Validation Report
Report for:
PT. Wirajaya Packindo
Validation of CDM project for
Installation of Waste Heat Recovery Steam
Boiler at Wirajaya Packindo
LRQA Reference
Date
Work carried out by
Work verified by
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
: ENQ/2607/11/IRE
Version 02.14
: 04/12/2012
: Ankush Jain
Cholid Bafagih
Hikmat Wijaya
M. Nursyam
: Ketan Deshmukh
Brahim Abdullah
Michiaki Chiba
Date: 04/12/2012
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Contents
1
Executive Summary ............................................................................................ 3
2
Introduction ......................................................................................................... 5
3
4
2.1
Objective ................................................................................................................ 6
2.2
Scope...................................................................................................................... 6
2.3
GHG Project Description ....................................................................................... 6
Methodology........................................................................................................ 6
3.1
Review of documents ............................................................................................ 6
3.2
Site Visit and Follow-up interviews ...................................................................... 7
3.3
Resolution of clarification and corrective action requests................................. 8
3.4
Internal quality control .......................................................................................... 8
Validation protocol and conclusions ................................................................ 8
4.1
Approval ................................................................................................................. 9
4.2
Participation requirements.................................................................................... 9
4.3
Project design document ...................................................................................... 9
4.4
Project description .............................................................................................. 10
4.5
Baseline and monitoring methodology .............................................................. 10
4.6
Additionality of a project activity........................................................................ 12
4.7
Monitoring Plan.................................................................................................... 13
4.8
Local stakeholder consultation .......................................................................... 13
4.9
Environmental impacts ....................................................................................... 13
4.10
Summary of Changes .......................................................................................... 13
5
Comments by parties, stakeholders and NGOs ............................................. 14
6
Validation Opinion ............................................................................................ 15
7
Appendices........................................................................................................ 16
7.1
Appendix A: Letter of approval for the project by the host and investing
country DNA .................................................................................................................... 16
7.2
Appendix B: List of documents reviewed .......................................................... 16
7.3
Appendix C: List of persons interviewed........................................................... 18
7.4
Appendix D: How due account has been taken to the public input made to the
validation requirements .................................................................................................. 19
7.5
Appendix E: Certificate of Appointment ............................................................ 20
7.6
Appendix F: Validation Protocol and findings log............................................. 21
No distribution without permission from the client or responsible organisational unit
Limited distribution
Unrestricted distribution
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1
Executive Summary
Lloyd’s Register Quality Assurance Limited has been contracted by PT. Wirajaya
Packindo representing the project participants (PP), to undertake validation of the
proposed project activity “Installation of Waste Heat Recovery Steam Boiler at
Wirajaya Packindo”. The validation has been performed through a process of
document review based on the project design document, Version 1 dated 20/10/2011
initially submitted for validation and the subsequent revisions, follow-up interviews with
the stakeholders, resolution of outstanding issues and issuance of the validation report.
The project activity is recovery of waste heat in the existing gas turbine system to
generate steam. The project activity involves installation of a waste heat recovery
boiler which utilises the waste heat and natural gas as supplementary fuel to generate
steam. The steam otherwise would have been generated from the existing coal based
boilers. The project activity reduces the GHG emissions from recovery of waste heat
and using lower GHG natural gas as fossil fuel.
The fulfilment of the requirements as set forth in Article 12 of the Kyoto Protocol of the
United Nations Framework Convention on Climate Change (UNFCCC), the modalities
and procedures for a CDM (CDM M&P) and relevant decisions of the Conference of
the Parties, serving as meeting of the Parties to the Kyoto Protocol (COP/MOP) and
the Executive Board of the CDM (CDM-EB) have been evaluated and conformance to
the validation requirements were confirmed based on the given information. A risk
based approach was taken to conduct the validation and corrective action requests
(CARs) and clarifications (CLs) were raised for relevant actions by the PP.
The validation team has found through the validation process 4 CARs and 6 CLs.
The PP has taken actions and submitted to LRQA the revised PDD and supporting
evidence. The validation team is of the opinion that the proposed project activity as
described in the project design document Version 5.5 dated 04/12/2012 meets all the
relevant UNFCCC requirements for the CDM, as well as the host country’s national
requirements and if implemented as designed, is likely to achieve the emission
reductions and contribute to the sustainable development of the host country. LRQA
therefore requests the registration of “Installation of Waste Heat Recovery Steam
Boiler at Wirajaya Packindo” to the CDM Executive Board as a CDM project activity.
Lloyd’s Register Quality Assurance Ltd
Hiramford
Middlemarch Office Village
Siskin Drive
Coventry CV3 4FJ
United Kingdom
LRQA Reference: ENQ/2607/11/IRE
Registered office:
Lloyd’s Register
71 Fenchurch Street
London EC3M 4BS
United Kingdom
Date: 04/12/2012
Page 3 of 92
Lloyd's Register Quality Assurance Ltd, its affiliates and subsidiaries and their respective officers, employees or
agents are, individually and collectively, referred to in this clause as the ‘Lloyd's Register Group’. The Lloyd's
Register Group assumes no responsibility and shall not be liable to any person for any loss, damage or expense
caused by reliance on the information or advice in this document or howsoever provided, unless that person has
signed a contract with the relevant Lloyd's Register Group entity for the provision of this information or advice and
in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.
