I-DEV0447: Request for deviation on the : (1) sampling process for the monitoring of the Chemical Oxygen Demand (COD) for untreated and treated wastewater against the monitoring plan, and (2) internal QA/QC requirement not met during the monitoring period.

The request for deviation is for a registered CDM project activity “Methane Recovery in Wastewater Treatment, Project AIN07-W-04, Sumatera Utara, Indonesia” (project reference number 2130), which was registered against AMS-III.H version 7 on 16/01/2009. The request for issuance was submitted and rejected by the EB as the project participant (PP) had deviated from the provisions of the registered monitoring plan on the monitoring of untreated and treated COD. The deviations were as follows:

The Monitoring Plan of the registered PDD (page 25 and 26) has defined that the monitoring of CODuntreated and CODtreated shall be measured and recorded semi- annually via third party sampling and analysis.

In the same monitoring plan, under the QA/QC procedure to be applied, the following additional statement has been included : ”In addition, internal sampling on a monthly basis will be conducted to ensure proper digester operation”.

There were two deviations against the above requirements as follows:

Deviation no. 1: Sampling process for the monitoring of the Chemical Oxygen Demand (COD) for untreated and treated wastewater against the monitoring plan

The sampling of the POME for the measurement of CODuntreated and CODtreated was carried out by internal staff instead of by third party.
The reason for this deviation was due to the fact that it has been the practice from the beginning of the project implementation that the ‘sampling’ is carried out by a trained internal staff instead of by a third party. In fact PP, had established a standard operating procedure titled “Sample Collection of Palm Oil Mill Effluent Wastewater and Related Field Analysis” which described this process. The collected samples were sent to a third party accredited laboratory for analysis.

Deviation no. 2: Internal QA/QC requirement not met during the monitoring period

During the first Monitoring Period from 16 January 2009 to 28 February 2010, the internal sampling on a monthly basis was not carried out for the months of January 2009, January 2010 and February 2010.
The internal monthly sampling was intended purely as part of the QA/QC procedure to ensure proper operation of the digester and was not intended to be used in the ER calculation.

The deviations do not require revision of the monitoring plan or change from the project activity, as the third party sampling and analysis is already being implemented in accordance with the approved monitoring plan described in the registered PDD, beginning from 1 March 2011. Likewise, the internal monthly sampling is also being carried out as specified in the plan beginning from 1 March 2011.

For deviation no. 1:

The verification team had verified that the sampling point was appropriate and the sampling method was in accordance with the sampling procedure of the accredited laboratory. The internal staff that performed the sampling had been adequately trained. An interview with the staff revealed that the staff is competent to carry out the sampling. The COD analysis was carried out by a third party laboratory. The results were within the normal range of the POME, as reported in the “Industrial Process and the Environment (Handbook no.3) Crude Palm Oil Industry”, published by the Department of Environment, Malaysia. Hence, it can be concluded that the sampling by the internal staff did not impact the estimates of the emissions reductions.
The methodology (AMS-III.H version 7) did not specify who should carry out the sampling. Therefore, this deviation does not change the applicability of the methodology.

For deviation no. 2:

The internal monthly samplings were meant for the monitoring of the digester operation. According to the Monitoring Plan, only the COD analysed semi annually by a third party laboratory was to be used in the calculation of the ER, thus this internal monthly samplings has no significant impact to the project ER calculation.
The methodology (AMS-III.H version 7) did not specify the QA/QC procedure for the monitoring of the digester operation. Therefore, this deviation does not change the applicability of the methodology.