facility compliance form. Insert limitation of liability statement and include information in an Appendix F if applicable.

The Conflict of Interest Checklist is included in Appendix E. This report has been prepared by RWDI AIR Inc. under and in accordance with its Validation and Verification Program. The contents of this report are strictly confidential and are intended solely to the client. Access to, or distribution of this report by any other party is unauthorized without explicit consent. Any opinions expressed within this report are limited in application to the Industrial Emissions Management program managed by AEP through the Climate Change and Emissions Management Act, and the Carbon Competitiveness Incentive Regulation – Alberta Regulation 255/2017.

5.3 Confirmations Document information confirmed, including any discrepancies or inconsistencies, as per the Confirmations section in the Standard for Greenhouse Gas Verification. Confirmations are activities for verifiers to perform during the verification. Confirmations are conducted to ensure that required data and information in facility reports and application are completed and accurate. The confirmations required by AEP are defined in Section 5.1.3 of the Standard for Verification, Carbon Competitiveness Incentive Regulation – Version 1.0 – December, 2017. During our verification, the confirmation criteria were assessed using suitable verification procedures. A summary is provided below:

Table 6: Summary of Confirmations

Confirmation Criteria Summary of Findings The information regarding the Zama Battery 12 Enhanced Oil Recovery Project has been reviewed for consistency including the following documents: • Offset Project Plan (OPP); Consistency of offset • Offset Project Report (OPR); project information • GHG Assertion (Notice of Creation); across offset project • Site and project permitting documents; documentation • Emissions calculations; and, • Supporting data and information. Information was found to be consistent across the above documents with any changes in calculation/estimation methodologies from OPP clearly defined in OPR. Offset project location Site location was provided by Paramount in Lat/Long coordinates. and any applicable Project location information is included in the OPP, OPR and GHG approvals information

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Assertion and was found to be consistent with our independent review, including site visit. Methodology documents or This documentation exists in the OPP, OPR and supporting electronic procedures manual files. exist Offset project contact, Project contact, report dates, emission reduction numbers are provided report dates, emission in the OPR and found to be complete and consistent with supporting reduction numbers, information that we reviewed as part of our verification. etc. Detailed and simplified process flow diagrams were provided by Completeness and Paramount and Blue Source for our review. The diagrams were found accuracy of process to be reasonably complete and accurate representations of operations and data flow diagrams based on our understanding.

6.0 References Author. Year. Title. (no hyperlinks)

Alberta Environment and Parks (AEP). 2013. Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance – Version 1.0. ISO 14064-3:2006 Greenhouse Gases Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions. ISO 14065:2013 Greenhouse Gases: Requirements for greenhouse gas validation and verification bodies for use in accreditation of other forms of recognition. Government of Alberta. 2017. Climate Change and Emissions Management Act. AEP. 2017. Carbon Competitiveness Incentive Regulation – Alberta Regulation 255/2017. AEP. 2017. Standard for Greenhouse Gas Emission Offset project developers – Version 1.0 AEP. 2017. Standard for Verification Carbon Competitiveness Incentive Regulation – Version 1.0. AEP. 2007. Quantification Protocol for Enhanced Oil Recovery – Streamlined – Version 1.0. AEP. 2015. Carbon Offset Emissions Factors Handbook, No. 1. ISO 14064 Greenhouse gases - Part 2: Specification with guidance at the project level for quantification, monitoring and reporting of greenhouse gas emission reductions or removal enhancement, ISO, April 2006 (ISO 14064-2)*.

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Appendix A: Final Verification Plan and Sampling Plan

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Information to be included in the Verification Plan and Sampling Plan: Revisions to the sampling plan Date originally sent to Facility/project Level of assurance agreed with the facility/project developer Verification scope Verification criteria Amount and type of evidence (qualitative and quantitative) necessary to achieve the agreed level of assurance Methodologies for determining representative samples Sampling Plan and Procedures Risk Assessment: Risks of potential errors, omissions or misrepresentations that are identified throughout the verification process including: - Details of site visit -offset/facility boundaries - Methodologies, emissions factors and conversions used - Comparability with the approved baseline - Conformance to the program criteria - Integrity for the responsible party’s data management system and control (organization chart, GHGH management plan, personnel/consultant training, protocols used, control system documentation, software/program documentation/certifications) - Greenhouse gas data and information, including the type of evidence collected, verification testing and crosschecking, inventory of emission sources - Discussion of data management, (measurement, fuel sampling, calibration, consistent use of standard conditions, data storage, procedures to fill missing data; procedures to repair inconsistent data, adjustment of variables and factors) - Other relevant information

Page 33 of 44 VERIFICATION PLAN

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Date: February 22, 2018

RWDI Reference #: 1802397

Subject: Verification Plan for Paramount Resources Ltd. – Apache Zama Battery 12 Enhanced Oil Recovery Project

Revision: 2

RWDI AIR Inc. (RWDI) was retained by Blue Source Canada ULC (Blue Source) to provide third party verification services for the Paramount Resources Ltd. – Apache Zama Battery 12 Enhanced Oil Recovery Project located in Zama City, Alberta. The subject of the verification is the assertion of GHG emissions reductions associated with the offset project for the period January 1, 2015 – November 30, 2017, for submission to the Alberta Emissions Offset Registry under the Carbon Competitiveness Incentive Regulation – Alberta Regulation 255/2017. This verification plan serves to document the scope and breadth of verification activities being performed.

VERIFICATION SUMMARY

A summary of information relevant to this verification has been provided in Table 1.

Table 1: Verification Summary

General Information

Project Name Apache Zama Battery 12 Enhanced Oil Recovery Project

The Zama Battery 12 Enhanced Oil Recovery Project is located approximately 875 km northwest of Edmonton, Alberta.

Project Location Legal Land Location: 00/14-12-116-6W6 Latitude: 59° 03' 57" N Longitude: 118° 52' 16" W

Authorized Project Contact Blue Source Canada ULC Primary Contact Tooraj Moulai Engineer, Carbon Services [email protected]

Project Description Enhanced Oil Recovery (EOR)

NAICS Code n/a

Alberta Emissions Offset Registry Reporting Program Carbon Competitiveness Incentive Regulation – Alberta Regulation 255/2017

Specified Gas Emitters Regulation Quantification Protocol for Enhanced Oil Quantification Protocol(s) Recovery - Streamlined – Version 1 – October, 2007 VERIFICATION PLAN

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1 GHG Assertion 24,808 tonnes CO2e emissions reduction

Inventory Scope

Reporting Period January 1, 2015 to November 30, 2017

Organizational Boundary Paramount Resources Ltd.

Geographical Boundary Same as project location

All emissions sources and sinks as defined in the protocol within the Operational Boundary organization and geographical boundaries.

CO2, CH4, N2O included in assertion; however, we also consider any

Emissions Scope potential emissions of SF6, HFCs, and PFCs during our assessment of completeness.

Emissions Sources2

SQM Source of Greenhouse Gas Description

Emissions from the combustion of tail gas and make-up n/a B2a Flaring at Capture Site fuel gas that would go to incinerator under baseline conditions (hydrocarbon flaring)

Emissions from the formation of CO2 contained within the n/a B3a Venting at Capture Site acid gas and tail gas that would be vented through the incinerator.

Emissions that would occur upstream of the facility under baseline conditions that are associated with the extraction n/a B13 Fuel Extraction and Processing and processing of the fuel gas that would be used by the incinerator under baseline conditions

Emissions that occur upstream of the project that are associated with the extraction and processing of the fuel n/a P21 Fuel Extraction and Processing gas used by project-related equipment (compressors and flares)

Emissions associated with the operation of electric n/a P12 Injection Gas Transportation compressors that power the transportation of acid from the plant

Emissions associated with the operation of natural gas n/a P14 Injection Unit Operation compressors that power the acid gas injection process

Flaring at: Battery 14-12 high pressure flare, n/a P15 Flaring at Injection Site Tank KO low pressure vent gas flare and EOR compressor flare

Verification Fundamentals

1 This value is based on the initial assertion provided to RWDI; the assertion was later revised to 23,790 tonnes CO2e based on issues identified in RWDI’s verification. 2 These sources are based on the initial Offset Project Report provided to RWDI; the sources were later revised based on issues identified in RWDI’s verification.

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Provide an opinion with a reasonable level of assurance to the Alberta Environment and Parks (AEP) as to whether the greenhouse gas emissions Verification Objective reduction assertion is free from material misstatement, and is presented fairly in accordance with program criteria.

Achieving the overall objective of this verification involves executing verification procedures designed to generate evidence that is sufficient Level of Assurance and appropriate to provide a basis for our opinion with a reasonable level of assurance.

Generating sufficient and appropriate evidence to support our opinion involves executing verification procedures that assess the assertion against the following criteria: Climate Change and Emissions Management Act; Carbon Competitiveness Incentive Regulation – Alberta Regulation 255/2017; Standard for Greenhouse Gas Emission Offset project developers – Version 1.0 – December, 2017; Standard for Verification Carbon Competitiveness Incentive Regulation – Version 1.0 – December, 2017; Program Criteria Quantification Protocol for Enhanced Oil Recovery - Streamlined – Version 1 – October, 2007; The Emission Factors Handbook (March 2015, V1.0); and ISO 14064 Greenhouse gases - Part 2: Specification with guidance at the project level for quantification, monitoring and reporting of greenhouse gas emission reductions or removal enhancement, ISO, April 2006 (ISO 14064-2)*.

*Should any discrepancies exist between ISO and regulatory criteria, the regulatory criteria shall take precedence.

The verification assesses the operations and equipment associated with the project as well as calculations and supporting information used to Verification Scope quantify the greenhouse gas emissions reduction assertion for the period January 1, 2015 – November 30, 2017.

The verification will be conducted in accordance with: Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance – Version 1.0; ISO 14064-3:2006 Greenhouse Gases Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions*; and, Verification Standards ISO 14065:2013 Greenhouse Gases: Requirements for greenhouse gas validation and verification bodies for use in accreditation of other forms of recognition*. *Should any discrepancies exist between ISO and regulatory criteria, the regulatory criteria shall take precedence.

In accordance with AEP criteria, the threshold used to determine the Materiality Threshold materiality of combined misstatements on the overall assertion of 5% of total emissions reductions.

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VERIFICATION Team

The team for this assurance engagement includes:

• Project Manager: Candace Bell, M.Sc., RWDI AIR Inc. • Lead verifier and Signing Authority: Joyce Funk, M.Sc., P.Eng., RWDI AIR Inc. • Verifier: Jyotsna Kashyap, M.Sc., RWDI AIR Inc. • Verifier in Training: Thana Boonlert-Mounarath, EIT, RWDI AIR Inc. • Peer Reviewer: Alena Saprykina, M.Sc., RWDI AIR Inc. VERIFICATION SCHEDULE

To date, RWDI has performed the following verification activities:

• Internal impartiality assessment.

• Initial review of emissions report and supporting documents provided to date.

• Kickoff meeting.

• Risk assessment based on the review of information systems and controls (included herein).

• Sampling plan to verify sources, systems or facilities deemed to have elevated risk of material misstatement (included herein).

The following schedule is proposed for the remaining verification milestones:

• Site Visit February 8, 9 & 22, 2018

• Draft report submitted by March 7, 2018

• Final report and management letter by March 8, 2018

• Close out meeting TBD Site Visit

The detailed information about the site visit were provided in the detailed site visit plan.

H2S Alive training is required prior to arrival on site. The required personal protective equipment on site includes: CSA certified safety boots, Nomex coveralls, hardhats, safety glasses and hearing protection. RISK ASSESSMENT

In the context of greenhouse gas assurance, risk assessments involve assessing the risk that the emissions report (i.e., the assertion) presented to the intended user contains material misstatements and/or has not been prepared in accordance with program criteria. RWDI uses a two-tiered risk assessment process: assertion-level risk assessment and source-level risk assessment.

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Assertion-level Risk Assessment

The first tier of RWDI’s risk assessment process is an assertion-level risk assessment, which establishes the overall level of risk that RWDI is willing to accept on this engagement. This overall level of risk is called the Verification Risk and is related to Inherent Risk, Control Risk, and Detection Risk according to the following:

Verification Risk = Inherent Risk x Control Risk x Detection Risk

The levels of Inherent and Control Risk established after our preliminary review of the responsible party’s GHG information management system and controls inform the level of Detection Risk that we must strive to obtain through our verification strategy and sampling plan in order to obtain the selected level of Verification Risk.

A summary of the assertion-level risk assessment, including details of inherent and control risks is provided in Table 2.

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Table 2: Summary of Assertion-level Risk Assessment

Risk Category Risk Level Discussion

This is the level of risk that RWDI is willing to accept for this particular Verification Risk Low engagement.

• There is a small variety of source types and sources that are commonly encountered in enhanced oil recovery offset projects. Sources and sinks included in the inventory have not changed from the previous few submissions, however this engagement is RWDI’s first since 2014. The sources included in the Offset Project Report (OPR) are consistent with protocol requirements. Justification for excluding any of the sources that are listed in the protocol from the OPR is provided in the Offset Project Plan (OPP). Completeness risk in terms of sources and sinks is considered to be low. Reported gases include CO2, CH4, and N2O. This is consistent with protocol requirements. Completeness risk in terms of specified gases considered is deemed to be low. (Medium) • The methodology and emission factors used are generally based on well established guidance and follow the appropriate quantification protocol and technical guidance documents from AEP. Methodologies require some level of data pre-processing, but the data trail is transparent and traceable. However, there are some methodology changes from previous reports, in how compressor emissions are calculated; these changes were made in Inherent Risk Medium order to increase the accuracy of the calculations. (Medium) • Data systems are organized primarily electronically; however, significant data entry effort to the emissions calculator is required (eg. project gas flows, project compressor data, sulphur simulation analysis data). Primary records are a combination of hard copies and electronic. Copies of primary records are stored centrally in Blue Source files. (Medium) • The inventory boundary includes a single site. There is no integration with other facilities, however operational boundaries between the plant and the battery are not very clearly defined in the documentation. (Medium) • Operations are occasionally subject to unplanned shutdowns; and the temporal scope includes multiple years. (Medium) • Blue Source Canada prepared the OPP, OPR and emissions calculator. Blue Source has substantial experience working with developers on emission offset projects. Responsible staff have several years of experience in GHG reporting and have attended training/information programs. Their primary roles involve regular environmental and sustainability tasks. (Low)

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Risk Category Risk Level Discussion

• The GHG information management system is well-developed and has been in use for several years/reporting periods. All supporting records appear to be readily available. (Low) • Data capture system exists on site; however, some of the data are transferred manually into the calculation spreadsheet. QA/QC procedures are in place at both Paramount and Blue Source, with supporting records available. (Medium) Control Risk Medium • Paramount owns 100% of the enhanced oil recovery/acid gas injection equipment the environmental attributes associated with the project. Ownership and organizational structure is not expected to pose a significant risk. (Low) • There has been turnover in the staff responsible the greenhouse gas inventorying process since the transfer of ownership from Apache to Paramount; however the staff at Blue Source remain the same. (Medium)

• The detection risk was set at low. Therefore, the verification Detection Risk Low strategy and sampling plan have been designed accordingly.

