I-DEV0431: Deviation of the estimation of electricity consumed in the plant and the frequency of recording

>>Description of noncompliance with the monitoring plan
This request for deviation is being submitted to address two issues related to monitoring electricity consumption for net electricity generation calculation that were raised during verification of emission reductions from the Korea Water Resources Corporation (KOWACO) small-scale hydroelectric power plants project for the monitoring period from 01 January 2010 to 31 December 2010. The issues are discussed below

1.Estimation of the missed value of electricity consumption in the power plant

This project is bundling renewable energy power generation project consisted with 3 small hydro power plants (Seongnam, Jangheung, Andong). The monitoring plan in Section. D.3 of the registered CDM PDD (dated 06 Oct. 2006) has defined that EGy is the electricity delivered to the grid by the project and measured hourly and recorded monthly. And it is also described that electricity comsumed in the plant is excluded from the EGy values.

In this monitoring period, it is found that the measured value of the electricity comsumed in the two plants (Seongnam, Jangheung) for the 5 months (from 01 Jan. 2010 to 31 May 2010) has been missed and only the gross electricity ouput was measured. In order to reflect the amount of electricity consumption, PP applied the missed value as 14,489kWh (Seongnam : 7,347 kWh, Jangheung : 7,142 kWh) in the monitoring report(version 1) using the monthly average data actually measured for 7 months (from 01 Jun. 2010 to 31 Dec. 2010, it is remaining period of 4th monitoring peiod.).
For the checking the validity of the applied data, all applicable data for electricity consumption in the plant was identified. (refer table 1)

1)It is measured the electricity consumption in the plants (Seongnam, Jangheung) during the same period of subsequent year; 01 Jan. 2011 to 31 May 2011 to check whether the value applied in the monitoring report as an alternative is reasonable and conservative for ER calculation. As a result, the measured value was totally 13,631kWh(Seongnam 7,231 kWh , Jangheung 6,400 kWh), which was 858kWh lower than the value applied in the monitoring report(version 1)
2)And, if the electricity consumed in the plants can’t be directly measured, 0.5% of the value shall be deducted from electricity delivered to the grid especially in case, the capacity of the generator is smaller than 1MW according to the ‘Feed-in tariff policy’ in Korea. The capacity of Seongnam and Jangheung hydroelectric is 340kW and 800kW respectively, and as a result of applying to the estimation of the missed value, it was calculated as 2,835kWh(for Seongnam) and 10,870kWh(for Jangheung) respectively. The calculated value for Seongnam was lower than the value in monitoring report (version 1) (7,347 kWh) and the calculated value for Jangheung was higher than the value in the moniroing report (version 1) (7,142 kWh), while total 13,705 kWh was still lower than the value in the monitoring report (version 1) (14,489kWh)

For the measuring data for 7 months (from 01 Jun. 2010 to 31 Dec. 2010), we checked the capable error from resetting meters and confirmed there was no error from that(refer issue 2). The watt hour meter for electricity consumption of project activity is installed on the branch of grid supply line and it does not checked with invoice. (Only total electricity consumption including the one in other facilities not directly related with the electricity generation can be checked with invoice from grid company). Thus the electricity consumption was recorded by field worker. For the validity of recorded value, we checked the measured value recorded in work log with photos (we checked two photos taken on 01 Jun. 2010 and 31 Dec. 2010 to verify the electricity consumption of each site)

As a conservative approach, the highest values were applied as electricity consumption in each power plant from 01 January 2010 to 31 May 2010. In Seongnam plant, the average monthly electricity consumption that was measured and recorded subsequently during the period 01 June 2010 to 31 December 2010 is applied for the period for which the electricity consumption data was not monitored (7,347 KWh for Seongnam). And in Jangheung plant, the electricity consumption calculation according to the ‘Feed-in tariff pocity’ is appled for the period for which the electricity consumption data was not monitored (10,870 KWh for Jangheung).

We are hereby requesting the approval of the deviation that the approach for electricity consumption in two plants (Seongnam, Jangheung) calculated using the monthly average data monitored during 7 months (from 01 Jun. 2010 to 31 Dec. 2010 for Seongnam) and the internal electricity consumption calculation according to related policy (0.5% of electricity generation supplied to grid, for Jangheung), be allowed for the period 01 Jan. 2010 to 31 May 2010.

2.Frequency of recording electricity consumption

PP didn’t record the electricity supplied from the grid on a monthly basis from 01 Jun. 2010 to 31 Dec. 2010 in the two plants (Seongnam, Jangheung) but recorded the meter value only two times on 01 Jun. 2010 and 31 Dec. 2010. The type of meter is accumulated value measuring and the electricity consumption in each plant during the period was measured with the differences between two accumulated values (from 01 Jun. 2010 to 31 Dec. 2010).

In verification team’s opinion, against the argument of PP, the electricity consumption in the plant has to be recorded on a monthly basis as the frequency of recording the electricity delivered to the grid. However, PP is now recording the electricy on a monthly basis after the related monitoring period and there was no change of the total electricity consumption value during the period because the using meters are accumulated value measuring meters.
And also it is checked the possibility of resetting the meters during this period. The type of applied meters for electricity consumption is analog type and from the manufacturer’s information (catalogue of the product and interview with the charge of quality management of manufacturer), the applied analog type meter has the function of pawllock and the housing of meter is sealed by manufacture. So, only manufacturer can reset the meter and also it is checked during site inspection that the housing is still sealed as initially manufactured status. Also, we checked the possibility of resetting the meters when the accumulated measuring value exceeds the reset point. From the simulation of maximum electricity consumption considering each site condition during 1 Jun. to 31 Dec. 2010, it is demonstrated that the electricity consumption during the period can not exceed the reset point. (refer table 2)

We are hereby requesting the approval of the deviation that the approach for electricity consumption in two plants (Seongnam, Jangheung) recorded only two times (start and end), be allowed for the period 01 Jun. 2010 to 31 Dec. 2010.

As mentioned above, this request for deviation from the monitoring plan of the registered PDD is applicable only for this monitoring period and will not affect the subsequent monitoring periods of the project activity. Because PP is recording the electricity consumed on a monthly basis in the plant after this monitoring period. Thus, it doesn’t require a revision of monitoring plan or any changes to the project activity.

To be conservative, estimates of the missed value of electricity consumed in the each plant has to be the largest among resonable alternatives.
Furthermore, the temporary changes of recording frequency did not effect the calculation of the emission reductions during the monitoring period.

In conclusion, as stated above, the deviation proposed above do not have any impact on the estimates of the emissions reductions (i.e no overall increase in emission reductions) due to the following reasons.
-The electricity consumption during the non-monitoring period(01 Jan. 2010 to 31 May 2010) has been considered as conservative value among applicable value.
-Even though the electricity consumption did not recorded as monthly basis, the total electricity consumption during the monitoring period did not change because the type of meters are accumulated value measuring system and the total electricity consumption during the monitoring period can be calculated with the difference between two recorded data (start and end data) and it can be demonstrated that there was no capable error from resetting the watt hour meter during the specific period.