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Abbreviations
AE
BE
CARs
CDM
CDM-EB
CDM M&P
CDM PS
CDM VVM
CDM VVS
CERs
CLs
COP/MOP
DEHSt
DNA
DOE
EF
EIA
EPC
ERPA
FAR
GHG
GSP
IPCC
IRR
ISO
KP
kW / kWh
LE
LoA
LR
LRQA
MW / MWh
NCV
NGO
NPV
ODA
PDD
PE
PP
tCO2e
UNFCCC
Applicant entity
Baseline emissions
Corrective action requests
Clean development mechanism
Executive board of clean development mechanism
Modalities and procedures for a clean development mechanism
CDM Project Standard
CDM Validation and Verification Manual
CDM Validation and Verification Standard
Certified emission reductions
Clarification requests
Conference of the Parties serving as meeting of the Parties to the
Kyoto Protocol
German Emission Trading Authority
Designated national authority
Designated operational entity
Emission factor
Environmental impacts assessment
Engineering, Procurement and Construction
Emissions reduction purchase agreement
Forward action requests
Greenhouse gas
Global stakeholders’ consultation process
Intergovernmental panel on climate change
Internal rate of return
International Standards Organisation
Kyoto Protocol of the United Nations Framework Convention on
Climate Change
Kilowatt / Kilowatt hour
Leakage emissions
Letter of approval
Lloyd’s Register
Lloyd’s Register Quality Assurance Limited
Mega watt / Mega watt hour
Net calorific value
Non governmental organization
Net Present Value
Official development aid
Project design document
Project emissions
Project participant
Tonnes of carbon dioxide equivalent
United Nations Framework Convention on Climate Change
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2
Introduction
The project participant (PP) represented by PT. Wirajaya Packindo has contracted with
Lloyd’s Register Quality Assurance Limited (LRQA) to undertake validation of the
proposed project activity “Installation of Waste Heat Recovery Steam Boiler at
Wirajaya Packindo”. This report summarise the findings of the validation process that
has been conducted on the validation requirements of the CDM.
The validation has been undertaken by the team formed of the qualified personnel of
LRQA as follows:
Ankush Jain
LRQA India
Cholid Bafagih
LRQA Indonesia
Hikmat Wijaya
M. Nursyam
Ketan Deshmukh
Brahim Abdullah
Michiaki Chiba
LRQA Indonesia
External expert
LRQA Ltd.
External expert
LRQA Ltd.
Team Leader,
CDM Lead Validator
Team member,
CDM Validator,
Host country expert
Trainee
Sector expert
Technical reviewer
Sector expert to technical reviewer
Decision maker
Personnel being engaged in a CDM project validation are qualified based on the
established procedures of LRQA to assure the resource requirements satisfy all the
requirements of competence criteria for an AE/DOE under CDM (CDM-Accreditation
Standard for Operational Entities Version 04.0). LRQA is designated as an operational
entity and holds the full responsibility of decision-making regarding the validation, in
line with the accreditation requirements of the CDM-EB. The certificate of appointment
of the team personnel is attached to this report.
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2.1
Objective
Validation is the process of an independent third party evaluation of a project activity
on the basis of the PDD, against the requirements of the CDM as set out in Article 12
of the Kyoto Protocol, the CDM M&P, subsequent decisions made by the COP/MOP
and CDM-EB, and other rules applicable to the proposed project activity including the
host country’s legislation and its specific requirements for sustainable development.
The validation follows the requirements of the current version of the CDM validation
and verification standard (CDM VVS) and the CDM Project Standard (CDM PS) to
ensure the quality and consistency of the validation work and the report.
2.2
Scope
The scope of validation is an independent and objective review of the project design.
Review of the PDD is conducted against the requirements of the Kyoto Protocol, the
CDM M&P and relevant decisions of the COP/MOP and the CDM-EB. LRQA follows a
risk-based approach in the validation focusing on the identification of significant risks
for project implementation and generation of CERs. Validation is not meant to provide
any consulting towards the PP, however, the corrective actions requests (CARs) and
clarifications (CLs) might provide input for improvement of the project design. A
validation conclusion shall become final subject to the decision maker’s review by
LRQA Ltd.
2.3
GHG Project Description
The Project activity is recovery of waste heat from the existing turbine of capacity
12MW (15MW under International Standards Organisation (ISO) conditions) to
produce steam. The project activity involves installation of a new waste heat recovery
boiler. The waste heat recovery boiler will also use natural gas as supplementary fuel
to produce steam required for the manufacturing process of paper. Prior to the project
activity the steam demand was met through the existing coal fired boilers. The
existing coal fired boilers will be used as stand by for meeting steam demand in
emergency situations. The project activity reduces the GHG emissions from the
recovery and utilisation of waste heat and use of lower GHG fossil fuel.
The estimated GHG emission reductions are 56,427 tCO2e per annum. The emission
reduction has been estimated based on the designed efficiency, emission factor based
on IPCC and average annual working days.
3
Methodology
3.1
Review of documents
The validation is performed primarily based on the review of the project design
document (PDD) and the other supporting documentation.
The PDD Version 1 dated 20/10/2011 was initially reviewed. LRQA requested the PP
to present supporting information and documents relating to the project design and
such additional information and documents were also reviewed by LRQA.
Through the process of the validation, the PDD and the supporting documents of the
same were evaluated to confirm the actions taken by the PP to the CARs and CLs
issued by LRQA. The documents reviewed by LRQA are listed in Appendix B. LRQA
reviewed the final version of the PDD version 5.5 dated 04/12/2012 to confirm that all
changes agreed had been incorporated.
