Verification Report Voluntary Carbon Standard · · 2012-08-03Verification Report Voluntary Carbon Standard ... digester plant for palm oil mill effluent treatment at United Plantations

Verification Report Voluntary Carbon Standard

Danish Energy Management A/S

VCS VERIFICATION OF THE CDM PROJECT:

METHANE RECOVERY AND UTILIZATION

PROJECT AT UNITED PLANTATIONS BERHAD, JENDARATA PALM OIL MILL, MALAYSIA

Report No. 1128960

16 September 2009

TÜV SÜD Industrie Service GmbH Carbon Management Service

Westendstr. 199 - 80686 Munich – GERMANY

VCS Verification Report : Methane Recovery and utilization project at

United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia

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Verification Report: Name of Verification company: Date of the issue: TÜV SÜD Industrie Service GmbH, Carbon Management Service Westendstrasse 199 - 80686 Munich, Federal Republic of Germany

16 Sept. 2009

Report Title: Approved by: VCS Verification of the Project: “Methane recovery and utilisation project at United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia”

Rachel Zhang Deputy Head, Certification Body

Client: Project Title: Danish Energy Management A/S

Methane recovery and utilisation project at United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia

Summary: Summary: TÜV SÜD Industrie Service GmbH has performed the VCS verification of the registered CDM project: “Methane recovery and utilisation project at United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia” (Ref. 1153). The project consists of installation of closed continuous-flow stirred tank reactor (CSTR) anaerobic digester plant for palm oil mill effluent treatment at United Plantations Bhd. The recovered biogas would be used in the steam boiler of the group’s palm oil mill and refinery plant. Excess biogas, if any, would be flared through an open flare. The management of United Plantations Berhad is responsible for the preparation of the GHG emissions data and the reported GHG emission reductions. A document review, followed by a site visit was conducted to verify the information submitted by the project participant regarding the present verification period. Based on the assessment carried out, the verifier confirms:

that the project has been implemented and operated in accordance with the description given in the registered PDD (version 04, 25-06-2007, registration date 08-11-2007).

that the project is completely implemented as described in registered PDD. All the project components are in place (flare unit and heat production).

that the monitoring plan complies with the applied methodology (Methodology name and version).

The following parameters have not been measured since the project beginning: #6:Dlag, Depth of lagoon, #29 FRe, Flow rate of the heat generation equipment stack gases, #22a: Flame detection. Please see section 3.5 for details of approaches and actions taken. Conservative approaches have been adopted in order to ensure conservative estimate of the Emission Reductions. Comprehensive justification has been described in this report to detail the approaches used. Installed equipments essential for generating emission reductions run reliably and the



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meters are calibrated appropriately. The project is generating emission reductions as a CDM project. The verifier can confirm that the GHG emission reductions are calculated without material misstatements. Our opinion refers to the project’s GHG emissions and resulting GHG emission reductions reported, both determined due to the valid and registered project’s baseline, its monitoring plan and its associated documents. Based on the information we have seen and evaluated we confirm that the implementation of the project resulted in 25,087 CO2e of emission reductions during the verification period 01-01-2007 to 07-11-2007 Work carried out by: Number of pages: Verification team: Thomas Kleiser (Assessment Team Leader) Ivan Hernandez (GHG Auditor) Madhuri Nanda (GHG Auditor)

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1 Introduction 1.1 Objective Danish Energy Management A/S has commissioned an independent verification by TÜV SÜD Industrie Service GmbH (TÜV SÜD) of its registered CDM project: “Methane recovery and utilisation project at United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia”.

TÜV SÜD shall: ensure that the project activity has been implemented and operated as per the

registered PDD “Methane recovery and utilisation project at United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia” Version 04.-25-06-2007, and that all physical features (technology, project equipment, monitoring and metering equipment) of the project are in place, ensure that the published MR and other supporting documents provided are complete and verifiable and in accordance with applicable VCS requirements,

ensure that actual monitoring systems and procedures comply with the monitoring systems and procedures described in the monitoring plan and the approved methodology,

evaluate the data recorded and stored as per the “Avoided methane emissions from organic waste-water treatment”, AM0013 Version 04.

1.2 Scope and Criteria The verification scope is defined as an independent and objective review and ex-post determination of the monitored reductions in GHG emissions by the Designated Operational Entity. The verification is based on the submitted monitoring report, the validated project design documents including its monitoring plan and validation report, the applied monitoring methodology and any other information and references relevant to the project activity’s resulting emission reductions. These documents are reviewed against the requirements of VCS Modalities and Procedures and related rules and guidance.

The principles of accuracy and completeness, relevance, reliability and credibility were combined with a conservative approach to establish a traceable and transparent verification opinion.

The verification considers both quantitative and qualitative information on emission reductions.

The verification is not meant to provide any consultancy towards the client. However, stated requests for clarifications, corrective and/or forward actions may provide input for improvement of the monitoring activities.



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1.3 VCS project Description

Project activity: “Methane recovery and utilisation project at United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia”

Project Participants: United Plantations Berhad; and Danish Energy Management A/S

Location of the project: United Plantations Berhad Jendarata Estate 36009 Teluk Intan, Perak Darul Ridzuan, MALAYSIA

Crediting period: 01-01-2007 to 07-11-2007

The project activity involves the installation of a closed tank anaerobic digester plant with floating roof and continuous-flow stirred tank reactor (CSTR) for collecting biogas generated from the palm oil mill effluent (POME). The CSTR technology ensures continuous long working of the tank reactor without the need for sludge removal. The biogas generated is stored in the floating roof type tanks, which allows buffer storage for efficient operations of the boiler where the biogas is consumed. The biogas in the project activity is sent to the boiler at Unitata Berhad, one of the associated companies located adjacent to the palm oil mill. The boiler is attached with dual burner with automatic control for biogas flaring. Excess biogas, if any, would be sent to an open flare.

1.4 Level of assurance

The verifier has included the review of all the relevant documents and information that have impact in the data quality and final result of Emission Reduction during the verification exercise. In the cases where more information was required to ensure a reliable results or where mistakes were found, some corrections were raised asking for more details or modification of data.

2 Methodology Standard auditing techniques have been adopted. The verification team performs first a desk review, followed by an on-site visit which results in a protocol including all the findings. The protocol is attached to the report as Annex 1. The next step is to close out the findings through direct communication with the PPs and finally prepare the verification report. This verification report and other supporting documents then undergo an internal quality control by the CB “climate and energy” before submission to the VCS Board.

3 Verification Findings 3.1 Remaining issues, including any material discrepancy, from

previous validation



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No open issue or Forward Actions Request have been presented in the validation report.

3.2 Project Implementation The main components of the project (biodigester tanks, flare unit and heat production unit) have been implemented according to the description presented in the PDD. The project activity is completely operational, except for the parameters described below, the metering system, devices and requirements for the Emission Reduction determination have been implemented according the PDD.

The following parameters have not been measured since the project beginning:

#6:Dlag, Depth of lagoon #29 FRe, Flow rate of the heat generation equipment stack gases #22a: Flame detection. Please see section 3.2 for details of approaches

and actions taken.

No data and/or variables (except the one mentioned above) presented in the MR differ significantly from the stated in the registered PDD, which would to cause an increment of the ER in this period or in future periods in relation to the estimates in the registered PDD.

3.3 Accuracy of Emission Reduction Calculations

The Project Participant demonstrates through an analysis that they meet the 95% of confidence level for parameters measured with samples. Particularly the verifier reviewed the analysis, the formulas used to calculate the confidence level are adequate. (CAR1)

A correction (CAR3) was about Data #22a: Flame detection. Detection of flame in the open flare being on or off. This parameter was described in the spreadsheet, so the verifier asked for its inclusion in the measurements. The verifier also asked for the inclusion of flare temperature in order to determine the flare efficiency according the tool’s requirement. The “on/off” function was added to the SCADA from 1st June 2008 onwards. As such, a signal transmitter was added to link the thermocouple to the “on/off” reading in SCADA. The flare temperature will rise immediately and when reaches 500 deg C as detected by a thermocouple (signal sent to SCADA by transmitter) installed adjacent to the flare burner, a timer log starts (a SCADA program) which will register flame ON. There is no provision within the flaring system to enable the SCADA to capture the flare temperature (500 deg C) prior to 1st June 2008. As such, from January 2007 to May 2008, the flare computation in the file “Calc for PE Due To Flare - VER” and “Calc for PE Due To Flare - CER” has been amended to include flare efficiency as “0%” rather than “50%”. Please refer column L. From June 2008 onwards, this value has been maintained at “50%” efficiency. The approach used is conservative since they are considering the lowest flare efficiency (0%) in absence of temperature measurement. The action taken permits the proper monitoring of project emission due the flaring process.



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Other correction was raised (CAR4) in order to define a conservative approach for missed parameters #6:Dlag, Depth of lagoon and data #29 FRe, Flow rate of the heat generation equipment stack gases. About data #6:Dlag, Depth of lagoon: The measurements of this parameter has not been recorded since the beginning of the project activity. The project participant has implemented a procedure to measure the depth of the lagoon. The data recorded since April 2007 shows that the depth of the lagoon has stable range of 1.2meters to 2.3meters. The original design (which was reviewed) shows the depth of the lagoon of 1.8meter (in highest level) and 2.4meter (in lowest level). As conclusion, considering recent measurement and original design is justified the uses of the fraction of anaerobic degradation, fd = 0.5 for depth 1-5 m in the calculations before April 2007. For the date measured after April 2007 the direct measurement of depth of the lagoon indicates the use of the same facto (0.5) as fraction of anaerobic degradation.

