I-DEV0414: Deviation from the monitoring plan for monitoring parameter ID 13 “ Amount of chemical oxidizing agents entering the system boundary” regarding the monitoring frequency and the power imported from grid.

The request for deviations is for a registered CDM project activity “Methane Capture and On-site Power Generation Project at Sungai Kerang Palm Oil Mill in Sitiawan, Perak, Malaysia (Reference no. 2181).)”, which was registered against AM0022 version 4 on 26 January 2009. During the first periodic verification, as per the requirement of VVM para 210, SIRIM QAS Intl. found that the project participant (PP) had deviated from the provisions of the registered monitoring plan. Two deviations were found as follows:

i)Deviation no. 1: the monitoring frequency for ID 13. “Amount of oxidizing agents entering the system boundary (Cchemical_ox)”

In accordance with the approved revised monitoring plan, “the chemical oxidizing agents (kg SO4/m3) will be analyzed daily in the in-house laboratory for a period of one month to observe the fluctuation pattern of chemical oxidising agents (kgSO4 /m3) in the POME. If there is no fluctuation on the monitored value of the parameter during the period of one month, the parameter can be monitored by taking one sample per month. The sulphate content will be considered as major fluctuation if the concentration exceeds 5000 mg/l continuously for more than three times. In this case, the sulphate content will be monitored daily”. During this monitoring period, the PP had not conducted the daily analysis by the in-house laboratory for a period of one month until 1 December 2010.

The reason for the deviation was that, in the initial submission for revision of the monitoring plan in February 2010, PP had indicated that this parameter will be monitored by taking samples and sending them to the accredited laboratory at least three times per month for the first 6 months. However, this request was not approved by the EB. EB requested further clarification on this matter on 22 June 2010. Clarification was provided in July 2010 and subsequently EB approved the request on condition that further corrections be made to the monitoring plan. The correction requested was that the daily monitoring and analysis by the in-house laboratory be carried out for a period of one month and that this may be reduced to once a month if there is no major fluctuation (i.e. value of more than 5000 mg/l) in the results continuously for more than three times. Due to some miscommunication, the requested change to the monitoring plan was only submitted in February 2011. Subsequently the final approval from EB was received on 1 March 2011 indicating that the approval had been granted on 7 September 2010.

From the start of operation of the project activity on 1 June 2009, the amount of oxidizing agent in the POME entering the anaerobic digester tanks (ID 13- Oxidizing chemical agents entering system boundary) had been analyzed by sending samples to an accredited laboratory at least three times a month. The necessity to monitor the sulphate content daily for the period of one month was not identified until 1 December 2010 when the request for revision of the monitoring plan for another similar project activity owned by the same PP was approved by the EB. Daily monitoring and analysis by PP’s in-house laboratory was carried out from 1 December 2010 until 28 February 2011. During this period, no major fluctuation in reading was detected.

ii)Deviation no. 2- Power imported from grid

According to the registered PDD, power consumed by the project actvitiy shall be generated by the existing biomass boiler that will be retrofitted with a burner for the biogas. During the monitoring period from 1 June 2009 to 31 December 2009, the biogas was not sent to the boiler due to problems in connecting the pipelines to the boiler. Thus, the electricy had to be imported from the grid for the project activity. Since no power meter had been installed to measure the grid electricity consumption for the project, the electricity consumed by the project activity equipment has to be estimated by the following formula, as per “Tool to calculate baseline, project and/or leakage emissions from electricity consumption”(Version 01):

Electricity consumed by the project activity equipment =
(total equipment power rating x hours of operation) x grid emission factor x distribution loss

Both deviations do not require revision of the monitoring plan or change from the project activity as described in the registered PDD, as

i) the results of three months of daily monitoring and analysis (between 1 December 2010 to 28 February 2011) showed no major fluctuation and thus justified the once a month monitoring and analysis.

ii) the renewable energy component (i.e. the retrofitting of the existing biomass fired boiler), will be installed by the PP in the next monitoring period.

i)Deviation no. 1- the monitoring frequency for ID 13. “Amount of oxidizing agents entering the system boundary (Cchemical_ox)”

The purpose for daily analysis for a period of one month was to determine the fluctuation pattern of chemical oxidising agents (kgSO4 /m3) in the POME. In accordance with the revised monitoring plan, if there is no fluctuation in the monitored value of the parameter during the one month period where daily monitoring and analysis is carried out, the parameter can subsequently be monitored by taking one sample per month. The sulphate content will be considered as major fluctuation if the concentration exceeds 5000 mg/l continuosly for more than three times during that one month period. In this case, the sulphate content was monitored daily for a period of three months (1 December 2010 to 28 February 2011) using the nationally accepted method and the results showed no fluctuation i.e. none of the results exceeded the 5000 mg/l. Therefore, the once a month monitoring can be justified. During this monitoring period, the sulphate content had actually been monitored and analysed by an accredited laboratory at a frequency of more than once a month.

In conclusion, the deviation will not have any impact on the estimates of the emission reductions.

ii) Deviation no. 2- Power imported from grid

The electricity consumed by the project activity equipment which is imported from the grid is one of the project emissions that need to be considered. Since there was no power meter installed during this monitoring period, the estimation of the power consumption by using the equipment power rating multiplied by the maximum operational hours is considered conservative as :

a)The power rating (which indicates the maximum power of the equipment as designed) of all the equipment involved in the project activity is used. All the equipment will not run at the maximum power rating.
b)The project equipment is assumed to be operating for 24 hours per day for the first monitoring period of 214 days. The actual operating hours of all the equipment is actually less than 24 hours per day.
The total power consumption estimated using the total power rating of all the equipment and the assumption that this equipment will be operated on a 24 hour basis will give a higher value that would lead to a higher estimate of project emissions. Hence, the actual total emission reduction will be less and as such can be deemed to be conservative.