I-DEV0427: Deviation from Monitoring Plan for monitoring parameter ID25 and ID20/22b

REQUEST FOR DEVIATION NO.1
Monitoring Parameter:
ID25:- Flow rate of the electricity generation equipment stack gases (FRe,s)
• Measurement Method as in Monitoring Plan:
Monitoring continuously following standard procedures and equipment manufacturer’s specifications.
• Monitoring Implemented:
Exhaust flow is measured with a calibrated flow meter. Pressure and temperature are measured continuously by calibrated sensors at the location where exhaust gas flow is measured.

Deviation Observed:
During the period from 1st Dec 08 – 6th Apr 09, the exhaust gas flow measurement equipment were newly installed and faced some technical problems. This flow measurement equipment was new to both the equipment supplier and the project participant, technically. Because of this, it has taken quite a long period of time to troubleshoot and rectify the problem due to the need to depend on the technical support from the manufacturer in UK.
Deviation Requested:
• To use the factor derived from the monitoring data from 7th Apr – 31stMay 2010 to estimate the flow of the electricity generation equipment stack gases for the affected period i.e. 1st Dec 08 – 6th April 2009.
• Flow volume of the gas engines exhaust (FRe,s) during this period of time was estimated by multiplying a factor of 15 to the biogas flow volume entering the gas engines (FRe,inlet), which had been monitored continuously by a flow meter. The factor 15 was derived from 7th April – 31st May 2010 monitoring data of FRe,inlet and FRe,s during which the stack gas flow data of the exhaust from the gas engines had been available.


Justifications of Deviation Requested:
• The factor derived, which is based on the actual monitoring data when the monitoring equipment is operating in accordance with the manufacturer’s specification, is considered appropriate and justifiable.
• The factor derived is also deemed conservative when compared to a study by the technology provider on the same model of gas engine used at another project site, where average exhaust flow vs biogas flow ratio of 10 has been observed.
REQUEST FOR DEVIATION NO.2
Monitoring Parameter:
(a) ID20: Flow rate of biogas entering the flare (FRf,inlet) in m3/yr; and
(b) ID22b: Volumetric flow rate of the residual gas in dry basis at normal conditions in the hour h (FVRG,h) in m3/hr
(The two flow rates were measured continuously at the point of the biogas entering the flare system)
• Measurement Method as in Monitoring Plan:
ID20: Measured with a pre-calibrated vortex gas flow meter incorporated into the flare gas pipe before flaring
ID22b: Measurements continuously using a flow meter. Ensure that the same basis (dry or wet) is considered for this measurement and the measurement of volumetric fraction of all components in the residual gas (fvi,h) when the residual gas temperature exceeds 60 °C. Values to be averaged hourly or at a shorter time interval.
• Monitoring Implemented:
Biogas flow is measured with a calibrated flow meter. Pressure and temperature are measured continuously by calibrated sensors at the location where biogas flow is measured. The measurement of pressure and temperature is required in order to calculate the biogas flow at normal condition in accordance with the ‘Tool to determine project emissions from flaring gases containing methane”.

Deviation Observed:
The temperature data for the period from 19th Feb – 31st May 2009 were found to be in abnormal range. The cause to the abnormal temperature data recorded was uncertain, but possibly could be due to “loose cable connection” of the temperature sensor. The operator had over-looked the abnormal temperature recorded. The problem had only been resolved since 6th November 2009.
Deviation Requested:
Therefore, it requested that a conservative estimate of the temperature of the biogas entering the flare system based on the monitoring data available be applied for the period from 19th Feb 2009 – 31st May 2009. Specifically, the following estimates are proposed:
(a) the lowest of the monthly average temperature i.e. 28.54°C, calculated from the historical temperature data available for the period from 1st Dec 08 – 18th Feb 09 and temperature data available for subsequent monitoring period from 7th Nov 09 – 31st May 10, for this period of time should be used for the calculation of the normalised biogas flow entering the flare system (FVRG,h), which is required for the calculation of the project emissions due to incomplete combustion by the flare system i.e. PEflare,y;
(b) the highest of the monthly average temperature i.e. 35.44°C, calculated from the historical temperature data available for the period from 1st Dec 08 – 18th Feb 09 and temperature data available for subsequent monitoring period from 7th Nov 09 – 31st May 10, for this period of time should be used for the calculation of the normalised biogas flow entering the flare system (FRf,inlet), which is required for the calculation of the physical leakage from biodigesters, PEphy_leakage.