Source-level Risk Assessment

The second tier of RWDI’s risk assessment process is a source-level risk assessment. This step involves assigning a level of risk to each emissions source that has been included in the inventory in order to inform the design of an effective sampling plan and prioritize verification efforts. Assignment of risk levels is based on the following risk calculation:

risk = probability of misstatement x impact of misstatement

Risk is a calculated value ranging from 1 to 15, probability is a value from 1 to 3 assigned based on the inherent and control risks affecting the source, and impact is a value from 1 to 5 assigned based on the source’s contribution to total emissions.

The inherent and control risks affecting each source are determined based on a review of the data management systems and controls related to each source. A summary of this review is provided in Table 3. The risk calculation for each source is documented in Table 4. Detailed Sampling Plan is provided in Table 5.

Tolerable Error

Tolerable Error is the misstatement allowed in a particular category (for each baseline and project source) that would be acceptable to the verifier without needing additional assessment (AEP, January 2013). The conservative value of 0.1% was selected for the overall tolerance percent for all baseline and project sources. The detailed materiality planning is provided in Table 6.

Table 3: Qualitative Notes for Data Management Systems and Controls Emissions Source Emissions Calculations Parameters Data Acquisition Equipment, Sampling Frequency, Analytical Data Processing and Tracking Management Policies and Practices Method Baseline Emission Sources Baseline Source B2a/B3a: Emissions calculations include CO2, CH4, N2O; total CO2e Fuel gas volume consumed at incinerator First, Tail gas volume calculated from acid gas injected that would Metered volumes primary data is tracked in separate spreadsheets Based on the most updated Offset project plan (OPP), March 2013, for Flaring/Venting at Capture Site emissions are calculated using corresponding GWPs; have gone to SRU (metered by FQI_4245; available daily but monthly and the aggregates are manually transcribed to calculator. monitoring and quality assurance purposes, the quantification aggregate used in calcs), times (TG:AG). methods and formulas used in the quantification calculator have been Calculation methodologies provided in AEP's SULSIM report is created based on inputs provided via Blue Source reviewed by the project participants. Quantification Protocol for Enhanced Oil Recovery - TG:AG is ratio of tail gas to acid gas processed by SRU; obtained from (acid gas vols and compositions); SULSIM output data manually Streamlined, Version 1.0, Oct 2007 were followed to SULSIM report. SULSIM uses acid gas analyses and volumes as input. transcribed into calculator. Based on the most udpated OPP, calibration and metering estimate CO2, CH4 and N2O emissions from the maintenance for the meters are performed. A calibration metering flaring/venting emissions from fuels that would have Fuel gas volume is calculated by applying (FG:TG) to tail gas volume. Daily gas analyses primary data is tracked in separate spreadsheets maintenance schedule is provided in the OPP. A detailed QA/QC been used throughout the baseline condition. and monthly aggregates are manually transcribed to calculator. procedure related to storage and security of the metered data is also Calculations are performed using tail gas and make-up FG:TG is the fuel gas to tail gas ratio, calculated from LHVs of fuel gas described in the project plan, and is consistent with interviews with fuel volume that would have been combusted in the and tail gas, which are calculated from the gas analyses, and using the Handbook emission factors are manually transcribed into calculator. field staff during the site visit. absence of the project times emission factors. assumption that flared gas has an LHV of 20 MJ/m3 as per AER Directive 60. Calculations using these data are performed in the calculator. Paramount has QA/QC procedures regarding the GHG primary data - Emissions from the combustion of tail gas and make-up by field operators at the plant/battery in Zama and by various fuel gas that would go to the incinertor under the Sales gas analysis is obtained from TCPL; Daily Volume Energy production operations staff in the Calgary office. There is a system to baseline conditions (hydrocarbon flaring and CO2 Composition Report; available daily but monthly aggregate used in add notes when any bad data is identified and/or modified. venting). calcs. Blue Source has their own QA/QC procedures described in detailed in Fuel gas and tail gas volumes used in the incinerator, Tail gas analysis is from SULSIM report. the project plan. Blue Source staff has much experience in GHG times applicable emission factors. related projects and reporting. The staff are all trained under the ISO Flow volumes and gas compositions are captured through flow meters 14064-2 program. Blue Source also have their own data back-up and Emissions calculations occur in a spreadsheet and GCs. document retention policies which were provided as part of the ("calculator") that was developed by Blue Source. project plan. Blue Source has been using the quantification calculator Tail gas volume consumed at incinerator Tail gas volume calculated from acid gas injected that would have for multiple years, thus this data management system should be gone to SRU (metered by FQI_4245; available daily but monthly robust. aggregate used in calcs), times (TG:AG).

Primary data is stored electronically, systems are automated, data is TG:AG is ratio of tail gas to acid gas processed by SRU; obtained from extracted through a SCADA, Avocet, CPO and spreadsheets, in a form SULSIM report. SULSIM uses acid gas analyses and volumes as input. that is easily transferred to the calculator.

Flow volumes and gas compositions are captured through flow meters and GCs, acid gas analyses are pulled from SCADA.

CO2 emission factors from compositional analysis of fuel Sales gas analysis is obtained from TCPL; Daily Volume Energy gas (plant 4 sales gas), and simulated analysis of tail gas Composition Report; available daily but monthly aggregate used in calculations.

Emission factor is calculated using gas compositions in conjunction with molecular weights of different carbon components (eg. C1, C2, etc.)

Tail gas analysis is from SULSIM report. SULSIM uses acid gas analyses and volumes as input.

Gas compositions are captured through GCs, acid gas analyses are CH4 and N2O emission factors Carbon Offset Emission Factors Handbook, Version 1.0, March 2015, Table 6, "Industrial" Baseline Source B13: Fuel Extraction Emissions calculations include CO2, CH4, N2O; total CO2e Fuel gas volume consumed at incinerator See above in B2a/B3a Fuel gas volume used in B2a/B3a is used in conjuction with applicable See above in B2a/B3a and Processing emissions are calculated using corresponding GWPs; emission factors; calculations are performed in the calculator.

Fuel gas that would have gone to incinerator, times CO2, CH4 and N2O emission factors Carbon Offset Emission Factors Handbook, Version 1.0, March 2015 applicable emission factors.

Calculation methodologies provided in AEP's Quantification Protocol for Enhanced Oil Recovery - Streamlined, Version 1.0, Oct 2007 were followed to estimate CO2, CH4 and N2O emissions from the fuel extraction and processing emissions from fuel gas that would have been used in the incinerator throughout the baseline condition.

Emissions that would occur upstream of the facility under the baseline condidtions.

Fuel gas volumes used in the incinerator, times applicable

Emissions Source Emissions Calculations Parameters Data Acquisition Equipment, Sampling Frequency, Analytical Data Processing and Tracking Management Policies and Practices Method Project Emission Sources Project Source P21: Emissions calculations include CO2, CH4, N2O; total CO2e Compressor fuel gas volumes from P14 See below in P14 Fuel gas volumes used in P14 & P15 are used in conjunction with See above in B2a/B3a Fuel Extraction and Processing emissions are calculated using corresponding GWPs; applicable emission factors; calculations are performed in the calculator. Fuel gas consumed in Project processes i.e. compressors and flares, times applicable emission factors.

Calculation methodologies provided in AEP's Quantification Protocol for Enhanced Oil Recovery - Streamlined, Version 1.0, Oct 2007 were followed to estimate CO2, CH4 and N2O emissions from the fuel extraction and processing emissions from fuel gas consumed in the project processes.

Emissions that occur upstream of the project that are Fuel gas volume for EOR compressor gas flare See below in P15 associated with the extraction and processing of the fuel CO2, CH4 and N2O emission factors Carbon Offset Emission Factors Handbook, Version 1.0, March 2015 d b j t l t d i t ( d Project Source P12: Emissions calculations include CO2e; Electricity consumption Engine utilizations are measured internally in each compressor; Daily utilization is tracked in separate spreadsheets and the See above in B2a/B3a Injection Gas Transportation available daily but monthly aggregate used in calcs; these are aggregates are manually transcribed to calculator (2015 is Electricity consumed by electric compressors, times combined with runtime hours and compressor power ratings; extrapolated based on 2016 and 2017 data). applicable emission factor for CO2e. compressor data comes from CPO, productivity optimization report. Handbook emission factors are manually transcribed into calculator. CO2e emission factor Carbon Offset Emission Factors Handbook Version 1.0, March 2015, Calculation methodologies provided in AEP's Table 2. Quantification Protocol for Enhanced Oil Recovery - Calculations using these data are performed in the calculator. Streamlined, Version 1.0, Oct 2007 were followed to estimate CO2 emissions from the emissions associated with transporting the acid gas to the injection site under the the project conditions..

Emissions associated with the operation of electric Project Source P14: Emissions calculations include CO2, CH4, N2O; total CO2e Fuel consumed by compressors and heaters, propane Fuel consumption is measured internally in each compressor; Daily fuel consumption is tracked in separate spreadsheets and the See above in B2a/B3a Injection Unit Operation emissions are calculated using corresponding GWPs; and electricity consumed by heaters available daily but monthly aggregate used in calcs. Compressor data aggregates are manually transcribed to calculator. comes from CPO, productivity optimization report. Heater fuel use, Fuel gas consumed in natural gas compressors and propane use or electricity use is based on power ratings. Daily gas analyses primary data is tracked in separate spreadsheets heaters, times applicable emission factors; propane CO2 emission factors from compositional analysis of fuel Sales gas analysis is obtained from TCPL; Daily Volume Energy and monthly aggregates are manually transcribed to calculator. consumed by heaters, times applicable emission factors; gas (plant 4 sales gas) and propane emission factor Composition Report; available daily but monthly aggregate used in electricity consumed by heaters, times applicable calculations. Handbook emission factors are manually transcribed into calculator. emission factors. Emission factor is calculated using gas compositions in conjunction Calculations using these data are performed in the calculator. Calculation methodologies provided in AEP's with molecular weights of different carbon components (eg. C1, C2, Quantification Protocol for Enhanced Oil Recovery - etc.) Streamlined, Version 1.0, Oct 2007 were followed to estimate CO2, CH4 and N2O emissions from the Sales gas compositions are captured through GCs but the data in the emissions associated with treating the acid gas to meet calcs is from TCPL, not pulled from SCADA. required specification before being injected into the ground. Propane usage and electricity usage emission factors are taken from CH4 and N2O emission factors Carbon Offset Emission Factors Handbook, Version 1.0, March 2015, Emissions associated with the operation of natural gas Table 6, "Industrial" compressors that compress the acid gas further before it is injected into the zama field.

Emissions calculations occur in a spreadsheet ("calculator") that was developed by Blue Source. Emissions Source Emissions Calculations Parameters Data Acquisition Equipment, Sampling Frequency, Analytical Data Processing and Tracking Management Policies and Practices Method Project Source P15: Emissions calculations include CO2, CH4, N2O; total CO2e Flaring volumes from: From old reports Zama 14-12-116-06W6 TANK FLARE KO GAS & Zama High pressure and low pressure flare volumes are manually See above in B2a/B3a Flaring at Injection Site emissions are calculated using corresponding GWPs; Battery 14-12 high pressure flare & 14-12-116-06W6 FLARE EST in combination with XMD_1047A report transcribed to calculator Tank KO low pressure vent gas flare which provides the EOR fraction. Calculation methodologies provided in AEP's Metered volumes primary data is tracked in separate spreadsheets Solution gas i.e. raw gas volume to EOR compressor flare Total gas to EOR flare is metered (FQI_4101; available daily but Quantification Protocol for Enhanced Oil Recovery - and the aggregates are manually transcribed to calculator. monthly aggregate used in calcs); solution gas volume is calculated by Streamlined, Version 1.0, Oct 2007 were followed to applying (1-FG:SG) to this. estimate CO2, CH4 and N2O emissions from the Daily gas analyses primary data is tracked in separate spreadsheets emissions associated with flaring at the project site. and monthly aggregates are manually transcribed to calculator. FG:SG is the fuel gas to solution gas ratio, calculated from LHVs of fuel gas and solution gas, which are calculated from the gas analyses, and Solution gas flaring from inlet separator/treater and Handbook emission factors are manually transcribed into calculator. using the assumption that flared gas has an LHV of 20 MJ/m3 as per vapor recovery unit (VRU), solution gas flaring from the AER Directive 60; that was in the original version of the OPR; this was tanks and a small volume of acid gas flaring from Calculations using these data are performed in the calculator. later modified to use meter data from FQI-4110 and FQI-1530, based compressor blowdowns. on RWDI findings.

Emissions calculations occur in a spreadsheet Flow volumes and gas compositions are captured through flow meters ("calculator") that was developed by Blue Source. and GCs. Acid gas analyses are pulled from SCADA. Sales gas compositions are captured through GCs but the data in the calcs is Flared gas in Project processes i.e. vent gas, solution gas from TCPL, not pulled from SCADA; TCPL data - Daily Volume Energy and fuel gas, times applicable emission factors. Composition Report; available daily but monthly aggregate used in Fuel gas volume for EOR compressor flare Total gas to EOR flare is metered (FQI_4101; available daily but monthly aggregate used in calcs); fuel gas volume is calculated by applying (FG:SG) to this.

