annual emission monitoring plan

8/12/2019 Annual Emission Monitoring Plan

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219727512.xls.ms_office

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Black bold text:Blue italic text:

Black italic text

Column heading may include comments boxes that include additional guidance

EU Websites:

EU-Legislation:

EU ETS general: http://ec.europa.eu/clima/policies/ets/index_en.htm

Monitoring and Reporting in the EU ETS:

Competent Authority Websites:

www.environment-agency.gov.uk/emissionstrading

http://www.sepa.org.uk/climate_change/solutions/eu_emissions_trading_system.aspx

http://www.doeni.gov.uk/niea/pollution-home/emissionstrading.htm

http://og.decc.gov.uk/en/olgs/cms/environment/leg_guidance/eu_ets/eu_ets.aspx

Competent Authority Contacts:

[email protected]

[email protected]

[email protected]

[email protected]

In several fields you can choose from predefined inputs. For selecting from such a "drop-down list" either click with the mouse on the small arrow

appearing at the right border of the cell, or press "Alt-CursorDown" when you have selected the cell. Some fields allow you to input your own text even ifsuch drop-down list exists. This is the case when drop-down lists contain empty list entries.

Member States may require the operator and aircraft operator to use electronic templates or specific file formats for submission of monitoring plans

and changes to the monitoring plan, as well as for submission of annual emissions reports, tonne-kilometre data reports, verification reports andimprovement reports.

Those templates or file format specifications established by the Member States shall, at least, contain the information contained in electronic

templates or file format specifications published by the Commission.

http://ec.europa.eu/clima/news/articles/news_2011121401_en.htm

The monitoring plan shall consist of a detailed, complete and transparent documentation of the monitoring methodology of a specific installation [or

aircraft operator] and shall contain at least the elements laid down in Annex I.

How to use this file:It is recommended that you go through the file from start to end. In Section 7(d) you will be asked to select which of the monitoring approaches you wish to

The Directive can be downloaded from:

This template has been produced to help UK operators to prepare for submission of Phase III monitoring plans. Operators of UK onshore installations will

need to complete a Phase III monitoring plan in ETSWAP once the online system is available so this template has been designed to assist operators in

collating the information that will need to be entered into ETSWAP. It will not be possible to automatically upload this form into ETSWAP but much of the

data and text will be able to be copied and pasted into the online ETSWAP monitoring plan, it is also not necessary for onshore operators to submit this

form to their Competent Authority. Updates on progress with ETSWAP will be sent out by the appropriate UK Regulators.

The template has been developed to accommodate the minimum content of a monitoring plan required by the MRR, operators should therefore refer to the

MRR and any associated guidance when completing.

Directive 2003/87/EC as amended by Directive 2009/29/EC (hereinafter "the (revised) EU ETS Directive") requires operators of installations which are

included in the European Greenhouse Gas Emission Trading Scheme (the EU ETS) to hold a valid GHG emission permit issued by the relevant

Competent Authority and to monitor and report their emissions, and have the reports verified by an independent and accredited verifier.

Furthermore, Article 74(1) states:

Colour codes and fonts:

EUETS PHASE III ANNUAL EMISSIONS MONITORING PLAN

Introduction to this form

Guidelines and conditions

This file provides a representation of the information that will need to be entered into the ETSWAP online monitoring plan for UK onshore installations. The

template has been designed to incorporate the requirements for the minimum content of monitoring plans defined in Annex I of the MRR plus requirements

to assist the operator in demonstrating compliance with the MRR.

All Commission guidance documents on the Monitoring and Reporting Regulation will be published at the link below as they become available:

http://ec.europa.eu/clima/policies/ets/monitoring/index_en.htm

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2003L0087:20090625:EN:PDF

Article 12 of the MRR sets out specific requirements for the content and submission of the monitoring plan and its updates. Article 12 outlines the

importance of the Monitoring plan as follows:

The Monitoring and Reporting Regulation (Commission Regulation (2012) xxxx/EU) (hereinafter the "MRR"), defines further requirements for monitoring

and reporting. The MRR can be downloaded from:

This is set template text.

This text gives further explanations/guidance.

http://ec.europa.eu/clima/policies/ets/monitoring/index_en.htm

Yellow fields are input fields

Other than this introductory worksheet there is no further protection enabled so users may add rows to tables where needed. The print layout has been set

initially though it may be necessary to review this once the form is completed. Some pages may also be easier to read when printed on A3.

Information sources:

http://eur-lex.europa.eu/en/index.htm

This text provides examples for inputs in tables
http://www.environment-agency.gov.uk/emissionstradinghttp://og.decc.gov.uk/en/olgs/cms/environment/leg_guidance/eu_ets/eu_ets.aspxmailto:[email protected]:[email protected]:[email protected]://ec.europa.eu/clima/news/articles/news_2011121401_en.htmhttp://ec.europa.eu/clima/policies/ets/monitoring/index_en.htmhttp://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2003L0087:20090625:EN:PDFhttp://ec.europa.eu/clima/policies/ets/monitoring/index_en.htmhttp://eur-lex.europa.eu/en/index.htmhttp://eur-lex.europa.eu/en/index.htmhttp://ec.europa.eu/clima/policies/ets/monitoring/index_en.htmhttp://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2003L0087:20090625:EN:PDFhttp://ec.europa.eu/clima/policies/ets/monitoring/index_en.htmhttp://ec.europa.eu/clima/news/articles/news_2011121401_en.htmmailto:[email protected]:[email protected]:[email protected]://og.decc.gov.uk/en/olgs/cms/environment/leg_guidance/eu_ets/eu_ets.aspxhttp://www.environment-agency.gov.uk/emissionstrading


