VERIFICATION REPORT FOR CAMBRIA 33 ABANDONED MINE METHANE CAPTURE & USE PROJECT

Transcription

1 VERIFICATION REPORT FOR CAMBRIA 33 ABANDONED MINE METHANE CAPTURE & USE PROJECT Document Prepared by First Environment, Inc. Project Title Cambria 33 Abandoned Mine Methane Capture & Use Project Version 1.0 Report ID 1.0 Report Title Client Verification Report for the Cambria 33 Abandoned Mine Methane Capture & Use Project Vessels Coal Gas, Inc. Pages 17 Date of Issue Prepared By Contact Approved By Work Carried Out By 16-September-2015 First Environment, Inc. 91 Fulton Street Boonton, New Jersey Tel: Jay Wintergreen Jeff Daley Luca Nencetti Michael Carim

2 Summary: This report is provided to Vessels Coal Gas, Inc. (Vessels) as a deliverable of the Verified Carbon Standard (VCS) project verification process for the Cambria 33 Abandoned Mine Methane Capture & Use Project (the Project) located in the Township of Ebensburg, Pennsylvania. The Project voluntarily captures gas from a gob well at an abandoned coal mine. The gas is processed to produce high-grade methane, which is injected in a natural gas distribution pipeline. A portion of the raw gas is also consumed by an engine generator to produce power required by the project activity. The verification process and scope consists of the independent third-party assessment of the implementation of the project and emission reduction assertion against the criteria stated in the Verified Carbon Standard (VCS) Standard, 25 March 2015, v3.5; the approved Clean Development Mechanism (CDM) Methodology ACM0008 (Version 6); the approved methodology revision VMR0002 (Version1.0); and the validated Project Description (PD). The purpose of the verification is to ensure the project was implemented and monitored in accordance with the validated Project Description, the underlying CDM Methodology, and the approved methodology revision. During the verification process, First Environment, Inc. (First Environment) issued eight corrective action requests and one clarification request which were all addressed sufficiently by Vessels. No uncertainties were identified during the verification process. The Project claims emission reductions of 24,729 metric tonnes CO 2 e for the period of January 1 through December 31, First Environment is reasonably assured that the Project meets all relevant VCS program requirements and correctly applies the CDM Methodology ACM0008 (Version 6), VCS Methodology Revision VRM0002 (Version 1.0), and the validated PD (VCS PD).

3 TABLE OF CONTENTS 1 Introduction Objective Scope and Criteria Level of Assurance Summary Description of the Project Verification Process Method and Criteria Document Review Interviews Site Inspections Resolution of Findings Forward Action Requests Eligibility for Validation Activities Validation Findings... 4 Participation under Other GHG Programs Methodology Deviations Project Description Deviations Grouped Project Verification Findings Project Implementation Status Accuracy of GHG Emission Reduction and Removal Calculations Quality of Evidence to Determine GHG Emission Reductions and Removals Non-Permanence Risk Analysis Verification Conclusion... 9

4 APPENDICES APPENDIX A: Findings... 11

5 1 INTRODUCTION 1.1 Objective This report is provided to Vessels Coal Gas, Inc. (Vessels) as a deliverable of the Verified Carbon Standard (VCS) project verification process for the Cambria 33 Abandoned Mine Methane Capture & Use Project (the Project) located in the Township of Ebensburg, Pennsylvania. This report covers the verification of greenhouse gas (GHG) emission reductions from the capture and destruction of abandoned coal mine methane (AMM) over the period from January 1 through December 31, First Environment, Inc. (First Environment) conducted the verification from the date of the kick-off meeting through September 3, During the verification process, Ruby Canyon Engineering (RCE) served as the project consultant for the project proponent, Vessels. First Environment communicated with RCE regarding verification activities. 1.2 Scope and Criteria The specific scope metrics for the verification are outlined in the table below: Reporting Period January 1 December 31, 2014 Emission Sources Verified Definition of Materiality Baseline Sources Emission reductions of methane from the destruction of fugitive AMM Project Sources Emissions of CO 2 from purchased electricity Emissions of CO 2 from AMM destruction in the gas grid and by project equipment Emissions of CH 4 from un-combusted methane Misstatements of greater than five percent of the Project s GHG assertion Qualitative non-conformities with Standards of Verification described below The following table outlines the guidance and protocols used to conduct this verification: Standards of Verification Verification Process VCS Standard: VCS Version 3, 25 March 2015, v3.5 (VCS Standard) Validated VCS Project Description (VCS PD), October 5, 2010 VMR0002 Revision to ACM0008 to Include Methane Capture and Destruction from Abandoned Coal Mines, Version 1.0 (VMR0002) ACM0008 Consolidated methodology for coal bed methane, coal mine methane and ventilation air methane capture and use for power (electrical or motive) and heat and/or destruction through flaring and flameless oxidation, Version 6. VCS Standard VCS Program Guide, Version 3, 8 October 2013, v3.5 ISO :Specification with guidance for the validation and verification of greenhouse gas assertions,

