I-DEV0441: Deviation on the monitoring wastewater volume prior to installation of wastewater flow meter

The request for deviation is being applied for the registered CDM project activity titled “ID08-WWP-09, Methane Recovery in Wastewater Treatment, Aceh, Indonesia” with project reference number: 2663. The project was registered on 13 November 2009. Methodology applied for this registered CDM project activity is AMS-III.H Version 9. During the 1st periodic CDM verification (i.e. covered by the verification team from 01 February 2010 to 30 April 2011), TÜV Rheinland Japan Ltd. found the following deviation from the registered monitoring plan:

Deviation 1 : Estimation of wastewater volume prior installation of wastewater flow meter
According to monitoring plan defined in the registered PDD, Qy,ww (volume of wastewater treated) is to be monitored continuously and recorded daily by a flow meter. However, Qy,ww was not measured and recorded daily via flow meter since the monitoring period started from 01 February 2010 till 08 September 2010. It was confirmed during on site verification that the flow meter was only in operation starting from 09 September 2010 onwards. The reason for the deviation is described as follows:
1. The original PDD submitted to the UNFCCC for registration defined the wastewater volume (Qy,ww), using an approach taken from publication released by the Department of Environment (DoE), Malaysia (i.e. Industrial Processes & The Environment (Handbook No.3), Crude Palm Oil Industry). It uses an effluent (Palm Oil Mill Effluent) conversion factor to estimate the wastewater amount. Hence, the formula used for determination of wastewater volume is:
Volume of waste water = Fresh fruit bunches (FFB) processed X Effluent conversion factor
2. The conversion factor has been determined as the ratio between the amount (m3) of wastewater generated by the palm oil mill and the amount (ton) of fresh fruit bunches (FFB) processed by the palm oil mill
3. During the registration process, a Request for Review (F-CDM-RR dated 01 September 2009) was issued where the PP (project participant) was requested to ensure that the volume of wastewater treated (Qy,ww) will be monitored in line with the requirements of EB 41, Annex 20, para 12 (b). Subsequently, the PP has amended the PDD Monitoring Plan to include a flowmeter to measure the volume of wastewater treated. The PP took several months to complete the sourcing, testing & installation of the flow meter. During the on site verification, the verification team was able to verify the work order information via online database system, and found the flow meter was fully operational starting from 9 September 2010 onwards.

4. Hence, for the period prior to the installation of flow meter i.e. from 01 February 2010 till 08 September 2010, Qy,ww has been determined as follows:
Qy,ww = Site specific conversion factor (m3/ton FFB) x Vintage FFB processed (ton)

5. The site specific effluent conversion factor (m3/ton FFB) will be determined based on the monitoring data gathered starting from the installation of the wastewater flowmeter until the end of the crediting period (30 April 2011) divided with the quantity of FFB processed during the period.

6. Vintage ton FFB processed will be based on the amount of fresh fruit bunches processed during vintage period prior to the installation of the wastewater flow meter.

The proposed deviation does not require a revision of monitoring plan or the changes from the project activity as described in the registered project design document since the deviation is only applicable for the specific period during the 1st verification. The volume of wastewater has been measured continuously via the use of flow meter since its operational date 9 September 2010; this is in line with the monitoring plan described in the registered PDD.

The proposed deviation does not have any impact on the estimates of the emission reductions for the proposed project activity. The reason is because the parameter Qy,ww is being used to calculate the methane produced per unit of COD (chemical oxygen demand) removed.

According to AMS-III.H Version 9 methodology, paragraph 34 “…..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.”
During on site verification, it was found that the site specific conversion factor has been calculated as 0.61 m3 / tFFB. This has been calculated based on the data available since the effective date of flow meter operational i.e. 9 September 2010 till 30 April 2011. The value is accepted since the amount of FFB processed per month is similar during the period when the volume of wastewater was not monitored (i.e. February to August 2010)
The verification team found that based on the entire monitoring period (i.e. from 01 February 2010 to 30 April 2011), the methane produced per unit of COD removed calculated is 0.27 tonnes CH4 / tonnes of COD which is higher than the baseline value (0.17 tonnes CH4 / tonnes of COD). Cross checking the calculation again by considering the period when the flow meter was installed i.e. from 9 September 2011 till 30 April 2011, the methane produced per unit of COD removed calculated is 0.38 tonnes CH4 / tonnes of COD which is also higher than the baseline value (0.17 tonnes CH4 / tonnes of COD).

Hence, according to AMS-III.H Version 9 methodology, paragraph 34 requirements, project emission (i.e. PEy,ww,treated) will be calculated & deducted from the emission reductions calculated from the methane recovered & combusted.