Justifications of Deviation Requested:
• The monitoring of the biogas flow is in accordance with the monitoring plan i.e. with a pre-calibrated vortex flow meter, coupled with a temperature sensor and a pressure transmitter. The flow meter and the pressure transmitter was operating and recording the biogas flow accordingly and correctly during this period of time. Only the temperature measurement, which is used for calculation of measured flow to normalised flow, was found to be abnormal during the stated period of time.
• Since there is no process change during the monitoring period and Malaysia is a tropical country with small fluctuation in ambient temperature, use of historical temperature is deemed appropriate.
• The use of the lowest monthly average temperature (calculated from 1st Dec 08 – 18th Feb 09 and 7th Nov 09 – 31st May 10 monitored data) to calculate the normalised biogas flow entering the flare system for the calculation of the project emissions due to incomplete combustion by the flare system i.e. PEflare,y is deemed to be a conservative approach. As the normalised biogas flow is calculated acc. to the equation Biogas Flow [Nm3] = Biogas Flow [m3] x (273.15/Temperature [K]) x (Pressure [Pa]/101,325) the use of the lowest monthly average temperature would give higher biogas flow (FVRG,h) and hence higher PEflare,y.
• The use of the highest monthly average temperature (calculated from 1st Dec 08 – 18th Feb 09 and from 7th Nov 09 – 31st May 10 monitored data) to calculate the normalised biogas flow entering the flare system for the calculation of the physical leakage from biodigesters, PEphy_leakage (i.e. FRbio – FRf,inlet – FRe,inlet) is deemed to be a conservative approach. The use of highest monthly average temperature would give lower biogas flow (FRf,inlet) and hence higher PEphy_leakage.

ID25: Flow rate of the electricity generation equipment stack gases (FRe,s)
The monitoring of this parameter from 2008-12-01 to 2009-04-06 is different from the monitoring plan as during this monitoring period the gas flow meter had some technical problems. Please refer to the description above. The technical problems were solved on 2009-04-06 and the flow meter was in operation on 2009-04-07. A factor was derived using actual monitored data of the later dates of the monitored period and a study conducted by the technology provider. The determination method of the factor had been reviewed and is considered conservative. The factor applied to estimate the emission reductions was further explained at the next section. Thus, the value applied is conservative in the ERs calculations. As the technical problems are solved a revision of the monitoring plan is not required.
ID20/ID22b: Flow rate of biogas entering the flare (FRf,inlet) / Volumetric flow rate of the residual gas in dry basis at normal conditions in the hour h (FVRG,h)
The monitoring of this parameter was deviated for the monitoring period 2009-02-19 to 2009-05-31. A deviation was necessary as abnormal temperature data were observed due to lose cable connections of the temperature sensor instrument.
As explained in the next section, the default value applied is determined based on the actual measured value of the earlier dates of the monitored period for determining the project emissions of the flare and leakage is deemed conservative.
A notification for changes in the PDD of the CDM project activity "Methane Recovery and Utilisation Project at TSH Kunak Oil Palm Mill" (0916) was requested on 2010-12-22. The notification includes a revision of the registered monitoring plan. The notification has been approved on 03 Jun 11. In accordance to EB49 Annex 26 paragraph 7 (b) there is no need for a request for revision of the revised registered monitoring plan or changes to the project activity since the technical problem has been resolved. A request for deviation is sufficient to address deviation from the provision of the revised registered monitoring plan. According to the VVM 1.2 213 (a) TUV NORD confirms that the revised monitoring plan in the registered PDD is in line and compliance with the methodology AM0013 version 4.

