I-DEV0415: Deviation from Monitoring Plan for parameters (a) volume of wastewater treated and (b) electricity consumed by project activity equipment

During the first verification period of the registered CDM project activity (ID08-WWP-10, Methane Recovery in Wastewater Treatment, West Sumatera, Indonesia, CDM Ref. No. 2643), DNV identified some deviations in the monitoring plan and monitoring report of the project. The monitoring period covered by the verification is from 12 November 2009 to 31 January 2011. There are deviations from the registered monitoring plan (registered on 12 November 2009) regarding the (a) volume of wastewater treated (Qy,ww) and (b) electricity consumed by the project activity equipment (kWhproject).

1) For Qy,ww, the monitoring plan in the registered PDD states that this parameter will be monitored continuously and recorded daily by a flow meter. However, Qy,ww has not been measured and monitored via flow meter from the start of the monitoring period 12 November 2009 to 17 September 2010. The continuous monitoring and daily recording of Qy,ww only commences from the flow meter commissioning date of 18 September 2010. This is due to the time it took to change the monitoring system to comply with the request for review raised by the EB on 30 August 2009. The effort to comply with the request for review raised by the EB1 only commences after the project is registered (12 November 2009).
The project design document (PDD) submitted for registration defined the ex-post monitored volume of wastewater treated using an approach taken from a publication by the Malaysian Department of Environment (DOE) . In the publication, palm oil mill effluent (POME) conversion factor is used to estimate the volume of wastewater treated. The conversion factor is the ratio between volume of wastewater from a typical palm oil mill and the amount of fresh fruit bunch processed and the unit is m3/t FFB.

The project was submitted for registration on 7 June 2009 and a request for review was raised by the EB on 30 August 2009. As a result of the request for review, the monitoring system was changed to include flow meter to monitor Qy,ww and it took several months for the project developer to source, test and install satisfactorily the appropriate flow meter for the wastewater. It took the project developer 3.5 months (from the date of the request for review by EB) to source and procure the flow meter due to the project developer’s internal scheduling and logistics . The cost for the flow meter was quoted on 16 December 2009 and a purchase order was issued on the same day. The project developer received the flow meter on 25 February 2010 and installation works completed on 2 June 2010. The flow meter was subsequently commissioned on 18 September 2010 after a period of testing (from 2 June to 17 September 2010). For the period prior to the installation of wastewater flow meter (12 November 2009 to 17 September 2010), Qy,ww is determined as follows:

Qy,ww = POME conversion factor (m3/ton FFB) x vintage FFB processed (ton)

There are two options for POME conversion factor (CF). One is the industry default of a typical facility of 0.70 m3/tFFB and the second option is the site specific CF. Site specific POME CF (1.09 m3/ton FFB) is based on the actual monitored data obtained starting from the commissioning date (18 September 2010) of the wastewater flow meter until the end of this monitoring period (31 January 2011), divided by actual measured quantity of FFB processed during the same period . Vintage FFB processed (ton) is the actual amount of fresh fruit bunches processed for the period prior to the installation of wastewater flow meter.

2) For kWhproject, the monitoring methodology in the registered PDD states that this parameter will be continuously monitored and recorded by electricity meter. However, kWhproject has not been monitored via electricity meter from the start of the monitoring period from 12 November 2009 to 26 January 2010. The continuous monitoring and recording of kWhproject only commences from the electricity meter commissioning date of 27 January 2010. This is due to the time it took to change the monitoring system to comply with the request for review raised by the EB on 30 August 2009.

For the ex-post monitored value of kWhproject, the initial PDD submitted for registration assumed that all project activity equipment operate at full rated capacity, plus 10% to account for distribution losses, for 8 760 hours per annum.

The project was submitted for registration on 7 June 2009 and a request for review was raised by the EB on 30 August 2009. As a result of the request for review raised, the initial PDD was changed to include kWh meter to monitor kWhproject and it took several months for the project developer to source, test and install satisfactorily the appropriate kWh meter for the monitoring of electricity consumed by the project activity equipment. Cost for the electricity meter was quoted on 9 November 2009 and a purchase order was issued the next day (10 November 2009). The project developer received the electricity meter in December 2009 and installation and commissioning completed on 27 January 2010. For the period prior to the installation of the kWh meter (12 November 2009 to 26 January 2010), kWhproject is determined as follows:
kWhproject = [rated capacity of equipment (kW) x 24 (hr/day) x 365 (days/year)] *1.10
The 10% is to account for distribution losses.