FG:SG is the fuel gas to solution gas ratio, calculated from LHVs of fuel gas and solution gas, which are calculated from the gas analyses, and using the assumption that flared gas has an LHV of 20 MJ/m3 as per AER Directive 60.

Flow volumes and gas compositions are captured through flow meters and GCs. Acid gas analyses are pulled from SCADA. Sales gas compositions are captured through GCs but the data in the calcs is from TCPL, not pulled from SCADA; TCPL data - Daily Volume Energy Composition Report; available daily but monthly aggregate used in CO2 emission factors from compositional analysis of vent Gas compositions are captured through GCs. Acid gas analyses are gas (low pressure flare), solution gas (battery flare), fuel pulled from SCADA. Sales gas compositions are captured through GCs gas (plant 4 sales gas) but the data in the calcs is from TCPL, not pulled from SCADA; TCPL data - Daily Volume Energy Composition Report; available daily but monthly aggregate used in calcs.

Emission factor is calculated using gas compositions in conjunction with molecular weights of different carbon components (eg. C1, C2, t) CH4 and N2O emission factors Carbon Offset Emission Factors Handbook, Version 1.0, March 2015, Table 6, "Industrial" Table 4: Risk Calculations Rank Emissions Source Fuel/Input Type Fuel/Input Amount HHV or Carbon Content Total Emissions (tonnes % of Emissions Inherent Risks Control Risks Risk Calculation

CO2e) 2015 2016 2017 2015 2016 2017 2015 2016 2017 2015 2016 2017 2015 2016 2017 Baseline Emission Sources

1 1 1 Baseline Source B2a/B3a: Flaring/Venting at Tail gas and makeup 7161 e3m3 tail gas + 5815 e3m3 tail gas + 4001 e3m3 tail gas + 0.6613 kg 0.6613 kg 0.6613 kg 22,504.3 18,315.5 12,575.7 92.88% 92.84% 92.87% Medium: Medium: Probability = M x M = 2 Capture Site fuel gas i.e. natural 8627 e3m3 fuel gas 7055 e3m3 fuel gas 4825 e3m3 fuel gas CO2/m3 tail gas & CO2/m3 tail gas & CO2/m3 tail gas & Impact = 93% = 5 gas 2.0409 kg 2.0315 kg 2.0377 kg 'Emissions source is related to moderately complex equipment, 'Emissions calculations rely on data from information management CO2/m3 fuel gas CO2/m3 fuel gas CO2/m3 fuel gas operations or processes that require some technical knowledge to systems that are well-developed and have been in use for over 3 Risk = Probability x Impact = 2 x 5 = 10 out of 15 understand energy/material flows or physical/chemical reactions reporting cycles. (Low) that affect GHG emissions. (Medium) High Risk Emissions calculations rely on information management systems Emissions calculations depend on a moderate number of data the may be unreliable, but have controls in place to manage input parameters. (Medium) reliability. (Medium)

Emissions are calculated using default methodologies and/or Processes for collecting and processing primary data and emission factors consistent with program-specific protocols. (Low) executing emissions calculations are reasonably well-documented with minor gaps or transparency issues. (Medium) Emissions calculations require a moderate level of data pre- processing, but the data trail is transparent and traceable. Data trails between the emissions estimate and the primary data (Medium) may be long, but they are well-documented and traceable. Some QA/QC procedures are in place with some supporting records Staff responsible for acquisition/processing of primary data and available. (Medium) delivery/communication of primary data to staff responsible for GHG calculations have several years of experience in their Primary data are unlikely to be lost or corrupted due to the operational role as well as a moderate understanding of implementation of robust data security measures. (Low) greenhouse gas reporting. (Low)

2 2 2 Baseline Source B13: Fuel Extraction and Fuel gas i.e. natural 8627 e3m3 7055 e3m3 4825 e3m3 0.133 kg CO2/m3 0.133 kg CO2/m3 0.133 kg CO2/m3 1,726.2 1,411.7 965.4 7.12% 7.16% 7.13% Medium: Medium: Probability = M x M = 2 Processing gas Impact = 7% = 3 'Emissions source is related to moderately complex equipment, 'Emissions calculations rely on data from information management operations or processes that require some technical knowledge to systems that are well-developed and have been in use for over 3 Risk = Probability x Impact = 2 x 3 = 6 out of 15 understand energy/material flows or physical/chemical reactions reporting cycles. (Low) that affect GHG emissions. (Medium) Medium Risk Emissions calculations rely on information management systems Emissions calculations depend on a moderate number of data the may be unreliable, but have controls in place to manage input parameters. (Medium) reliability. (Medium)

Emissions are calculated using default methodologies and/or Processes for collecting and processing primary data and emission factors consistent with program-specific protocols. (Low) executing emissions calculations are reasonably well-documented with minor gaps or transparency issues. (Medium) Emissions calculations require a moderate level of data pre- processing, but the data trail is transparent and traceable. Data trails between the emissions estimate and the primary data (Medium) may be long, but they are well-documented and traceable. Some QA/QC procedures are in place with some supporting records Staff responsible for acquisition/processing of primary data and available. (Medium) delivery/communication of primary data to staff responsible for GHG calculations have several years of experience in their Primary data are unlikely to be lost or corrupted due to the operational role as well as a moderate understanding of implementation of robust data security measures. (Low) greenhouse gas reporting. (Low)

Project Emission Sources

4 4 4 Project Source P21: Fuel gas i.e. natural 3383 e3m3 3159 e3m3 2566 e3m3 0.133 kg CO2/m3 0.133 kg CO2/m3 0.133 kg CO2/m3 812 841 639 7.01% 7.04% 6.96% Low: Medium: Probability = L x M = 1 Fuel Extraction and Processing gas Impact = 7% = 3 Emissions source is related to equipment, operations or processes Emissions calculations rely on data from information management that do not require specialized technical knowledge to understand systems that are new and/or incomplete. (High) Risk = Probability x Impact = 1 x 3 = 3 out of 15 energy/material flows or physical/chemical reactions that affect GHG emissions. (Low) Emissions calculations rely on information management systems Low Risk the may be unreliable, but have controls in place to manage Emissions calculations depend on a small number of data input reliability. (Medium) parameters. (Low) Processes for collecting and processing primary data and Emissions are calculated using default methodologies and/or executing emissions calculations are reasonably well-documented emission factors consistent with program-specific protocols. (Low) with minor gaps or transparency issues. (Medium)

Emissions calculations require a moderate level of data pre- Data trails between the emissions estimate and the primary data processing, but the data trail is transparent and traceable. are not very long, and they are reasonably well-documented and (Medium) traceable. Some QA/QC procedures are in place with some supporting records available. (Medium) Staff responsible for acquisition/processing of primary data and delivery/communication of primary data to staff responsible for Primary data are unlikely to be lost or corrupted due to the GHG calculations have several years of experience in their implementation of robust data security measures. (Low) operational role as well as a moderate understanding of h i (L ) Rank Emissions Source Fuel/Input Type Fuel/Input Amount HHV or Carbon Content Total Emissions (tonnes % of Emissions Inherent Risks Control Risks Risk Calculation

CO2e) 2 3 3 Project Source P12: Electricity 3003 MWh 2677 MWh 2181 MWh 0.64 tonnes 0.64 tonnes 0.64 tonnes 1,922 1,713 1,396 16.60% 14.36% 15.21% Low: Medium: Probability = L x M = 1 Injection Gas Transportation CO2e/MWh CO2e/MWh CO2e/MWh Impact = 14%-17% = 4 Emissions source is related to equipment, operations or processes Emissions calculations rely on data from information management that do not require specialized technical knowledge to understand systems that are new and/or incomplete. (High) Risk = Probability x Impact = 1 x 4 = 4 out of 15 energy/material flows or physical/chemical reactions that affect GHG emissions. (Low) Emissions calculations rely on information management systems Medium Risk the may be unreliable, but have controls in place to manage Emissions calculations depend on a small number of data input reliability. (Medium) parameters. (Low) Processes for collecting and processing primary data and Emissions are calculated using default methodologies and/or executing emissions calculations are reasonably well-documented emission factors consistent with program-specific protocols. (Low) with minor gaps or transparency issues. (Medium)

Emissions calculations require a moderate level of data pre- Data trails between the emissions estimate and the primary data processing, but the data trail is transparent and traceable. are not very long, and they are reasonably well-documented and (Medium) traceable. Some QA/QC procedures are in place with some supporting records available. (Medium) Staff responsible for acquisition/processing of primary data and delivery/communication of primary data to staff responsible for Primary data are unlikely to be lost or corrupted due to the GHG calculations have several years of experience in their implementation of robust data security measures. (Low) operational role as well as a moderate understanding of h i (L ) 1 1 1 Project Source P14: Fuel gas i.e. natural 3383 e3m3 3159 e3m3 2566 e3m3 2.0409 kg 2.0315 kg 2.0377 kg 7,133 6,648 5,437 61.61% 55.71% 59.24% Low: Medium: Probability = L x M = 1 Injection Unit Operation gas CO2/m3 CO2/m3 CO2/m3 Impact = 56%-62% = 5 Emissions source is related to equipment, operations or processes Emissions calculations rely on data from information management that do not require specialized technical knowledge to understand systems that are new and/or incomplete. (High) Risk = Probability x Impact = 1 x 5 = 5 out of 15 energy/material flows or physical/chemical reactions that affect GHG emissions. (Low) Emissions calculations rely on information management systems Medium Risk the may be unreliable, but have controls in place to manage Emissions calculations depend on a small number of data input reliability. (Medium) parameters. (Low) Processes for collecting and processing primary data and Emissions are calculated using default methodologies and/or executing emissions calculations are reasonably well-documented emission factors consistent with program-specific protocols. (Low) with minor gaps or transparency issues. (Medium)

Emissions calculations require a moderate level of data pre- Data trails between the emissions estimate and the primary data processing, but the data trail is transparent and traceable. are not very long, and they are reasonably well-documented and (Medium) traceable. Some QA/QC procedures are in place with some supporting records available. (Medium) Staff responsible for acquisition/processing of primary data and delivery/communication of primary data to staff responsible for Primary data are unlikely to be lost or corrupted due to the GHG calculations have several years of experience in their implementation of robust data security measures. (Low) operational role as well as a moderate understanding of h i (L ) 3 2 2 Project Source P15: Solution gas 205 e3m3 vent gas + 133 711 e3m3 vent gas + 98 466 e3m3 vent gas + 87 2.6629 kg 2.6629 kg 2.6629 kg 1,712 2,731 1,706 14.79% 22.89% 18.59% Medium: Medium: Probability =M x M = 2 Flaring at Injection Site e3m3 solution gas + 469 e3m3 solution gas + 331 e3m3 solution gas + 163 CO2/m3 vent gas CO2/m3 vent gas CO2/m3 vent gas Impact = 15%-23% = 4 e3m3 fuel gas e3m3 fuel gas e3m3 fuel gas & 1.4970 kg & 1.5442 kg & 1.4568 kg 'Emissions source is related to moderately complex equipment, 'Emissions calculations rely on data from information management CO2/m3 solution CO2/m3 solution CO2/m3 solution operations or processes that require some technical knowledge to systems that are well-developed and have been in use for over 3 Risk = Probability x Impact = 2 x 4 = 8 out of 15 gas & 2.0409 kg gas & 2.0315 kg gas & 2.0377 kg understand energy/material flows or physical/chemical reactions reporting cycles. (Low) CO2/m3 fuel gas CO2/m3 fuel gas CO2/m3 fuel gas that affect GHG emissions. (Medium) Medium Risk Emissions calculations rely on information management systems Emissions calculations depend on a moderate number of data the may be unreliable, but have controls in place to manage input parameters. (Medium) reliability. (Medium)

Emissions are calculated using default methodologies and/or Processes for collecting and processing primary data and emission factors consistent with program-specific protocols. (Low) executing emissions calculations are reasonably well-documented with minor gaps or transparency issues. (Medium) Emissions calculations require a moderate level of data pre- processing, but the data trail is transparent and traceable. Data trails between the emissions estimate and the primary data (Medium) may be long, but they are well-documented and traceable. Some QA/QC procedures are in place with some supporting records Staff responsible for acquisition/processing of primary data and available. (Medium) delivery/communication of primary data to staff responsible for GHG calculations have several years of experience in their Primary data are unlikely to be lost or corrupted due to the operational role as well as a moderate understanding of implementation of robust data security measures. (Low) greenhouse gas reporting. (Low) Table 5: Sampling Plan & Verification Procedures Emissions Source or Scope Risk ID Verification Procedures Item Protocol Application of the Protocol Check that appropriate protocol was used. 1.0 Review the protocol and determined if this is the right protocol for the project. Check if Quantification protocol for Enhanced Oil Recovery (EOR) - Streamlined (AEP, October 2007) is applicable for this project (parts of the project). Check to see if acid gas injection protocol is applicable.

Emission Sources Baseline Source B2a/B3a: Has the volume of required tail gas and fuel gas used in incinerator 1.1 Review the calculations and methodology used to determine the total volume Flaring/Venting at Capture been calculated correctly? of tail gas and fuel gas consumed in the baseline period to ensure Site appropriateness. Check that all appropriate sources of fuel gas used in the baseline are included.

1.2 Verify that the data taken from the SULSUM report is extracted correctly and calculated correctly.

1.3 Verify that the metered data to determine the fuel gas flow rates are extracted correctly. Explain any outliers or abnormal trends. Obtain calibration/maintenance records for the meters if applicable.

1.4 Verify that the methodology used to determine tail gas and fuel gas volumes matches the methodology described in the project plan and project report. Have the CO2 emission factors and HHV for the tail gas and fuel gas 1.5 Verify the tail gas info fromthe sulsim report is correct. Verify the compositions been used appropriately? from sales gas anaysis from TCPL/NOVA is extracted correctly. Verify the the primary data used matches the compositional data used in the calculator. Check if the HHV are calcuated and referenced correctly.