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3.2
Site Visit and Follow-up interviews
A site visit and follow-up interviews with the stakeholders were conducted as detailed
in the schedule as below:
Date
Location/
Address
Tangerang,
Banten,
Indonesia
Party
Interviewed
PT. Wirajaya
Packindo
Subjects Covered
13/12/2011
Tangerang,
Banten,
Indonesia
Local
stakeholders
Ankush Jain
Cholid Bafagih
Hikmat Wijaya
M. Nursyam
14/12/2011
Local
Environment
Protection
Bureau,
Tangerang
PGN Office,
Jakarta,
Indonesia
BPLHD
1. Invitation letters issued to local
stakeholders
2. Representation by stakeholders
in stakeholders’ consultation
meeting
3. Minutes of meeting –
comments, action taken
4. Employment generation due to
the project activity
5. Discussion on land ownership
and transaction procedures
6. Views on the project activity
7. Any other issues of
stakeholders’
8. Interview local stakeholders
1. EIA
2. Other statutory requirements
3. Clearances required
4. Views on project activity
Gas supplier
1. General overview about the
project
2. Gas pricing and supply
scenario
Ankush Jain
Cholid Bafagih
Himkat Wijaya
M. Nursyam
Tangerang,
Banten,
Indonesia
PPs
Consultant
1. Discussion on project and
timelines
2. Closing meeting
Ankush Jain
Cholid Bafagih
Himkat Wijaya
M. Nursyam
13/12/2011
14/12/2011
14/12/2011
1. Project description, boundary
and technology
2. Applied project technology and
industrial good practices.
3. Monitoring plan.
4. Record keeping
5. Emergency preparedness
6. Data collection and archiving
7. Training and internal audits
8. Legal requirements
9. Environmental impacts of the
project activity
10. Local stakeholders
consultation
Team Members
on Site
Ankush Jain
Cholid Bafagih
Himkat Wijaya
M. Nursyam
Ankush Jain
Cholid Bafagih
Himkat Wijaya
M. Nursyam
A full list of persons interviewed is shown in Appendix C.
For details of all the findings of the desk review and site visit, please refer to the
Validation Protocol and Findings in Appendix F.
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3.3
Resolution of clarification and corrective action requests
LRQA applies the risk based approach aimed at focusing on high risk issues to the
validation results while not omitting any part of the mandatory processes.
Findings identified in the process are indicated under the titles corrective action
requests (CARs) and clarification requests (CLs) and forward action requests (FARs).
CARs and CLs require the PP to take relevant actions. Criteria for judging items as
CAR or CL are as follows:
Corrective action request (CAR):
• the project participants have made mistakes that will influence the ability of the
project activity to achieve real, measurable additional emission reductions
• the CDM requirements have not been met, or
• there is a risk that emission reductions cannot be monitored or calculated.
Clarification request (CL):
• information is insufficient or not sufficiently clear to determine whether the
applicable CDM requirements have been met.
FARs are to be raised to highlight issues related to project implementation that require
review during the first verification of the project activity. FARs do not relate to CDM
requirements for registration.
CARs and CLs are to be resolved or closed out if the PP modifies the project design,
rectifies the PDD or provides adequate additional explanations or evidence that
satisfies the concerns. If this is not completed, the project activity cannot be
recommended for registration to the CDM Executive Board.
For details of the nature of the issues raised, the nature of the responses provided, the
means of validation of such responses and the resulting changes in the PDD or
supporting annexes please refer to the Validation Protocol and Findings in appendix F.
3.4
Internal quality control
A technical review by a qualified person independent from the validation team and a
review by an authorized decision maker were conducted before the submission of the
validation report to the PP and before requesting the registration of the project activity.
4
Validation protocol and conclusions
This section provides an overview of the validation activities undertaken by LRQA
in order to arrive at the final validation conclusions and opinion. It includes
general conclusions based on the Clean Development Mechanism Validation and
Verification Standard (CDM VVS) version 03.0. Further details in relation to each
element of the protocol and each finding are shown in the Validation Protocol and
Findings – Appendix F.
The protocol is structured based on the main validation requirements as follows:
• Approval by the Parties involved
• Participation requirements
• Project design document
• Project description
• Baseline and monitoring methodology
o Applicability of the selected methodology
o Project boundary
o Baseline identification
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Algorithms and/or formula used to determine emission reductions
Additionality of a project activity
o Prior consideration of the CDM
o Identification of alternatives
o Investment analysis
o Barrier analysis
o Common practice analysis
• Monitoring plan
• Local stakeholder consultation
• Environmental impacts.
o
•
4.1
Approval
A CDM project shall be approved by the Parties involved.
The host Party of the proposed project is Indonesia. Indonesia ratified the Kyoto
Protocol on 28/07/2004. The Designated National Authority (DNA) is National
Committee on Clean Development Mechanism. The information of the DNA has been
confirmed by the validation team against the relevant information on the UNFCCC
CDM website (http://cdm.unfccc.int/DNA/index.html). A letter from approval from the
host country, reference number B074/KNMPB/032012 has been received. This letter
of approval confirms the contribution of the project activity “Installation of Waste Heat
Recovery Steam Boiler at Wirajaya Packindo” to the sustainable development of
Indonesia.
The Annex I Party is Germany. Germany ratified the Kyoto Protocol on
31/07/2002. The DNA is German Emission Trading Authority (DEHSt). The
information of the DNA has been confirmed by the validation team against the
relevant information on the UNFCCC CDM website
(http://cdm.unfccc.int/DNA/index.html). A letter from approval from the Annex I
Party dated: 01/08/2012, reference number E1.6-18410-0403/100 has been
received.
For details relating to this section, please refer to the Validation Protocol in
Appendix F.
4.2
Participation requirements
PT. Wirajaya Packindo is a private entity having its registered office in Indonesia.
KfW is a private entity having its registered office in Germany.
The contact details of the PPs are correctly provided in Annex 1 of the PDD.
Participation in the project activity of the PPs has been ٛ authorized, as confirmed in
the LoAs issued by the Parties concerned. The team confirmed that no entities other
than the ٛ authorized entities are indicated as project participants in the PDD.
For details relating to this section, please refer to the Validation Protocol in Appendix
F.
4.3
Project design document
The PDD was checked and confirmed as complete against the Guidelines for
completing the project design document form for small-scale CDM project, Version 01.
A valid form of the F-CDM-SSC-PDD is used that is the current form under CDM VVS
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track as available on the UNFCCC-CDM website.
