I-DEV0403: The parameter FGT was not monitored according to the RMP (presented together with this deviation) during period of time (4 months, 01/06/2009 to 30/09/2009) and not in compliance with the methodology ACM0007 version 1.

NOTE: When inseting the information for this deviation we encountered difficulties with the formatting of data sets and inserted images. Please refer to (Annex-1) PDF representation of the request for deviation.

The project activity (UN ref. number 1482) starts its crediting period on 31/05/2009. At that time the project had installed on site just one gas meter to measure the whole consumption of natural gas in the facilities. The cited meter, a Flobos 407 (see M1 in diagram below in page 3 or full size in reference 30), was the one identified in the registered PDD, section B.7.1. (pag. 39&40) parameters FGT and FST. The meter M1 is located at the gas entrance to the plant and is used for invoicing purposes by the gas provider (Cammuzi). Assessing the Monitoring Plan available in the registered PDD, it was found that it does not comply with the methodology applicable to the project (ACM0007 version 1).
According with the methodology (ACM0007 version 1) the parameters FGT and FST have to be monitored independently; therefore the monitoring system implemented originally by the project and the monitoring plan in the registered PDD did not satisfy the methodology requirement. For this reason during September 2009 independent meters were installed in the plant to monitor FGT and FST (M2 to M6 in diagram below). Based on the previous background the project is presenting a Request for Deviation from 31/05/2009 to 30/09/2009 (period monitored only with one gas meter M1), and a Revision of the Monitoring Plan.

As per EB 49 annex 26 and EB 43 para 57 “The Board agreed that for cases where a delayed installation/operation of a monitoring equipment is observed, a request for deviation can be applied for a period covering the monitoring period under verification until the start of the operation of the equipment. The DOE shall clearly indicate in their submission the reasons for the delays and the expected start date of the operation of the equipment.”. The new meters M2 to M6 were installed during September and calibrated on 21th and 22nd (ref 33), however since they operated only for one week on September 2009, the PP preferred to start the monitoring as per the RMP from 01/10/2009. The situation was reviewed and found reasonable, because the crosschecking information (gas invoices) are issued monthly. Additionally as it is explained below the Deviation is conservative because the parameter FGT is over valuated, therefore PE are over valuated and by consequence the ER are reduced.

The following diagram summarizes the project situation for its first monitoring period.


The following paragraphs explain the deviation of the project and provide the corresponding verification means followed to ensure that the deviation does not threaten the conservativeness and accuracy principles.
1. The PP had installed just one gas meter (M1) to measure all the gas consumed in the plant (see next point). This situation did not allow quantifying the parameter FGT and FST separately as requested by the methodology.
2. At the project facility natural gas is consumed in 4 parts:
2.1. Source 1: Gas turbines, it corresponds to the gas burned to operate the gas turbines, and it is included in the parameter FGT.
2.2. Source 2: Duct Burners at the HRSG (Heat Recovery Steam Generators), it corresponds to the additional natural gas burned to add supplementary energy to the exhaust combustion gases from each gas turbine to raise the steam generation to be used in the Steam Turbines. The consumption of this item corresponds to the parameter FST.
2.3. Source 3: Natural gas warming station. The plant has a station (installed before the project beginning) to warm up the natural gas before being burned in the gas turbines. It was verified against the turbines provider (General Electric) process specification (ref 7) that natural gas requires to be at 28°C for burning to raise the steam generation to be used in the Steam Turbines. The daily records of gas (ref 42) shows that the gas is received in the plant around 8°C during cold months.
The PP did not explain in the PDD that part of the gas consumed in the gas turbines corresponded to the gas used in the warming process. However it was considered in FChist because the measurements were done with the only gas meter existing in the plant at that time (meter M1).
As it is explained in the RMP (presented together with this request for deviation), the gas used in the warming station from October 2009 is being measured separately with the meter M6 and it is included in the parameter FGT (together with the measurements done by the new gas turbine meters M2&M3).
2.4. Source 4: Warming boiler. The plant has installed a boiler for facilities warming purposes (central heating). Therefore the natural gas used for facilities heating is out of the project boundaries. As per the invoice (ref 29) and the boiler plate (ref 46, pics 17&18) it was verified that the boiler was bought on November 2007, therefore the gas consumed by this item was not included in the historical data (FChist, 1999, 2000, 2001 2005 & 2006) measured with the meter M1. As it was verified in the past (before 2007) the plant consumed natural gas only for electricity generation, therefore until 2006 M1 accounted only gas consumed by the gas turbines. In this way, it was verified that the parameter EFoc was correctly calculated without considering the gas consumed by the heating boiler.

