Info Report Check
Submission incomplete:
1: (a) Parameter FCLPG,y is measured with weighing scale belonging to the LPG distributor. As per the monitoring plan, the calibration is to be done as per the manufacturer specification. The validation report (page 101) states that the adopted calibration frequency is in accordance with national requirements and also with related requirements/recommendations as established by the weight scale manufacturer. However, neither the monitoring report nor the validation report states the calibration frequency as the manufacturer.

(b) There is inconsistency in the calibration of pitot tube used by the 3rd party to determine the flare efficiency. The monitoring report states the date as 31/10/2017, while the validation report mentions two dates: 31/08/2017 and 31/10/2017 (ps. In my case the VR mentioned two dates as 31/08/2017 and 23/02/2018, then in my case I will only mention 31/08/2017). The DOE is requested to address this inconsistency.



2: The DOE is requested to clarify how it verified the application of option B.1 to determine the flare efficiency in line with the Tool: Project emissions from flaring, version 02.0.0, in particular:
(a) The results of the measurements conducted on 02/10/2017 and 26/03/2018 have been used for the two previous monitoring period, i.e. 01 May 2017 - 31 Jan 2018 and 01 Feb 2018 - 30 Apr 2018 which already covers one year, whereas the tool describes that flare efficiency in the year “y” is determined based on two measurements in year “y”;
(b) As per the tool, the two time periods in year y during which the flare efficiency is measured are separated by at least six months. However, the gap of the two measurements on 02/10/2017 and 26/03/2018 is less than six months;
(c) As per the tool, the measurements shall be done by third accredited entity. The two measurements were done by BIOAGRI Ambiental Ltda. / Mérieux NutriSciences Brasil. However, there is no information in the validation report whether or not this entity is accredited to conduct the measurements.
(d) As per page 49 of the PDD, the Option A “applying default value for flare efficiency” could be used if the biannual related measurements are not available, it is not clear why the Option A was not applied.