About data #29 FRe, Flow rate of the heat generation equipment stack gases, has not been measured since the beginning, the approach used by the project participant is: The stack gas flow recommended by the manufacturer in the absence of flow meter is based on the following conservative parameters:

Maximum Biogas inflow rate of 550 Nm³ Maximum Excess Air level of 15% at an MCR of 100% Maximum Steam output of 4678 kg/hr Density of Exhaust Gas is 0.7934 Nm³ Exhaust Gas Temperature is 235 °C

At the above conservative conditions the maximum stack gas flow expected is 8500 Nm³/hr

An external laboratory carried out four test of flow stack gas monitoring. The stack gas measurement was done at different biogas inputs (rage between 200Nm3/hr to 550Nm3/hr), these results shown an average stack gas flow of 2609.27 Nm3/hr (at 200Nm3/hr biogas input, lower) and 5851.78 Nm3/hr (at 500Nm3/hr biogas input, higher).

The average of biogas inlet measured is 4230.52 Nm3/hr, so the approach to use 8500Nm3/hr for stack gas flow is conservative. No methane detected in the tests at detection level of <1ppm v/v.

The action taken to solve it is the installation of a flow meter which is already in place.

The conclusion of the Corrective Action Request 5 give information about parameter #9 HGBl,y Quantity of thermal energy that would be consumed in year y at the project site in the absence of the project activity using fossil fuel. The monitoring plan is not in line with the methodology. Following the comments in the methodology about, this parameter has to be measured continuously.



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The PDD says: The quantity of thermal energy that would be consumed in year y will be measured in terms of the quantity of steam generated using the biogas generated to displace the use of fossil fuel. The efficiency of the boiler will been predetermined.

PP is using this formula HGBl,y = (Steam Output x Steam Enthalpy at specified pressure / Baseline Boiler Efficiency)

The methodology says (comment in monitoring methodology): Thermal energy consumed is determined from quantity of fuel consumed and calorific value of fuel.

Based in the measurement of Flow rate of the biogas entering the heat generation equipment We propose this formula: HGBl,y = (methane consumed in biogas boiler x calorific value of methane x efficiency of biogas boiler) / efficiency of baseline boiler x emission factor of the baseline boiler fuel.

A couple of Corrections were raised (CAR10 and 11) in order to ensure the inclusion of data that correspond to the crediting period.

The Mistakes found in the spreadsheet like discrepancies with original sources and data out of range have been corrected, the final spreadsheet reflect the correctly this amendments, details can be found in CAR 12, 13, 14 and 15.

The system characteristics and integrity should be documented as was required in FAR 10 and 11

At the end all the corrections were done as were requested and the final result reflect correctly the Emission Reduction.

3.4 Quality of Evidence to Determine Emission Reductions

As part of the revision the external lab result were reviewed detecting the data out of range, at the end The values of CODa,in has been corrected in adequate manner, showing a figure that takes out the data out of range, see details in CAR6.

The issues related the quality of evidences for Emission Reduction Determination have been closed and the verifier can state that final result is correct.

3.5 Management and Operational System

The verifier reviewed the evidences submitted by the Project Participant (see IRL20), the documents submitted shown data like: Data of training, topics included, name and signature of the trainee, supervisor responsible, name and signature of trainer. CAR2

Information Relating the regulation was added in the Monitoring Report after solve the CAR7 which asked for the inclusion of this information.



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The information about environmental regulation was added in the Monitoring Report, it was the conclusion CAR8.

During the next periodic verification the audit team will include as part of the agenda the Forwards Action Request raised in this exercise like: The procedures implemented and documented have to be compiled in a monitoring manual, this document will help to understand the system and improve the project operation, this requirement has been detailed in FAR1. The further training requirements have to be anticipated, this consideration was asked in FAR2. Inclusion of Organization Structure and internal audit procedures in monitoring manual (FAR3a and FAC4), improvement of spreadsheet throud the built-in formulae for electricity consumption (stated in FAR7)7, creation of reports master list (FAR8) establishment of a procedure where it is clear who is responsible of the preparation of monitoring report.

CAR9 The document has been updated including all the parameters described in monitoring plan. The document gives details like: frequency recording, data source, data storage and sampling point. The information submitted solves the issue. 3.6 VCS checklist The special requirements of the VCS standards were validated as below: 1. Demonstration to confirm that the project was not implemented to create GHG

emission reductions primarily for the purpose of its subsequent removal or destruction

a. Yes, it is confirmed that the project is not implemented for its removal or destruction. It is implemented as for reduction of methane emission to the atmosphere. The project is a registered CDM project using approved CDM methodology, which further confirms that the ERs are not created for subsequent removal or destruction. The same has been confirmed in the monitoring report.

2. Demonstration that the project has not created another form of environmental credit (for example renewable energy certificates)

a. Project falls only under Clean Development Mechanism (CDM) and no double-counting is involved. Currently, there are no other schemes in Malaysia in which this project could be used. The same has been confirmed in the monitoring report.

3. Confirmation if the Project has been rejected under other GHG programs (if applicable)

a. Not applicable. 4. Is the proof of title been provided?

a. The PP submitted the document ‘’Dept. Of Env. License 2004’’. The license was acquired in year 2004 and subsequently it was renewed based on the regulation on an annual basis (page 2 of document). The first page of the license clearly refers to United Plantations Bhd and division 3 jendarata estate (place where jendarata mill, estate and biogas plant is).

b. All the limits that United Plantations Jendarata Mill needs to comply are stipulated under section 2.2 of page 3 and 4.

5. Projects that reduce GHG emissions from activities that participate in an emission trading program (if applicable)

a. Not applicable.



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4 Verification conclusion

TÜV SÜD Industrie Service GmbH has performed the VCS verification of the CDM project: “Methane recovery and utilisation project at United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia”. The verification is based on the currently valid documentation of the Voluntary Carbon Standard. The management of United Plantation Berhad is responsible for the preparation of the GHG emissions data and the reported GHG emission reductions on the basis set out within the project’s Monitoring Plan indicated in the registered PDD version 04, dated 25-06-2007 and the applied methodology AM0013, Version 4. The verifier can confirm that:

the development and maintenance of records and reporting procedures are in accordance with the registered monitoring plan;

the project is operated as planned and described in the validated and registered PDD;

that the installed equipment being essential for generating emission reduction runs reliably and is calibrated appropriately;

that the monitoring system is in place and generates GHG emission reductions data;

that the GHG emission reductions are calculated without material misstatements;

Our opinion refers to the project’s GHG emissions and resulting GHG emission reductions reported both determined due to the valid and registered project’s baseline, its monitoring plan and its associated documents. Based on the information we have seen and evaluated, we confirm the following statement: Reporting period: From 01-01-2007 to 07-11-2007 Verified emissions in the above reporting period: Project emissions: 2759.83 t CO2 equivalents Baseline emissions: 27847.02 t CO2 equivalents Emission reductions: 25087 t CO2 equivalents

Munich, 16-09-2009

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Munich, 16-09-2009

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Rachel Zhang Deputy Head

Certification Body “climate and energy”

Thomas Kleiser Assessment Team Leader

VCS Verification of Emission reductions for “Methane recovery and utilisation project at United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia”

Verification Protocol

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VCS 5-point checklist

CHECKLIST QUESTION Ref. MoV* COMMENTS Draft Concl

Final Concl

A. Description of the Project A.1 Title of the project activity Methane Recovery and utilization project at United

Plantations Berhad, Jendarata Palm Oil Mill, Malaysia

A.12 Demonstration to confirm that the project was not implemented to create GHG emission reductions primarily for the purpose of its subsequent removal or destruction.

Is it confirmed in the document that the project was not implemented to create GHG emission reductions primarily for the purpose of its subsequent removal or destruction?

Yes, it is confirmed that the project is not implemented for its removal or destruction. It is implemented as for reduction of methane emission to the atmosphere. The project is a registered CDM project using approved CDM methodology, which further confirms that the ERs are not created for subsequent removal or destruction. The same has been confirmed in the monitoring report. Refer section A.2 of PDD and section 2 of attached monitoring report 20090730_up-mru_VCS_ver3_YAT.

A.13 Demonstration that the project has not created another form of environmental credit (for example renewable energy certificates). If the project has created another form of environmental credit: Is a letter provided from the program operator that the credit has not been used and has been cancelled from the relevant program?

Project falls only under Clean Development Mechanism (CDM) and no double-counting is involved. Currently, there are no other schemes in Malaysia in which this project could be used. Please refer section 1 of attached monitoring report 20090730_up-mru_VCS_ver3_YAT.

A.14 Project rejected under other GHG programs (if applicable)



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Final Concl

Projects rejected by other GHG programs can be considered. If this is the case it shall be: a) clearly stated in the VCS PD: all GHG programs for which the project has applied for credits and why the project was rejected (no commercially sensitive information, see A.17). b) provision of the VCS verifier and registry with the actual rejection document(s) including explanation. c) If the project was validated against VCS program requirements.

Not Applicable. Refer above section.

