I-DEV0412: Request for deviation in the approach to determine the value for the parameter “Feed Water Load” (ID No. – D3(b) – 2.5) in absence of the monitored data for the same parameter as per the requirement of registered PDD

According to the registered CDM-SSC-PDD/Reference No.0266, section D.3 of the registered project documentation requires the project proponent to measure the Feed Water Load online as per the Table ID No. D 3(b) 2.5 and the measured data to be used in the Emission Reduction calculation.

The project activity under consideration is currently claiming the retroactive CERs for the monitoring period 01/04/2001 up to 31/03/2006, this monitoring period is prior to the project registration date with UNFCCC i.e. 14/04/2006 (http://cdm.unfccc.int/Projects/DB/SGS-UKL1139821468.24/view). Hence, the Feed Water Load could not be monitored as per the registered PDD. Therefore, this deviation is proposed to calculate the Feed Water Load using the monitored data of steam load and a conservative estimation of steam blow down of 3%. As per the proposed deviation, the Feed Water Load will be calculated by addition of steam blow down to the monitored steam load. The value of 3% blow down has been considered on conservativeness principle and has been demonstrated to be appropriate for the proposed deviation.

During the monitoring period (i.e.01/04/2001 up to 31/03/2006) under consideration, the quantity of feed water used for emission reduction calculation is determined from the steam generation data considering a maximum (standard) blow down of 3% as per the ex-ante calculation procedure. This ex-ante procedure is also evident through the discussion made in the validation report – (replies to NIR-4: Energy Output Data/Paragraph-(b)’ of the Annex-6: Findings. Please refer to http://cdm.unfccc.int/Projects/DB/SGS-UKL1139821468.24/view for project docs during validation). As per this finding,“The total feed water enthalpy calculations are based on the feed water load (which is based on the assumption of 3% blow down to be on a conservative basis), feed water temperature and feed water enthalpy. Please note that the maximum blow down for the Boiler System is 3%. Therefore for all calculations the Blow down has been assumed to be 3% in order to be conservative. This assumption would be applicable for both the baseline scenario and project scenario because the source and quality of feed water will not alter for both the scenarios”.

However, the project participant wishes to clarify that feed water load is being measured through the water flow meter since post-Validation period. The water flow meter was Installed on 01/04/2006 and the feed water consumption data is being measured on a daily basis from 01/04/2006 onwards. The same was verified with the Certificate of Installation & Commissioning by Rockwin Flowmeter India Pvt. Ltd., dated 05/04/2006.The measured feed water values will be utilised for emission reduction calculation for the consecutive monitoring periods in accordance with the requirement of registered PDD. Hence, it was considered appropriate to propose the deviation for the concerned monitoring period (i.e.01/04/2001 up to 31/03/2006).

Determination of feed water load for the monitoring period 01/04/2001 to 31/03/2006 using the approach provided in the proposed deviation

During the verification of the monitoring period (01/04/2001 to 31/03/2006), it was observed by the assessment team that the feed water load was not monitored using flow meter (ID No – D3(b) 2.5) which was the requirement of the registered PDD. Hence, the deviation is proposed by the PP to estimate the feed water load using the steam load monitored data obtained during the relevant monitoring period (i.e. 01/04/2001 to 31/03/2006).

It was verified by the assessment team from the ER calculation sheet that there exists inverse relationship between the parameter “Feedwater Load” and the resultant Emission Reductions. The Emission Reductions will be the most conservative when the maximum value for the parameter “Feedwater Load” is used. Therefore, it was found appropriate by the assessment team to use ex-ante value for steam blow down ratio of 3% as a conservative approach with respect to ER calculations. The standard blow down of 3% has been periodically cross-checked by conducting ‘Blow Down Test’ every month with steam generation data and the corresponding feed water consumption data by the project participant. The feed water consumption data for the period of ‘Blow Down Test’ is measured with the help of a Water Flow Meter. The test certificate of the Water Flow Meter provided by the manufacturer during the purchase of the equipment ensured the accuracy of the ‘Blow Down Test’.

The test certificate for water flow meter and the blow down test reports have been checked and those substantiate that the actual blow down is in the range of 2.82% to 2.88%. Therefore consideration of a standard blow down of 3% ensures a conservative computation of emission reductions resulting from the project activity over the monitoring period (01/04/2001 to 31/03/2006) under consideration.

