Quest Ccs Report

Quest Carbon Capture and Storage Project
April 2023
Verification Report for:

Proponent Name and Proponent Project Number:

Shell Canada Limited, as Managing Partner and on Behalf of Shell Canada
Energy (an Alberta Partnership)
Prepared by:
GHD Limited
Prepared for:
Shell Canada Limited, as Managing Partner and on Behalf of Shell Canada
Energy (an Alberta Partnership)
Version:
Final
RPT-2
Date:
April 27, 2023
Version 3.0 Offset Verification Report Form

April 2023
Table of Contents
1.0 Summary of Offset Project ..................................................................................... 3
2.0 Introduction ......................................................................................................... 7
2.1 Objective ........................................................................................................... 11
2.2 Scope ................................................................................................................ 11
2.3 Level of Assurance .............................................................................................. 12
2.4 Criteria .............................................................................................................. 12
2.5 Materiality .......................................................................................................... 13
3.0 Methodology ....................................................................................................... 13
3.1 Procedures ......................................................................................................... 13
3.2 Team ................................................................................................................. 29
3.3 Schedule ............................................................................................................ 30
4.0 Results .............................................................................................................. 31
4.1 Assessment of Internal Data Management and Controls ........................................... 31
4.2 Assessment of GHG Data and Information .............................................................. 33
4.3 Assessment against Criteria .................................................................................. 48
4.4 Evaluation of the GHG Assertion............................................................................ 49
4.5 Summary of Findings ........................................................................................... 50
4.6 Opportunity for Improvement ............................................................................... 52
5.0 Closure .............................................................................................................. 52
5.1 Verification Statement ......................................................................................... 52
5.2 Limitation of Liability ........................................................................................... 52
5.3 Confirmations ..................................................................................................... 53
6.0 References ......................................................................................................... 55
Appendix A: Final Verification Plan and Sampling Plan ............................................................ 56
Appendix B: Statement of Qualifications................................................................................ 57
Appendix C: Findings and Issues .......................................................................................... 60
Appendix D: Statement of Verification .................................................................................. 64
Appendix E: Conflict of Interest Checklist .............................................................................. 67
Appendix F: Supplemental Diagrams/Tables/Figure ................................................................ 70
List of Tables
Table 1: Offset Criteria Assessment ...................................................................................... 48
Table 2: Summary of Findings ............................................................................................. 50
Table 3: Detailed Findings and Issues Log ............................................................................. 61
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1.0 Summary of Offset Project
Item Description
Project Title Quest Carbon Capture and Storage Project
Project Description The purpose of this offset project is to quantify

emission reductions generated under the Alberta
Offset System from Shell Canada Limited’s (Shell)
Quest CCS Project (Quest). The Quest CCS project
captures approximately one third of the
greenhouse gas emissions at the Scotford
Upgrader, which is located at the Scotford
Complex, northeast of Edmonton, Alberta.
The opportunity for generating carbon offsets with
this project arises from the direct greenhouse gas
emission reductions resulting from the geological
sequestration of CO2 in saline aquifers located
approximately 2-km under the surface in the Basal
Cambrian Sands Formation. This activity is
considered a permanent sequestration of CO2.
Project Location Latitude: 53.7407°N; Longitude: 113.0231°W

The address of the Quest CCS project is
55522 Range Road 214, Fort Saskatchewan,
Alberta.
The Injection wells are located:
Well #1: 07-11-59-20-W4
Well #2: 08-19-59-20-W4
Well #3: 05-35-59-21-W4
All aspects of the project occur in Alberta.
Project Start Date The project, as defined by commencement of

injection, started on August 23, 2015.
Offset Start Date The offset start date was August 23, 2015.
Offset Crediting Period The credit duration period is 20-years with on-
going five-year extensions as allowed by the
protocol. The initial credit period is therefore
August 23, 2015, to August 22, 2035, with
potential five-year extensions commencing
thereafter
Offset Reporting Period 2022 Reporting Period (January 1 to

December 31, 2022)
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GHG Assertion (Actual Emission The total emissions offsets for the reporting
Reductions/Sequestration period were 715,416.00 tonnes CO2e
Achieved)
Government Approved Quantification Protocol for CO2 Capture and

Quantification Protocol Permanent Storage in Deep Saline Aquifers,
Version 1, Date: June 23, 2015
Ownership Shell Canada Limited is the managing partner

for Shell Canada Energy and holds the
necessary regulatory approvals for the project.
Prior to February 1, 2017, Shell Canada Energy
operated the project on behalf of the
Athabasca Oil Sands Project (AOSP) Joint
Venture, a consortium of Shell Canada Limited
(60%), Chevron Canada Limited (20%), and
Marathon Oil Canada Corporation (20%). After
February 1, 2017, ownership of AOSP Joint
Venture changed to Canadian Natural
Upgrading Limited (60%), Chevron Canada
Limited (20%), and 1745844 Alberta Ltd.
(20%).Effective January 1, 2017,
1745844 Alberta Ltd. is a Shell affiliate, and is
a successor by name change to Marathon Oil
Canada Corporation. Shell Canada Limited and
Canadian Natural Upgrading Limited both own
50% of 1745844 Alberta Ltd. Notwithstanding
this change in ownership, Shell Canada Energy
will continue as operator of the Quest CCS
Project and as agent for and on behalf of the
AOSP Joint Venture.
Project Activity The Project meets the eligibility criteria as per

the following:
• Occur in Alberta
• Result from an action taken that is not
otherwise required by law at the time the
action is taken
• Must not be required by law at the time the
reduction occurs
• Result from actions taken on or after
January 1, 2002
• Occur on or after January 1, 2002
• Be real and demonstrable
• Be quantifiable and measurable, directly or
by accurate estimation using replicable
techniques
• Must not have had an effect on the
determination of a regulated facility’s total
regulated emissions
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Project Contact Celina Duong

Shell Canada Limited
P.O. Bag 23
55522 Range Rd 214, Fort Saskatchewan, AB
T8L 4A4
(780) 997-5117
Celina.Duong@shell.com
Lead Verifier Mr. Sean Williams, P.Eng.

GHD Limited
#640, 10250 – 101 Street NW, Edmonton, AB
T5J 3P4
+1 780-705-7055
sean.williams@ghd.com
Verification Team Members Sean Williams, P. Eng.

Roles: Lead Verifier
Training: Greenhouse Gas Verification –
ISO 14064-3, Canadian Standards Association,
April 2012
Stephaney Davey, M.Sc., E.I.T.

Roles: Verifier
April 2020
Gordon Reusing, P. Eng.

Roles: Peer Reviewer
December 2008 and November 2010
Designated Signing Authority Deacon Liddy, P.Eng

GHD Limited
138 E 7th Ave
Vancouver, BC
V5T 1M6
(604) 214-0510
deacon.liddy@ghd.com
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Verification Strategy GHD’s detailed verification strategy is

summarized in Section 3.0 below.
Verification Conclusion The verification conclusion is: Positive
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2.0 Introduction
Shell Canada Limited, as Managing Partner and on Behalf of Shell Canada Energy (an Alberta
Partnership) (Shell) retained GHD Limited (GHD) to undertake a verification of the Quest
Carbon Capture and Storage (CCS) Project (Project) for the period of January 1, 2022 to
December 31, 2022 (Offset Project Report or OPR). The Project is registered with the Alberta
Emissions Offset Registry, registration number 7306-8118.
GHD completed the verification in accordance with the requirements of the Technology
Innovation and Emissions Reduction Regulation (Reg. 133/2019, TIER) and any promulgated
amendments, under the Emissions Management and Climate Resilience Act (Government of
Alberta, 2019). The applicable protocol for this Project is the Quantification Protocol for CO2
Capture and Permanent Storage in Deep Saline Aquifers, Version 1.0 (Alberta Environment and
Parks (AEP), June 2015) (Protocol). Shell is responsible for the preparation and fair
presentation of the OPR in accordance with the TIER. Celina Duong is GHD’s contact at Shell for
this verification.
GHD has prepared the Verification Plan and this Verification Report in accordance with the
ISO Standard ISO 14064 Greenhouse gases – Part 3: Specification with guidance for the
validation and verification of greenhouse gas assertions (ISO 14064 3) and with Alberta
Environemnet and Protected Areas (AEPA) Standard for Validation, Verification and Audit
(Alberta Environment and Protected Areas, 2023).
Offset Credit Project Boundaries
The Project consists of two separate components: the CCS capture facility and three injection
sites. The CCS capture facility is located at the Shell Scotford Site, and captures CO2 produced
from the hydrogen manufacturing units (HMUs) of the Scotford Upgrader Facility. CO2 is
absorbed from the raw gas stream through the use of a licensed Shell amine absorption system
(ADIP-X) in a scrubbing tower located at each of the three HMUs. The CO2-amine mixture from
each absorption system is then sent through a regeneration column, separating the CO2 from
amine. The CO2 stream undergoes dehydration (removal of water) and compression, and is
then transported via pipeline to the well pads. There are three injection wells, one per well pad.
Currently, two out of the three injection wells are in operation for sequestering the CO2
approximately two kilometres below ground.
The overall Project consists of emissions associated with the capture of CO2 and operation of
the CCS capture facility and injection wells. The operation of the Scotford Site consists of the
following facilities which, unless otherwise noted, are owned by the AOSP JV or Shell Canada
Limited, and operated by Shell:
• Quest CCS capture Facility

• Scotford Upgrader Facility (which itself consists of the Upgrader Base and Upgrader
Expansion Facilities).
• ATCO Cogen facility (owned by ATCO Power Canada Limited, operated by Shell).
• Air Liquide Cogen facility (owned and operated by Air Liquide Canada).
• Air Products facility (owned and operated by Air Products)
• Scotford Refinery.
• Shell Chemicals Facilities.
The Scotford Upgrader provides the CO2 for injection, while both the Scotford Upgrader and
Scotford Refinery provide heat (in the form of steam) for the Project operation. All other
operations at the Scotford Site are not included in the project, and will not be reviewed.
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Geographic Boundaries
The Project is located at the following addresses:
CCS Facility
55522 Range Road 214
Fort Saskatchewan, Alberta
Latitude: 53.74047 N, Longitude 113.0231 W
Injection Wells
Well #1: 07 11 59 20 W4
Well #2: 08 19 59 20 W4
Well #3: 05 35 59 21 W4
Description of Project Baseline and Project Conditions
During the baseline condition, CO2 is produced in the hydrogen manufacturing units in the
Scotford Upgrader through the steam-methane reforming reaction, and is then emitted directly
to the atmosphere.
During the product condition, the CO2 produced in the hydrogen manufacturing units is
captured and separated from the raw gas stream by the CCS capture facility, compressed,
transported to the injection wells, and then sequestered underground. Emissions from the
project at the CCS capture facility include the following operations:
• Production and transportation of materials

• Production, transportation and combustion of fuels
• Production of off-site heat and electricity.
• Combustion of fuels at the CCS capture facilities
• Emissions associated with the loss, disposal and recycling of materials
Emissions from the project at the injection wells potentially include the following operations:
• Construction and drilling of new injection wells

• Production and transportation of materials
• Production, transportation and combustion of fuels
• Fugitives and venting at the well injection points
• Production of on-site and off-site electricity
• The use of aviation turbo fuel (for pipeline inspections)
• Loss of CO2 containment from the subsurface.
The emission offsets from the implementation of this Project occur from the following (listed by
the protocol categories) – all non-applicable emissions are listed as “NA”:
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Table 2.1 Specified Emissions Reductions and Gas Types
Protocol Specified Gas Type

Source
Carbon Methane Nitrous Hydro- Per- Sulfur CO2
Category
Dioxide (CH4) Oxide fluorocarbons fluorocarbons Hexafluoride Equivalent
(CO2) (N2O) (HFCs) (PFCs) (SF6) (CO2e)
Baseline Condition
B1 – Injected Y NA NA NA NA NA Y
CO2
Project Condition
P3 – Well Y Y Y NA NA NA Y
drilling
reportable
releases
P4 – NA NA NA NA NA NA Y
Production
and delivery
of material
inputs
P5/P6/P7 – Y Y Y NA NA NA Y
Extraction/
processing
and
transportation
of fuel used
for on-Site
and off-Site
heat and
electricity
generation
P8 – Off-Site NA NA NA NA NA NA Y
electricity
generation
P9 – Off-Site Y Y Y NA NA NA Y
heat
generation
P10 – On-Site Y Y Y NA NA NA Y
heat and
electricity
generation
P11 – CCS Y Y Y NA NA NA Y
facility
operation
P18 – Venting Y Y NA NA NA NA Y
of CO2 at
injection well
sites
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Protocol Specified Gas Type

Source
Carbon Methane Nitrous Hydro- Per- Sulfur CO2
Category
Dioxide (CH4) Oxide fluorocarbons fluorocarbons Hexafluoride Equivalent
(CO2) (N2O) (HFCs) (PFCs) (SF6) (CO2e)
P19 – Fugitive Y Y NA NA NA NA Y
emissions at
injection well
sites
P20 – Y Y Y NA NA NA Y
Emissions
from
subsurface to
atmosphere
P21 – Loss, Y Y Y NA NA NA Y
disposal or
recycling of
materials
used in CO2
capture
process
Summary of Changes to Baseline Condition

There have been no changes made to the baseline condition since the project start date.
Summary of Changes to Project Since Project Start and/or Baseline Period
Since the Project commencement, the Project has undergone the following changes:
• Ownership of the Athabasca Oil Sands Project Joint Venture (AOSP JV) (including both Quest
and the Shell Upgrader) changed on February 1, 2017. Prior to this date, ownership of the
AOSP JV was split between Shell Canada Energy (60%), Chevron Canada Limited (Chevron)
(20%) and Marathon Oil Canada Corporation (Marathon) (20%). Afterwards, CNUL
purchased Shell Canada Energy’s share of the AOSP JV, and CNUL and Shell jointly
purchased Marathon’s share (creating 1745844 Alberta Ltd.). Therefore, as of February 1,
2017, the ownership split was changed to CNUL (60%), Chevron (20%) and
1745844 Alberta Ltd. (20%), with CNUL and Shell each having 50% ownership of
1745844 Alberta Ltd. Shell remains operator of the Project.
• Starting in early September 2015, the values measured by the CO2 analyzer were found to
drifting lower than expected. This was identified to be the result of three issues:
- A manufacturer’s defect in the switching valve
- Low accuracy due to low volumes of injected gas into analyzer
- High sensitivity in the analyzer to barometric pressure
The above issues were fully resolved by February 3, 2017. Shell submitted and AEP approved a
variance request allowing alternative measurement methodologies be used while the analyzer
was not operational and supporting gas samples be collected of the gas stream. This did not
affect the calculations for the 2022 reporting period, as the analyzer was operational for the
reporting period.
• The initial methodology to quantify waste heat contributions to Quest steam was found to
be not in accordance with the Protocol during an AEP re-verification of the project
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(conducted by TetraTech EBA Inc. (TetraTech)). A revised steam allocation methodology

was developed up to the 6th reporting period; for the 7th reporting period onwards (including
for this reporting period), the Project does not quantify any contributions from waste heat.
• Starting in October 2016, Shell commenced using small generators powered by methanol
combustion as a secondary power source for line-break valves (previously these were all
solar-powered).
• Starting August 1, 2017, Shell commenced using caustic soda to reduce the acidity of
wastewater. The caustic soda is noted to be a new input, which was not included in the
initial OPP.
• Starting January 1, 2018, the Project is utilizing the Carbon Competetiveness Incentive
Regulation (CCIR) approved benchmark value to represent the emissions intensity from
directly-supplied electricity from the cogeneration unit. This has continued, but starting on
January 1, 2020 the TIER benchmark value is used.
Additional minor changes were made to the calculations of various sources, none of which have
a material impact on emissions. Beyond the above, there have been no operational changes to
the Project.
2.1 Objective
The objective of the verification is to provide Shell and AEP with an opinion that there are no
material misstatements in the Project's 2022 reporting period OPR and that the information
reported is accurate and consistent with the requirements of the TIER. This report has been
prepared for the use of Shell and AEP.
2.2 Scope
The scope of this verification is described as follows:
• Project Description – The scope of the verification includes the greenhouse gas (GHG)
offsets resulting from the capture and underground storage of CO2 that would otherwise
have been emitted directly to the atmosphere.
• GHG Types – The claimed offsets result from reductions in CO2 released to the atmosphere
due to the Project. The emissions during the operation of the Project result from:
- The venting and fugitive releases of CO2 and CH4 from the Project.
- Releases CO2, CH4 and N2O due to combustion of fuels for Project operation and heat
and electricity requirements.
- Releases of CO2, CH4 and N2O from the production and/or loss, disposal or recycling of
the various chemical products and fuels required for the Project.
- Emissions from venting releases from drilling or construction
- Emissions due to loss of containment within the storage complex
• Time Period – January 1, 2022 – December 31, 2022
• Use of this Report - This report has been prepared for the use of Shell and AEP.
• Relative Size – The size of the claimed GHG reductions was 715,416.00 tonnes CO2
equivalent (tCO2e).
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GHD will ensure and attest to the following:
• The accuracy of the reported data and calculated emissions, and that all data and emissions
accurately reflected the operation of the Project in the reporting period and are consistent
with the approved Offset Project Plan (OPP).
• The baseline and project conditions during the 2022 Reporting period were consistent with
the requirements of the Protocol and OPP
• The reasonableness of the emission estimation methodologies, assumptions, and results.
• Whether any errors in data, estimations or methodology were adequately managed,
documented, and either corrected or accounted for.
• Whether all measurement devices and sources of data are appropriate, well-maintained and
reading accurately.
• Whether the OPR is clear, well supported, and comprehensive.
• The reporting systems conform to relevant government-mandated or industry-standard
quality assurance procedures.
• The assertion refers to the emissions, from the sources and sinks reported by the Project
• ISO principles such as consistency, conservativeness, transparency, etc. are met by the
Project.
2.3 Level of Assurance
The verification was conducted to a reasonable level of assurance.
Reasonable assurance is a high level of assurance, or positive assurance. Reasonable assurance
is a direct factual statement expressing the opinion of the verifier. If a verification statement
can be provided, it is worded in a manner similar to "Based on our verification, the GHG
emissions statement is, in all material aspects, in accordance with the approved quantification
protocols."
2.4 Criteria
GHD assessed the Project against the following criteria:
• Occur in Alberta
• Result from actions not otherwise required by law and be beyond business as usual and
sector common practice
• Be real, demonstrable, quantifiable, and verifiable
• Result from actions taken on or after January 1, 2002
• Have clearly established ownership
• Be counted once for compliance purposes
• Be implemented according to a Government of Alberta-approved quantification protocol
• Be verified by qualified third-party
GHD has prepared this Verification Report in accordance with the ISO Standard ISO 14064
Greenhouse gases – Part 3: Specification with guidance for the validation and verification of
greenhouse gas assertions (ISO 14064-3) and the VVA Standard.
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For this verification, GHD applied the following ISO and AEP criteria:
• ISO 14064 Greenhouse gases-Part 2: Specification with guidance at the project level for
quantification and reporting of greenhouse gas emissions and removals, ISO, March 2006
(ISO 14064-2)
• ISO 14064 Greenhouse gases-Part 3: Specification with guidance for the validation and
verification of greenhouse gas assertions, ISO, April 2019 (ISO 14064-3)
• Emissions Management and Climate Resilience Act, Technology Innovation and Emissions
Reduction Regulation, Alberta Regulation 133/2019 (TIER) and amendments.
• Standard for Greenhouse Gas Emission Offset Project Developers, Version 3.1, AEP, 2023
• Standard for Validation, Verification and Audit, Version 5.2, AEP, 2023
• Quantification Protocol for CO2 Capture and Permanent Storage in Deep Saline Aquifers,
Version 1.0 (AEP, 2015).
• Carbon Offset Emission Factors Handbook, Version 2.0 (2019)
2.5 Materiality
As the total project offsets are more than 500 ktonnes of CO2e for each full calendar year,
quantitative materiality for this verification is set at absolute 2% of the OPR as per
Section 5.1.1 of the AEPA VVA Standard. In addition, a series of discrete errors, omissions or
misrepresentations or individual or a series of qualitative factors, when aggregated (absolute
values) may be considered material.
3.0 Methodology
The purpose of GHD's verification procedures was to assess the following critical items:
• Accuracy and completeness of the current OPR.

