Validation Opinion Paulinia Highlight

VALIDATION OPINION
POST REGISTRATION CHANGES
Final
ESTRES Paulnia Landfill Gas Project (EPLGP)
in
Brazil
Validation Opinion N 2015-BQ-41-MD

Revision N 1.2 Aa
Validation Opinion Post Registration Changes, N 2015-BQ-41-MD, REV. 1.2 AA

CDM_VAL_OP_PDD-05-15
VALIDATION OPINION POST REGISTRATION CHANGES

Project Title:
Country:
CDM Registration Reference

N:
ESTRES Paulnia Landfill Gas Project Brazil

(EPLGP)
0165
Client:
Client contact:
ESTRE Ambiental S/A
Mr. Adriano Francisco de Almeida
Report No.:
Revision:
Date of this report:
2015-BQ-41-MD
1.2 Aa
29/02/2016
Approved by (Final Report Authorized officer signing for the DOE):
Date of approval:
01/03/2016
Laura Severino
Methodology
Number:
Version:
Title:
Scale
SS(s):
ACM0001
13.0.0 of 11/05/2012
Flaring or use of landfill gas
Large
13
RINA Services S.p.A. (RINA), commissioned by ESTRE Ambiental S/A, has performed the validation of post
registration changes for the project activity ESTRES Paulnia Landfill Gas Project (EPLGP) in Brazil.
It is RINAs opinion, the changes, as outlined in the revised PDD version 04.5 of 29/02/2016, from the
project activity as described in the registered PDD ensure that the level of accuracy and completeness in the
monitoring and verification process is not reduces as a result of the revision; the revisions are in accordance
with the applied monitoring methodology and the changes to the project activity comply with the
requirements established in the CDM Project Standard.
Hence RINA requests that the validation opinion on changes from the project activity as described in the
revised PDD for the project activity ESTRES Paulnia Landfill Gas Project (EPLGP) in Brazil may be
considered by the Board.
Work carried out by:
Thas de Lima Carvalho

Geisa Maria Principe Branco Saettoni
No distribution without permission from the Client or

organizational unit responsible
Strictly confidential
Unrestricted distribution
Work verified by (Final Report)
Keywords:
Climate Change, Kyoto

Development Mechanism
Protocol,
Clean
Rita Valoroso
Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA


Abbreviations
BE
CAR
CDM
CDM M&P
CER(s)
CH4
CL
CO2
CO2e
CRT
DCI
DNA
DOE
EB
EIA
ER
FAR
GHG(s)
GWP
IPCC
LoA
MoV
MP
MR
NGO
ODA
PCP
PDD
PE
PP(s)
PS
Ref.
RINA
SS(s)
TA(s)
UNFCCC
VVS
Baseline Emissions
Corrective Action Request
Clean Development Mechanism
Modalities and Procedures CDM
Certified Emission Reduction(s)
Methane
Clarification Request
Carbon dioxide
Carbon dioxide equivalent
Coordination and Technical Control Staff
Certification Division of RINA Services Spa
Designated National Authority
Designated Operational Entity
Executive Board
Environmental Impact assessment
Emission Reductions
Forward Action Request
Greenhouse gas(es)
Global Warming Potential
Intergovernmental Panel on Climate Change
Letter of Approval
Means of Verification
Monitoring Plan
Monitoring Report
Non-governmental Organization
Official Development Assistance
Project Cycle Procedure
Project Design Document
Project Emission
Project Participant(s)
Project Standard
Document Reference
RINA Services Spa
Sectoral Scope(s)
Technical Area(s)
United Nations Framework Convention on Climate Change
Validation and Verification Standard


Table of Contents
Page
1
1.1
1.2
INTRODUCTION ...................................................................................................................... 4
Objective
4
Scope
4
2
2.1
2.2
2.3
2.4
2.5
METHODOLOGY ..................................................................................................................... 4
Document Review
4
Follow-up actions
6
Resolution of outstanding issues
7
Internal quality control
8
Validation team and the technical reviewer(s)
8
3
3.1
3.2
3.3
3.4
VALIDATION FINDINGS .......................................................................................................... 8

Project activity details
9
Reason for request for revision in monitoring plan
9
Changes from the registered PDD
9
Changes from the registered Monitoring Plan
9
VALIDATION OPINION .......................................................................................................... 13
Appendix A: Validation Protocol


1 INTRODUCTION
ESTRE Ambiental S/A has commissioned RINA to carry out the validation of the revised monitoring plan
for the ESTRES Paulnia Landfill Gas Project (EPLGP) project in Brazil.
This report summarizes the findings from the validation of the monitoring plan of the project, performed on
the basis of UNFCCC criteria for CDM, as well as criteria given to provide for consistent project operations,
monitoring and reporting.
1.1 Objective
The objective of the Validation is to have an independent evaluation of the changes of the project activity
from the registered PDD compliance with relevant UNFCCC requirements Project Standard to confirm that
it is sound and reasonable and meets the identified criteria and to ensure the level of accuracy and
completeness. The objective of this validation was to assess the revised project design document in order
to confirm its accuracy and completeness of the information reported for the ESTRES Paulnia Landfill
Gas Project (EPLGP) project in Brazil.
1.2 Scope
The validation scope is to review the revised project design document (PDD) against the UNFCCC criteria
for CDM and it is defined as required in the context of proposed revision of a registered CDM activity and
will result in a conclusion by the executing RINA as to whether a revised PDD is valid and should be
submitted to replace the previous version.
UNFCCC criteria refers to paragraph 62(g) of the modalities and procedures for the CDM
The Validation Opinion is not meant to provide any consultancy towards the project participants. However,
stated requests for clarifications and/or corrective actions may have provided input for improvement of the
project design.
2 METHODOLOGY
Validation was conducted using RINA procedures in line with the requirements specified in the CDM M&P,
the latest version of the CDM Validation and Verification Manual, and relevant decisions of the COP/MOP
and the CDM EB and applying standard auditing techniques.
The following sections outline each step in more detail.
2.1 Document Review

