Info Report Check
Submission incomplete:
1: The PP/DOE are requested to explain in the PDD the methodological choices for the calculation of the baseline, project emissions, leakage and emission reductions as per PS version 05.0 paragraphs 50 and 51.
a) The applied version of the "Project Emissions form Flaring" tool states, on page 3, that "For enclosed flares that are defined as low height flares, the flare efficiency in the minute m (...) shall be adjusted, as a conservative approach, by subtracting 0.1 from the efficiency as determined in Options A or B. For example, the default value applied should be 80%, rather than 90%, and if for example the measured value was 99%, then the value to be used shall correspond to 89%". A 90% default value of flare efficiency is applied by the PP, without indicating whether the flare is defined as a low height flare or not;

b) To determine the value of the parameter "EFequipment ("Leakage rate for fugitive emissions from the compression technology as per specification from the compressor manufacturer in kg/hour/compressor"), Appendix 1 from the methodology AMS-III.H v16.0 (quoted by AMS-III.AQ) states that if no default value from the technology provider is available, an approach applying emission factors from the 1995 Protocol for Equipment Leak Emission Estimates, published by EPA, shall be used. The PDD, on page 32, states that "If no default value from the technology provider is available, the approach below shall be used" without explaining which is the approach to be used.

2: The DOE is requested to describe how it has assessed the application of the equations and parameters for the calculation of emission reductions as per VVS version 2 paragraphs 97 and 99 (d) (e).
a) The applied version of the "Project Emissions form Flaring" tool states, on page 3, that "For enclosed flares that are defined as low height flares, the flare efficiency in the minute m (...) shall be adjusted, as a conservative approach, by subtracting 0.1 from the efficiency as determined in Options A or B. For example, the default value applied should be 80%, rather than 90%, and if for example the measured value was 99%, then the value to be used shall correspond to 89%". The DOE has validated that the project applies a 90% default value of flare efficiency, however it has not validated whether the flare is defined as a low height flare or not;

b) To determine the value of the parameter "EFequipment ("Leakage rate for fugitive emissions from the compression technology as per specification from the compressor manufacturer in kg/hour/compressor"), Appendix 1 from the methodology AMS-III.H v16.0 (quoted by AMS-III.AQ) states that if no default value from the technology provider is available, an approach applying emission factors from the 1995 Protocol for Equipment Leak Emission Estimates, published by EPA, shall be used. The DOE is required to validate how this approach was assessed since the PDD, on page 32, states that "If no default value from the technology provider is available, the approach below shall be used" without explaining which is the approach to be used.

3: The DOE is requested to describe how it has validated the compliance of the monitoring plan with the applied methodology(ies) as per VVS version 2 paragraph 132 (a).
The PDD states that the monitoring parameters to determine the project emissions from compressor leaks ("Tequipment" and "EFequipement") will be determined once the compression and upgrading unit (PSA) is installed in the project activity and, therefore, these 2 parameters were not listed in section B.7.2 from the PDD. However, there is no FAR raised by the DOE to check the implementation status of Phase II, which may include the need to add the two above mentioned parameters in the monitoring plan through a post-registration change (permanent changes form the registered monitoring plan).