Info Report Check
Submission incomplete:
1: Paragraph 283 of VVS-PA:
The DOE is requested to explain how it validated the temporary deviation from the registered monitoring plan, in particular:
(a) Deviation 1:
(i) It is not evident that the formulas described on page 8 of the monitoring report are applied in the ER sheets;
(ii) The ER sheets (for example in file “Annex 30 to CER Sheet”) include parameter "Maximum LFG Methane fraction in DEVIATION" in sheet "Assumptions" which is used to determine "LFG Methane fraction (%)". However, there is no explanation what this parameter is and why it is used in the calculation;
(iii) On page 8, the monitoring report concluded that the estimate presented is conservative since it does not add the methane losses in the biogas purification process (D) to the result of methane concentration in biogas. The DOE is requested to substantiate how this is conservative, considering that lower D (for not adding methane losses in the biogas purification process) would result in higher volumetric fraction of CH4 in the LFG and eventually higher BECH4,y which not conservative;
(iv) The DOE is requested to substantiate how it is conservative not to consider fraction of the biomethane which was flared. The monitoring report on page 11 states that biomethane which does not reach the required parameters to be delivered to the NG distribution system is flared. As this may include biomethane with volumetric fraction lower than the requirement, excluding lower volumetric fraction would result in volumetric fraction of CH4 in the LFG being overestimated, and eventually BECH4,y being overestimated;
(b) Deviation 3:
(i) The PP considered the highest temperature of LFG as 78 degree C whereas the value observed is 78.333 degree C, instead of rounded down value 78 degree C;
(ii) The ER sheet for August 2020 shows that the highest measured temperature is 1370.

2: Paragraph 309(b) of VVS-PA:
The DOE is requested to explain how it validated the changes to the project design, in particular:
(a) There is no opinion on assessment on the reasons for the expansion of landfill area;
(b) There is no explanation how the expected annual amount of waste is lower than the amount described in the registered PDD with the increased area of landfill.

3: Paragraph 272 (e) of VVS-PA:
In the validation report for PRC the DOE referred to paragraph 338(b) and 339 of the VVS-PA for the requirement for mandatory site visit. However, it has not considered the relevant requirement for mandatory site visit applicable to PRC, i.e. paragraph 301 of VVS-PA.

4: Paragraph 258 of PS-PA:
(i) Monitoring report on page 13 lists the equipment for measurement. However, each equipment is not shown in the monitoring diagram described on page 8 of monitoring report;
(ii) Total number of gas meters listed on page 13 of monitoring report (i.e. 3 meters) does not match total number of gas meters shown in the monitoring diagram on page 8 of monitoring report (i.e. 7 meters).

5: Paragraph 373(c) of VVS-PA:
The monitoring report on page 28 states that during the monitored period Options A and B were used to determine the mass flow of gases containing methane. Option B is applicable when the volume flow in wet basis and volumetric fraction in dry basis. The DOE is requested to explain how it verified the correctness of application of option B, in particular the application of equation 6 of the revised PDD for the period October 2018 to August 2020, as it is observed in some instances that LFG temperature is above 60 degree C (which shows that the volume flow is wet basis), however equation 6 is not used to convert volumetric flow from wet basis to dry basis.

6: Paragraph 373(e) of VVS-PA:
The DOE is requested to explain how it verified parameter "Methane density at standard T and P" which value is fixed for the entire monitoring period as 0.7168 kg/m3 as: (i) Version 15 of ACM0001 does not have this value; (ii) The revised PDD does not include this parameter as parameters fixed ex-ante; (iii) The revised PDD requires that the density be calculated as per equation 5; (iv) The monitoring report states that the flow meter measures the flow at normal conditions whereas this parameter refers to standard conditions.