The revised PDD, version 04.5 of 29/02/2016 and previous version 04.4 of 24/011/2016 and version 4.3 of
20/10/2015 /01/, and the supporting documents listed below are used for validation assessment.
The following table lists the documentation that was reviewed during the verification.
/01/
UniCarbo Energia e Biogs Ltda. CDM-PDD for project activity ESTRES Paulnia Landfill Gas
Project (EPLGP) in Brazil, version 04.5 of 29/02/2016, version 04.4 of 24/11/2016, version 4.3
of 20/10/2015
/02/
CDM Executive Board: Clean Development Mechanism Project Cycle Procedure, version 09 of
20/02/2015


/03/
CDM Executive Board: Clean Development Mechanism Project Standard, version 09 of

20/02/2015
/04/
CDM Executive Board: Clean Development Mechanism Validation and Verification Standard,
version 09 of 20/02/2015
/05/
CDM Executive Board: Baseline and monitoring methodology ACM0001 Flaring or use of
landfill gas version 13.0.0 of 11/05/2012.
/06/
Econergy: CDM-PDD for project activity ESTRES Paulnia Landfill Gas Project (EPLGP) in
Brazil, version 4.2 of 26/04/2013 (renewal crediting period),
Brazil, version 3.1 of 18/01/2012
Brazil, version 2b of 04/12/2005
/07/
CDM Executive Board Tool to determine the mass flow of a greenhouse gas in a gaseous
stream, version 02.0.0 of 03/06/2011
/08/
CDM Executive Board Tool to calculate the emission factor for an electricity system, version
03.0.0 of 23/11/2012
/09/
CGR Paulinia Technical Project Description dated 15/12/2014 (MEMORIAL DESCRITIVO.pdf)
/10/
CDM Executive Board: Baseline and monitoring methodology AM0003 Simplified financial
analysis for landfill gas capture projects version 3 of 30/09/2005.
/11/
CDM Executive Board: Project emissions from flaring, version 2.0.0 dated 20/07/2012
/12/
Biotecnogas technical memory of Central aspiration and biogas combustion, dated 09/2006
/13/
* Cetesb partial operational license number 37002080 for the landfill, dated 25/02/2014 valid
until 25/02/2019
* Cetesb operational license number 37001297 for biogas plant (flare 1 and 2) , dated
30/09/2011 valid until 30/09/2016
* Cetesb operational license number 37002348 for the flare 3 , dated 23/12/2014 valid until
23/12/2019
* Cetesb operational license number 37001298 for the flare 4 and 5 , dated 30/09/2011 valid
until 30/09/2016
* Cetesb operational license number 37002536 for the flare 6 , dated 31/07/205 valid until
31/07/2020
/14/
UniCarbo Energia e Biogs Ltda. CERs spreadsheet version 04.5 of 29/02/2016 CER
sheet_165 - v4.5.xlsx (revised to be in line with PDD version)
Version 04.4 of 24/11/2015 CER sheet_165 - v4.4.xlsx
version 4.3 of 20/10/2015 CER sheet_165 - V4.3.xlsx
/15/
Biotecnogas s.r.l., technical note regarding the flare maximum temperature and flow of the
flares installed at CGR Paulinia landfill (160229 - Paulinia Declaration.pdf)


2.2 Follow-up actions
On 28/09/2015, RINA, visited Estre Paulinia landfill located in Estrada Municipal PLN 190, s/no., Parque
da Represa, Paulnia SP, Brazil. During the on-site assessment of the project RINA assessed the
implementation and operation of the proposed project activity, reviewed the information flows for
generating, aggregating and reporting the monitoring parameters, interviewed key personnel of the plant to
confirm the operational and data collection procedures, cross-checked between information provided in the
monitoring report and data plant, checked the monitoring equipment including calibration performance,
reviewed calculations and assumptions made in determining the GHG data and emission reductions,
checked the quality control and quality assurance procedures in place to prevent or identify and correct
any errors or omissions in the reported monitoring parameters.
The key personnel interviewed and the main topics of the interviews are summarized in the table below.
Date
Name and Role
Organization
Topic
/a/
28/09/2015
Nuno
Barbosaconsultant
Unicarbo
/b/
28/09/2015
Tiago Nascimento
Silva- Operational
manager
Estre
/c/
28/09/2015
Raul P. CavalcantiBiogas Operational

Lider
Estre
/d/
28/09/2015
Henrique
Novais
Bicalho
Estre
/e/
28/09/2015
Adriano
AlmeidaBiogas Specislist
Estre
Emission
Reductions
calculation
Monitoring report
Monitoring plan
Monitoring methodology
Monitoring data
Implementation status of the
project
Monitoring equipment and
operation
Calibration of equipments
Emission Reductions
calculation


2.3 Resolution of outstanding issues
The objective of this phase of the validation was to resolve any outstanding issues which needed to be
clarified prior to RINAs positive validation opinion on the changes of the project activity as described in the
registered PDD.
A corrective action request (CAR) is raised if one of the following occurs:
The project participants have made mistakes that will influence the ability of the project activity to
achieve real, measurable additional emission reductions.
The CDM requirements have not been met.
There is a risk that the emission reductions cannot be monitored or calculate.

