19:11 16 Aug 24
Registration Request for Review Form
CDM project activity/programme of activities registration request review form (CDM-REGR-FORM) (Version 03.0) |
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Reference number of the proposed CDM project activity/programme of activities (PoA) submitted for registration | 9996 |
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Title of the proposed CDM project activity/PoA submitted for registration | Electricity and heat Generating through a cogeneration system in Gerencia Refinería Barrancabermeja (GRB), Ecopetrol, S.A. |
Please indicate, in accordance with paragraphs 37 and 40 of the CDM modalities and procedures, which validation requirement(s) may require review. A list of requirements is provided below. Please provide reasons in support of the request for review. Including any supporting documentation. | |
The following are requirements derived from paragraph 37 of the CDM modalities and procedures: | |
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The following are requirements derived from paragraph 40 of the CDM modalities and procedures: | |
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Additional information | |
1) The validation report page 18 indicates that the gas turbine TG-2961 is not a cogeneration unit and the existing cogeneration units (i.e. TG-951/2, TG901/2/3) were out of service since 2005 and 2009 respecitvely, whereas in the PDD page 20, it is stated that "Ecopetrol has only a cogeneration system (TG-2961), ....". The PP/DOE is requested to clarify the inconsistency and elaborate the reason that the existing cogeneration units (TG-951/2, TG901/2/3) were out of service, as well as the fate of these units in the project scenario. If these units are not scrapped, the PP/DOE shall explain why repowering these units are not considered as the baseline scenario. Please refer to PS v7 paragraph 36, 38, VVS v7 paragraph 65 and 69. 2) The AM0014 v4 requires that "the methodology can only claim reductions from only that fraction of displaced electricity from the baseline dedicated power plants, for which it can be demonstrated that project activity led to reduction in generation of baseline dedicated power plant(s)". The DOE has indicated that the replaced steam turbines TG-2401/2/3 (3*10MW) was operated at 17.75MW to 22.38MW during 2011-2013, which is lower than the installed capacity of project cogeneration unit (TG-5100 with 35MW). As per the PDD, the baseline emission from dedicated baselinen power units is calculated as BEelec,fossil fuel = CEO*BEFelec,fossil fuel, CEO is electricity generation metered at TG5100 and BEFelec,fossil fuel is calculated based on three years arithmetic average of TG-2401/2/3. The PP/DOE is requested to clarify how the baseline emissions from electricity generation is calculated as per aforementioned requirement. In particular, (1) how the claimed emission reductions calculated from metered CEO that exceeding the historical generation represents the reduced generation of baseline dedicated power plant(s) TG2401/2/3, but not reduced generation of other connected existing dedicated power plant(s) like TG-2951/2/3 or TG-2961; (2) the appropriateness of using arithmetic average rather than weighted average. Please refer to PS v7 paragraph 36, 38, VVS v7 paragraph 65 and 69, VVS v7 paragraph 101, 103-105. 3) The methodology requires the monitoring of cogeneration electricity/heat supplied to the industrial plant, however as per the monitoring plan in page 38-40 of the PDD, the monitoring of electricity/heat would be conducted at the supply side, i.e. exit of steam generator and electricity generator, rather than the inlet of the recipient units. The PP/DOE is requested to ensure that the monitoring of electricity and heat supplied to the industrial plant will not be overestimated due to the location of the metering point. Please refer to VVS v7 paragraph 139(a)(ii). |
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Date | 15 Oct 15 |
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