• Consistency between baseline and project conditions.
• Conformance to the program criteria.
• Uncertainty of external data sources used.
• Compliance of the OPR to the verification standards and criteria.
• Completeness of the OPR in comparison to the structure and criteria presented in AEP
guidance.
• Offset assumptions.
• Accuracy of emission calculations.
• Potential magnitude of errors and omissions.
• Integrity of the data management system and controls.
• ISO principles are met
3.1 Procedures
Verification Procedures
To sustain a risk-based assessment, the GHD Project Team identified and determined risks
related to project GHG offsets during both the desk reviews and the follow-up interviews. The
components of the document review and follow-up interviews were:
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Document Review:
• Review of data and information to confirm the correctness and completeness of presented
information.
• Cross checks between information provided in the OPP and OPR and information from
independent background investigations.
• Determine sensitivity and magnitude analysis for parameters that May be the largest
sources of error.
Follow-up Interviews:
• On Site
• Via telephone
• Via email
The GHD Project Team interviewed Project personnel to:
• Cross-check information provided by interviewed personnel, i.e., by source check or other
interviews.
• Compare with projects or technologies that have similar or comparable characteristics.
• Test the correctness of critical formulae and calculations.
• Review data management and recording procedures.
Through the document review GHD established to what degree the presented OPR meets the
verification standards and criteria.
The GHD Project Team's document review during the review process comprised an evaluation of
whether or not:
• The documentation is complete and comprehensive and follows the structure and criteria
given in the AEP guidelines and regulations.
• The OPR, and the emissions estimates therein, conform to the program criteria.
• The OPP and OPR are accurate, transparent and complete overview of the Project's GHG
emissions sources
• The methodologies used in the GHG emission inventory are justified and appropriate.
• The assumptions behind the inventory are conservative and appropriate.
• The GHG emission calculations are appropriate and use conservative assumptions for
estimating GHG emissions.
• The GHG information system and its controls are sufficiently robust to minimize the
potential for errors, omissions or misrepresentations.
• The frequency of, and responsibility and authority for, monitoring, measurement, data
recording activities and quality control/quality assurance/management control procedures is
sufficient.
GHD completed data checks from the data source(s) (meter, scale, etc.) through the plant data
management system to the GHG emissions data reports. A sample of raw data was collected for
recalculation. If errors or anomalies were identified that could lead to a material misstatement,
GHD requested further raw data samples to assess the pervasiveness of the errors or
anomalies.
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The specific verification tests conducted by GHD as Part of the audit included the following:
• Review of third-party data and reports
• Tracing of data from output back to the measurement device(s)
• Full recalculations of key GHG supporting data and emissions
• Reasonableness checks of the sources of data and calculation methodologies
The specific documents received by GHD as Part of the verification to conduct the verification
tests outlined above is provided in Appendix F.1.
Verification Steps
GHD adhered to the following schedule for this verification:
Conflict of Interest (COI) and Independence

GHD completed a thorough evaluation for Conflict of Interest (COI) and Independence
Verification for the Project. GHD confirmed that the verification could be successfully completed
without undue risk to either GHD or Shell.
GHD has rigorous COI and Verifier Competency evaluation procedures that are followed for
every verification project. GHD's COI program ensures that both Shell and the Project Team
have no potential COI's.
GHD also evaluated and approved the Verification Team's competenciesGHD sets competency
requirements in terms of education, years of experience, and work experience in the sector.
Verification Plan
Prior to completion of the site visit, GHD prepared a verification plan, including an overview of
the verification process, a risk assessment, a sampling plan and the site visit agenda. In the
sampling plan, GHD provided a comprehensive list of information and data requests. GHD
utilized a risk-based approach to select a sample size of data and information for each facility.
Documentation Review and Emissions Recalculations

GHD reviewed the information provided by Shell and conducted recalculations of the emissions.
GHD assessed the quantitative discrepancy based on the recalculations and determined
whether there were any material issues.
The components of the document review and follow-up interviews are detailed above under
“Verification Procedures”.
Site Visit
On February 8, 2023, Ms. Stephaney Davey (Verifier) and Bryan Rubie (Verifier) completed an
in-person site visit of the Project at the Scotford Site/Quest Capture Site. On April 6, 2023,
Mr. Sean Williams (Lead Verifier) and Stephaney Davey (Verifier) of GHD completed a in-person
site visit Site visit of the Project Injection Site. Ms. Celina Duong (Environmental Engineer) and
Mr. Brendan Barski (Site GHG Reporter) of Shell arranged the Site visit, provided an overview
of the Facility operations, answered verification questions, and coordinated data retrievals.
Mr. Barski and Ms. Duong were the primary staff members interviewed by GHD, and are
responsible for the preparation of the OPR. On the first day, Andrea Smitchz (Quest OSE) from
Shell also attended the site visit. Note that the Injection Site visit were conducted concurrently
with the Shell Chem Solar 2022 Offset TIER Report verification site visit. Member of AEPA were
also present for the Injection Site visit.
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GHD also interviewed the following Shell personnel during the two in-person site visits:
• Mark Rogers (Maintenance Tech Support), review of Quest metering and analyzers
• Trevor Pawlik (Operator), Injection Well #3 Operator
• Merisha Bily (Electrical Engineer), Electricity Meter tour
Issues Logs
During the course of the document review and interviews, questions and clarifications were
identified by the Project Team; these were communicated to Shell either verbally, by email, or
in an Issues Log sheet. Shell had an opportunity to respond to identified issues prior to the
completion of GHD's draft and final verification reports.
Internal Peer Review

GHD conducted an independent peer review of the verification, including a review of findings
and emission calculations developed by the verification team. This peer review was documented
in a Peer Review Memo completed by the assigned independent peer reviewer. The verification
report and statement was not finalized until approval was received from the peer reviewer.
Documentation and Deliverables

GHD prepared the following deliverables to document the verification services provided:
• COI Checklist, which will meet the TIER requirements

• Statement of Qualification (included in the proposal)
• Verification Plan (prior to site visit and after receiving relevant information)
• Draft Verification Report
• Final Verification Report
• Statement of Verification (included in Verification Report)
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Risk Assessment
Based on GHD's review of the Site operations, GHD prepared the following table, which summarizes the potential risk and
magnitude of potential errors, omissions, or misrepresentations:
Potential Risk Percentage of Attributes Inherent Risk Control Risk Detection Consideration for
Area (Sink and total Risk Design Procedure
Source) Baseline/
Project
Emissions
Baseline Emission
B1: Injected 100% Occurrence High – Based on total Low – One meter Low GHD has set the
CO2 CO2 injected. Metering present at each detection risk as low,
points are required to be injection well, and one as GHD reviewed all
located as close to the composition CO2 injected
injection points as measurement system. measurements and
possible. Composition of All meter and analyzer composition data for
CO2 is understood to be data is stored within crediting period.
based on direct gas Shell’s PI system,
analysis; understood to while sampling data is
be additional manual stored in LIMS.
samples historically
collected. Potential
venting/fugitives after
metering point (at
Completeness injection points)
captured in project
condition.
Accuracy Low – Metering system

present at each injection
well and composition
based on gas analysis on
injected CO2 stream.
Classification Low – classification of offsets is well defined

within the system.
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Source) Baseline/
Project
Emissions
Transparency Medium - Calculations are completed in “black-

box” calculation model, although inputs and
outputs, along with methodologies are clearly
defined.
Consistency Low – Understood calculations are consistent

with previous reporting periods
Project Emissions
P3: Well <1% Occurrence Low – only reportable if Medium – Emissions Medium GHD confirmed if any
Drilling gas is released during estimated based on reportable gas
Reportable Completeness kicks and blowouts of procedures as per AER releases from well
Releases wells as per the Alberta Directive 059. drilling occurred
Accuracy Energy Regulator (AER) during crediting
Directive 059. Emissions period.
during reportable
releases are quantified
using methodologies
defined in the
Directive 059 Reports.

within the system.

defined.

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Source) Baseline/
Project
Emissions
P4: Production <1% Occurrence Medium – multiple Medium – based on Medium GHD reviewed total
and Delivery of materials used in CCS delivery and metered quantification of the
Material Inputs Completeness process. Quantities of quantities of the material inputs as well
each determined based different material as confirm
on delivery and metered inputs. All delivery appropriateness of
quantities. Emission invoices are stored on emission factors.
factors estimated based Shell’s servers, and Based on the size of
primarily on literature meter data is stored in the project emissions
references. Shell’s PI system. from previous
reporting periods,
Accuracy Low – based on delivery significant
and metered quantities discrepancies in
of the different material emissions for this
inputs. category are not
expected to result in
Classification Low – classification of offsets is well defined material error.
within the system.

defined.

Page 19 of 70
April 2023
Source) Baseline/
Project
Emissions
P5, P6 & P7: 7.1% Occurrence High – Two types of High – Total quantities Low GHD reviewed
Extraction/ fuels used (natural gas of steam measured complete details of
Processing and Completeness and liquid fuels including based on multiple the steam balance
Transportation diesel, gasoline, and steam meters, along and confirmed total
of Fuel Used propane). Total natural with temperature and quantities of natural
for On-Site and gas usage based on pressure meters. gas used, as well as
Off-Site Heat complex steam balance. Liquid fuels determined liquid fuel invoiced
and Electricity Liquid fuels based on based on invoicing. quantities. GHD
Generation default emission factors Steam metering data is confirmed
for each fuel used. stored on Shell’s PI appropriateness of
system. emission factors.
Accuracy High – Complex steam
balance used to quantify
natural gas usage. Liquid
fuels determined based
on invoicing.

within the system.

defined.

Page 20 of 70
April 2023
Source) Baseline/
Project
Emissions
P8: Off-Site 20.7% Occurrence High – Multiple Medium – the majority Low GHD reviewed all
Electricity electricity meters and of electricity usage is electricity metering
Generation Completeness invoices (for electricity based on direct quantities. GHD
usage at wellpads) used metering. A confirmed
to quantify electricity small (<1%) quantity appropriateness of
usage by the Project. is estimated. Electricity emission factors.
Standard emission meter data is stored in
factors are used for both Shell’s PI system.
quest and grid-derived Electricity invoices for
electricity. wellpads stored on
Shell’s server.
Accuracy Medium – the majority
of electricity usage is
based on direct
metering. A small (<1%)
quantity is estimated.

within the system.

defined.

Page 21 of 70
April 2023
Source) Baseline/
Project
Emissions
P9: Off-Site 72.1% Occurrence High – Total natural gas High – Total quantities Low GHD reviewed
Heat based on steam balance of steam measured complete details of
Generation Completeness and back-calculation of based on multiple the steam balance
equivalent fuel gas steam meters, along and confirmed total
burned. Composition of with temperature and quantities of natural
natural gas based on pressure meters. gas used, as well as
third-party information Steam metering data is the third-party
stored on Shell’s PI composition data.
Accuracy High – Steam balance system.
used to quantify natural
gas usage.

within the system.

defined.

Page 22 of 70
April 2023
Source) Baseline/
Project
Emissions
P10: On-Site <1% Occurrence Low – based on total Medium – total fuel Medium GHD confirmed if any
Heat and invoiced propane, consumption based on on-site
Electricity Completeness methanol and metered invoicing (propane) propane/natural
Generation natural gas usage. and metering (natural gas/methanol
Accuracy Default emission factors gas). Invoices are consumption for heat
for propane, while stored on Shell’s or electricity
natural gas emission server. generation occurred in
factors calculated based crediting period.
on gas composition.

within the system.

defined.

P11: Carbon <1% Occurrence Low – based on total Medium – total fuel Medium GHD reviewed total
Capture consumption of diesel, consumption based on quantification of fuel
Storage Facility Completeness gasoline and aviation invoicing. Invoices are usage as well as
Operation fuel, calculated based on stored on Shell’s confirmed
Accuracy direct measurement, server. appropriateness of
invoices or calculated emission factors.
based on kilometers Based on 1st crediting
driven. Default emission period project report,
factors for each fuel type significant
used. discrepancies in
Page 23 of 70
April 2023
Source) Baseline/
Project
Emissions
emissions for this
category are not
within the system.
expected to result in
material error.
defined.

P18: Venting of <1% Occurrence Low – multiple vent Medium – multiple Medium GHD reviewed total
CO2 at event categories. Total vent event types can quantification of
Injection Well Completeness gas vented and occur, with different vented quantities and
Sites composition for each quantification methods composition of vented
Accuracy type based on either for each. Calculations gases. Based on 1st
engineering calculations for the vented crediting period
or direct measurements. quantities are project report,
performed on significant
spreadsheets stored on discrepancies in
Shell’s server. emissions for this
category are not
Classification Low – classification of offsets is well defined expected to result in
within the system. material error.
Transparency Medium - Calculations are completed in “black-box”

calculation model, although inputs and outputs,
along with methodologies are clearly defined.
Consistency Low – Understood calculations are consistent with

previous reporting periods
Page 24 of 70
April 2023
Source) Baseline/
Project
Emissions
P19: Fugitive <1% Occurrence Low – total fugitive Low – based on known Medium GHD confirmed
Emissions at emissions on fitting equipment counts and equipment counts and
Injection Well Completeness counts and default measured gas gas composition. Based
Sites emission rates from each composition. on 1st crediting period
Accuracy type of fitting. Gas project report,
composition based on significant
measured injected gas discrepancies in
composition. emissions for this
category are not
Classification Low – classification of offsets is well defined within expected to result in
the system. material error.


P20: Emissions <1% Occurrence Low – emissions Medium – Shell’s PI and High GHD reviewed
from calculated only if a leak is LIMS systems are the documentation and
Subsurface to Completeness detected. Methodologies primary data storage methodology used to
Atmosphere to monitor subsurface location; however, some assess leaks from the
Accuracy storage of CO2 and leaks data is stored in subsurface to confirm
performed by Shell using alternative locations, whether leaks occurred
several methodologies at which is then manually during the crediting
multiple levels – each downloaded and period.
methodology is described transferred by Shell
in the Methodology, personnel. All data is
Monitoring and monitoring by Shell.
Verification Plan (MMV).
Classification Low – classification of offsets is well defined within

the system.
Page 25 of 70
April 2023
Source) Baseline/
Project
Emissions


P21: Loss, <1% Occurrence Medium – multiple Medium – based on Medium GHD reviewed total
Disposal or materials used in CCS delivery and metered quantification of the
Recycling of Completeness process that can potential quantities of the disposals as well as
Materials Used be disposed. Quantities of different material confirmed
each determined based on inputs. All delivery appropriateness of
disposal and recycling invoices are stored on emission factors. Based
estimates. Emission Shell’s servers, and on first crediting period
factors estimated based meter data is stored in project report,
on material balances. Shell’s PI system. significant
discrepancies in
Accuracy Low – based on delivery emissions for this
and metered quantities of category are not
the different material expected to result in
inputs. material error.
Classification Low – classification of offsets is well defined within

the system.