A clarification request (CL) is raised if information is insufficient or not clear enough to determine whether
the applicable CDM requirements have been met.
A forward action request (FAR) is raised during verification for actions if the monitoring and reporting
require attention and/or adjustment for the next monitoring period. CARs, CLs and FARs identified are
included in the verification protocol in Appendix A of this report.


2.4 Internal quality control
The draft final validation opinion before being submitted to the client were subjected to an independent
internal technical review to confirm that all validation activities had been completed according to the
pertinent RINA instructions.
The technical review was performed by a technical reviewer(s) qualified in accordance with RINAs
qualification scheme for CDM validation and verification.
2.5 Validation team and the technical reviewer(s)

The validation team and the independent technical reviewer team have the collective competence
necessary to perform the validation.
The validation team fulfills the following requirements:
qualification for all technical area/s (TAs) related to the activity;
technical experts who provides specific technical, methodological and sectoral knowledge and/or
expertise and qualification for TAs can be involved;
it includes one Team Leader that takes the responsibility to lead the team;
it includes a Validator and in presence of investment analysis a Financial Expert;
at least one member who performs the on-site visit is qualified for all TAs related to the activity;
at least one member who performs the on-site visit is qualified as Team Leader, even if he/she
does not cover this role for the specific activity;
the same person can cover more than one role.
The independent technical reviewer team fulfills the following requirements:
qualification for the CDM scheme and attendance to specific training related to the independent
technical reviewer activity;
qualification for all technical area/s (TAs) related to the activity in case of Final Report.
The validation team members and the technical reviewers consist of the following personnel (refer to the
relevant attachments to see the pertinent qualification certificates):
Role
Last Name
First Name
Site Visit (Yes/No)
Country
Team
Leader/
Technical expert 13.1
De
Lima
Carvalho
Thas
Yes
Brazil
Validator/Verifier
Principe Branco
Saettoni
Geisa Maria
Yes
Brazil
Technical
TA 13.1
Valoroso
Rita
No
Italy
Reviewer
3 VALIDATION FINDINGS
The findings of the validation related to the project, as described in the version 04.5 of 29/02/2016 and
previous PDD version 04.4 of 24/11/2015 and version 4.3 of 20/10/2015 /01/, are stated in the following
sections.
The validation requirements, the means of validation and the results from validating the identified criteria
are documented in more detail in the validation report.


3.1 Project activity details
Project UNFCCC reference
0165
Date of registration
03/03/2006
Title of the project activity
ESTRES Paulnia Landfill Gas Project (EPLGP)
Methodology(ies)
ACM0001 Flaring or use of landfill gas version

13.0.0 of 11/05/2012 /05/
Party(ies) involved
Brazil
Norway
Project Participants
ESTRE Ambiental S/A
Nordic Environment
Finance Corporation
3.2 Reason for permanent changes

Not applicable.
3.3 Changes from the registered PDD

Revised PDD describes that the CGR Paulnia landfill is now under expansion, with neighbour areas
already under ESTREs ownership. With this expansion, the landfill is expected to remain operational until
2023 and its total capacity of waste disposal will be increased from 16 million tonnes (as defined in the
registered PDD of the first crediting period) to 33 million tonnes (due to the fact that the projected year for
landfill closure changed from 2014 to 2023). Due to the that, the GHG emission reductions to be achieved
nd
by the project activity during the 2 7-year crediting period was revised taking into account the approved
expansion of the CGR Paulnia landfill and related forecasted increase in the Municipal Solid Waste
(MSW) stream disposal stream to be annually disposed at the landfill. Rina verified that the change in the
landfill disposal area described in the revised PDD are in accordance with CGR Paulinia Technical Project
Description dated 15/12/2014 /09/. Moreover, the project activity has the applicable environmental licenses
/13/. Rina verified that the revised CERs spreadsheet /14/ correctly considers the landfill operation
expansion until 2023.
The impacts of the changes were assessed and are described below:
(a) The applicability and application of the applied methodology and, where applicable, the applied
standardized baseline under which the project activity or PoA has been registered;
The occurred changes described above, did not cause any impact in the applicability or application of the
applied methodology in the registered CDM project activity.
(b) Compliance of the monitoring plan with the applied methodology and, where applicable, the applied
standardized baseline;
The changes described above did not cause any modification in the monitoring plan.
(c) The level of accuracy and completeness in the monitoring of the project activity or PoA;
The changes described above did not cause any modification in the compliance of the monitoring plan as
explained in item b.
(d) The additionality of the project activity, PoA or CPA;

The change do not impact the additionality since there is no revenue in the project activity other than the
carbon credit.
(e) The scale of the project activity or CPA;
The scale of the project activity is not impacted by the change. Project remains large scale.
(f) The eligibility criteria of PoA.
Not applicable.
As assessed above, in accordance with the project standard, appendix 1, item 6, the post registration
changes do not require prior approval.

