I-DEV0430: Deviation from Monitoring Plan for parameter volume of wastewater treated

During the second verification period of the registered CDM project activity (AMA08-W-23, Methane Recovery in Wastewater Treatment, Sarawak, Malaysia, CDM Ref. No. 2635), Det Norske Veritas identified a deviation in the monitoring report with respect to the monitoring plan of the project. The monitoring period covered by this verification is from 01 August 2010 to 30 April 2011. The deviation from the registered monitoring plan (registered on 13 November 2009) is regarding the volume of wastewater treated (Qy,ww). This is the second deviation requested for the same parameter. The earlier accepted deviation (I-DEV0381) is applicable to the first verification period of the project and the request was due to the delayed installation of flow meter for Qy,ww and electricity meter. The current request for deviation is due to parameter Qy,ww¬ which has not been monitored continuously via flow meter; as required by the registered monitoring plan; from 20 November 2010 to 28 February 2011 due to faulty flow meter.

The project design document (PDD) submitted for registration defined the ex-post monitored volume of wastewater treated using an approach taken from a publication by the Malaysian Department of Environment (DOE) [1]. In the publication, palm oil mill effluent (POME) conversion factor is used to estimate the volume of wastewater treated. The conversion factor is the ratio between volume of wastewater from a typical palm oil mill and the amount of fresh fruit bunch processed and the unit is m3/ton FFB.

The following is the determination of Qy,ww for the period where there is a lapse in measurement and monitoring:

Qy,ww = POME conversion factor (m3/ton FFB) x vintage FFB processed (ton)

DNV has made a comparison of methane produced per COD removed by applying a conversion factor (CF) to actual monitored Qy,ww. It has been concluded that applying a CF is conservative as the methane produced per COD removed for monitored months would have been higher.

There are two options for POME CF. One is the industry default of a typical facility of 0.70 m3/ton FFB [1] and the second option is the site specific CF. Site specific POME CF (1.77 m3/ton FFB) is based on the actual monitored data of the wastewater flow meter obtained from the monitored months (from 01 August 2010 to 19 November 2010 and from 1 March 2011 until the end of this monitoring period 30 April 2011), divided by actual measured quantity of FFB processed during the same period [2]

Vintage FFB processed (ton) is the actual amount of fresh fruit bunches processed for this monitoring period which has been evidenced from the mill records [3].

A comparison was made using both the CF of a typical facility of 0.7 m3/ton FFB and the site specific CF of 1.77 m3/ton FFB and it was found that the methane produced per unit of COD removed is higher by 22.8% when using the CF of 0.7 m3/ton FFB. Hence the present request for deviation is to use a CF of 0.7 m3/ton FFB for the calculation of Qy,ww for the deviation period.

Supporting files
[1] 'Department of Environment, Ministry of Science, Technology and the Environment, Malaysia: Industrial Processes & The Environment (Handbook No. 3) - Crude Palm Oil Industry, December 1999'
[2] 'RH-POME Flow vs FFB Aug 2010 - Apr 2011-ver1.0.xls'
[3] 'FFB Processed July 2010 - April 2011.pdf' and 'MY0064WWP-RH-FFB (2008-May 2010).pdf'

The proposed deviation from the monitoring plan does not require a revision of the monitoring plan or changes from the project activity as described in the registered PDD as the deviation is only for a specific period in the second periodical verification. The monitoring period covered by the second verification is from 01 August 2010 to 30 April 2011. It is confirmed that there are no permanent changes to the project activity as described in the registered PDD.

The impact of this deviation request for parameters as explained above is as follows:
The proposed deviation does not impact the emission reductions of the project as this parameter is only used for the demonstration of methane produced per unit of chemical oxygen demand (COD) removed. The emission reduction of the project activity is based on the actual amount of methane destroyed by the project. Based on the registered PDD and validation report, in the event that methane produced per unit of COD removed is higher than the baseline, project emissions would have to be deducted from the emission reduction. This is in line with paragraph 34 of the applied methodology (AMS-III.H version 9) which states that project emissions and leakage will be deducted from the emission reductions calculated from the methane recovered and combusted, except where it can be demonstrated that the technology implemented does not increase the amount of methane produced per unit of COD removed.
Cross-checking shows that applying the CF of a typical facility of 0.7 m3/ton FFB to the monitored months yields the average methane produced per unit of COD removed (0.11 tonneCH4/tonneCOD) that is lower than the baseline (0.17 tonneCH4/tonneCOD [4]), which was demonstrated in accordance to the requirements from paragraph 34 of AMS-III.H. version 9. Hence, this deviation request has no impact on the emission reduction in this deviation period and is deemed reasonable.

[4] RH-Deviation.xls