I-DEV0416: Request for deviation for missing total biogas data

1. The project activity started operation with biogas collection from July 2009. Installation of the total biogas meter FT-80 was delayed and it was first installed in November 2009, however, the meter encountered an initial technical problem and did not produce a normal data until the end of the monitoring period, i.e. 30/06/2010.
2. The meter FT-80 was sent back to the supplier in the USA and after thorogh testing and re-calibration, the meter was re-installed and started presenting a normal data after the end of the monitoring period.
3. The installation of gas flow meters follows the requirement of the applied methodology as follows. As per AM0013 Version 02 applied to the project activity, emission reductions are ex-post determined by the actual amount of methane destructed monitored at the inlet of boilers by the gas flow meter FT-76. Biogas collected and destructed by the flare system is monitored by the gas flow meter FT-01 but it is not counted for the emission reductions according to AM0013 Version 02 and the total biogas volume monitored by the meter FT-80 is used only for a purpose to cross-check the sum of the biogas volume monitored by gas flow meters FT-01 and FT-76. The location of the meters is as described below.

4. The project participant requests the deviation to be accepted because the emission reductions are determined based on the biogas flow to the boilers that is directly measured by the meter FT-76.
5. The project biogas recovery system and the boilers and the flare system are directly connected by the gas pipes and there is little room for the total biogas measurement at FT-80 to deviate from the sum of biogas measured at FT-01 and FT-76.
6. In the absence of the total biogas volume directly measured by FT-80, the sum of biogas volume measured by the meters FT-01 and FT-76 can be cross-checked with the volume calculated from the COD removal by the project digester that is also directly measured and/or an energy balance analysis of the total energy required for production process, energy efficiency of the boilers and the energy inputs by fossil fuels.
7. Consistency of data can also be checked by comparison with the data after repairing and re-installation of the meter FT-80 that will be reported during the subsequent monitoring periods.

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The deviation requested does not require a revision of the monitoring plan or the changes from the project activity as described in the registered PDD.
The deviation is caused by delayed installation and initial technical problem of the total biogas meter that is for cross checking and has no direct impact to the emission reductions if the other parameters are properly monitored. The status of the project implementation deviated from the requirements of the registered monitoring plan has been resolved by 08/10/2010 and thereafter the monitoring will be implemented in accordance with the requirements of the monitoring plan. The problem was unique during the initial period of the project operation and it does not produce a permanent change to the project activity described in the registered PDD.
LRQA verification team conducted on site assessment and confirmed that the project digester is directly connected by gas pipes with the enclosed flare system and the industry boilers that supply process steam to the ethanol factory and there is no other supply source of gas that can be mixed through the gas supply line. Therefore it was verified that there is little room for the total biogas measurement at FT-80 to deviate from the sum of biogas measured at FT-01 and FT-76.
LRQA also referred to the similar requests made on the projects ref # 0675, 1153, and 1993 that the justification was provided in a similar line and have been accepted by the CDM Executive Board.

The deviation proposed only relates with the total biogas volume that is not a parameter used for emission reductions calculation. As the parameters for emission reductions calculation were monitored and reported without problem during the monitoring period, the deviation does not affect the emission reductions calculation.