10

3.4 Changes from the registered Monitoring Plan
The project activity was registered on 03/03/2006 and renewal crediting period under the approved
baseline and monitoring methodology ACM0001 Flaring or use of landfill gas version 13.0.0 of
11/05/2012 /05/. After the second verification of the second crediting period from 01/10/2014 to 31/07/2015
of the project activity was noticed that the registered monitoring plan /06/ is not in accordance with the
applied monitoring methodology /05/. In accordance with the applied methodology /05/ if LFG is flared
through more than one flare, then PEflare,y is the sum of the emissions for each flare determined separately.
PP included in the revised PDD the provisions to monitor the project emissions for each flare separately.
Section B.6.1 of the revised PDD was updated to include the option C to determine the mass flow of
greenhouse gas i (Fi,t) in accordance with the Tool to determine the mass flow of a greenhouse gas in a
gaseous stream, version 02.0.0 /07/
In the section B.6.2 - Inclusion of the maximum operation temperature of 1,200C in the flare
specifications and in the monitored parameter SPECflare, in accordance with manufacturer technical note,
dated 29/02/2016 /15/.
Moreover, revised PDD included also the provisions to determine the flare efficiency applying Option A
(Apply a default value for flare efficiency) of the methodological tool Project emissions from flaring if the
biannual measurements are not available.
Section B.7.1 was correctly updated to include the description of monitoring the flow rate individually for
each flare in the parameter Vt,db: Volumetric flow of the gaseous stream in time interval t on a dry basis.
Monitored parameter Vt,wb: Volumetric flow of the gaseous stream in time interval t on a wet basis and
vi,t,wb : Volumetric fraction of greenhouse gas methane in a hourly time interval t on a wet basis were
correctly included in the monitoring plan in accordance with the tool Tool to determine the mass flow of a
greenhouse gas in a gaseous stream (Version 02.0.0) /07/.
In addition to the revision of the monitoring plan, PPs have made corrections in the revised PDD that do
not affect the project design.
Fixed parameters available at validation were included in the section B.6.2:
3
- Ru: Universal ideal gases constant in accordance with Default value of 8,314 Pa.m /kmol.K as per the
Tool to determine the mass flow of a greenhouse gas in a gaseous stream (Version 02.0.0) /07/.
- wBM: Weighting of build margin emissions factor, 0.75 (75%) during the 2nd 7-year crediting period in
accordance with the default value as per the Tool to calculate the emission factor for an electricity system
(version 03.0.0) /08/
- wOM: Weighting of operating margin emissions factor, 0.25 (25%) during the 2nd 7-year crediting period in
accordance with the default value as per the Tool to calculate the emission factor for an electricity system
(version 03.0.0) /07/
RINA verified that level of accuracy and completeness of the monitoring is not reduced in the revised PDD
and complies with the applied monitoring methodology /05/ and applicable tool /07/
3.5 Temporary deviations from the registered monitoring plan, monitoring

methodology or standardized baseline

11

th
th
PP is requesting a temporary deviation for the 16 monitoring period 14/09/2013 to 30/09/2014 and 17
monitoring period 01/10/2014 - 31/07/2015 to apply the default value for the flare efficiency. Project activity
was registered under AM0003 Simplified financial analysis for landfill gas capture projects version 3 of
30/09/2005 /10/and renewal crediting period under ACM0001 Flaring or use of landfill gas version 13.0.0
of 11/05/2012 /05/ and has operated with a unique LFG flow meter installed for measuring the amount of
the LFG sent to all the installed high temperature enclosed flares (set of the installed flares). In order to be
in line with the applied methodology /05/ and Tool to determine the mass flow of a greenhouse gas in a
gaseous stream /07/a post registration change is requested as described in the section above.
For the current monitoring period as individual flow meters for each flare were not installed, PPs have
applied a conservative approach for calculating project emissions from flaring (PEflare,y) in accordance with
Option A of the methodological tool Project emissions from flaring /11/ applying the default value of 90%
for flare efficiency.
PP have provided the Biotecnogas technical memory /12/ which describes that all installed flares are
equipped with individual flame detectors (of which in case of no detection of flame in a particular flare
automatically trigger instantaneous closure of the main LFG supply valve for such particular flare, thus
preventing any possibility of LFG venting through that particular flare. PP clarified the operation procedures
to monitor the flare operational specifications (please, see detailed information in the CL 1). Moreover, a
conservative approach will be adopted for the emission reduction calculation, considering that no Emission
Reduction will be claimed with the flares operating in non-conformity with the specified operational
parameters.
During the completeness check the following issues were raised:
Regarding the temporary deviation, the DOE is required to provide more information on how the proposed
deviation to use option A of the tool complies with the tool Project emissions from flaring p. 3 and 4, in
particular:
1) The validation opinion (p 19-20) states that Although the flare manufacturer does not specify a
maximum value for flame temperature, the assumed maximum recommended set point of the flare (in
order to maintain the physical integrity of the flare isolation) is 1,200C. However, the tool requires that the
temperature of the flare (TEG.m) is within the manufacturers specification for the flare (SPECflare) in minute
m. Therefore, the DOE is requested to further substantiate how it has validated that the reported
temperature specifications comply with the manufacturers specifications of the type of installed flare.
2) The validation opinion (p 20-21) states that during the previous monitoring periods where the LFG plant
also operated with only one LFG flow meter installed, the control system of the flaring facility controlled the
LFG supply valve of each individual flare in order adjust the amount of LFG sent in each flare, thus
ensuring overall operation of the LFG flaring facility within the flares operational parameters inter alia in
terms of LFG flow. During such period LFG flaring capacity was programmed to a maximum flaring
3
capacity of 14,000 Nm /h of LFG. However, the tool requires that the flow rate of the residual gas to the
flare (FRG,m) has to be is within the manufacturers specification for the flare (SPECflare) in minute m.
Therefore, the DOE is required to further substantiate i) whether the maximum flaring capacity of 14,000
Nm3/h is within the manufacturer specifications, and ii) how flow rate of residual gas to the flare (FRG,m) has
been monitored as per the tool.
In order to address the issues RINA has amended the CL 1 to provide more detail how the manufacturer
specifications of the flares operation will be considered in the temporary deviation. Manufacturer has
provided technical note, dated 29/02/2016 /15/ to support the manufacturers specification.
PDD was revised to version 04.5 of 29/02/2016 to include the maximum operation temperature, in
accordance with the manufacturer technical note, dated 29/02/2016 /15/
Rina verified that the proposed deviation is not reducing the accuracy of the calculation of emission
reductions, as project participants will apply conservative assumptions to ensure that emission reductions
will not be overestimated as a result of the deviation.
12
4 VALIDATION OPINION
RINA Services Spa (RINA) has performed a validation of post registration changes for the project activity
ESTRES Paulnia Landfill Gas Project (EPLGP) in Brazil, CDM Registration Reference N 0165. The
validation has s based on the information made available to us.
RINA has performed this validation on the basis of the following documents:
CDM Executive Board: Clean Development Mechanism Project Cycle Procedure, version 09 of
20/02/2015;
CDM Executive Board: Clean Development Mechanism Project Standard, version 09 of