H. Ownership H.1 Proof of land title Is the proof of title been provided by one of the following: a) a legislative right b) a right under local common law c) ownership of plant, equipment and/or process generating the reductions/removals d) a contractual arrangement with the owner of the plant, equipment or process that grants all reductions/removals to be proponent

Refer attached file ‘’Dept. Of Env. License 2004’’. The license was acquired in year 2004 and subsequently it was renewed based on the regulation on an annual basis (page 2 of document). The first page of the license clearly refers to United Plantations Bhd and division 3 jendarata estate (place where jendarata mill, estate and biogas plant is). All the limits that United Plantations Jendarata Mill needs to comply are stipulated under section 2.2 of page 3 and 4.

H.2 Projects that reduce GHG emissions from activities that participate in an emission trading program (if applicable) Is, if applicable, a list included to the document that shows all project proponents of projects that reduce GHG emissions from activities that: a) are included in an emission trading program, or b) take place in a jurisdiction or sector in which binding limits are established on GHG emissions.

N/A



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Final Concl

Is, if applicable, evidence that reductions or removals generated by the project have or will not be used in the program or jurisdiction for the purpose of demonstrating compliance included?

N/A

If yes, does evidence include: a) a letter from the program operator or designated national authority that emissions allowances (or other GHG credits used in the program) equivalent to the reductions/removals generated by the project have been cancelled from the program, or national cap as applicable or; b) purchase and cancellation of the GHG allowances equivalent to the reductions/removals generated by the project related to the program or national cap.

N/A

Have the VCS starting date / crediting start requirements been met? a) Start date after 1st January 2002 / Earliest crediting start

28 March 2006 (if requirements below are met) b) For Projects claiming GHG credits sequentially under the

VCS Program and the CDM: i) CDM validation or VCS validation shall be completed

within two years of the project start date; or ii) CDM validation or VCS validation shall be completed

or contracted before 19 November 2008. In relation to contracts entered into before 19 November 2008, the CDM validation or VCS validation, as the case may be, shall be completed before 19 November 2009. Proof of contracting of the CDM validation or VCS validation, as the case may be, prior to 19 November 2008 shall be provided.

N/A



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Verification Checklist

OBJECTIVE Ref. COMMENTS Conclusion (incl

FARs/ CARs)

1. Opening Session

1.1. Introduction to audits 1 At the beginning of the Initial Verification the intention and target of the visit was explained to all the participants, indicating the scope, activities and requirements to carry out the on site visit and complete the process of the Verification.

1.2. Clarification of access to data archives, records, drawings etc.

1, 2, 10 , 21

As part of the Initial verification, information relating monitoring reports, data archives, records, plans, were required to verify the proper implementation of the project; in this case the project participant submitted all the information required.

1.3. Contractors for equipment and installation works

1, 2 The Danish Energy Management is the carbon consultant who offer advice for the project development and operation to United Plantations Bhd, Jendarata Estate Palm Oil Mill who is the site owner and the responsible of the operation and monitoring, they contracted Aquarius System SDN BHD whom is the technology supplier that provide the equipments digester thanks, meters, flare, monitoring system, etc.

1.4. Actual status of installation works

1, 3, 5 At the moment of the initial verification the project was operating according the design. The equipments and monitoring system are in place to generate emission reductions. The verification team visited the facilities to corroborate the state of project implementation, all were according the design.

2. Open issues indicated in validation report

2.1. Missing steps to final 1, 3, 5 5

There are not open issues indicated in the validation report.



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FARs/ CARs)

approval

3. Implementation of the project

3.1. Physical components

1, 2 The audit team corroborated during the onsite visit that the equipments and facilities have been installed accord the description made in the PDD, the components included among others are: three anaerobic digester tanks (two with floating roof), a sedimentation tank, a flare, boiler unit, acidification pound, cooling pound, aerobic pound. See 4.1

Open

3.2. Project boundaries 1, 2 The project boundary is still in compliance with the one described in the PDD. The emission reduction is taken part like was indicate in the design. There are not emission sources identify outline of the project boundary.

3.3. Monitoring and metering systems

1, 2, 25 For the parameters that require a meter device for the monitoring, the project participant has installed the equipments according acceptable standards (taking in account the manufacturer recommendation) complying with the calibration required. Calibration certificates were reviewed during the on site visit, no devices out of calibration or malfunctioning detected.

3.4. Data uncertainty

1, 2, 3, 11, 24

The project participant has been followed the recommendation from the manufacturer for the installation and calibration to ensure the proper operation within acceptable accuracy level and quality of the data. In the monitoring methodology there are not specifications about deductions from uncertainty or accuracy form the instruments. The audit team asked about all the calibration procedure of each device involved in the monitoring plan and the other

CAR1



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FARs/ CARs)

equipments part of the operation are correctly installed and work under calibration. Corrective Action Request No.1. For the parameters: - Data #30 PCH4, e, s, Methane content in stack gas of heat generation equipment - Data#19 PCH4,bio Percentage of biogas that is methane in the outlet of the bio-

digester the method described in the monitoring plan established a 95% confidence level using a calibrated portable gas meter and taking statistically valid number of samples. Please implement the changes required (i.e. increase number of samples) to meet this level.

3.5. Calibration and quality assurance

1, 2 There are procedures documented for the calibration and quality assurance routines applied for the metering equipments. The laboratories that carried out test and extend results used in the emission reduction determination have the certification that prove the competence to develop the service that the project participant requires (see details in section E. External Data)

3.6. Data acquisition and data processing systems

1, 2, 6, The data to determine the Emission Reductions come from different system and reports generated in the operation. The parameters Fdig, FRe, inlet and FRf, inlet, are collected in automated way utilizing the Scada system (raw data were reviewed in detail). Parameters like CODa_in, CODc_la, CODdig-out, So, NC and PCH4,e,s come from external and internal laboratory measurements which are captured in electronic reports (hard copies of result are kept and were reviewed during on site visit). Other parameter like PCH4,bio, Fla and ELPr,y, are recorder manually and captured in the electronic report. In conjunction the systems used permit an adequate data collection and processing



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FARs/ CARs)

that result in an eligible system to get reliable result. See 3.8 and 3.9

3.7. Reporting procedures

1, 2, 6, 10, 21

The monitoring records (raw data from Scada System) and documents (laboratory reports, manual records, meters readings) used for the emissions reduction determination have been identified. The different files used were the measurements are reported have been reviewed in order to ensure that final the calculations reflect correctly Emission Reductions archived by the project. See 3.8

Open

3.8. Documented instructions

1, 2, 3 Forward Action Request No.1. The project runs procedures for the monitoring, the reports required are done but there are not specific instructions or particular procedures defined for the emission reduction determination. The project participant should develop a monitoring manual indicating the monitoring procedures, data path, report generated to record the data, frequency, quality assurance and responsibilities.

FAR1

3.9. Qualification and training

1, 2, 20 Corrective Action Request No.2. Please submit all the evidences about the training developed in the UP Jendarata Mill about CDM activities like monitoring and reports generation procedures (summaries, minutes, list of participants, topics included). Forward Action Request No.2. Please anticipate further requirements (i.e. for new personnel) of training to ensure the correct performing of monitoring and operative task. The general plan of qualification and training should be part of the monitoring manual.

CAR2 FAR2

3.10. Responsibilities 1, 2 Forward Action Request No.3. FAR3



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FARs/ CARs)

As part of the information of the monitoring manual required in section 3.8 the project participant should include the organization structure, including the participation of Aquarius (as technology supplier) and Danish Energy Management (as carbon consultant).

3.11. Troubleshooting procedures

1, 2 In case of failure of the Scada system the project participant has been implemented routines that permits collect the data manually, the data can be collected manually from the device display, the manual collection happened at the beginning of the operation when the automated system was not fully operating. For the parameters that comes from external laboratories, prudently the project participant use different laboratories, it permits compare the results and identify in early stage data out of range. Also at the site there is an internal laboratory with the capabilities to develop the task required. Forward Action Request No.4. Please document the procedure to collect the data manually in case of Scada system failure, describing the report to be used, frequency, employee responsible to develop this task, etc.

FAR4

4. Internal Data

4.1. Type and sources of internal data

2, 3, 7, 8, 18, 19, 27

Below are listed the parameters used to determine the emissions reductions, which are directly measured with frequencies correctly established.