For details relating to this section, please refer to the Validation Protocol in Appendix
F.
4.4
Project description
The Project activity is recovery of waste heat from the existing gas turbine to generate
steam in a recycled-paper production factory owned by PT Wirajaya Packindo in
Indonesia. The project activity involves installation of a new waste heat recovery
boiler which utilises waste heat from the gas turbine and natural gas as
supplementary fuel. The steam required for the paper manufacturing process in the
existing line and planned new production line would have been generated from the
existing coal fired boilers. In the project scenario, the existing coal fired boilers will be
kept as stand by for emergencies. The project activity will reduce GHG emissions by
utilisation of waste heat and use of natural gas as fuel.
The details on the location of the project activity was confirmed as Karawaci SubDistrict, Regency of Tangerang, Desa Koang Jaya, Banten Province, Indonesia as
given in the section A.4.1 of the PDD. The geographic coordinates of the project
activity were confirmed as Latitude 106° 37’18.80’’ East and Longitude 6°12’14.03’’
South.
LRQA confirms that the project description included in the PDD is accurate and
complete. This description provides the reader with a clear understanding of the
precise nature of the project activity and the technical aspects of its implementation.
The project description was validated by document review including PDD and
supporting project documentation, official information of the host country and sector
information as publicly available, interview, and the on site visit.
Sustainable development
The host Party’s DNA confirmed the contribution of the project activity to the
sustainable development of the host Party.
Small scale CDM criteria
The project activity recovers and utilises waste heat from the existing gas turbine. The
project activity, therefore, is characterised as ‘Type III’ activity. Validation team
confirms from the review of PDD and its supporting documents, sectoral expertise and
on site visit that emission reductions from the project activity will not cross 60,000
tCO2e/annum every year throughout the crediting period.
Validation team confirms from the interview of the PP that it does not intend to change
the project design.
For details relating to this section, please refer to the Validation Protocol in Appendix F.
4.5
Baseline and monitoring methodology
Applicability of the selected methodology to the project activity
The project activity applied the approved baseline and monitoring methodologies:
AMS-III.Q. “Waste energy recovery (gas/heat/pressure) projects”, Version 4.0.
This version of the methodology is valid from 29/04/2011 and currently having an
“active” status.
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LRQA confirms unambiguously that the selected methodology is applicable to this
project activity. The project applicability was confirmed against each condition in the
approved methodology selected. Appendix F includes the list of each applicability
condition, the steps taken to validate each one and the conclusions about its
applicability to the proposed project activity.
For details relating to this section, please refer to the Validation Protocol in Appendix F.
Project boundary
The project boundary has been validated through documentation review on the overall
design document, EIA report, quotation and contract with equipment supplier, interview
and field survey that included the waste heat recovery system, gas turbine generator,
and paper mill where steam will be used. This information was substantiated via cross
check with the information obtained from the public sources by the validation team.
Through the processes taken, the validation team confirmed that the identified project
boundary, the selected sources and the gases were justified for the project activity and
they meet the requirements of the approved methodology.
Baseline identification
The baseline scenario identified in the PDD has been assessed against the
requirements in the approved methodology AMS-III.Q. “Waste energy recovery
(gas/heat/pressure) projects”, Version 4.0. LRQA can confirm that the procedure
included in this methodology to identify the most reasonable baseline scenario, has
been correctly applied.
The steps taken to assess the baseline identification are described in the Validation
protocol in Appendix F.
LRQA confirms that:
-
-
All the assumptions and data used by the project participants are listed in the PDD,
including their references and sources;
All documentation used is relevant for establishing the baseline scenario and
correctly quoted and interpreted in the PDD;
Assumptions and data used in the identification of the baseline scenario are
justified appropriately, supported by evidence and can be deemed reasonable;
Relevant national and/or sectoral policies and circumstances are considered and
listed in the PDD;
The approved baseline methodology has been correctly applied to identify the most
reasonable baseline scenario and the identified baseline scenario reasonably
represents what would occur in the absence of the proposed CDM project activity.
Algorithms and/or formula used to determine emission reductions
LRQA has confirmed that the steps taken and the equations applied to calculate
project emissions and baseline emissions and emission reductions comply with the
requirements of the approved methodology AMS IIIQ version 4.0.
The steps taken to assess the algorithms and/or formula used to determine emission
reductions are described in the Validation protocol in Appendix F.
LRQA confirms that:
•
•
•
All assumptions and data used by the project participants are listed in the PDD,
including their references and sources;
All documentation used by project participants as the basis for assumptions and
source of data is correctly quoted and interpreted in the PDD;
All values used in the PDD are considered reasonable in the context of the
proposed CDM project activity;
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•
•
4.6
The baseline methodology has been applied correctly to calculate project emissions,
baseline emissions, leakage and emission reductions;
All estimates of the baseline emissions can be replicated using the data and
parameter values provided in the PDD.
Additionality of a project activity
The project additionality was demonstrated by the PP using the Guidelines on the
demonstration of additionality for small-scale project activities (Version 09.0).
Prior consideration of CDM
The start date of the project activity is 01/08/2011 based on the date of signing
Engineering, Procurement and Construction (EPC) contract with PT. Indoturbine. The
start date was confirmed from the review of EPC contract with PT. Indoturbine. The
start date was confirmed in accordance with the Glossary of CDM terms, Version 07.0.
The start date of the project activity was after 02/08/2008. Prior consideration of the
project was demonstrated through notification made to the DNA of Indonesia and
UNFCCC secretariat on 20/07/2011. Validation team confirmed the prior consideration
through the list of notifications available at UNFCCC website, Filled prior consideration
form dated: 18/07/2011, email submitted to UNFCCC dated: 20/07/2011 and
confirmation email received from the Indonesian DNA dated: 25/07/2011.