General
Page 26 of 70
April 2023
Source) Baseline/
Project
Emissions
Project NA Occurrence High – if the project quantification methodology Low GHD assessed the
Eligibility and deviates from the Protocol and the validation, it Project against the
Conformance Completeness would result in a non-conformance with the offset criteria to
with Project verification criteria. confirmed project
Plan and Accuracy eligibility.
Protocol
GHD reviewed the
Classification Project Report against
the Project Plan and
Transparency Protocol
Consistency
Page 27 of 70
April 2023
Source) Baseline/
Project
Emissions
Use of ICT NA Occurrence Medium –The GHD project Medium – ICT Medium The majority of
team has previous technologies are activities were
Completeness experience in conducting available to both Shell conducted on-Site or
verifications for similar and GHD, when via desktop review, but
Accuracy project types. required. selected interviews
were conducted
Classification virtually. To lower the
detection risk, GHD
Transparency worked with Shell to
arrange meetings at
appropriate times for
Consistency
Shell operators and
staff to be available to
work through the
verification process and
provide sufficient time
to deal with potential
technical limitations.
Data NA Occurrence Medium – Majority of Medium – All data is Low The data management
Management quantities used for managed and tracked systems are present at
Completeness emission reduction are by Shell personnel. the Site. GHD reviewed
real-time data stored on Multiple systems are all data systems and
Accuracy PI or LIMS systems, or via used to track data. the flow of data
third-party invoices. between them.
Classification Some data for subsurface
emissions (P20) are from
Transparency additional data systems.
Consistency
The final sampling plan developed based on the risk assessment is presented in the final Verification Plan, included as Appendix A to this
report.
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April 2023
3.2 Team
Roles and Responsibilities
Designated Signing Authority – Deacon Liddy – Mr. Liddy will review and sign the
verification report and statement.
Lead Verifier – Sean Williams – Mr. Williams will lead the verification and is responsible for
development of the verification plan. Mr. Williams will review the risk assessment, recalculation
of raw data, data management and draft findings. Mr. Williams will prepare the verification
statement and verification report. Mr. Williams conducted a site visit of the Project.
Verifier – Stepheney Davey –– Ms. Davey will develop and revise the verification plan and
sample plan, develop a risk assessment, recalculate raw data, review management of data
quality and prepare draft findings. Ms. Davey will conduct a site visit of the Project.
Verifier – Bryan Rubie –– Mr. Rubie will develop and revise the verification plan and sample
plan, develop a risk assessment, recalculate raw data, review management of data quality and
prepare draft findings. Mr. Rubie will conduct a site visit of the Project.
Peer Reviewer – Gordon Reusing – Mr. Reusing will conduct a peer review of the risk
verification plan risk assessment and verification report and findings.
Qualifications
Deacon Liddy, P. Eng. – Mr. Liddy is a Principal with GHD and an experienced GHG validator
and verifier, having completed over 100 GHG validation/verifications with 17-years of
experience. Mr. Liddy works with large industrial facilities, Provincial governments, and offset
project developers to complete risk-based verifications. Mr. Liddy has been the lead verifier for
completion of greenhouse gas verifications conducted on behalf of Alberta Environment for
emission offset projects for landfill gas, biomass, tillage, composting and fuel switching for
lumber kilns. Mr. Liddy has completed verifications of greenhouse gas emission intensity
baseline applications and annual compliance reports under the Alberta Specified Gas Emitters
Regulation and British Columbia Mandatory Reporting Regulation. Mr. Liddy is a professional
engineer in BC, Alberta, and Saskatchewan.
Sean Williams, P.Eng. – Mr. Williams is a Project Manager, GHG Lead Verifier and Technical
Expert and with over 10-years of experience in environmental consulting and is a licensed
Professional Engineer in the provinces of Alberta, Saskatchewan and Ontario. Mr. Williams has
experience in completing greenhouse gas verifications, permit applications, air and noise
compliance assessments, completion of annual inventory reports under various voluntary,
provincial and federal regulations across Canada. Mr. Williams is an accredited lead verifier
under the California Air Resources Board and Oregon Department of Environmental Quality.
Mr. Williams has significant air and GHG expertise in a variety of industrial sectors, including oil
sands extraction and upgrading, refineries, chemical plants, mining and mineral production,
power generation facilities, waste management and metals production. Mr. Williams serves as
the Greenhouse Gas Assurances Services (GGAS) Manager for GHD’s ANAB accreditation.
Stepheney Davey, M.Sc., E.I.T. – Ms. Davey is a junior engineer and member of the EHS
Compliance team with GHD. She holds a Master of Science degree in Chemical Engineering
from the University of Alberta. Ms. Davey has been involved with multiple GHG verifications in
various sectors under the Greenhouse Gas Industrial Reporting and Control Act in British
Columbia, The Management and Reduction of Greenhouse Gases in Saskatchewan and the
Technology Innovation and Emissions Reduction regulations in Alberta. She has also been
involved with reporting under the federal Output-Based Pricing System and national reporting
under the National Pollutant Release Inventory. Her experience includes a range of industries
including oil and gas extraction, production and upgrading, power generation, chemical
production, pulp and paper mills, and mining and mineral production facilities.
Page 29 of 70
April 2023
Bryan Rubie, P.Eng. – Mr. Rubie has a Bachelor of Environmental Engineering from the
University of Guelph. Mr. Rubie has experience completing permit applications, air and noise
compliance assessments and completion of annual inventory reports for a number of industrial
facilities. Mr. Rubie has experience in greenhouse gas verifications under the Alberta Specified
Gas Emitters Regulation (SGER) and Carbon Competitiveness Incentive Regulation (CCIR) and
has acted as verifier for a number of projects. Mr. Rubie also has experience in completing
greenhouse gas reports for numerous oil and gas facilities as per the US EPA Greenhouse Gas
Reporting Program (GHGRP).
Gordon Reusing, M. Sc., P. Eng. – Mr. Reusing is a greenhouse gas (GHG) Lead Verifier,
Lead Validator, and Peer Reviewer with extensive experience including GHG programmes in
Alberta, British Columbia, Saskatchewan, Ontario, Quebec, Nova Scotia, California, and
programmes operated by the United Nations Framework Convention on Climate Change
(UNFCCC) Clean Development Mechanism (CDM), The Gold Standard, The Climate Registry
(TCR), the Carbon Disclosure Project (CDP), and Verra: Verified Carbon Standard (VCS). He has
completed numerous GHG quantification studies for the oil and gas sector, including upstream,
midstream and downstream facilities. Mr. Reusing has conducted GHG verifications as a Lead
Verifier, Technical Expert and Peer Reviewer in many jurisdictions, including, but not limited to,
British Columbia, Alberta, Ontario, Quebec, and Nova Scotia.
3.3 Schedule
The following presents the final verification schedule:
• Submit Verification Plan to Shell – January 31, 2023
• Shell Verification Plan review period – January 31 – February 2, 2023
• Request, receive, and review documents and raw data from Shell – February 15 –
April 2023
• Site Visit – February 8, 2023 (Capture Site), April 6, 2023 (Injection Site)
• Issues Log provided to Shell – February 16, 2023
• Issue draft Verification Report to Shell – April 24, 2023
• Issue final Verification Report and Statement of Verification – April 28, 2023
Page 30 of 70
April 2023
4.0 Results
The verification results are presented in the following five subsections. Subsections 4.1 – 4.3
present the results of the verification procedures for the data integrity (4.1), Quantification
Methodologies and Quantification (4.2), and Boundary Conditions and Activity Data (4.3).
4.1 Assessment of Internal Data Management and Controls
Summary of Data Management and Controls Procedures
The total quantities of emissions from the various baseline and project sources and sinks are
determined based on either direct measurement, third party data, and/or engineering
estimates.
The data management system used by Shell is built upon the existing systems at the Scotford
Site, and is based on a network of Data Focals. The Data Focals consist of various personnel
responsible for the collection and maintenance of data at key measurement points. Each Data
Focal collects the required data for each unit and completes required review and QA/QC on a
monthly basis. Once the data is confirmed, it is supplied to the Shell Environment Department.
Meter and analyzer data is collected from the measurement points by the Distributed Control
System (DCS), and then stored in the Process Information (PI) system. The final meter data is
stored within the PI system. All meters involved have specified standards and practices to
control uncertainty, including calibration and preventative maintenance activities. Data is stored
for at least seven year's past the end of the project reporting period.
At the injection sites, most of the data is integrated with the DCS/PI systems with the exception
of the distributed temperature sensors in the injection wells; this data is stored in separate
storage located on each well during the 2022 reporting period, then transferred for archiving.
Additional data comes from third-party data. These files are received by the relevant personnel
and sent to the Environment Department for storage.
The Data Focal collects all key data and enters this data into the Shell Environmental Reporting
System (SERS), which is the Site’s emissions calculation software. The data and outputs from
the SERS software is reviewed monthly, quarterly and yearly to ensure accuracy.
Findings and Conclusions
Flow of Data
GHD verified that the flow of data from the meters/analyzers through to the SERS system was
appropriate, and could verify that the raw readings from the meters are appropriately
transferred.
GHD noted that the use of the SERS system removes some transparency, as the actual
calculations used can be difficult to review (as opposed to an excel system, which allows for
easy reading of the formulas). The inputs and outputs along with the calculation formulas from
the system can be downloaded, which GHD reviewed and confirmed were appropriate.
Therefore GHD was able to determine that SERS was calculating emissions in accordance with
the Project Plan.
The use of Data Focals to collect and review source-specific data is appropriate. There is some
risk due to the separate responsibilities of these Data Focals. GHD has confirmed that the
Focals interviewed as Part of the verification were knowledgeable in the specific tasks required,
however, there were some issues in transfer of data as a result of the Data Focals, mainly
found while verifying electricity (P8).
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April 2023
Meter Calibrations
Multiple gas flow, steam and electricity meters are used as Part of the data measurement and
collection for the project (in particular the B1 injection CO2 and P9 heat generation categories).
All meters are subject to Shell’s preventative maintenance (PM) program, and a minimum
calibration frequency of annual has been set for all transmitters identified as “key” for the
purposes of the Quest project.
As Part of the verification, GHD received the following calibration records (some directly used in
the calculation of baseline/project emissions):
FIT-702104 – CO2 injection in Well #1 (July 6, 2022)
FIT-247004 – CO2 injection metered at capture site (February 24, 2022)
FT-246005, FT-246006, FT-246120 – LP steam to Quest (July 27, 2022)
FT-248001 – (August 18, 2021)
FT-248004 – HP steam to Quest (June 29, 2022)
FT-246085– condensate return flow from Quest (August 18, 2021)
FT-251020A – HP steam pressure to Quest (September 30, 2019)
PI-246065 – condensate return from Quest pressure (October 9, 2019)
PT-241062/PT-242062 – HP-IP letdown pressure (November 25, 2019)
PT-247025 (March 8, 2018)
TT-251084 – High Pressure steam to Quest (July 7, 2022)
TI-246050 – condensate return from Quest temperature (September 3, 2021)
TT-247058 (March 2, 2020)
PV-251020A/B – Pressure relief values for HP-MP letdown (July 22, 2022)
PV-251022A – Pressure relief values for LP steam pressure to Quest (September 30, 2019)
FI-246094 – Nitrogen distribution meter (August 18, 2021)
52-15B (Quest Main power) and 52-16B (Compressor power) – Shell has indicated these
meters do not have documentation and do not need to be calibrated.
GHD has reviewed each of the above calibration records, and confirmed that they were
appropriate. There is no specific calibration frequency currently defined for steam meters, this
is not a specific deviation with the protocol, and the impact on emissions is minimal.
The calibrations without documentation have been noted as Item 22-05 in Appendix C.
Conclusion
GHD reviewed available meter calibration records for the meters. Multiple meters were not
calibrated; this will not result in a material misstatement.
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April 2023
4.2 Assessment of GHG Data and Information

Effectiveness of ICT
Summary of ICT Techniques Used
GHD and Shell used MS Teams to hold calls, video conferences and screen shares. GHD and
Shell used an online SharePoint folder and email to share files.
Findings and Conclusions
The majority of the verification was conducted via on-Site activities and as a desktop exercise;
some client calls between Shell and GHD did occur via MS Teams, in particular a high-level
overview of the Shell Quest Project prior to the site visits along with interviews with the data
focals and reviewing the raw client files and back-up data for the Mass Balance, Power Balance
and Heat Balance spreadsheets.
GHD and Shell encountered no issues using ICT as a Part of this re-verification; transfer of data
between Shell and GHD was smooth, and MS Teams calls did not encounter any technical issues.
Based on GHD's review, the ICT technologies used are acceptable and reasonable for use in the
Offset Project Report, and GHD was able to maintain the acceptable level of assurance during
the verification.
B1- Injected CO2
Quantification of Total Gas Injected
The total gas quantities sent for injection are measured by continuous Coriolis mass flow
meters at two distinct points within the system:
• FIT-247004 –located downstream of compressor at CCS Facility
• FIT-702104 – located at Injection Well 1
For the purposes of calculating the emissions reductions, Shell utilizes the three injection well
meters, with the CCS Facility meter used as a reasonableness check. Each of the injection
meters measure the flowrate on a mass basis.
The measurement requirements for injected gas are specified in the Protocol, Section 5.1.2,
Table 8. These requirements and Shell’s conformance with the requirements are summarized
below:
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April 2023
Protocol Requirement Review of Item
Continuous measurement of gas flow (defined as The meters record data at a greater than
one measurement every 15-minutes). 15-minute measurement rate. For the
purposes of calculating baseline
emissions, meter data is aggregated on
an hourly basis.
Meter readings May be temperature/pressure As the meters are Coriolis mass flow
compensated to standard temperature and meters, compensation is not required.
pressure.
The flow meters must be placed based on GHD has confirmed the meters were
manufacturer’s specifications installed per manufacturer’s
recommendations.
Must be placed downstream of the input to the GHD has verified that the location of the
gas transport equipment such that they are injection meters are as close to the
downstream of the capture and compression injection wellheads as possible,
equipment to account for fugitives and venting downstream of the gas transport
equipment.
Flow meters should be as close as possible to
injection wellheads to ensure accurate
measurement of injected volumes
Flow meters must be calibrated according to GHD has confirmed that the meters are
manufacturer’s specifications, and must be calibrated on a yearly basis per
check/calibrated at regular intervals according to manufacturer’s specifications. As noted
these specifications and industry standards above, GHD has confirmed the
calibrations were performed properly.
Ownership must be clearly documented for CO2 Not applicable, as both the CCS Capture
transferred (third-party injection activity). and Injection sites are owned/operated by
the AOSP JV/Shell.
Based on GHD’s review, the total quantity of gas injected along with the meters used to
measure these quantities are appropriate and in accordance with the Protocol requirements.
Quantification of Injected Gas Composition – Analyzer Measurements
As defined by Shell in the OPP, the injected gas composition (specifically CO2, methane (CH4),
hydrogen (H2) and water (H2O)) is measured via a continuous online gas analyzer, located at
the Quest CCS Facility (specifically located on the suction side of the seventh stage
compressor). This analyzer measures data on a continuous basis (at a rate greater than once
every 15-minutes), which is then aggregated by Shell on an hourly basis for the purposes of
calculating GHG emissions. This is in accordance with the Protocol.
Issues were identified in the analyzer just after installation, which required updates. While
these issues have been resolved, Shell does conduct additional analysis of the CO2 injected
stream, including grab samples analyzed both on-Site and via a third-party laboratory. These
analysis are in addition to the protocol requirements.GHD has confirmed that the composition is
determined in accordance with the Protocol.
Calculation Methodology for Emissions
The Protocol requires that the Injected CO2 be calculated as per the equation listed in
Section 4.1, Table 6, Part B1. GHD notes that this equation is specifically based on volumetric
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April 2023
flowrates and compositions for gas injected and CO2 composition. The use of mass flowrates
and composition is not a deviation from the protocol as noted above, and the methodology used
by Shell is functionally equivalent to Protocol equation (just on a mass rather than volume
basis). Therefore GHD has verified that the calculations are completed in accordance with the
Protocol.
Recalculations
Based on the provided information, GHD has recalculated the B1 - Injection CO2 emissions.
These recalculations have yielded a difference of 25.18 tonnes CO2e, <0.01% of total baseline
emissions and <0.01% of total reductions, which is not material. This has been noted as
Issue 22-01.
P3 – Well Drilling and Construction Activities
GHD has confirmed that all well drilling and construction activity venting occurrences are
reported and calculated based on the Protocol and Directive 059 requirements. During the 2022
reporting period, Shell did not report any emissions from well drilling activities. GHD has
confirmed there were no venting events due to well drilling during the 2022 reporting period,
therefore this is appropriate.
P4 – Production of Material Inputs
The following materials are included as Part of the Project:
• Utility/Instrument Air
• Nitrogen
• Methyl diethanol amine (MDEA)
• Antifoam
• Activated Carbon
• Water
• Lubricant
• Refrigerants
• Caustic Soda
• Refridgerants (HFCs)
Consumption of Material Inputs
For MDEA, antifoam, activated carbon, lubricants, refrigerants and caustic soda, emissions are
based on top-ups and purchases of each material, with the purchased quantities equal to the
used amount during the reporting period. GHD notes that the actual consumption amounts may
be different than the shipment amounts; given the low amount of emissions associated with
this source, this will not result in a material discrepancy in the claimed reductions. For the 2022
reporting period, Shell claimed material purchases of 27,100 kg of caustic soda and 8960 kg of
triethylene glycol (TEG), which GHD verified as appropriate.
Shell also reported a three periods of refrigerant (HFC401a) leaks for the 2022 reporting year
which was then added to the Quest site. Shell originally missed these HFC leaks in their original
SERS report. This has been noted in Issue 22-02.
The consumption of nitrogen is estimated with a combination of metered quantities and
engineering estimates. Much of the nitrogen flow is below meter detection thresholds, requiring
engineering calculations to estimate these flowrates. GHD has reviewed the estimation for
nitrogen and confirmed that it is conservative and appropriate. A small quantity of nitrogen is
also used at the wellpads, contained in bottles which are tracked by the field operators based
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April 2023
on deliveries. The total quantities of nitrogen at the wellpads is estimated based on the
purchased quantities of nitrogen bottles. Shell has omitted the Project’s nitrogen usage for the
month of May in their original SERS report. This Issue has been noted in Issue 22-03.
Utility/instrument air consumption is estimated based on the maximum design flow rate of
instrument air in the Quest project. This estimation method will give a conservative maximum
air usage rate, and therefore a conservative estimation of project emissions. The estimated
amount of instrument air used is 5,594,000 m3.
Water is based on direct metering of the wastewater treated on-Site. It is noted there are no
emissions associated with the production of wastewater (as all water is sourced from local
water bodies).
Emission Factors for Material Inputs
For instrument and utility air, as air is supplied primarily by electric-driven compressors, the
emissions associated with its production are based on the rated power for the compressor and
air supply rate (0.597 MW of power divided by 4,500 sm3/hr = 1.327x10 3 MWh/sm3), which is
then multiplied by the Alberta grid emission factor for increased on-Site grid electricity usage
(0.64 tonnes CO2e/MWh). GHD has confirmed that this calculation is appropriate, and that the
correct grid factor has been used.
For other material inputs, Shell has utilized academic or related data to derive emission factors
for the various materials. For example, the nitrogen emission factor has been derived based on
a nitrogen production factor of 1.093 MWh/tonne N2 published by the US Office of Technology
Assessment, and the Alberta grid factor (since in this specific case, nitrogen is supplied by the
Air Liquide Facility located on the Scotford Site). In some cases, no direct primary or secondary
emissions data is available, so a reasonable analogue has been used; for example, data to
calculate an emission factor for MDEA was not readily available, so a factor for monoethylamine
(MEA) was derived and has been assumed to apply to MDEA (along with any other future amine
solvents). GHD has reviewed the derivation of each material input emission factor, and has
determined that the factors calculated are reasonable and conservative.
Calculation Methodologies for Emissions
The Protocol requires that the emissions be calculated as per the equation listed in Section 4.1,
Table 6, Part 4. GHD has confirmed that this equation is used by Shell.
GHD has confirmed that the Protocol has no specific quantification requirements for the
calculation of material consumptions.
Recalculations
Based on the provided information, GHD has recalculated P4 emissions. GHD identified a
difference of 0.5 tonnes contributing to a total error in project emissions of 0.2%
(underreported) and a total error in reductions of 0.01% (overreported). This difference is likely
due to rounding. This difference is not material. This has been noted as Item 22-01.
P5/P6/P7 – Extraction/Processing of Fossil Fuels for Off/On-Site Electricity/Heat
Generation
Two fossil fuels are combusted for off/on-Site electricity/heat generation; natural gas (used for
both on and off-Site heat generation), and methanol (on-Site only).
Consumption of Fuels
The total consumption of natural gas/methanol and GHD’s findings is documented in the
findings for P9 (off-site heat generation) and P10 (on-site electricity and heat generation).
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April 2023
Emission Factors for Fuels

