06:29 24 Apr 24
Info Report Check
Submission incomplete:
1: Scope: The validation report does not contain a confirmation whether the temporary deviation from the registered monitoring plan or applied methodology does not require prior approval of the Board and the provisions of Appendix 1 of PS apply to those deviations as per VVS version 09.0 paragraphs 289, 298, 300, 301 and 302.
Issue: In regard to the following temporary deviations, the DOE is requested to explain how they can be considered temporary deviations that do not require prior approval by the Board:
(a) Temporary deviation #1 (delay in the NCV measurements), the DOE cited paragraph 3 of Appendix 1 of project standard version 09.0 that is applicable for project emissions. As NCV of black liquor is used to calculate baseline emissions: (i) The DOE is requested to explain how this paragraph is applicable; (ii) Furthermore, as paragraph 2 of the appendix is applicable for baseline emissions, the DOE is also requested to explain how the temporary deviation is in line with paragraph 2, hence does not require prior approval from the Board; (iii) How the values from the IPCC have been applied in the calculation.
(b) Temporary deviation #2 (malfunction of low pressure steam flow meter from turbogenerator 1), the DOE is requested to further explain: (i) how using the maximum value in the month of November 2014 for the period of malfunction can be considered as being in operation at maximum capacity as per the paragraph 3 of the Appendix 1 of the project standard version 09.0; (ii) in light of malfunction of this flow meter, how the share of steam from turbogenerator 1 of 79.3% is appropriate.
2: Scope: The verification and certification report does not describe the implementation status of the project as per VVS version 09.0 paragraph 385 (a).
Scope: The verification report does not describe the reasons for the phased-implementation delay and/or does not present the expected implementation dates as per VVS version 09.0 paragraph 385 (a).
Issue: The DOE is requested to explain how it has verified the project being implemented as per the PDD, as the PDD mentions the pressure generated in the recovery boiler being 61 bar(a), whereas the verification and certification report mentions it as 86 bar.
3: Scope: The verification and certification report does not list each parameter required by the monitoring plan and does not provide an statement on how the DOE verified the information flow for these parameters including the values in the monitoring reports as per VVS version 09.0 paragraphs 393 and 409 (e).
Issue: The DOE is requested to explain how it has verified the parameter average net energy efficiency of heat generation in the boiler that would generate heat in the absence of the project activity, in particular:
(i) How the use of measured efficiency of similar plant complies with the requirement of the methodology (i.e Either use the higher value among (a) the measured efficiency and (b) manufacturer’s information on the efficiency OR assume an efficiency of 100% as a conservative default value). In doing so, the DOE shall explain how the other plant can be considered similar as the project activity’s plant fro example in light of its capacity or technology;
(ii) How the DOE concluded that the use of efficiency of 85% is more conservative and results in lower emission reductions compared with the use of 100% efficiency.
4: Scope: The verification and certification report does not provide an assessment on whether the calibration of measuring equipments was conducted at a frequency specified by the applied methodology, the standardized baseline and/or the monitoring plan as per VVS version 09.0 paragraph 400.
Issue: The DOE is requested to explain how it verified the following:
(a) As mentioned in the monitoring report page 28, the black liquor flow meter 352-FT-461 had erratic reading from September to November 2014, hence the missing readings were taken directly from flow meter 352-FT-433. However there is no information how the DOE has verified the calibration of meter 352-FT-433;
(b) In regard to the delayed calibration for weight meter 331-WT-005, the DOE is requested to explain how the adjustment for the delay in April 2014 is appropriate. The adjustment is made assuming the value for each day in April 2014 was the same (i.e. by dividing the monthly value by 30 days). However, in the absence of information of whether the values during the delayed period in April were higher or lower than the daily average value, how the DOE can ensure that the approach is conservative;
(c) The monitoring report page 16 shows that adjustments were made for the reading of the following meters: 330-WT-050, 330-WT-052, 310-81-1150, 310-81-1151, 365FT901, 365FT902, 365FT914, 365FT920 and 365FT923. However, it is not clear from the ER spreadsheet how the adjustments have been made, and there is no information on how the DOE verified the adjustments.