20/02/2015
CDM Executive Board: Clean Development Mechanism Validation and Verification Standard,
version 09 of 20/02/2015
Approved baseline and monitoring methodology ACM0001 Flaring or use of landfill gas version
13.0.0 of 11/05/2012
It is RINAs opinion, the changes, as outlined in the revised PDD version 04.5 of 29/02/2016, from the
project activity as described in the registered PDD ensure that the level of accuracy and completeness in
the monitoring and verification process is not reduces as a result of the revision; the revisions are in
accordance with the applied monitoring methodology and the changes to the project activity comply with
the requirements established in the CDM Project Standard.
Hence RINA requests that the post registration changes from the project activity as described in the
registered PDD for the project activity ESTRES Paulnia Landfill Gas Project (EPLGP) in Brazil may be
considered by the Board.
Sao Paulo, 29/02/2016
Genova, 01/03/2016
Thais de Lima Carvalho

CDM Team Leader
RINA Brasil Servicos Tecnicos LTDA
Laura Severino
Authorized officer signing for the DOE
RINA Services S.p.A

13
APPENDIX A

1-A

TABLE - RESOLUTION OF CORRECTIVE ACTION REQUESTS AND CLARIFICATION REQUESTS
Corrective action and/ or clarification requests
CAR 1
Revised PDD describes the updated information
regarding the landfill expansion and forecast to
receive 5 tonnes of waste per day from 2016 and
closure in 2023. As there will be a change in the
project design of the landfill and consequently in
the baseline emissions estimative PP is requested
to follow the provisions described in the section
13.8.3.5 Changes to the project design of a
registered project activity or programme design of
a registered programme of activities
and
appendix 1 of the project standard.
Reference to Section
of the report
3.3

Response by project participants
Validation Conclusion
The performed revision in the ex-ante

estimates of GHG emission reductions to
be achieved by the project activity during
nd
the 2
7-year crediting period is
performed by taking into account the
approved expansion of the CGR Paulnia
landfill and related forecasted increase in
the Municipal Solid Waste (MSW) stream
disposal stream to be annually disposed
at the landfill. Moreover, as a response of
the raised CAR, it is addressed as a
permanent change in the project design in
the revised PDD. Moreover, a disclaimer
was included in Section B.6.4 of the
revised PDD justifying that this occurred
change does not affect the previously
identified baseline scenario, scale of the
project
activity
and
previously
demonstrated additionality.
Revised PDD describes the permanent

changes. GHG emission reductions to be
achieved by the project activity during the
nd
2 7-year crediting period is performed by
taking into account the approved
expansion of the CGR Paulnia landfill
and related forecasted increase in the
Municipal Solid Waste (MSW) stream
disposal stream to be annually disposed
at the landfill. Rina verified that the
change in the landfill disposal area
described in the revised PDD are in
accordance with CGR Paulinia Technical
Project Description
dated 15/12/2014
/09/.
The impacts of the changes were
assessed and are described below:
(a) The applicability and application of the
applied
methodology
and,
where
applicable, the applied standardized
baseline under which the project activity
or PoA has been registered;
The occurred changes described above,
did not cause any impact in the
applicability or application of the applied
2-A

of the report
methodology in
project activity.
the
registered
CDM
(b) Compliance of the monitoring plan