The emission factors for fuel extraction/processing and transportation are taken from the
“Carbon Offset Emission Factors Handbook”, Version 1.0, March 2015 (EF Handbook), published
by AEP, Table 4. This table includes extraction and processing emissions for natural gas. It is
noted that a more recent Version of this Handbook (latest Version is 3.0) has been published,
but as this project was initiated prior to its implementation it is not required to be utilized.
The methanol emission factors are based on a combination of production factors from
Environment and Climate Change Canada (ECCC) National Inventory Report, 1990-2015 (NIR)
and a derived factor for transportation based on the original of the methanol (Germany) and
distance to the Project. GHD notes that rail factors were used by Shell for the entire distance as
this was considered more conservative. GHD tested that assumption by comparing against
marine transport emission factors (the most logical alternative). GHD has confirmed that
marine transport have lower emission factors overall (between 3.81 – 15.33 g
CO2e/deadweight-tonne nautical-mile (dwt-nm) 1), therefore the use of rail transport emission
factors are more conservative.
Table 6, Parts P5, P6 and P7. GHD has confirmed that this equation is used by Shell.
calculation of consumptions beyond what is required in P8, P9 and P10.
Recalculations
Based on the provided information, GHD has recalculated P5/P6/P7 emissions. These
recalculations have yielded a difference of 36.51 tonnes CO2e, 0.01% of total project emissions
(overreported) and 0.01% of total reductions (underreported). This difference is not due to any
specific discrepancy in Shell’s calculations. This difference is not material. This has been noted
as Item 22-01.
P8 – Off-Site Electricity Generation
Total Electricity Consumption
Shell Quest CCS receives electricity from the Alberta Electricy Grid and from the Gas Turbine
(GT) on-site at the Scotford Upgrader Cogeneration Plant (Upgrader Cogeneration or Cogen).
The following users are electricity are assumed by Shell to be sourced entirely from the Alberta
Electricity grid:
• Quest Capture Site: Electrical sources (amine pumps transformers, heat tracer
transformers, etc.) are calculated based on the maximum design ratings for electricity
usage for each equipment. The compressor motor power (52-16B) and one for the main
Quest power (52-15B), however, frequently receive electricity from Cogen as discussed
further later in this section.
1
Greenhouse gas emissions from global shipping, 2013–2015, The International Council on
Clean Transportation, https://www.theicct.org/publications/GHG-emissions-global-shipping-
2013-2015
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• Quest Injection Site: Total electricity at each of the three injection sites is metered based on
third-party utility meters. Electricity invoices is provided to Shell’s accounting department,
who store all invoice data and provide the final monthly values.
In addition, the following two sources of electricity at the Quest Project are assumed by Shell to
be sourced via Upgrader Cogen. However, during periods that GT cannot provide enough
electricity to these sources, electricity is imported from the grid. GHD has confirmed the
method used to calculate the amount imported versus provided by the GT is acceptable.
• Quest Capture Site: The majority of electricity at the Capture Site is measured via two
electrical meters, one for the compressor motor power (52-16B) and one for the main Quest
power (52-15B). The summation of these two meters provides the majority of total Quest
electricity.
• Upgrader Electricity: There is an incremental increase in cooling water circulation in the
Upgrader due to the implementation of the Quest Project; this increase in water increases
the load in the cooling towers, and as a result requires additional electricity generation.
Shell This electricity increase is based on engineering estimates. Electricity usage is
estimated based on the measured usage of the cooling towers, rated fan speed, measured
total cooling water usage rate (on a daily basis) and the rated cooling water requirements of
the Quest Project, as follows:
𝑄𝑄𝑄𝑄𝑄𝑄𝑄𝑄𝑄𝑄𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐 𝑤𝑤𝑤𝑤𝑤𝑤𝑤𝑤𝑤𝑤
𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐶𝐶𝐶𝐶 = 𝐹𝐹𝐹𝐹𝐹𝐹 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 ∗ %𝐹𝐹𝐹𝐹𝐹𝐹 𝐿𝐿𝐿𝐿𝐿𝐿𝐿𝐿 ∗
𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐 𝑤𝑤𝑤𝑤𝑤𝑤𝑤𝑤𝑤𝑤
GHD notes that for the unmetered quantities there is some risk that the values are not
necessarily representative of total electricity, as they are based on estimates as opposed to
direct metering.
During GHD’s review of the Cogen electricity, GHD found that Shell accounted for the electricity
from the cooling tower fan twice. Cooling tower electricity is counted as a Part of Cogen
calaculations which was the summation of compressor motor power, main Quest power, and
cooling water tower electricity. Shell also had included cooling tower electricity as a standalone
value in SERS. This has been noted as Issue 22-04. Shell has since remediated this issue.
As Cogen electricity is used to partially power the Quest Project, Shell requested permission to
use an emission factor other than grid-derived electiricty for the portion sourced from the
Cogen. The Alberta Environment and Parks (AEP) provided a re-approval on February 28, 2023,
for a deviation request to use the Technology Innovation and Emissions Reduction (TIER)
Electricity Benchmark of 0.37 tonnes CO2e/MWh for directly connected electricity given all the
protocol requirements are met. The protocol has several conditions which must be met to use
an electricity emissions factor other than grid. The measurement requirements for off-Site
electricity generation are specified in the Protocol, Section 5.1.2, Table 9. These requirements
and Shell conformance with the requirements are summarized below:
Electricity Consumption: Continuous The electricity meters at Quest record data at

measurement of electricity consumption or a greater than 15-minute measurement rate.
reconciliation of maximum power rating for each For the purposes of calculating emissions,
type of equipment and operating hours. meter data is aggregated on an hourly basis.
Electricity meters must be calibrated by an Confirmed the direct meters used are
accredited third-party in accordance with calibrated by an accredited third-party
manufacturer specifications. (Chemco Electrical Contractors Ltd., a
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April 2023

member of the Electric Contractors
Association of Alberta).
All other sources are based on either third-
party electricity or estimates.
Incremental, Directly Connected Electricity: For Direct Connection, Quest is supplied by

Continuous measurement of electricity electricity from the Shell 284 Substation.
consumption or reconciliation of maximum Electricity from the GT and Steam Turbine
power rating for each type of equipment and Generator (STG) in the Upgrader Cogen is fed
operating hours. Note that electricity under this into the 284 Substation. Electricity from the
category must meet the following three criteria: Industrial System Designation (ISD) is also
• Direct Connection: electricity source is fed into this 284 Substation. The ISD for the
directly connected to the site or through a Scotford Complex is connected to different
recognized Industrial System Designation facilities at Scotford including:
(ISD) • Scotford Upgrader, which includes
• Dedicated Electricity Contract: electricity is Scotford Upgrader Cogen and the Quest
sourced using an electricity purchase Capture Site
agreement • Scotford Refinery
• New or Unused Generating Capacity: • Air Liquide, which includes the Air Liquide
electricity resulting from incremental Cogeneration Plant and the Shell
electricity generating capacity that was not Chemicals Facility.
previous utilized (this electricity must either
be newly installed or unused in an average
hour over the three year period prior to and
ending within six months of project
initiation).
Emission Factor for Off-Site Electricity

The main grid electricity factor as published in the EF Handbook, Table 2 for “Increased on-Site
grid electricity” was used by Shell. GHD has confirmed that the appropriate emission factor of
0.57 tCO2e/MWh has been utilized.
As discussed previously, Shell requested permission to use an emission factor other than grid
as certain electricity sources use electricity provided by the Upgrader Cogen. The Alberta
Environment and Parks (AEP) provided a re-approval on February 28, 2023, for a deviation
request to use the Technology Innovation and Emissions Reduction (TIER) Electricity
Benchmark of 0.37 tonnes CO2e/MWh for directly connected electricity.
Calculation Methodologies
Table 6, Part P8. GHD has confirmed that this equation is used by Shell.
As noted above, off-site electricity was taken from grid and cogen sources of electricity. The
measurement requirements for off-Site electricity generation are specified in the Protocol,
Section 5.1.2, Table 9. As discussed previously, GHD has confirmed that these requirements
have been met by Shell.
Recalculations
Based on the provided information, GHD has recalculated P8 emissions. These recalculations
have yielded a difference of 226.42 tonnes CO2e, 0.09% of total project emissions
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(overreported) and 0.03% of total reductions (underreported). This difference is not

attributable to any specific discrepancy and not material. This has been noted as Item 22-01.
P9 – Off-Site Heat Generation
All off-Site heat is sourced from the main Upgrader steam system. The Project uses both High-
Pressure (HP) steam and Low-Pressure (LP) steam, with LP steam constituting the large
majority (>99%) of steam usage.
The measurement requirements for incremental heat are specified in the Protocol,
Section 5.1.2, Table 9. As heat is taken from the incremental increase in steam in the
Upgrader, GHD can confirm the Protocol requirement is met. It is also noted that in Section 4.1,
Table 6, the measurement of total Quest steam usage is specified as being based on direct
measurement.
Total Quest Steam Usage
All HP steam used for the Quest Project is directly sourced from the Residue
HydroconVersion (RHC) unit at the Upgrader. The total consumption of HP steam (in units
of tonnes/hr) delivered to the Quest Project is measured by a single meter, FI248004. In
accordance with the Protocol, this source is classified as an LFE non-Cogen source. GHD has
reviewed this consumption methodology and confirmed it is in accordance with the
requirements of the protocol (requiring direct measurement).
Total LP steam used by the Quest Project is taken from the LP steam header in the Upgrader
(Base Plant – the Expansion Plant has a separate steam header). There are three separate
meters which measure LP steam usage (in units of tonnes/hr) from the LP steam header,
FC246005, FC246006 and FI246120. The methodology to determine total LP steam is in
accordance with the protocol (as it relates to total steam consumption only).
Calculation of Total Heat
The enthalpy of low and high-pressure steam are calculated based on the measured
temperature/pressure of LP/HP steam (PI251020A/TI251084 for HP, PI251022A/TI251020 for
LP). GHD confirmed the calculation was appropriate.
The heat associated with condensate returned is measured based on the mass flow of total
condensate and the pressure/temperature of the condensate (FI246085A, PI246065 and
TI246050). It is assumed that 100% of the HP steam mass is returned as condensate, with the
difference between the total measured condensate and HP steam equal to the condensate of LP
steam returned. As the mass of HP steam used is much smaller than the mass of LP steam, this
is conservative from an energy perspective (as it assigns additional energy to the LP steam)
and is therefore reasonable. This calculation is reasonable.
It is noted that in reporting periods prior to December 31, 2017 that the LP steam was split
between waste heat and non-waste heat sources, but after this period all steam is considered
non-waste heat.
Emission Factors for Natural Gas/Fuel Gas Consumption
GHD has confirmed that the CO2, CH4 and N2O emission factors are calculated using the
equation for LFE non-cogen emission factor, with fuel-specific CO2 emission factors (in units
of tonnes CO2/m3), published CH4 and N2O emission factors (from the EF Handbook) and
higher-heating values. The CO2 emission factor and HHV are derived from gas sampling data.
Shell derives emission factors and HHVs based on gas composition data. The gas combusted to
produce steam primarily consists of a combination of the following three gasesous fuels
(combusted in different steam-generating equipment):
• Third-party natural gas
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• Base plant fuel gas

• Expansion plant fuel gas
The actual contribution of each type of gas to steam generation is difficult to quantify (as the
contribution of each steam generating equipment to Quest steam cannot be directly measured).
Shell assumed that all steam was generated from natural gas combustion, as this was
considered more conservative than the combined base and expansion fuel gas (allocated using
ratios).
For this reporting period, Shell modified the procedure to include a comparison of the
composition for each of the three main fuel gases, with the gas resulting in the largest project
emissions used to be conservative. For the 2022 reporting period, the natural fuel gas emission
factor was the most conservative (compared to a ratio of base and expansion fuel gas) and was
used in the calculations.
Table 6, Part P9. GHD has confirmed that this equation is used by Shell.
Recalculations
(overreported) and 0.02% of total reductions (underreported). This difference is not
attributable to any specific discrepancy in the Project Report, and is not material. This has been
noted as Item 22-01.
P10 – On-Site Heat and Electricity Generation
There are two sources of on-Site Heat and Electricity Generation:
• Natural gas used in HVAC equipment at the CCS Capture Site

• Methanol used to power up the line-break valves
Shell also could potentially use propane as a combustion source at the CCS Capture or Injection
Site – no propane was recorded during the 2022 reporting period.
The total consumption of natural gas is quantified based on direct metering of the gas to the
HVAC equipment, through meter FI246130. Methanol consumption is metered at each of the
line-break valves (six in total). GHD has confirmed these quantities are measured accurately.
Emission Factors
The emission factor for natural gas usage is the same as noted in P9 above.
For methanol, the CO2 emission factor is from the United States Environmental Protection
Agency (USEPA) reference document “Emission Factors for Greenhouse Gas Inventories”
(USEPA GHG Document). GHD has confirmed these factors are reasonable. There are no CH4 or
N2O emission factors, so propane factors were used. As the CH4/N2O emissions are minimal,
this is a reasonable assumption.
Table 6, Part P10. GHD confirmed that the methodologies are used by Shell.
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Recalculations
have yielded a difference of 0.28 tonnes CO2e, <0.01% of total project emissions
(underreported) and <0.01% of total reductions (overreported). This difference is not
attributable to any specific discrepancy and not material. This has been noted as Item 22-01.
P11 – CCS Facility Operation
There are three main fuels used to operate the CCS Facility; Gasoline/Diesel for vehicle usage,
and Aviation Turbo fuel for light aircraft involved in pipeline inspections.
The total consumption of diesel, gasoline and aviation turbo fuel are tracked on a monthly basis
by the Shell accounting department. Shell reported no aviation turbo fuel use for this reporting
period. The use of each of these records are appropriate.
Diesel and gasoline usage by the various contractors were estimated based on tracked vehicle
kilometres driven and fuel economy factors from the API Compendium, Table 4-13. The
gasoline usage by the two main Shell employees are tracked via Cardlock and fuel receipts.
GHD has confirmed the above methods for diesel/gasoline are reasonable and conservative.
Emission Factors
The emission factors for diesel and gasoline are taken from the EF Handbook, Table 7, while the
emission factors for aviation turbo fuel are from the most recent Version of the NIR. These
sources are appropriate. There were no other Protocol-specific requirements.
Recalculations
(overreported) and <0.01% of total reductions (underreported). This difference is not
attributable to any specific discrepancy, and is not material. This has been noted as
Item 22-01.
P18 – Venting at Injection Sites
Venting occurring as Part of the Project includes well head blowdowns, surface casing venting
and well workover vents.
Calculation of Gas Vented
For blowdown and workovers, vented quantities are estimated for each venting event and
tracked in the mass balance spreadsheet. No blowdown or workover venting occurred during
the reporting period.
Surface casing venting is estimated based on the results of yearly vent rate measurements for
each well. The Alberta Energy Regulator (AER) requires Shell to test for surface casing vent gas
(SCVG), which is reported under P18, and gas migration at the injection wells on a periodic
basis, and Shell has performed this test in June of every year to date. The most recent test was
completed in June 2022, which was assumed to occur at a constant rate based thereafter.
Assuming a constant venting rate based on the vent rate measurement test is a conservative
estimation method, and is appropriate.
Composition of Vented Gas
The composition of the surface casing vent gas is determined based on the sampling conducted
during the vent rate measurement tests for each well. The sampling of the well surface casing
vent gas is appropriate.
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April 2023
Table 6, Part P18. No issues were identified.
Recalculations
have yielded a difference of 0.43 tonnes CO2e, <0.01% of total project emissions and total
reductions (overreported in Project emissions, underreported in Reductions). This difference is
primarily due to rounding and is immaterial. This has been noted as Item 22-01.
P19 – Fugitive Emissions at Injection Sites
Fugitive emissions include passive venting from fittings (after the CO2 Injection Meters) and gas
migration venting.
Emissions from Fittings
The count of fittings at each well pad were completed at project outset. Emission rates are
based on the published emission factors published in the American Petroleum Institute
“Compendium of Greenhouse Gas Emissions Methodologies for the Oil and Natural Gas
Industry” (API Compendium), Tables 6-4 and 6-12. These emission factors are for total organic
compounds – to convert to CO2, equation 6-10 of the API compendium (multiplying by the
square root of the ratio of the CO2 and CH4 molecular weights) is applied. TetraTech had
previously noted that the API rates are not corrected based on the actual gas composition;
Shell has indicated that this methodology conservatively overestimates emission rates. Since
the fugitive emissions are small relative to total project emissions (<0.01% of project
emissions) and are conservative, GHD has confirmed these are appropriate.
Gas Migration Emissions
The fugitive releases from gas migration are calculated similarly to surface casing venting,
using the surface casing vent gas volumes (measured based on a once/year test done in June
2022) and the composition of the gas migration based on the annual tests. GHD has confirmed
this is appropriate.
Table 6, Part P19. No issues were identified.
Recalculations
(overreported) and <0.01% of total reductions (underreported). This difference is not material.
This has been noted as Item 22-01.
P20 – Emissions from Subsurface
Protocol Monitoring Requirements
The specific Measurement, Monitoring and Verification (MMV) requirements for emissions from
subsurface are outlined in the Protocol, Section 5.1.3. These requirements and Shell’s
conformance to them are listed below:
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The MMV Plan is required to be submitted as The Quest Measurement Monitoring and
Part of the Project application needed under the Verification (MMV) Plan (January 31, 2015,
Mines and Minerals Act, as amended by the version) MMV Plan is updated on a 3-year
Carbon Capture and Storage Statutes cycle. The latest MMV Plan is Version 2020,
Amendment Act (Alberta Regulation 68/2011). approved November 25, 2020. This MMV
plan is in effect until November 2023.
The directives which specify measurement and
All applicable directives are applied in MMV
monitoring include:
• Directive 007/017 – measuring and reporting
acid gas injection
• Directive 020 – requirements for well
abandonment, leakage detection and
mitigation
• Directive 051 – classification of disposal wells,
and design, operation and monitoring
requirements for each classification
• Directive 065 – requirements for confinement
of injected fluids (including acid gas, of which
CO2 is considered part)
The project must have an MMV which is specific Approved MMV is specific to Quest storage
to the storage complex complex
The MMV must be prepared in accordance with
MMV is prepared in accordance with AER
the requirements of the AER, and must
requirements, and lists specific operating
demonstrate the project operates in accordance
license requirements. MMV details when
with the operating license. The MMV must be
updates are required.
updated as required by the AER.
MMV requirements apply to the following four All four project phases are described in MMV,
project phases: with required monitoring and reporting
• Pre-Injection – characterization and outlined.
identification of risks, select monitoring
approach, and acquire baseline data
• Injection – monitoring of activities to manage
containment, and update as needed to ensure
effectiveness
• Closure – monitor to manage containment
risk and demonstrate permanent storage
• Post-Closure – monitoring requirements are
transferred to the Government of Alberta to
ensure storage is behaving in stable and
predictable manner
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April 2023
Quest Monitoring, Measurement and Verification Plan

The MMV details four specific environmental domains for monitoring of both containment and
conformance of CO2 in the storage complex. These domains are the following:
• Atmosphere – air above ground where the CO2 reservoir is located.

