CDM project activity/programme of activities issuance request review form (CDM-ISSR-FORM) (Version 03.0)

Project title of the project activity or programme of activities (PoA) for which issuance is requested	Landfill Gas Recovery and Flaring Project in the El Verde Landfill, León. (3378)
DOE that requested for issuance and date of request	TÜV NORD (12 Jul 19)
Please indicate, in accordance with paragraphs 65 of the CDM modalities and procedures, for which reason(s) you request review
Incompetence
Please indicate reasons for the request for review
1) The DOE is requested to explain how it concluded that there is no delayed calibration for thermocouples at the exhaust of the flare for measurement of parameter TEG,m.  As per the monitoring report and the verification report, the last calibration was on 24/02/2017 and it was valid until 21/11/2018, whereas the monitoring period is until 31/12/2018. Refer to paragraphs 365 to 368 of VVS-PA. Please refer to paragraphs 365 to 368 of VVS-PA.. 2) The DOE is requested to explain how it has verified the emission reductions calculation in line with the applied tools, in particular:   (a)  The application of Option A to determine the flow of LFG to flare: As per the tool “Tool to determine mass flow rate of greenhouse gas in a gaseous stream”, version 03.0, for application of Option A for flow measurement on a dry basis, it has to be demonstrated that temperature of the gaseous stream (Tt) is less than 60 degree C. The PP has applied Option A in the calculation when Tt is less than 60 degree C and considered the flow as zero when Tt is more than 60 degree C. However, it is observed that Option A for flow measurement was applied when Tt equals 60 degree C. The DOE is requested to explain how the determination of the flow using Option A is in accordance with the applied tool. Refer to paragraph 373 (c) of VVS-PA.   (a)  The determination of flare efficiency as per option B.2 of the tool “Project emissions from flaring” (Version 02.0.0): (i)  As shown in the monthly emission reductions spreadsheet, the flare efficiency is determined/calculated every two minutes instead of each minute which is required by the monitoring plan and the applied tool. Furthermore, the required monitored parameters by the tool to determine the flare efficiency, i.e. Volumetric flow of the residual gas on a dry basis at reference conditions in the minute m, Mass flow of the residual gas on a dry basis at reference conditions in the minute m, Volumetric fraction of O2 in the exhaust gas on a dry basis at reference conditions in the minute m, Concentration of methane in the exhaust gas of the flare on a dry basis at reference conditions in the minute m, Mass flow of methane in the residual gaseous stream in the minute m, Volumetric fraction of methane in the residual gas on a dry basis in the minute m, are also not averaged on a minute basis as required by the tool; (ii)  In the corresponding cells in the monthly spreadsheet which calculate the flare efficiency (e.g. cells in column DR of sheet “ER calculation” for October 2017), the PP included a provision that if the calculated efficiency is less than 0.9, an efficiency of 0.9 will be used. This provision is not in line with equation (2) of the tool; (iii) It is not clear how parameter Flamem (Flame detection of flare in the minute m) has been determined as per the applied tool which requires the detection of flame. In the verification report, the DOE indicated that the parameter is linked with parameter Opflare,h which detects whether the flame is on or off (page 79). However, as shown in the emission reductions spreadsheets, the parameter Opflare,h, is determined based on the temperature in the exhaust gas of the enclosed flare in minute m (TEG,m), i.e. when TEG,m is larger than 500 degree C, the flame is considered on.   (c) The emission reduction spreadsheet for December 2018 has not been submitted and the emission reduction spreadsheet for November 2018 cannot be opened. Please refer to paragraph 373 (c) of VVS-PA..
Date	25 Mar 20