with the applied methodology and, where
applicable, the applied standardized
baseline;
The changes described above did not
cause any modification in the monitoring
plan.
(c) The level of accuracy and
completeness in the monitoring of the
project activity or PoA;
The changes described above did not
cause any modification in the compliance
of the monitoring plan as explained in
item b.
(d) The additionality of the project activity,
PoA or CPA;
The change do not impact the
additionality since there is no revenue in
the project activity other than the carbon
credit.
(e) The scale of the project activity or
3-A

of the report
CPA;
The scale of the project activity is not
impacted by the change. Project remains
large scale.
(f) The eligibility criteria of PoA.
Not applicable.
This CAR is closed
CAR 2
Revised PDD updated the CERs estimative
considering the expansion of the landfill operation
until 2023, however, the estimative of waste
disposal was not updated in the table 8 of the
revised PDD
CAR 3
Revised PDD did not update section B.7.3 figure
4- Monitoring equipments location, to include the
meters for each flare. Moreover, the subsection
2.1 LFG flow, describes only 4 flares in the project
activity.
CAR 4
Revised PDD did not update the information
provided in Annex 4- table Key parameters
(projected year of landifil closure). Moreover, the
table do not consider the 10% discount in the flare
efficiency due to the low height flares installed.
3.3
3.4
3.4

As a response of the raised CAR, Table 8

of the revised PDD was updated to
include the forecasted amounts of MSW
to be disposed in the CGR Paulnia
landfill during the years from 2016 to
2023.
As a response of the raised CAR, section
B.7.3 figure 4- Monitoring equipments
location was updated in the revised PDD,
as well as subsection 2.1 LFG flow,
correcting the number of flares to 6.
Table 8 was revised accordingly.
The projected year for the landfill closure

was updated in appendix 4 of the revised
PDD.
Regarding the 10% discount it is only
applicable in the calculation of the Option
A Default Value for the Flare Efficiency of
the Methodological Tool Project emission
The Annex 4- table was revised

accordingly. PP clarified that the flare
efficiency considered in the table are from
manufacturer and the 10% discount due
to the low heigh flare will be considered in
the ex-post calculation.
This CAR is closed.
Figure 4 was revised and presents the

meter for each flare.
This CAR is closed
4-A

of the report

from flaring Version 02.0.0. The
mentioned table Key Parameters that
mentions 97% as Flare efficiencies (%)
operational data from flare manufacturer
refers to the minimum efficiency that is
assured by the flare manufacturer, and
not to the low height flares 10% discount.
Moreover PP mentioned in the PDD that
the flares installed are indeed low height
flares, thus the 10% discount will be
applied during the ex-post calculations of
Emission Reductions. It is also important
to mention that, according to the
methodology and methodological tools
used, the flare efficiency is not used in the
ex-ante
calculations
of
Emission
Reductions.
CL 1
PP is requested to clarify the quality control
quality assurance procedure to guarantee that the
biogas is burnt within the flares specifications
(temperature and flow) in all flares that are
operational at the same time.
3.5

Regarding
the
flare
operational
requirements of the flares in terms of
temperature, it is crucial to note that each
flare
is
equipped
with
individual
temperature meter (that measures the
temperature of the flame). Depending on
measurements of the temperature of the
flare, the air-LFG mixture is adjusted
through automatically opening and/or
closure of the air damper window located
in the bottom of the flare in order to have
This CAR is closed
PP clarified the operation procedures to

monitor
the
flare
operational
specifications. Moreover, a conservative
approach will be adopted for the emission
reduction calculation, considering the flare
specifications.
Flare manufacturer Biotecnogs s.r.l as
an answer to the request made by the
Project Participant, issued a TECHNICAL
NOTE /15/, where it is possible to confirm
that the maximum flare operation
5-A

of the report
the fuel-air mix adjusted and temperature

increased or decreased in order to have it
within
the
specified
operational
requirements.
Flare manufacturer Biotecnogs s.r.l as
an answer to the request made by the
Project Participant, issued a TECHNICAL
NOTE informing that:
temperature is 1200 C (the parameter

SPECflare and flares characteristics in
Section A.3 were also revise in the PDD).
For the flow, during the deviation period,
LFG flaring capacity was programmed to
a maximum flaring capacity of 14,000
3
Nm /h of LFG, considering the nominal
flow for flare 1 and flare 2 is 2,000 Nm/h
Maximum flaring temperature: 1,200 C.

Rationale:
By taking into consideration inter alia the
material and dimensions/geometrics (e.g.
diameter and height) of the flares body;
design and operation rationale/logic for
theair intake windows located in the lower
section of the flares, design of the flares
ceramic revetment material, design and
location of the flares ancillary and safety
instruments (e.g. thermocouples, and
ultra-violet (UV) flame detectors); we at
Biotecnogas s.r.l. state and recommend
that the high temperature enclosed flares
installed as part of the landfill gas
destruction facility implemented at the
CGR Paulnia landfill are operated with
temperature of exhaust gases in the flares
within the range from 850 C to 1,200 C
in order to ensure as direct outcome of
and for flares 3, 4, 5 and 6 is 2,500 Nm/h