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CONTENTS

- please read the introductory information about this form

- this section is to be completed for all installations


- this section is to be completed where emissions are determined by calculation

- this section is to be completed where continuous emissions monitors are used in the determination of CO2 emis

- this section is to be completed where a Fall-back approach is applied under Article 22 of the MRR

- this section is to be completed for determination of N2O emissions from production of nitric, adipic, glyoxal and g

- this section is to be completed for determination of PFC emissions from production or processing of primary alum

- this section includes details on CO2 inherent in fuel, or CO2 transferred out of an installation to a CCS facility


Introduction - PLEASE READ

Identification of the operator

Activities and Emission sources

Calculation approach

Determination of N2O emissions

Determination of PFC emissions

Management

Determination of Transferred CO2

Measurement approach

Fall-back methodology


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1 About the operator

Operator Name

2

(a) What is the name of the installation and the site on which it is located?

Installation name

Site name

(b)

Address Line 1

Address Line 2

City

State/Province/Region

Postcode/ZIP

Country

Local Authority

Grid reference of site main entrance

ABOUT THE OPERATOR

Cheshire

Big Industrial Estate

Competent Authority Environment Agency

EA-ETCO2-9999

ABC Industries Limited

About your installation

These sections are included for your information to allow you to identify the installation that the template relates to. For

existing installations this information will be pre-populated in ETSWAP.

Warrington Cleaning Chemicals

Warrington Site

The installation name should aim to provide information on the main process or purpose of the installation, for example "Corby Cereal

Manufacture". Please avoid using generic names such as "boilerhouse".

Note: To improve the format of installation names existing installation names may be changed during Phase III re-permitting.

Emissions trading permit number

WA1 4HQ

Warrington

What is the address / location of the site of the installation?

UK

High Lane

SJ68168025

Cheshire West and Chester


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3 About the Installation Activities

(a) Please provide a description of the installation and its activities

(b) Please provide the following technical details for each Annex I activity carried out by you at the installation

Total Activity

Capacity

Capacity units

(e.g. MW th,

t d65 MWth

(c)

(d)The operator may submit a simplified monitoring plan for an installation where no nitrous oxide activities are carried out and it can be demonstrated that:

(a) the average verified annual emissions of the installation during the previous trading period was less than 25 000 tonnes CO 2(e) per year, or;

(b) where this data is not available or inappropriate, a conservative estimate shows that emissions for the next 5 years will be less than 25 000 tonnes CO 2(e)

DESCRIPTION OF THE INSTALLATION ACTIVITIES AND EMISSIONS

Annex I Activity

Example:

The installation is a Combined Heat and Power (CHP) plant producing heat and electricity. The installation shares a site with a chemical manufa

which it supplies power and heat. The site is located on Brooking Road on Woodside Industrial Estate 2 miles from the centre of Coventry. A si

the location of the CHP installation is provided with this application.

The main purpose of the site is the manufacture of chemicals, this process is operated by another operator, Cleaning Chemicals Ltd, who also o

activities. The CHP plant, which is operated separately by ABC CHP Ltd, produces heat and electricity and has an aggregate combustion capac

20MW thermal input, which constitutes the regulated activity operated by ABC CHP Ltd. The CHP installation is the only part of the site operated

The CHP plant comprises of two 15MW thermal input gas turbines, two unfired heat recovery boilers and two 6MW thermal input auxiliary boiler

thermal input overall.

The fuels used by the CHP plant are natural gas and gas oil. The combustion of these fuels is the only process operated by ABC CHP Ltd on thto the production of carbon dioxide by the CHP installation.

Provide a brief outline description of the site and the installation and the location of the installation on the site. The description should identify and explain any p

which are not operated by the applicant. The description should also include a non-technical summary of the activities carried out at the installation, briefly des

performed and the technical units used within each activity.

40,000

Note: the above data shall include transferred CO 2, but exclude CO 2stemming from biomass.

Does the installation satisfy the criteria for installations with low emissions (as defined by Article 47 of the MRR)?

Include brief description of installation and activities along lines of the example above.

Combustion

This information should enable categorisation of the installation in accordance with Article 19 of the MRR and should be based on the average verified annual e

previous trading period data OR if this data is not available, or is inappropriate, a conservative estimate of annual average emissions, including transferred CO

from biomass.

Note that capacity in this context means:

- Rated thermal input (for combustion installations), which is defined as the rate at which fuel can be burned at the maximum continuous rating of the installatio

calorific value of the fuel and expressed as megawatts thermal.

- Production capacity for those specified Annex I activities for which production capacity determines ETS eligibility.

http://ec.europa.eu/clima/policies/ets/docs/guidance_interpretation_en.pdf

Please make sure that the installation boundaries are correct and in line with Annex I of the EU ETS Directive. For further information please consult the releva

Commission's Guidance on Interpretation of Annex I. This document can be found under the following link:

AInstallation category

(assigned in accordance with Article 19)

Estimated annual emission from installation

(tonnes)

What is your estimated Total annual emission of CO2equivalent?

Carbon dioxide

Specified Emissions
http://ec.europa.eu/clima/policies/ets/docs/guidance_interpretation_en.pdfhttp://ec.europa.eu/clima/policies/ets/docs/guidance_interpretation_en.pdf


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4

(a)

Emission source ref.

