I-DEV0440: Deviation on the monitoring wastewater volume prior to installation of wastewater flow meter

Reference I-DEV0440
Submitted by TÜV Rheinland (21 Sep 2011)
Project activity 2662: ID08-WWP-11, Methane Recovery in Wastewater Treatment, Jambi, Indonesia
Selected monitoring period 01 Mar 2010 - 31 Mar 2011
Title/subject of deviation Deviation on the monitoring wastewater volume prior to installation of wastewater flow meter
Description
The request for deviation is being applied for the registered CDM project activity titled “ID08-WWP-11, Methane Recovery in Wastewater Treatment, Jambi, Indonesia” with project reference number: 2662. The project was registered on 18 February 2010. 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 March 2010 to 31 March 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 March 2010 till 19 September 2010. It was confirmed during on site verification that the flow meter was only in operation starting from 20 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 05 September 2009) was issued where the PP (project participant) was requested to clarify the inconsistencies in the information of the monitoring of Qy,ww between section B.7.1 and Annex 4 in the PDD. 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 20 September 2010 onwards
4. Hence, for the period prior to the installation of flow meter i.e. from 01 March 2010 till 19 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 (31 March 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.
Assessment
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 20 September 2010; this is in line with the monitoring plan described in the registered PDD.
Impact
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 the methodology AMS-III.H Version 9, 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 1.99 m3/tFFB. This has been calculated based on the data available since the effective date of flow meter operational i.e.
20 September 2010 till 31 March 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. March to August 2010).
The verification team found that based on the entire monitoring period (i.e. from 01 March 2010 to 31 March 2011), the methane produced per unit of COD removed calculated is 0.11 tonnes CH4 / tonnes of COD which is lower 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 20 September 2011 till 31 March 2011, the methane produced per unit of COD removed calculated is 0.14 tonnes CH4 / tonnes of COD which is still lower than the baseline value (0.17 tonnes CH4 / tonnes of COD).

This is clearly in line with the AMS-III.H Version 9 methodology, paragraph 34 requirements. Therefore, this substantiates that the proposed deviation does not caused any impact on the estimates of the emission reductions.
Annexes Reference: Industrial Processes & The Environment (Handbook No. 3), Crude Palm Oil Industry, page 25 (264 KB)
Wasterwater quantity correlation (3995 KB)
Comparison of ECF (446 KB)
Link to the documentation made available at validation stage or monitoring report Link to relevant documentation
Signed form Signed form (513 KB)
Decision This request for deviation has been accepted.

The Chairs have accepted the proposed request for deviation to the monitoring and reporting process for the part of the first monitoring period (from 1 March 2010 to 19 September 2010).

Current status 24 Nov 2011 - Deviation accepted
Historic statuses 21 Sep 2011 - Submission received
19 Oct 2011 - Successfully passed the Completeness Check
09 Nov 2011 - Awaiting EB decision