Info Report Check
Submission incomplete:
Scope: The DOE shall determine whether a complete set of data for the specified monitoring period is available. (VVM v 01.2 paragraph 208 (a)
Issue: The Monitoring plan requires “the methane content (MCbiogas) to be measured and recorded at least quarterly (dry basis). A sufficient number of measurements will be made to meet a 95% confidence level.” However, the Verification report (page 12) states that "for the RE units, there was no data available for the first quarter of the monitoring period. A corrective action request (CAR 4) was issued. PP had explained the reason for not having the data for this parameter. PP had replaced the missing data with the lower boundary coupled with deducting the equipment accuracy."
The verification report does not contain information on how the DOE assessed the proposed approach to be the most conservative assumption theoretically possible, or why it has not raised a request for deviation prior to submitting request for issuance, as per VVM v 01.2 paragraph 208 (a).