I-DEV0387: Deviation about measure of total landfill gas flow

This deviation (1120 / Jiaozishan Landfill Gas Recovery and Utilisation Project) refers to 2 monitoring periods: The 1st one covering the period from 30/11/2007 to 31/10/2008 (one full monitoring period for which monitoring report has been already uploaded to UNFCCC website http://cdm.unfccc.int/Projects/DB/SGS-UKL1178631263.99/view and the remaining period from 01/11/2008 to 03/09/2010 makes part of the 2nd monitoring period (end date of this 2nd monitoring period has not been determined yet by the PPs).
Project activity collects landfill gas and uses it for producing hot water and flaring. According to ACM0001 (version 5) and the monitoring plan of the registered PDD, flow meters should be installed to monitor the total quantity of landfill gas generated (LFGtotal,y), and quantity of landfill gas fed to each utilization or destruction facilities (in the case of this project, LFGflare,y, and LFGthermal,y).
During the current monitoring period (30/11/2007 to 31/10/2008) and the remaining period from 01/11/2008 to 03/09/2010 only hot water boilers were built and in operation. All the collected landfill gas was supplied to the boilers. Since there is only one permanent pipe line between the collecting system and the hot water boilers, only one flow meter was installed. This flow meter serves as flow meters for both LFGtotal,y and LFGthermal,y. This approach slightly deviates from the MP, but is acceptable considering :

 There is only one permanent pipe line between the collecting system and the hot water boilers
 According to ACM0001 / Version 05, page number 6 and 7 “in the case where LFG is just flared, one flow meter can be used provided that the meter used is calibrated periodically by an officially accredited entity.” During the current monitoring period (30/11/2007 to 31/10/2008) and the remaining period from 01/11/2008 to 03/09/2010, LFG is used only for boilers.
 The flow meter has been calibrated by a qualified third party.

Please note that, in order to install the flare as deccribed in the PDD, a few tests have been carried out with a small flare prototype from 1st October 2008 to 31st October 2008 as the project owner has no experience with flaring. The flare was fed through a separate auxiliary pipe before the flow meter of LFGthermal, y. (please see the figure below). However, the emission reductions from flaring were not claimed. Therefore, this has no impact on the emission reductions.

Please see Enclosure 1.

The deviation affects the period, as mentioned above, from 30/11/2007 to 03/09/2010. September 03, 2010 is the day on which the flare fully entered into operation.
At present, the flare system has been implemented, and the Project Owner has installed flow meters for LFGtotal,y , LFGflare,y, and LFGthermal,y as required by the monitoring plan in the registered PDD.

As per the Monitoring plan of the PDD, the LFGtotal, y is equal to sum of LFGflare and LFGthermal. As indicated by the PP and verified by DOE during on site audit that due to insufficient gas production and inexperienced PP, the flaring equipment has not been used until 03/09/2010 as per requirements of PDD MP. Hence, LFGflare is equal to zero and LFGtotal is equal to LFGthermal.
Since, as per requirement of registered PDD Monitoring plan and methodology the PP did not install the LFGtotal flow meter and LFGflare (due to insufficient gas production) on site and same has been verified by audit team during onsite audit. Hence theoretically, LFGthermal is equal to LFGTotal and same has been used by PP to calculate the emission reduction which is conservative because this meter was also calibrated periodically by an officially accredited third party entity. Calibration details are listed below:
• First time Flow meter calibration certificate (LFG to boilers) (Calibrated by Nanjing Institute of Measurements and Testing Technology on 20/11/2007).
• Second time Flow meter calibration certificate (LFG to boilers) (Calibrated by Nanjing Institute of Measurements and Testing Technology on 18/11/2008).
• Third time Flow meter calibration certificate (LFG to boilers) (Calibrated by Nanjing Institute of Measurements and Testing Technology on 13/04/2009).
• Fourth time Flow meter calibration certificate (LFG to boilers) (Calibrated by Nanjing Institute of Measurements and Testing Technology on 02/04/2010).
Also, as indicated above by PP and according to methodology (ACM0001 / version 05) “In the case where LFG is just flared, one flow meter can be used provided that the meter used is calibrated periodically by an officially accredited entity.” Hence, based on above findings, the DOE thinks that the deviation does not require a revision of monitoring plan or the changes from the project activity as described in the registered project design document.
The monitoring plan of the registered PDD has covered the monitoring of all the relevant parameters, and is in compliance with the methodology. Therefore, the deviation does not require a revision of monitoring plan.

The deviation to measure the LFGtotal, y using LFGthermal flow meter (LFGtotal= LFGflare (0) + LFGthemal) instead of the total flow meter has no impact on the estimation of the Emission Reductions for the period from 30/11/2007 to 03/09/2010. Also, there is no difference between the emission reductions claimed with or without an overall flow meter. This is because the meter aims to check LFGtotal against LFGflare + LFGthermal. Furthermore, accordng to the most recent version of the methodology ACM0001, Version 11, page 15 “In the case where LFG is just flared, one flow meter for each flare can be used provided that these meters used are calibrated periodically by an officially accredited entity” Hence, in the opinion of the DOE the same can be applied for LFG combusted in boilers.
In this case, the flow meter was calibrated periodically as per monitoring plan requirement (annual calibration) by an officially accredited entity (please see above for details) and hence reading recorded by this meter can be trusted and verified by the audit team during on site audit for this monitoring period and for extended period audit team will check in next periodic verification. Therefore, the conservativeness check of comparing measured and calculated values for LFGtotal, y is not necessary or possible, considering the flare was not in use. Furthermore, during onsite audit for this first monitoring period the monitoring instruments have been correctly installed and calibrated periodically (please see above for details).
Based on above considerations this deviation has no impact on the estimates of the emission reductions for the project.