Have the CH4 and N2O emission factors for the tail gas and fuel gas 1.6 Verify the appropriateness of the emission factors used in the GHG been used appropriately? calculations. Check if the emission factors are referenced correctly. Were the correct GWP applied?

Has the emission calculation been executed correctly? 1.7 Recalculate the total annual GHG emissions based on the verified data identified in the verification procedures above.

1.8 Verify that the methodology used to determine the emissions is consistent with the project plan and EOR protocol. Check to see if there are any changes made for the reporting period.

Baseline Source B13: Fuel Has the volume of required tail gas and fuel gas used in incinerator 2.1 Review the calculations and methodology used to determine the total volume Extraction and Processing been calculated correctly? of tail gas and fuel gas consumed in the baseline period to ensure appropriateness. Check that all appropriate sources of fuel gas used in the 2.2 Verify that the data taken from the SULSUM report is extracted correctly and calculated correctly. 2.3 Verify that the metered data to determine the fuel gas flow rates are extracted correctly. Explain any outliers or abnormal trends. Obtain calibration/maintenance records for the meters if applicable 2.4 Verify that the methodology used to determine tail gas and fuel gas volumes matches the methodology describes in the project plan and project report.

Emissions Source or Scope Risk ID Verification Procedures Item

Have the CO2, CH4 and N2O emission factors for the tail gas and fuel 2.5 Verify the appropriateness of the emission factors used in the GHG gas been used appropriately? calculations. Check if the emission factors are referenced correctly. Were the correct GWP applied?

Has the emission calculation been executed correctly? 2.6 Recalculate the total annual GHG emissions based on the verified data identified in the verification procedures above. 2.7 Verify that the methodology used to determine the emissions is consistent with the project plan and EOR protocol. Check to see if there are any changes made for the reporting period. Project Source P21: Has the volume of required fuel gas used in the compressors (P14) and 3.1 Review the calculations and methodology used to determine the total volume Fuel Extraction and in the EOR compressor flare been calculated correctly? of fuel consumed in the compressors and flare to ensure appropriateness. Processing Check that all appropriate sources of fuel gas used in the project are included.

3.2 Verify that the fuel gas used in the compressors is measured and extracted correctly.

3.3 Verify that the fuel gas used in the EOR compressor flare is measured and extracted correctly.

3.4 Verify that the methodology used to determine fuel gas volumes matches the methodology describes in the project plan and project report. Have the CO2, CH4 and N2O emission factors been used appropriately? 3.5 Verify the appropriateness of the emission factors used in the GHG Were the correct GWP applied? calculations. Check if the emission factors are referenced correctly. Has the emission calculation been executed correctly? 3.6 Recalculate the total annual GHG emissions based on the verified data identified in the verification procedures above. 3.7 Verify that the methodology used to determine the emissions is consistent with the project plan and EOR protocol. Check to see if there are any changes made for the reporting period. Project Source P12: Has the electricity consumed by the compressor determined correctly? 4.1 Review the calculations and methodology used to determine the power Injection Gas Transportation consumed in the compressors to ensure appropriateness. Check that all appropriate sources of the power used in the project are included.

4.2 Verify that the runtime hours used by the compressors is measured and extracted correctly. 4.3 Verify that the compressor power ratings are extracted and used correctly.

4.4 Verify that the methodology used to determine the power consumption matches the methodology describes in the project plan and project report.

Has the CO2 emission factor been used appropriately? 4.5 Verify the appropriateness of the emission factor used in the GHG calculations. Check if the emission factor is referenced correctly.

Has the emission calculation been executed correctly? 4.6 Recalculate the total annual GHG emissions based on the verified data identified in the verification procedures above.

4.7 Verify that the methodology used to determine the emissions is consistent with the project plan and EOR protocol. Check to see if there are any changes made for the reporting period. Project Source P14: Has the volume of required fuel gas used in the compressors been 5.1 Review the calculations and methodology used to determine the total volume Injection Unit Operation calculated correctly? of fuel consumed in the compressors to ensure appropriateness. Check that all appropriate sources of fuel gas used in the project are included.

5.2 Verify that the fuel gas volumes are extracted correctly.

5.3 Verify that the methodology used to determine fuel gas volumes matches the methodology describes in the project plan and project report.

Have the fuel gas and propane heater fuel volumes, and electric heater 5.4 Review the calculations and methodology used to determine the total fuel gas, power usage, been calculated correctly propane and power consumed by heaters to ensure appropriateness. Verify that the methodology matches the project plan and project report. Veryify the fuel gas volume, propane fuel volume and power usage are extracted correctly

Emissions Source or Scope Risk ID Verification Procedures Item

Has the CO2 emission factor been used appropriately? 5.5 Verify the appropriateness of the emission factors used in the GHG calculations for natural gas compressors and heaters. Verify the compositions from fuel gas anaysis from TCPL/NOVA are extracted correctly. Verify the the primary data used matches the compositional data used in the calculator. Verify the propane CO2 emission factor is correct. Verify the CO2e emission factor for electric heaters is correct Have the CH4 and N2O emission factors for the fuel gas and propane 5.6 Verify the appropriateness of the emission factors used in the GHG been used appropriately? calculations for natural gas compressors and heaters, and propane heaters. Were the correct GWP applied? Check if the emission factors are referenced correctly.

Has the emission calculation been executed correctly? 5.7 Recalculate the total annual GHG emissions based on the verified data identified in the verification procedures above.

5.8 Verify that the methodology used to determine the emissions is consistent with the project plan and EOR protocol. Check to see if there are any changes made for the reporting period. Project Source P15: Has the flaring volumes from Battery 14-12 high pressure flare & 6.1 Review the calculations and methodology used to determine the total flare to Flaring at Injection Site Tank KO low pressure vent gas flare been calculated correctly? ensure appropriateness. Check that all appropriate sources of fuel gas used in the project are included. 6.2 Verify that the flare gas volumes are extracted correctly.

6.3 Verify that the methodology used to determine flare gas volumes matches the methodology describes in the project plan and project report.

Has the Solution gas volumes (i.e. raw gas volume to EOR compressor 6.4 Review the calculations and methodology used to determine the total volume flare) been calculated correctly? of solution gas to ensure appropriateness. Check that all appropriate sources of solution gas used in the project are included. Obtain calibration/maintenance records for the meters if applicable.

6.5 Verify that the solution gas volumes are measured and extracted correctly.

6.6 Verify the compositions from sales gas anaysis from TCPL/NOVA are extracted correctly, as well as the acid gas analyses from the onsite GC data. Verify the the primary data used matches the compositional data used in the calculator. Check if the LHV are calcuated and referenced correctly.

6.7 Verify that the methodology used to determine flare gas volumes matches the methodology describes in the project plan and project report.

Has the fuel gas volume used in the EOR compressor flare calculated 6.8 Review the calculations and methodology used to determine the total volume correctly? of fuel consumed in the compressor flare to ensure appropriateness. Check that all appropriate sources of fuel gas used in the project are included. Obtain calibration/maintenance records for the meters if applicable.

6.9 Verify that the fuel gas volumes are measured and extracted correctly.

6.10 Verify that the methodology used to determine flare gas volumes matches the methodology describes in the project plan and project report.

Has the CO2 emission factor been used appropriately? 6.11 Verify the appropriateness of the emission factor used in the GHG calculations. Verify the compositions from fuel gas anaysis from TCPL/NOVA is extracted correctly, as well as the acid gas analyses from the onsite GC data. Verify the the primary data used matches the compositional data used in the calculator Have the CH4 and N2O emission factors for the vent gas and fuel gas 6.12 Verify the appropriateness of the emission factors used in the GHG been used appropriately? calculations. Check if the emission factors are referenced correctly. Were the correct GWP applied?

Has the emission calculation been executed correctly? 6.13 Recalculate the total annual GHG emissions based on the verified data identified in the verification procedures above.

6.14 Verify that the methodology used to determine the emissions is consistent with the project plan and EOR protocol. Check to see if there are any changes made for the reporting period. Emissions Source or Scope Risk ID Verification Procedures Item

Negligible sources Have negligible sources been accounted correctly and truly negligible? 7.1 Verify during the site visit if there are any negligible sources.

Emissions Offset Credits Emission Reduction Have the emission reductions been estimated correctly 8.1 Recalculate the emissions reduction based on the verified baseline and project level emissions identified in the verification procedures above.

Other Scope Items Review any applicable Are there any changes to operations, organizational and operational 9.1 Review facility ownership history changes boundaries since the last verification (2014 reporting year)? Review corporate structure and changes Review any changes in employees responsible for the offset reporting

Baseline and Project Are the baseline and project sources included correctly based on the 9.2 Do a check on the baseline and project sources to determine if there sources and sinks preliminary data provided? are any sources missing and compare these to previous year (2013/2014) source inventory. Assess completeness of emissions inventory during site visit and assess rationales provided for any sources that have been excluded.

Offset Project Confirmations Is offset project information consistent across offset project 9.3 Review most updated OPR for consistency with OPP and emissions calculator. documentation?

Have offset project location and any applicable approvals information 9.4 Confirm offset project location per site visit. been provided? 9.5 Obtain AER license for plant operations.

Do methodology manuals or procedure manuals exist? 9.6 Obtain offset project methodology manuals and/or procedures manuals.

Are offset project contact, report dates, emission reduction numbers 9.7 Verify the OPR and OPP information for consistency and accuracy. reported correctly?

Are process flow diagrams complete and accurate? 9.8 Obtain process flow diagrams and review for completeness and consistency with emissions calculations.

Program Criteria Have eligibility criteria as defined in Section 7 of the Specified Gas 9.9 Verify that the specified gas emissions reduction occur in Alberta Emitters Regulation been satisfied. 9.10 Verify and confirm that the emissions reduction are from an action that is not otherwise required by law at the time it was initiated.

9.11 Confirm that the emissions reduction took place due to actions taken on or after January 1, 2002 and occur on or after January 1, 2002.

9.12 Verify that the emissions reduction are real and demonstrable

9.13 Verify that the emissions reduction are quantifiable and measurable.

9.14 Verify that the requirements of Part 3, Section 16 of the Alberta Regulation 255/2017 have been met. Table 6: Source Tolerance Percentage Materiality Planning A discrepancy should be considered an issue if its impact on the facility's total annual emissions is >=0.1%

Baseline Emissions Source % Contribution Overall Tolerance Source Tolerance Baseline Source B2a/B3a: Flaring/Venting at Capture Site 92.9% 0.10% 0.11% Baseline Source B13: Fuel Extraction and Processing 7.1% 0.10% 1.40% Project Emission Source % Contribution Overall Tolerance Source Tolerance Project Source P14: Injection Unit Operation 61.6% 0.10% 0.16% Project Source P12:

Injection Gas Transportation 16.6% 0.10% 0.60% Project Source P15:

Flaring at Injection Site 14.8% 0.10% 0.68% Project Source P21: Fuel Extraction and Processing 7.0% 0.10% 1.43%

Appendix B: Statement of Qualifications

Page 34 of 44 Statement of Qualifications

Offset Report Project Name Offset Project ID Apache Zama Battery 12 Enhanced 8806-0274 Oil Recovery Project

Reporting Company Legal Name Report Type Reporting Period Jan 1, 2015 to Paramount Resources Ltd. Offset Report from November 30, 2017 to Signature of Third Party Verifier

I , Joyce Funk (Third Party Verifier), meet or exceed the qualifications of third party

Third-party verifiers described in Section 29 of the Carbon Competitiveness Incentive Regulation.

Verifying Company Name RWDI Air Inc. Per: Signature of Third Party Verifier Date J.Funk 7-Mar-18 Training Received Under ISO 14064 Part 3 Certificate Number 0000447902 First Name Last Name Joyce Funk Professional Designation E-mail Address Phone Number P.Eng [email protected] (780)-566-5129

Lead Verifier X Same as third party verifier?? Yes First Name Last Name

Professional Designation E-mail Address Phone Number

Training Received Under ISO 14064 Part 3

Peer Reviewer First Name Last Name Alena Saprykina E-mail Address Phone Number [email protected] (403) 232-6771 ext. 6273

Training Received Under ISO 14064 Part 3

Certificate Number 0000448155

Page 35 of 44 Appendix C: Findings and Issues

Page 36 of 44 Table 7: Detailed Findings and Issues Log Number the issue with the year and provide a unique # for the issue. If the issue resolved during the verification, indicate that in the resolution column. If the issue is not resolved during the verification, or if the issue was material (whether resolved or not) record it as a finding in Table 2 and provide a cross reference to the finding # in the resolution column. Describe the issues investigated. State the verification criteria that are not met. Provide a description of how it is not met and provide the evidence. Indicate the Source Category (for facilities) or the Source/Sink (for offsets). Indicate if the finding is an understatement or overstatement. Summarize information between verifier and client. Provide a conclusion including % discrepancy, if applicable.