COD of organic wastewater into the digester COD of the effluent that leaves the lagoon COD of the effluent that enters the lagoon which is assumed to be equal to

the COD input to the digester COD in discharged effluent from digester

CAR3 CAR4 CAR5



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FARs/ CARs)

COD pf concentrations in sludge used for land application Parameters listed above are also measured by external laboratories. Quantity of thermal energy that would be consumed in year y at the project

site in the absence of the project activity using fossil fuel Operating hours per year of the refinery boiler fired on biogas Operating hours per year of the refinery using steam from biogas boiler Flow rate of organic wastewater into the digester Electricity consumed at the project site for the project activity Flow rate of sludge applied to land Amount of biogas collected in the outlet of the Biodigester using a continuous

flow meter Percentage of biogas that is methane in the outlet of the biodigester Flow rate of biogas entering the flare Project emissions from flaring of the residual gas stream in year y Flow rate of the biogas entering the heat generation equipment Fraction of time gas is combusted in the heat generation equipment Amount of sludge applied to land Regulations and incentives relevant to effluent

The calculations incorporated correctly the default values of the following factors:

Carbon emission factor of the electricity grid Calorific value of methane



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FARs/ CARs)

Carbon emission factor of the oil used in the baseline for the boiler operation

Corrective Action Request No.3. Data #22a Flame detection, Detection of flame in the open flare being on or off is not reported in the spreadsheet designed. Please incorporate this parameter in the spreadsheet and submit the information the verifier the details of measurement. Corrective Action Request No.4. - Data #6:Dlag, Depth of lagoon - Data #29 FRe, Flow rate of the heat generation equipment stack gases The above two parameters are listed in the monitoring plan approved in the Project Design Document but are not monitored. The Depth of lagoon has a minimum impact in the emission reduction determination. A deviation should be applied. For the Flow rate of the heat generation equipment stack gases, the flow meter has not been installed. The PP has to justify the use of a conservative way to calculate the CH4 emissions due to incomplete combustion during thermal energy generation without the measurement of this parameter. A deviation should be applied. Corrective Action Request No.5. According to the monitoring plan in the Project Design Document, HGBl,y “the quantity of thermal energy that would be consumed in year y” will be measured in terms of the quantity of steam generated using the biogas generated to displace the use of fossil fuel (refer Data #9). The monitoring plan further states that the steam



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FARs/ CARs)

measuring flow meter will be verified as recommended by the manufacturer. However the ER calculation spreadsheet submitted revealed that in fact, HGBl,y is derived from the amount and calorific value of methane consumed by the boiler due to difficulties in measuring the steam output. Please explain in the monitoring report why the monitoring plan was not exactly implemented in obtaining the source data to calculate BEheat and justify the change to the monitoring plan.

4.2. Data collection

1, 2, 6 For the parameters measured directly the readings of most of the instruments are transmitted electronically to the main system, other readings are captured directly form the value shown in the devise or obtained in the analysis. All the data collected are recorded electronically and transferred to the plant spread sheet. With all the information daily and monthly reports are prepared.

4.3. Quality assurance

1, 2 Forward Action Request No.5. Even that there are internal checks of data monitored, the procedure is not documented. Please include in the monitoring manual (see 3.8) a section with the information about crosschecks, supervision and internal audits.

FAR5

4.4. Significance and reporting risks

1, 2 Forward Action Request No.6. The data and readings used in the spreadsheet derive form monitoring records and Scada system, the excel file used for the emission reduction termination is linked to other files. As was observed on site, the values could change at the moment to copy and open the file in other computer. Please create and document a procedure to ensure that the values in the final spread sheet are still the same even when the file is copied or send to be open in other equipment. Forward Action Request No.7.

FAR6 FAR7



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FARs/ CARs)

It was observed on-site that in the spreadsheet “Biogas Electricity” for deriving the project emissions due to electricity consumption, the results were calculated by manually entering figures where built-in formulae which automatically references the right cell could have been used. Please incorporate built-in formulae with automatic referencing to reduce error due to manual entry wherever possible.

5. External Data

5.1. Type and sources of external data

1, 2, 7, 10, 14 24, 28,

The external data identified in the calculation of emission reduction are: COD of organic wastewater into the digester COD of the effluent that leaves the lagoon COD of the effluent that enters the lagoon which is assumed to be equal to

the COD input to the digester COD in discharged effluent from digester COD in sludge used for land application

Parameters measured by external laboratories (also by the internal lab)

Temperature of lagoon. This parameter comes from Jabatan Meteorogical Malaysia.

Parameters measured only by external laboratories:

Methane content in stack gas of heat generation equipment Nitrogen content in the sludge used for land application, for estimating N2O emission in project emission.

5.2. Access to external data 1, 7, During the on site visit all the reports from the external laboratories were available. The audit team reviewed the results and the procedure described. The laboratory



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FARs/ CARs)

12,14 results are captured in monitoring records and are kept in paper.

5.3. Quality assurance 1, 2, 7, 10, 14 24, 28

The laboratories contracted to carry out the measurements (Environmental Science (M) Sdn Bhd, EDTECH ASSOCIATES SDN BERHAD, ALS TECHNICHEM (M) SDN BHD, ChemVi Laboratory Sdn. Bhd.) and the internal laboratory have the accreditation of MS ISO/IIEC 17025. The Jabatan Meteorogical Station is an official source from Malaysian government. Corrective Action Request No.6. During the on site visit, as the result of the records reviewing of parameter CODa,in, concentration of the effluent that enters the lagoon, the audit team detected a value out of range that came from an external laboratory report. In comparison with the result from the internal laboratory and the result from close dates, a value used to calculate the average of this parameter for February 2006 is out of range. During the days when the sample was taken, the condition of the mill operation, temperature and sampling procedure did not changed, using these facts, the audit team recommended take out this value and recalculate the average for this month (original value = 67.017 Kg/m3 CODa,in. Average recalculated = 53.115 Kg/m3 CODa,in).

CAR6

5.4. Data uncertainty

1, 2, 7, 10, 14 24, 28,

In the reports delivered by the external laboratories, there is a complete description of the procedure used to obtain the result, which includes the uncertainty of the method and equipment used.

5.5. Emergency procedures

1, 7, 12,14

Prudentially the project participant the use both, the internal laboratory and external laboratories results. The service is given by four different laboratories. It permits choose at least one when the others are not available, also the result from the internal result can be used.



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FARs/ CARs)

6. Environmental and Social Indicators

6.1. Implementation of measures

1, 2, 3, 26

The mill comply with the environmental regulation, it was verified with the licence extended by the authority and the periodic renovation. Corrective Action Request No.7. As the Regulations and incentives relevant to effluent is a parameter included in the monitoring plan, please include the monitoring report a summary with the relevant information about regulation and requirements from the authority and how the project comply with this requirement.

CAR7

6.2. Monitoring equipment

1, 2, 3, 26

Corrective Action Request No.8. Please include in the information regarding the environmental regulation if specific measurements are required. In case of affirmative answer, the details about the quality assurance should be part of the information described in the summary of monitoring report (see 6.1).

CAR8

6.3. Quality assurance procedures

1, 2, 3, 26

See 6.2 Open

6.4. External data

1, 2, 3, 26

See 6.2 Open

7. Management and Operational System

7.1. Documentation 1, 2, 21 The operation and maintenance procedure are correctly documented but, as is required in the section 3.8 a specific manual should be developed. This document

Open



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FARs/ CARs)

should be focused on monitoring and quality assurance of emission reduction determination.

7.2. Qualification and training

1, 2, 21 As part of the project file the evidences about the training session should be archive as was required in section 3.9. For further needs of training and qualification, adequate anticipation should be considered in monitoring manual (see 3.9)

Open

7.3. Allocation of responsibilities

1, 2, 21 At the moment the responsibilities from each party involved in the project are not documented. The project participant should follow the request stated in section 3.10

Open

7.4. Emergency procedures

1, 2, 21 The project participant has anticipated forms and manual reports to collect the data that comes from automated system. To comply fully with this requirement they need to document the procedure about it (see 3.11).

Open

7.5. Data archiving 1, 2, 21 The information is archived in printed and soft files, each document has the proper identification, the audit team had no problems to identify the source of each parameter. Forward Action Request No.8. For further verification and like support of monitoring management, the relevant reports and monitoring records should be listed in a table as manner of list of master documents.

FAR8

7.6. Monitoring report

1, 2, 21 Forward Action Request No.9. The entity responsible to prepare, review and approve the monitoring report should be clearly documented in the monitoring manual.

FAR9

7.7. Internal audits and management review

1, 2, 21 See 4.3 Open



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Table 1: Data Management System/Controls

Expectations for GHG data management system/controls Score Verifiers Comments (including Forward Action Requests)

8. Defined organizational structure, responsibilities and competencies

8.1. Position and roles

Limited One of the finding stated in the initial verification checklist was the absence of the position and roles documented in written manner (see 3.10 of IVC)

8.2. Responsibilities Limited At the moment the responsibilities from each party involved in the project are not documented. It should be included in the monitoring manual, specially the details about who is the responsible to elaborate the monitoring report (see 3.10 and 7.6 of IVC)

8.3. Competencies needed Partial The personnel involved in the project have the capabilities needed to operate the project and. To complete the documentation about this topic on section 3.9 of IVC documentation and consideration about the training was required.

9. Conformance with monitoring plan

9.1. Reporting procedures

Partial As is explained in the section 3.7 all the reports needed for the emission reduction determination are available and identified, but the project participant should document the procedures in order to define the path data flow, frequency quality assurance and responsibilities, it is required I FAR in section 3.8 of IVC.



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9.2. Necessary Changes

Partial The project has been developed and installed as was designed in the PDD, but specifically about the monitoring plan, there are two parameters that could be excluded with out impact to the emission reduction determination. Considering the neutral impact after their exclusion and the complexity to measure. A justification about the exclusion of these parameters (Data #6:Dlag, Depth of lagoon and Data #29 FRe, Flow rate of the heat generation equipment stack gases) was requested in CAR5 section 4.1 of IVC.

10. Application of GHG determination methods

10.1. Methods used

Full The methods used for the GHG determination are correctly applied. The project participant follows the methodology and the design. In the monitoring report it is explained the methods used and showing the values and result.

10.2. Information/process flow

Partial During the onsite visit, the audit team reviewed the how the information is processed, from the metering device to the final spreadsheet. In the main the data processing and flow is adequate. The project participant needs to attend the requirement stated in FAR1 in section 3.8 of IVC.

