I-DEV0375: Monitoring plan deviation regarding accuracy of monitoring equipments

During the verification of the proposed project “Dalian Maoyingzi Landfill Gas Recovery for Power Generation Project”(UNFCCC Ref. 2523, registered on 10/11/2009) for the monitoring period 10/11/2009 – 30/04/2010, it was found that several monitoring equipments’accuracy levels are different from the
requirements indicated in the monitoring plan of the registered PDD:
1. LFG flowmeters (one for main pipe and one for the flare pipe): Grade 1.0 in PDD vs. Grade 1.5 in reality.
2. Thermocouple for measurement of Tflare: Grade 0.2 in PDD vs. Grade II in reality.
3. Plant-use electricity meter for ELgridtoPJ: Grade 0.5s in PDD vs. Grade 2.0 in reality.
Below are the reasons for requesting a deviation from provisions of registered monitoring plan:

1. LFG flowmeters:
During the on-site verification it was found that the two LFG flowmeters (one at the main pipe and one at the flare pipe) were both of Grade 1.5. Since it is stated in the registered PDD that the LFG flowmeters would be of Grade 1.0, a Corrective Action Request was raised. In response to this request, project
proponent replaced the two LFG flowmeters (which were Grade 1.5) with Grade 1.0 meters after on-site verification, on 10/06/2010. Evidence of meter replacement was provided by the PP and reviewed by GLC. The scenario after meter replacement is assessed to be in compliance with the registered PDD. A Forward
Action Request has been raised to check the new flowmeters in the next verification. To be conservative, for the period before meter replacement, a certain deduction factor is applied on measurement results of LFG flow rates. Since there is no direct applicable guideline for this specific project
case, a comparable guideline “Guidelines for assessing compliance with the calibration frequency requirements (Version 01)” is considered and 1.5% is applied as the deduction factor.

2. Thermocouple for Tflare:
During on-site verification it was found that a working base metal thermocouple with “Index K” type for measurement of Tflare is installed which is of “Grade II”. Since it is stated in the registered PDD that the thermocouple for measurement of Tflare would be of Grade 0.2, a Corrective Action Request was raised. The National Chinese Standard: “Verification Regulation of Working Base Metal Thermocouple” /JJG351-1996/, states for Working Base Metal thermocouples only a Grade classification of I Grade and II Grade, with no “0.2 Grade” at all.
According to the project owner, which is also the author of registered PDD, the “0.2 Grade” of thermocouple was a mistake.
Since “0.2 Grade” in PDD is not a valid Grade of thermocouple, the acceptance of current meter - Grade II, is assessed.
According to JJG351-1996 (JJG is alphabetic abbreviation of “Measurement and Verification Regulation” in Chinese), the maximum error of Grade II thermocouple (Index K) is ±2.5℃ or±0.75%.
According to the methodology, the measurement results of Tflare are not directly involved in ER calculation. They are only used to find the specific hours, when the exhaust gas temperature is lower than 500 ℃ for
more than 20 minutes per hour. ±2.5℃or±0.75% is very small compared to operation range of flare, which is 600℃-800℃ as per registered PDD.
Based on these, II Grade thermocouple to measure Tflare is assessed as acceptable for the project.
To be conservative, for this monitoring period, the largest maximum error 6℃ (0.75%*800℃) is applied for deduction from each measurement result of Tflare. Even after the deduction is applied, the result of number of hours, during which the Tflare is lower than 500 ℃ for more than 20 minutes within one hour, is not affected; and emission reduction calculation is not affected as well.
A futher MP revision will be applied afterwards to accept Grade II thermocouple for Tflare in the whole
crediting period.

3. plant-use electricity meter for ELgridtoPJ:
The proposed project is expected to flare LFG and/or generate electricity using LFG. Flaring and electricity generation were not implemented at the same time and this is as per the registerd PDD. In this 1st monitoring period, only flare is involved; electricity generation has not started yet. This is due to the long
process of grid connection plan preparation and approval which is in the hands of the local government and not under project owner’s control.
Since the official grid connection system for electricity generation and supply is not ready for implementation yet, a temporary 380kV line is used to import electricity from grid for plant use. And a Grade 2.0 electricity meter on the 380kV line is used to measure ELgridtoPJ. After checking the National Chinese Standard: “Technical Administrative Code of Electric Energy Metering /DL/T448-2000/”, it is confirmed that the meter in concern belongs to “Type IV Electric Energy Metering Device: for user with capacity less than 315kVA; for internal economical/technical indicator analysis or assessment within electricity generation or supply plant”. According to DL/T448-2000, accuracy requirement for Type IV Electric Energy Metering Device is Grade
2.0 for active power. Accuracy requirement for Type I Electric Energy Metering Device (eg. electric energy metering device at the grid delivery measuring point between provincial-level grid-operating plant and its electricity supply plant.) is 0.2s or 0.5s for active power. Thus the current plant-use meter, although accuracy not consistent with information provided in CDM PDD, fulfils relevant national/sectoral requirement for its specific condition (power generation not started, temporary line for plant-use. When the official grid connection system for electricity generation and supply is ready, 0.5s electricity meter will be installed to measure ELgridtoPJ and ELPJtogrid, in accordance with registered PDD and DL/T448-2000. A Forward Action Request is raised to check this.To be conservative, for the period that a temporary 380kV line is used to import electricity from grid for plant use, 2% of the monitored electricity import value has been added to the actual monitored result of the
electricity imported by the project plant from the grid, to calculate emission reductions.

1. LFG flowmeters:
The two LFG flowmeters were replaced with Grade 1.0 meters after on-site verification, on 10/06/2010. After the replacement, the actual situation is in compliance with the registered monitoring plan. Thus no revision of monitoring plan or changes from the project activity is required.

2. thermocouple for Tflare:
A futher MP revision will be applied afterwards to accept Grade II thermocouple for Tflare in the whole crediting period. No change from the project activity is required.

3. plant-use electricity meter for ELgridtoPJ:
When the official grid connection system for electricity generation and supply is ready, 0.5s electricity meter will be installed to measure ELgridtoPJ and ELPJtogrid, in accordance with registered PDD and DL/T448-2000. Thus no revision of monitoring plan is required. Also, after checking submitted evidences and documents, in all it is concluded that although power generation facilities were not implemented during this monitoring period, it is only a temporary delay in implementation of a part of the project activity compared to original timeline rather than a permanent change in the project design. Based on the current scenario, the risk of permanent change of project design has not been identified and hence no changes from project activity as described in the registered PDD are required.

1. LFG flowmeters:
1.5% deduction is applied on measurement result of LFG flowrate. This is following a comparable guideline “Guidelines for assessing compliance with the calibration frequency requirements” (Version 01) and is very conservative.

2. thermocouple for Tflare:
To be conservative, for this monitoring period, the largest maximum error 6℃ (0.75%*800℃) is applied for deduction from each measurement result of Tflare. Even after the deduction is applied, the result of number of hours, during which the Tflare is lower than 500 ℃ for more than 20 minutes, is not affected; and emission reduction calculation is not affected as well.

3. plant-use electricity meter for ELgridtoPJ:
To be conservative, for the period that a temporary 380kV line is used to import electricity from the grid for plant use, 2% of the monitored electricity import value has been added to the actual monitored value, to calculate emission reductions.