I-DEV0380: Deviation from Monitoring Plan for parameters (a) electricity consumed by project activity equipment “EGy,consumed,elec”, and (b) COD measurement for the wastewater discharged to the open channel from the last pond of the existing lagoon system “CODy,ww,treated”.

During the first verification period of the registered CDM project activity (BAJ Gunung Agung Factory Tapioca Starch Wastewater Biogas Extraction and Utilization Project, Lampung Province, Republic of Indonesia, CDM Ref. No. 2673) Det Norske Veritas identified two deviations in the monitoring plan and monitoring report of the project. The monitoring period covered by the verification is from 4 October 2009 to 31 March 2010. The two deviations from the registered monitoring plan (registered on 4 October 2009) involves a) electricity consumed by the project activity equipment “EGy,consumed,elec” and (b) COD analysis of wastewater discharged to the open channel from the last pond of the lagoon system “CODy,ww,treated”.

For EGy,consumed,elec, the monitoring plan in the registered PDD states that this parameter will be measured. However, EGy,consumed,elec has not been measured and monitored via appropriate instruments from the start of the monitoring period, 4 October 2009 to 25 January 2010. The continuous monitoring and daily recording of EGy,consumed,elec only commences from the electricity meter installation date of 26 January 2010. For the period prior to the installation of the electricity meter (deviation request period), the project proponent has adopted the approach introduced in more recent version of AMS-III.H, the methodology applied by the project activity. In the latest version (version 15), AMS-III.H stipulates as follows when electricity consumption for the project activity is not measured (page 19, item No. 9).

“Alternatively it shall be assumed that all relevant electrical equipment operate at full rated capacity, plus 10% to account for distribution losses, for 8760 hours per annum”.

Thus, in this proposed calculation it is assumed that all project activity equipment operate at full rated capacity, plus 10% to account for distribution losses, for 8 760 hours per annum.

EGy,consumed,elec = [rated capacity of equipment (kW) x 24 (hr/day) x 365 (days/year)] *1.10

The 10% (1.10) is to account for distribution losses.

For CODy,ww,treated, the monitoring plan in the registered PDD states that this parameter will be measured on a weekly basis. During the first two months of the crediting period, only a monthly COD sampling was carried out for the final discharge stream as this was the standard practice of the starch plant in the baseline, instead of the planned weekly sampling. This was rectified from December 2009 onwards, where in line with the PDD the aggregated (average) weekly results were used in the CER calculations. In the absence of a weekly sampling and monthly average readings, it is proposed that the COD reading for October and November 2009 were taken from the highest actual weekly measurements from a third party laboratory between the period December 2009 and March 2010.

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 4 October 2009 to 31 March 2010. Subsequent to the commissioning date of the electricity meter on 26 January 2010, the parameter is monitored as per the registered monitoring plan. In addition, the project proponent has adopted weekly sampling of the COD discharged from the last pond to the open channel from December 2009 onwards. It is confirmed that there are no permanent changes to the project activity as described in the registered PDD.

The rated capacity of the equipment used in the calculation has been evidenced by the corresponding equipment’s specifications sheet and was calculated to be 221.45 kW. By applying the above formula, the estimated daily electricty consumption for the project activity is 5.85 MWh/day. In comparison, the actual measured average electricity consumption for the project activity is 1.15 MWh/day. Hence, the deviation request for this parameter is deemed to be conservative.

Month - Proposed estimated monthly consumption
4-31 October 2009 - 163.7 MWh
November 2009 - 175.4 MWh
December 2009 - 181.2 MWh
1-25 January 2010 - 146.2 MWh

Month - Actual measured monthly consumption
(26-31) January 2010 - 6 MWh
February 2010 - 32 MWh
March 2010 - 37 MWh

In addition, the final discharge from the last pond of the lagoon system is less prone to flucations having resided in the lagoons for long period, and this parameter has little impact on the CERs as compared to the fresh inlet stream into the project activity biogas reactor. The CODy,ww,treated parameter was applied in the calculation of a) project activity emissions from degradable organic carbon in treated wastewater, and b) to calculate the project activity’s CODremoved in accordance to paragraph 34 of AMS-III.H version 9. In accordance with the afore-mentioned approach, the project proponent will apply the highest recorded data (115 mg/l tested in 7 Feb 2010) in this monitoring period to estimate the parameter CODy,ww,treated for October and November 2009. This compares conservatively with any of the actual weekly average measured values from the independent laborotary in the subsequent months: 56 mg/l for December 2009, 93 mg/l for January 2010, 79 mg/l for February 2010 and 51 mg/l for March 2010. In addition, the monthly COD test results for October and November 2009 was verified to be 78 mg/l and 86 mg/l respectively.

As the resulting methane produced per unit COD removed in the project is higher than in the baseline, therefore the project emissions have been deducted from the emission reductions calculated. Furthermore it was checked that for the months verified in this monitoring period, the starch plant is in compliance with the discharge standard of 250 mg/l as stipulated by the Indonesian Environmental Decree . Based on the above observations, the deviation request for this parameter is is likely to lead to higher project emissions and can be deemed conservative in relation to ER calculation.

Month - Average monthly reading for the COD of final discharge
October 2009 - 115 mg/l (deviation request)
November 2009 - 115 mg/l (deviation request)
December 2009 - 56.4 mg/l
January 2010 - 92.5 mg/l
February 2010 - 79.4 mg/l
March 2010 - 51 mg/l