The steps taken to assess the prior serious consideration of the CDM are described in
the Validation protocol in Appendix F.
Identification of alternatives
The list in the Validation Protocol – Appendix F section 6.b, shows the alternatives
given in the PDD, and clearly states how LRQA has validated whether these
alternatives are credible and complete.
It is the opinion of LRQA that the list of alternatives provided in the PDD are credible
and complete considering the technology and circumstances of the proposed Project
activity as well as the investor business.
Investment analysis
The Investment analysis option has been used to demonstrate the additionality of the
proposed project activity. LRQA confirms that the PDD provides evidence that this
project activity would not be the most economically or financially attractive alternative.
The PPs have shown that the project activity is additional by demonstrating that the
financial returns of the proposed CDM project activity would be insufficient to justify the
required investment.
For assessing the additionality of this project activity LRQA has complied with the
latest version of the “Guidelines on the Assessment of Investment Analysis” as
provided by the CDM Executive Board and with other relevant guidance including the
latest guidelines on plant load factors “Guidelines for the reporting and validation of
plant load factors”.
For details about the validation of the parameters used in the financial calculations and
assessment of the benchmark applied, please refer to the Validation protocol in
Appendix F.
LRQA confirms that the underlying assumptions for the investment analysis are
appropriate and that the financial calculations are correct.
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4.7
Monitoring Plan
The PDD includes a Monitoring Plan based on the approved monitoring methodology
AMS III Q version 4.0.
LRQA confirms that the Monitoring Plan described in the PDD complies with the
requirements in the Monitoring Methodology and that the PPs will be able to apply
this Monitoring Plan following the monitoring arrangements described in it.
For details about the validation of the Monitoring Plan, please refer to the Validation
protocol in Appendix F.
4.8
Local stakeholder consultation
The PPs invited Local Stakeholders to comment on the proposed project activity on the
5/10/2011 before the publication of the PDD on the UNFCCC website. The local
stakeholder consultation meeting was held in Club House Modernland and Country
Golf, Tangerang and the following persons and entities attended this meeting.
-
Local people
Chief of village
Local authorities
The representatives of Local official agencies of Environment (BLHD
The representatives of PT. SEML’s management and staff
KfW representative
LRQA confirms that the stakeholder consultation process targeted stakeholders and
was appropriate for identifying stakeholders’ opinions about the project and collecting
their views.
For details about the steps taken to assess the adequacy of the Stakeholder
consultation, please refer to the Validation protocol in Appendix F.
4.9
Environmental impacts
LRQA has confirmed that the PPs have undertaken an environmental impact
assessment as required by the host country.
The PPs have submitted documentation to LRQA on the analysis of the environmental
impacts of this project activity in line with paragraph 37 (c) of the CDM modalities and
procedures.
For details about the document review and determination of whether the PPs have
undertaken the analysis of environmental impacts, please refer to the Validation
protocol in Appendix F.
4.10 Summary of Changes
Significant changes made to the original PDD published for Global Stakeholder
Consultation Process are summarised below. The PDD version 1 dated 20/10/2011
was modified and several changes occurred due to the result of validation process.
The PDD version 5.5 dated 04/12/2012 includes all these changes.
For details about the results of the responses to CARs and CLs, discussions on
revisions to project documentation and the detailed changes to the PDD coming from
the validation process, please refer to the Validation Findings Log in the Validation
Protocol in Appendix F.
Item
Description
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Value in PDD
GSP
RfR
CAR/CL
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Item
Value in PDD
Value in PDD
GSP
RfR
CAR/CL
1.
Emission factor of the coal was corrected
based on CAR 02
92.80 tCO2/TJ
89.50 tCO2/TJ
CAR 02
2.
NPV was increased due to correction in
depreciation and interest calculations.
-4.03
USD
-1.35
USD
CL 05
3.
Monitoring plan was revised
NA
NA
CAR 03
4.
PP has removed the methodology AMS.II.D
based on the finding and clarification from
UNFCCC (SSC_582)
PP has changed the PDD from CDM-VVM
track to CDM-VVS track
NA
NA
CL 04
NA
NA
NA
5.
5
Description
Million
Million
6.
PP has revised the baseline efficiency of coal
boiler from the designed to most
conservative
value
in
the
applied
methodology
78%
100%
NA
7.
Based on the use of correct emission factor
of coal and conservative baseline efficiency
of coal boilers the ex-ante emission reduction
estimate were decreased
70,593
tCO2/annum
56,427
tCO2/annum
CAR 02
Comments by parties, stakeholders and NGOs
In line with the requirement of the Procedures for Processing and Reporting on
Validation of CDM project activities, the PDD is to be made publicly available for 30
days subject to confidentiality provisions agreed with the PP, to enable comments to
be received from Parties, stakeholders, and UNFCCC accredited NGOs on the
validation and registration requirements.
The PDD was made publicly available in line with the requirements of the procedure
for the period of 29/10/2011 to 27/11/2011 as per
http://cdm.unfccc.int/Projects/Validation/DB/SY7X21Y5CMMDJDGCAL596JSNKSDP9
N/view.html
No comment was received during this period.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 14 of 92
Revision 0.9, 07 November 2012
6
Validation Opinion
LRQA has undertaken the validation of the proposed project activity “Installation of
Waste Heat Recovery Steam Boiler at Wirajaya Packindo” based on the requirements
of CDM as set out in Article 12 of the Kyoto Protocol, the CDM M&P, the present
annex, subsequent decisions made by the COP/MOP and CDM-EB, and the other
rules applicable to the proposed project activity including the host country’s legislation
and its specific requirements for sustainable development.