• Biosphere – soil and ecosystems where organisms are located. Focuses on soil monitoring.
• Hydrosphere – includes all subsurface between ground surface and the base of groundwater
protection (located at the top of the Geosphere). Primarily focuses on groundwater
monitoring.
• Geosphere – rock formations below base groundwater protection. Includes the Basal
Cambrian Sands (BCS) formation, which is the specific storage reservoir used by Quest for
storage.
As noted above, the most current MMV plan was approved November 25, 2020. This MMV plan
was applicable for the 2022 reporting period. This source is only calculated in the event of a leak
of CO2 from the subsurface to the atmosphere. In accordance with the MMV plan created the
location, size, and stability of the underground plume of CO2 will be monitored. If subsurface or
surface monitoring techniques detect the migration of some amount of the stored plume, then
the mass of CO2e lost to the atmosphere would be quantified through a site-specific study.
A suite of technologies has been employed, each of which uses different indicators to determine
whether a trigger event has occurred. Indicators include, but are not limited to, direct emission
rates at specific locations, seismic amplitude information or downhole pressures. Technologies,
indicators, and trigger thresholds will evolve as characterization of the project performance, and
data on the injection progresses. These technologies evolve and change, and the most up to date
MMV must therefore be referenced to understand the technologies and indicators used for
determining trigger events and the consequences of each trigger. For the most up to date details
on trigger events and approaches used to assess performance of the Quest project, please refer
to the most recent MMV plan.
Trigger events can occur at three levels or “Tiers” as discussed below:
• Tier 1 technologies: Address critical risks to loss of containment through direct, continuous
monitoring. These technologies monitor data closest to the Storage Complex or along the
wellbore with immediate action to address any trigger events. These barriers are actively
maintained.
• Tier 2 technologies: Address potential critical risks to loss of containment, though less
directly tied to the Storage Complex. These technologies have a longer sample time or
surveillance frequency, with analysis and longer response time to the trigger event. These
barriers are actively maintained.
• Tier 3 technologies: Contingency based monitoring that can be triggered as a potential
response to Tier 1 or Tier 2 based monitor activities. Discontinuous monitoring or frequency
of analysis may occur, with some technologies requiring re-deployment if triggered.
Comprehensive baseline data (ie InSAR, GW discrete sample profiles) can be utilized for any
trigger events that re-establish utilization of Tier 3 technologies.
Trigger events indicate the need for greater review when they occur. The trigger response plan,
as indicated in the Integrated Response Plan (IRP) is specific to each monitoring technology but
typically involves reviewing the data and data management system to first ensure that the
trigger event is ‘real’. Once confirmed to be a ‘real’ event, other monitoring technologies are
incorporated and reviewed to develop an explanation or set of potential explanations for the
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April 2023
event. Should the review result in the determination that conformance and containment
performance are not anomalous, routine monitoring may continue. Should an anomalous result
be obtained, a site-specific study may need to be initiated. Measures are then proposed and
evaluated to resolve the Issue through the site-specific study. Any impact to the emission
reduction inventory will be reported through the site-specific study and are the inputs to this
quantification plan.
The results from all monitoring is summarized in quarterly reports. An annual status update
report detailing the yearly monitoring results, status of the MMV plan and future activities is
also prepared.
Monitoring Conducted for 2022 Reporting period and Results
GHD reviewed the P20 (Emissions from Subsurface to Atmosphere) quarterly reports and the
2022 Calendar Year Verification report of the Quest MMV Program and found that the data does
not indicate loss of containment. There were however, two Tier 1 trigger events reported, and
they have been addressed.
As Part of the approved MMV plan, the assessment of trigger events based on a tiered system
are used to help determine if there is a possible loss of containment of CO2 from the Basal
Cambrian Sand Formation.
The first trigger occurred in Q2 and was due to BHP (bottom hole pressure) gauge data,
erroneously reading below 20 Mpa on the Basal Cambrian Sand (BCS) injection well, IW 7-11.
The reason for this was due to a faulty gauge. This has been rectified in July 2022.
Another well, IW 8-19 also began having erroneous BHP Gauge readings in Q2, but they were
not recorded below 20 Mpa. They have been troubleshooting the problem through the end of
the year. As a result, additional alarms on surface pressure have been put in place to ensure no
BHP maximums are not exceeded while working the issue.
The second trigger event occurred in Q4 on the deep monitoring well DMW 8-19 which monitors
the pressure in the above Cooking Lake Formation. The pressure increase was observed after
completing a well intervention, but the pressure continues to fall off towards baseline pressure.
The pressure increase was due to adding fluid during fishing operations.
Thus, no emissions have been identified as a result of these two trigger events
In the Tier 2 level technologies utilized for MMV in 2022, including DTS temperature sensing,
casing inspection logs, packer isolation tests, and MSM microseismic monitoring, there were no
trigger events. Therefore, no emissions have been identified from the subsurface.
GHD Assessment
GHD has been provided the Q1-Q4 2022 quarterly summary reports, along with the current
MMV plan. GHD has reviewed the monitoring activities and results. GHD has confirmed that
Shell has met the requirements of the protocol for monitoring.
Based on GHD’s review, the monitoring program utilized by Shell to monitor the subsurface
emissions of CO2 is very comprehensive and detailed, with multiple levels of monitoring from
the reservoir itself up to the atmosphere. This detailed monitoring allows multiple levels of
redundancy in both the detection and quantification of potential leaks from the subsurface.
With respect to the 2022 reporting period, GHD has confirmed that the requirements of both
the protocol and Shell’s MMV plan have been met, and that the assertion of zero emissions from
the subsurface for the 2022 reporting period is reasonable.
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P21 – Loss/Disposal/Recycle of Material Inputs

The full list of materials used in the project are outlined under the P4 Section above. Of that
list, there are zero emissions from the loss/disposal/recycling of nitrogen and instrument/utility
air (as there is zero carbon in those materials).
Loss, Disposal or Recycling of Material Inputs
For water usage, as noted above total consumption is based on the metered quantities of
wastewater (meter FC246009).
All other materials are quantified using the same usages as per P4 above, assuming that the
total material lost is equal to the material purchased. GHD has confirmed this is a reasonable
assumption. As noted in the P4 discussion above, Shell claimed material purchases of
27,100 kg of caustic soda and 8,960 kg of TEG, which GHD verified as appropriate.
Shell also reported a three periods of refrigerant (HFC401a) leaks for the 2022 reporting year.
Emission Factor for Loss, Disposal or Recycling of Material Inputs
For amine, glycol, antifoam, activated carbon and lubricants, Shell assumes that these
materials are disposed via complete combustion, which is considered the worst-case disposal
method from a GHG perspective. The total carbon mass of each material is estimated (as the
exact molecular formula is not known). For lubricants, emissions are estimated using the US
Environmental Protection Agency (EPA) Emission Factor Hub.
For wastewater, the emission factor is calculated based on the measured chemical oxygen
demand (COD) and equation 6-13 in the API Compendium. Shell has indicated that as the
Upgrader WWTP is not overloaded, no anaerobic digestion occurs, therefore only CO2 emissions
occur. N2O emissions are considered to be minimal and are excluded.
For refrigerants, it is assumed to be lost to atmosphere, so the total top-up quantities are
multiplied by the global warming potentials.
GHD has confirmed that the calculation of emission factors for each quantity above are
appropriate.
Table 6, Part 4. GHD has confirmed that this equation is used by Shell.
calculation of materials lost, disposed or recycled.
Recalculations
(underreported) and <0.01% of total reductions (overreported). This difference is not material.
This has been noted as Item 22-01.
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4.3 Assessment against Criteria

Table 1: Offset Criteria Assessment
Offset Eligibility Criteria Assessment
The reduction or sequestration must The Quest CCS Facility is located at the Shell
occur in Alberta; Scotford Site, located near Fort Saskatchewan,
Alberta. The injection wells are located 50 to
80-km from the CCS Facility, and are all located
in Alberta.
The reduction or sequestration The implementation of carbon capture is not

regulated by law or considered common
(i) must result from an action taken
practice in Alberta.
that is not required by law at the time
the action is taken, and
(ii) must not be required by law at the
time the reduction or sequestration
occurs;
The reduction or sequestration must The Project start date was August 23, 2015,
(i) result from an action taken on or upon commencement of CO2 injection
after January 1, 2002, and
(ii) occur on or after January 1, 2002;
The reduction or sequestration must be The project sequesters CO2 emissions produced
real and demonstrable; from the hydrogen manufacturing units that
would otherwise have been released to
atmosphere. GHD confirmed that the CCS
Facility and Injection Sites are in place and
operational, and resulting in actual avoidance of
CO2 emissions to atmosphere.
The reduction or sequestration must be As noted in Sections 4.1 and 4.2 above, GHD
quantifiable and measurable, directly or has verified that the baseline and project
by accurate estimation using replicable emissions are quantified based on approved
techniques; protocol methodologies (with the exception of
the approved AEP deviation)
The specified gas emissions that were GHD has verified the specified gas emissions
reduced or the carbon dioxide that was that were reduced or the carbon dioxide that
sequestered must not have had an was sequestered must not have had an effect
effect on the determination of a on the determination of a regulated facility’s
regulated facility’s total regulated total regulated emissions.
emissions under Section 13(3) or (4).
Page 48 of 70
April 2023
If reverification confirm the project was N/A

verified by a third party verifier that
meets the requirements in Part 1 for
the Standard for Validation,
Verification, and Audit.
4.4 Evaluation of the GHG Assertion

The verification assessment is that the GHG Assertion meets the requirements of the
Technology Innovation and Emissions Reduction Regulation
The GHG data and information available does support the GHG assertion.
The resulting absolute difference between the Project offsets and GHD's calculated offsets is
1,388.29 tonnes CO2e, which is equal to 0.19%. As the materiality threshold for this
verification is 2%, the difference identified in the offsets means that the GHG assertion was not
materially misstated. Appendix F.2 below presents GHD’s reconstructed emissions based on the
raw data provided, the emissions reported by the Project, and the resulting net/absolute
discrepancies for each category.
Based on GHD’s review, the GHG assertion is in accordance with the TIER to a reasonable level.
The full verification opinion is provided in Section 5.
Page 49 of 70
April 2023
4.5 Summary of Findings

Table 2: Summary of Findings
Result Type Summary Description of Finding Understatement Tonnes CO2 eq Tonnes CO2 eq
# Source Category or Source/Sink /Overstatement % net % absolute
22-01 Quantitative The calculated absolute difference Overstatement 0.06% 0.06%

between Shell’s and GHD’s values for in project
the baseline/project sources and sinks emissions,
are the following: understatement
in project
B1 – 25.18 tonnes CO2, <0.01% of
reductions
total offsets
P4 – 0.50 tonnes CO2, <0.01% of total
offsets
P5/P6/P7 – 36.51 tonnes CO2e, 0.01%
of total offsets
P8 – 226.42 tonnes CO2e, 0.03% of
total offsets
P9 – 147.10 tonnes CO2e, 0.02% of
total offsets
P10 – 0.28 tonnes CO2e, <0.01% of
total offsets
P11 – 0.52 tonnes CO2e, <0.01% of
total offsets
P18 – 0.43 tonnes CO2e, <0.01% of

offsets
P21 – 17.72 tonnes CO2e, <0.01% of
offsets
Page 50 of 70
April 2023
Result Type Summary Description of Finding Understatement Tonnes CO2 eq Tonnes CO2 eq
# Source Category or Source/Sink /Overstatement % net % absolute
GHD reviewed all process data used to
develop the baseline/project sources.
None of these discrepancies are
material, and the overall difference is
less than the materiality threshold.
Overall difference is 0.06%, less than
the materiality threshold.
22-02 Quantitative Shell originally missed three HFC leaks Understatement NA – Issue NA – Issue
in their original SERS report. Shell has in project has been has been
since accounted for these leaks in their emissions, addressed. addressed.
Version 5, SERS report. overstatement
in project
reductions
22-03 Quantitative Shell omitted the Project’s nitrogen Understatement NA – Issue NA – Issue
usage for the month of May in their in project has been has been
original SERS report. Shell has since emissions, addressed. addressed.
accounted for this in their Version 5, overstatement
SERS report. in project
reductions
22-04 Quantitative Shell accounting for the electricity from Overstatement NA – Issue NA – Issue
the cooling fan twice, once as a Part of in project has been has been
Total Import Electricity - Cogen emissions, addressed. addressed.
calaculations and once as a standalone understatement
value (Total Import Electricity – Cooling in project
Fans) in SERS. Shell has been made reductions
aware of this issue, and addressed the
error by providing an updated SERS
report without the double-count. This
Issue does not result in a material
misstatement.
Total % Error 0.06%
Page 51 of 70
April 2023
4.6 Opportunity for Improvement

No OFIs were identified.
5.0 Closure
5.1 Verification Statement
The verification conclusion is: Positive
GHD has prepared this Verification Report for Shell and AEPA. Shell was responsible for the
preparation and fair presentation of the Offset Project in accordance with TIER with a qualified
third-party verifier to verify the Offset Project Report. Shell’s GHG-related activities are detailed
in Section 4.2.
GHD's objective and responsibility was to provide an opinion regarding whether the Project’s
2022 Offset Project Report was free of material misstatement and that the information reported
is a fair and accurate representation of the operations for the reporting period accurate and
consistent with the requirements of the TIER, and associated criteria. The criteria used by GHD
for the verification of the Offset Project Report is detailed in Section 1.4. GHD completed the
verification of the Offset Project Report in accordance with ISO 14064-3:2019. GHD completed
the verification to a reasonable level of assurance.
Shell reported 715,416 tonnes CO2e as the total emissions reduction the reporting period. This
includes the GHG emissions resulting from operating conditions from January 1, 2022 through
December 31, 2022. The quantitative aggregated magnitude of errors, omissions, and
misstatements is detailed in Section 4.7 and Appendix D.
Based on the verification conducted by GHD, the GHG assertion provided in the 2022 Offset
Project Report for the Quest Carbon Capture and Storage Project was determined to be free of
material misstatements, fairly presented, substantiated by sufficient and appropriate evidence,
and was prepared in accordance with the TIER and relevant criteria.
5.2 Limitation of Liability
Because of the inherent limitations in any internal control structure, it is possible that fraud,
error, or non-compliance with laws and regulations may occur and not be detected. Further, the
verification was not designed to detect all weakness or errors in internal controls so far as they
relate to the requirements set out above as the verification has not been performed
continuously throughout the period and the procedures performed on the relevant internal
controls were on a test basis. Any projection of the evaluation of control procedures to future
periods is subject to the risk that the procedures may become inadequate because of changes
in conditions, or that the degree of compliance with them may deteriorate.
The verification opinion expressed in this report has been formed on the above basis.
GHD's review of the OPR claimed included only the information discussed above. While the
review included observation of the systems used for determination of the claimed OPR, GHD did
not conduct any direct field measurements and has relied on the primary measurement data
and records provided by Shell as being reliable and accurate. No other information was
provided to GHD or incorporated into this review. GHD assumes no responsibility or liability for
the information with which it has been provided by others.
The information and opinions rendered in this report are exclusively for use by Shell. GHD will
not distribute or publish this report without Shell’s consent except as required by law or court
order. The information and opinions expressed in this report are given in response to a limited
assignment and should only be evaluated and implemented in connection with that assignment.
Page 52 of 70
April 2023
GHD accepts responsibility for the competent performance of its duties in executing the
assignment and preparing this report in accordance with the normal standards of the
profession, but disclaims any responsibility for consequential damages.
5.3 Confirmations
Reported Item Consistency of Offset Project Information
Verification Procedure Confirm that the offset project information is

consistent across offset project documentation
Verification Findings GHD reviewed the OPP and OPR and found
them to be consistant.
Conclusion Project information is consistent across offset

documentation.
Reported Item Location of Offset Project and Applicable

Approvals
Verification Procedure Confirm that the location of the Offset Project

is correctly applied in the project
documentation and any applicable approvals
Verification Findings The specific project location is provided in

Section 2.0 above. GHD has confirmed that this
is consistent with the project documentation
and associated approvals.
Conclusion The location of the Offset Project is consistently

applied in all documentation.
Reported Item Availability of Methodology Documents

and/or Procedures
Verification Procedure Confirm that the project has documented

methodologies and procedures
Verification Findings GHD has confirmed that the methodologies

used by Shell are in accordance with the
Protocol, Carbon Emissions Factor Handbook
and other associated methodology documents.
Conclusion The location of the Offset Project is consistently

applied in all documentation.
Page 53 of 70
April 2023
Reported Item All Project Contacts, Dates and Emissions

Reductions
Verification Procedure Confirm that all project contacts, dates and

emissions reductions are correctly reported in
the project documentation
Verification Findings GHD reviewed the OPR and confirmed the

Project contact and report date. A summary of
the Project information is provided in
Section 1.0.
GHD reviewed the emissions and credits
quantification methodology, and independently
recalculated the emissions and credits
assertions.
Conclusion GHD confirmed that Project information is

correct, and the total credits claimed are
accurate.
Reported Item Process and Data Flow Diagrams
Verification Procedure Confirm that all process and data flow

diagrams prepared as Part of the SGER
submission are complete and accurate
Verification Findings GHD reviewed the process flow diagrams.