The average Blow Down test reports as made available in the following link: http://cdm.unfccc.int/Projects/DB/SGS-UKL1139821468.24/iProcess/SGS-UKL1199458113.28_W1/view

The values of Average Blow Down by S K Dutta, PE, Consultant Engineers, a third party firm, for April 2005 is 2.83%, for May 2005 it is 2.85%, For June 2005 it is 2.82%, For July 2005 it is 2.87%, August it is 2.83%, For September 05 it is 2.87%, For October 05 it is 2.87%, For November 05 it is 2.87%, For December it is 2.88%, For January 2006 it is 2.88%, For Feb 2006 it is 2.87%, and for March 06 it is 2.88%. On the conservative side, the PP has considered the Blow Down as 3% which is on the higher side hence conservative and accepted.

Furthermore, the feed water load is being directly measured on a daily basis through the Water Flow Meter (Make: Rockwin; Serial No. : 22569) installed at the feed water line from 01/04/2006 onwards which is inline with registered PDD. This direct measurement procedure and on site instrumentation has been physically verified during the verification site visit on 08/11/2010. Feed water consumption is being directly monitored by the water flow meter as verified and the data will be made available during subsequent monitoring periods.

Therefore, this deviation in the approach to determine the feed water load during the monitoring period (01/04/2001 to 31/03/2006) is appropriate and does not require a revision to the approved monitoring plan for the proposed project activity.

Determination of feed water load for the monitoring period 01/04/2001 to 31/03/2006:

The deviation adopted for feed water load during the pre registration retroactive monitoring period 01/04/2001 to 31/03/2006 does not have impact on the estimates of the emissions reductions with reference to the registered PDD. This is because, the ex-ante determination of the emission reduction is also based on the Feed Water Load data, which has been calculated from the steam generation data considering a maximum blow down of 3%. This is evident through the discussion made in the validation report. The average Blow Down test reports as made available in the following link:

http://cdm.unfccc.int/Projects/DB/SGS-UKL1139821468.24/iProcess/SGS-UKL1199458113.28_W1/view
Equations from the registered PDD has been incorporated here in the deviation form to demonstrate the mathematical relation of the parameter under deviation with the ER calculations as follows:
 Emission Co-efficient of Coal = (Fixed carbon content in coal*44/12)/GCV
 Heat energy input = Quantity of coal used*GCV*1000
 Steam Enthalpy = (2778.7*0.239)*Steam Load*1000 (Specific enthalpy of steam at a pressure of 8.83 bar and at a temperature of 177 deg C is 2778.7 kJ/kg and the conversion factor of kilo joule to kilo calorie is 0.239 i.e. 1 kilo joule = 0.239 kilo calorie.)
 Output Enthalpy = Steam Enthalpy – Feed Water Enthalpy
 Feed Water Enthalpy = Feed Water Enthalpy (KJ/Kg) *0.239*Feed Water Load*1000
 Boiler Efficiency = Output Enthalpy/Heat Energy Input*100
 Baseline Technical Losses = Output Enthalpy*{(100/Baseline Boiler Efficiency)-1}
 Technical Losses = Heat Energy Input – Output Enthalpy
 Reduction in Losses = Baseline Technical Losses - Technical Losses
 Coal Reduction = Reduction in Losses/GCV
 Emission Reduction = Reduction in Losses*Emission Co-efficient of Coal/1000
From the above equations it is very transparent that the Feed water load data is required to calculate feed water enthalpy, which has a direct impact on output enthalpy. The output enthalpy is required to obtain the Technical losses and this loss is accounted to calculate reduction in losses and reduction in losses is directly proportional to the emission reduction value. Previously this calculation was based on the blow down losses assuming 3% maximum, however monitored data for feed water load was found below 3% from the test reports of “Blow Down Test”. This test was carried out on monthly basis not daily and test reports show the value in the range of 2.82% to 2.88%, which is below the value of 3%,hence 3% is conservative. Emission reduction calculation excel sheet is available at the following web link: http://cdm.unfccc.int/Projects/DB/SGS-UKL1139821468.24/iProcess/SGS-UKL1199458113.28_W1/ReviewInitialComments/OFJ4S6VJKCRIINNP3DIWOR91QI7R7I