(Nominal flow were confirmed during the
onsite visit in the flares plate) and
Biotecnogs s.r.l technical note /15/.
The technical note also describes that

that the facilitys automated control and
safety system was designed and
configured by Biotecnogas s.r.l. in order
to ensure that the installed set of high
temperature flares be prevented of
operating not under accordance with the
operational criteria and requirements
applicable for such main LFG combustion
units (e.g. including inter alia maximum
stream flow of LFG to the set of installed
flares of 14,000 Nm3/h), and also to
prevent any LFG venting (a shut off valve
closes automatically whenever the flame
is not detected in the flare)
In addition, PP clarified that a
conservative measure, the Emission
6-A

of the report
their operation, achievement of high CH4

destruction
rate,
achievement
of
acceptable/reduced levels of emissions of
NOx and other undesirable pollutants and
avoidance of premature degradation/wear
of the flares ceramic revetment material..
Reduction calculations will apply a criteria

to discount all the Emission Reductions
generated by the LFG flaring facility
during the periods where one or more
flares operate outside the specified
operational parameters, thus assuring
that no Emission Reduction is claimed
with the flares operating in non-conformity
with the specified operational parameters
for the LFG flow and temperature.
Therefore if one of the flares is not
operational in accordance with the
manufacturer specifications for the
temperature, all the flow (measured by
one flow meter) will not be considered in
the emission reduction calculation, an
conservative approach.
Thus, with this new clarification, Project

Participants corrected the registered PDD
(Version 4.2 of 24/06/2013) in order to
include this maximum temperature
parameter as part of the monitored
parameter SPECflare, as well as in the
flares characteristics in Section A.3.
Moreover the flare manufacturer also
stated in the mentioned TECHNICAL
NOTE that:
We also clarify that as per the
configuration of the LFG destruction
facility at the CGR Paulnia valid from
14/09/2006, the date of start of operations
until
31/07/2015
(date
when
a
new/revised design and configuration for
LFG flow monitoring infrastructure was
implemented by ESTRE Ambiental S/A),
the facility operated on the basis of an
automated control and safety system
Rina verified that the proposed deviation

is not reducing the accuracy of the
calculation of emission reductions, as
project participants will apply conservative
assumptions to ensure that emission
reductions will not be overestimated as a
result of the deviation
This CL is closed
7-A

of the report
designed by Biotecnogas s.r.l. including

main components such as automated
frequency inverter for the electrical motors
of the centrifugal blowers that were
configured for the facility, automatic
controlled step motors for adjusting the
position of the air inlet window for each
one of the flares, a programmable logic
controller unit (PLC unit) exclusively
designed/configured for the facility and
input signals from monitoring and safety
sensors (e.g. flow meter measuring the
flow of LFG stream the set of flares,
temperature sensor for measuring the
temperature of LFG stream to the flares,
pressure sensor for measuring the
pressure of LFG stream to the flares,
etc.). Such facilitys automated control
and safety system was designed and
configured by Biotecnogas s.r.l. in order
to ensure that the installed set of high
temperature flares be prevented of
operating not under accordance with the
operational criteria and requirements
applicable for such main LFG combustion
units (e.g. including inter alia maximum
stream flow of LFG to the set of installed
flares of 14,000 Nm3/h), and also to
prevent any LFG venting (a shut off valve
8-A

of the report
closes automatically whenever the flame

is not detected in the flare). Regarding
such previously defined nameplate value
of maximum LFG flow to the set of flares,
by taking into account the overall design
and operation rationale/logic for the
facility as a whole (incl. the facilitys
automated control and safety system),
such previously defined value of
maximum stream flow of LFG to the set of
installed flares was conceived/determined
by taking as a requirement that all
installed flares would operate within their
operational conditions/requirements under
such maximum LFG flow range. It is
important to note that the facilitys
automated control and safety system
ensure, under a certain limit, that the
amount (flow) of LFG sent to the set of
flares are appropriately distributed among
the flares (by also taking into account the
specifications of the installed flare models
2000 HT and 2500 HT.
Thus it is possible to conclude that the
flaring plant is designed to operate within
the manufacturer specifications.
It is also important to note that during the
previous monitoring periods where the
9-A

of the report
LFG plant also operated with only one

LFG flow meter installed, the control
system of the flaring facility controlled the
LFG supply valve of each individual flare
in order adjust the amount of LFG sent in
each flare, thus ensuring overall operation
of the LFG flaring facility within the flares
operational parameters inter alia in terms
of LFG flow. During such period LFG
flaring capacity was programmed to a
maximum flaring capacity of 14,000
3
Nm /h of LFG.
Moreover, as a conservative measure, the
Emission Reduction calculations will apply
a criteria to discount all the Emission
Reductions generated by the LFG flaring
facility during the periods where one or
more flares operate outside the specified
operational parameters, thus assuring
that no Emission Reduction is claimed
with the flares operating in non-conformity
with the specified operational parameters

10-A

TABLE - FORWARD ACTION REQUEST
Forward action request
Reference to Table 2
FAR 1

11-A
CERTIFICATO DI QUALIFICA
QUALIFICATION CERTIFICATE
Thais De Lima Carvalho
Si attesta che il sig./sig.ra:

We declare that Mr/Mrs/Ms:
1
CDM -TEC, -VAL, -VER, -TL
qualificato come :
is qualified as:
1.1, 1.2, 2.1, 13.1
per le seguenti aree tecniche:

for the following technical areas:
AREE TECNICHE
TECHNICAL AREAS
1.1
1.2
2.1
13.1
DESCRIZIONE DELLAREA TECNICA