The proposed deviation from the monitoring plan does not require a revision of the monitoring plan or changes from the project activity as described in the registered PDD as the deviation is only for a specific period in the initial verification. The monitoring period covered by the initial verification is from 12 November 2009 to 31 January 2011. Subsequent to the commissioning dates of both meters; 18 September 2010 for flow meter and 27 January 2010 for electricity meter, the parameters are monitored as per the registered monitoring plan. Also, it is confirmed that there are no permanent changes to the project activity as described in the registered PDD.

The impact of this deviation request for parameters as explained above is as follows:

1) Volume of wastewater treated (Qy,ww) not monitored via flow meter for a certain time period: The proposed deviation does not impact the emission reductions of the project as this parameter is only used for the demonstration of methane produced per unit of chemical oxygen demand (COD) removed. The emission reduction of the project activity is based on the actual amount of methane destroyed by the project. Based on the registered PDD and validation report, in the event that methane produced per unit of COD removed is more than the baseline, project emissions would have to be deducted from the emission reduction. This is in line with paragraph 34 of the applied methodology (AMS-III.H version 9) which states that 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.

DNV has made a comparison of methane produced per COD removed using (i) actual monitored Qy,ww (18 September 2010 to 31 January 2011), and using (ii) Qy,ww calculated by applying a conversion factor (CF) for the same period. It has been concluded that applying the CF is conservative as the methane produced per COD removed would have been higher.

There are two options for POME CF. One is the industry default of a typical facility of 0.70 m3/tFFB2 and the second option is the site specific CF. Site specific POME CF (1.09 m3/ton FFB) has been calculated based on the actual monitored data obtained starting from the commissioning date (18 September 2010) of the wastewater flow meter until the end of this monitoring period (31 January 2011), divided by actual measured quantity of FFB processed during the same period . The site specific conversion factor of 1.09 m3/ton FFB is representative since the monthly amount of FFB processed is similar for these months compared to the monthly amount of FFB processed from September 2010 to January 2011. In addition, the site specific conversion factor is representative as it has been calculated based on the actual monitored data of the specific mill which reflects the actual process and condition of the mill. The amount of FFB processed has been evidenced from the mill records. The monthly amount of FFB are similar between the measured data (from September 2010 to 31 January 2011) in comparison to previous months since the difference between the monthly average of FFB processed between 2008 (17 120 tonnes/month) and 2010 (19 856 tonnes/month) is found to be 16% whilst the difference between the monthly average of FFB processed between 2009 (19 473 tonnes/month) and 2010 is 2%, and the difference between the monthly average of FFB processed between 2010 and 2011 (15 963 tonnes/month) is -19.6%, and these are deemed appropriate.

A comparison was made using both the CF of a typical facility of 0.7 m3/tFFB and the site specific CF of 1.09 m3/tFFB and it was found that the methane produced per unit of COD removed is higher by 27.6% when using the CF of 0.7 m3/tFFB. Hence the present request for deviation is to use a CF of 0.7 m3/tFFB for the calculation of POME for the period up to installation of the flow meter.

Cross-checking shows that the post-project implementation (12 November 2009 to 31 January 2011) average methane produced per unit of COD removed (0.15 tonneCH4/tonneCOD, applying the CF of a typical facility of 0.7 m3/tFFB) is lower than the baseline (0.17 tonneCH4/tonneCOD ), which was demonstrated in accordance to the requirements from paragraph 34 of AMS-III.H, version 9. Hence, this deviation request has no impact on the emission reduction in this deviation period and is deemed reasonable.

2) Electricity consumed by the project activity equipment (kWhproject) not monitored via electricity meter for a certain time period: The deviation request results in additional project emissions as for the months of November to December of 2009 and January 2010, the kWhproject has been calculated as 18 031 kWh per month using the formula above.

The rated capacity of the equipment used in the calculation has been evidenced by the corresponding equipment’s specifications sheet . The total actual monitored kWhproject for the month of February 2010 to January 2011 is only approximately 5.33% (average of 962 kWh per month) of the estimated monthly kWhproject. The proposed deviation reduces emission reductions of the project by 0.03% for this monitoring period. Also, the formula above is in line with the latest version of the methodology (AMS-III.H version 16, parameter 9 of paragraph 37). Hence, the deviation request for this parameter is deemed to be conservative.