At the beginning of the first monitoring period (until September 2009) the plant had only the meter M1; it recorded the gas consumption of the four cited sources. To solve this problem the Project Participant (PP) installed separate gas meters (M2 to M6) to quantify the gas consumed in sources 1 to 3 (items that belong to the project boundaries), for this reason a Revision of the Monitoring Plan (RMP) is being presented together with this request for deviation. Please see in the following drawing the gas consumption sources and the meters related.




The new meters (M2 to M6) were installed during September 2009 (ref 20) and were calibrated on 18&19/September/2009 (ref 33). Therefore from 31/05/2009 until 19/09/2009 the PP had not implemented a monitoring system in compliance with ACM0007 version 1.
In order to simplify the deviation, the requested period deviated is 31/05/2009 until 30/09/2009. From the CDM point of view, it is considered a conservative approach because M1 includes the gas consumed in the heating boiler (item 4), which lead to increase the project emissions and to reduce the emission reductions.
It was verified that during the cited deviation period (31/05/2009 until 30/09/2009) and even until June 2010, Energía del Sur was not authorized to burn additional gas. For this reason the plant operated the combined cycle only using the exhausted combustion gases from the gas turbines, therefore FST = 0. SGS verified on site the dossier of documentation presented by EDS on 01/05/2010 (ref. 44&45) to the gas provider (Cammuzy) to obtain the final approval to burn additional gas. The cited documents (ref 44&45) were approved on 10/06/2010, receiving in the same document the official stamp.
According with the verified information, it can be assured that for the period from 31/05/2009 to 30/09/2009 FST was equal to zero.
As per the verified information the parameter FGT was equal to 39,962.211 Nm3 during the period 01/06/2009 until 30/09/2009. The PP is not going to claim the Emissions Reductions of the day 31/05/2009, all calculation will be done from 01/06/2009. The fact of excluding ER of 31/05/2009 is conservative because, that day the plant operated normally i.e. generated electricity working under its combined cycle modality (ref 42, daily plant operation report), but the ER are not going to be claimed by the PP (please see published MR, page 6 in the following link http://cdm.unfccc.int/UserManagement/FileStorage/R71CSD3PXTBVIK49ZNYM5OWAE0QHJG ).
Therefore, the natural gas consumption was verified having this issue into consideration.
The value was obtained from the meter M1 and was crosschecked against the gas provider invoices (Cammuzi, ref. 21). The monthly natural gas consumption recorded by M1 is summarized in the following table, it corresponds to the records from the 00:00 hrs of the first day of the month until 24:00 hrs of the last day of the month.
Month Monthly consumption recorded by meters (Nm3) – Ref 54
June 2009 12,624,276
July 2009 9,479,499
August 2009 8,538,007
September 2009 9,320,429
Total 39,962.211

Therefore, the FGT during the deviated period (01/06/2009 – 30/09/2009) is equal to 39,962.211 Nm3. It is important to note that as it is stated in the RMP and its corresponding Validation report (that are being presented together with this Request for Deviation), for the ER calculations the measured values of natural gas consumption will be corrected (multiplied by 1.00025, equivalent to 0.025%) because the accuracy new meters installed (M2 to M6) is 0.075% while registered PDD stated 0.1%.

As it was previously described, the PP is presenting at the same time a Request for Deviation and a Revised Monitoring Plan. The Revised Monitoring Plan is required because the monitoring plan available at the registered PDD does not allow monitoring the project as per ACM0007 version 1 requirements.

Previously was showed and verified that for the deviated period (31/05/2009 to 30/09/2009) the parameter FGT was measured with the meter M1. The meter is located at the entrance of the plant and is used by the gas provider for invoicing purposes. It was verified as well that during the same period FST = 0, then PESTy = 0.
Therefore M1 registered the full consumption of natural gas at Energia del Sur facility, it means that counted the gas used in gas turbine (source 1), gas warming station (source 3) and heating boiler (source 4). As previously explained and verified sources 1 and 3 correspond to the parameter FGT, while source 4 is out of the project boundary.

The parameter FGT is used in the following equation of ACM0007 version 1:

PEGTy = ΣFGTi,y *COEFi (ACM007, ver 1, equation 2)

Then, knowing that PEy = PEGTy + PESTy (ACM007, ver 1, equation 2) and that PESTy = 0, lead to have PEy = PEGTy . Finally in the presented request for deviation FGT is over valuated because includes gas consumption that is out of the project boundary, then PEGTy and PE y are over valuated as well.

Finally since ERy = BEy – PEy – Ly, PEy is over valuated and BEy is not affected by the deviation, the resulting emission reductions claimed are less than the actual reductions that occurred.