10.3. Data transfer

Partial For all the parameters the audit team reviewed the main source and how from there the data is transferred to the monitoring records, reports and the spreadsheet. The main consideration about the data transferred is the one required in FAR6 in section 4.4 of IVC, it is relating how the project participant will ensure the integrity of the data at the moment to copy the spreadsheet to other computers because this file



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is linked to others that have the raw data.

10.4. Data trails

Partial As part of the verification, the audit team followed all the data trails. The data used in the spreadsheet for the GHG emission reduction determination comes from the reports and monitoring records which have the raw data that coincides with the operation of the project. In order to make transparent and clear the data trail the project participant should follow the requirement stated in FAR1 about the documentation of data path.

11. Identification and maintenance of key process parameters

11.1. Identification of key parameters

Partial Corrective Action Request No.9.

There is a document named “Data Source UP” where the main parameters are identified and listed indicating the document source with the raw data. Please complete this document with all the parameters of monitoring plan and give details about how the data are collected (manually or automated) and the name of the monitoring record or report used to store the information. Also include in this list the default data used (CEF electricity grid, CV of methane, CEFoil used in the baseline for the boiler operation, etc).

11.2. Calibration/maintenance

Full The calibration and maintenance procedure are correctly documented in the Operation Manual. In this document there is a complete description about the calibration and maintenance for each equipment used in the project.



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12. GHG Calculations

12.1. Use of estimates and default data

Partial The values and the application of default data are correctly applied. Corrective Action Request No.10. In order to complete the review of raw data, please submit the manual records of Data#1 Fdig, Flow rate of organic wastewater into the digester of February 2007. In case of the data is not available, complete or it was taken under irregular basis, the first two months (January and February, 2007) of the period should be excluded from the emission reduction determination. Corrective Action Request No.11. The proposed period of VERs claiming is form 1st January 2007 to 7th November 2007. In the spreadsheet “VER_calc_Final-190208” there is data for all November, Please only include data till the end of the period (7th November 2007). Corrective Action Request No.12. For Data #14, Fla Flow rate of sludge applied to land, some discrepancies (for moths April and July) were noted between the summary table and the excel sheet. Please review and correct. Corrective Action Request No.13. For Data #20, FRf, inlet Flow rate of biogas entering the flare,



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some discrepancies (for January and February 2007) were noted between the manual entry data and data form SCADA system. Please submit the raw data form the manual entry. In case of the data is not available, complete or it was taken under irregular basis, the first two months (January and February, 2007) of the period should be excluded from the emission reduction determination. Corrective Action Request No.14. For Data # 12, ELPr,y Amount of electricity in the year y that is consumed at the project site for the, some errors were found (for months January and March, 207). Please correct the spreadsheet. Corrective Action Request No.15. For Data #33, NC Nitrogen content in the sludge used for land application, for estimating N2O, there is a large difference between the average for January to June, 2007 (0.3683 kg N/kg sludge) and July to November, 2007 (0.00218 kg N/kg sludge). Please explain the procedure followed.

12.2. Guidance on checks and reviews

Limited Specific crosschecks and guidance should be implemented to ensure the quality and integrity of the data monitored, periodical review or double checks from all levels should be incorporated and documented. See section 4.3 of IVC

12.3. Internal validation and verification

Partial The internal validation and verification should be defined and document as was required in the FAR5 in section 4.3 of IVC. Third part audit and approval from high management level should be part of this section in the monitoring manual.



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12.4. Data protection measures

Partial In the spreadsheet there is a brief comment about the data protection that textually says: “Formula and computation in all other spreadsheets are protected by password to prevent unauthorised or accidental data entry.”

The spread sheet is protected as it is explained above.

Forward Action Request No.10.

Please describe and document the details about integrity all data, reports, monitoring records and the spread sheet.

12.5. IT systems

Limited Forward Action Request No.11.

The IT system (SCADA system) characteristics should be described (parameters measured, frequency and reports generated) in the monitoring manual.



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Table 2: GHG calculation procedures and management control testing

Identification of potential reporting risk Identification, assessment and testing of

management controls Areas of residual risks

- As was described along this checklist, the measurements of some parameters were missed at the beginning of project operation. The incorporation of these data and new procedures represent a risk for reporting task.

- The absence of a Monitoring Manual represent a risk, the project Participant should take accions for further verification in order to consolidate in a single document the procedures part of the project.

The spreadsheet used to calculate the Emission Reductions and the other documents where data involved in the ERs determination are recorded where reviewed thoroughly.

The errors found due wrong links in for some cells has minimum impact in reliability of the final data, after the corrections required, the data verified reflect in reliable manner the emission reduction achieved in the period. The residual risk identified is described in CARs11 to 15.



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Table 3: Detailed audit testing of residual risk areas and random testing

Areas of residual risks Additional verification testing performed

Conclusions and Areas Requiring Improvement

(including Forward Action Requests)

Based on an assessment of the emission calculation procedures potential reporting risks are: - The task of data transferring from Scada system to the spreadsheet of parameter measured in automated manner. - The task to data compilation in the spread sheet from external sources ( i.e. External laboratory) results represent a residual risk.

- The IT risk is low; discrepancies from the original source and spread sheet with Emission Reduction Calculation represent the main correction. The procedures of data transfers represent the residual risk - The accuracy of the measurements is assure by the calibration of the equipment used (according to the manufacturer recommendations)

The data transfers from Scada System and originals sources to Spread sheet where all the data are compiled is the area of residual risk identified.

The system characteristics and integrity should be documented as was required in FAR 10 and 11.



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Table 4: Compilation of open issues Draft report corrective and forward action requests by audit team

Summary of project owner response Audit team conclusion

Corrective Action Request No.1. For the parameters: - Data #30 PCH4, e, s, Methane content in

stack gas of heat generation equipment - Data#19 PCH4,bio Percentage of biogas that

is methane in the outlet of the bio-digester the method described in the monitoring plan established a 95% confidence level using a calibrated portable gas meter and taking statistically valid number of samples. Please implement the changes required (i.e. increase number of samples) to meet this level.

A comprehensive monitoring manual will be established by adopting the conditions stated as per the PDD. A minimum of 5 samples will be taken quarterly and tested for confidence level. If the confidence level of 95% is not reached, the sample size would be increased till confidence level is reached. DOE Comments: Please run the test now to see if the 95% confidence level can be reached with 5 samples, in the case that 5 samples taken quarterly won’t meet the 95% of confidence level, please establish a comprehensive number of samples to meet this criterion. PP Comments: For parameter PCH4, e, s please refer to the file “Lab Statement on Flue Gas”. For the parameter PCH4,bio as advised by the auditor, we have conducted an analysis of methane in biogas using a calibrated portable gas meter on the 5th November 2008; 5 samples were obtained consecutively with an interval of 1 minute and it was found that all readings

The samples taken meet the confidence level. The file with the Confidence Level Calculation has been submitted. 95% of the values obtained in the period measured are in the mentioned interval of confidence level. A third party has carried out the measurement (E S Laboratories (M) Sbn Bhd).



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Draft report corrective and forward action requests by audit team


obtained complied to a confidence level of 95% (alpha value at or less than 0.05); please refer file “Methane Content in Bio-digester” . As such, it is concluded that sets of 5 samples is will be taken until the alpha value of the calculation is below 0.05. This would be sufficient to achieve 95% confidence level. Also, to be on the conservative side, result for the analysis will be the lower value of the confidence interval.

Forward Action Request No.1. The project runs procedures for the monitoring, the reports required are done but there are not specific instructions or particular procedures defined for the emission reduction determination. The project participant should develop a monitoring manual indicating the monitoring procedures, data path, report generated to record the data, frequency, quality assurance and responsibilities.

A comprehensive monitoring manual will be established by adopting the conditions stated as per the PDD.

The monitoring manual and the procedures documented and records will be reviewed in the periodic verification.

Corrective Action Request No.2. Please submit all the evidences about the training developed in the UP Jendarata Mill about CDM activities like monitoring and reports generation procedures (summaries, minutes, list of participants, topics included).

All training records are attached together in this reply.

Evidences about training have been submitted, the training was developed by the technology supplier, minutes signed of training session has been submitted, in this documents are described the topics covered.



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Forward Action Request No.2. Please anticipate further requirements (i.e. for new personnel) of training to ensure the correct performing of monitoring and operative task. The general plan of qualification and training should be part of the monitoring manual.

The comprehensive monitoring manual to be established will incorporate training needs matrix; a matrix to identify training required on annual basis for every staff/personnel involved in this project.

The monitoring manual and the training needs matrix will be reviewed in the periodic verification.

Forward Action Request No.3. As part of the information of the monitoring manual required in section C8 the project participant should include the organization structure, including the participation of Aquarius (as technology supplier) and Danish Energy Management (as carbon consultant).

A new organization on the CDM project will be established, which will be Aquarius as the technology provider and Danish Energy Management as the carbon consultant.

The correct description of the organization structure will be reviewed in the periodic verification.

Forward Action Request No.4. Please document the procedure to collect the data manually in case of Scada system failure, describing the report to use, frequency, responsible to develop this task, etc.