During the site visit, GHD confirmed that all
required emission sources have been
accounted for in the OPP, OPR.
Conclusion Based on GHD's review, Shell has included all

relevant emission sources as per the
requirement of the Protocol.
Page 54 of 70
April 2023
6.0 References
Alberta Environment and Parks. January 2023. Standard for Validation, Verification and Audit
(Version 5.2).
Alberta Environment and Parks. January 2023. Standard for Greenhouse Gas Emission Offset
Project Developers (Version 3.2).
Government of Alberta. June 2015. Quantification protocol for CO2 capture and permanent
storage in deep saline aquifers.
Government of Alberta. January 2023. Carbon Offset Emission Factors Handbook (Version 3.1).
Government of Alberta. January 2023. Technology Innovation and Emissions Reduction (TIER)
Regulation, Alberta Regulation 133/2019 and amendments.
International Organization for Standardization. April 2019. ISO 14064 2:2019. Greenhouse
gases –Part 2: Specification with guidance at the project level for quantification and reporting of
greenhouse gas emissions and removals.
International Organization for Standardization. April 2019. ISO 14064 3:2019. Greenhouse
gases –Part 3: Specification with guidance for the validation and verification of greenhouse gas
assertions
All of Which is Respectfully Submitted,

GHD
Deacon Liddy, P.Eng., Designated Signing Authority
Sean Williams, P.Eng., Lead Verifier
Gordon Reusing, P.Eng., Peer Reviewer
Page 55 of 70
Appendix A: Final Verification Plan and Sampling Plan
Page 56 of 70
Verification Plan
Shell Quest Carbon Capture and Storage
Period Jan 01, 2022 to Dec 31, 2022
Shell Canada Ltd.
27 April 2023
The Power of Commitment

GHD
9426 51st Avenue NW, Suite 101
Edmonton, Alberta T6E 5A6, Canada
T +1 780 705 7055 | E info-northamerica@ghd.com | ghd.com
Document status
Status Revision Author Reviewer Approved for issue

Code
Name Signature Name Signature Date
S3 00 Sean Williams Gordon Gordon January 31,
Reusing Reusing 2023
S4 01 Sean Williams Gordon Gordon April 27,
Reusing Reusing 2023
© GHD 2023
This document is and shall remain the property of GHD. The document may only be used for the purpose for which it
was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised use of this
document in any form whatsoever is prohibited.
The Power of Commitment

Contents
1. Introduction 1
2. Verification Objective and Level of Assurance 1
3. Verification Standards and Criteria 2
4. Scope 2
4.1 Project Emissions Sink and Source 2
4.2 Geographical and Operational Boundaries 3
4.3 Client contact 3
4.4 Reporting Period 3
4.5 Use of this Report 3
4.6 Use of Information and Communication Technology 3
5. Facility's Data Management System and Controls 3
6. Prior Verification Report and Findings 4
7. Verification Schedule 4
8. Site visit 4
9. Strategic Analysis 5
10. Assessment of Risk and Magnitude of Potential Errors, Omissions, or
Misrepresentations 5
11. Sampling Plan 15
12. Quantitative Testing 17
13. Materiality Level 18
14. Review Team and Peer Reviewer 18
14.1 Roles and Responsibilities 18
14.2 Qualifications 18
15. Verification Procedures 19
16. Closure 20
17. References 22
Table index
Table 1.1 Year-Over-Year Trends 1
Table 9.1 Risk Assessment 6
Table 10.1 Sampling Plan 15
GHD | Shell Canada Ltd. | 12602394 | Verification Plan i

GHG Alberta Verification Plan (Offset) | January 2023
1. Introduction
Shell Canada Limited (Shell) retained GHD Limited (GHD) to undertake a verification of the Greenhouse Gas (GHG)
emission reductions (Offset) for the Quest Carbon Capture and Storage (CCS) Project (Project), located in Fort
Saskatchewan, Alberta for the period from January 1 to December 31, 2022. The Project is registered with the Alberta
Emissions Offset Registry and the Project Identification (Project ID) is 7306-8118. GHD will complete the verification in
accordance with the requirements of the Technology Innovation and Emissions Reduction Regulation (Reg. 133/2019,
TIER) and any promulgated amendments, under the Emissions Management and Climate Resilience Act
(Government of Alberta, 2019) 1.
The Quest CCS project captures approximately one third of the greenhouse gas emissions at the Scotford Upgrader,
which is located at the Scotford Complex, northeast of Edmonton, Alberta. The opportunity for generating carbon
offsets with this project arises from the direct greenhouse gas emission reductions resulting from the geological
sequestration of CO2 in saline aquifers located approximately 2 km under the surface in the Basal Cambrian Sands
Formation. This activity is considered a permanent sequestration of CO2.
Table 1.1 Year-Over-Year Trends
Units 2019 2020 2021 2022

Baseline Emissions tCO2e 1,128,159 940,593 1,054,918 TBD
Project Emissions tCO2e 280,669 243,521 270,677 TBD
Offsets claimed tCO2e 847,490 697,072 784,241 TBD
Shell is responsible for the preparation and fair presentation of the Project Report in accordance with TIER.
GHD has prepared this Verification Plan in accordance with the ISO Standard ISO 14064 Greenhouse gases – Part 3:
Specification with guidance for the validation and verification of greenhouse gas assertions (ISO 14064-3:2019) and
with Alberta Environment and Protected Areas (EPA)'s Standard for Validation, Verification and Audit (EPA, 2020).
2. Verification Objective and Level of

Assurance
The objective of the verification is to provide Shell and EPA with an opinion on whether the Shell’s GHG emissions
reduction assertion from the Project for the period from January 1 to December 31, 2022, are free of misstatement and
that the information reported is accurate and consistent with the requirement of the TIER and relevant criteria.
The verification will be conducted to a reasonable level of assurance. Reasonable assurance is a high level of
assurance, or positive assurance. Reasonable assurance is a direct factual statement expressing the opinion of the
verifier. If a verification statement can be provided, it will be worded in a manner similar to Section 6.1 of the VVA
Standard.
1
The TIER replaced the Carbon Competitiveness Incentive Regulation, Reg. 255/2017 (CCIR) as of January 1, 2020.
GHD | Shell Canada Ltd. | 12602394 | Verification Plan 1

GHG Alberta Verification Plan (Offset) | November 2022
3. Verification Standards and Criteria
For this verification, GHD will apply the following ISO and EPA verification criteria:
– ISO 14064 Greenhouse gases - Part 1: Specification with guidance at the organization level for quantification and
reporting of greenhouse gas emissions and removals, ISO, December 2018 (ISO 14064-1)
– ISO 14064 Greenhouse gases – Part 3: Specification with guidance for the validation and verification of
greenhouse gas assertions, ISO, April 2019 (ISO 14064-3)*
– Emissions Management and Climate Resilience Act, Technology Innovation and Emissions Reduction
Regulation, Alberta Regulation 133/2019 (TIER) and amendments
– Standard for Validation, Verification and Audit, Version 5.2 (VVA Standard) (January 2023) and/or any
subsequent revisions
– Quantification Protocol for CO2 Capture and Permanent Storage in Deep Saline Aquifers, Version 1.0 (June 23,
2015).
– Carbon Offset Emission Factors Handbook. Version 2.0 (November 1, 2019)*
– Offset Project Plan Carbon Capture and Storage Project, Version 2.0 (August 18, 2016)
Note:
* Changed from initial proposal. GHD received its accreditation to the new ISO 14064-3:2019 standard.
4. Scope
4.1 Project Emissions Sink and Source
During the baseline condition, CO2 is produced in the hydrogen manufacturing units in the Scotford Upgrader through
the steam-methane reforming reaction and is then emitted to the atmosphere.
During the project condition, the CO2 produced in the hydrogen manufacturing units is captured and separated from
the raw gas stream by the CCS capture facility, compressed, transported to the injection wells, and then sequestered
underground.
The baseline emissions source prior to the implementation of the Project includes the following:
– B1: Injected CO2
The project emissions sources include the following:
– P3: Well Drilling Reportable Releases
– P4: Production and Delivery of Material Inputs
– P5, P6 & P7: Extraction/ Processing and Transportation of Fuel Used for On-Site and Off-Site Heat and Electricity
Generation
– P8: Off-Site Electricity Generation
– P9: Off-Site Heat Generation
– P10: On-Site Heat and Electricity Generation
– P11: Carbon Capture Storage Facility Operation
– P18: Venting of Co2 at Injection Well Sites
– P19: Fugitive Emissions at Injection Well Sites
– P20: Emissions from Subsurface to Atmosphere
– P21: Loss, Disposal or Recycling of Materials Used

4.2 Geographical and Operational Boundaries
The verification will include the GHG emission sources from the Project located at the following address:
Latitude: 53.7407° N; Longitude: 113.0231° W
55522 Range Road 214,
GHD will review and confirm consistency of the Project boundaries for the 2022 reporting period.
4.3 Client Contact

Ms. Celina Duong is GHD’s contact at Shell for this verification.
4.4 Reporting Period

The reporting period is between January 1, 2022 and December 31, 2022.
4.5 Use of this Report

This report has been prepared for the use of Shell and EPA.
Statements from GHD's Verification Plan must use the language in which the statement was issued, and reference the
date of issuance of GHD's report, the applicable verification period and the associated program for which the
verification was conducted. The GHD mark shall not be used by Shell in any way that might mislead the reader about
the verification status of the organization. The GHD mark can only be used with the expressed consent of GHD and
then, only in relation to the specific time period verified by GHD.
4.6 Use of Information and Communication Technology

As part of the verification process, GHD may utilize information and communication technology (ICT) in accordance
with IAF Mandatory Document for the use of Information and Communication Technology for Auditing/Assessment
Purposes (IAF MD 4:2018) for various aspects of the verification, including conducting video/tele-conferencing with
various personnel up to full virtual site visits.
The decision to use ICT is permissible if GHD and the client agree on using ICT. The agreed ICT method will be MS
Teams, Skype, Zoom, Google Meet, or Webex. By accepting GHD’s proposal, Shell agreed to the use of the afore
mentioned ICT methods and their associated information security, data protection and confidentiality measures. Any
other ICT method(s) will be agreed to in writing (email) between GHD and Shell prior to use. The parties will not agree
to the use of an ICT method which either party does not have the necessary infrastructure to support. Throughout the
entire verification process, including use of ICT, GHD will abide by the confidentiality procedures.
5. Facility's Data Management System and

Controls
GHD's current understanding of the data management system and controls is based on the Project Plan provided by
Shell. The data management system and controls will be reviewed in detail during the completion of the verification of
the GHG assertion.

6. Prior Verification Report and Findings
GHD was previously retained by Shell to complete the verifications of the 2nd - 6th Reporting Period, consisting of the
time period between November 1, 2015 – December 31, 2017, conducted under the Specified Gas Emitters
Regulation (SGER), plus several limited scope restatements (including one for the 1st Reporting Period). Based on
GHD's 6th Crediting Period verification, the GHG assertion for the Project is free of misstatements, in all material
aspects, and was in accordance with the SGER and relevant criteria. The following discrepancies were identified and
none of the discrepancies noted below result in misstatements.
– Quest high pressure steam meter is not set to zero as part of the iSteam model; this resulted in a understatement
of less than 0.01% tonnes CO2e.
– The STG and GTG were not fully operational for five days, but iSteam adjusts the model as if it were operational;
this likely resulted in a waste heat overstatement.
7. Verification Schedule
The following presents a draft verification schedule:
– Submit Verification Plan to Shell – January 31, 2023
– Shell Verification Plan review period – January 31 – February 2, 2023
– Request, receive and review documents and raw data from Shell – February 15 – April 10, 2023
– Site Visit – February 7, 2023 (Capture Site), TBD (Injection Site)
– Submit Issues Log – early February, 2023
– Independent review by independent peer reviewer – week of April 10, 2023
– Submit draft verification report to Shell – April 12, 2023
– Review draft verification report with Shell – April 12 – 24, 2023
– Issue Final Verification Report and Statement of Verification – April 27, 2023
8. Site Visit
The Site Visit, will generally adhere to the following agenda. Deviations from the proposed agenda may be necessary
to respond to data gaps and or issues identified during the verification process:
– Opening Meeting - Introduction and sign in, safety review, and overview of verification process and expectations
(key personnel need to be present).
– Overview of Facility operations, activities and production processes, including description of key emission
sources.
– Review of monitoring practices, quality control and quality assurance procedures, GHG data and emission
calculations, and any personnel activities that have a potential to impact materiality.
– Review of meter calibration certificates and accuracy specifications for key meters.
– Interviews with key personnel and review of data collection process from meter through distributed control system
or transcription and data entry, as applicable.
– Walkthrough to view Facility boundaries, physical infrastructure, and equipment and measuring devices.
– Closing Meeting – Review issues identified and next steps

9. Strategic Analysis
GHD’s Verification Team performed a strategic analysis to understand the activities and complexity of the Project and
product to determine the nature and extent of the verification activities.
GHD’s strategic analysis included:
a. Relevant sector information
b. Nature of operations of the Facility and product
c. Criteria requirements, including applicable regulatory and/or GHG programme requirements
d. Materiality threshold, including the quantitative and qualitative components
e. Likely accuracy and completeness of the GHG statement
f. Scope of the GHG statement and related boundaries
g. Time boundary for data
h. Emissions sources and their contribution to the overall GHG statement
i. Changes in GHG emissions from the prior reporting period
j. Appropriateness of quantification and reporting methods, and any changes
k. Sources of GHG information
l. Data management information system and controls
m. Management oversight of the reporting data and supporting processes
n. Availability of evidence for the GHG information and statement
o. Results of previous verifications
p. Results of sensitivity or uncertainty analysis
q. Allocation approach
r. Type of GHGs
s. Applied monitoring methodology (i.e., direct measurement of GHGs or calculation of GHGs with indirect
measurement of activity and calculation data)
t. Other relevant information
10. Assessment of Risk and Magnitude of

Potential Errors, Omissions, or
Misrepresentations
The results of GHD’s strategic analysis were used in the risk assessment. Information about the 2022 GHG assertion
was not yet available, as a result, the strategic analysis did not consider the contribution of the emission sinks/sources
to the overall GHG Statement and changes in GHG emissions reduction from the reporting period. The risk
assessment will be updated during the verification process. Based on GHD initial review of the Project, a risk
assessment summarizing the potential risk and magnitude of potential errors, omissions, or misrepresentation, as
currently known was completed. During the review, any new risks or material concerns that could potentially lead to
errors, omissions and misrepresentations will be identified, reviewed, and assessed.
The following table summarizes the potential risk and magnitude of potential errors, omissions, or misrepresentations,
as currently known:

Table 10.1 Risk Assessment
Potential Risk Area Percentage of total Site Attributes Inherent Risk Control Risk Detection Consideration for
(Sink and Source) Emissions Risk Design Procedure
Baseline Emission
B1: Injected CO2 100% Occurrence High – Based on Low – One meter Low GHD has set the
total CO2 injected. present at each detection risk as low, as
Metering points are injection well, and GHD will review all CO2
required to be one composition injected measurements
located as close to measurement and composition data for
the injection points system. All meter crediting period.
as possible. and analyzer data
Composition of CO2 is stored within
is understood to be Shell’s PI system,
based on direct gas while sampling data
analysis; is stored in LIMS.
understood to be
additional manual
samples historically
collected. Potential
venting/fugitives
after metering
Completeness point (at injection
points) captured in
project condition.
Accuracy Low – Metering
system present at
each injection well
and composition
based on gas
analysis on injected
CO2 stream.
Classification Low – classification of offsets is well
defined within the system.
Transparency Medium - Calculations are completed in
“black-box” calculation model, although
inputs and outputs, along with
methodologies are clearly defined.
Consistency Low – Understood calculations are
consistent with previous reporting periods

Project Emissions
P3: Well Drilling <1% Occurrence Low – only Medium – Medium GHD will confirm if any
Reportable Releases reportable if gas is Emissions reportable gas releases
Completeness released during estimated based on from well drilling occurred
Accuracy kicks and blowouts procedures as per during crediting period.
of wells as per the AER Directive 059.
Alberta Energy
Regulator (AER)
Directive 059.
Emissions during
reportable releases
are quantified using
methodologies
defined in the
Directive 059
Reports.
P4: Production and <1% Occurrence Medium – multiple Medium – based on Medium GHD will review total
Delivery of Material materials used in delivery and quantification of the
Inputs Completeness CCS process. metered quantities material inputs as well as
Quantities of each of the different confirm appropriateness
determined based material inputs. All of emission factors.
on delivery and delivery invoices Based on the size of the
metered quantities. are stored on project emissions from
Emission factors Shell’s servers, and previous reporting
estimated based meter data is stored periods, significant
primarily on in Shell’s PI discrepancies in
literature system. emissions for this
references. category are not expected
to result in material error.
Accuracy Low – based on
delivery and
metered quantities
of the different
material inputs.

P5, P6 & P7: 7.1% Occurrence High – Two types of High – Total Lowest GHD will review complete
Extraction/ fuels used (natural quantities of steam details of the steam
Processing and Completeness gas and liquid fuels measured based on balance and confirm total
Transportation of Fuel including diesel, multiple steam quantities of natural gas
Used for On-Site and gasoline, and meters, along with used, as well as liquid fuel
Off-Site Heat and propane). Total temperature and invoiced quantities. GHD
Electricity Generation natural gas usage pressure meters. will confirm
based on complex Liquid fuels appropriateness of
steam balance. determined based emission factors.
Liquid fuels based on invoicing. Steam
on default emission metering data is
factors for each fuel stored on Shell’s PI
used. system.
Accuracy High – Complex
steam balance
used to quantify
natural gas usage.
Liquid fuels
determined based
on invoicing.
P8: Off-Site Electricity 20.7% Occurrence Medium – Multiple Medium – the Lowest GHD will review all
Generation electricity meters majority of electricity metering
Completeness and invoices (for electricity usage is quantities. GHD will
electricity usage at based on direct
wellpads) used to metering. A confirm appropriateness
quantify electricity small (<1%) of emission factors.
usage by the quantity is
Project. Standard estimated.
emission factors Electricity meter
are used. data is stored in
Shell’s PI system.
Accuracy Medium – the Electricity invoices
majority of for wellpads stored
electricity usage is on Shell’s server.
based on direct
metering. A
small (<1%)
quantity is
estimated.
P9: Off-Site Heat 72.1% Occurrence High – Total natural High – Total Lowest GHD will review complete
Generation gas based on quantities of steam details of the steam
Completeness steam balance and measured based on balance and confirm total
back-calculation of multiple steam quantities of natural gas
equivalent fuel gas meters, along with used, as well as the
burned. temperature and third-party composition
Composition of pressure meters. data.
natural gas based Steam metering
on third-party data is stored on
information Shell’s PI system.
Accuracy High – Steam
balance used to
quantify natural gas
usage.