S1, S2,...

S1

S2

S1

S2

S3

S4

S5

(b)

Emission point ref.

EP1, EP2,...

EP1

EP2

EP1

EP2

EP3

EP4

(c)

Source stream ref.

F1, F2, M1...

F1

M1

F1

F2

F3

d

Please insert additional rows if required.

Please provide a summary of the emission source and source stream detailsTo allow the competent authority to fully understand the functioning of your installation please complete the table below to identify the activities, emiss

which correspond to each source stream. The details entered here should be selected from the lists generated in the above tables, if more than one acorresponds please enter for example, S1, S2.

Note: in the ETSWAP online form the details entered here may be selected from auto-populated data generated once the preceeding comparable tab

Biodiesel

Combustion: Other gaseo

Combustion: Other gaseo

Source Stream Description

Heavy fuel oil

Raw meal

Combustion: other

Cement clinker: Kiln

Natural gas

Gas oil



Source

South site boiler stack

Office heating boiler flue

Process drier stack

Please provide the following details for all source streams at the installation

Please provide the following details for all emission points included in the installation

Use the table below to list all relevant emission points (including diffuse emission sources). Please use a consistent format for the Emission Point Re

etc.

Emission Point Description

Stack 1 (main boiler)

Stack 2 (cement clinker kiln)

North site boiler stack

Combustion: Commercial

Use the table below to list all source streams (fuels, materials, products...) that are to be monitored at the installation. Please use a consistent format

Reference such as: F1, F2, F3; for fuels M1, M2, M3 for materials; etc. The Source Stream Type should be selected from the dropdown list and links

applied under the MRR (note full dropdown list has been recreated in column S for reference).

North Site Boilers B1-B3

Use the table below to list the emission sources linked to the regulated activities at the installation. Please use a consistent format for the Emission S

S2, S3, etc.

Emission Source Description

Main boiler

South Site Boiler 1

About your emissions

The MRR (Annex I) requires that monitoring plans include a description of "the installation" and activities to be carried out and monitored, including a

source streams. The information you provide in this template should relate to the Annex I activity(ies) comprised in the installation in question, and sh

installation. You should only include any activities carried out by you in this section and should not include related activities carried out by other oper

The information entered here will be used as reference data that can then be selected in subsequent tables.

Cement clinker kiln

Please provide the following details for all emission sources included in the installation

Domestic heating boiler

South Site Boiler 2

Process drier


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(e)

Emission point ref

(f)

Note in some cases this may be specifically requested by the competent authority.

YES NO

Calculation

Measurement

Fallback approach

Monitoring of N2OMonitorin of PFC

Monitoring transferred/inherent CO2

Please ensure you have completed the relevant sections for each approach selected above then continue to section 11 "Management"

Note: the operator may, subject to competent authority approval, combine measurement and calculation for different sources. The operator is required to e

neither gaps nor double counting of reportable emissions occurs.


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219727512.xls.

5 Calculation

(a)

(b)

Source stream

ref.

Emission

source refs.

Type of measurement device

F1 S1 Turbine meter 1

F1 S2, S3 Turbine meter 1

F1 S4 Turbine meter 1

F2 S1 Su lier invoices 2F3 S5 Su lier invoices 2n/an/a

Please provide a concise description of the calculation approach, including formulae, used to determine your annual e

Natural gas use is monitored via continual metering using three gas meters. MD1 supplies the North Site boiler plant, MD2 suppl

The meters are read monthly and gas use summed to give the annual activity data.

In addition to natural gas, the North Site boilers can also be fired on both gas oil and the process drier runs on a pure biomass (liq

assessment of stock changes. Both source steams currently fall within the category of de minimis source stream.

Default calculation factors are used for all fuels and applied to the activity data to determine the CO2 by calculation: CO2 = Activit

All details on source streams (determination of activity data, determination of calculation factors) are outlined in other sections of t

Please describe the specification and location of the measurement systems to be used for each source stream where e

Provide a description of all measurement devices, including sub-meters and meters used to deduct non-Annex I activities, to be used for each so

Where possible please use a consistent format for the Measurement Device Reference such as MD1 MD2 MD3 etc."Type of measuring instrument" may be selected from the drop-down list, or a more appropriate type may be typed in.

For each measuring instrument please enter the specified uncertainty, including the range this uncertainty is related to, as given in the manufactu

please enter both of them.

The typical use range refers to the range the relevant measuring instrument is usually used in your installation.

Under "Location" you should specify where the meter is found in the installation, and how it is identified in the process flow chart.

In case of gas flow meters please refer to Nm/h if the p/T compensation is integral to the instrument and relate to m measurement units if the p/

instruments.

Measurement Device reference

Example:

The calculation approach used at the installation is done according to the following sequence:

a) for each source stream, where default values for calculation factors are used (natural gas, heavy fuel oil, and all minor source

24(1) is used.

b) for each source stream, where analyses results are used for calculation factors (coal, raw meal), the activity data and calcula

according to Article 24(1). The resulting emissions for each batch are then summed up to the annual emissions value of the souc) In cases b), weighted average calculation factors are determined for reporting.

d) the emissions of all source streams are added up to give the annual emissions of the installation.

For solid fuels, batch metering in accordance with Article 27(2) is used. All other source streams are monitored using continual m

All details on source streams (determination of activity data, determination of calculation factors) are outlined in other sections o

0-500 Nm3/hr

0-100 Nm3/hr

0-1000 Nm3/hrMD1

MD2

CALCULATION OF EMISSIONS

Measurement Range (including

units)

MD3

PO1PO2


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219

(c)

Overall measurement

uncertainty (+/-%)

Standard, Mass Balance or Fall-

back Approach Applied?

