I-DEV0286: Deviation to the monitoring plan of the registered PDD project No. 1673

The deviation is for the first monitoring period (13/02/2009 -31/12/2009) of registered CDM project (Ref 1673:Waste Heat Recovery and Utilisation for Power Generation Project of Huaining Conch Cement Company Limited). Two deviations are requested,
Deviation 1: Minor deviation of monitoring system in terms of number of meters for auxiliary electricity (EGAUX);
Deviation 2: Conservative adjustment of metered data during part of the first monitoring period in order to get rid of any uncertainties due to lower meter accuracy than what is specified in PDD.


Deviation 1
Description of noncompliance with monitoring plan (MP)
As per ACM0004 version 02 and registered monitoring plan, the monitoring system has been installed to monitor total generation (EGGEN) and auxiliary electricity (EGAUX), and the net electricity supplied to facility (EGy) by the project is obtained as:
EGY = EGGEN– EGAUX
Where,
EGGEN:total electricity generated
EGAUX:auxiliary electricity
The noncompliance is about the number of meters for EGAUX from 13/02/2009 to 11/09/2009.
The project was put into operation before the CDM registration. The number of meters for auxiliary electricity (EGAUX) from 13/02/2009 to 11/09/2009 is different from registered PDD. Besides those meters described in the registered PDD, two other temporary meters (ER2-1AT and ER3-1AT) are used to monitor part of the auxiliary electricity. The monitoring system in the registered PDD (current monitoring system) and the actual monitoring system from 13/02/2009 to 11/09/2009 are shown in the figures in the signed request form.
The former and current monitoring systems are in full compliance with ACM0004, and this deviation highlights the difference.
This deviation will not apply in the future as the project owner has removed meter ER2-1AT and ER3-1AT, and the auxiliary electricity metered with these two meters in the past is now monitored by 52H, and the current monitoring system is in compliance with the monitoring plan of the registered PDD.

Solutions to address the non-compliance
The auxiliary electricity consumed by the Project was measured with the power meters 52H, 52B, 52B2, 52B3 and ER2-1AT, ER3-1AT from 13/02/2009 to 11/09/2009. The net electricity, which was still calculated by total generation deducting auxiliary electricity, would be crosschecked against the meter readings of 52P minus those of ER2-1AT and ER3-1AT for the same period.

Deviation 2
Description of noncompliance with monitoring plan (MP)

The noncompliance is about the accuracy of meters for monitoring EGAUX.
The meters for measuring EGGEN are of accuracy 0.5% (the same as PDD), while meters for measuring EGAUX are of accuracy of 2%, which is inconsistent with the description in the registered PDD.
After the registration of the project activity, the project owner purchased new power meters with accuracy of 0.5%. However, the power meters could only be replaced step by step when the relevant facilities of the power plant are shut down for maintenance. Therefore, the new meters were not fully installed until 11/09/2009. As a result, the data of EGAUX from 13/02/2009 to 11/09/2009 are monitored by the old power meters with accuracy of 2%.

Solutions to address the noncompliance
As the accuracy of the meters for monitoring EGAUX is 2%, which is inconsistent with the description in the registered PDD, an adjustment is made based on the maximum permissible error of the meters used. Thus, the data of EGAUX from Feb 2009 to Sep 2009 is increased by 2% as a conservative approach.

As the two temporary meters have been removed and the project owner has replaced all the low-accuracy power meters with new high-accuracy meters required, the current monitoring system is in consistent with the description in the monitoring plan of the registered PDD and the methodology applied. Therefore, a revision of monitoring plan or the changes form the project activity is not necessary for the project activity.

Deviation 1
As the former and current monitoring systems are in compliance with ACM0004 version 02, and the auxiliary electricity monitored by the two temporary meters will be included in the emission reduction calculation process, the deviation has no impact on the emission reductions calculation.
Deviation 2
The deviation results in lower emission reductions for the project activity.
As discussed above, the value of EGAUX from Feb 2009 to Sep 2009 is increased by 2% based on the maximum permissible error of the meters used.
The data monitored for EGAUX from Feb 2009 to Sep 2009 is 5865.58 MWh and the baseline emission factor calculated ex-ante in the registered PDD is 0.9047tCO2e/MWh.
With this request for deviation and after the conservative adjustment of metered data, the emissions reductions are reduced by 5865.58MWh*2%*0.9047tCO2e/MWh=106 tCO2e compared with the figure directly calculated from the metered data.