Info Report Check
Submission incomplete:
1: Paragraphs 365-369 of VVS-PA:
(a) As per the information on page 35 of the verification report, there are penalty periods due to calibration gaps of the thermocouples for parameter Tflare with serial numbers 685169-1, 686675-5, HM00001007/2-3, 690553/2-2 and 696125/4-2 and maximum permissible error from the manufacturer was deducted from measured data, since it is more conservative. However, there is no information on when the delayed calibration of those thermocouples was conducted. For example: Calibration of thermocouple with SN 685196-1 expired on 05/06/2010 and the thermocouple was used until 12/11/2010. The verification report in page 35 states that the error in the calibration certificate for this equipment is -0.34%. However, there is no information when the delayed calibration which result is -0.34% was conducted in order to apply the provision in paragraph 366 of VVS-PA;
(b) The calibration of thermocouple for parameter Tflare with serial number HM00008728/1-2 was valid until 10/11/2017, however the equipment was used until 11/11/2017;
(c) As per the information on page 35 of the verification report, in the case of the electricity meter for parameter ECPJ,y, no calibration was carried out during the monitoring period as the calibration was outside the control of the PP. The DOE is requested to explain why it did not follow the applicable requirements related to post-registration changes in line with requirement in paragraph 369 of VVS-PA;
(d) There is no information on calibration of equipment measuring parameter Tcombust which is used to determine whether manufacturer specification for flaring is met.

2: Paragraph 374(a) of VVS-PA:
There are missing data outside the temporary deviation period as evidenced from ER sheets. However, there is no explanation provided by the DOE. For example: 1 - 7 December 2013; 1 - 8 December 2015.