I-DEV0439: A.T.Biopower Rice Husk Power Project in Pichit, Thailand

NOTE: When inserting the inforation for this deviation we encountered difficulties with the formatting of the data. Please refer to the attached document (Annex VI: PDF representation of the F-CDM-DEV-ISS form.) which shows the form in a PDF format.

The deviation is requested for the registered CDM project “A.T. Biopower Rice Husk Power Project in Pichit, Thailand (UNFCCC reference 1026)”.
The project boundary encompasses the power plant at the project site, the means for transportation of biomass to the project site (e.g. vehicles), and all power plants connected physically to EGAT’s electricity system (the system that the project is connected to). It has been found that the project boundary is still consistent with the information mentioned in the registered PDD.
The deviation request is for the parameter “On-site fossil fuel consumption of diesel for start-up/auxiliary use, FFproject plant”. This parameter (FFproject plant), in absence of the continuous monitoring (as required by the PDD, page 38), was calculated using alternative methods. Therefore, this request has been made for the approval of the alternative calcualtion method, as detailed below, of the estimation of FFproject plant.
Following the registered PDD, the project proponent had installed a fuel meter to continuously measure the quantity of diesel oil consumption in the boiler. However, during July 1, 2007 to November 6, 2008 the fuel meter malfunctioned and underwent maintenance. Therefore, the deviation is only requested for the period (01/07/2007 – 06/11/2008), when the fuel pump meter malfunctioned.


(The clear diagram of the diesel tank and monitoring devices can refer to Annex V)

It was verified on site that the diesel oil is stored in the Fuel Tank and used in the project activity for two purposes;
1. On site fossil fuel consumption of diesel for start-up/auxiliary use (FFproject plant)
2. Fossil fuel consumption for on-site transportation of rice husk (FTrans)
All diesel used in the project activity is accounted for as project emissions. The FTrans was monitored correctly as per the monitoring methodology and registered monitoring plan (measured continuously, using a volume meter). Only FFproject plant was deviated as its meter malfunctioned and was unable to quantify the FFproject plant as per monitoring methodology and registered monitoring plan. This is the reason for requesting this deviation.

The FFproject plant is determined following the equation given below.
FFproject plant = Initial stock inventory – End stock inventory + Total fuel purchase receipts – FTrans

Initial and End of Stock Inventory
The initial and end of stock inventory is monitored by the Level Transmitter (LT 4001) which is connected to the DCS system.

Initial stock inventory = Quantity of fossil fuel in the fuel tank at the initial period (July 01, 2007), this data is measured by LT and is displayed on DCS
End stock inventory = Quantity of fossil fuel in the fuel tank at the end period (November 06, 2008), this data is measured by LT and is displayed on DCS.

The Level Transmitter measures the level of the diesel oil in the fuel tank and then detected signal of level transmitter is converted automatically into the quantity of fuel (Litre) in the tank. The data of fuel quantity in the tank (stock inventory) can be read on the screen of DCS in the control room. The stock inventory is recorded by the Shift Operator on monthly basis.

Total Fuel Purchase Receipts
The data is collected from the total fuel purchase invoices during the period July 01, 2007 – November 06, 2008.

Fossil Fuel Consumption for On-Site Transportation of Rice Husk (FTrans)
This parameter is measured continuously using the fuel pump meter which has undergone calibration yearly according to Thai regulation /Annex I/.

Consistency with the Applied Methodology ACM0006 Version 4
Quote from the methodology ACM0006 version 4 page 48
“On-site fossil fuel consumption for the operation of the biomass power plant should be metered through mass or volume (flow) meters, or with an energy balance over the verification period, considering stocks at the beginning and at the end of each verification period. Where possible, project participants should cross-check these estimates with fuel purchase receipts.”
Refer to the ACM0006 version 4 page 48; there are two approaches to monitor on-site fossil fuel consumption in the project activity (i.e. diesel) as following.
1.) Metering through mass or volume (flow) meters
2.) Energy balance over the verification period, considering fuel stocks at the beginning and at the end of each verification period.
Cross reference: With fuel purchase receipts.

In this project activity, diesel onsite consumption is used for two purposes these are for on site transportation and for consumption in the boiler as start-up / auxiliary fuel. In addition, the boiler is a rice husk fired boiler and not co-fired boiler/Annex III/. The stock inventory at the beginning and at the end of verification is being used to quantify diesel consumption in the boiler. However, diesel consumption is not being considered for the energy balance as it uses for start-up purpose in the distillate fuel burner only (to support the flame).
Thus, by considering the stocks at the beginning and at the end of each verification period and cross checking with the fuel purchase receipts. The deviation is in accordance with the applied methodology accordingly.

For data corroboration purposes ; Installation of New Fuel Meter
Furthermore, the new fuel meter was installed/Annex IV/ to continuously monitor fuel consumption for the boiler directly since November 07, 2008. This deviation is requested only for the period of July 1, 2007 – November 6, 2008. Hence confirm that starting from November 07, 2008 onwards, the quantity of fuel used in the boiler will be monitored using the fuel pump meter which will be monitored continuously.

The deviation request does not require a revision of monitoring plan or the changes from the project activity as described in the registered project design document. The deviation is limited to a period during 01/07/2007 – 06/11/2008. The project participant installed the new fuel pump meter on 07/11/2008. Hence, on site fossil fuel consumption of diesel for start-up/auxiliary use (FFproject plant) will be monitored using fuel meter which is in line with the registered PDD and applied methodology ACM0006 Version04.

As stated above, the new fuel pump meter has been installed onsite for the purpose of measuring the diesel consumption in the boiler. Thus, from November 07, 2008 onwards, the monitoring of FFproject plant is in accordance with the applied methodology ACM0006 Version 04. Only for the period requested for deviation (July 1, 2007 – November 6, 2008) FFproject plant was monitored by considering the fuel stocks at the beginning and at the end of the verification period and cross checked with the fuel purchase receipts.
Conservativeness of Deviation Request
This deviation request is found in accordance with the applied methodology accordingly. Thus, the deviation results in no significant impact on the emission reductions from the project activity.
The conservativeness of the method (FFproject plant = Initial stock inventory – End stock inventory + Total fuel purchase receipts – FTrans) used for calculating the parameter FFproject plant can be justified through the following points:
1. All diesel coming in the project activity is accounted for project emissions
2. The entire diesel inventory is available. The stock inventory can be read on the screen of DCS in the control room and is also recorded by the Shift Operator on a monthly basis
3. All fuel purchase invoices & sales receipts for the entire period of deviation are available.
4. The parameter FTrans is being monitored correctly as per monitoring methodology and registered monitoring plan
All the supporting documents & cross checks for the values of the parameters used in the calculation of FFproject plant are available. Also, since all the diesel is accounted for the calculation of project emissions, hence the alternative method for calculation of FFproject plant is conservative.
It was also found during the site visit that the Level Transmitter which is used for monitoring the initial and end of stock inventory was not calibrated during the period for deviation. It was calibrated later on the 10/11/2009. The results of the delayed calibration shows that the error is smaller than the maximum permissible error of the instrument. Hence, the non-compliance with the calibration frequency requirements will be applied in accordance with EB 52 Annex 60 (Guidelines for Assessing Compliance with the Calibration Frequency Requirement) during the verification process of the project activity.
From the above discussion, the determination method of fossil fuel (i.e. diesel) as per this deviation request is conservative. The uncertainty of the calculations is considered as low because the factors used are factors that come from registered laboratory report (PTT laboratory) which are traceable to Internaltional Standard (ASTM D 4052- 96)/Annex II/, they were verified and deemed appropriate.