REQUEST FOR DEVIATION NO.1:
ID25: Flow rate of the electricity generation equipment stack gases (FRe,s)
The impact of the requested deviation to the emission reductions is explained as follows:
• Impact to the Baseline emissions:
The deviation does not have any impact on the baseline emissions. It has been demonstrated that for the monitoring period, the baseline emissions for the project activity is based on methane emissions of the lagoon system and not the actual methane captured and combusted.
• Impact to the Project emissions:
Since the factor used to estimate the exhaust flow is based on actual monitoring data available from 7th April 09 to 31st May 2010, the estimation of the project emission deemed to be appropriate and conservative. The deviation should not caused under-estimation of stack emissions from electricity generation.
Table below summarised the ratio of gas engine Exhaust Flow : Biogas Flow based on the actual monitoring data obtained from 7th Apr – 31st May 2010.


• Impact to the Emission reductions:
The deviation applied resulted in conservative estimation of emission reductions.
REQUEST FOR DEVIATION NO.2:
(a) ID20: Flow rate of biogas entering the flare (FRf,inlet) in m3/yr; and
(b) ID22b: Volumetric flow rate of the residual gas in dry basis at normal conditions in the hour h (FVRG,h), in m3/hr (The two flow rates were measured continuously at the point of the biogas entering the flare system)
The impact of the requested deviation to the emission reductions is explained as follows:
• Impact to the Baseline emissions:
The deviation does not have any impact on the baseline emissions. It has been demonstrated that for the monitoring period, the baseline emissions for the project activity is based on methane emissions from the lagoon system and not the actual methane captured and combusted.
• Impact to Project emissions:
(a) PEflare,y
The calculation used during the monitoring period (deviation) deemed to be conservative. This is demonstrated by the calculation using the actual monitoring temperature data at the Digester Outlet (for biogas produced, FRbio).
Biogas flow (FVRG,h) and subsequently project emissions calculation (PEflare,y) are based on the followings data:
 Biogas temperature at Digester Outlet (under parameter FRbio) as measured during this period of time;
 Taken into consideration the temperature different between these two measuring points, based on historical data from 1st Dec 08 – 18th Feb 09 and monitoring data for subsequent monitoring period from 7th Nov 09 – 31st May 10; which is averagely 6°C lower compared to temperature at the Digester Outlet.
Table below summarises the results and demonstrated that deviation applied is conservative.
Monitoring Period Affected PEflare,y (tCO2-e)
Deviation Based on Actual Monitoring Temperature @ Digester Outlet
19th – 28th Feb 09 138.33 138.46
March 09 746.00 740.18
April 09 759.04 753.21
May 09 789.64 781.27
Total 2,433.01 2,413.12
(b) PEphy_leakage
The calculation used during the monitoring period (deviation) deemed to be conservative. This is demonstrated by the calculation using the actual monitoring temperature data at the Digester Outlet (for biogas produced, FRbio).
Biogas flow (FRf,inlet) and subsequently project emissions calculation (PEphy_leakage) are based on the following data:
 Biogas temperature at Digester Outlet (under parameter FRbio) as measured during this period of time;
 Taken into consideration the temperature different between these two measuring points, based on historical data from 1st Dec 08 – 18th Feb 09 and monitoring data for subsequent monitoring period from 7th Nov 09 – 31st May 10; which is averagely 6°C lower compared to temperature at the Digester Outlet.
Table below summarises the results and demonstrated that deviation applied is conservative.
Monitoring Period Affected PEphy_leakage (tCO2-e)
Deviation Based on Actual Monitoring Temperature @ Digester Outlet
19th – 28th Feb 09 179.67 151.79
March 09 573.90 521.17
April 09 2,523.74 2,511.79
May 09 794.12 749.90
Total 4,071.43 3,934.65

• Impact to Emission reductions:
The deviation applied resulted in conservative estimation of emission reductions.