Activity

data

Net CV Emis

F1 S1 3.2 Standard Approach 3 2a

F1 S1, S2, S3 1.5 Standard A roach 4 2a

F1 S4 2 Standard A roach 3 2a

F2 S1 10 Standard A roach No tier 2a

F3 S5 10 Standard A roach No tier 2a

(d)

* Note 3: For biomass or mixed fuels the emission factor is the preliminary emission factor, as defined in Definition 35, Article 3 of th

Uncertainty calculations document title and reference: Warrington site ETS uncertainty assessment; EP_002

(ii) Operators may apply a tier one level lower than those referred to in sub paragraph (i) above for Category C installations and up

satisfaction of the competent authority that this is not technically feasible or would lead to unreasonable cost to apply the higher tie

(iii) The competent authority may allow an operator to apply even lower tiers than those referred to in the sub paragraph (ii), with a

competent authority that this is not technically feasible or would lead to unreasonable cost to apply the higher tier and provides an

improvement plan should be referenced in Table 8(e) and provided to the competent authority at the time of submission of this plan

* Note 1: For commercial standard fuels, the minimum tiers listed in Annex V of the MRR may be applied for all activities in all insta

* Note 2: If you are intending to apply a fall-back approach please complete the table below and select "n/a" for the tiers to be app

source streams.

In the table below, please identify the tiers applied against the relevant input data for each source stream a

applied. You are also asked to provide information on the source stream category (MRR Article 26).

(i) The highest tiers as defined in Annex II of the MRR should be used by Category B and C installations to determine the activity d

A installations should apply as a minimum the tiers listed in Annex V.

Source stream

ref.

Emission

source refs.


You must provide evidence to demonstrate compliance with the applied tiers, in accordance with Article 12

Note that in accordance with Article 47(3), installation with low emissions do not have to submit this docum

(iv) For minor source streams operators shall apply the highest tier which is technically feasible and will not lead to unreasonable c

use conservative estimations rather than tiers, unless a defined tier can be achieved without additional effort (MRR Article 26(2)).

(v) Installations with low emissions as identified in section 6(d) may apply as a minimum tier 1 for determining activity data and calc


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e

Source steam

ref.

Emission

source refs.

Parameter

(f)

Source steam

ref.

Emission

source refs.

Parameter

F1 S1 EF

F2 S1 EF

F1, F2 S1, S2, S3, S4 NCVF1, F2 S1, S2, S3, S4 EFF1, F2 S1, S2, S3, S4 OxFF3 S5 NCVF3 S5 EFF3 S5 OxF

(g)

Source steam

ref.

Emission

source refs.

Parameter

F3 S1 Biomass Fraction

M1 S2 Carbon Content

M

All default values used must be set out within the monitoring plan. Where the values change on an annual basis (e.g. national


UK National

Please complete the table below for each parameter where default values are to be used for calculation

Note: for parameters to be determined from analysis, please complete table 5(g).

Please provide justifications for the applied tiers for each major source stream where highest tiers are nFor each major source stream listed in table 5(c) above for which highest tiers are not currently applied you must provide a just

Article 26 of the MRR, this should be submitted with this monitoring plan and referenced below. Where justification is based up

and referenced within the justification below.

Re

UK National Greenhouse Gas Inventory



Tier 1 default value


Please complete the table below for each source stream where calculation factors are to be determined

Tier 1 value taken from Commission list published under

For each source stream, list the methods to be used for analysing fuels and materials for the determination of all relevant calcu

that the laboratory is technically competent in accordance with Article 34 of the MRR.

Method of analysis

(include procedure reference and brief description of me

EN 15440:2011 - some deviations regarding sample size and treatmen

procedure ANA-1234/UBA

EN 15104:2011. See procedure ANA-1233/UBA

Justificat


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h

i

(j)

N/ATitle of procedure

Title of procedure

Brief description of procedure

Description should cover the

essential parameters and

operations performed

Diagram reference (where

applicable)



essential parameters andoperations performed

Post or department responsible

for the procedure and for any data

generated

Reference for procedure


applicable)


applicable)


Please provide details about the written procedures for the above analyses.






for the procedure and for any data

generated

Location where records are kept

N/A

Where a number of procedures are used, please provide details of an overarching procedure which covers the quality assu

together individual analytical methods. Alternatively please provide details of each relevant procedure on a separate shee

Name of IT system used (where

applicable).

List of EN or other standards

applied (where relevant)



Please describe the procedure to be used to revise the appropriateness of the sampling plan.


Please provide details about the procedure covering the sampling plan for the analyses listed in tableThe procedure below should cover the elements of a sampling plan as required by Article 33 of the MRR. A copy of the pr

competent authority with the monitoring plan.

Title of procedure N/A



applicable).


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219727512.xls.ms_o

6

(a)

b

Emission

point ref

MEASUREMENT OF CO2 EMISSIONS

Please provide a concise description of the measurement approach used to determine your annual CO2 emissions in

Measurement of CO2emissions

Note: this section is to be completed for measurement of CO 2emissions, approaches for measurement of N2O or PFCs shall be detailed i

Your description should include what type of instrument(s) are used, whether measurements are carried out under wet or dry conditions; th

calibrat ion factors required for QAL2 procedures. If flue gas volume is calculated, please describe the method for determination of the stoic

Please describe how based on concentration and flue gas flow data annual emissions are determined, taking into account time units for de

valid hour of data can be determined.