A comprehensive monitoring manual will be established by adopting the conditions stated as per the PDD. The monitoring manual to be established will include methods to collect the data manually in the case where the SCADA system fails. Every monitoring parameter will be classified according to separate forms, which includes this alternative data collection method.

The monitoring manual will be reviewed in the periodic verification including the procedures and routines to collect the data in case of SCDA system failure.

Corrective Action Request No.3. Data #22a Flame detection, Detection of flame in the open flare being on or off is not reported in the spreadsheet designed. Please incorporate this parameter in the spreadsheet and submit

The current readings obtained from SCADA indicate the number of minutes the flare is operating. Nevertheless, the parameter flame detection and its measurement units (on/off) will be incorporated into the system as per the

About Data #22a: Flame detection. Detection of flame in the open flare being on or off. This parameter was not monitored, so the



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the information the verifier the details of measurement.

auditor’s advice. DOE Comments: The SCADA system takes from the flow meter the flow rate and record the operation time (in minutes), when there are values registered the flare is considered on, in order to corroborate the flare state was “on” please submit the raw data of flare temperature to corroborate that there was flame (under defined conditions, 500°C for 50% efficiency) when there was biogas flow. PP Comments: The “on/off” function was added to the SCADA from 1st June 2008 onwards. As such, a signal transmitter was added to link the thermocouple to the “on/off” reading in SCADA. The flare temperature will rise immediately and when reaches 500 deg C as detected by a thermocouple (signal sent to SCADA by transmitter) installed adjacent to the flare burner, a timer log starts (a SCADA program) which will register flame ON. There is no provision within the flaring system to enable the SCADA to capture the flare temperature (500 deg C) prior to 1st June 2008. As such, from January 2007 to May 2008, the

verifier asked for its inclusion in the measurements. (see CAR3 IVC). The verifier also asked for the inclusion of flare temperature in order to determine the flare efficiency according the tool’s requirement. The “on/off” function was added to the SCADA from 1st June 2008 onwards. As such, a signal transmitter was added to link the thermocouple to the “on/off” reading in SCADA. The flare temperature will rise immediately and when reaches 500 deg C as detected by a thermocouple (signal sent to SCADA by transmitter) installed adjacent to the flare burner, a timer log starts (a SCADA program) which will register flame ON. There is no provision within the flaring system to enable the SCADA to capture the flare temperature (500 deg C) prior to 1st June 2008. As such, from January 2007 to May 2008, the flare computation in the file “Calc for PE Due To Flare - VER” and “Calc for PE Due To Flare - CER” has been amended to include flare efficiency as “0%” rather than “50%”. Please refer column L. From June 2008 onwards, this value has been maintained at “50%” efficiency.



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flare computation in the file “Calc for PE Due To Flare - VER” and “Calc for PE Due To Flare - CER” has been amended to include flare efficiency as “0%” rather than “50%”. Please refer column L. From June 2008 onwards, this value has been maintained at “50%” efficiency.

The approach used is conservative since they are considering the lowest flare efficiency (0%) in absence of temperature measurement. The action taken permits the proper monitoring of project emission due the flaring process. A deviation of the monitoring plan is required.

Corrective Action Request No.4. - Data #6:Dlag, Depth of lagoon - Data #29 FRe, Flow rate of the heat generation equipment stack gases The above two parameters are listed in the monitoring plan approved in the Project Design Document but are not monitored. The Depth of lagoon has a minimum impact in the emission reduction determination. A deviation should be applied. For the Flow rate of the heat generation equipment stack gases, the flow meter has not been installed. The PP has to justify the use of a conservative way to calculate the CH4 emissions due to incomplete combustion during thermal energy generation without the measurement of this parameter. A deviation should be applied.

For parameter: Dlag – records are in place since April 2007 onwards. Depth indicator is in all 3 facultative ponds. The project proponent are in the process of sourcing for a suitable flow meter and will install the same at the earliest. DOE Comments: For data #6:Dlag, Depth of lagoon, please submit to the validator the records taken since April 2007 and give all the information about the procedure used to measured it on daily basis. If emission reduction data have been monitored before the measurement of this parameter, please submit the design of the lagoons in order to justify the correct use of the fraction of

About data #6:Dlag, Depth of lagoon: The measurements of this parameter has not been recorder since the beginning of the project activity. The project participant recently has implemented a procedure to measure the depth of the lagoon. The data recorded since April 2007 shows that the depth of the lagoon has stable range of 1.2meters to 2.3meters. The original design (which was reviewed) shows the depth of the lagoon of 1.8meter (in highest level) and 2.4meter (in lowest level). As conclusion, considering recent measurement and original design is justified the uses of the fraction of anaerobic degradation, fd = 0.5 for depth 1-5 m in the calculations before April 2007. For the date measured after April 2007 the direct measurement of depth of the



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anaerobic degradation, fd = 0.5 for depth 1-5 m. For the data monitored before April 2007 a deviation should be applied. For data #29 FRe, Flow rate of the heat generation equipment stack gases, please submit the details of the flow meter to be installed. In the PDD we can read (page 35) “Assuming combustion of biogas in boiler at 99% efficiency, based on the operations of the burner-boiler under optimum conditions in accordance with the equipment manufacturer’s specifications. The project proponent will appoint a qualified engineering company to conduct the methane combustion efficiency test to verify this value.” Please submit the manufacturer specification explaining how the equipment meets it, and whether an external company carried out the test mentioned. If data have been recorder before the installation of the flow meter, using the test result and a conservative approach, please define the efficiency of the period and calculate the CH4 emissions due to incomplete combustion during thermal energy generation. A deviation is required for data monitored before the installation of the flow meter.

lagoon indicates the use of the same factor (0.5) as fraction of anaerobic degradation.

About data #29 FRe, Flow rate of the heat generation equipment stack gases, has not been measured since the beginning, the approach used by the project participant is: The stack gas flow recommended by the manufacturer in the absence of flow meter is based on the following conservative parameters: Maximum Biogas inflow rate of 550 Nm³ Maximum Excess Air level of 15% at an MCR of 100% Maximum Steam output of 4678 kg/hr Density of Exhaust Gas is 0.7934 Nm³ Exhaust Gas Temperature is 235 °C At the above conservative conditions the maximum stack gas flow expected is 8500 Nm³/hr An external laboratory carried out four test of flow stack gas monitoring. The stack gas measurement was done at different biogas inputs (rage between 200Nm3/hr to 550Nm3/hr), these results shown an average



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PP Comments: For Data #6:Dlag; Procedure to measure depth of lagoon:

1. A measuring pole to measure was installed at the base of all 3 facultative ponds.

2. On a daily basis, the operator visually observes the depth measuring pole and records the effluent level as indicated by the pole.

3. The data is then recorded in a logbook and subsequently transferred to be electronically archived.

For data monitored before April 2007, the engineering drawing (done in 1979) of the pond is scanned and attached with this reply. The files are “Pond Depth Diagram1” and “Pond Depth Diagram 2”. The depth of the pond has been constant between 6 feet to 7 feet, which corresponds to 1.8m to 2.1m (applies for fd = 0.5). Please refer to attached file “Lagoon Depth Apr07 – Oct08” for records. For Data #29 FRe; Flue (stack) gas analysis has been conducted since December 2007 on a quarterly basis. 21 samples of flue gas (with

stack gas flow of 2609.27 Nm3/hr (at 200Nm3/hr biogas input, lower) and 5851.78 Nm3/hr (at 500Nm3/hr biogas input, higher). The average of biogas inlet measured is 4230.52 Nm3/hr, so the approach to use 8500Nm3/hr for stack gas flow is conservative. No methane detected in the tests at detection level of <1ppm v/v. The action taken to solve it is the installation of a flow meter which is already in place.



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various biogas loading) have been tested for methane content. Flue gas flow rate at the various biogas loading was also computed. None of the analysis since December 2007 has shown a detection of methane in any amount. Thus, it can be concluded that the combustion efficiency of methane in the biogas boiler is 100%. Also, for the months before the analysis was conducted (before Dec 2007), the efficiency of the biogas could not have been lower as it is only rationale for combustion efficiency to decrease as time passes. Thus, it can be concluded that the combustion efficiency of methane in the biogas boiler was 100% from January 2007 to November 2007. The analysis of the flue gas from Dec 2007 to Oct 2008 is scanned and attached together as “Flue Gas Record”. Also, the specification for the new flow rate meter is attached as “Flowrate Technical Manual”. Please read under Measurement Principle. DOE Comments: In the file "Raw_Data_File_for_CER", sheet Data#29, column of Boiler Efficiency % there are values higher of 100% (i.e. December 2007 105%). In comparison with document



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"Raw_Data_File_for_VER" the efficiency in this file is 98%, with the same figures Biogas running hours = 550 and stack gas flow 8500 Nm³/hr.

PP Comments:

The file "Raw Data file for CER" is more accurate due to corrections made in calculations at a later stage and also, the figures for Nov 8th – 30th 2007 and December 2007 are CER figures and should be referred to file "Raw Data file for CER". Nevertheless, the auditor's concern has been taken into consideration and "Raw Data file for VER" has been corrected based on the CER file readings. The boiler efficiency column has been removed. Both files are renamed with date as extensions. Please refer to the attached files.

DOE Comments: An answer given about the measurement of parameter #29 was: "The project proponent are in the process of sourcing for a suitable flow



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meter and will install the same at the earliest." Can you update the status of this equipment, is this meter already installed. The continues measurement is still missing.

