I-DEV0388: Guidance regarding acceptability of deviation related to the monitoring procedure of the parameters EGGEN : Total electricity generated and EGAUX : Auxiliary consumption of electricity

The project has approached for fourth periodic verification (Monitoring period from 02nd April 2008 to 01st July 2009) and thus the deviation is requested from 02/04/2008 to 19/06/2009. The requested deviation is due to the non compliance observed in the monitoring procedure for the following parameters as mentioned in the registered PDD and approved revised monitoring plan:
EGGEN : Total electricity generated
EGAUX : Auxiliary consumption of electricity

Deviation Requested:
According to the monitoring plan of the registered PDD and the applied methodology ACM0004, version 01 EGGEN: Total Electricity Generated and EGAUX: Auxiliary consumption of electricity need to be monitored continuously with the measurements being taken online and DCS metering is required to be followed. However, the same could not be adhered to for the period from 02/04/2008 to 19/06/2009 in the proposed monitoring period of 02/04/2008 to 01/07/2009.

Reason for Deviation:

During the site visit of the third monitoring period (02/04/2007 to 01/04/2008), DOE had indentified that the parameters EGGEN & EGAUX are not being monitored through DCS, which is a requirement of the approved revised monitoring plan and the applied methodology ACM0004, version 01. Thus a deviation for the same was submitted to the CDM EB by DOE for the 3rd monitoring period and subsequently approved by the CDM EB (http://cdm.unfccc.int/Projects/deviations/02971 ). It was assumed at the time of request for deviation that integration of the energy meters into the DCS will be implimentated by end of the 3rd monitoring period and thus deviation was sought for the particular monitoring period only.

However the procedure of DCS integration of energy meters, that Phillips Carbon Black Limited Plant (PCBL) had to undertake in order to meet the monitoring requirements, was long drawn because of the below reasons. Following is the chronology of actions that were taken for DCS integration by PCBL finally leading to the DCS integration on 19/06/2009.

Serial No./ Date/ Event
1./ May 2008/ Verifying DOE (SGS UK) raised the issue of DCS Integration for subsequent verification purposes with a revision of the monitoring plan and deviation for the monitoring period 02/04/2007 to 01/04/2008 (The deviation and the revision for the aforementioned period were approved by UNFCCC).
However the DCS integration of meters could only be effected by project participants during a planned shutdown./
2./ June 2008/ The plant was under planned Shutdown as per Indian Boiler’s Act, 1923 (Sections 7 or 8) for annual inspection. However the DCS integration could not be effected during this shutdown due to the following activities which needed to be conducted:
1. Preparation of a CAPEX Plan to estimate the budget for the relevant instrumentation
2. Getting the approval from the Plant Management for purchase of the same
3. Relevant trial runs

The same could not be conducted in the interim period of just one month since finding raised by DOE.
The Power Plant Planned Shutdown is an annual affair, which is mainly coordinated with on the Boiler Inspection dates as per Indian Boiler’s Act, 1923 (Sections 7 or 8). Hence the next due date was June 2009 where the DCS integration could be effected./
3./ May 2008 to October 2008/ The revision to the Monitoring Plan and the Deviation for the period 02/04/2007 to 01/04/2008 was under preparation and the same was sent to UNFCCC in October 2008.
The deviation for third monitoring period 02/04/2007 to 01/04/2008 got approved. The monitoring plan was subsequently revised to incorporate the deviation and approved by CDM EB on 21/02/2009./
4./ November 2008 to April 2009/ The DCS integration process was initiated by the project participant. There were discussions with the technology suppliers for the proper technology for integration during the period. Based on these discussions and trials, the CAPEX Plan was prepared in April 2009 and approved in May 2009./
5./ 11th June 2009/ The DCS integration was completed on 11/06/2009./
6./ 19th June 2009/ Formal operation of DCS initatied on 19/06/2009./

NOTE: When inserting the information for this deviation we encountered difficulties with the formatting of the above data set. Please refer to the attached document (PDF of F-CDM-DEV-ISS form) tabular representation of the above information in .PDF format.

Hence for the proposed monitoring period 02/04/2008 to 01/07/2009, a deviation is proposed until 19/06/2009 for the measurements of the parameters EGGEN – Total Electricity Generated and EGAUX – Auxiliary consumption of electricity where in it is proposed that the parameters would be measured as follows:

Recording Frequency: Shiftwise
Monitoring Location: Parameters are measured continuously by the energy meter of cumulative type installed at the site. The energy meter (generation meter and auxiliary meters) readings are displayed on separate display panels in the Control Room by the Panel Operators on duty. The energy meter readings are recorded in the plant log-book shift-wise and transferred to the in-plant monitoring system (SAP System) everyday. Manager In-charge would be responsible for calibration of the meters.

Therefore it is requested that CDM Executive Board allows the project activity deviation of non incorporating the DCS in the monitoring system of PCBL as per the approved revised monitoring plan from 02/04/2008 upto 19/06/2009 which is the first day of formal DCS operation in the PCBL system. This deviation is not applicable for rest of the monitoring period i.e. from 19/06/2009 to 01/07/2009.

As per the applied methodology ACM0004, version 01 and revised monitoring plan approved by CDM EB on 21/02/2009, both parameters EGGEN & EGAUX are required to be monitored through DCS system. Thus the revised monitoring plan approved on 21/02/2009 is in line with the ACM0004 version 01 and a revision in monitoring plan is not required for the submitted deviation.
It can be concluded that the indicated deviation in the monitoring frequency and the monitoring location for the parameters; EGGEN: Total Electricity Generated and EGAUX: Auxiliary consumption of electricity for the period from 02/04/2008 to 19/06/2009 neither require a revision of monitoring plan nor involves changes in project activity description as mentioned in the registered PDD.

There is no impact of this deviation on the estimation of emission reduction or emission reduction calculation. Same deviation was approved by the CDM EB during the third monitoring period with a condition of “the display of meter readings in the panels in the control room, and instruct the DOE to confirm that either the waste gas flow is constant or there is constant intake from the electricity consuming equipment (or recipient of electricity) to ensure no fluctuations within the time intervals of recording the display.”
During the site visit of fourth monitoring period on 26th and 27th October 2010, the verification team member has observed the DCS system was working properly and monitoring the data appropriately as mentioned in the registered PDD.
From the period 02/04/2008 to 19/06/2009, the generation and auxiliary electricity meters installed at the panel room are totalizers in nature, which provides cumulative readings and will get rest automatically to zero as verified from the manual under section 1.13 (Auto reset). The cumulative readings are being recorded in the logbooks for each shift. In this case, it was found that there was no uncertainty involved in the recording of the readings from the control panel meter. If there is any fluctuation within the time intervals of recording the display, it is then being covered in the next shift readings making no impact on the CERs calculation. Also It was verified during the third monitoring period that there are negligible fluctuations in the process of carbon black generation process & subsequent waste gas flow and did not involve any sudden surges as verified from the “total electricity generated”. The auxiliary consumption of the power plant also does not fluctuate significantly since it is dependent on the power generation of power plant itself.
Thus it can be concluded the meters installed at the panel are totalizers in nature and there are no fluctuations within the time interval of recording the display, with no impact on the calculation of the CERs.
The DCS system is intergrated with the energy meters and has started functioning on 19/06/2009. Since then, both parameters are being monitored countinously online through DCS, which is in line with the applied monitoring methodology ACM0004, version 01 and the revised monitoring plan approved on 21/02/2009.