04:15 10 Oct 24
Info Report Check
Submission incomplete:
The DOE did not determine that the alternative monitoring arrangements proposed by project participants apply conservative assumptions to ensure that GHG emission reductions will not be overestimated as a result of the deviation. Please refer to paragraph 283 of the VVS-PA, version 2.0.
In order to demonstrate that the proposed monitoring arrangement is conservative in the ERs spreadsheet, the PP compared (i) the methane flow calculated through the approach proposed against the methane flow calculated against (ii) the "total flow of collected LFG sent to the 19 engine generators" (cells B16 to B18 of the sheet “FCH4,EL,y”) multiplied by the average methane concentration. The "total flow of collected LFG sent to the 19 engine generators" is determined by multiplying the "average flow of collected LFG sent to the 19 engine generators" (cells C16 to C18, measured by a single flow-meter positioned in the main pipeline supply of gas to the power plant) by 24 hours/day and by the numbers of day in a month, indicating that the gas flow was not measured continuously.
The DOE should further validate how the "average flow of collected LFG sent to the 19 engine generators" was measured (e.g. under which operational conditions of the project, frequency of measurement (every minute, hourly, daily, etc), the details of the instrument used (including the calibration), among others) and whether it reproduces figures that can be reliably used to secure the conservativeness of the proposed monitoring arrangement.
The DOE did not determine that the alternative monitoring arrangements proposed by project participants apply conservative assumptions to ensure that GHG emission reductions will not be overestimated as a result of the deviation. Please refer to paragraph 283 of the VVS-PA, version 2.0.
In order to demonstrate that the proposed monitoring arrangement is conservative in the ERs spreadsheet, the PP compared (i) the methane flow calculated through the approach proposed against the methane flow calculated against (ii) the "total flow of collected LFG sent to the 19 engine generators" (cells B16 to B18 of the sheet “FCH4,EL,y”) multiplied by the average methane concentration. The "total flow of collected LFG sent to the 19 engine generators" is determined by multiplying the "average flow of collected LFG sent to the 19 engine generators" (cells C16 to C18, measured by a single flow-meter positioned in the main pipeline supply of gas to the power plant) by 24 hours/day and by the numbers of day in a month, indicating that the gas flow was not measured continuously.
The DOE should further validate how the "average flow of collected LFG sent to the 19 engine generators" was measured (e.g. under which operational conditions of the project, frequency of measurement (every minute, hourly, daily, etc), the details of the instrument used (including the calibration), among others) and whether it reproduces figures that can be reliably used to secure the conservativeness of the proposed monitoring arrangement.
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