1: Scope: The validation report does not contain a confirmation whether the temporary deviation from the registered monitoring plan or applied methodology does not require prior approval of the Board and the provisions of Appendix 1 of PS apply to those deviations as per VVS version 09.0 paragraphs 289, 298, 300, 301 and 302.
Issue: In regard to the following temporary deviations, the DOE is requested to explain how they can be considered temporary deviations that do not require prior approval by the Board:
(a) Temporary deviation #1 (delay in the NCV measurements), the DOE cited paragraph 3 of Appendix 1 of project standard version 09.0 that is applicable for project emissions. As NCV of black liquor is used to calculate baseline emissions: (i) The DOE is requested to explain how this paragraph is applicable; (ii) Furthermore, as paragraph 2 of the appendix is applicable for baseline emissions, the DOE is also requested to explain how the temporary deviation is in line with paragraph 2, hence does not require prior approval from the Board; (iii) How the values from the IPCC have been applied in the calculation.
(b) Temporary deviation #2 (malfunction of low pressure steam flow meter from turbogenerator 1), the DOE is requested to further explain: (i) how using the maximum value in the month of November 2014 for the period of malfunction can be considered as being in operation at maximum capacity as per the paragraph 3 of the Appendix 1 of the project standard version 09.0; (ii) in light of malfunction of this flow meter, how the share of steam from turbogenerator 1 of 79.3% is appropriate.
2: Scope: The verification and certification report does not describe the implementation status of the project as per VVS version 09.0 paragraph 385 (a).
Scope: The verification report does not describe the reasons for the phased-implementation delay and/or does not present the expected implementation dates as per VVS version 09.0 paragraph 385 (a).
Issue: The DOE is requested to explain how it has verified the project being implemented as per the PDD, as the PDD mentions the pressure generated in the recovery boiler being 61 bar(a), whereas the verification and certification report mentions it as 86 bar.
3: Scope: The verification and certification report does not list each parameter required by the monitoring plan and does not provide an statement on how the DOE verified the information flow for these parameters including the values in the monitoring reports as per VVS version 09.0 paragraphs 393 and 409 (e).
Issue: The DOE is requested to explain how it has verified the parameter average net energy efficiency of heat generation in the boiler that would generate heat in the absence of the project activity, in particular:
(i) How the use of measured efficiency of similar plant complies with the requirement of the methodology (i.e Either use the higher value among (a) the measured efficiency and (b) manufacturer’s information on the efficiency OR assume an efficiency of 100% as a conservative default value). In doing so, the DOE shall explain how the other plant can be considered similar as the project activity’s plant fro example in light of its capacity or technology;
(ii) How the DOE concluded that the use of efficiency of 85% is more conservative and results in lower emission reductions compared with the use of 100% efficiency.
4: Scope: The verification and certification report does not provide an assessment on whether the calibration of measuring equipments was conducted at a frequency specified by the applied methodology, the standardized baseline and/or the monitoring plan as per VVS version 09.0 paragraph 400.
Issue: The DOE is requested to explain how it verified the following:
(a) As mentioned in the monitoring report page 28, the black liquor flow meter 352-FT-461 had erratic reading from September to November 2014, hence the missing readings were taken directly from flow meter 352-FT-433. However there is no information how the DOE has verified the calibration of meter 352-FT-433;
(b) In regard to the delayed calibration for weight meter 331-WT-005, the DOE is requested to explain how the adjustment for the delay in April 2014 is appropriate. The adjustment is made assuming the value for each day in April 2014 was the same (i.e. by dividing the monthly value by 30 days). However, in the absence of information of whether the values during the delayed period in April were higher or lower than the daily average value, how the DOE can ensure that the approach is conservative;
(c) The monitoring report page 16 shows that adjustments were made for the reading of the following meters: 330-WT-050, 330-WT-052, 310-81-1150, 310-81-1151, 365FT901, 365FT902, 365FT914, 365FT920 and 365FT923. However, it is not clear from the ER spreadsheet how the adjustments have been made, and there is no information on how the DOE verified the adjustments.
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