I-DEV0453: Deviation from provisions of registered PDD due to delayed installation of flare efficiency continuous monitoring equipment.

Reference I-DEV0453
Submitted by TÜV Rheinland (22 Nov 2011)
Project activity 1371: Proactiva Mérida Landfill Gas Capture and Flaring project
Selected monitoring period 03 Apr 2008 - 31 Dec 2009
Title/subject of deviation Deviation from provisions of registered PDD due to delayed installation of flare efficiency continuous monitoring equipment.
Description
The DOE and PPs assessed the following:

1. This deviation takes into account the provisions of the VVM 01.2, EB55, Annex 1, paragraph 214, in which it is stipulated that the request for deviation applies to the monitoring period under verification. Furthermore, in EB 43 Report, paragraph 57 is consider: “The Board agreed that for cases where a delayed installation/operation of a monitoring equipment is observed, a request for deviation can be applied for a period covering the monitoring period under verification until the start of the operation of the equipment…”

2. According to the approved monitoring plan in the registered PDD, to calculate the parameter PEflare it is necessary to determine the flare efficiency (ηflare,h) as per the Step 6 of the “Tool to determine project emissions from flaring gases containing methane” for enclosed flares and continuous monitoring. This requires a continuous exhaust gas analyzer.

3. However, as a result of very low biogas production at the site (for this monitoring period PPs claims less than 6% of the initially foreseen CERs in this Monitoring Period), the project participants have not installed a continuous monitoring system for the concentration of CH4 in the exhaust gas of the flare and thus no monitoring data is available to calculate the project emissions from flaring of the residual gas stream in year y, PEflare,y as per registered PDD. More specifically, the parameters tO2,h and fvCH4,FG,h were not monitored during the Monitoring period as per the registered Monitoring Plan.

4. Technical measures are currently taken and additional investment employed in order to improve the landfill gas capture system. This will decrease the gap between the theoretical gas production predicted in the PDD and the amount of captured gas on site. As a result, the number of CERs generated is expected to increase and thus the PPs ability to invest into monitoring equipment (gas
analyzer for exhaust gas). As mentioned in the official communication of the PPs (/4/) the investment into the additional monitoring equipment is expected for January 2013.

5. For the parameter flare efficiency (ηflare,h), the PP stated in the PDD that “In case the continuous system is unavailable for maintenance, or failure…” a default value will be applied according to Step 6 of the mentioned Tool as follows:

· 0% if the temperature in the exhaust gas of the flare (Tflare) is below 500 °C for more than 20
minutes during hour h.

· 50%, if the temperature in the exhaust gas of the flare (Tflare) is above 500 °C for more than 40 minutes during hour h, but the manufacturer’s specifications on proper operation of the flare are not met at any point during hour h (manufacturer’s specifications state that 90% of the flare efficiency shall met at temperatures above 700°C ).

· 90%, if the temperature in the exhaust gas of the flare (Tflare) is above 500 °C for more than 40 minutes during hour h and the manufacturer’s specifications on proper operation of the flare are met continuously during hour h (manufacturer’s specifications state that 90% of the flare efficiency shall met at temperatures above 700°C).

During the verified period April 3rd, 2008 – December 31st, 2009 the PP has adopted the above approach to determine the Flare efficiency due to the lack of continuous measurements.


6. In the case of the Proactiva Mérida Landfill Gas Capture and Flaring Project, the manufacturer’s specifications on proper operation of the flare in order to apply a 90% default value for ηflare,h are:
- flare temperature shall be above 700°C
- WCH4 shall be in a range of 20-80%
- LFGflare shall be in a range of 150-2000Nm3/h

These three conditions have been continuously monitored during the entire Monitoring Period.
Therefore during the verified period, the project participants applied a 90% default value for the flare efficiency ηflare,h for all monitored data with flare temperatures above 700°C. For flare temperatures between 500°C and 700°C, the project participants applied a default factor for the flare efficiency ηflare,h of 50%. In both cases the manufacturer’s specifications with regard to WCH4 and LFGflare are respected. For flare temperatures below 500°C the ηflare,h is considered to be 0%.

