I-DEV0289: Request For Deviation for Project N° 0198

According to the approved monitoring plan in the PDD, the measurement of Non-Condensable Gas shall be executed every 4 months; however, for this specific Monitoring Period (01 Jan 2009 up to 29 Jun 2009), the preceding Non-Condensable Gas (NCG) measurement was performed on 15December 2008 and the following was due by mid April 2009. Whereas, the NCG measurement was carried out on July 05, 2009 which is 3 months later than the required date. Both DOE and PP treat it as a Deviation to the monitoring plan of the registered PDD. This specific occurrence was outside of PENSA’s control since the Laboratory responsible for the performance of the service, La Geo from El Salvador, cancelled at the last minute due to a Corporate Policy instruction not to undertake work outside of El Salvador.

PENSA conducted new NCG measurements on 05 July 2009, contracting the services of “Instituto de Investigaciones Eléctricas” (IIE) from Mexico. IIE has the technical experience as well as the geothermal background to perform such a service. IIE (http://vmwl1.iie.org.mx/sitioIIE/sitio/indice.php) is an acknowledged governmental laboratory for geothermal science in Mexico which has been certified by ISO under ISO 9001:2000, ISO 14001:2004 and by NMX-SAST-001-IMNC-2000 (Mexico Health and Safety Standard at the Work Place, which is partially compatible with BSI OHSAS 18001:2007). It is also certified by the “Entidad Mexicana de Acreditación, A.C. (EMA)” in accordance to the Norm NMX-EC-17025-IMNC-2006 (Mexican Standard for the Administration of a Laboratory).

In accordance with the above, the PP and the DOE considered this event as a deviation to the monitoring plan (MP) due to the delayed measurement and non-fulfillment of the required measurement frequency according to the MP. Therefore, this requested deviation aims to use the maximum value among the measurements performed on 15/12/2008 and 05/07/2009 for the calculation of project emission. According to the formula provided in section D.2.2.2 of the registered PDD (on page 28), this approach would lead to the most conservative result of emission reduction.

Using the above approach, the following result was obtained:

 The maximum value of CO2 tonnes/tonne (0.0025591216), which is the maximum value obtained on 05 July 2009, was used in the Calculation Sheet for the period from 16 April 2009 (due date of measurement of Non-Condensable Gas) and ending on 29 June 2009.

 Similarly, the maximum value of CH4 tonnes/tonne (1.44800 x 10-6), which is also the maximum value obtained on 05 July 2009, was used in the Calculation Sheet for the period from 16 April 2009 (due date of measurement of Non-Condensable Gas) and ending on 29 June 2009.

 With this approach, an Emission Reduction of tCO2e of 24,202.07 was obtained.

This was a unique event that the Operator was unable to control, but which the Operator took reasonable steps to correct. The measurements taken in July 2009, compared with earlier measurements, confirm that the NCG levels do not change significantly and hence the approach adopted of using the maximum value of NCG levels between the ones obtained in December 2008 and July 2009 is a realistic and conservative solution. See attached graphs showing the observed changes in NCG levels over the pervious 18 month operating history of the project.

The delay in measuring the NCG level impacts the calculation of Project Emissions and Emission Reductions for this monitoring period (01 Jan 2009 to 29 Jun 2009) only, but does not impact the following Crediting Periods. The delay that occurred is not expected to happen again and therefore is not a permanent change and does not affect additionality or the application of the methodology.

Please see Table below with relevant data on which the calculation of Emissions Reductions has been based. The result of the total value of the emission reduction is calculated based on the following results:

Case 1: The average value of the samples taken on 15-16/12/2008.
Case 2: The maximum value of the samples taken on 15-16/12/2008.
Case 3: The average value of the samples taken on 05/07/2009.
Case 4: The maximum value of the samples taken on 05/07/2009.

Please see the table in Enclosure 1

The maximum difference in emission reduction observed in using the above ranges of values is only 0.69%, which is less than the observed measurement uncertainty between the various NCG samples taken at any one time. See attached graphs.

Based on the information reviewed and that presented within this Request for Deviation, the DOE can confirme that the approach adopted, namely to use Case 4 is the most conservative approach and the one that should be used in the PE and consequently in the ER calculations.