The Project activity is recovery of waste heat from the existing gas turbine. The project
activity involves installation of a new 50TPH waste heat recovery boiler. The waste
heat recovery boiler recover the waste heat from the existing gas turbine of capacity 12
MW (15MW under ISO conditions) and it uses natural gas as supplementary fuel. The
steam generated from the waste heat recovery boiler will replace it from the existing
coal fired boilers. The project activity will reduce GHG emissions from the utilisation of
waste heat and use of natural gas.
To arrive at the final validation conclusions and opinion, LRQA carried out review of
project documents, assessment of compliance with and application of the approved
baseline and monitoring methodology as well as the approved methodological tools,
field survey and physical on site assessment of the project site and interviewing the
local stakeholders.
Through the validation process, the validation team identified 4 CARs and 6 CLs. The
PP has taken action on the raised issues and submitted to LRQA the revised PDD and
other supporting evidence.
The validation team is of the opinion that the proposed project activity conforms to all
the relevant UNFCCC requirements for the CDM as well as the host country’s national
requirements, and if implemented as designed, is likely to achieve the validated
emission reductions of 56,427 tCO2 and contribute to the sustainable development of
the host country. Therefore, LRQA requests the registration of “Installation of Waste
Heat Recovery Steam Boiler at Wirajaya Packindo” to the CDM Executive Board as a
CDM project activity.
Decision Maker
Michiaki Chiba
Climate Change Manager – Asia & Pacific
04/12/2012
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 15 of 92
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7
Appendices
7.1
Appendix A: Letter of approval for the project by the host and
investing country DNA
Letter of Approval from Indonesia dated 06/03/2012
Letter of Approval from Germany dated 01/08/2012
7.2
Appendix B: List of documents reviewed
Category A documents (documents prepared by the PP)
• PDD Version 1 dated 20/10/2011
• PDD Version 2 dated 23/02/2012
• PDD Version 3 dated 30/03/2012
• PDD Version 04.0.0 dated 29/05/2012
• PDD Version 05.0.0 dated 16/07/2012
• PDD Version 05.1.0 dated 20/07/2012
• PDD Version 05.1.1 dated 07/08/2012
• PDD Version 05.2 dated 27/09/2012
• PDD Version 5.3 dated 05/10/2012
• PDD Version 5.4 dated 29/10/2012
• PDD Version 5.5 dated 04/12/2012
• Spreadsheet for IRR calculation, Version 01 dated 20/10/2011
• Spreadsheet for IRR calculation, Version 02 dated 23/02/2012
• Spreadsheet for IRR calculation, Version 03 dated 16/07/2012
• Emission reduction spreadsheet, Version 01 dated 20/10/2011
• Emission reduction spreadsheet, Version 02 dated 29/05/2012
• Emission reduction spreadsheet, Version 03 dated 16/07/2012
• Emission reduction spreadsheet, Version 04 dated 07/08/2012
• Emission reduction spreadsheet, Version 04.1 dated 27/09/2012
• Mass and Energy balance spreadsheet dated 07/08/2012
• Overall design documents for project Installation of Heat Recovery Steam Boiler at
Wirajaya Packindo
• Gas turbine manufacturer’s specifications
• Contract with HRSG supplier and EPC contractor between PT Wirajaya Packindo
and PT. Indoturbine dated 01/09/2011
• ERPA term sheet between PT Wirajaya Packindo and KfW dated 12/08/2011
• Sustainable development criteria set by host country DNA
(http://pasarkarbon.dnpi.go.id/web/index.php/komnasmpb/cat/5/kriteria-p.)
• Turbine specification and lifetime from Turbomach
• Letter of Designed operational life of HRSG by Mackenzie Industries Sdn Bhd
• Procedure for employee recruitment by PT Wirajaya Packindo
• Minutes of Meeting for CDM Stakeholder Consultation dated 05/10/2011
• Approval letter from Environmental Agency for Environmental Management and
Monitoring Plan dated 08/11/2011
• Contract for new paper machine duplex by supplier in China
• Contract for Coal Boiler by Shanghai Distribution co. Ltd, dated 05/06/2008 and
10/08/2008
• Business license for PT Wirajaya Packindo
• Prior consideration form submitted to UNFCCC dated 18/07/2011
• Commitment fee Invoice by Caterpillar dated 01/11/2010
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 16 of 92
Revision 0.9, 07 November 2012
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Invoice for boiler maintenance of pipe from PT. Zug Industry Indonesia dated
15/09/2011
Purchase order for boiler maintenance to Shanghai Chenguan Import and Export
co. Ltd dated 27/10/2011
Invoice for gas consumption from PT Gas Negara (PGN) dated 05/10/2009 and
04/10/2011
Agreement of grace period by Catterpilar finance
Offer to lease and acceptance between PT Wirajaya Packindo and PT Caterpillar
Finance Indonesia dated 08/09/2011
Offer for insurance for HRSG operation by ACA Asuransi dated 19/09/2011
Spreadsheet for coal price of July 2009 to August 2011
News translation on gas price increase in 2011 by Indonesia Finance Today
(14/09/2011), Liputan 6 SCTV (13/04/2011) and Kabarbisnis (07/10/2011)
PGN business presentation slides
News on gas export price increase from Jakarta Globe dated 15/09/2011
News on Indonesia: searching for gas supplies from Jakarta Post dated
05/09/2011
News on gas price renegotiation from Jakarta Post dated 07/09/2011
News on industrial gas price increase from Indo Finance dated 14/09/2011
News on BP Migas seeks to hike PGN gas price by 200% from Jakarta Globe
dated 2 August 2011
News on Kadin protest for industrial gas price increase from Kadin Sumatera Utara
website dated 29/09/2011
News on gas price increase by PGN to be reported to government from
Kabarbisnis dated 07/10/2011
Purchase order for Coal Boiler to Shanghai Distribution co. Ltd, dated 07/06/2008