P10: On-Site Heat <1% Occurrence Low – based on Medium – total fuel Medium GHD will confirm if any
and Electricity total invoiced consumption based on-site propane/natural
Generation Completeness propane, methanol on gas/methanol
Accuracy and metered invoicing (propane) consumption for heat or
natural gas usage. and electricity generation
Default emission metering (natural occurred in crediting
factors for propane, gas). Invoices are period.
while natural gas stored on Shell’s
emission factors server.
calculated based
on gas
composition.
P11: Carbon Capture <1% Occurrence Low – based on Medium – total fuel Medium GHD will review total
Storage Facility total consumption consumption based quantification of fuel
Operation Completeness of diesel, gasoline on invoicing. usage as well as confirm
Accuracy and aviation fuel, Invoices are stored appropriateness of
calculated based on Shell’s server. emission factors. Based
on direct on 1st crediting period
measurement, project report, significant
invoices or discrepancies in
calculated based emissions for this
on kilometers category are not expected
driven. Default to result in material error.
emission factors for
each fuel type
used.

P18: Venting of CO2 <1% Occurrence Low – multiple vent Medium – multiple Medium GHD will review total
at Injection Well Sites event categories. vent event types quantification of vented
Completeness Total gas vented can occur, with quantities and
Accuracy and composition for different composition of vented
each type based on quantification gases. Based on 1st
either engineering methods for each. crediting period project
calculations or Calculations for the report, significant
direct vented quantities discrepancies in
measurements. are performed on emissions for this
spreadsheets category are not expected
stored on Shell’s to result in material error.
server.
P19: Fugitive <1% Occurrence Low – total fugitive Low – based on Medium GHD will confirm
Emissions at Injection emissions on fitting known equipment equipment counts and
Well Sites Completeness counts and default counts and gas composition. Based
Accuracy emission rates from measured gas on 1st crediting period
each type of fitting. composition. project report, significant
Gas composition discrepancies in
based on measured emissions for this
injected gas category are not expected
composition. to result in material error.

P20: Emissions from <1% Occurrence Low – emissions Medium – Shell’s PI High GHD will review
Subsurface to calculated only if a and LIMS systems documentation and
Atmosphere Completeness leak is detected. are the primary methodology used to
Accuracy Methodologies to data storage assess leaks from the
monitor subsurface location; however, subsurface to confirm
storage of CO2 and some data is stored whether leaks occurred
leaks performed by in alternative during the crediting
Shell using several locations, which is period.
methodologies at then manually
multiple levels – downloaded and
each methodology transferred by Shell
is described in the personnel. All data
Methodology, is monitoring by
Monitoring and Shell.
Verification
Plan (MMV).
P21: Loss, Disposal <1% Occurrence Medium – multiple Medium – based on Medium GHD will review total
or Recycling of materials used in delivery and quantification of the
Materials Used Completeness CCS process that metered quantities disposals as well as
can potential be of the different confirm appropriateness
disposed. material inputs. All of emission factors.
Quantities of each delivery invoices Based on 1st crediting
determined based are stored on period project report,
on disposal and Shell’s servers, and significant discrepancies
recycling estimates. meter data is stored in emissions for this
Emission factors in Shell’s PI category are not expected
estimated based on system. to result in material error.
material balances.

Accuracy Low – based on
delivery and
metered quantities
of the different
material inputs.
General
Project Eligibility and NA Occurrence High – if the project quantification Lowest GHD will assess the
Conformance with methodology deviates from the Protocol Project against the offset
Project Plan and Completeness and the validation, it would result in a non- criteria to confirm project
Protocol Accuracy conformance with the verification criteria. eligibility.
GHD will review the
Classification Project Report against the
Transparency Project Plan and Protocol
Consistency
Use of ICT* NA Occurrence Medium –. The Medium – ICT Medium To lower the detection
GHD project team technologies are risk, GHD will work with
Completeness has previous available to both Shell to arrange meetings
Accuracy experience in Shell and GHD, at appropriate times for
conducting when required. Shell operators and staff
Classification verifications for to be available to work
similar project types through the verification
Transparency
process and provide
Consistency sufficient time to deal with
potential technical
limitations.
Data Management NA Occurrence Medium – Majority Medium – All data Lowest The data management
of quantities used is managed and systems are present at
Completeness for emission tracked by Shell the Site. GHD will review
Accuracy reduction are real- personnel. Multiple all data systems and the
time data stored on
Classification PI or LIMS

Transparency systems, or via systems are used flow of data between
third-party invoices. to track data. them.
Consistency Some data for
subsurface
emissions (P20)
are from additional
data systems.
*- An assessment of ICT is mandatory for all verifications.

11. Sampling Plan
GHD developed a sampling plan based on review of the objectives, criteria, scope, and level of assurance detailed
above. The sampling plan is dynamic and will be revised, as required, throughout the course of the verification. The
following table summarizes the sampling plan.
Table 11.1 Sampling Plan
Data/Information Data/Information Source Collection Sample size/Action

Description Frequency
General
Project Report Project Report for the NA Review against Project Eligibility criteria
period January 1 to Review against Protocol
December 31, 2022
Project Plan Project Plan 2016 Review to confirm all methodologies have been
correctly referenced and applied
Data Data acquisition system N/A Review frequency of data backup
management Interview site personnel
Baseline Emissions
B1: Total CO2 Gas injected at each Continuous Mass balance spreadsheet with calculation of CO2
Injected injection well site: injected
FIT-702104 Flow of data from meters to GHG calculation system
FIT-702204 Most recent calibration records for each meter
FIT-702304
Gas downstream of
compressor
FIT-247004
Gas composition analyzers Continuous/ As- Composition of CO2 stream injected into the well sites
AT-247001, AT247002 collected Flow of data from analyzers to GHG calculation system
Laboratory sampling data Laboratory management and QA/QC procedures
on CO2 stream
Laboratory results for crediting period
Project Emissions
P3: Well Drilling Total gas and composition As recorded AER Directive 059 report for each well kick or
Reportable of gas released if well kick blowout (if applicable)
Releases or blowout occurred
P4: Production Total usage of materials As recorded/ Purchasing records
and Delivery of on-Site: continuous Mass balance spreadsheet with calculation of CO2
Material Inputs Methyl diethanol injected
amine (MDEA) Flow of data from meters/accounting to GHG
Activated Carbon calculation system
Nitrogen Most recent calibration records for nitrogen meter
Utility/Instrument Air
Emission factors N/A Review methods for determining emission factors
P5, P6 & P7: Total steam usage: Continuous Steam balance spreadsheet (for calculation of each
Extraction/ Low pressure (LP) steam type of steam produced, along with pressure and
Processing and temperature)
Transportation of High pressure (HP) steam
from RHC unit Flow of data from meters to GHG calculation system
Fuel Used for
Most recent calibration records

On-Site and Off- Condensate return
Site Heat and
Electricity Natural gas As recorded All data for the duration of the crediting period for
Generation composition/higher heating natural gas composition and HHV data from third party
value (HHV) supplier
Liquid fuel usage As recorded All data for the duration of the crediting period for
invoice quantities for liquid fuels used in the CCS
facility
Extraction/processing N/A Confirm appropriateness
emission factors
P8: Off-Site Total electricity usage: Continuous Mass balance spreadsheet with calculation of electricity
Electricity 52-15B at Quest and electricity from Upgrader
Generation Third-party invoices for electricity consumed at the well
52-16B
pads
702-DP-A
Flow of data from meters to GHG calculation system
702-DP-B
Most recent calibration records
702-DP-C
PM-44108A
PM-44108B
FI-25003
FI-25007
F-252F01A-J
Grid Emission Factors N/A Confirm appropriateness of emission factors
P9: Off-Site Heat Total steam Continuous Steam balance spreadsheet (for calculation of each
Generation usage (multiple meters for type of steam produced, along with pressure and
each): temperature)
LP steam Flow of data from meters to GHG calculation system
HP steam from RHC unit Most recent calibration records
Condensate return
Natural gas As recorded All data for the duration of the crediting period for
composition/HHV natural gas composition and HHV data from third party
supplier
Combustion emission N/A Confirm appropriateness of natural gas CO2 emission
factors factor calculated by Shell
Confirm appropriateness of published emission factors
for other gas species
P10: On-Site Natural gas usage for local Continuous All data for the duration of the crediting period for
Heat and heating natural gas for local heating (if applicable)
Electricity Flow of data from meters to GHG calculation system
Generation
Natural gas HHV As recorded All data for the duration of the crediting period for
natural gas composition and HHV data from third party
supplier
Propane usage (if As recorded Invoiced quantities of propane usage for the duration of
applicable) the crediting period (if applicable)
Combustion emission N/A Confirm appropriateness of natural gas CO2 emission
factors (if emissions from factor calculated by Shell
this source occurred during Confirm appropriateness of published emission factors
crediting period) for other gas species

P11: Carbon Diesel consumption As recorded Cardlock fuel consumption measured for the duration of
Capture Storage the crediting period
Facility
Operation Gasoline consumption As recorded Cardlock fuel consumption measured for the duration of
the crediting period
Combustion emission N/A Confirm appropriateness
factors
P18: Venting of Total gas vented As recorded Mass balance spreadsheet with calculations of total
CO2 at Injection quantity of gas vented from each venting event for the
Well Sites duration of the crediting period
Gas composition analyzers Continuous Composition of CO2 stream injected into the well sites
AT-247001, AT247002 Flow of data from analyzers to GHG calculation system
Laboratory sampling data Laboratory management and QA/QC procedures
on CO2 stream
Laboratory results for crediting period
P19: Fugitive Fitting counts As recorded Confirm total number of fittings
Emissions at
Injection Well Gas composition analyzers Continuous Composition of CO2 stream injected into the well sites
Sites AT-247001, AT247002 Flow of data from analyzers to GHG calculation system
P20: Emissions Quantity of gas leaking As recorded Measurement, Monitoring and Verification (MMV) Plan
from Subsurface from subsurface and associated records
to Atmosphere Methodologies used to MMV Quarterly Reports for the crediting period
assess leakage from Lightsource documentation report and data
subsurface
Flux chamber data for baseline (June 2015) and project
for crediting period
Hydraulic Isolation Logs for crediting period
Confirm if any releases from subsurface occurred in
crediting period
P21: Loss, Total quantities of materials As recorded/ Disposal/off-site shipment records for the full crediting
Disposal or lost/disposed/recycled continuous period
Recycling of on-Site: Wastewater treatment volumes for the full crediting
Materials Used Methyl Diethanol period
amine (MDEA) Refrigerant charge records for the duration of the
TEG-glycol crediting period
Water (wastewater
treatment)
Lubricant
Refrigerant HFC (R410a)
Emission factors N/A Review methods for determining emission factors
12. Quantitative Testing

Quantitative data or raw data will be made available to GHD. GHD will review key GHG-related process data, evaluate
the GHG emissions calculation methodologies and recalculate GHG emissions reduction.

13. Materiality Level
The quantitative materiality for this verification is set at absolute 2% as per the requirements of Section 5.1.1 of VVA
Standard. In addition, a series of discrete errors, omissions, or misrepresentations or individual or a series of
qualitative factors, when aggregated (absolute values) may be considered material.
14. Review Team and Peer Reviewer

14.1 Roles and Responsibilities
Designated Signing Authority – Deacon Liddy – Mr. Liddy will review and sign the verification report and statement.
Lead Verifier – Sean Williams – Mr. Williams will lead the verification and is responsible for development of the
verification plan. Mr. Williams will review the risk assessment, recalculation of raw data, data management and draft
findings. Mr. Williams will prepare the verification statement and verification report.
Verifier – Stepheney Davey –– Ms. Davey will develop and revise the verification plan and sample plan, develop a
risk assessment, recalculate raw data, review management of data quality and prepare draft findings. Ms. Davey will
conduct a site visit of the Facility.
Verifier – Bryan Rubie –– Mr. Rubie will develop and revise the verification plan and sample plan, develop a risk
assessment, recalculate raw data, review management of data quality and prepare draft findings. Mr. Rubie will
conduct a site visit of the Facility.
Peer Reviewer – Gordon Reusing – Mr. Reusing will conduct a peer review of the risk verification plan risk
assessment and verification report and findings.
14.2 Qualifications
Deacon Liddy, P. Eng. – Mr. Liddy is a Principal with GHD and an experienced GHG validator and verifier, having
completed over 100 GHG validation/verifications with 17-years of experience. Mr. Liddy works with large industrial
facilities, Provincial governments, and offset project developers to complete risk-based verifications. Mr. Liddy has
been the lead verifier for completion of greenhouse gas verifications conducted on behalf of Alberta Environment for
emission offset projects for landfill gas, biomass, tillage, composting and fuel switching for lumber kilns. Mr. Liddy has
completed verifications of greenhouse gas emission intensity baseline applications and annual compliance reports
under the Alberta Specified Gas Emitters Regulation and British Columbia Mandatory Reporting Regulation. Mr. Liddy
is a professional engineer in BC, Alberta, and Saskatchewan.
Sean Williams, P.Eng. – Mr. Williams is a Project Manager, GHG Lead Verifier and Technical Expert and with over
10-years of experience in environmental consulting and is a licensed Professional Engineer in the provinces of
Alberta, Saskatchewan and Ontario. Mr. Williams has experience in completing greenhouse gas verifications, permit
applications, air and noise compliance assessments, completion of annual inventory reports under various voluntary,
provincial and federal regulations across Canada. Mr. Williams is an accredited lead verifier under the California Air
Resources Board and Oregon Department of Environmental Quality. Mr. Williams has significant air and GHG
expertise in a variety of industrial sectors, including oil sands extraction and upgrading, refineries, chemical plants,
mining and mineral production, power generation facilities, waste management and metals production. Mr. Williams
serves as the Greenhouse Gas Assurances Services (GGAS) Manager for GHD’s ANAB accreditation.
Stepheney Davey, M.Sc., E.I.T. – Ms. Davey is a junior engineer and member of the EHS Compliance team with
GHD. She holds a Master of Science degree in Chemical Engineering from the University of Alberta. Ms. Davey has
been involved with multiple GHG verifications in various sectors under the Greenhouse Gas Industrial Reporting and

Control Act in British Columbia, The Management and Reduction of Greenhouse Gases in Saskatchewan and the
Technology Innovation and Emissions Reduction regulations in Alberta. She has also been involved with reporting
under the federal Output-Based Pricing System and national reporting under the National Pollutant Release Inventory.
Her experience includes a range of industries including oil and gas extraction, production and upgrading, power
generation, chemical production, pulp and paper mills, and mining and mineral production facilities.
Bryan Rubie, P.Eng. – Mr. Rubie has a Bachelor of Environmental Engineering from the University of Guelph.
Mr. Rubie has experience completing permit applications, air and noise compliance assessments and completion of
annual inventory reports for a number of industrial facilities. Mr. Rubie has experience in greenhouse gas verifications
under the Alberta Specified Gas Emitters Regulation (SGER) and Carbon Competitiveness Incentive Regulation
(CCIR) and has acted as verifier for a number of projects. Mr. Rubie also has experience in completing greenhouse
gas reports for numerous oil and gas facilities as per the US EPA Greenhouse Gas Reporting Program (GHGRP).
Gordon Reusing, M. Sc., P. Eng. – Mr. Reusing is a greenhouse gas (GHG) Lead Verifier, Lead Validator, and Peer
Reviewer with extensive experience including GHG programmes in Alberta, British Columbia, Saskatchewan, Ontario,
Quebec, Nova Scotia, California, and programmes operated by the United Nations Framework Convention on Climate
Change (UNFCCC) Clean Development Mechanism (CDM), The Gold Standard, The Climate Registry (TCR), the
Carbon Disclosure Project (CDP), and Verra: Verified Carbon Standard (VCS). He has completed numerous GHG
quantification studies for the oil and gas sector, including upstream, midstream and downstream facilities. Mr. Reusing
has conducted GHG verifications as a Lead Verifier, Technical Expert and Peer Reviewer in many jurisdictions,
including, but not limited to, British Columbia, Alberta, Ontario, Quebec, and Nova Scotia.
15. Verification Procedures

The review procedures used in this verification will be used to assess the following:
1. Accuracy and completeness of the GHG assertion
2. Uncertainty of external data sources used
3. Emission assumptions
4. Accuracy of emission calculations
5. Potential magnitude of errors and omissions
To sustain a risk-based assessment, the GHD Project Team will identify and determine risks related to GHG
emissions reduction during both the desk reviews and the follow-up interviews. The GHD Project Team will particularly
focus on the accuracy and completeness of provided information. The components of the document review and
follow-up interviews are:
– Document Review
• Review of data and information to confirm the correctness and completeness of presented information.
• Cross-checks between information provided in the GHG assertion and information from independent
background investigations.
• Determine sensitivity and magnitude analysis for parameters that may be the largest sources of error.
– Follow-up Interviews
• On Site
• Via telephone
• Via email

The GHD Project Team will interview Project personnel to:
– Cross-check information provided
– Test the correctness of critical formulae and calculations
– Compare with projects or technologies that have similar or comparable characteristics
– Compare project emission with baseline emission conditions
– Review data management and recording procedures
The document review shall establish to what degree the presented GHG assertion documentation meets the
verification standards and criteria.
The GHD Project Team's document review during the review process shall comprise, but not be limited to, an
evaluation of whether or not:
– The documentation is complete and comprehensive and follows the structure and criteria given in the AEP
guidelines and regulations
– The GHG assertion, and the emission estimates therein, conform to the program criteria
– Monitoring methodologies were justified and appropriate for the specific project
– The assumptions behind the inventory are conservative and appropriate
– The GHG emissions calculations are appropriate and use conservative assumptions for estimating GHG
emissions
– The GHG information system and its controls are sufficiently robust to minimize the potential for errors,
omissions, or misrepresentations
– The frequency of, and responsibility and authority for, monitoring, measurement, data recording activities and
quality control/quality assurance/management control procedures is sufficient
16. Closure
The Verification Plan is considered to be a dynamic document that will require modification and adaptation to project
conditions as encountered during the completion of the Verification process. GHD will communicate the changes to
the verification plan with Shell throughout the verification.