If applicable, please describe also the methodology by which emissions from biomass are determined (using a calculation approach) for sub

This description should provide the linking information which is needed to understand, how the information given in other parts of this templ

Please provide a list of emission points where emissions are determined by measurement.

Include details of all emission sources where emissions may be determined by a measurement based methodology during typical operation

or commissioning periods.

Provide a description of all measurement devices including emissions monitors and flow measurement devices to be used in the determina

Emission sources & unique reference identifier

(please use S1, S2, etc)

Emissions Measured during typical

and/or non-typical operation?

Estimated

sourc


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219727512.xl

(e)

Emission

point ref.

Emission

source ref.

Type of measurement device Me

u

EP2 S1 CO2 concentration (NDIR)

EP2 S1 Flow measurement (averaging pitot)

f

Emission

point ref.

Emission

source ref.

Parameter

EP1 S1 QAL2 procedures

EP1 S1 CO2 concentration N/A

EN14181

ISO12039

(briefly des

N/A

Please insert additional lines if required.

Applied Standard

Unique reference to

the device

Measurement Range (including

units)

Provide a description of all measurement devices, including emissions monitors and flow measurement devices, to be used in the d

Where possible please use a consistent format for the Measurement Device Reference such as MEAS1, MEAS2, MEAS3, etc.

MEAS2 10 - 10,000 m3/hr

MEAS1 0 - 250 g CO2/m2

Please describe below all relevant equipment used in the measurement of emissions from the sources listed in

Please provide details of the laboratory and a list of applied standards and briefly describe any deviations from


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219727512.xl

(g)

(h)

(i)


applicable)





Please provide details about the written procedures which describe in detail the calculation formulae used and the method of data

applied in accordance with Article 44 of the MRR.

Title of procedure



for the procedure and for any

data generated



applicable).

List of EN or other standardsapplied (where relevant)


Please provide details about the written procedures detailing any calculation formulae used for data aggregatio

determine the emissions where measurement based methodologies are applied.

Please provide details about the written procedures which describe the methods used for determining the refer

periods for each parameter and for substitution of missing data.

Brief description of procedureDescription should cover the





data generated









applicable)

Where flue gas flow is determined by calculation, please provide details about the written procedure for this ca

each relevant emission source in accordance with Article 43(5)(a) of the MRR.

Title of procedure

Name of IT system used (whereapplicable).



applicable)

Please provide details about the written procedures which describe the methods for determining if valid hours or shorter reference p

each parameter can be provided, and for substitution of missing data in accordance with Artic le 45 of the MRR.

Title of procedure


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219727512.xl

(j)

(k)


applicable).






data generated






applicable)


Title of procedure

Where CO2 stemming from biomass is included in the emissions measurement, please provide details about the

procedure detailing how the biomass CO2 is to be determined and subtracted from the measured CO2 emissionapplicable, in accordance with Article 43(4) of the MRR.




applicable).





Title of procedure


Please provide details about the written procedure for carrying out the corroborating calculations, where applic

accordance with Article 46 of the MRR.



applicable)



data generated


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219727512.

evidence to

ed

(02/02/12)


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7 Fall-back approach

(a)

(b)

(c)



applicable)

Article 22 of the MRR provides that an operator may use a methodology that is not based on tiers for selected source streams or emission sources, where certain

met. Please complete this section if you propose to apply such a fall-back approach to any emission sources. Your competent authority may ask for further inform

Where a fall-back monitoring methodology is applied in accordance with Article 22 of the MRR, please provide a detailed description of the

applied for all source streams or emission sources, for which no tier approach is used.

USE OF FALL-BACK APPROACH FOR DETERMINATION OF EMISSIONS

Please provide details about the written procedures used for carrying out the annual uncertainty analysis required under

Article 22 of the MRR.

Title of procedure

Your must be able to demonstrate that the overall uncertainty thresholds for the annual level of greenhouse gas emissions for the whole installation do not exceed

category B and 2.5 % for category C installations. Note: Your competent authority may request full details of your justification to demonstrate that application of a t

measurement approach is technically not feasible or would lead to unreasonable costs.

Please provide a concise justification for the application of a fall-back approach to the above emission sources, in line with the provisions s


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8

(a)

(b)

Emission

point ref

Emission sources &

unique reference

identifier

(please use S1, S2, etc)

Type of N2O

emissions

Estimated annual emission

from source stream, tCO2(e)

% of total fossil CO2(e) emission So

Please provide details about the N2O emission points at the installation and confirm the approach to be used for determ

MRR.

DETERMINATION OF NITROUS OXIDEEMISSIONS

Determination of N2O emissions

Note: this section is to be completed for determination of N2O emissions from specified production activities at an installation, N2O emissions fro

from the installation shall be detailed separately in the appropriate sections of this plan.

Please provide a concise description of the approach used to determine your N2O emissions and to convert these to an

This description should provide the linking information which is needed to understand, how the information given in other par

Please describe how based on concentration and flue gas flow data annual emissions are determined, taking into account time

Your description should include what type of instrument(s) are used, whether measurements are carried out under wet or dry

Where EN 14181 is applied, the calibration factors required for QAL2 procedures. If flue gas volume is calculated, please desc

Note: Emissions of N2O from nitric acid production shall be monitored using a measurement based approach. For emissions of N2O from adipic

abated emissions using a measurement based approach and a calculation method (based on a mass balance approach) for temporary occurren


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(d)

Emission

Source ref.