Summary of Conclusion Item Description of the Issues information (including % (YR- Investigated During the exchanged Resolution discrepancy if ##) Verification between verifier applicable) and client RWDI communicated Transparency: The original this concern Bluesource Offset Project Report through a (OPR) and Calculator contained a questionnaire. source named B2a/B3a: Addressed before the final submission N/A Bluesource Flaring/Venting at Capture Site, modified the however there was no venting source to be included in the source. named B2a: 15-17: #1 Flaring. RWDI communicated Accuracy: The sales gas analysis this concern data in the Calculator did not through a match the primary data obtained questionnaire. during the verification site visit; Bluesource Addressed before the final submission N/A this impacted sources B2a: Flaring updated the sales at Capture Site, P14: Injection Unit gas data used in Operation and P15: Flaring at the calculator with Injection Site. the correct 15-17: #2 compositions. Accuracy: The primary sales gas compositional data show small Impact is less negative values for C7 and C8 This was not than the components; the data should not communicated to Added to final report under summary tolerable error be included in the analyses. This Bluesource until of findings as an Opportunity for (<0.1%), would impact sources B2a: Flaring the draft issues Improvement Opportunity for at Capture Site, P14: Injection Unit log. Improvement Operation and P15: Flaring at 15-17: #3 Injection Site. This was not communicated to Bluesource until Accuracy: Daily gas compositions the draft issues are time-weighted rather than log. Bluesource being volume-weighted; volume- responded and Impact is less weighting would be a more provided than the accurate method, and could be a Added to final report under summary clarification on the tolerable error potential opportunity for of findings as an Opportunity for reasoning behind (<0.1%), improvement in the future. This Improvement their calculations; Opportunity for would impact sources B2a: Flaring however RWDI Improvement at Capture Site, P14: Injection Unit ultimately decided Operation and P15: Flaring at to keep this Injection Site. concern as an Opportunity for 15-17: #4 Improvement. Accuracy: CH4 and N2O emission factors for natural gas combustion (from Carbon Offset Emission Factors Handbook table 6, Industrial sources) are used for tail This was not Added to final report under summary Qualitative gas, solution gas and acid gas communicated to of findings as a Qualitative Discrepancy, flaring. The CH4 and N2O natural Bluesource until Discrepancy, Opportunity for Opportunity for gas combustion emission factors the draft issues Improvement Improvement may not be the most suitable for log. tail gas, solution gas and acid gas, since the different gases have different compositional analysis 15-17: #5 compared to natural gas. Flaring emission factors are also estimated differently than combustion emission factors.

RWDI communicated Accuracy: HP/LP flared volumes this concern were incorrectly included in the through a volume of fuel associated with the questionnaire. Addressed before the final submission N/A source P21: Fuel Extraction and Bluesource Processing. The error was found in modified the the emissions calculator. calculations to exclude the HP/LP 15-17: #6 flare volumes. Accuracy: The power usage for compressors K220 and K240 in 2015 is extrapolated based on 2016 & 2017 data, using average HP and acid gas volumes, and an assumption of 24-hour run-time for the compressors. Extrapolation This was not using kWh and acid gas would be a 0.11% communicated to Added to final report under summary more realistic method, as it also Overstatement Bluesource until of findings as an Overstatement of accounts for the non-continuous of Project the draft issues Project Emissions runtime. Emissions log. This error resulted in an overestimation of emissions from the source P12: Injection Gas Transportation by 0.71% and an overestimation of Project scenario 15: #7 emissions by 0.11%. Transparency/Accuracy: Compressors K210, K430 and K420 are included in the source RWDI P14: Injection Unit Operation; communicated however, it would be more this concern appropriate to include them under through a the source P12: Injection Gas questionnaire. Added to final report under summary Opportunity for Transportation. They are located at Bluesource did not of findings as an Opportunity for Improvement Battery 12 (i.e. at LSD 14-12) and take any action as Improvement compress a combined stream of their gas that comes from the field and understanding of the plant; this streams then goes the source was to the injection sites which are different. located elsewhere (i.e. LSDs 11- 15-17: #8 25, 1-13, 4-36, 5-34, 14-32, 5-1). RWDI Accuracy: There were 147 days communicated during the reporting period where this concern there were non-zero runtime hours through a reported by SCADA, but no questionnaire. compressor utilization data Bluesource Addressed before the final submission N/A available from the CPO software; modified the these were excluded from the calculations to calculations, resulting in an account for the underestimation of emissions from 147 missing days the P14 and P21 sources. 15-17: #9 of data. Accuracy: The average LHV applied to natural gas heaters is based on LHVs for the entire year; since the heaters are only This was not operational during winter months, 0.07% communicated to Added to final report under summary it would be more accurate to apply Understatement Bluesource until of findings as an Understatement of an average based on only on of Project the draft issues Project Emissions winter months. Emissions log. This error resulted in an underestimation of emissions from 15-17: #10 the source P14: Injection Unit Operation by 0.11% and an underestimation of Project scenario emissions by 0.07%.

RWDI communicated this concern Accuracy: There were some linking through a and formula errors in the questionnaire. Addressed before the final submission N/A emissions calculator relating to the Bluesource emissions from source P14. modified the calculator to fix 15-17: #11 the errors. RWDI communicated Accuracy: Data from meters FQI- this concern 4110 and FQI-1530, which through a measure dilution fuel gas that is questionnaire. added to the EOR compressor flare Addressed before the final submission N/A Bluesource stream, i.e. to the stream modified the measured by FQI-4101, was not calculations using used in the emission calculations. the data from the 15-17: #12 two new meters. Accuracy: Acid gas compositions are not normalized before being This was not used in the calculations; this could communicated to Added to final report under summary Opportunity for be a potential opportunity for Bluesource until of findings as an Opportunity for Improvement improvement in the future. This the draft issues Improvement would impact source P15: Flaring log. 15-17: #13 at Injection Site. This was not Transparency: The Calculator communicated to Added to final report under summary refers to the ERCB, rather than the Opportunity for Bluesource until of findings as an Opportunity for AER in the B2a Flaring and P15 Improvement the draft issues Improvement Flaring tabs. 15-17: #14 log. This was not Transparency: The Calculator has communicated to Added to final report under summary Opportunity for incorrect units stated in cells I22 Bluesource until of findings as an Opportunity for Improvement and J22 of the Data Entry tab. the draft issues Improvement 15-17: #15 log. Transparency: The Offset Project Plan (OPP) is out of date and an update would be appropriate, for This was not changes in methodology as well as communicated to Added to final report under summary large scale changes that have Opportunity for Bluesource until of findings as an Opportunity for occurred at the plant and battery Improvement the draft issues Improvement 12, eg. the merging of plant 2 and log. plant 3 to create plant 4, the rearrangement and renaming of 15-17: #16 compressors, etc. RWDI communicated this concern Transparency: The Offset Project through a Report refers to the Project as questionnaire. Apache Zama Battery 12 Enhanced Bluesource stated Added to final report under summary Oil Recovery. However, the Project Opportunity for that they had of findings as an Opportunity for Developer is now Paramount Improvement contacted Improvement Resources Ltd.; the Project name Paramount should be updated for Resources Ltd. transparency. about this issue, but there was no 15-17: #17 other follow up. Transparency: It was noticed from the SULSUM report pdf diagram representing the two stage Claus process, that there is an additional tail gas stream that recycles back to the acid gas SRU furnace. However, it appears that the estimated tail gas flow rate used in This was not the emissions calculation includes communicated to Added to final report under summary Opportunity for the recycled portion that is used in Bluesource until of findings as an Opportunity for Improvement the acid gas furnace, Thus, it the draft issues Improvement appears that total volume of tail log. gas is accounted for.

This would be an OFI to segregate the emissions associated to the tail gas incineration and the tail gas used as fuel to combust the acid 15-17: #18 gas in the SRU furnace. Transparency: The formula used to determine the volume of tail Gas that would have been sent to This was not incinerator is shown in Cell I27, communicated to Added to final report under summary Opportunity for Tab . This formula Bluesource until of findings as an Opportunity for Improvement written in the emissions calculator the draft issues Improvement does not match the reported log. calculations and formula listed in 15-17: #19 the OPR. Appendix D: Statement of Verification

Page 38 of 44 Apache Zama Battery 12 Enhanced Oil Recovery Project / #8806-0274 March 2018

Statement of Verification

Associated SGER Submission Offset Project QuantificationProtocol Protocol for Project ID # Apache Zama Battery 12 Enhanced Oil Enhanced Oil Recovery – 8806-0274 Recovery Project Streamlined, Version 1.0, October 2007 Project Developer Serial Range Start Report Period Paramount Resources Ltd. Jan 1, 2015 to Not Available November 30, 2017 Serial Range End Not Available Statement of Verification GHG Assertion Value Units

Total Baseline Emissions) 57,502 tonnes CO2eq

Total Project Emissions ) 33,710 tonnes CO2eq

Other ) Not Applicable tonnes CO2eq

Net Reductions) 23,790 tonnes CO2eq

January 1, 2015 to November 30, 2017 - Emissions reduction for Apache Statement of Assertion Zama Battery 12 Enhanced Oil Recovery Project is 23,790 tonnes of CO2 equivalent.

Responsibilities of Project Developer and Third Party Verifier

RWDI Air Inc. has reviewed the Apache Zama Battery 12 Enhanced Oil Recovery Project emissions reduction for the period of January 1, 2015 to November 30, 2017. Bluesource was responsible for preparing the offset project emission reduction report. RWDI Air Inc.’s objective and responsitbiltiy is to provide an opinion to Alberta Environment and Parks as to wheather the GHG assertion is free from material misstaments, and is presented fairly in accordance with the program criteria.

Conclusion

During the course of the verification, no material misstatements were identified. It is our opinion, because the total misstatement is below the materiality threshold of 5%, the GHG assertion does present fairly the Project’s emissions reduction for the period of January 1, 2015 to November 30, 2017. Furthermore, it is our opinion that the evidence generated during the verification is appropriate and sufficient to support an overall positive finding with a reasonable level of assurance.

Signature of Third Part Verifier Verifying Company Name RWDI AIR Inc. Per: Signature of Third Party Verifier Date: J.Funk 7-Mar-18 First Name Last Name Joyce Funk Professional Designation E-mail Address Phone Number P.Eng [email protected] (780)-566-5129

Page 39 of 44 Appendix E: Conflict of Interest Checklist

Page 40 of 44 Apache Zama Battery 12 Enhanced Oil Recovery Project / #8806-0274 March 2018

Conflict of Interest Checklist

Associated SGER Submission Offset Project Protocol

Apache Zama Battery 12 Quantification Protocol for Enhanced Oil Recovery Enhanced Oil Recovery – Project Streamlined, Version 1.0, October Project Developer Report Type Report Period Jan 1, 2015 to Paramount Resources Ltd. Offset Report November 30, 2017

Checklist Respond either "True" or "False" to each of the following statements:

The relationship between my firm and this reporting company poses 1 unacceptable threat to or compromises the impartiality of my firm. FALSE

The finances and sources of income of my firm compromise the 2 impartiality of my firm. FALSE

The personnel my firm has scheduled to participate in the verification 3 may have an actual or potential conflict of interest. FALSE

My firm participated in some manner in the development or completion of 4 the associated offset submission for this reporting company. FALSE

My firm provided greenhouse gas consultancy services to this reporting 5 company. FALSE

My firm will use personnel that have, are, or will be engaged or previously 6 employed by the reporting company. FALSE

My firm will outsource the Statement of Verification for the associated 7 offset submission. FALSE

My firm offers products or services that pose an unacceptable risk to 8 impartiality. FALSE

Important: If you have checked "True" to any of the above, you may not fulfill the "independence" requirement for third party verifiers. Please contact Alberta Environment and Parks for further instruction. If the potential conflict of interest is a sufficient threat to impartiality (perceived or actual), or cannot be effectively managed, you Third Party Verification Report will not be acceptable to Alberta Environment and Parks.

Signature of Third Party Verifier

I , Joyce Funk (Third Party Verifier), have personally examined and am familiar

with the information contained in this Conflict-of Interest Checklist, and can demonstrate freedom from any conflict of interest related to the reporting company for which the verification was performed. I hereby warrant that the information submitted in this Conflict-of Interest Checklist is true, accurate and complete to the best of my knowledge, and that all matters affecting the validity of this Conflict-of-Interest Checklist have been fully disclosed. Impartiality shall be monitored over the duration of the verification and any identified actual or potential conflict-of- interest situations will be communicated to AEP directly.

Verifying Company Name RWDI Air Inc. Per: Signature of Third Party Verifier Date

J.Funk 7-Mar-18

First Name Last Name Joyce Funk Professional Designation E-mail Address Phone Number P.Eng [email protected] (780)-566-5129 Page 42 of 44 Appendix F: Supplemental Diagrams/Tables/Figures

(Site Visit Notes & Recalculations)

Page 43 of 44 SITE VISIT PLAN

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General Information

Site(s) to visit: Paramount Resource Ltd. Zama Battery 12, Zama City office and Calgary office

Date(s) of site visit: Feb 8 & 9, 2018 in Zama City and Feb 22 in Calgary

RWDI field verifiers: Jyotsna Kashyap, Thana Boonlert-Mounarath

Client hosts: Zama: Logan Boyle Calgary: Lance Hofer

Meeting location: Zama City Field office, 929 Wildcat Ave Calgary office, 421 7th Avenue SW, Suite 2800

Meeting time: Zama City Field office: Feb 8 8:00 am, Feb 9 8:00 am Calgary office: Feb 22 9.00am

Safety training requirements prior H2S Alive & WHMIS (Jyotsna and Thana), First Aid (Thana) to arrival on site:

Safety training requirements upon Worksite orientation on basic safety awareness and test, arrival to site: orientation at site

Personal protective equipment ▪ CSA certified safety boots required: ▪ nomex coveralls ▪ hardhats ▪ safety glasses ▪ hearing protection

Additional notes: Contact numbers: Logan Boyle: 780-841-8201 Jyotsna Kashyap: 403-826-6212 Thana Boonlert: 403-689-8547 Lance Hofer: 403-817-5076

The general tasks to be completed during the site visit include:

• Safety and site orientation; • Review of verification terms of engagement; • Overview of facility history, operations, processes and equipment; • Tour of facility to gain general understanding of processes, emissions sources and greenhouse gas data measurement/collection; • Overview of greenhouse gas data collection, management, and controls; • Overview of greenhouse gas emissions calculation methodologies; • Review of selected emissions calculations; and, • Retrieval/reproduction of primary records for selected samples of data (e.g., meter/scale readings, CEMS data, fuel purchasing invoices, lab reports) from their original source.

Specific tasks to be completed are listed in the table below. The tasks are not necessarily listed in the order that they must be completed. It is advised that the task list be reviewed in detail prior to the site visit in order to ensure that appropriate personnel are available for discussion with verifiers and to ensure that the requested data and records will be retrievable from their original sources. SITE VISIT PLAN

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Date & Time Task Notes Follow-up

Feb 8 Safety and site orientation Jyotsna and Thana reviewed the worksite 8:00-8:30 orientation on basic safety awareness and took the test; were not able to visit the plant and battery on Feb 8 due to onsite purging that was happening due to an H2S leak and temporary plant shutdown operations; visited the plant on Feb 9 after purging was over and there were no heightened safety concerns.