All of Which is Respectfully Submitted,
GHD
Sean Williams, P. Eng., Lead Verifier
Deacon Liddy, P. Eng., Designated Signing Authority
Gordon Reusing, P. Eng., Peer Reviewer

17. References
Alberta Environment and Protected Areas. 2023. Standard for Validation, Verification and Audit.
Alberta Environment and Protected Areas. 2015. Quantification Protocol for CO2 Capture and Permanent Storage in
Deep Saline Aquifers.
Alberta Environment and Protected Areas. 2019. Carbon Offset Emission Factors Handbook.
Government of Alberta. 2020. Technology Innovation and Emissions Reduction Regulation, Alta Reg. 133/2019 with
amendments.
International Organization for Standardization. 2018. ISO 14064-1:2018. Greenhouse gases – Part 1: Specification
with guidance at the organization level for quantification and reporting of greenhouse gas emissions and
removals.
International Organization for Standardization. 2016. ISO 14064-3:2016. Greenhouse gases – Part 3: Specification
with guidance for the validation and verification of greenhouse gas assertions.
Shell Canada Limited. 2016. Offset Project Plan Carbon Capture and Storage Project.

ghd.com The Power of Commitment

Appendix B: Statement of Qualifications
Page 57 of 70
Statement of Qualifications
Alberta Emission Offset
Project
Emission Offset Project Name Offset Project ID
Quest Carbon Capture and Storage
Project 7306-8118
Emission Offset Project Developer Offset Reporting Period
December 31,
Shell Canada Limited January 1, 2022 2022
from to
Signature of Designated Signing Authority
(Designated Signing Authority), meet or exceed the qualifications

and eligibility of a third party assurance provider described in
I, Section 27 of the Technology Innovation and Emissions Reduction
Deacon Liddy Regulation.
Third Party Assurance Provider Company
Name
GHD Limited Per:
Signature of Designated Signing Authority Date

April 27, 2023
Training Received meeting Verification

Standard requirements
Mr. Liddy has received training under ISO 14064 Part 3 as required by GHD's internal lead verifier training.
GHD is an accredited verification body under ISO 14065.
First Name Last Name

Deacon Liddy
Professional Designation or
Accreditation Org/Number E-mail Address Phone Number
P. Eng. Deacon.Liddy@GHD.com 604-241-0510
Lead Verifier
Same as designated signing
☐ authority.
Sean Williams
Professional Designation or
Accreditation Org/Number E-mail Address Phone Number
P.Eng Sean.Williams@GHD.com 780-705-7055

Mr. Williams has received training under ISO 14064 Part 3 as required by GHD's internal lead verifier
training. GHD is an accredited verification body under ISO 14065.
Page 58 of 70
Peer Reviewer
Gordon Reusing
E-mail Address Phone Number
Gord.Reusing@GHD.com 519-340-4231

Mr. Reusing has received training under ISO 14064 Part 3 as required by GHD's internal lead verifier training.
GHD is an accredited verification body under ISO 14065.
Page 59 of 70
Appendix C: Findings and Issues
Page 60 of 70
Table 3: Detailed Findings and Issues Log
Item (YR-##) Description of the Issues Summary of Information Resolution Conclusion

Investigated During the Exchanged (Resolved or (including %
Verification Unresolved) discrepancy if
applicable)
22-01 The calculated absolute GHD reviewed all process data Resolved Overall
difference between Shell’s and used to develop the difference is
GHD’s values for the baseline/project sources. 0.06%, less
baseline/project sources and than the
None of these discrepancies are
sinks are the following: materiality
material, and the overall
threshold.
B1 – 25.18 tonnes CO2, difference is less than the
<0.01% of total offsets materiality threshold.
P4 – 0.50 tonnes CO2,
<0.01% of total offsets
P5/P6/P7 – 36.51 tonnes
CO2e, 0.01% of total offsets
P8 – 226.42 tonnes CO2e,
0.03% of total offsets
0.02% of total offsets

<0.01% of offsets
<0.01% of offsets
Page 61 of 70
applicable)
GHD reviewed all process data
used to develop the
baseline/project sources.
None of these discrepancies
are material, and the overall
difference is less than the
materiality threshold. Overall
difference is 0.06%, less than
the materiality threshold.
22-02 Shell originally missed three GHD reviewed the email Resolved Confirmed to
HFC leaks in their original communication between Shell not result in
SERS report. Shell has since Data Focals and the HFC leaks any material
accounted for these leaks in spreadsheet. discrepancies.
their Version 5, SERS report.
Shell addressed the error by
providing evedience of the HFC
leaks and an updated SERS
report.
22-03 Shell omitted the Project’s GHD reviewed the monthly Resolved Confirmed to
nitrogen usage for the month nitrogen consumption provided not result in
of May in their original SERS in the Mass Balance any material
report. Shell has since spreadsheets and compared the discrepancies.
accounted for this in their consumption to the amounts
Version 5, SERS report. provided in the SERS report.
providing an updated SERS
report including the nitrogen
consumption for May.
22-04 Shell accounting for the GHD reviewed the raw meter Resolved Confirmed to
electricity from the cooling fan data and the calculations from not result in
twice, once as a Part of Total the Power Monthly spreadsheets any material
Import Electricity - Cogen discrepancies.
calaculations and once as a
Page 62 of 70
applicable)
standalone value (Total as well as the SERS outputs for
Import Electricity – Cooling electricity.
Fans) in SERS.
providing an updated SERS
report without the double-count.
22-05 Shell did not provide GHD reviewed the calibration Resolved GHD has
calibration records for the records provided by Shell. confirmed that
following meters: the lack of
Shell has indicated these meters
calibration
52-15B (Quest Main Power) do not have documentation and
records for
do not need to be calibrated.
52-16B (Compressor Motor these meters
Power) will not result
in a material
misstatement.
Page 63 of 70
Appendix D: Statement of Verification
Page 64 of 70
April 2023
Statement of Verification
Alberta Emission Offset Project
Emission Offset Quantification Protocol
Project Title (Date/Version) Project ID #
Quantification protocol
for CO2 capture and
permanent storage in
deep saline aquifers
Quest Carbon Capture and (June 23,
Storage Project 2015/Version 1.0) 7306-8118
Offset Reporting Period Serial Range (if

Emission Offset Project Developer Start applicable)
Shell Canada Limited January 1, 2022 N/A
Authorized Project Contact (if Offset Reporting Period

applicable) End
December
N/A 31, 2022
Statement of Verification
Total GHG Assertion
Value Units
Total Baseline tonnes

970,606
Emissions CO2eq
Total Project tonnes

255,190
Emissions CO2eq
tonnes
Other (I.e. levied)
CO2eq
Net Reduction 715,416 tCO2e
Page 65 of 70
April 2023
The Quest Carbon Capture and Storage Offset Project reported

715,416 tCO2e net offsets for the 2022 reporting period of January 1 –
Statement of
December 31, 2022.
Assertion
Responsibilities of Project Developer and Third Party

Assurance Provider
Shell is responsible for completing an accurate offset project report and engaging a qualified
third party verifier to conduct a verification of the offset project report form and assertion.
GHD's responsibility was to express a conclusion with respect to the offset project report (2022
reporting period).
Conclusion
The verification conclusion is positive.

Based on the verification conducted by GHD, the GHG assertion provided in the OPR for the
Quest Carbon Capture and Storage Project was determined to be free of material
misstatements, fairly presented, substantiated by sufficient and appropriate evidence, and was
prepared in accordance with the TIER and relevant criteria.
Verification
Company Name
GHD Limited Per:
Da
Signature of Designated Signing Authority te:
April 27, 2023
Deacon Liddy
Professional
Designation/Accredit Phone
ation Org & Number E-mail Address Number
P. Eng Deacon.liddy@ghd.com 604-241-0510
Page 66 of 70
Appendix E: Conflict of Interest Checklist
Page 67 of 70
April 2023
Conflict of Interest Checklist

Alberta Emission Offset
Project
Emission Offset
Project Title Quantification Protocol (Date/Version)
Quest Carbon Quantification protocol for CO2 capture and
Capture and Storage permanent storage in deep saline aquifers (June 23,
Project 2015/Version 1.0)
Offset Reporting
Project Developer Offset Reporting Period Start Period End
December 31,
Shell Canada Limited January 1, 2022 2022
Checklist
Respond either "True" or "False" to each of the following statements:
The relationship between my firm and this reporting company poses unacceptable
1.
threat to or compromises the impartiality of my firm. False
The finances and sources of income of my firm compromise the impartiality of my

2.
firm. False
The personnel my firm has scheduled to participate in the verification may have an
3.
actual or potential conflict of interest. False
My firm participated in some manner in the development or completion of the

4.
associated offset submission for this reporting company. False
5. My firm provided greenhouse gas consultancy services to this reporting 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 offset
7.
submission. False
8. My firm offers products or services that pose an unacceptable risk to 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, the Verification
Report will not be acceptable to Alberta Environment and Parks.
Page 68 of 70
April 2023
(Designated Signing Authority), have personally examined and am

I, Deacon Liddy 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.
Verifcation Company
Name
GHD Limited Per:
Signature of Designated Signing
Authority
Date:
April 27, 2023

Deacon Liddy
Professional
Designation/
Accreditation Org &
Number E-mail Address Phone Number
P. Eng Deacon.liddy@ghd.com 604-241-0510
Page 69 of 70
April 2023
Appendix F: Supplemental Diagrams/Tables/Figures
Page 70 of 70
Appendix F.1
List of Documents Received by GHD
Quest Carbon Capture and Storage (CCS) Project - 6th Reporting Period
Document No. Document Title Document Description

Alberta - Project Plan (Project #7306-8118) Updated Aug
1 2016 Offset Project Plan
2 Quest Carbon Capture and Storage Project - 2022 OPR.docx Offset Project Report for the 2022 reporting period
ConsumptionValues.xls
EmissionValues.xls
Measurements.xls
3 (Multiple Versions) SERS output
Emissions Drilldown - Quest 2022.xlsx
Quest SERS Protocol Report 2022.xlsx
4 (Multiple Versions) Emissions Summary of SERS output
5 Various Files Calibration records for meters
Enviro Report Verification (Monthly)
6 TransCanada Report-2022 (NOVA Gas Transmission Ltd.) Gas composition data summaries
Contractor Fuel Usage 2022.xlsx
2022 Fuel Consumption Report.xlsx (Monthly)
Fuel Consumption Report - Activity Summary report by
7 Account for Product - (Month) 2022.xlsx Diesel and gasoline usage
8 Analyzer vs Lab data_Quest 2022.xlsx Comparison of lab and analyzer data
Calibration gas and calibration procedures for
9 SCT - GC-023 Quest details.docx laboratory GC
Quest Well Electricity:
10 Quest {Month} 2022.xlsx (Monthly) Monthly injection well site electricity invoices
2022 JV Cogen Billing Model {Month} Final - New Server.xlsx
11 (Monthly) Quest Main Site Electricity
12 Quest Mass Balance - {Month} 2022 Mass Balance spreadsheets
Steam:
13 MM - Monthly Quest {Month} 2022.xlsb.xlsx (Monthly) Steam Spreadsheets
14 MMV Overview through 2022 Presentation overview of MMV Plan updates
Summary of Mass Balance Spreadsheets and Waste
15 2022 Mass Balance Summary.xlsx Water Treatment Volumes Summary
16 Quest_2020_MMV_Plan_Resubmit_Nov20.pdf Most recent MMV Plan
Assessment of MMV plan and emissions for Q1-Q4 in
17 P20_assessment_Q# 2022 (Four files for each Quarter) 2022
AER Quest 8-19 BHP Gauge Erroneous Data_August 2022.pdf

AER Quest 8-19 BHP Gauge Erroneous Data_Q4_2022.pdf
Feb.14_audit_Q1-
Q4_2022_P20_MMV_Overview_shared.pdf Explaination of erroneous Subsurface emission trigger
18 SS MMV Data Requests.xlsx events
NG to HVAC DataRec Verified Volumes
Summary
19 AOSP PI TAGS - DataRec.xlsx Overview of Quest natural gas usage
20 SERS_ Quest_GM SCVFT_summary_2022.xlsx Venting summary
Bird Master Refrigerant leak check Form with auto totals -
2022.xlsx
21 RE_ Chemicals Purchased.msg HFC leak check and additions
Cathodic Protection additions or replacements
22 Re_ 2022 Cathodic Protection - rectifier beds.msg confirmation email
23 RE_ Quest Gov Reporting - Material Inputs for 2022.msg Material input purchasing email
Appendix F.2
Comparison Between Facility's Emission Reductions and GHD Reconstructed Emission Reductions
Quest Carbon Capture and Storage (CCS) Project - 2022 Crediting Period
Shell Reported Emission Reductions GHD Reconstructed Emission Reductions

Net Absolute
(tonnes (tonnes Net % Net % of Net % of Absolute Absolute
Category Protocol Decription CO2 CH4 N2O CO2e CO2e CO2 CH4 N2O CO2e CO2e CO2e) CO2e) Diff. B/P ERs % of B/P % of ERs
Baseline
B1 Injected CO2 970,606.79 - - 970,606.79 970,606.79 970,631.98 - - 970,631.98 970,631.98 -25.18 25.18 0.00 0.00 0.00 0.00 0.00
Injection Well 1 300,414.41 - - 300,414.41 300,414.41 300,424.69 - - 300,424.69 300,424.69 -10.28 10.28 0.00 0.00 0.00 0.00 0.00
Injection Well 2 377,122.27 - - 377,122.27 377,122.27 377,129.61 - - 377,129.61 377,129.61 -7.35 7.35 0.00 0.00 0.00 0.00 0.00
Injection Well 3 293,070.12 - - 293,070.12 293,070.12 293,077.67 - - 293,077.67 293,077.67 -7.56 7.56 0.00 0.00 0.00 0.00 0.00
Total Baseline (CO2e) 970,606.00 - - - 970,606.00 970,631.00 - - - 970,631.00 -25.00 25.00 0.00 0.00 0.00 0.00 0.00
Project
P3 Well Drilling/Construction 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
P4 Production of Inputs 782.23 782.23 781.7283453 781.7283453 0.50 0.50 0.06 0.00 0.00 0.00 0.00
P5, P6, P7 Use of Fuels 11,627.92 227.31 0.61 17,493.01 11,603.58 226.84 0.61 17,456.50 36.51 36.51 0.21 0.01 0.01 0.01 0.01
P8 Off-Site Electricity 57,930.75 57,930.75 57704.32791 57704.32791 226.42 226.42 0.39 0.09 0.03 0.09 0.03
P9 Off-Site Heat 177812.4459 3.23 2.88 178,753.04 177667.2982 3.22797381 2.879003668 178605.9406 147.10 147.10 0.08 0.06 0.02 0.06 0.02
P10 On-Site Heat and Electricity 4.9823977 0.00 0.00 5.02 4.972830366 9.04351E-05 8.06584E-05 5.298563538 -0.28 0.28 -5.63 0.00 0.00 0.00 0.00
P11 CCS Facility Operation 126.27 0.00 0.01 128.34 127.79 0.01 0.02 127.82 0.52 0.52 0.41 0.00 0.00 0.00 0.00
P18 Venting at Injection Sites 0.77 0.92 0.00 23.81 0.003214745 0.935081382 23.3802493 0.43 0.43 1.81 0.00 0.00 0.00 0.00
P19 Fugitives at Injection Sites 5.56 0.40 0.00 15.56 5.559805147 0.003805492 5.654942459 9.90 9.90 63.65 0.00 0.00 0.00 0.00
P20 Subsurface Emissions 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
P21 Loss of Inputs 60.69 60.69 78.4272202 78.4272202 -17.73 17.73 -29.22 -0.01 0.00 0.01 0.00
Total Project 189,577.94 231.87 3.50 58,773.67 255,192.44 189,409.21 231.01 3.51 58,564.48 254,789.07 403.37 439.41 0.69 0.16 0.06 0.17 0.06
Total Project (CO2e) 189,577.00 5,796.00 1,044.00 58,773.00 255,190.00 189,409.00 5,775.00 1,045.00 58,564.00 254,793.00 397.00 439.41 0.68 0.16 0.06 0.17 0.06
Total Reductions 715,416.00 715,838.00 -422.00 464.59 -0.06 -0.06 0.06

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Quest Carbon Capture and Storage Project

Verification Report for:

Proponent Name and Proponent Project Number:

Version 3.0 Offset Verification Report Form

1.0 Summary of Offset Project

Project Title Quest Carbon Capture and Storage Project

Project Description The purpose of this offset project is to quantify

Project Location Latitude: 53.7407°N; Longitude: 113.0231°W

Project Start Date The project, as defined by commencement of

Offset Reporting Period 2022 Reporting Period (January 1 to

Government Approved Quantification Protocol for CO2 Capture and

Ownership Shell Canada Limited is the managing partner

Project Activity The Project meets the eligibility criteria as per

Project Contact Celina Duong

Lead Verifier Mr. Sean Williams, P.Eng.

Verification Team Members Sean Williams, P. Eng.

Stephaney Davey, M.Sc., E.I.T.

Gordon Reusing, P. Eng.

Designated Signing Authority Deacon Liddy, P.Eng

Verification Strategy GHD’s detailed verification strategy is

Verification Conclusion The verification conclusion is: Positive

• Quest CCS capture Facility

• Production and transportation of materials

• Construction and drilling of new injection wells

Table 2.1 Specified Emissions Reductions and Gas Types

Protocol Specified Gas Type

Protocol Specified Gas Type

Summary of Changes to Baseline Condition

(conducted by TetraTech EBA Inc. (TetraTech)). A revised steam allocation methodology

GHD will ensure and attest to the following:

• Accuracy and completeness of the current OPR.

Conflict of Interest (COI) and Independence

Documentation Review and Emissions Recalculations

Internal Peer Review

Documentation and Deliverables

• COI Checklist, which will meet the TIER requirements

Accuracy Low – Metering system

Classification Low – classification of offsets is well defined

Transparency Medium - Calculations are completed in “black-

Consistency Low – Understood calculations are consistent

Classification Low – classification of offsets is well defined

Transparency Medium - Calculations are completed in “black-

Consistency Low – Understood calculations are consistent

Transparency Medium - Calculations are completed in “black-

Consistency Low – Understood calculations are consistent

Classification Low – classification of offsets is well defined

Transparency Medium - Calculations are completed in “black-

Consistency Low – Understood calculations are consistent

Classification Low – classification of offsets is well defined

Transparency Medium - Calculations are completed in “black-

Consistency Low – Understood calculations are consistent

Classification Low – classification of offsets is well defined

Transparency Medium - Calculations are completed in “black-

Consistency Low – Understood calculations are consistent

Classification Low – classification of offsets is well defined

Transparency Medium - Calculations are completed in “black-

Consistency Low – Understood calculations are consistent

Consistency Low – Understood calculations are consistent

Transparency Medium - Calculations are completed in “black-box”