I-DEV0433: Request for deviation on the monitoring of the wastewater volume (Qy,ww)

The request for deviation is for a registered CDM project activity “AIN08-W-03, Methane Recovery in Wastewater Treatment, Sumatera Utara, Indonesia” (project reference number 2633), which is registered against AMS-III.H (version 9) on 12/11/2009. During the first periodic verification, as per the requirement of VVM para 210, SIRIM QAS Intl. found that the project participant (PP) had deviated from the provisions of the registered monitoring plan. The deviation was as follows:

In accordance with the monitoring plan of the registered PDD (page 22), the volume of wastewater treated Qy,ww is to be monitored continuously using a flowmeter. During the on-site verification, it it was found that there were no recorded data from the flowmeter for Qy,ww.

Thus, for the period from 1 March 2010 and 28 February 2011, PP had used the following formula to estimate the total volume of wastewater treated:

Qy,ww = fresh fruit bunches (FFB) processed x effluent conversion factor (ECF)... (Equation 1)

The reason for the deviation was that in the original PDD submitted for registration to the UNFCCC, EB defined the volume of wastewater using Equation (1). During the registration process, a Request for Review (F-RR-CDM dated 20/08/2009) was issued where PP was required to install a flowmeter to measure the volume of the wastewater treated. The monitoring plan of the PDD was reviewed and included the monitoring of this parameter using a continuous flowmeter. Subsequent to the registration of the project on 12/11/2009, an appropriate wastewater flowmeter was sourced, tested, and installed, a process which took several months. The meter was installed on 7/07/2010. During the initial installation, the flow meter was not connected to any data logger. Connection to the data logger had only been done in September 2010 and the first data was recorded on 3/09/2010. However, data recorded from the data logger was found to be abnormal as the results were too low. It was determined that this was due to the fact that the flow meter encountered a forced outage caused by its data cable, and there was a need for it to be replaced or repaired. Due to remoteness of the project activity site and the time required in procuring the flow meter, the new flow meter was only installed in June 2011.

The deviations do not require revision of the monitoring plan or change from the project activity, as the monitoring of Qy,ww is already in accordance with the approved monitoring plan described in the registered PDD. The flow meter has been in operation beginning from the 16/06/2011 onwards.

PP had proposed that during this monitoring period (i.e. from 1 March 2010 to 28 February 2011), the amount of wastewater treated (Qy,ww) will be calculated as follows:

Qy,ww = fresh fruit bunches (FFB) processed x effluent conversion factor (ECF)

Data from the palm oil mill will be used for the FFB processed, while for ECF, the value shall be determined using these three methods :
i) an approach taken from publications released by the Depatment of Environment, Malaysia where the ECF is defined as the amount of wastewater generated by the mill (in m3) divided by the amount of fresh fruit bunches (in tonnes FFB); or
ii) adopt the average ECF for palm oil mills operation,as 0.7m3 per tonne of FFB processed, provided in the same publication referred above; or
iii) employ the ECF based on original wastewater treatment system design as stated in the Environmental Impact Analysis (EIA) for the said mill.
The methodology, AMS-III.H (version 9) clearly specifies that the monitoring of the amount of wastewater treated shall be done via a continuous flow meter. The installed flow meter was already in operation, thus this deviation does not change the applicability of the methodology.

In accordance with paragraph 34 of AMS-III.H (version 9); for the cases of (ii), (iii), (iv) and (vi), the calculation of emission reductions shall be based on the amount of methane recovered and fuelled or flared, that is monitored ex-post. Also for these cases, the 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 (COD removed is the difference between the inflow COD(CODy,ww,untreated) and outflow COD (CODy,ww,treated)), compared with the technology used in the baseline.

The amount of methane produced per unit of COD removed in the baseline was determined as 0.17. In order to address the requirement in paragraph 34, PP had calculated the required using all three ECFs and the results were summarized as below.

Reference/Method: Method no. 1 Measurement campaign done by PP from 16/06/2011 to 31/07/2011
Effluent conversion factor(m3/ tonnes FFB) = 0.95
Paragraph 34 demonstration = 0.08

Reference/Method: Method no. 2 Publication by the Department of Environment, Malaysia
Effluent conversion factor(m3/ tonnes FFB) = 0.70
Paragraph 34 demonstration = 0.10

Reference/Method: Method no. 3 Design capacity as in the Environmental Impact Analysis (EIA) for PT Permata Hijau Sawit
Effluent conversion factor(m3/ tonnes FFB) = 0.55
Paragraph 34 demonstration = 0.13

Based on the presented data, it was determined that all results were below 0.17. Thus, it can be concluded that the technology implemented does not increase the amount of methane produced per unit of COD removed compared with the technology used in the baseline.

It can also be established that the lowest ECF from the proposed method i.e. Method no. 3 with ECF equal to 0.55m3/tonne of FFB, will gave the most conservative measure in fulfilling the paragraph 34 requirement. With this, we can also conclude that the deviation request has no impact on the emission reduction.