Feb 8 Review of verification terms of engagement: Referred to the applicable sections in RWDI’s

8:30-12:00 • Level of assurance Initial Verification Plan • Objectives • Criteria • Scope • Materiality • Verification standards

Feb 8 Review of verification team members Project Manager - Candace Bell

8:30-12:00 Lead Verifier – Joyce Funk Supporting Verifiers – Jyotsna Kashyap and Thana Boonlert-Mounarath Field Verifiers – Jyotsna Kashyap and Thana Boonlert-Mounarath Peer Reviewer – Alena Saprykina

Feb 8 Review RWDI’s complaints and appeals process http://rwdi.com/assets/factsheets/161214-

8:30-12:00 Complaints-Appeals-Statement-for-Webpage.pdf

Feb 8 Review RWDI’s confidentiality policy RWDI is committed to high standards with

8:30-12:00 documented policies and procedures

Feb 8 Review corporate structure Paramount Resources Ltd. acquired Apache in July

8:30-12:00 Any changes to corporate structure during reporting 2017; however there are no relevant changes to period? the GHG emissions reporting process (organizational chart would be helpful) SITE VISIT PLAN

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Date & Time Task Notes Follow-up

This information is helpful in assessing the chosen inventory boundaries.

Feb 8 Review facility ownership history The facility ownership changed from Apache to

8:30-12:00 Any changes to ownership during reporting period? Paramount Resources Ltd.; however there are no relevant changes to the GHG emissions reporting process

Feb 8 Review GHG inventory boundaries The boundaries between the plant and the

8:30-12:00 battery, as well as the EOR vs conventional battery were discussed; only the processes related to EOR are included in the GHG inventory

Feb 8 Discuss shutdowns or periods of irregular operation that Field operators maintain flare spreadsheets

8:30-12:00 occurred during the reporting year: where they manually log shutdowns and periods • Descriptions of irregular operations. The spreadsheet has • Dates and durations dropdown menus where the operators can • Effects on GHG emissions choose the type of event (eg. compressor shutdown), and other fields (eg. volume of gas purged due to a compressor shut down) are automatically populated. RWDI obtained copies of the 2016 and 2017 flare logs. There were around 25 compressor shutdown related flaring events in those years. The data from the flare logs is not directly used in the GHG calculations; the shutdowns would be reflected in the EOR compressor flare volume.

Feb 8 Review facility operations, processes, and equipment (site Reviewed EOR and AGI processes with Logan and 8:30-12:00 plans and simplified process flow diagrams would be Lance. Discussed PFD with Logan at Zama and Feb 22 helpful) 9:00-10:00 later reviewed metering schematic with Lance in Calgary as well.

Confirmed what these meters measure, they are used in the Blue Source calculator v4.1_2018-2-3:

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Date & Time Task Notes Follow-up

Zama 14-12 Gas Plant AG FLARE (4101) -EOR compressor flare vol Zama 14-12 Gas Plant Acid Gas to K220 FQI-4245 - total acid gas injected

Enquired about these meters, which were not used in the calculator; they were later incorporated into the calculations by Bluesource: Zama 14-12 Gas Plant Acid Gas Dilution FQI-1530 – provides additional nat gas dilution to EOR flare if needed, depends on FQI-4110 Zama 14-12 Gas Plant High Pressure Dilution FQI- 4110 – nat gas dilution to EOR flare, i.e. added to FQI-4101 stream

Enquired about these flares: 14-12 High Pressure flare Tank KO Low Pressure Vent Gas Flare They are connected to plant processes; the contribution from the EOR acid gas system is small; Bluesource clarified the calculations through responses to RWDI Questionnaire#1.

Clarified the distribution of operations between the different compressors. Electric compressors are at the plant at LSD 14-12 and process plant acid gas, natural gas compressors are at the battery, also at LSD14-12 and compress a combination of plant and field acid gas; the combined stream goes to the north and south injection sites located at LSDs 11-25, 1-13, 4-36, 5- 34, 14-32, 5-1. Confirmed there are no additional emission sources at the injection points; i.e. all

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Date & Time Task Notes Follow-up

applicable emission sources related to the EOR project have been accounted for in the inventory.

Feb 8 Review roles, responsibilities and competencies of Logan Boyle

8:30-12:00 individuals involved in generating the emission report. For Field Operations Lead each individual involved: Lead operator position for the plant and battery • Name processes; not involved in GHG reporting, only • Title involved in verification site visit • Contribution to the report (e.g., provided fuel At Zama since 2011 purchasing invoices, or developed emissions Qualification - Gas Process Operations Certificate calculations spreadsheet, or provided detailed QA/QC of data transcription from lab report to Charles Perez emissions calculations spreadsheet) Field Operator • Number of years work experience at the facility Operator for plant and battery processes; not • Experience/training in environmental reporting or involved in GHG reporting, only involved in GHG’s verification site visit At Zama since 2008 Qualification - Gas Process Operations Certificate

Lance Hofer Production Engineer in Production Operations Department Provides the GHG data, i.e. the primary data used in the calculations, to Blue Source, via Trevor Dillabough; this is his first year involved in GHG reporting At Paramount since 2011

Martin Lamothe – was unavailable for interview during verification timeframe. Martin is in the Calgary office, he is the resource for compressor utilization data; he is in charge of the CPO system (productivity optimization software) and he

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Date & Time Task Notes Follow-up

provided compressor data to Lance which then went to Bluesource.

Trevor Dillabough Bluesource’s main contact at Paramount; this is his first year involved in GHG reporting

Feb 8 Review of previous emissions reports and verification RWDI worked on verification for 2008 to 2013,

8:30-12:00 findings positive opinion with some OFIs, no material issues. Tetra Tech EBA worked on verification for 2014, positive opinion, no material errors or OFIs.

Feb 8 Discuss changes for this year’s emissions report: Plant 2 and 3 ceased to exist and Plant 4 came to

8:30-12:00 • Changes to operations, processes, equipment, existence in 2014; a compressor was moved from emissions sources the plant to the battery; but overall processes as • Changes in calculation methodologies relate to AGI and EOR remain the same; these • Changes in primary data used updates are incorporated in the 2015-2017 offset • Changes in data measurement or collection project report. methodologies There are changes to the way the compressor utilizations and fuel consumption are tracked. Meter FQI-4110 was installed in December 2015; it measures dilution gas added to the EOR compressor flare; this was not originally included in the calculations but Bluesource updated the calculator to use the metered data after RWDI Questionnaire#1.

Feb 9 General tour of facility Physically located the flow meters mentioned

10:00-11:30 • Observe emission sources above, and the sales gas and acid GCs, and visited • Observe measurement devices such as flow each of the compressors (Elec K220,K240, FG meters, online analyzers, scales K210,K430,K420). See site visit photos. Noted meter identifications and compressor. Observed flaring processes & piping. There is no venting on site due to the H2S content of the gas; it’s all

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Date & Time Task Notes Follow-up

flared. Weren’t able to visit injection sites due to time constraints (lost time due to safety-related delay at plant, see safety and site orientation section above).

Feb 8 Interviews with selected facility specialists. For example: Interviewed field operators Logan Boyle and

8:30-12:00 • Process specialists (knowledge of energy and Charles Perez at the Zama office and plant; Logan material flows) provided most of the information at the office on • Maintenance/operations specialist (knowledge of PFDs and data, Charles led the plant and battery measurement device specs and visit. maintenance/calibration procedures) • Lab specialists (knowledge of sampling procedures Interviewed instrumentation technician Robert and test methods) Masters at the Zama office. Robert handles all of • Network administrator (knowledge of network the calibration and maintenance of the security and backups) equipment onsite including meters and GCs.

Interviewed Production Engineer Lance Hofer at the Calgary office. Darren gathered the primary data for the GHG calculations and provided it to Bluesource vis Trevor Dillabough.

Met briefly with John Hawkins in the Environmental Health and Safety department. He showed us where the environmental files are stored on the company networks, and with all the staff turnover at Apache/Paramount, is the only person who was involved in GHG reporting in the past.

Feb 8 Review data management systems Observed SCADA that shows labelled PFDs,

8:30-12:00 Emphasis on measured data: metering, GCs, equipment etc. Feb 22 • How is it collected (meter or scale ID and type)? 9:00-10:00 • How are readings transferred to database system There’s automatic data capture from the meters (manual transcriptions or automatic transfers)? and GCs. The metered data from SCADA is dumped into Avocet (it’s compatible). The GC data

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Date & Time Task Notes Follow-up

• What is the name of the database where is sent by the field operators to Avocet support measured data are stored? personnel and they enter it into Avocet. Irregular • Who controls the database (department)? operations are tracked in flare spreadsheets • Are there QA/QC procedures in place (mentioned above). Compressor utilization is (calibration/verifications, daily or monthly tracked in CPO software; Productivity Optimizer reconciliation for management review, procedures Gas Emissions Detailed Report. This is sent to for missing or erroneous data)? Caterpillar; Caterpillar estimates final compressor • How does data get from the primary database into energy usage. Sales gas analyses are obtained the emissions calculations? from TCPL; these are used for production accounting so they are available anyway; they are then also provided for the GHG reporting.

Production Operations department maintains Avocet. IT maintains the SCADA software. CPO is maintained by Martin Lamothe. Environment data is only accessible to EHS staff, which are only 2-3 people.

The instruments appear to be calibrated regularly; Robert at the field office was able to produce records for regular maintenance and calibration of the requested meters and GCs.

QA/QC checks are in place. Production operation staff check the meter data that is dumped into Avocet, and also the GC data which is sent from the field. The field op leads (Logan and his counterpart Brian Gibbs) check the flare spreadsheets onsite. There is a system to add notes when any bad data is identified and/or modified.

Lance and Trevor gather the data from Avocet, production operation staff, reservoir engineer

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Date & Time Task Notes Follow-up

staff, CPO staff, and provide it to Blue Source. Blue Source transfers the data to the emissions calculator, and has QA checks in place.

Feb 8 Cross-check selected GHG data against primary databases From Logan: 8:30-12:00 Copies of the flare log spreadsheets; these are not Feb 22 9:00-10:00 used directly in GHG calculations.

From Lance: FQI-4245 May, Jun, Jul - 2015 Jan, Feb, Mar - 2016, Aug, Sep, Oct - 2017

FQI-4101 Jan, Feb, Mar - all years

FQI-4110 & 1530 Dec 2015 – Nov 2017

Sales gas analyses Mar, Apr, May - all years Acid gas analyses Oct, Nov, Dec - all years

Compressor utilization for electric and fuel gas consumption for nat gas compressors – the files that were compiled by Lance after gathering data

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Date & Time Task Notes Follow-up

from Martin Lamothe and pulling compressor runtime hours from SCADA archives.

Feb 8 Review data protection and security: Everyone at the Zama field office needs to log in

8:30-12:00 • Where are data stored and how is access to access the SCADA systems and networks. Feb 22 controlled? Access there is fairly unrestricted, but many of the 9:00-10:00 • What measures are in place to prevent loss or systems are read-only. IT takes care of backing up corruption of data? systems and would be able to help retrieve files in • Where are emissions calculations and reports case of data loss. Lance has read-only access to stored and how is access controlled? Avocet. The EHS network folder with environment Consider IT/network policies and procedures, password files is highly restricted. protection of directories or individual files, conversion to read-only file types, etc.

Feb 22 Review document retention policy and practices: John Hawkins showed us the EHS network folders;

9:00-10:00 • How/where are GHG emissions reports, while there was other data related to supporting data, and verification reports stored? environmental reporting, there were no files • How is the 7-year retention period enforced? directly associated with the GHG offset project • Demonstrate that reports from previous years are reporting; those are maintained by Paramount’s filed consistently with document retention consultant, Bluesource; this was confirmed by policy/practices. both John and Tooraj Moulai at Bluesource. RWDI did no further follow up with Bluesource on this.