6 The Monitoring Report dated September 14, 2015; Version 4.0 titled Cambria 33 VCS Monitoring Report No.5 was also reviewed to inform the verification assessment. 1.3 Level of Assurance First Environment and Vessels have agreed that a reasonable level of assurance be applied for the Project. 1.4 Summary Description of the Project The Project consists of the collection and utilization of fugitive methane emissions from the abandoned Cambria 33 coal mine located in Ebensburg, Pennsylvania (latitude and longitude are and , respectively). The captured AMM is purified and injected into a natural gas transmission pipeline or destroyed in an engine used to produce electricity to power project equipment. The Project claims GHG emission reductions from the destruction of the AMM that would otherwise have been released to the atmosphere. During the current reporting period, the Project is not claiming emission reductions from the displacement of fossil fuel-derived natural gas in the gas grid as discussed in further detail in Section 3.2 below. The VCS PD provides additional details regarding the project activity. 2 VERIFICATION PROCESS The verification process was utilized to gain an understanding of the Project s GHG emission sources and reductions and to evaluate and verify the collection and handling of data, the calculations that lead to the results, and the means for reporting the associated data and results. The following verification process was used: conflict of interest review; selection of Audit Team; kick-off meeting with Vessels and RCE; review of the VCS PD; development of the verification plan and sampling plan; desktop review and evaluation of raw data, calculations, and supporting documentation for the period under review; follow-up interaction with Vessels and RCE for corrective action or supplemental data as needed; and final statement and report development. 2.1 Method and Criteria The following verification method was applied when conducting the verification: Conflict of Interest Review Prior to beginning any verification project, First Environment conducts an evaluation to identify any potential conflicts of interest associated with the project. No potential conflicts were found for this Project. Audit Team First Environment s Audit Team consisted of the following individuals who were selected based on their verification experience, as well as familiarity with coal mine operations and methane capture: 2

7 Jeff Daley Lead Verifier Luca Nencetti Verifier Michael Carim - Verifier Jay Wintergreen Internal Reviewer Audit Kick-off The verification audit was initiated with a kick-off conference call on July 27, 2015 between First Environment and Vessels. The communication focused on confirming the verification scope, objectives, criteria, schedule, and the data required for the verification. Project Description Review The Audit Team reviewed the VCS PD as a basis for developing the verification plan. Development of the Verification Plan The Audit Team formally documented its verification plan as well as determined the data-sampling plan. The verification plan was developed based on discussion of key elements of the verification process during the kick-off meeting. Vessels was given the opportunity to comment on key elements of the plan for verification. Based on items discussed and agreed upon with Vessels, the plan identified the First Environment team members, project level of assurance, materiality threshold, and standards of evaluation and reporting for the verification. It also provided an outline of the verification process and established project deliverables. A separate sampling plan was designed to review all project elements in areas of high risk of inaccuracy or non-conformance. Site Visit First Environment performed a site visit on February 14, 2013 as part of the verification process for a previous reporting period. The site visit included interviews with relevant site personnel and project stakeholders; review of the Project s operations, data collection procedures, and information management systems; as well as assessments of the Project s controls for sources of potential errors and omissions. All project activity locations, metering equipment, and engine plant were visited. It was confirmed during the current verification through a review of the Monitoring Report, project personnel interviews, and current project documentation (permits, calibration records, and field monitoring reports) that no significant operational or data management changes had occurred since the previous site visit. The current project documentation including the raw data files and plant field reports were reviewed and found to be consistent with the previous reporting periods. Data formats, monitoring and recording frequencies, and data quality processes were also found to be consistent with previous reporting periods which support the Project Developer s claim that no significant changes have occurred to the project s monitoring or data management procedures. Through the above identified review processes, First Environment was able to confirm with reasonable assurance that there have been no significant project changes from the previous verifications and therefore a repeat site visit for this verification period was deemed unnecessary. Desktop Review The Audit Team performed a desktop review of the Monitoring Report, GHG emission reduction assertion, and supporting documentation, as further described in Section 2.2 below. Corrective Actions and Supplemental Information The Audit Team issued requests for supplemental information, corrective action, and clarification during the verification process. The corrective action and clarification requests and the associated responses provided by Vessels are summarized in Section 2.5. Verification Reporting 3