PP Comments:

UP has already completed the installation of the flowmeter and the first batch of the reading is attached as file "Fluegas Flowrate Dec 2008".

DOE Comments: In the last answer about data #29 was explained that December 2007 on a quarterly basis gas analysis has been conducted since December 2007 on a quarterly basis, even this analysis include the measurement of flow rate of stack gas, you are using the maximum stack gas flow 8500 Nm³/hr, it is ok because it is conservative, but the answer given we can read: "21 samples of flue gas (with various biogas loading) have been tested for methane content. Flue gas flow rate at the various biogas loading was also computed. None of the analysis since December



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2007 has shown a detection of methane in any amount. Thus, it can be concluded that the combustion efficiency of methane in the biogas boiler is 100%." It seem contradictory with the calculation Boiler Efficiency % that we can find in document Raw_Data_File_for_CER", sheet Data#29.

PP Comments:

The boiler efficiency column would not be of any use for this project, because what UP needs to ensure is that the methane's combustion efficiency is 100% in its boiler; by conducting the flue gas analysis. The boiler efficiency was calculated by dividing energy output / energy input. Thus, whenever the boiler efficiency is lower than 100%, it simply means there's a heat/energy loss occurring. As for the methane's combustion efficiency, it can only be stated that the efficiency is lower than 100% if there's a methane leakage in the flue gas emitted. For example, by looking at May 2007's records (Raw Data File for CER 090109), the methane input to the biogas boiler would be 302.49 Nm3/hr. If at all



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there's a leakage of 1% (1% v/v, methane's combustion efficiency being 99%), there must be at least 3 Nm3 of methane released in flue gas for every hour and it should have been detected through the flue gas analysis. Furthermore, the fluegas anaysis has a detection capacity up to 0.01 % v/v. Thus, it can be concluded that there's no methane released through the flue gas.

Corrective Action Request No.5. According to the monitoring plan in the Project Design Document, HGBl,y “the quantity of thermal energy that would be consumed in year y” will be measured in terms of the quantity of steam generated using the biogas generated to displace the use of fossil fuel (refer Data #9). The monitoring plan further states that the steam measuring flow meter will be verified as recommended by the manufacturer. However the ER calculation spreadsheet submitted revealed that in fact, HGBl,y is derived from the amount and calorific value of methane consumed by the boiler due to difficulties in measuring the steam output. Please explain in the monitoring report why the monitoring plan was not exactly implemented in obtaining the source data to calculate BEheat and justify the

Spreadsheet calculation has been amended to incorporate the quantity of thermal energy consumed year “y” in terms of quantity of steam generated. Amended spreadsheet attached with this reply. DOE Comments: The spreadsheet submitted is still the same for calculation of HGBl, HGBl,y = (methane consumed in biogas boiler x calorific value of methane x efficiency of biogas boiler) / efficiency of baseline boiler x emission factor of the baseline boiler fuel. PP Comments: As the steam generated by the biogas boiler is

For, #9 HGBl,y Quantity of thermal energy that would be consumed in year y at the project site in the absence of the project activity using fossil fuel. The monitoring plan is not in line with the methodology. Following the comments in the methodology about, this parameter has to be measured continuously. The PDD says: The quantity of thermal energy that would be consumed in year y will be measured in terms of the quantity of steam generated using the biogas generated to displace the use of fossil fuel. The efficiency of the boiler will been predetermined.



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change to the monitoring plan. See also CAR 6. measured using a flowmeter, the spreadsheet “VER Calculation Biogas ver2” has been amended to incorporate this figure. HGBl,y “the quantity of thermal energy that would be consumed in year y” has been recalculated based on the quantity of steam generated. As such HGBl,y is now calculated as the formula below: HGBl,y = (Steam Output x Steam Enthalpy at specified pressure / Baseline Boiler Efficiency) Please refer to “VER Calculation Biogas ver2”.

PP is using this formula HGBl,y = (Steam Output x Steam Enthalpy at specified pressure / Baseline Boiler Efficiency) The methodology says (comment in monitoring methodology): Thermal energy consumed is determined from quantity of fuel consumed and calorific value of fuel. Based in the measurement of Flow rate of the biogas entering the heat generation equipment The Methodology does not give a equation to calculate this parameter, but base in the statement above, the formula use in the calculation is: HGBl,y = (methane consumed in biogas boiler x calorific value of methane x efficiency of biogas boiler) / efficiency of baseline boiler x emission factor of the baseline boiler fuel. The project participant has been corrected the calculations.

Forward Action Request No.5. Even that there are internal checks of data


The monitoring manual and the results of the internal audits and crosschecks will be reviewed in the periodic verification.



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monitored, the procedure is not documented. Please include in the monitoring manual (see C.8) a section with the information about crosschecks, supervision and internal audits.

These monitoring manual will incorporate a separate form to verify that internal reviewing process has been carried out by respective personnel.

Forward Action Request No.6. The data and readings used in the spreadsheet derive form monitoring records and Scada system, the excel file used for the emission reduction termination is linked to other files. As was observed on site, the values could change at the moment to copy and open the file in other computer. Please create and document a procedure to ensure that the values in the final spread sheet are still the same even when the file is copied or send to be open in other equipment.

A comprehensive monitoring manual will be established by adopting the conditions stated as per the PDD. These monitoring manual will incorporate a separate procedure when to follow when there is a need to copy/transfer data from one file/form to another file/form.

The monitoring manual will be reviewed with the raw data and data transferred to corroborated that the procedure has been implemented successfully.

Forward Action Request No.7. It was observed on-site that in the spreadsheet “Biogas Electricity” for deriving the project emissions due to electricity consumption, the results were calculated by manually entering figures where built-in formulae which automatically references the right cell could have been used. Please incorporate built-in formulae with automatic referencing to reduce error due to manual entry wherever possible.

The built-in formulae have been referred. Recommendation has been complied with.

The spreadsheet submitted incorporate the recommendation, the issue has been closed with the action taken.

Corrective Action Request No.6. The values of CODa,in has been corrected



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During the on site visit, as the result of the records reviewing of parameter CODa,in, concentration of the effluent that enters the lagoon, the audit team detected a value out of range that came from an external laboratory report. In comparison with the result from the internal laboratory and the result from close dates, a value used to calculate the average of this parameter for February 2006 is out of range. During the days when the sample was taken, the condition of the mill operation, temperature and sampling procedure did not changed, using these facts, the audit team recommended take out this value and recalculate the average for this month (original value = 67.017 Kg/m3 CODa,in. Average recalculated = 53.115 Kg/m3 CODa,in).

DOE Comments: The values adopted is 53.120 Kg/m3 CODa,in the difference is minimum, but explain if the figure was rounded or other average was used. PP Comments: Refer to lab reports for February 2007,under the “Lab Results” sheet in the file “Raw Data File for VER”. The value 53.120 Kg/m3 refers to the actual average computed, excluding the two out of range readings.

in adequate manner, showing a figure that takes out the data out of range.

|

Corrective Action Request No.7. As the Regulations and incentives relevant to effluent is a parameter included in the monitoring plan, please include the monitoring report a summary with the relevant information about regulation and requirements from the authority and how the project comply with this requirement.

A list of regulations relevant to the monitoring parameters/project and the corresponding standards/limits has been prepared and attached with in this reply. In future, this list will be incorporated as part of the monitoring manual to be established. Please refer to “List of Acts and Corresponding Regulations” for records.

The list with details of regulations has been submitted. The site has the active premises and licenses that accredit the accomplishment of applicable regulation.

Corrective Action Request No.8. Please include in the information regarding the environmental regulation if specific

A list of regulations relevant to the monitoring parameters/project and the corresponding standards/limits has been prepared and

The list with details of regulations has been submitted. The site has the active premises and licenses that accredit the



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measurements are required. In case of affirmative answer, the details about the quality assurance should be part of the information described in the summary of monitoring report (see F.1).

attached with in this reply. In future, this list will be incorporated as part of the monitoring manual to be established. Please refer to “List of Acts and Corresponding Regulations” for records.

accomplishment of applicable regulation.

Forward Action Request No.8. For further verification and like support of monitoring management, the relevant reports and monitoring records should be listed in a table as manner of list of master documents.

A comprehensive monitoring manual will be established by adopting the conditions stated as per the PDD. The recommendations in FAR 8 will be incorporated into the monitoring manual.

The monitoring manual will be reviewed in the next periodic verification as with all the documentation involved in the procedures and task developed for the project.

Forward Action Request No.9. The entity responsible to prepare, review and approve the monitoring report should be clearly documented in the monitoring manual.

A comprehensive monitoring manual will be established by adopting the conditions stated as per the PDD. This manual will define Danish Energy Management as the consultants responsible for monitoring of this project.

The monitoring manual and the definition of responsibilities from each entity involved in the project will be reviewed in the next periodic verification.

Corrective Action Request No.9. There is a document named “Data Source UP” where the main parameters are identified and listed indicating the document source with the raw data. Please complete this document with all the parameters of monitoring plan and give details about how the data are collected

Please refer to “Data Source UP” for records DOE Comments: In order to justify the adequate and acceptable monitoring of the date involved in the project the document is evidence required; in absence of a monitoring manual this document is the base to understand the monitoring system.

The document has been updated including all the parameters described in monitoring plan. The document gives details like: frequency recording, data source, data storage and sampling point. The information submitted solves the issue.