Additional items n/a

Feb 8 Site Visit Close-out Meeting  Discussion led by Jyotsna Kashyap

8:30-12:00  Reviewed follow-up requirements – n/a to field Feb 22 or office staff who were interviewed 9:00-10:00  Reviewed the remaining steps of the verification process – summarized these at field and Calgary office  Reminder that verifiers are not able to advise or consult – n/a to field or office staff who were interviewed

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Date & Time Task Notes Follow-up

 Review RWDI’s control of mark policy – n/a to field or office staff who were interviewed  Discuss verification schedule – summarized these at field and Calgary office

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Table 1: Recalculation Summary Reported Percent Source Recalculated Emissions (Tonnes) Emissions Difference (Tonnes)

CO2 CH4 N2O CO2e CO2e % B2a Flaring at Capture Site 52,997 1.39 1.24 53,400 53,398 <0.1%

B13 Fuel Extraction and Processing 2,728 53.34 0.14 4,105 4,104 <0.1%

P21 Fuel Extraction and Processing 1,365 26.69 0.07 2,054 2,054 <0.1%

P12 Injection Gas Transportation 4,995 0 0 4,995 5,031 0.71% P14 Injection Unit Operation 19,680 0.35 0.31 19,783 19,761 -0.11% P15 Flaring at Injection Site 6,832 0.12 0.10 6,866 6,865 <0.1% Total Emissions Reductions 22,853 27.57 0.89 23,806 23,790 -0.07% Table 2: Recalculation of source B2a Emissions

Sulsim SRU CH4 Emissions N2O Emissions Acid gas volume from CO2 Emissions from CH4 Emissions from N2O Emissions from LHV Ratio of fuel Fuel gas consumed at CO2 Emissions from Total Emission from Total Emission from fuel Molar Ratio LHV tail gas LHV fuel gas from Fuel Gas from Fuel Gas Total B2a Emissions FQI-4245 Tail Gas Combustion Tail Gas Combustion Tail Gas Combustion combined gas to tail gas incinerator Fuel Gas Combustion tail gas combustion gas combustion (Output/Inpu Combustion Combustion t)

VOLAG CO2TG CH4TG N2OTG LHVC LHVTG LHVFG FG:TG FGINCIN CO2FG CH4FG N2OFG TG:AG

3 3 3 3 3 3 3 e m kg CO2 kg CH4 kg N2O MJ/m MJ/m MJ/m - e m kg CO2 kg CH4 kg N2O Tonnes CO2E Tonnes CO2E Tonnes CO2E 2.27

January 156.22 234,957.90 13.15 11.73 20 0.34 36.61 1.18 420.78 869,493.27 15.57 13.89 238.78 874.02 1,112.80

February 143.02 215,104.85 12.04 10.73 20 0.34 36.39 1.20 390.23 798,789.13 14.44 12.88 218.60 802.99 1,021.59 March 151.02 227,137.00 12.71 11.34 20 0.34 36.18 1.22 417.49 848,345.46 15.45 13.78 230.83 852.84 1,083.67 April 163.26 245,546.20 13.74 12.25 20 0.34 36.22 1.21 450.31 916,708.32 16.66 14.86 249.54 921.55 1,171.09 May 389.27 585,469.62 32.76 29.22 20 0.34 36.24 1.21 1,071.91 2,182,044.41 39.66 35.37 595.00 2,193.58 2,788.57

2015 June 331.31 498,296.65 27.88 24.87 20 0.34 36.33 1.20 907.43 1,851,108.27 33.58 29.95 506.40 1,860.87 2,367.28 July 352.48 530,136.74 29.66 26.46 20 0.34 36.32 1.21 966.06 1,969,023.90 35.74 31.88 538.76 1,979.42 2,518.18 August 324.00 487,302.27 27.27 24.32 20 0.34 36.38 1.20 884.46 1,806,905.27 32.73 29.19 495.23 1,816.42 2,311.65 September 290.95 437,594.43 24.49 21.84 20 0.34 36.29 1.21 798.66 1,626,244.82 29.55 26.36 444.71 1,634.84 2,079.55 October 331.17 498,086.09 27.87 24.86 20 0.34 36.32 1.20 907.34 1,849,776.68 33.57 29.94 506.19 1,859.54 2,365.73 November 275.32 414,086.61 23.17 20.66 20 0.34 36.37 1.20 752.29 1,536,067.53 27.83 24.83 420.82 1,544.16 1,964.99 December 240.36 361,506.09 20.23 18.04 20 0.34 36.28 1.21 660.33 1,345,285.98 24.43 21.79 367.39 1,352.39 1,719.78 January 248.88 374,320.34 20.94 18.68 20 0.34 36.33 1.20 681.74 1,390,662.80 25.22 22.50 380.41 1,398.00 1,778.41 February 239.34 359,971.99 20.14 17.96 20 0.34 36.29 1.21 657.08 1,338,168.74 24.31 21.68 365.83 1,345.24 1,711.07 March 216.41 325,484.83 18.21 16.24 20 0.34 36.30 1.21 593.82 1,209,429.16 21.97 19.60 330.78 1,215.82 1,546.60 April 230.88 347,247.99 19.43 17.33 20 0.34 36.33 1.20 632.17 1,289,297.32 23.39 20.86 352.90 1,296.10 1,649.00 May 215.92 324,747.86 18.17 16.21 20 0.34 35.70 1.25 614.98 1,229,433.40 22.75 20.29 330.03 1,236.05 1,566.08 June 234.09 352,075.89 19.70 17.57 20 0.34 36.27 1.21 643.57 1,309,139.63 23.81 21.24 357.80 1,316.06 1,673.87 2016 July 223.96 336,840.18 18.85 16.81 20 0.34 36.30 1.21 614.60 1,251,475.72 22.74 20.28 342.32 1,258.09 1,600.41 August 220.10 331,034.66 18.52 16.52 20 0.34 36.31 1.21 603.65 1,229,655.68 22.34 19.92 336.42 1,236.15 1,572.57 September 161.44 242,808.89 13.59 12.12 20 0.34 35.70 1.25 459.90 919,150.38 17.02 15.18 246.76 924.10 1,170.86 October 177.19 266,497.19 14.91 13.30 20 0.34 36.22 1.21 488.65 992,654.29 18.08 16.13 270.83 997.91 1,268.74 November 220.05 330,959.46 18.52 16.52 20 0.34 36.28 1.21 604.64 1,230,711.90 22.37 19.95 336.34 1,237.22 1,573.56 December 168.54 253,487.42 14.18 12.65 20 0.34 36.29 1.21 462.78 942,703.81 17.12 15.27 257.61 947.68 1,205.29 January 204.09 306,955.31 17.18 15.32 20 0.34 36.46 1.19 554.43 1,136,417.89 20.51 18.30 311.95 1,142.38 1,454.33 February 168.10 252,825.65 14.15 12.62 20 0.34 36.37 1.20 459.40 938,065.70 17.00 15.16 256.94 943.01 1,199.95 March 125.88 189,325.96 10.59 9.45 20 0.34 36.52 1.19 340.80 699,590.53 12.61 11.25 192.41 703.26 895.66 April 151.64 228,069.50 12.76 11.38 20 0.34 35.64 1.26 433.72 863,488.77 16.05 14.31 231.78 868.16 1,099.94 May 230.89 347,263.03 19.43 17.33 20 0.34 36.27 1.21 634.78 1,291,728.21 23.49 20.95 352.91 1,298.56 1,651.47 2017 June 190.82 286,996.97 16.06 14.32 20 0.34 36.29 1.21 523.86 1,066,849.04 19.38 17.29 291.67 1,072.49 1,364.15 July 162.64 244,613.71 13.69 12.21 20 0.34 36.33 1.20 445.43 908,395.12 16.48 14.70 248.59 913.19 1,161.78 August 149.23 224,444.81 12.56 11.20 20 0.34 36.45 1.20 405.69 831,262.83 15.01 13.39 228.10 835.63 1,063.72 September 91.13 137,061.28 7.67 6.84 20 0.34 36.04 1.23 254.18 513,874.19 9.40 8.39 139.29 516.61 655.90 October 144.51 217,345.84 12.16 10.85 20 0.34 36.29 1.21 396.82 808,979.15 14.68 13.10 220.88 813.25 1,034.13 November 139.95 210,487.51 11.78 10.50 20 0.34 36.48 1.19 379.73 779,858.99 14.05 12.53 213.91 783.94 997.86 Total 2015-2017 11,226,090.76 628.14 560.23 Total 2015-2017 41,770,786.32 759.01 676.95 Tables 3a & 3b: Recalculation of source B13 Emissions

Natural Gas Extraction Natural Gas Extraction & Natural Gas Extraction & Emissions Factor & Processing (CO2) Processing (CH4) Processing (N2O)

Notation NXPCO2EF NXPCH4EF NXPN2OEF

3 3 3 Units kg CO2/m kg CH4/m kg N2O/m

Carbon Offset Emission Carbon Offset Emission Carbon Offset Emission Factors Handbook, Factors Handbook, Version Factors Handbook, Version Source Version 1.0, March 2015 1.0, March 2015 1.0, March 2015 Factor - Extraction 0.043 0.0023 0.000004 Factor - Processing 0.090 0.0003 0.000003 Factor - Extraction & Processing 0.133 0.0026 0.000007

CO2 Emissions from Fuel CH4 Emissions from Fuel N2O Emissions from Fuel gas consumed at Gas Extraction & Gas Extraction & Fuel Gas Extraction & Total Emissions incinerator Processing Processing Processing

FGINCIN CO2NXP CH4NXP N2ONXP

3 m kg CO2 kg CH4 kg N2O CO2E Tonnes January 420780.66 55963.83 1094.03 2.95 84.19 February 390,229.90 51,900.58 1,014.60 2.73 78.08 March 417,491.76 55,526.40 1,085.48 2.92 83.53 April 450,312.80 59,891.60 1,170.81 3.15 90.10 May 1,071,907.95 142,563.76 2,786.96 7.50 214.47 June 907,433.70 120,688.68 2,359.33 6.35 181.56 2015 July 966,063.19 128,486.40 2,511.76 6.76 193.30 August 884,462.10 117,633.46 2,299.60 6.19 176.97 September 798,660.16 106,221.80 2,076.52 5.59 159.80 October 907,344.58 120,676.83 2,359.10 6.35 181.55 November 752,293.08 100,054.98 1,955.96 5.27 150.52 December 660,329.54 87,823.83 1,716.86 4.62 132.12 January 681,739.96 90,671.41 1,772.52 4.77 136.41 February 657,084.75 87,392.27 1,708.42 4.60 131.47 March 593,822.32 78,978.37 1,543.94 4.16 118.82 April 632,166.41 84,078.13 1,643.63 4.43 126.49 May 614,978.72 81,792.17 1,598.94 4.30 123.05 June 643,569.49 85,594.74 1,673.28 4.50 128.77 2016 July 614,601.73 81,742.03 1,597.96 4.30 122.97 August 603,651.70 80,285.68 1,569.49 4.23 120.78 September 459,901.67 61,166.92 1,195.74 3.22 92.02 October 488,649.16 64,990.34 1,270.49 3.42 97.77 November 604,636.75 80,416.69 1,572.06 4.23 120.98 December 462,777.09 61,549.35 1,203.22 3.24 92.60 January 554,427.22 73,738.82 1,441.51 3.88 110.93 February 459,395.84 61,099.65 1,194.43 3.22 91.92 March 340,798.11 45,326.15 886.08 2.39 68.19 April 433,723.42 57,685.22 1,127.68 3.04 86.78 May 634,780.04 84,425.75 1,650.43 4.44 127.01 2017 June 523,863.44 69,673.84 1,362.04 3.67 104.82 July 445,428.87 59,242.04 1,158.12 3.12 89.12 August 405,685.38 53,956.16 1,054.78 2.84 81.17 September 254,183.99 33,806.47 660.88 1.78 50.86 October 396,824.93 52,777.72 1,031.74 2.78 79.40 November 379,733.11 50,504.50 987.31 2.66 75.98 Tables 4a & 4b: Recalculation of source P21 Emissions Yr Mo Fuel gas volume e3m3 Emission tonnes K210+K420+K430 compressor EOR compressor flare CO2 CH4 N2O 20151 275.94 50.18 43.37 0.85 0.0023 20152 244.92 61.07 40.70 0.80 0.0021 20153 226.42 55.35 37.48 0.73 0.0020 20154 322.38 28.04 46.61 0.91 0.0025 20155 318.62 26.83 45.94 0.90 0.0024 20156 296.51 36.38 44.27 0.87 0.0023 20157 273.61 33.66 40.87 0.80 0.0022 20158 317.81 36.86 47.17 0.92 0.0025 20159 316.16 43.33 47.81 0.93 0.0025 201510 340.53 40.86 50.72 0.99 0.0027 201511 266.82 31.01 39.61 0.77 0.0021 201512 240.94 18.45 34.50 0.67 0.0018 20161 273.73 17.47 38.73 0.76 0.0020 20162 264.52 5.55 35.92 0.70 0.0019 20163 224.44 29.54 33.78 0.66 0.0018 20164 207.96 34.57 32.26 0.63 0.0017 20165 237.30 30.27 35.59 0.70 0.0019 20166 266.38 34.86 40.06 0.78 0.0021 20167 277.43 30.06 40.90 0.80 0.0022 20168 265.30 42.83 40.98 0.80 0.0022 20169 279.12 11.74 38.68 0.76 0.0020 201610 325.71 18.93 45.84 0.90 0.0024 201611 307.80 18.68 43.42 0.85 0.0023 201612 291.33 11.63 40.29 0.79 0.0021 20171 294.89 11.33 40.73 0.80 0.0021 20172 251.89 20.45 36.22 0.71 0.0019 20173 241.61 14.47 34.06 0.67 0.0018 20174 251.28 12.87 35.13 0.69 0.0018 20175 238.05 22.83 34.70 0.68 0.0018 20176 253.12 16.23 35.82 0.70 0.0019 20177 253.21 22.73 36.70 0.72 0.0019 20178 260.99 15.03 36.71 0.72 0.0019 20179 134.87 13.98 19.80 0.39 0.0010 201710 247.23 16.73 35.11 0.69 0.0018 201711 248.56 13.87 34.90 0.68 0.0018 Total 2015-2017 1365.38 26.69 0.0719

Fuel extract/process EF kg/m3 CO2 CH4 N2O 0.133 0.0026 0.000007 Tables 5a, 5b & 5c: Recalculation of source P12 Emissions K220+K240 kWh from K220+K240 kWh using Yr Mo Total monthly kWh K220 Yr Mo Bluesource alternate extrapolation 2016 1 0.00 2015 1 208848.4586 196,746.81 2016 2 0.00 2015 2 183496.4058 190,674.15 2016 3 0.00 2015 3 206606.2645 194,354.55 2016 4 0.00 2015 4 205074.1123 200,013.17 2016 5 0.00 2015 5 309359.1231 303,984.47 2016 6 2,868.90 2015 6 275177.4528 277,301.57 2016 7 0.00 2015 7 293491.2876 287,054.63 2016 8 0.00 2015 8 281202.3389 273,943.20 2016 9 43,624.62 2015 9 258360.9967 258,761.55 2016 10 188,911.85 2015 10 284306.9154 277,255.56 2016 11 209,854.91 2015 11 251809.6726 251,538.77 2016 12 74,740.92 2015 12 245154.7561 235,483.02

Total 2017 1 201,166.48 2015- 7,860,690.35 7,804,913.99 2017

2017 2 162,225.27 2017 3 220,209.88 2017 4 2,224.79 2017 5 0.00 2017 6 12,724.14 2017 7 202,587.31 2017 8 161,227.74 2017 9 60,989.23 2017 10 203,183.43 2017 11 193,576.88 Yr Mo Total monthly kWh K240 2016 1 252,285.77 2016 2 238,782.68 2016 3 252,082.59 2016 4 234,574.24 2016 5 250,854.45 2016 6 225,080.47 2016 7 215,781.77 2016 8 238,921.41 2016 9 124,243.81 2016 10 0.00 2016 11 34.35 2016 12 124,608.21 2017 1 0.00 2017 2 6,592.58 2017 3 0.00 2017 4 184,055.02 2017 5 220,087.05 2017 6 209,851.57 2017 7 0.00 2017 8 33,510.92 2017 9 106,339.32 2017 10 0.00 2017 11 0.00 Table 6: Recalculation of source P14 Emissions

