I-DEV0331: Deviations on the monitoring of volume of wastewater treated and project electricity consumption prior to installation of wastewater flow meter and kWh meter during the specified monitoring period

The request for deviations is for a registered CDM project activity “MY08-WWP-26, Methane Recovery in Wastewater Treatment, Pahang, Malaysia (project reference no. 2657)”, which is registered against AMS III H version 9 on 13/11/2009. 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. Two deviations were found as follows:

Deviation no. 1 – volume of wastewater treated, Qy,ww

In accordance with the monitoring plan in the registered PDD, the volume of wastewater treated Qy,ww is to be monitored using a flowmeter. During the on-site verification, the verification team found that the flowmeter was only in operation from 19/2/2010 onwards. Thus, for the period from 13/11/2009 to 18/2/2010, PP had used the following formula to estimate the total volume of wastewater treated:

Volume of wastewater treated = fresh fruit bunches (FFB) processed x effluent conversion factor
- Equation (1) -

The reason for the deviation was that the original PDD submitted for registration to the UNFCCC EB defined the volume of wastewater using Equation (1) where the effluent conversion factor was using the data provided in the publication released by the Department of Environment, Malaysia. During the registration process, a Request for Review (F-RR-CDM dated 11/9/2009) was issued where PP was required to ensure that the monitoring of volume of wastewater treated is in line with the requirements of EB41, Annex 20, para 12(b). To address the Request for Review, the PDD/Monitoring Plan was changed to include a flowmeter to measure the volume of the wastewater treated. Subsequent to the registration, an appropriate wastewater flowmeter was sourced, tested, and installed, a process which took several months. The meter was fully operational from 19/2/2010.

Deviation no. 2 – electricity consumed by project activity equipment,kWhproject

In accordance with the monitoring plan in the registered PDD, the electricity consumed by the project activity equipment is to be monitored using a kWh meter. During the on-site verification, the verification team found that the kWh meter was only in operation from 03/2/2010 onwards. For the period from 13/11/2009 to 02/2/2010, PP had used the following formula to estimate the electricity consumed by the project activity equipment:

Electricity consumed by the project activity equipment =
(equipment kW x no. of the equipment unit x 8760hrs x 1.1% distributionloss) / 12 months
- Equation (2) -

The reason for the deviation was that the original PDD submitted for registration to the UNFCCC EB proposed to monitor the project electricity consumption kWhproject using the power rating of equipment based on specification and with assumption of continuous operation (24hr/day), 365 days/year or 8760 hours/year with additional 10% distribution loss (as in Equation (2) above). During the registration process, a Request for Review (F-RR-CDM dated 11/9/2009) was issued where PP was required to install a kWh meter to measure this parameter. To address the Request for Review, the PDD/Monitoring Plan was changed to include the use of a kWh meter. Subsequent to the registration, an appropriate kWh meter was sourced, tested, and installed, a process which took several months. The meter was fully operational from 03/2/2010.

Both deviations do not require revision of the monitoring plan or change from the project activity as described in the registered PDD, as both meters were now in place and the installation were as stated in the monitoring plan described in the registered PDD.

Deviation no. 1 – volume of wastewater treated, Qy,ww

By using Equation (1), Qy,ww was estimated based on the actual fresh fruit bunches (FFB) processed multiplied with the effluent conversion factor. The effluent conversion factor is a common ratio derived when estimating the volume of wastewater from every tonnes of FFB processed in the palm oil mill. The effluent conversion factor was derived from a measurement campaign carried out from 19/2/2010 to 30/6/2010 using the installed flowmeter reading. The FFB processed for the same period was obtained from the monthly mill production report. The effluent conversion factor was derived using the following formula:

Effluent conversion factor = total volume of wastewater recorded from the flow meter during the measurement campaign / FFB processed during the measurement campaign

From the data obtained during the measurement campaign, the effluent conversion factor was determined as 0.99 m3/tonne of FFB. In a publication by the Department of Environment (Industrial Process and the Environment for Crude Palm Oil Industry) the ratio was reported as 0.7m3/tonne of FFB. Based on our (the verification team) knowledge of the palm oil milling process, we can confirm the 0.99 m3/tonne of FFB is an acceptable ratio as it gives a higher volume of wastewater which contributes to higher project emissions.

In accordance with AMS III H version 9 para 16, the volume of wastewater treated Qy,ww is used in the calculation of project emissions (PE) relating to PEww,treated, PEww,fugitive and PEdissolved. However, as in para 34 of AMS III H version 9, the calculation of emission reductions(ER) shall be based on the amount of methane recovered, fuelled or flared that is monitored ex-post. The project emissions 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, compared with the technology used in the baseline.

In case that the PP is not able to demonstrate 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, the related PE (as stated above) need to be deducted from the total ER (measured ex-post). In case that PP is able to demonstrate that the technology does not increase the amount of methane produced per unit of COD removed, compared with the technology used in the baseline, then the above PE will not be deducted from the total ER. Therefore, if the PE is deducted, the ER will be more conservative, and if PE not deducted, the ER will not be affected. As such it can be concluded that the deviation will not have significant impact on the estimates of ER for the proposed project activity.

Deviation no. 2 – electricity consumed by project activity equipment,kWhproject

The electricity consumed by project activity equipment is one of the project emission identified in the registered PDD. The equipment used in the project activity was verified against that listed in the PDD, and the power rating of all equipment was checked against the equipment specification provided by the manufacturers. PP provided the actual electricity consumption metered by the kWh meter (S/N 180024), for the period between February and June 2010. The kWh meter was calibrated by Krizik (M) Sdn Bhd, and calibration certificate provided showed that the meter is in good condition. The data is continuously recorded via data logger of their current system.
A comparison of electricity consumption calculated using the equipment power rating (as in Equation 2) and that measured using the kWh meter is as below:

Calculated using equipment power rating for the period from November 2009 to January 2010 (data in kWh):
13 – 30/11/2009 : 12,938
01 – 31/12/2009 : 21,862
01 - 31/1/2010 : 21,862
01 – 2/2/2010 : 1,438
Daily average : 709 kWh/day

Measured using kWh meter for the period from February 2010 to June 2010 (data in kWh):
03/2 - 03/3/2010 : 3,435
04/3 - 09/4/2010 : 2,958
10/4 - 05/5/2010 : 3,435
06/5 - 03/6/2010 : 3,436
04/6 - 04/7/2010 : 2,851
Daily average : 105 kWh/day

From the data provided a comparison between the estimated consumption and actual consumption was carried out. From the comparison above, it can be seen that the estimated electricity consumption using the equipment power rating will give higher value that will lead to higher project emission. Hence, the total ER will be less and as such can be deemed to be conservative.