I-DEV0474: Deviation on the monitoring wastewater volume & electricity consumed by the project activity equipment

The request for deviation is being applied for the registered CDM project activity titled “MY08-WWP-34,
Methane Recovery in Wastewater Treatment, Pahang and Negeri Sembila, Malaysia” with project reference
number: 1756. The project was registered on 25 November 2009. Methodology applied for this registered
CDM project activity is AMS-III.H Version 9. During the 1st periodic CDM verification (i.e. covered by the
verification team from 01 March 2010 to 30 September 2011), TÜV Rheinland (China) Ltd. found the
following deviation from the registered monitoring plan:
Deviation 1 : Estimation of wastewater volume treated during equipment outage period
According to monitoring plan defined in the registered PDD, Qy,ww (volume of wastewater treated) is to be
monitored continuously and recorded daily by a flow meter. However, Qy,ww was not measured and recorded
daily via flow meter since the monitoring period started from 03 March 2010 till 30 June 2010 (for Anaerobic
1A lagoon) & from 03 March 2010 till 18 July 2010 (for Anaerobic 1B lagoon). It was confirmed during on
site verification that the flow meter was only in operation starting from 01 July 2010 onwards for Anaerobic
1A lagoon & starting from 19 July 2010 onwards for Anaerobic 1B onwards.
Remarks: This Request for Deviation is applicable for Kilang Kelapa Sawit Serting site
Both lagoons were covered since the start of the monitoring period, but waste water flow meters were installed
at separate timing. The actual start of monitoring period is from 3 March 2010 instead of 1 March 2010 as
evident via review of the raw data records, collected for monitoring parameters via data logger. The verification
team considered this to be conservative as the project participant decided not to claim for any emission
reductions from 1 March 2010 to 2 March 2010
Similarly at the 2nd site, i.e. Kilang Sawit Jengka 8,the actual start of monitoring period is from 5 March 2011.
The project participant also will not claim for any emission reductions starting from 1 March 2011 till 4 March
2011, which is deemed to be conservative
The reason for the deviation is described as follows:
1. The original PDD submitted to the UNFCCC for registration defined the wastewater volume (Qy,ww),
using an approach taken from publication released by the Department of Environment (DoE), Malaysia
(i.e. Industrial Processes & The Environment (Handbook No.3), Crude Palm Oil Industry). It uses an
effluent (Palm Oil Mill Effluent) conversion factor to estimate the wastewater amount. Hence, the
formula used for determination of wastewater volume is:
Volume of waste water = Fresh fruit bunches (FFB) processed X Effluent conversion factor
2. The conversion factor has been determined as the ratio between the amount (m3) of wastewater
generated by the palm oil mill and the amount (ton) of fresh fruit bunches (FFB) processed by the palm
oil mill
3. However during the initial stage of project activity at Kilang Kelapa Sawit Serting, the project
experienced delay in the installation of waste water flow meter. The delay resulted from the rotation of
asset installation at all project participant sites. The priority of the equipment to be installed will be in
accordance to the fully operational sites first followed by Serting site, which was just commissioned in
March 2010. Hence, the installation process at this site took a few months after the unit was purchased.
These are all supported via review of the “Work schedule for wastewater flow meter installation in
2010”, “OMM Site Visit Checklist Form”, “Weekly Report Week 26” & email containing summary of
OMM (Operation Management Meeting) discussion dated 14 July 2010
From the review of the “Work schedule for wastewater flow meter installation in 2010”, the verification
team was able to verify that there are 7 other projects sites (belong to the same project participant i.e.
AES AgriVerde Services (Malaysia) Sdn. Bhd.) that are scheduled for flow meter installation starting
from beginning of January 2010 till June 2010, prior to Serting site (in July 2010). Hence, the
verification team accepted the justfications provided by the project participant, regarding the delay for
installation of the flow meter
Through the review of the “Weekly Report Week 26”, “OMM Site Visit Checklist Form” and also
through cross checking the raw data recorded via data logger during on site visit, the verification team
was able to confirm that on 01 July 2010, the flow meter had started to be operational (for Anaerobic 1A
lagoon).
As for the flow meter installation for Anaerobic 1B lagoon, it was evidenced through the email
containing summary of OMM (Operation Management Meeting) discussion dated 14 July 2010 &
“OMM Site Visit Checklist Form”, the installation was completed on 14 July 2010. However, it
experienced some error in data capture & further repair was carried out. Eventually on 19 July 2010,
flow meter starts the operation for Anaerobic 1B lagoon. Cross checked the raw data recorded via data
logger & confirmed there are no readings available between 14 July 2010 until 18 July 2010. The raw
data recording had started eventually on 19 July 2010
4. Hence, for the period prior to the installation of flow meter i.e. from 03 March 2010 till 18 July 2010,
Qy,ww has been determined as follows:
Qy,ww = Site specific conversion factor (m3/ton FFB) x Vintage FFB processed (ton)
5. The site specific effluent conversion factor (m3/ton FFB) will be determined based on the monitoring
data gathered starting from the installation of the wastewater flowmeter until the end of the crediting
period (30 September 2011) divided with the quantity of FFB processed during the period.
6. Vintage ton FFB processed will be based on the amount of fresh fruit bunches processed during vintage
period prior to the installation of the wastewater flow meter.
7. Remarks: The request for deviation period is from 03 March 2010 till 18 July 2010. In view of separate
installation dates for the waste water flowmeter at Anaerobic 1A & 1B lagoon (approximately 19 days
apart), the project participant decided to apply the for deviation up to 18 July 2010. This is also due to
partial available data of Qww during the period from 01 July 2011 till 18 July 2010. The decisions has
been accepted by the verification team as this is deemed more conservative – see details below (Section:
Estimating impact of deviation to the emission reductions)
Deviation 2 : Estimation of project electricity consumption prior installation of kWh meter at Kilang
Kelapa Sawit Serting
As-built drawing on 10 January 2010 shows presence of electricity meter upon completion of electrical works
at site. This was confirmed in an email by Kyowa stating electrical job completed on 29 Jan 2010 with test run
and commissioning at site, which include multi-range meter. However, the equipment experienced force
outage from the start up of operation until it was being replaced on 12 May 2010.
The initial unit of electricity meter installed on 29 January 2010 had to be replaced due to the unit required to
enter a code in order for data retrieving. This is evident via email communication & reporting by the Regional
Maintenance Technician dated 01 April 2010. The project participant took another more than a month for the
replacement to be made by their contractor. It was to source, install and test satisfactorily of the electricity
meter at the project site until it was replaced on 12 May 2010. Delivery order dated 6 May 2010 was verified
& accepted by the verification team
For the period prior to the replacement of the kWh meter starting from 01 March 2010 till 11 May 2010,
kWhproject is determined as:
Rated capacity of equipment (kW) x 24 hours / day x 365 days / year x (1+10%) (to account for distribution
loss)

