21:26 15 Jul 26
Info Report Check
Submission incomplete:
1: The monitoring report (section C) shall provide line diagram (graphical schemes) showing all relevant monitoring points as required by the PS-PA ver. 03.0 paragraph 258.
2: The submitted emission reduction (workbooks “Ammonia-I Feed RLNG” and “Ammonia-I Feed RLNG”) Cells C6 on both workbooks show calculated losses (volume to mass conversion for the NG). Please submit a revised emission reduction sheet (traceable) which shows how these losses were calculated. In doing so, the DOE shall confirm the appropriateness of the method applied to correct the measured volume into the equivalent mass for the consumed of NG (column G of the above workbooks) considering that the method has resulted to negative project emissions in workbook PE-Feed. Please provide a justification if it is considered that the applied method is appropriate. please refer to the applied methodology (page 9 -equation 11) and the VVS-PA paragraph 374 (c).
3: The DOE (VR, page 11) confirms the supply and implementation of feed switchover based on a letter from GAIL (reference 05) “the Proof of start date, communication between GAIL & IFFCO related to the supply of RLNG dated 22/04/2006”. The DOE shall report how it verified the starting date of operation for each site (reported in the monitoring report as July 2006 (Phulpur I) and May 2006 (Phulpur II)). Please refer to the VVS-PA ver. 03.0 paragraph 356.
4: The registered monitoring plan (PDD page 52) has listed monitoring of the parameter “Quantity of fuel type i consumed in the steam generator used for utility steam in each year (FCutility,steam,i,y) and further the submitted emission reduction excel sheet (workbook “Fuel consumed in utility) reported values for two fuels (NG and coal) used in boiler Nos. 1,2,&3. However, the monitoring report does not list this parameter, including how it was monitored. In doing so, please ensure the parameter naming is consistent between the registered PDD and the monitoring report
5: The DOE is requested to provide information on how the following parameters have been verified in compliance with the applied methodology:
i. Production of Urea in each year is based on the plant records (daily Urea production through DCS which is countersigned by Shift in charge) and cross-checked with the Urea stock logbook (which was verified by external entity, Fertilisers Industry Coordination Committee (FICC)). The methodology requires this parameter is calculated based on the ammonia input to the urea plant; and the measurement results should be cross-checked with the periodic urea stock verification carried out by external agencies. However, it is not clear if the plant records data is based on the ammonia input, and if so, how the data was aggregated as reported in workbook “Urea production”.
ii. For the parameter “Carbon content, expressed as weight fraction, of NG/LNG used as feed during year” (Tonnes of carbon/tonnes of NG/LNG), the DOE (VR, page 22) has verified that the values are calculated as per the lab analysis done at the Phulpur plant. However, the applied methodology (page 20) requires that these values are derived from the feed composition report provided by the feed supplier from a certified laboratory.
6: The registered PDD (Section B.6.2) has excluded the parameters “CO2 content in the raw natural gas stream” and “Density of the CO2 gas” applied for calculating the upstream emissions due to CO2 removal from the raw gas and further (page 34) explained these emissions need to be estimated only if the average CO2 content of the raw gas is higher than 5% on volume basis, which applies to the gas used by this project activity. The DOE is requested to clarify how it assessed the information provided by the project participants in the PDD. Please refer to the VVS-PA paragraph 337.
1: The monitoring report (section C) shall provide line diagram (graphical schemes) showing all relevant monitoring points as required by the PS-PA ver. 03.0 paragraph 258.
2: The submitted emission reduction (workbooks “Ammonia-I Feed RLNG” and “Ammonia-I Feed RLNG”) Cells C6 on both workbooks show calculated losses (volume to mass conversion for the NG). Please submit a revised emission reduction sheet (traceable) which shows how these losses were calculated. In doing so, the DOE shall confirm the appropriateness of the method applied to correct the measured volume into the equivalent mass for the consumed of NG (column G of the above workbooks) considering that the method has resulted to negative project emissions in workbook PE-Feed. Please provide a justification if it is considered that the applied method is appropriate. please refer to the applied methodology (page 9 -equation 11) and the VVS-PA paragraph 374 (c).
3: The DOE (VR, page 11) confirms the supply and implementation of feed switchover based on a letter from GAIL (reference 05) “the Proof of start date, communication between GAIL & IFFCO related to the supply of RLNG dated 22/04/2006”. The DOE shall report how it verified the starting date of operation for each site (reported in the monitoring report as July 2006 (Phulpur I) and May 2006 (Phulpur II)). Please refer to the VVS-PA ver. 03.0 paragraph 356.
4: The registered monitoring plan (PDD page 52) has listed monitoring of the parameter “Quantity of fuel type i consumed in the steam generator used for utility steam in each year (FCutility,steam,i,y) and further the submitted emission reduction excel sheet (workbook “Fuel consumed in utility) reported values for two fuels (NG and coal) used in boiler Nos. 1,2,&3. However, the monitoring report does not list this parameter, including how it was monitored. In doing so, please ensure the parameter naming is consistent between the registered PDD and the monitoring report
5: The DOE is requested to provide information on how the following parameters have been verified in compliance with the applied methodology:
i. Production of Urea in each year is based on the plant records (daily Urea production through DCS which is countersigned by Shift in charge) and cross-checked with the Urea stock logbook (which was verified by external entity, Fertilisers Industry Coordination Committee (FICC)). The methodology requires this parameter is calculated based on the ammonia input to the urea plant; and the measurement results should be cross-checked with the periodic urea stock verification carried out by external agencies. However, it is not clear if the plant records data is based on the ammonia input, and if so, how the data was aggregated as reported in workbook “Urea production”.
ii. For the parameter “Carbon content, expressed as weight fraction, of NG/LNG used as feed during year” (Tonnes of carbon/tonnes of NG/LNG), the DOE (VR, page 22) has verified that the values are calculated as per the lab analysis done at the Phulpur plant. However, the applied methodology (page 20) requires that these values are derived from the feed composition report provided by the feed supplier from a certified laboratory.
6: The registered PDD (Section B.6.2) has excluded the parameters “CO2 content in the raw natural gas stream” and “Density of the CO2 gas” applied for calculating the upstream emissions due to CO2 removal from the raw gas and further (page 34) explained these emissions need to be estimated only if the average CO2 content of the raw gas is higher than 5% on volume basis, which applies to the gas used by this project activity. The DOE is requested to clarify how it assessed the information provided by the project participants in the PDD. Please refer to the VVS-PA paragraph 337.

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