Yr Mo K210+K420+K430 fuel m3 EF kg/m3 Emissions tonnes

CO2e CO2 CH4 N2O CO2 CH4 N2O CO2e' combined 2015 1 275,938.09 2.07 0.000037 0.000033 570.19 0.01 0.01 20152 244,921.32 2.05 501.35 0.01 0.01 20153 226,423.61 2.03 460.09 0.01 0.01 20154 322,382.51 2.04 656.28 0.01 0.01 20155 318,617.58 2.04 648.60 0.01 0.01 20156 296,507.13 2.04 604.86 0.01 0.01 20157 273,612.68 2.04 557.68 0.01 0.01 20158 317,811.31 2.04 649.27 0.01 0.01 20159 316,155.06 2.04 643.76 0.01 0.01 201510 340,527.49 2.04 694.22 0.01 0.01 201511 266,818.87 2.04 544.80 0.01 0.01 201512 240,935.35 2.04 490.86 0.01 0.01 20161 273,727.17 2.04 558.37 0.01 0.01 20162 264,523.81 2.04 538.71 0.01 0.01 20163 224,444.01 2.04 457.12 0.01 0.01 20164 207,962.82 2.04 424.14 0.01 0.01 20165 237,298.60 2.00 474.39 0.01 0.01 20166 266,379.29 2.03 541.86 0.01 0.01 20167 277,426.45 2.04 564.91 0.01 0.01 20168 265,303.35 2.04 540.43 0.01 0.01 20169 279,123.76 2.00 557.85 0.01 0.01 201610 325,709.26 2.03 661.65 0.01 0.01 201611 307,799.92 2.04 626.51 0.01 0.01 201612 291,325.59 2.04 593.45 0.01 0.01 20171 294,890.68 2.05 604.44 0.01 0.01 20172 251,890.00 2.04 514.35 0.01 0.01 20173 241,605.29 2.05 495.97 0.01 0.01 20174 251,282.66 1.99 500.27 0.01 0.01 20175 238,052.14 2.03 484.42 0.01 0.01 20176 253,116.81 2.04 515.47 0.01 0.01 20177 253,211.32 2.04 516.39 0.01 0.01 20178 260,992.29 2.05 534.78 0.01 0.01 20179 134,865.46 2.02 272.65 0.00 0.00 201710 247,227.56 2.04 504.01 0.01 0.01 201711 248,556.97 2.05 510.46 0.01 0.01 Total - Compressors 19,014.57 0.35 0.31 - 19,115.03 Total - Fuel Gas, Propane & Electric 181.32 0.00 0.01 484.56 667.61 Heaters

Total 2015-2017 19,195.89 0.35 0.31 484.56 19,782.65 Table 7: Recalculation of source P15 Emissions To EOR Yr Mocompressor flare HP/LP flare vol e3m3 Raw gas EF kg/m3Fuel gas EF kg/m3 Vent gas EF kg/m3 Emission tonnes vol e3m3

EOR compressor flare raw gas EOR compressor flare fuel gas HP/LP flare

Raw gas Fuel gas Vent gas CO2 CH4 N2O CO2 CH4 N2O CO2 CH4 N2O CO2 CH4 N2O CO2 CH4 N2O CO2 CH4 N2O

2015 1 14.52 50.18 5.00 1.41 0.000037 0.000033 2.07 0.000037 0.000033 2.66 0.000037 0.000033 20.54 0.0005 0.0005 103.69 0.0019 0.0017 13.32 0.0002 0.0002 2015 2 9.83 61.07 17.64 1.48 2.05 14.51 0.0004 0.0003 125.02 0.0023 0.0020 46.97 0.0007 0.0006 2015 3 9.85 55.35 12.12 1.53 2.03 15.03 0.0004 0.0003 112.47 0.0020 0.0018 32.28 0.0004 0.0004 2015 4 13.69 28.04 16.60 1.52 2.04 20.87 0.0005 0.0005 57.09 0.0010 0.0009 44.20 0.0006 0.0005 2015 5 14.86 26.83 17.76 1.51 2.04 22.51 0.0005 0.0005 54.61 0.0010 0.0009 47.31 0.0007 0.0006 2015 6 10.37 36.38 30.02 1.47 2.04 15.27 0.0004 0.0003 74.22 0.0013 0.0012 79.94 0.0011 0.0010 2015 7 6.27 33.66 10.07 1.49 2.04 9.35 0.0002 0.0002 68.60 0.0012 0.0011 26.82 0.0004 0.0003 2015 8 8.77 36.86 9.54 1.47 2.04 12.90 0.0003 0.0003 75.30 0.0014 0.0012 25.40 0.0004 0.0003 2015 9 9.89 43.33 20.18 1.50 2.04 14.82 0.0004 0.0003 88.23 0.0016 0.0014 53.75 0.0007 0.0007 201510 8.46 40.86 21.19 1.48 2.04 12.56 0.0003 0.0003 83.29 0.0015 0.0013 56.43 0.0008 0.0007 201511 18.02 31.01 22.90 1.59 2.04 28.56 0.0007 0.0006 63.32 0.0011 0.0010 60.98 0.0008 0.0008 201512 34.15 18.45 21.91 1.52 2.04 51.87 0.0013 0.0011 37.59 0.0007 0.0006 58.33 0.0008 0.0007 2016 1 45.82 17.47 26.01 1.52 2.04 69.66 0.0017 0.0015 35.64 0.0006 0.0006 69.26 0.0010 0.0009 2016 2 10.44 5.55 16.61 1.51 2.04 15.75 0.0004 0.0003 11.30 0.0002 0.0002 44.24 0.0006 0.0005 2016 3 46.19 29.54 23.36 1.54 2.04 71.00 0.0017 0.0015 60.16 0.0011 0.0010 62.21 0.0009 0.0008 2016 4 53.84 34.57 67.92 1.52 2.04 81.83 0.0020 0.0018 70.51 0.0013 0.0011 180.87 0.0025 0.0022 2016 5 36.75 30.27 72.48 1.59 2.00 58.54 0.0014 0.0012 60.51 0.0011 0.0010 193.01 0.0027 0.0024 2016 6 59.75 34.86 98.85 1.59 2.03 94.95 0.0022 0.0020 70.91 0.0013 0.0012 263.22 0.0037 0.0033 2016 7 38.35 30.06 75.55 1.53 2.04 58.60 0.0014 0.0013 61.21 0.0011 0.0010 201.18 0.0028 0.0025 2016 8 52.65 42.83 48.97 1.55 2.04 81.57 0.0019 0.0017 87.25 0.0016 0.0014 130.42 0.0018 0.0016 2016 9 14.97 11.74 80.54 1.63 2.00 24.46 0.0006 0.0005 23.46 0.0004 0.0004 214.46 0.0030 0.0027 201610 25.22 18.93 83.80 1.57 2.03 39.57 0.0009 0.0008 38.45 0.0007 0.0006 223.16 0.0031 0.0028 201611 26.52 18.68 59.83 1.47 2.04 39.11 0.0010 0.0009 38.02 0.0007 0.0006 159.33 0.0022 0.0020 201612 15.16 11.63 57.42 1.52 2.04 22.98 0.0006 0.0005 23.69 0.0004 0.0004 152.89 0.0021 0.0019 2017 1 16.16 11.33 71.26 1.43 2.05 23.09 0.0006 0.0005 23.22 0.0004 0.0004 189.76 0.0026 0.0024 2017 2 29.62 20.45 68.19 1.42 2.04 42.08 0.0011 0.0010 41.76 0.0008 0.0007 181.58 0.0025 0.0023 2017 3 19.25 14.47 58.03 1.41 2.05 27.08 0.0007 0.0006 29.70 0.0005 0.0005 154.53 0.0021 0.0019 2017 4 15.99 12.87 55.53 1.38 1.99 22.13 0.0006 0.0005 25.62 0.0005 0.0004 147.88 0.0021 0.0018 2017 5 31.74 22.83 43.11 1.46 2.03 46.46 0.0012 0.0010 46.46 0.0008 0.0008 114.79 0.0016 0.0014 2017 6 22.47 16.23 30.21 1.49 2.04 33.58 0.0008 0.0007 33.05 0.0006 0.0005 80.44 0.0011 0.0010 2017 7 30.11 22.73 23.72 1.46 2.04 43.94 0.0011 0.0010 46.35 0.0008 0.0008 63.18 0.0009 0.0008 2017 8 22.54 15.03 36.71 1.45 2.05 32.64 0.0008 0.0007 30.80 0.0006 0.0005 97.76 0.0014 0.0012 2017 9 20.31 13.98 32.11 1.61 2.02 32.73 0.0008 0.0007 28.26 0.0005 0.0005 85.50 0.0012 0.0011 201710 23.35 16.73 11.46 1.46 2.04 33.99 0.0009 0.0008 34.11 0.0006 0.0006 30.51 0.0004 0.0004 201711 17.14 13.87 35.23 1.46 2.05 25.07 0.0006 0.0006 28.48 0.0005 0.0005 93.81 0.0013 0.0012

Total 2015- 1,259.59 0.0308 0.0275 1,892.38 0.0344 0.0306 3,679.71 0.0511 0.0456 2017 Tables 8a & 8b: Sales Gas Summary

Natural Gas Natural Gas Yr Mo CO2 EF kg/m3 LHV MJ/m3 Combustion Combustion

(CH4) (N2O)

2015 1 2.07 36.61 NGCH4EF NGN2OEF 3 3 2015 2 2.05 36.39 kg CH4/m kg N2O/m 2015 3 2.03 36.18 0.000037 0.000033

2015 4 2.04 36.22

2015 5 2.04 36.24

2015 6 2.04 36.33 2015 7 2.04 36.32 2015 8 2.04 36.38 2015 9 2.04 36.29 2015 10 2.04 36.32 2015 11 2.04 36.37 2015 12 2.04 36.28 2016 1 2.04 36.33 2016 2 2.04 36.29 2016 3 2.04 36.30 2016 4 2.04 36.33 2016 5 2.00 35.70 2016 6 2.03 36.27 2016 7 2.04 36.30 2016 8 2.04 36.31 2016 9 2.00 35.70 2016 10 2.03 36.22 2016 11 2.04 36.28 2016 12 2.04 36.29 2017 1 2.05 36.46 2017 2 2.04 36.37 2017 3 2.05 36.52 2017 4 1.99 35.64 2017 5 2.03 36.27 2017 6 2.04 36.29 2017 7 2.04 36.33 2017 8 2.05 36.45 2017 9 2.02 36.04 2017 10 2.04 36.29 2017 11 2.05 36.48 Table 9: Acid Gas Summary Yr Mo CO2 EF kg/m3 LHV MJ/m3 2015 1 1.41 7.12 2015 2 1.48 5.88 2015 3 1.53 6.27 2015 4 1.52 9.10 2015 5 1.51 9.55 2015 6 1.47 7.29 2015 7 1.49 6.24 2015 8 1.47 6.77 2015 9 1.50 6.73 2015 10 1.48 6.48 2015 11 1.59 9.65 2015 12 1.52 7.98 2016 1 1.52 6.80 2016 2 1.51 6.45 2016 3 1.54 6.23 2016 4 1.52 6.23 2016 5 1.59 10.07 2016 6 1.59 8.85 2016 7 1.53 6.86 2016 8 1.55 6.51 2016 9 1.63 12.41 2016 10 1.57 7.67 2016 11 1.47 7.16 2016 12 1.52 7.71 2017 1 1.43 7.99 2017 2 1.42 8.81 2017 3 1.41 9.19 2017 4 1.38 10.93 2017 5 1.46 8.12 2017 6 1.49 7.44 2017 7 1.46 7.95 2017 8 1.45 9.14 2017 9 1.61 11.15 2017 10 1.46 11.17 2017 11 1.46 13.17 Tables 10a, 10b & 10c: Tail Gas Summary

Tail Gas Composition - Sulsim Report (Sulphur Experts) CO2 EF LHV report_mnth H2_pct Ar_pct n2_pct c1_pct co_pct co2_pct c2_pct h2s_pct cos_pct so2_pct cs2_pct H2O c3_pct iC4_pct nC4_pct iC5+_pct SUM (t/e3m3) (MJ/m3) Dec, 2013 0.90% 0.54% 45.30% 0.00% 1.06% 34.33% 0.00% 0.30% 0.06% 0.15% 0.07% 17.27% 0.00% 0.00% 0.00% 0.00% 99.98% 0.66 0.34 Source: Sulphur Experts (Feb, 2018), "Apache SRU Simulation Report February 2018 "

Source: From Gas Tail Gas Tail Gas Net Heating Value (LHV) Processors Association Combustion Combustion (MJ/m3) (2009) GPA Standard (CH4) (N2O) LHV 2145-09: Table of Component: 3 (MJ/m ) Physical Properties for TGCH4EF TGN2OEF 3 3 H2 10.22 Hydrocarbons and kg CH4/m kg N2O/m Other Compounds of Carbon Offset Carbon Offset Interest to the Natural Emission Emission Gas Industry . GPA, Factors Factors Tulsa. Handbook, Handbook, H2S 21.91 Version 1.0, Version 1.0, March 2015, March 2015, Table 6, Table 6, "Industrial " "Industrial " C1 33.95 0.000037 0.000033 C2 60.43 C3 86.42 Verified from reference Carbon Offset Emission Factors Handbook, Version 1.0, March 2015, Table 6, "Industrial". iC4 112.00 nC4 112.40 iC5 138.10 nC5 138.40 C6+ 164.39 C7+ 190.39 nC8 216.38 CO 12.03 COS 29.25 CS2 44.90