Deviation 1 : Estimation of wastewater volume treated during equipment outage period
The proposed deviation does not require a revision of monitoring plan or the changes from the project activity
as described in the registered project design document since the deviation is only applicable for the specific
period during the 1st verification.
The volume of wastewater has been measured continuously via the use of flow meter since its operational
date starting from 01 July 2010 onwards for Anaerobic 1A lagoon & starting from 19 July 2010 onwards for
Anaerobic 1B lagoon & this is in line with the monitoring plan described in the registered PDD
The verification team was able to verify the evidence of operational date based on review of OMM Site Visit
Checklist Form & also cross checking the raw data excel sheet which contains data downloaded from
datalogger & confirmed the operational dates stated in the monitoring report as correct
Deviation 2 : Estimation of project electricity consumption prior installation of kWh meter at Kilang
Kelapa Sawit Serting
The proposed deviation does not require a revision of monitoring plan or the changes from the project activity
as described in the registered project design document since the deviation is only applicable for the specific
period during the 1st verification.
The electricity consumed by the project activity equipment has been measured continuously via the use of
kWh meter since its operational date starting from 12 May 2010 onwards (i.e. the date when the kWh meter
was replaced) & this is in line with the monitoring plan described in the registered PDD
The verification team was able to verify the evidence of operational date based on review of raw data
spreadsheet which indicated that the kWh readings are available starting from 12 May 2010 onwards

Deviation 1 : Estimation of wastewater volume treated during equipment outage period
The proposed deviation does not have any impact on the estimates of the emission reductions for the proposed
project activity. The reason is because the parameter Qy,ww is only used for the demonstration of 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 AMS.III.H
Version 9 methodology
According to AMS-III.H Version 9 methodology, paragraph 34 “…..the calculation of emission reductions
shall be based on the amount of methane recovered and fuelled or flared, that is monitored ex-post. Also for
these cases, the 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 (COD removed
is the difference between the inflow COD (CODy,ww,untreated) and outflow COD (CODy,ww,treated)), compared with
the technology used in the baseline.”
During on site verification, it was found that the site specific conversion factor has been calculated as 1.16 m3
/ tFFB. This has been calculated starting from 19 July 2010 onwards (available data of flow meter readings
since 19 July 2010) for Anaerobic 1A & 1B lagoon till 30 September 2011.
The values are accepted since the amount of FFB processed per month is similar during the period when the
volume of wastewater was not monitored (i.e. 03 March to 18 July 2010)
The verification team found that based on the entire monitoring period (i.e. from 03 March 2010 to 30
September 2011), the methane produced per unit of COD removed calculated is 0.0539 tonnes CH4 / tonnes of
COD which is lower than the baseline value (0.17 tonnes CH4 / tonnes of COD).
Comparing with the published conversion factor (0.70 m3 / tFFB, taken from publication released by the
Department of Environment (DoE), Malaysia (i.e. Industrial Processes & The Environment (Handbook No.3),
Crude Palm Oil Industry), the methane produced per unit of COD removed calculated is 0.0600 tonnes CH4 /
tonnes of COD which is also lower than the baseline value (0.17 tonnes CH4 / tonnes of COD).
This is clearly in line with the AMS-III.H Version 9 methodology, paragraph 34 requirements. Therefore, this
substantiates that the proposed deviation does not caused any impact on the estimates of the emission
reductions
Deviation 2 : Estimation of project electricity consumption prior installation of kWh meter at Kilang
Kelapa Sawit Serting
Hence, for crediting period data prior the installation, a conservative approach was employed to estimate the
electricity consumption of the project activity. The project electricity consumption was compared between
actual site specific data and estimation from equipment specification. The estimation was determined by
project activity equipment running at fully rated capacity with 24 hours and 365 days of operation plus 10% to
account for distribution losses and the more conservative value was selected.
For the period prior to the replacement of the kWh meter starting from 01 March 2010 till 11 May 2010,
kWhproject has been calculated & found to be much higher than the months where the actual monitoring
occurred (i.e. average of approximately more than 14,000 kWh). The actual total monitored kWhproject =
12,280 kWh, (taking total from 12 May 2010 till 30 September 2011)
The deviation has resulted in higher project emissions (PEy, power) for March till 11 May 2010
Hence, according to AMS-III.H Version 9 methodology, paragraph 34 requirements, project emission (i.e.
PEy,power) will be calculated & deducted from the emission reductions calculated