I-DEV0381: Deviation from Monitoring Plan for parameters (a) volume of wastewater treated and (b) electricity consumed by project activity equipment

During the first verification period of the registered CDM project activity (AMA08-W-23, Methane Recovery in Wastewater Treatment, Sarawak, Malaysia, CDM Ref. No. 2635), Det Norske Veritas identified some deviations in the monitoring plan and monitoring report of the project. The monitoring period covered by the verification is from 13 November 2009 to 31 July 2010. There are deviations from the registered monitoring plan (registered on 13 November 2009) regarding the (a) volume of wastewater treated (Qy,ww) and (b) electricity consumed by the project activity equipment (kWhproject).
1) For Qy,ww, the monitoring plan in the registered PDD states that this parameter will be monitored continuously and recorded daily by a flow meter. However, Qy,ww has not been measured and monitored via flow meter from the start of the monitoring period 13 November 2009 to 12 March 2010. The continuous monitoring and daily recording of Qy,ww only commences from the flow meter installation date of 13 March 2010. This is due to the time it took to change the monitoring system to comply with the request for review raised by the EB on 1 September 2009. The implementation was started only when registration of the activity as a CDM project was ensured (13 November 2009).
The project design document (PDD) submitted for registration defined the ex-post monitored volume of wastewater treated using an approach taken from a publication by the Malaysian Department of Environment (DOE) . In the publication, palm oil mill effluent (POME) conversion factor is used to estimate the volume of wastewater treated. The conversion factor is the ratio between volume of wastewater from a typical palm oil mill and the amount of fresh fruit bunch processed and the unit is m3/t FFB.
The project was submitted for registration on 6 June 2009 and a request for review was raised by the EB on 1 September 2009. As a result of the request for review, the monitoring system was changed to include flow meter to monitor Qy,ww and it took several months for the project developer to source, test and install satisfactorily the appropriate flow meter for the wastewater. The cost for the flow meter was quoted on 10 November 2009 and a purchase order was issued on 9 December 2009. The project developer received the flow meter on 22 January 2010 and installation works completed on 9 March 2010. The flow meter was subsequently commissioned on 13 March 2010 after a period of testing (from 9 to 12 March 2010). It took the project developer 1.5 months to complete the installation of the flow meter due to the project developer’s internal scheduling and logistics . For the period prior to the installation of wastewater flow meter (13 November 2009 to 12 March 2010), Qy,ww is determined as follows:
Qy,ww = site specific POME conversion factor (m3/ton FFB) x vintage FFB processed (ton)
Site specific POME conversion factor (m3/ton FFB) is based on the actual monitored data obtained starting from the installation date of the wastewater flow meter until the end of this monitoring period (31 July 2010), divided by actual measured quantity of FFB processed during the same period.
Vintage FFB processed (ton) is the actual amount of fresh fruit bunches processed for the period prior to the installation of wastewater flow meter.

2) For kWhproject, the monitoring methodology in the registered PDD states that this parameter will be continuously monitored and recorded by electricity meter. However, kWhproject has not been monitored via electricity meter from the start of the monitoring period (13 November 2009) to 11 January 2010. The continuous monitoring and recording of kWhproject only commences from the electricity meter commissioning date of 12 January 2010. This is due to the time it took to change the monitoring system to comply with the request for review raised by the EB1 on 1 September 2009.

For the ex-post monitored value of kWhproject, the initial PDD submitted for registration assumed that all project activity equipment operate at full rated capacity, plus 10% to account for distribution losses, for 8 760 hours per annum.
The project was submitted for registration on 6 June 2009 and a request for review was raised by the EB on 1 September 2009. As a result of the request for review raised, the initial PDD was changed to include kWh meter to monitor kWhproject and it took several months for the project developer to source, test and install satisfactorily the appropriate kWh meter for the monitoring of electricity consumed by the project activity equipment. Cost for the electricity meter was quoted on 1 October 2009 and a purchase order was issued on 26 October 2009. The project developer received the electricity meter on 24 November 2009 and installation and commissioning completed on 12 January 2010. For the period prior to the installation of the kWh meter (13 November 2009 to 11 January 2010), kWhproject is determined as follows:
kWhproject = [rated capacity of equipment (kW) x 24 (hr/day) x 365 (days/year)] *1.10
The 10% is to account for distribution losses.

The proposed deviation from the monitoring plan does not require a revision of the monitoring plan or changes from the project activity as described in the registered PDD as the deviation is only for a specific period in the initial verification. The monitoring period covered by the initial verification is from 13 November 2009 to 31 July 2010. Subsequent to the commissioning dates of both meters; 13 March 2010 for flow meter and 12 January 2010 for electricity meter, the parameters are monitored as per the registered monitoring plan. Also, it is confirmed that there are no permanent changes to the project activity as described in the registered PDD.

The impact of this deviation request for parameters as explained above is as follows:-
1) Volume of wastewater treated (Qy,ww) not monitored via flow meter for a certain time period: The proposed deviation does not impact the emission reductions of the project as this parameter is only used for the demonstration 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 paragraph 34 of the applied methodology (AMS-III.H version 9) which states that 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.
A higher conversion factor is more conservative as the methane produced per COD removed would have been higher. The present request for deviation is to use a conversion factor of 1.40 m3/tFFB for the period up to installation of the flow meter. This is calculated from the historical data after installation of the flow meter from 13 March to 31 July 20104. This conversion factor is representative since the monthly amount of FFB processed is similar for these months compared to the monthly amount of FFB processed in 2008 and 2009 . The conversion factor of 1.40 m3/tFFB is more conservative than the data of a typical facility of 0.70 m3/tFFB2 .
Cross-checking shows that the post-project implementation (13 November 2009 to 31 July 2010) average methane produced per unit of COD removed (0.16 tonneCH4/tonneCOD) is lower than the baseline (0.17 tonneCH4/tonneCOD ), which was demonstrated in accordance to the requirements from paragraph 34 of AMS-III.H. Hence, this deviation request has no impact on the emission reduction in this deviation period and is deemed reasonable.
2) Electricity consumed by the project activity equipment (kWhproject) not monitored via electricity meter for a certain time period: The deviation request results in additional project emissions as for the month of November and December 2009, the kWhproject has been calculated as 20 459 kWh per month using the formula above. The rated capacity of the equipment used in the calculation has been evidenced by the corresponding equipment’s specifications sheet . The total actual monitored kWhproject for the month of January to July 2010 is only approximately 7% (average of 1 442 kWh per month) of the estimated monthly kWhproject. The proposed deviation reduces emission reductions of the project by 0.01% for this monitoring period. Also, the formula above is in line with the latest version of the methodology (AMS-III.H version 14, paragraph 35). Hence, the deviation request for this parameter is deemed to be conservative.