I-DEV0317: Deviation from registered PDD and monitoring methodolgy with regards to measurement of parameters to be monitored

The project activity “Forced methane extraction from Organic wastewater at Mandya district, Karnataka by M/s. Sri Chamundeswari Sugars Ltd” has been registered on 27 July 2007. The project activity applies methodology AMS.III.H version 04. The project activity comprises of biogas recovery from anaerobic digestion of spentwash fom distillery and its utilisation on site as a fuel in boiler and surplus biogas is flared in an open flare.

DNV confirms that as per the verification site visit there are no other sources of generation of Biogas other than project activity. A request for revision of the monitoring plan has been submitted for the entire crediting period (Related reference: REVMP0372) in order to include monitoring of biogas sent to boiler and flare and monitoring of temperature of flare as per the requirement of the methodology AMS III H.

The first verification period falls between 27 July 2007 to 31 December 2008. This deviation request is for the period starting from 27 July 2007 to 24 February 2009.

1. Deviation regarding monitoring the volume of biogas recovered from the anaerobic digestion of spentwash from distillery

During the first verification site visit, DNV observed that the total biogas generated at the digesters was monitored as per the registered PDD only from 27 January 2009. Prior to this date, biogas generated was calculated as a sum of two individual flow meter readings installed at the points of its use, i.e., at the boiler and flare points

The registered PDD includes monitoring of total volume of biogas recovered using continuous flow meter. However, in case of project activity, two flow meters were installed which are used to measure amount of biogas utilised in boiler and amount of biogas flared. The sum of readings from these two meters was reported as amount of biogas recovered from the anaerobic digestion of spentwash fom distillery. Thus, there is a deviation from monitoring plan of the PDD, as no separate meter was installed to measure the total volume of biogas recovered. DOE requests UNFCCC to approve the deviation for the monitoring period from 27 July 2007 to 26 January 2009. Out of this; period from 27 July 2007 to 31 December 2008 is a part of first monitoring period while period from 1 January 2009 to 26 January 2009, would be a part of 2 monitoring period during which the same approach would be adopted.

It is to be noted that, although it was not mentioned in the monitoring plan of the registered PDD the project proponent monitored biogas sent to boiler (Qyboiler) and biogas flared (Qyflare) using a continuous flow meter for the entire monitoring period and these values were used for emission reduction calculation purpose. Project proponent is reporting the volume of biogas generated (Q y,biogas) as a sum of measured values of biogas sent to boiler and biogas flared. Thus, in absence of the measured value of biogas recovered the conservativeness check of comparing measured and calculated values for Q y,biogas could not be carried out. It was confirmed by DOE during the verification site visit that all the records related to data monitoring and calibration were maintained by PP in paper and electronic form for the meters which are used for monitoring amount of biogas sent to boiler and amount of biogas flared. Also records for volume of biogas recovered (calculated as described above) are available in paper and electronic form.

Since 27 January 2009, the third meter for measuring volume of biogas recovered has been installed. After the installation of flow meter on 27 January 2009, for monitoring volume of biogas recovered from the digesters; the project proponent is also maintaining records related to data monitoring and calibration of this meter in paper and electronic form.

2. Deviation regarding monitoring of operation of open flare

As per the methodology AMS.III.H requirement, which further refers to ‘Tool to determine project emissions from flaring gases containing methane’, 50% default value of flare efficiency is to be used if it is demonstrated that the flare is operational. However, during the monitoring period there are no records maintained by PP which indicate that the flare is operational, as this was not included in the monitoring plan of the registered PDD. Thus, to be in line with the ‘Tool to determine project emissions from flaring gases containing methane’, PP would consider default flare efficiency of 0% for this monitoring period, as a conservative measure.

However, since 25 February 2009, the thermocouple has been installed at the flare which monitors the temperature of flare (Tflare) on continuous basis indicating that the flare is operational. Thus, DOE requests UNFCCC to approve the deviation for the monitoring period from 27 July 2007 to 24 February 2009. Out of this; period from 27 July 2007 to 31 December 2008 is a part of first monitoring period while period from 1 January 2009 to 24 February 2009, would be the part of 2nd monitoring period during which the same approach would be adopted.

Project Proponent has installed separate flow meter to monitor the total biogas generated on 27 January 2009, at the digester outlet. This is in line with the monitoring plan of the registered PDD. The installation of biogas flow meter was verified from the purchase order copies dated 16 January 2009 and commissioning / installation certificate dated 27 January 2009.

For the period from 27 July 2007 until 26 January 2009, the total biogas flow considered shall be the sum of the two individual flow meter readings installed at the points of its use, i.e., at the boiler and flare points. DNV confirms though this is not as per the monitoring plan of the registered PDD, using these monitored biogas values for emissions reduction calculations is a conservative approach by the project proponent considering that the total volume of biogas values monitored at the digester outlet will be higher, as compared to the flows recorded at the points of use. (based on the assumption that there could be some losses).

Total volume of biogas recovered is not used for emission reduction calculation. Thus, the deviation pertaining to monitoring of biogas recovered (Q biogas) has no direct impact on the emission reduction. However it will add more transparency in the monitoring system.

The amount of biogas sent to boiler (Qyboiler) and biogas flared (Qyflare) have been used for the purpose of emission reduction calculation. For baseline emission calculation (BE y) and PEy, fugitiveemissions component of project emissions the amount of biogas sent to boiler and amount of biogas flared multiplied by appropriate factors have been used.

Since, 0% default value will be used as the appropriate factor for flare efficiency; it would lower the emission reduction. Thus, emission reductions due to biogas flared will not be accounted for this monitoring period.

Thus, the emission reduction with 50% default value is 27,486 tCO2 e whereas with 0% default value is 24,275 t CO2 e With these facts it is evident that a conservative approach has been adopted.