TECHNICAL AREA DESCRIPTION
Thermal energy generation
Renewables
Electricity distribution
Solid waste and wastewater
SCOPO SETTORIALE
SECTORAL SCOPE
1
1
2
13
in accordo alle istruzioni della Divisione Certificazione.

in accordance with the instructions of the Certification Division.
REVISIONE
REVISION
0
12
DATA
DATE
19-08-2009
15-01-2015
MOTIVAZIONI PER LA REVISIONE

REASON FOR THE REVISION
Added TA 2.1
Il Resp. QPT
Head of QPT
Legend:
VAL:
Validator
CDM: Clean Development Mechanism
VER:
Verifier
VCS : Verified Carbon Standard:
TEC:
Technical Expert
GS: Gold Standard
TL:
Team Leader
SCS: SocialCarbon Standard
FIN-EXP:
Financial Expert
JI: Joint Implementation
DET:
Determiner
RINA Services S.p.A. accreditato da UNFCCC, quale Entit Operativa Designata (DOE), per condurre la Validazione e la Verifica di Progetti CDM, da
VCSA per condurre la Validazione e la Verifica di Progetti VCS, da GS Foundation, per condurre la Validazione e la Verifica di Progetti GS, da Ecologica
Institute per condurre la Validazione e la Verifica di rapporti SCS
RINA Services S.p.A. is accredited by the UNFCCC, as Designated Operational Entity (DOE), to carry out Validation and Verification of CDM Projects, by
the VCSA, to carry out Validation and Verification of VCS Projects, by the GS Foundation, to carry out Validation and Verification of GS Projects and by
the Ecologica Institute, to carry out Validation and Verification of SCS Reports
GHG_QUAL_CERT_EN_04_12
Page 1 of 1
Geisa Maria Principe Branco Saettoni

qualificato come1:
is qualified as:
CDM-TEC, VAL, VER, TL

AREE TECNICHE
TECHNICAL AREAS
1.1
1.2
13.1
1.1, 1.2, 13.1

Thermal Energy generation
Energy generation from renewable energy sources
Waste Handling and Disposal
SCOPO SETTORIALE
SECTORAL SCOPE
1
1
13

REVISIONE
REVISION
0
9
DATA
DATE
27-08-2009
17-07-2015

Updating qualification according AS version 6
Il Resp. QPT
Head of QPT
Legend:
VAL:
Validator
VER:
Verifier
TEC:
Technical Expert
GS: Gold Standard
TL:
Team Leader
FIN-EXP:
Financial Expert
DET:
Determiner
Page 1 of 1
Rita Valoroso

CDM -TEC, -VAL, -VER, -TL

TECHNICAL REVIEWER
qualificato come1:
is qualified as:
1.2, 13.1

AREE TECNICHE
TECHNICAL AREAS
1.2
13.1

Renewables
Solid Waste and waste water
SCOPO SETTORIALE
SECTORAL SCOPE
1
13

REVISIONE
REVISION
0
9
DATA
DATE
18-01-10
22-12-2014

Update qualification according to AS ver.6.0
Il Resp. QPT
Head of QPT
Legend:
VAL:
Validator
VER:
Verifier
TEC:
Technical Expert
GS: Gold Standard
TL:
Team Leader
FIN-EXP:
Financial Expert
DET:
Determiner
Page 1 of 1

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VALIDATION OPINION

POST REGISTRATION CHANGES

Validation Opinion N 2015-BQ-41-MD

Validation Opinion Post Registration Changes, N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

CDM Registration Reference

ESTRES Paulnia Landfill Gas Project Brazil

ESTRE Ambiental S/A

Mr. Adriano Francisco de Almeida

Date of this report:

Approved by (Final Report Authorized officer signing for the DOE):

Flaring or use of landfill gas

Work carried out by:

Thas de Lima Carvalho

No distribution without permission from the Client or

Work verified by (Final Report)

Climate Change, Kyoto

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

VALIDATION FINDINGS .......................................................................................................... 8

VALIDATION OPINION .......................................................................................................... 13

Appendix A: Validation Protocol

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

2.1 Document Review

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

CDM Executive Board: Clean Development Mechanism Project Standard, version 09 of

CGR Paulinia Technical Project Description dated 15/12/2014 (MEMORIAL DESCRITIVO.pdf)

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

Name and Role

Raul P. CavalcantiBiogas Operational

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

The CDM requirements have not been met.

There is a risk that the emission reductions cannot be monitored or calculate.

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

2.5 Validation team and the technical reviewer(s)

Site Visit (Yes/No)

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

Title of the project activity

ESTRES Paulnia Landfill Gas Project (EPLGP)

ACM0001 Flaring or use of landfill gas version

ESTRE Ambiental S/A

3.2 Reason for permanent changes

3.3 Changes from the registered PDD

VALIDATION OPINION POST REGISTRATION CHANGES

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

3.5 Temporary deviations from the registered monitoring plan, monitoring

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES

VALIDATION OPINION POST REGISTRATION CHANGES

CDM Executive Board: Clean Development Mechanism Project Standard, version 09 of

Sao Paulo, 29/02/2016

Thais de Lima Carvalho

Validation Opinion Post Registration Changes N 2015-BQ-41-MD, REV. 1.2 AA

VALIDATION OPINION POST REGISTRATION CHANGES