Source stream ref. Parameter

(e)

Emission

point ref.

Emission source ref. Type of

measurement

device

Unique reference to the

device

Measurement

uncertainty

(+/-%)

(f)

Emission

point ref.

Emission source ref. Parameter Applied Standard Deviations from applied standard

(briefly describe any deviations from the standard

methodology)

Please provide justifications for the applied tiers for each major source stream where highest tiers are not currenFor each major source stream listed in table 8(b) above for which highest tiers are not currently applied you must provide a justification fo

Where an improvement plan is required in accordance with Article 26 of the MRR, this should be submitted with this monitoring plan and

Article 18 of the MRR, this calculation should be submitted with this monitoring plan and referenced within the justification below.

Justification for the applied tie

Please describe below all relevant equipment used in the measurement of emissions from the sources listed in ta

Provide a description of al l measurement devices to be used in the determination of emissions for each emission point listed in table 8(b).

Please insert additional lines if required.

Please provide details of the laboratory and a list of applied standards and briefly describe any deviations from th


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(g)

(h)

(i)

Diagram reference (where applicable)


Description should cover the essential

parameters and operations performed

Post or department responsible for the

procedure and for any data generated

Please provide details about the written procedures detailing any calculation formulae used for data aggregatio

and to determine the annual N2O emissions and the corresponding CO2(e)values of each emission source.

Title of procedure


applicable).

List of EN or other standards applied(where relevant)









Please provide details about the written procedures detailing the method and any calculation formulae used fodata aggregation and to determine the annual N2O emissions and the corresponding CO2(e)values of each emis

source.

Title of procedure

List of EN or other standards applied

(where relevant)

Where flue gas flow is determined by calculation, please provide details about the written procedure for this

calculation for each relevant emission source in accordance with Article 43(5)(a) of the MRR.

Title of procedure








Please provide details about the written procedures which describe in detail the calculation formulae used and the method of data

aggregation applied in accordance with Article 44 of the MRR.

Please provide details about the written procedures which describe the methods for determining if valid hours or shorter reference peri

for each parameter can be provided, and for substitution of missing data in accordance with Article 45 of the MRR.



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(j)

(k)

(l)

Post or department responsible for theprocedure and for any data generated







Please provide details about the written procedure which describes the method and parameters used to determ

the quantity of materials used in the production process and the maximum quantity of material used at fullcapacity.

Please provide details about the written procedure which describes the method and parameters used to determ

the quantity of product produced as an hourly load expressed as nitric acid (100%), adipic acid (100%), glyoxa

glyoxylic acid and caprolactam per hour.



applicable).







Title of procedure


Title of procedure


(where relevant)

Please provide details about the written procedure for carrying out the corroborating calculations, where

applicable, in accordance with Article 46 of the MRR.


(where relevant)





applicable).




Title of procedure




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(m)

(n)




(where relevant)

Please provide details about the written procedure detailing the calculation method used to determine N2O

emissions from periodic, unabated sources in nitric acid, adipic acid, caprolactam, glyoxal and glyoxylic acid

production.

Title of procedure




applicable).


(where relevant)






applicable).








Please provide details about the written procedure describing the method and parameters used to determine theN2O concentration in the flue gas from each emission source, its operating range, and its uncertainty, and detail

of any alternative methods to be applied if concentrations fall outside the operating range and the situations whe

this may occur.

Title of procedure



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(o) Please provide details about the written procedure describing the way in which or the extent to which theinstallation operates with variable loads and the manner in which the operational management is carried out.

Title of procedure









This information should include an indication of the potential frequency and the duration of such process conditions, as well as an indicatio

of the volume of the N2O emissions during the deviating process conditions such as abatement equipment malfunction.


applicable).


(where relevant)

Please provide information on process conditions that deviate from normal operations.


26/38


27/38


(e)

(f)

(g)

Title of procedure

Where a tier 2 emission factor is applied, please provide details about the written procedure setting out the

schedule for repetitions of the measurements detailed in 12(c) to be carried out in accordance with Section 8 of

Annex IV of the MRR.









(where relevant)

Note: the procedure should also show that the measurements have been and will be carried out for a sufficiently long t ime for measured

values to converge, but at least for 72 hours.

Where a tier 2 emission factor is applied, please provide details about the protocol describing the written procedure

determine the installation specific emission factors for CF4and C2F6.



applicable).





Title of procedure






applicable).


(where relevant)

Where a tier 2 emission factor is applied, please confirm the dates of measurement for the determination of the instaapplicable and in accordance with section 8 of Annex VI of the MRR.Please confirm the dates on which measurements were carried out to determine the tier 2 installation specific emission factors to be used

FC2F6for Method B). Note that if you are using method B, the emission factor must be determined every 3 years.

Dates of measurements:


28/38


(h)

i


Cell type


applicable).


(where relevant)







Please provide details about the written procedure detailing the methodology for determining the collectionefficiency for fugitive emissions, where applicable.

Title of procedure

Anode Type

Please provide a description of cell type and type of anode at the installation.



29/38


30/38


10

(a)

(b)

(c)

Measurement Point Measurem

(Article 48):

Inherent CO2 means CO2 which is part of a fuel. Inherent CO2 which is transferred into an installation shall be included in the emission factor of

out of the installation shall not be included in the emissions of that installation if it is transferred to another installation and activity covered by EU

covered by EU ETS it shall be counted as emissions of the installation where it originates (see Article 27 of the MRR).