8 Verification reporting documents the verification process and identifies its findings and results. Verification reporting consists of this report and a separate Deed of Representation to be submitted to the VCS Association. 2.2 Document Review During the verification process, First Environment reviewed the Project s Monitoring Report, GHG emission reduction assertion, and supporting documentation for the current verification period to ensure consistency with the VCS PD, ACM0008, and VMR0002. Discrepancies between project documentation and the verification criteria were considered material and identified for corrective action. Deviations required appropriate justification from Vessels. Additionally, First Environment assessed the GHG emission reduction assertion and underlying monitoring data to determine if either contained material or immaterial misstatements. The results of these reviews are discussed in greater detail below. 2.3 Interviews Through the course of verification activities, First Environment interviewed the following project personnel to inform the verification process: Tom Vessels Vessels Coal Gas, Inc. (Project Proponent) Julian Huzyk - Vessels Coal Gas, Inc. (Project Proponent) Nina Pinette Ruby Canyon Engineering (Project Consultant) 2.4 Site Inspections As described above a site visit was not performed during the current verification process. 2.5 Resolution of Findings The Audit Team issued eight requests for corrective action and one request for clarification during the verification process. No forward action requests were identified. Vessels responses were sufficient to resolve all requests. The corrective action and clarification requests and the responses provided are summarized in the tables found in Appendix A Forward Action Requests There were no Forward Action Requests issued during the current verification. 2.6 Eligibility for Validation Activities First Environment is accredited to perform validation activities as described in Section 3 below for activities in Sectoral Scopes 8 (Mining/Mineral production) and 10 (Fugitive emissions from fuels), which are the applicable scopes for the approved VCS methodology VMR0002, and CDM methodology ACM VALIDATION FINDINGS As described in Section 3.2 below, four new Project Description deviations were validated during the current reporting period. First Environment reviewed justification for the deviations, including supporting documentation, in order to confirm that they are consistent with the underlying methodology and did not negatively impact the conservativeness or accuracy of the emission reductions. The validation process for each new deviation consisted of an assessment of the Project s implementation, as described in the Monitoring Report and from discussions with Vessels, against the validation criteria. The validation criteria considered in the assessment of any deviations included the approved VCS methodology VMR0002, v1.0, the approved CDM methodology ACM0008, v6 and the VCS Standard. 4

9 3.1 Participation under Other GHG Programs VERIFICATION REPORT: VCS Version 3 The project is not seeking registration of emission reductions with any other GHG programs during the current reporting period. The project will be transitioning to the ARB compliance offset programme and report emission reduction under the applicable Compliance Offset Protocol for future reporting periods. Vessels has also listed the Project as an early action offset project in the ARB compliance programme in order to convert the emission reductions from this monitoring period to Early Action Offset Credits, upon the completion of the current VCS verification. 3.2 Methodology Deviations Not Applicable No new methodology deviations were applied during the current reporting period. 3.3 Project Description Deviations The following project description deviations were identified in the Monitoring Report and approved for the Project during the current verification: 1. Baseline emissions for reductions from the displacement of fossil fuel-derived natural gas in the gas grid (BEuse) were not included for this monitoring period. These baseline emissions were not included because emission reductions from displacement of natural gas are not eligible under California s Cap-and-Trade Regulation. The Project is seeking registration as an early action offset project and intends to convert the emission reductions from this monitoring period to ARB offset credits. First Environment approved this deviation because it is conservative and results in fewer emission reductions for the current monitoring period. Additionally, this deviation does not impact the applicability of the methodology, additionality, or appropriateness of the baseline scenario. 2. The VCS PD states that the sales gas chromatograph is automatically calibrated every 24 hours using a certified standard gas cylinder of known gas composition. The gas cylinder expiration date was November 22, The Project did not replace the calibration gas cylinder during the monitoring period. The average methane concentration readings prior to the calibration gas cylinder expiration were compared to the average methane concentration readings after the gas cylinder expired to demonstrate that there was very little (a tenth of a percent) difference between average methane concentration prior to and after the gas cylinder expired. Additionally, the gas chromatograph was calibration checked for accuracy on August 10, 2015 with a new calibration gas cylinder which indicated that the analyzer itself was operating accurately. First Environment approved this deviation because if the gas chromatograph auto calibration was materially affected because of the expired calibration gas cylinder, the methane concentration readings after the calibration gas expired would have differed by a larger margin when compared to the gas concentration reading prior to the calibration cylinder s expiration date. This deviation does not impact the applicability of the methodology, additionality, or appropriateness of the baseline scenario. 3. The Monitoring Plan originally identified that the gas composition to the engine would be continuously monitored with a Guardian Plus infrared methane analyzer. For the duration of the current reporting period, the gas composition was continuously monitored with a RKI Beacon 110 Gas Monitor. This is identified as deviation because a new instrument was introduced that is not described in the validated VCS PD. First Environment approved this deviation because gas quality is still being continuously measured with a gas analyzer at the same location as the old analyzer. In addition to this deviation, the VCS PD called for daily calibrations of the gas analyzer, which is not applicable to the new Beacon analyzer. The new analyzer was not calibrated during the current reporting period. The analyzer was checked for calibration accuracy on August 10, 2015, and the results indicated that the analyzer was operating accurately. Going forward, the device will be checked for accuracy according to the manufacturer s recommended procedures of 5