7. The DOE reviewed the following documents from the Manufacturer in order to confirm the proper operation of the flare is being followed:

-Flare specifications in which it is stated that the combustion temperature, the WCH4 and LFG flare operations ranges are those mentioned above /1/.

-Tflare Thermocouple certificate of conformity in which the operation ranges are indicated from 0°C
– 1,300°C, and the flare manufacturer confirms also it is confirmed that for measures above 700°C the flare efficiency of 90% is guaranteed /2/.

8. Furthermore, an independent laboratory, Intertek, carried out sample measurements to assess the flare emissions by the enclosed flare, on July 11th, 2008. Parameters measured during the study were tO2,h and fvCH4,FG,h. The results from this study were used to determine the flare efficiency following
the Steps 1-7 in the “Tool to determine project emissions from flaring gases containing methane”. The calculated flare efficiency from average conditions of the sample is 99.91% and in the case of the lowest flare temperature of the sample (695°C) the flare efficiency is the same. This way the PP ensured the adopted approach in points 5 and 6 is accurate and conservative /3/.

9. The DOE confirmed during the on-site visit that the determination of the flare efficiency complies at every time with the proposed approach.

Given the above observations, it is requested that to determine the Flare efficiency this default value may be used based on the default value proposed by the applicable tool and the manufacturer’s specifications, for this monitoring period and until the installation of the continuously measurement equipment (exhaust gas analyser – expected in January 2013).
Assessment
The PPs are expecting to install the missing continuous monitoring equipment in the near future, as indicated in point 4 of this request. This deviation does therefore not ask for a permanent change in the monitoring procedures nor does it constitute a change from the project activity. The PP is willing to reach higher methane and biogas volumes in order to invest in the equipment.

The proposed deviation concerns data which, instead of being calculated is replaced by a default value. The default value is foreseen in the applicable tool as well as in the registered PDD and is conservative. It is suggested to be applied until the time the new monitoring equipment for analysis of exhaust gas is installed. It is therefore understood, that the monitoring plan does not need to be changed.
Impact
The application of a default value of 90% for the flare efficiency ηflare,h leads to conservative emission reduction estimations. Although not fully quantifiable, it is expected that emission reduction estimates using
the default value for flare efficiency of 90% are more than 9% lower than those that otherwise have been calculated with the default value. Flare efficiency tests /3/ performed at the Merida landfill have shown values in excess of 99% when manufacturer’s specifications are met and the registered PDD assumed a flare efficiency of 97% for ex-ante estimations of ERs.
Based on the information reviewed and that presented within this Request for Deviation, the DOE can confirm that the approach adopted is the most conservative approach and the one that should be used in the ηflare,h and consequently in the ER calculations.
Annexes Flare specifications (1249 KB)
Thermocouple Conformity certificate (257 KB)
Flare efficiency test (137 KB)
Official written communication from the PP regarding the expected installation (421 KB)
Link to the documentation made available at validation stage or monitoring report Link to relevant documentation
Signed form Signed form (1338 KB)
Decision This request for deviation has been accepted.

The Chairs have accepted the request for deviation to the monitoring and reporting process covering the first monitoring period and subsequent monitoring period(s), from 03 April 2008 until January 2013, which is the time planned for the installation of the gas analysing equipment. Should the project participants foresee that they will be unable to install the required equipment by January 2013, a request for a change to the monitoring plan must be submitted in accordance with the latest provisions of the Clean Development Mechanism Project Cycle Procedure.

Current status 06 Jan 2012 - Deviation accepted
Historic statuses 22 Nov 2011 - Submission received
12 Dec 2011 - Successfully passed the Completeness Check
23 Dec 2011 - Awaiting EB decision