M-DEV0394: Deviation from methodology AM0009 (V.04) in order to include emissions from CNG transportation by trailer after the processing facility in project emissions

AM0009 ver. 4: Recovery and utilization of gas from oil wells that would otherwise be flared or vented

The request for deviation is about including further sources of project emissions in the approved methodology AM0009 (Version.04) “Recovery and utilization of gas from oil wells that would otherwise be flared”.

AM0009 (V.04) defines the following sources of project emissions to be accounted:
a)CO2 emissions due to consumption of fossil fuels for the recovery, pre-treatment, transportation, and, if applicable, compression of the recovered gas up to the points A and C in Figure 2;
b)CO2 emissions due to the use of electricity for the recovery, pre-treatment, transportation, and, if applicable, compression of the recovered gas up to the points A and C in Figure 2.

The proposed project activity is to recover associated gas from scattered oil wells, which would otherwise be flared. After pre-treatment (gas-liquid separation and desulphurization in some cases), compression and dehydration, the separated gas will eventually be compressed into CNG and then transported via trailer to Tazhong Gas Unload Station (TGUS) where it will be decompressed into dry gas and fed into Ta-lun Gas Pipeline to end users. The baseline activity and the project activity are schematically illustrated in Figure A and Figure B attached to this request for deviation (annex 1).

In the methodology, the process gas after point A is directly exported into pipeline, and there is no emission due to transportation after point A. However, as showed in Figure B, the proposed project activity includes transportation by trailer of CNG from the gas processing facilities to the unload station. Since the emission from diesel consumption of CNG trailers, which is behind of point A do not occur in the baseline scenario, it is DNV opinion that these emissions should be included in the project emissions as a conservative approach.
This is in accordance with paragraph 77 of the VVM (version 01.2) which requires DOEs to identify greenhouse gas emissions occurring as a result of the implementation of the proposed CDM project activity which are expected to contribute more than 1% of the overall expected average annual emissions reductions and which are not addressed by the applied methodology.
The project participants are therefore requesting a deviation from AM0009 (Version 04) to account for project emissions from CNG transportation by trailer after point A.

According to “Clarification for project participants on when to request a revision, clarification to an approved methodology or deviation” (EB 31, Annex 12), a request for deviation is suitable for situations where a change in the procedures for the estimation of emissions or monitoring procedures is required due to a change in the conditions, circumstances or nature of a registered project activity. The deviation shall be project specific and shall not deviate from the methodology, such that a revision would be required.
The proposed deviation changes the procedures for the estimation of emissions by including further project emissions for which the “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion (version 02) can be applied.
It was confirmed that the proposed project, which aims to recover and process the gas on site prior to transportation, is first of a kind in China. The CNG transportation after point A is therefore specific for the proposed project, and no applicable for other projects applying AM0009.
Hence, the deviation will not imply any amendment of AM0009.

According to “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion”(version 02), PECO2,fossifuel,y are calculated as attached formula (annex 2).

For transportation of transferring CNG from gas processing plant to TGUS, the fossil fuel is diesel. So the CO2 emission is calculated as attached formula (annex 3)

where:
PEco2,diesel,y=project emissions due to diesel consumption of transportation vehicle and emergency use consumption of diesel generators (tCO2/y).
FCdiesel,T,y = the quantity of diesel combusted in process point T during the year y (m3/y). This parameter is included in the monitoring plan, and will be measured by fuel dispenser.
ρdiesel,y = 0.84 (t/Nm3)as per GB 19147-2009.
COEFdiesel, y = CO2 emission coefficient of diesel in year y (103 tCO2/Gg).
NCVdiesel, y = the weighted average net calorific value of consumed diesel in year y. This parameter is included in the monitoring plan, and IPCC default value at the upper limit of the uncertainty at a 95% confidence interval (43.3 TJ/Gg) will be applied.
EFCO2,diesel, y = the weighted average CO2 emission factor of consumed diesel in year y. This parameter is included in the monitoring plan, and IPCC default values at the upper limit of the uncertainty at a 95% confidence interval(74.80 tCO2/TJ) will be applied.

For the proposed project, based on the diesel consumption estimated in the FSR, and as per above functions, the ex-ante estimate of yearly CO2 emissions due to diesel consumption for CNG transportation are calculated and showed in table attached (annex 2).

In conclusion, the deviation will result in increasing of the project emission hence decreasing the project emission reduction. For the proposed project activity, total 2,772 tons of carbon emission reduction will be decreased annually.