10 once every six months. First Environment approved this deviation because the gas analyzer was found to be operating accurately during the August 10, 2015 calibration accuracy check. Additionally, this deviation does not impact the applicability of the methodology, additionality, or appropriateness of the baseline scenario. 4. The Monitoring Plan requires an annual calibration of the Sage flow meter which measures gas flow at the engine. The Sage flow meter was not calibrated during the current reporting period. The meter was subsequently checked for calibration accuracy in accordance with the manufacturer s procedures on August 10, 2015 which indicated that the meter was found to be operating accurately in accordance with manufacturer s requirements. The Monitoring Plan has been revised to identify that going forward this meter will be checked for calibration accuracy annually and calibrated, if necessary. First Environment approved this deviation because the flow meter was found to be operating accurately during the August 10, 2015 calibration accuracy check. Additionally, this deviation does not impact the applicability of the methodology, additionality, or appropriateness of the baseline scenario. The above mentioned deviations were appropriately described and justified in the Monitoring Report and remain in compliance with the VCS rules. 3.4 Grouped Project Not Applicable the Project is not a grouped project. 4 VERIFICATION FINDINGS 4.1 Project Implementation Status The Project was implemented according to the description provided in the validated VCS PD, except where noted in this report as deviations. The Project began commercial operation by injecting pipeline gas on March 12, The engine generator was commissioned on December 13, The 10-year project crediting period began on May 1, 2008 and ends on April 30, The Audit Team confirmed that no data and/or variables presented in the Monitoring Report differ from those stated in the VCS PD, except where noted as project description deviations. Similarly, the data collection and recordkeeping procedures were found to be generally consistent with those outlined in the monitoring plan described by the VCS PD, except where noted below, and meet the requirements of VMR0002 and ACM0008. Vessels has adequate management and operational systems in place with respect to monitoring and reporting, as determined through observation during the previous verification site visit and the desktop review of project documentation. Through communications with Vessels, the Audit Team confirmed that the Project is not participating in any other GHG programs or emissions trading programs, nor attempted to register with such programs. As indicated in the VCS PD, no other environmental credits are generated by the Project. The following topics were discussed with Project personnel during a previous verification site visit and reconfirmed during the current verification process: the data collection process used to generate reports, and internal documents and protocols that set guidelines for the data collection process. The information gathered during these discussions and review was used to assess the Project s data management systems and its controls for sources of potential errors and omissions. The primary aspects of the Project s monitoring plan are described below. 6