Spreadsheet of plant historical data
2006 IPCC Guidelines for National Greenhouse Gas Inventories
Supporting data for CDM project by PT Wirajaya Packindo dated 23/07/2011
Spreadsheet data for Coal GCV
Gas composition before and after project activity
Gas turbine specification by Turbomach
Boiler specification report, dated 22/02/2011
Spreadsheet for CER calculation dated 14/11/2011
Diagram for heat mass balance by PT Wirajaya Packindo
Spreadsheet for GCV gas specification
DEG Technical Audit for energy optimization services by Siemens, dated
10/07/2011 to 15/07/2011
Electric power requirement information of baseline and HRSG
Gas specification of PT PGN dated 29/03/2011
Gas specification by Pertamina dated 27/03/2011
12 MW Operational capacity information
Letter from PGN on gas price increase dated: 08/05/2012, Ref:
069900.S/PP.01.01/SBU1/2012
Gas turbine mechanical and electrical drawings
Gas turbine manual
Gas turbine O&M Manual
Turbomach witness test of gas turbine dated: 05/09/2008
Gas Turbine Exhaust Silencer General Arrangement dated 15 April 2009
Email clarification from the German DNA on its requirements for approval dated:
06/11/2012
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 17 of 92
Revision 0.9, 07 November 2012
Category B documents (other documents referenced)
• Clean development mechanism validation and verification standard Version 03.0
• Guidelines for completing the simplified project design document (CDM-SSC-PDD)
and the form for proposed new small scale methodologies (CDM-SSC-NM),
Version 05 (14 September 2007)
• Project Design Document Form (CDM-SSC-PDD) Version 03
• Indicative simplified baseline and monitoring methodologies for selected small
scale CDM project activity categories AMS-III.Q “Waste energy recovery
(gas/heat/pressure) projects” version 04
• Tool to calculate project or leakage CO2 emissions from fossil fuel combustion
Version 2
• Tool to determine the remaining lifetime of equipment Version 1
• General guidelines to SSC CDM Methodologies Version 19.0
• Guidelines on the assessment of investment analysis Version 5
• Non-binding best practice examples to demonstrate additionality for SSC project
Activities (Annex 34, EB 35)
• Submission status of Prior Consideration of CDM to CDM Secretariat
http://cdm.unfccc.int/Projects/PriorCDM/notifications/index_html
• Indonesian DNA website: http://pasarkarbon.dnpi.go.id/web/index.php/home.html
• EB Clarification SSC 579
(http://cdm.unfccc.int/methodologies/SSCmethodologies/clarifications/40482)
• Bank of Indonesia website
• Google website for confirmation of geo-coordinates
• Project Mechanisms Act available on the website of German DNA
7.3
Appendix C: List of persons interviewed
Wirajaya Packindo
Budi Hartoyo H
Harimas Hutama
Ari Liberto
Eko Prasetyo
Muji Sarjono
Wira Rahardjo
KfW
Cynthia Hendrayani
Biosphere Capital
Thet Lin Thu
Angus McEwin
Local stakeholders
Mimin Priatna
Wawan
PT. PGN
Arys Djuanda
Rudiatmoko
Environmental Agency of Tangerang region (BPLH)
Agus Prasetyo
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 18 of 92
Revision 0.9, 07 November 2012
Arjono
Risdiana Setiawan
7.4
Appendix D: How due account has been taken to the public input
made to the validation requirements
The PDD was made publicly available in accordance with the requirements of the
Procedures for processing and reporting on validation of a CDM project activity for the
period of 29/10/2011 to 27/11/2011 as per
http://cdm.unfccc.int/Projects/Validation/DB/SY7X21Y5CMMDJDGCAL596JSNKSDP9
N/view.html
No comment was received during this period.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 19 of 92
Revision 0.9, 07 November 2012
7.5
Appendix E: Certificate of Appointment
Validation of “Installation of Waste Heat Recovery Steam Boiler
at Wirajaya Packindo”
We hereby certify that the following personnel have engaged in the validation process
that has fully satisfied the competence requirements of the validation of the CDM
project activity.
Name of Person
Assigned Roles
Ankush Jain
Cholid Bafagih
Hikmat Wijaya
M. Nursyam
Ketan Deshmukh
Brahim Abdullah
Chiba Michiaki
Team Leader
Team Member
Team Member
Sector Expert
Technical Reviewer
Sector Expert
Decision Maker
Signed by
Decision Maker
Michiaki Chiba
Climate Change Manager – Asia & Pacific
04/12/2012
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 20 of 92
Revision 0.9, 07 November 2012
7.6
Appendix F: Validation Protocol and findings log
LLOYDS REGISTER QUALITY ASSURANCE
Clean Development Mechanism
Validation Protocol and Findings
This document has been produced by the LRQA Validation Team after the completion of the desk review and the site visit.
It outlines the validated situation in relation to a number of criteria, including those defined in the Validation and Verification Standard (VVS) produced by the CDM
Executive Board.
The questions within this document must be completed in full and in your own words. The purpose of this protocol is to record LRQA’s opinion and LRQA’s findings.
If LRQA has identified issues requiring corrective action or clarification, make a reference in the ‘Conclusion’ column, and state details in the section marked ‘Findings’.
Conclusion
Validated situation
SECTION 1. Approval
Host Country Approval
1. Has the Host country DNA provided a written
approval?
2. Confirm that the letter has been issued by the
Party’s DNA and is valid for the proposed CDM
project activity under validation
3. Mention the means of validation employed to
assess the authenticity of the Letter of Approval.
Indicate the source of the LoA (for example, PP or
directly from the DNA)
1
Yes
No
NA
CAR 01 was issued as LoA was not submitted for validation. In response to the
finding, the PP has submitted the LoA. The resolution is as detailed in the findings
section of this protocol.
