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	Quimobásicos HFC Recovery and Decomposition Project (0151)
DOE that requested for issuance and date of request	TUV RHEIN (22 Aug 12)
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) According to the verification report, the reactor was replaced in June 2007. The new reactor operates at a significantly different design pressure and temperature and has slightly different physical dimensions. It is not clear why such a replacement is regarded as a „like-to-like replacement“ by the DOE. In the absence of the incentives from the CDM, the new reactor may be operated at its new design pressure and temperature. This could potentially impact the HFC-23 generation. In such case, the use of the historical waste generation rate may not be appropriate. 2) The DOE does not confirm since which point in time it has assessed that no other retrofit or replacement occurred in any key component of the plant. The DOE is kindly requested to confirm that no other retrofits or replacements occurred since the start of the three year period used to establish the historical waste generation rate w.
Date	12 Nov 12