11 Gas flow to the engine generator is monitored by a Sage thermal mass flow meter model SIP DC24-DIG GAS with s/n In accordance with a previously validated PD Deviation, the flow meter is to be calibrated annually. As identified in Section 3.2 above, the flow meter was not calibrated during the current reporting period and therefore a new PD deviation was identified and justified. The sales gas flow is monitored with a Dresser Roots model 3M s/n In accordance with a previously validated PD Deviation, the calibration requirement for the flow meter is once annually. The flow meter was calibrated during the current reporting period on August 12, 2014 which indicated the meter was operating accurately. Methane concentration of gas destroyed in the engine generator was monitored using an RKI Beacon 110 Gas Monitor. As identified in Section 3.2 above, the RKI Beacon Gas Monitor is a new analyzer which was not calibrated during the current reporting period. Therefore, a new PD deviation was identified and justified. Methane concentration for the sales gas flow is monitored using Daniel Danalyzer Gas Chromatograph s/n The VCS PD indicates that the QAQC requirement is the analyzers daily auto-calibration function using a certified reference gas cylinder. It was confirmed during a previous site visit that the analzyer is programmed to perform daily auto-calibrations. However, as identified in Section 3.2 above, the calibration gas certificate indicated that the calibration gas was expired in November 2014 and therefore, a new PD deviation was identified and justified. Electricity consumption by the project activity is determined using utility invoices from the electricity supplier. Although the validation report did not explicitly identify any methodology deviations, the following methodology deviation was approved for the Project during the validation process: ACM0008 requires that the parameter PCCH4 is monitored on a wet basis. However, the Project monitors methane content downstream of gas treatment and on the same moisture basis as gas flow. First Environment confirmed that this previously validated deviation was implemented during the verification period in accordance with the validated VCS PD. The following Project Description deviations were previously validated for the Project and are applicable to the current reporting period: Parameter Monitoring Requirement Deviations approved during third monitoring period VAMM gas grid,y VAMM genset,y Flow meter to be calibrated twice per year by a third party. Flow meter to be calibrated twice per year by third party (Gas Analytics). Project Description Deviation Vessels amended the frequency of calibration of the sales gas flow meter to once per year by a third party (Gas Analytics). Monitoring practices for the current verification period are consistent with this deviation. Vessels amended the frequency of calibration of the sales gas flow meter to once per year by a third party (Gas Analytics). Monitoring practices for the current verification period are consistent with this deviation. PC CH4,genset,y Gas analyzer is calibrated daily (self calibration). Vessels replaced this instrument during the current reporting period, as noted in Section 3.2 above under project deviation number 3. 7

12 Parameter Monitoring Requirement Deviations approved during fourth monitoring period VAMM i Parameter description and value in PD Project Description Deviation V AMM,i was incorrectly identified in the validated VCS PD. The initial volumetric flow rate of abandoned mine methane at mine closure was recorded as mcfd in PD, instead of the correct mmcfd value. The correct value was applied in the ex ante and all subsequent ex post emission reduction calculations The data collection and recordkeeping procedures were found to be consistent with those outlined in the monitoring plan described by the VCS PD and meet the requirements of the ACM0008 and VMR0002. There were no remaining issues or material discrepancies from the previous validation or verification processes. The Project has not received or sought another form of environmental credit nor has it become eligible to do so since the validation. First Environment confirmed through an attestation provided by Vessels that the Project has not participated in any other GHG program during the current reporting period. Overall, the Project is implemented according to the description provided in the VCS PD and the monitoring system implemented was found appropriate to the task of obtaining, recording, compiling, and analyzing the monitored data and parameters. 4.2 Accuracy of GHG Emission Reduction and Removal Calculations Emission reductions are calculated ex post using the approach indicated in VMR0002, ACM0008, and the VCS PD. Emission reduction calculations for the verification period were reviewed to ensure accuracy in the formulas used and the raw data used as inputs. The formulas were tested and found to be consistent with the calculations described in VMR0002, ACM0008, and the VCS PD. Monitored data for AMM captured and injected in the pipeline (AMMPJ,gas-grid,y) or piped to the engine generator (AMMPJ,genset,y), each multiplied for the respective monitored methane concentration (PCCH4 gas grid; PCCH4 genset), are used to determine the total methane destroyed by the project activity (AMMPJ,y). This value is compared to the avoided methane emissions released in the atmosphere by the abandoned mine (AMMDC,y), estimated according to the decline curve. The lesser of the two values is used in the emission reduction calculations. In the current monitoring period, AMMPJ,y was the lower of the two values. This value is then multiplied by GWPCH4 to obtain the baseline emissions from methane destruction (BEMR,y) in metric tons of CO 2 e. There are three sources of GHG emissions due to the project activity: emissions from use of additional energy for the capture and use of AMM; emissions from destruction of methane (by the genset and the grid end uses); and emissions from un-combusted methane. Because electricity is the only form of additional energy used by the Project, project emissions from energy use (PEME,y) are calculated by aggregating the annual electricity consumption from the utility bills and multiplying by the appropriate emission factor obtained from the US EPA egrid database. The other sources of project emissions are calculated from the monitored gas flow and methane concentration data, including the concentration of non-methane hydrocarbon content as tested by Vessels, and multiplied for the appropriate default factors for efficiency of combustion and distribution. For the current reporting period, the concentration of non-methane hydrocarbon content was less than the one percent threshold indicated in the methodology and therefore was excluded from the calculation of project emissions. 8

