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	Tunlan Coal Mine Methane Utilization Project, Shanxi Province, People’s Republic of China (3067)
DOE that requested for issuance and date of request	TÜV NORD (05 Oct 15)
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 has verified the parameter MMFL (Methane sent to flares) being in accordance with the registered monitoring plan which requires continuous monitoring of the parameter. It is reported that during the period of 08/10/2014 to 10/10/2014, the T gas No. 1 flare and T gas No. 3 flare were taken out for calibration. As mentioned in the verification report, during this period the values for T gas No. 1 flare and T gas No. 3 flare were considered as zero degree Celsius and this is conservative. The DOE is requested to explain how this approach can be considered conservative, since as per the gas law formula used to normalize the flow, assuming lower temperature would lead to higher flow hence higher baseline emissions than verified and reported. Furthermore, the DOE is also requested to explain why this is not considered as deviation to the registered monitoring plan as the monitoring plan requires continuous monitoring of the parameter. Please refer to VVS version 09.0 paragraphs 389 and 402(a)..
Date	12 May 16