(Article 49):

Transferred CO2 - Article 29 provides that an operator shall subtract any CO2 which is not emitted from the installation but is transferred out of th

below:

a capture installation for the purpose of transport and long-term geological storage in a storage site permitted under Directive 2009/31/EC;

a transport network with the purpose of long-term geological storage in a storage site permitted under Directive 2009/31/EC; ora storage site permitted under Directive 2009/31/EC for the purpose of long-term geological storage.

DETERMINATION OF INHERENT CO2(IN FUEL) AND TRANSFERRED CO2(CCS)

Determination of inherent and transferred CO2

Note: this section is to be completed where transfer of inherent CO2as part of a fuel in accordance with Article 48 of the MRR or t ransfer of CO 2

Please provide a detailed description of the monitoring methodology used to determine inherent or transferred CO2.

Please provide details of the receiving and transferring installations.

Installation Name

Unique reference to the device

Where continuous measurement systems are used to determine CO2at the point of transfer into or out of the installation, p

OperatorInstallation Identification Code

Type of measurement device


31/38


(d)

(e)

(f)


applicable).



Where part of the transferred CO2is generated from biomass, or where an installation is only partially covered by thdeducting the amount of transferred CO2which does not originate from fossil carbon activities covered by the EU E

Location Type of measurement device Unique reference to the device

Where applicable, please describe the equipment used for temperature and pressure measurement in the transportnetwork.

Please list all equipment used for measurement of temperature and pressure in the transport network in the determination of emissions

leakage events in accordance with section 22 of Annex IV of the MRR.

Post or department responsible for

the procedure and for any data

generated




applicable)





Where applicable, please provide details of the written procedure for preventing, detecting and quantification of lea

events from transport networks.

Title of procedure




generated








applicable).


applicable)

Title of procedure


32/38


(g)

(h)



generated

Where applicable, please provide details of the written procedure which describe the quantification methodologies f

emissions or CO2released to the water column from potential leakages as well as the applied and possibly adaptedquantification methodologies for actual emissions or CO2released to the water column from leakages, as specified

section 23 of Annex IV.Title of procedure





applicable)







applicable).

For transport networks, please provide details of the written procedure for ensuring that CO 2is transferred only toinstallations which have a valid greenhouse gas emission permit, or where any emitted CO2is effectively monitored

accounted for in accordance with Article 49.Title of procedure






generated



applicable).


applicable)






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11 Management

(a)

(b)

(c)

This procedure should identify how the monitoring and reporting responsibilities for the roles identified above are assigned and how training

and reviews are undertaken and how duties are segregated such that all relevant data is confirmed by a person not involved with the

recording and collection of the data..

ETS Reporting Procedure

(ABC/ETS/Proc-01)


Reference for procedure (ABC/ETS/Proc-01)Brief description of procedure




Asset list is held within the finance records which provides a list of all assets on the site.

Responsible person reviews the asset list periodically within the reporting year, at least quarterly.

Finance teams log any purchases of assets which are reviewed by the responsible person and

added to the asset list as appropriate.

Fuel use records are reviewed to identify any changes in fuel use, metering devices and

calibration issues.


for the procedure and for anydata generated

Quality Manager


Utilities Manager

Quality Manager

Collection of periodic meter readings and supplier invoices

Maintenance of quality manual and procedures

ii - assessing compliance with the uncertainty thresholds for activity data and other parameters (where applicable) for the applied tiers foreach source stream and emission source; and

Please provide details about the procedure used for managing the assignment of responsibilities for monitoring and

reporting within the installation and for managing the competencies of responsible personnel, in accordance with

Article 58 3 c of the MRR.

Responsible person maintains a list of personnel involved in ETS data management

Responsible person holds at least one meeting per year with each involved person, at least 4

meetings with key staff as defined in the annex of the procedure; Aim: Identification of training

needs

Responsible person manages internal and external training according to identified needs.

Please provide details about the procedure used for regular evaluation of the monitoring plan's appropriateness,

covering in particular any potential measures for the improvement of the monitoring methodology.

The procedure specified below should cover the following:

Quality Manager

Hardcopy: HSEQ Office, shelf 27/9, Folder identified ETS 01-P. Electronically:

P:\ETS_MRV\manag\ETS_01-P.xls

N/A

N/A (normal network drives)

Title of procedure




i - checking the list of emissions sources and source streams, ensuring completeness of the emissions and source streams and that all

relevant changes in the nature and functioning of the installation will be included in the monitoring plan;

iii - assessment of potential measures for improvement of the monitoring methodology applied.

Title of procedure ETS Reporting Procedure






applied (where relevant)N/A



data generated


applicable).

DESCRIPTION OF PROCEDURES FOR DATA MANAGEMENT AND CONTROL ACTIVITIES

Please identify the responsibilities for monitoring and reporting emissions from the installation, in accordance withPlease identify the relevant job titles/posts and provide a succinct summary of their role relevant to monitoring and reporting. Only those with

overall responsibility and other key roles should be listed below (i.e. do not include delegated responsibilities).

These could be outlined in a tree diagram or organisational chart attached to your submission.