13 The verification process focused on the assessment of calculation spreadsheets to ensure that they were consistent with the formulas and equations described in VMR0002, ACM0008, and the VCS PD. Copies of the raw data used in the calculations, including AMM gas flow measurements, gas analysis data, gas sales invoices, and electricity invoices, were compared with the values used in the final calculations and tested for transcription or mathematical errors. The calculations for the entire period were reviewed as well to determine whether they were free of material misstatement. All calculation methods and emission factors used to determine emission reductions were consistent with those outlined in the VCS PD. No material misstatements were observed in the final GHG assertion. The Audit Team performed an independent recalculation of the emission reductions from the verification period using the available raw flow, methane, electricity, and propane consumption data. Material misstatements were identified for correction by Vessels as described in Section 2.5. Overall, the GHG emission reductions were quantified correctly in accordance with the VCS PD, ACM0008 methodology, and VMR Quality of Evidence to Determine GHG Emission Reductions and Removals Vessels provided adequate documentation for the emission reduction calculations as well as its management systems around the data collection process. Specifically, First Environment was provided a Monitoring Report prepared in accordance with the VCS program template, transparent calculation spreadsheets, calibration records, and electronic data associated with AMM gas flow, AMM gas concentration, electricity generated, and operating hours. Raw data was reviewed beginning from its original source of generation to confirm the accuracy of the information flow. The evidence provided was consistent with the requirements of ACM0008, VMR0002, and the VCS PD and meets generally accepted evidentiary standards for best practice in GHG accounting to sufficiently quantify the GHG emission reductions. 4.4 Non-Permanence Risk Analysis Not relevant since the project is not an AFOLU activity. 5 VERIFICATION CONCLUSION First Environment was retained to provide verification services for the Project s GHG emission reductions assertion based on the following fundamentals: Level of assurance: Reasonable assurance. Objectives of verification: To assure project conformance with the VCS Standard, the CDM methodology ACM0008, the VCS methodology VMR0002 and the VCS PD. Verification criteria: VCS Standard, the CDM methodology ACM0008, the VCS methodology VMR0002 and the VCS PD. Definition of materiality: Misstatements of greater than five percent of the GHG assertion and qualitative non-conformities with the validated VCS PD are considered material. Scope, including: o o Boundaries of the assertion: Vessels AMM recovery operations at the Cambria 33 mine located in Ebensburg, Pennsylvania as well as gas transport via the commercial pipeline and combustion by end users connected to the natural gas grid; The physical infrastructure, facilities, and activities within the assertion: AMM gob well and associated piping, gas treatment and compression facility, engine generator, and commercial gas pipeline; 9

14 o GHG sources, sinks, and reservoirs included within the assertion: Methane emission reductions due to the capture of AMM, expressed as carbon dioxide-equivalents; carbon dioxide emissions due to the operation of project equipment and methane destruction as part of the project activity; and methane emissions from un-combusted methane due to the project activity expressed as carbon dioxide-equivalents; and o The time period for the assertion: January 1 through December 31, Based on the assessments performed and the historical evidence collected, First Environment concludes, with a reasonable level of assurance that the emissions reductions of the Project resulting from the capture and combustion of methane gas for the period of January 1 through December 31, 2014 are: consistent with the VCS PD of October 5, 2010; in conformance with the VCS Standard, the VCS methodology VMR0002 (Version 1.0), and the CDM methodology ACM0008 (Version 6.0); without material discrepancy; and meeting the minimum level of accuracy of at least 95 percent. Verified GHG emission reductions or removals from January 1 through December 31, 2014: Year Baseline emissions or removals (tco 2 e) Project emissions or removals (tco 2 e) Leakage emissions (tco 2 e) Net GHG emission reductions or removals (tco 2 e) ,766 4, ,729 Total 28,766 4, ,729 10