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(manually or automated) and the name of the monitoring record or report used to store the information. Also include in this list the default data used (CEF electricity grid, CV of methane, CEFoil used in the baseline for the boiler operation, etc). Corrective Action Request No.10. In order to complete the review of raw data, please submit the manual records of Data#1 Fdig, Flow rate of organic wastewater into the digester of February 2007. In case the data is not available, not complete or was obtained on an irregular basis, the first two months (January and February, 2007) of the period should be excluded from the emission reduction determination.

Scanned records have been attached with this reply. Please refer “Fdig-JanFeb2007” for further details. DOE Comments: In file Raw Data File for VER, sheet Data#1 the figures reported has been typed directly to the spreadsheet, please submit the scanned reports taken manually in order to support the figures shown, otherwise the January and February can not be considered like reliable and it should be excluded.

The scanned documents have been submitted and the validator completed the review of the raw data contented ensuring that the final result reflects the information monitored and recorded. The issue is closed.

Corrective Action Request No.11. The proposed period of VERs claiming is form 1st January 2007 to 7th November 2007. In the spreadsheet “VER_calc_Final-190208” there is data for all November, Please only include data till the end of the period (7th November 2007).

Has been corrected. Please refer “VER Calculation Biogas ver2” for further details. DOE Comments: The spreadsheet submitted in the date indicate, the November 2007 has been reported with all the days of the month, the crediting period proposed only cover till 7th November 2007, please correct the document.

The spreadsheet has been corrected. The data included the records corresponding to the crediting period.

Corrective Action Request No.12. For Data #14, Fla Flow rate of sludge applied to land, some discrepancies (for moths April and July) were noted between the summary table

Has been complied with. Records submitted to auditor on the 19th of February 2008.

The corrections required were done, the document submitted the shown the correct figures. The issue is solved.



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and the excel sheet. Please review and correct. Corrective Action Request No.13. For Data #20, FRf, inlet Flow rate of biogas entering the flare, some discrepancies (for January and February 2007) were noted between the manual entry data and data form SCADA system. Please submit the raw data from the manual entry. In case the data is not available, not complete or was obtained on an irregular basis, the first two months (January and February, 2007) of the period should be excluded from the emission reduction determination.

Scanned records have been attached with this reply. Please refer “FRfinlet – JanFeb2007” for further details. DOE Comments: In file Raw Data File for VER, sheet Data#20 the figures reported has been typed directly to the spreadsheet and they are only the opening and closing flow, please submit the scanned reports taken manually in order to support the figures shown, otherwise the January and February can to be considered like reliable and it should be excluded.

The scanned documents have been submitted and the validator completed the review of the raw data contented ensuring that the final result reflects the information monitored and recorded. The issue is closed.

Corrective Action Request No.14. For Data # 12, ELPr,y Amount of electricity in the year y that is consumed at the project site for the months January and March, 2007, some errors were found. Please correct the spreadsheet.

Has been complied with. Records submitted to auditor on the 19th of February 2008.

The corrections required were done, the document submitted the shown the correct figures. The issue is solved.

Corrective Action Request No.15. For Data #33, NC Nitrogen content in the sludge used for land application, for estimating N2O, there is a large difference between the average for January to June, 2007 (0.3683 kg N/kg sludge) and July to November, 2007 (0.00218 kg N/kg sludge). Please explain the procedure followed.

By referring to the current laboratory contractor, the most appropriate to determine nitrogen content in the sludge used for land application is by direct analysis of the Nitrogen Content in the sludge. This practice has been in place from July 2007 onwards. For the period from January 2007 to June 2007, the nitrogen content in the sludge was determined by Total Nitrogen in the effluent divided over the Total Suspended Solids in the

The result from the external laboratory of nitrogen content in the sludge for July to November, 2007 is much similar to the one used to calculate ex ante calculation of the Emissions from land application of sludge shown in the PDD (0.0365 kg N/kg sludge) the result are acceptable.



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effluent. This method gives a higher project emission, compared to the current method in practice. As such, by being conservative, the data from January 2007 to June 2007 will be maintained as it arrives at a higher project emission. Please refer to “VER Calculation Biogas ver2” for further details.

Forward Action Request No.10. Please document the procedures applied to ensure the integrity of all data, reports, monitoring records and the spread sheet.


The monitoring manual will be reviewed in the next periodic verification as with all the documentation involved in the procedures and task developed for the project.

Forward Action Request No.11. The IT system (SCADA system) characteristics should be described (parameters measured, frequency and reports generated) in the monitoring manual.

A comprehensive monitoring manual will be established by adopting the conditions stated as per the PDD. The monitoring manual will include description of SCADA system in general and how the system functions in this project.

The monitoring manual and the SCADA system description will be reviewed in the next periodic verification as with all the documentation involved in the procedures and task developed for the project.



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Annex 2: Information Reference List

Reference No. Document or Type of Information

1 On-site interviews at the plant site of the project conducted on January 28th to 29th, 2008 by auditing team of TÜV SÜD. Respectively Verification team: Ivan Hernandez GHG Auditor, TÜV SÜD Rupa Renganathan GHG Auditor Trainee, TÜV SÜD Interviewed persons: P. Rajasegaran Senior Engineer, United Plantations Dayalin Raman. Assistant Engineer, United Plantations Yogaanandh Tanggaraju CDM Consultant, Danish Energy Management Thirupathi Rao CDM Consultant, Danish Energy Management Lee Ah Lek Technology Provider, Aquarius

Category 1 Documents: Documents provided by the Client that relate directly to the GHG components of the project. These have been used as direct sources of evidence for the initial verification conclusions.

2 Monitoring Report

3 PDD, Methane recovery and utilisation project at United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia Version 04 Date: 25 June 2007.

4 Methodology AM0013 “Avoided methane emissions from organic waste-water treatment” Version 4



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5 Validation Report Methane recovery and utilisation project at United Plantations Berhad, Jendarata Palm Oil Mill, Malaysia Report NO. 2007-1009 Revision NO. 02

6 Data_Source_UP

7 “stack gas test external lab” Captured Data for stack Gas flow measurement done by External lab,

8 “Calc_for_PE_Due_to_Flare-CER” Monthly computation of Project Emissions due to flare

9 “Fluegas_Flowrate_Dec_2008” hourly Data Records (exported form Scada system from 12/01/2008 to 31/12/2008) of Biogas flow, Steam flow and Biogas flow to flare.

10 “Raw_Data_File_for_CER_090109” Data compilation of parameter measured (including: Fdig, Records of 24 Hour Mean Temperature, HGBI,y, ELPr,y, Fla, PCH4bio, FRf,inlet, FRe,inlet, FRe,s, AD FEED COD, ST DISCHARGE COD, Land Application COD Effluent, Sludge NC, BIOMASS BOILER RUNNING HOURS, Biogass Boiler Pressure (bar) and Specific Enthalpy (KJ/Kg))

11 “Methane_Content_in_Biodigester” (raw data and confidence level calculation)

12 “CER_Calculation_Biogas_ver2.1” Data Input Sheet for CER computation (including: Instruction, Data Input, Baseline Emissions, Project Emission, Emission Reductions)

13 “Leakage_test_Report_2007” and “Leakage_test_Report_2008” Internal Report for tanks leakages

14 Stack gas tests external from external laboratory for December 2007, March, July and September 2008 (original reports scanned)

15 “Fdig_-_JanFeb_2007 “ POEM flow rate and totaliser Manual Records for January and February 2007

16 “Flare On-Off Records” Monthly Reports from Scada System

17 “FRfinlet_-_JanFeb2007” Biogas Flow rate and Totaliser Manual Records for January and February 2007

18 “Lagoon_Depth_Aril07_-_Oct08” Manual Reports of Lagoon Depth

19 “Pond_Depth_Diagram” Original Design

20 “Operation_n_Maintenance_training_record”, “refresher_course_training” and “Operation_n_Maintenance_training_record”Training Records for Biogas Plant



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21 Sacada Reports, raw data for all the parameters measured automated.

22 EFFLUENT Raw data POME, facultative pond no: 1, aerobic pond no: 6, sludge application, FFB proceeded, Pome feeding into anaerobic tank, gas generation, biogas supplied for January to December 2007 and January 2008.

23 Electricity consumed by Biogas plant records (METER readings, KWH (AD), January to December 2007 and January 2008.

Category 2 Documents: Background documents related to the design and/or methodologies employed in the design or other reference documents. These documents have been used to cross-check project assumptions and confirm the validity of information given in the Category 1 documents and in verification interviews.

24 “Lab_Statement_on_Flue_Gas” External Laboratory (E S Laboratories (M) Sdn Bhd) statement about Measurement Conducted at 95% confidence level by taken statistically valid number samples of methane content in biogas boiler stack gas.

25 TECHNICAL MANUAL SmartCem Emissions Monitoring System Model V-CEM5100 Flow Monitor

26 LIST OF ACTS AND CORRESPONDING REGULATIONS, ENVIRONMENTAL QUALITY ACT 1974, OCCUPATIONAL SAFETY AND HEALTH ACT 1994, EMPLOYMENT ACT 1955

27 Pictures of flow meter and transmitter of biogas boiler stack gas installed.

28 “letter_-_safety_and_health_briefing” Record for session of Safety and health briefing for biogas plant operators, date 14th November 2007