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	Tecamac – EcoMethane Landfill Gas to Energy Project (2271)
DOE that requested for issuance and date of request	TÜV NORD (27 Jul 20)
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 verified the calibration of the following thermocouples in line with paragraphs 366 and 368 of VVS-PA: (a)    It was observed that the thermocouples with the following serial numbers for monitoring of parameter Tflare (Temperature in the exhaust gas of the flare) were used beyond the validity of the calibration: 690533/2-2; 685169-1; 696125/4-2; 686675-5; HM00001007/2-3; HM00008728/1-2. The PP has applied the maximum permissible error of the equipment as the result of the factory calibration was found within the maximum permissible error. The DOE stated that no delayed calibration is possible because the thermocouples are replaced instead of being calibrated. The DOE is requested to substantiate: (i)  How provision from paragraph 368 of VVS-PA has been met which requires the DOE to request the PP to conduct the required calibration prior to finalizing the verification;  (ii) How it confirmed that the result of the delayed calibration did not identify an error beyond the maximum permissible error of the instrument as there was no delayed calibration conducted (page 59 of verification report); (b)    It was observed that the thermocouples with the following serial numbers for monitoring of parameter Tcomb (Temperature of combustion) were used beyond the validity of the calibration: 690533/2-1; 685139-1; 696125/4-1; 686675-6; HM00001007/2-2; 18-0208-2A. As shown from the spreadsheets, the PP has applied the maximum permissible error of the equipment. The monitoring report (page 15) shows that the deviation from the calibration certificate is within the maximum permissible error. The DOE is requested to explain or substantiate: (i) How the provision in paragraph 366 of VVS-PA has been correctly applied as there is no information on when the delayed calibration of these thermocouples was conducted. For example: Calibration of thermocouple with SN 690533/2-1 expired on 11/11/2010 and the thermocouple was used until 12/11/2010. The deviation from the calibration certificate of this equipment as per the monitoring report is -0.39%, and the PP applied the maximum permissible error of the equipment (0.75%) during 11/11/2010 – 12/11/2010. However, there is no information when the delayed calibration which result is -0.39% was conducted in order to apply the provision in paragraph 366 of VVS-PA; (ii) If the thermocouples were not recalibrated, how provision from paragraph 368 of VVS-PA has been met which requires the DOE to request the PP to conduct the required calibration prior to finalizing the verification.   Please refer to paragraphs 366 and 368 of VVS-PA. 2) The DOE is requested to explain how it verified the determination of the default value for flare efficiency of the enclosed flare in line with the applied “Tool to determine Project emissions from flaring gases containing methane”. The ER sheets show and indicate instances where the flare operation did not conform to the manufacturer specification, but the default value of 90% is applied. To use 90% default value, the aforementioned tool requires that the manufacturer’s specifications on proper operation of the flare are met continuously during the hour h in addition to the temperature in the exhaust gas of the flare (Tflare) being above 500 °C for more than 40 minutes during the hour h. The following are the examples of these instances: 22/04/2015 18:15; 22/03/2011 22:30; 13/04/2012 17:30; 18/04/2017 12:00. Please refer to paragraph 373(c) of VVS-PA.
Date	17 Sep 21