15 APPENDIX A: Findings Corrective Action and Clarification Requests and Responses ID Corrective Action Request Participant Response Section 2.2 of the Monitoring Report does not identify the use of the RKI Beacon 110 Gas Monitor as a project description deviation. Please also clarify the required calibration/ inspection frequency of the RKI Beacon 110 Gas Monitor. The Monitoring Report does not conform to the VCS Monitoring Report template, specifically: The Project ID number on title page is not completed. Section 1.9 does not include a disclosure of the project being listed under the California ARB Early Action Offset Program. The sampling frequency of the concentration of non-methane hydrocarbons (PC_NMHC) described in Monitoring Report, Section 3.2, is not consistent with validated Project Description and the frequency of the actual samples taken during the reporting period. The calibration gas used for the Daniel Danalyzer Gas Chromatograph expired on November 21, The calculation of AMM captured and delivered to the genset (AMM_PJ,genset,y) incorrectly applies the quantity of methane sent to the genset during the reporting period. This issue also affects the following calculations: Section 2.2 of the Monitoring Report has been updated and now identifies the use of the new RKI Beacon 110 Gas Monitor and also identifies the lack of calibrations in 2014 as a Project Description Deviation. The meter was checked on August 10, 2015 which indicated the analyzer was operating accurately during the reporting period. Going forward the analyzer will be checked for calibration accuracy in accordance with the manufacturers recommended frequency of at least every six months. The title page and Section 1.9 of the Monitoring Report have been revised to address the identified issues. Section 3.2 of the Monitoring Report has been revised and is now consistent with the parameter description included in the VCS PD. Section of the Monitoring Report has been revised to identifiy this as a PD deviation. The analyzer was sucessfully calibrated on August 10, 2015 with a drift of 0.35% which indicates the analyzer was operating accurately. The emission reduction calculations have been revised to correct this issue for all of the identified parameters. Verification Conclusion 11

16 ID Corrective Action Request Participant Response Project emission calculations from methane destroyed in the genset (MD_genset). Project emission calculations from un-combusted methane (PE_UM,y). The calculation of AMM_DC,y does not apply the initial decline rate (Di) in accordance with Equation 4 of the validated Project Description. The calculation of project emissions from grid electricity consumption (PE_ME,y) applies an incorrect e- Grid emission factor. Section of the Monitoring Report does not state if the identified deviations impact the applicability of the methodology, additionality or the appropriateness of the baseline scenario as required per the VCS Monitoring Report Template. The calculation of AMM_DC,y has been corrected and now correctly applies the initial decline rate (Di). The previously incorrect formula did not affect the current year determination of the baseline emissions. The calculation of project emissions from grid electricity consumption have been revised and now apply the correct e-grid emission factor. Section of the Monitoring Report has been revised and now identifies whether the deviations identified impacts the applicability of the methodology, additionality or the appropriateness of the baseline scenario as required per the VCS Monitoring Report Template. Verification Conclusion ID Clarification Request Participant Response 1 The initial check performed during the Sage flow meter calibration accuracy check indicated the as found condition of the meter to be drifting by seven percent. Please clarify how this meter drift falls within the VCS Program materiality requirements. Additionally, the related deviation in Section of the Monitoring Report does not clearly identify the intended QAQC practices going forward (i.e., calibration vs. calibration accuracy check). The materiality requirement in the VCS Standard v3.5 is stated as The threshold for materiality with respect to the aggregate of errors, omissions and misrepresentations relative to the total reported GHG emission reductions and/or removals shall be five percent for projects. There is no requirement that calibration accuracy or percent drift be less than five percent. Materiality is only applicable to errors, omissions and misrepresentations relative to the total reported GHG emission reductions. The calibration requirement in the Standard is in the following section: Where measurement and monitoring equipment is used, the project proponent shall ensure the equipment is calibrated according to the equipment's specifications and/or Verification Conclusion 12

17 relevant national or international standards. For the project flow meter, Sage states in its manual that a value greater than 5 mw, but less than or equal to 10 mw, also indicates that the meter is still in calibration. For Sage 1mw=1% and thus the flow meter is reading within the threshold that Sage considers to be in calibration. Section of the Monitoring Report has been updated to reflect QA/QC practices going forward. 13