Responsibilities

Environment Manager

Job title/post

Collation of data to produce Annual Emissions Report; custodian of data sources

Hardcopy: HSEQ Office, shelf 27/9, Folder identified ETS 01-P. Electronically:

P:\ETS_MRV\manag\ETS_01-P.xlsName of IT system used (where

applicable).N/A (normal network drives)

Management 33 / 38


34/38


12 Data flow activities

(a)


applicable)



data generated








Where a number of procedures are used, please provide details of an overarching procedure which covers the main steps of data flowactivities along with a diagram showing how the data management procedures link together (please reference this diagram below and

include when submitting your monitoring plan). Alternatively please provide details of additional relevant procedures on a separate sheet.


applicable).

List of primary data sources


Description of the relevant

processing steps for each

specific data flow activity

Identify each step in the data

flow from primary data to annual

emissions which reflect the

sequence and interaction

between data flow activities and

include the formulas and data

used to determine emissions

from the primary data. Include

details of any relevant electronic

data processing and storagesystems and other inputs

(including manual inputs) and

confirm how outputs of data flow

activities are recorded

Please provide details about the procedures used to manage data flow activities in accordance with Article 57 of the

MRR.

Title of procedure


35/38


13 Control activities

(a)

(b)

(c)


applicable).



Please provide details about the procedures used to assess inherent risks and control risks in accordance with Article

58 of the MRR.

The brief description should identify how the assessments of inherent risks and control risks are undertaken when establishing an effective

control system.

The brief description should identify how all relevant measurement equipment is calibrated and checked at regular intervals, if applicable, and

how non-compliance with the required performance is dealt with.







data generated


Title of procedureReference for procedure

Please provide details about the procedures used to ensure quality assurance of measuring equipment in accordance

with Article 58 and 59 of the MRR.

Title of procedure







applicable).



data generated



Please provide details about the procedures used to ensure quality assurance of information technology used for data

flow activities in accordance with Article 58 and 60 of the MRR.

The brief description should identify how information technology is tested and controlled, including access control, back-up, recovery and

security.

Title of procedure




essential parameters andoperations performed



data generated



applicable).



36/38


(d)

(e)

(f)

The brief description should identify that the review and validation process includes a check on whether data is complete, comparisons with

data over previous years, comparison of fuel consumption reported with purchase records and factor obtained for fuel suppliers with

international reference factors , if applicable, and criteria for rejecting data.

Please provide details about the procedures used to ensure regular internal reviews and validation of data in

accordance with Articles 58 and 62 of the MRR.

Title of procedure



data generated









applicable).



Title of procedure







data generated

The brief description should identify how data flow activities and control activities of outsourced processes are checked and what checks are

undertaken on the quality of the resulting data.


applicable).

Please provide details about the procedures used to control outsourced processes in accordance with Articles 59 and

64 of the MRR.

Title of procedure

Please provide details about the procedures used to handle corrections and corrective actions in accordance with

Articles 58 and 63 of the MRR.

The brief description should outline what appropriate actions are undertaken if data flow activities and control activities are found not to

function effectively. The procedure should outline how the validity of the outputs are assessed, the process of determining the addressing

the cause of the error.





data generated








applicable).




37/38


(g)

(h)

(i)

(j)

Does your organisation have a documented environmental management system? Please choose the most relevant

response.Yes

ISO14001






Please provide details about the procedures used to manage record keeping and documentation in accordance with

Articles 58 and 66 of the MRR.

Title of procedure

The brief description should identify the process of document retention, specifically in relation to the data and information stipulated in Annex

IX of the MRR and to how the data is stored such that information is made readily available upon request of the competent authority or

verifier.



data generated


If the Environmental Management System is certified by an accredited organisation, please specify to which standard

e.g. ISO14001, EMAS, etc.




Please provide the reference to the documented results of a risk assessment that demonstrates that the control

activities and procedures are commensurate with the risks identified in accordance with Article 12(1)(b) of the MRR.

(Note: The requirement to submit the risk assessment to the CA does not apply to installations with low emissions, in

accordance with Article 47 3 of the MRR

Please reference the file/document attached to your monitoring plan in the box below.

ETS Risk Assessment (ABC/ETS-RA01)

Management 37 / 38


38/38


14 List of definitions and abbreviations used

a

15 Additional information

(a)

16 Changes in operation

(a)

Document description

If you are providing any other information that you wish us to take into account in considering your plan, tell us here.

Please provide this information in an electronic format wherever possible. You can provide information as Microsoft

Word, Excel, or Adobe Acrobat formats.

You are advised to avoid supplying non-relevant information as it can slow down the approval. Additional documentation provided should be

clearly referenced, and the file name / reference number provided below. If needed, check with your competent authority

Please provide file name(s) (if in an electronic format) or document reference number(s) (if hard copy) below:

File name/Reference

Please list any abbreviations, acronyms or definitions that you have used in completing this monitoring plan.

Abbreviation Definition

Title of procedure






Post or department responsiblefor the procedure and for any

data generated


Article 24(1) of Commission Decision 2011/278/EC requires that Member States must ensure that all relevant information about any planned

or effective changes to the capacity, activity level and operation of an installation is submitted by the operator to the competent authority by

31 December each year. Article 12(3) of the MRR further provides that Member States may require information to be included in the

monitoring plan of an installation for the purposes of meeting these requirements.

Please provide details about the procedure used to ensure regular reviews are carried out to identify any planned or

effective changes to the capacity, activity level and operation of the installation that have an impact on the installation's

allocation.

The procedure specified below should cover the following:

- planning and carrying out regular checks to determine whether any planned or effective changes to the capacity, activity level and operationof an installation are relevant under Commission Decision 2011/278/EC; and- procedures to ensure such information is submitted to the competent authority by 31 December of each year.


applicable).

annual emission monitoring plan

Documents