Yes
No
NA
The LoA is issued on 06/03/2012 by the National committee on CDM, which is the
DNA of the host Party as per http://cdm.unfccc.int/DNA/index.html. The LoA is
issued for the proposed project activity.
CAR 01
OK
The LoA was made available by the PP.
Validation team compared the LoA from the original submitted by the DNA.
Comparison with other approved projects by the DNA was also conducted to check
the authenticity of the letter (included project ref 5468 and 5240).
OK
OK
1
For each section and question where a YES / NO / NA answer is required, explain your choice.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date: 04/12/2012
Page 21 of 92
Revision 0.9, 07 November 2012
Validated situation
Conclusion
OK
4. Does the written Letter of Approval confirm the
following:
(a) The Party is a Party to the Kyoto Protocol
(including ratification)?
(b) Participation is voluntary?
(c) The proposed CDM project activity
contributes to the sustainable
development of the country?
(d) It refers to the precise proposed CDM
project activity title in the PDD being
submitted for registration?
Yes
No
NA
The LoA confirms:
(a) The host country Party ratified the KP on 28/07/2004.
(b) The participation is voluntary.
(c) The proposed project activity will assist the host country in achieving sustainable
development.
(d) LoA indicates the precise title of the proposed project activity as indicated in the
PDD
5. Is the letter of approval unconditional with respect
of (a) to (d) above?
Yes
No
NA
The LoA does not add any specific condition to the points stated therein
OK
6. Does the LoA from the host party acknowledge
the bundle activity (if applicable)?
Yes
OK
No
NA
Annex I Party Approval
7. Has the Annex I country DNA provided a written
approval?
8. Confirm that the letter has been issued by the
Party’s DNA and is valid for the proposed CDM
project activity under validation.
9. Mention the means of validation employed to
assess the authenticity of the Letter of Approval.
Indicate the source of the LoA (for example, PP or directly
from the DNA).
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Yes
No
NA
CAR 01 was issued as LoA from the Annex I Party has not been submitted for
validation. In response to finding the PP has submitted the LoA. The resolution is as
detailed in the findings section of this protocol.
Yes
No
NA
CAR 01 OK
LoA was confirmed from the list of projects available at the DNA website. Ref:
https://www.jicdm.dehst.de/promechg/pages/project1.aspx
OK
Page 22 of 92
Revision 0.9, 07 November 2012
OK
Validated situation
Conclusion
10. Does the written Letter of Approval confirm the
following:
(a) The Party is a Party to the Kyoto Protocol
(including ratification)?
(b) Participation is voluntary?
(c) It refers to the precise proposed CDM
project activity title in the PDD being
submitted for registration?
Yes
No
NA
The LoA confirms:
(a) The Annex-I country Party ratified the KP.
(b) The participation is voluntary.
(c) LoA indicates the precise title of the proposed project activity as indicated in the
PDD
OK
11. Is the letter of approval unconditional with respect
of (a) to (c) above?
Yes
No
NA
The LoA does not add any specific condition to the points stated therein
OK
Yes
CAR01
OK
Host Country and Annex I Party Approval
12. Do any of the Letters of Approval contain
additional specification of the project activity? Like:
- PDD Version number?
- Validation report version number?
Make sure that the request for registration is made on the
basis of the documents specified in any of the letters.
No
NA
LoAs from the host party DNA and Annex I Party do not include any specification of
the project activity, like specific version numbers of the PDD and validation report.
The LoA from the Annex I Party’s DNA refers to the project data base wherein
versions of the PDD and validation report earlier submitted are made available. The
project data base of German DNA is referring to PDD Version 4.0.0 and Validation
report Version 01.
The current versions are PDD Version 5.5 and the validation report Version 2.14 that
has accounted for issues raised during the internal review process at LRQA.
Validation team reviewed the Project Mechanisms Act and the email clarification sent
by the German DNA to the PP dated 06/11/2012 and confirmed that the German
DNA accepts a draft validation report for the approval even though the LoA refers to
the final validation report.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 23 of 92
Revision 0.9, 07 November 2012
Validated situation
Conclusion
SECTION 2. Participation
1
Confirm that the PPs are listed in a tabular form in
section A.3 of PDD and that this information is
consistent with the contact details provided in
Appendix 1 of the PDD and with the contact details in
the MoC.
2
Confirm that each of the PPs has been approved by
at least one Party involved.
3
Confirm that no entities other than those approved as
PPs are included in section A.3 of PDD.
4
Ensure that the approval of participation has been
issued from the relevant DNA. If in doubt verify this
with the corresponding DNA.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Host Party PP name in PDD/ A.4
PT Wirajaya Packindo
Host Party PP name in PDD/ Appendix 1
PT Wirajaya Packindo
Host Party PP name in MoC
PT Wirajaya Packindo
Annex 1 Party PP name in PDD/ A.4
KfW
CL 01 was raised as name of the PP
was inconsistent between section A.3
and Annex 1. In response to the finding,
the PP has corrected the name of the
PP, therefore, finding was closed. The
resolution is as detailed in the findings
section of this protocol.
Annex 1 Party PP name in PDD/
Appendix 1
KfW
Annex 1 Party PP name in MoC
KfW
CL-01
OK
Yes
No
NA
The PP, PT. Wirajaya Packindo is approved by the host Party, i.e. Indonesia, DNA.
The PP, KfW is approved by the Annex-I Party, i.e. Germany, DNA.
Yes
No
NA
CAR01
OK
The approval by the host country DNA and Annex I Party DNA has been issued by
the correct organizations. Validation team had also confirmed the LoAs from the
similar cases. LoA was also confirmed from the German DNA’s website at
https://www.jicdm.dehst.de/promechg/pages/project1.aspx
CAR01
OK
Page 24 of 92
Revision 0.9, 07 November 2012
CAR01
OK
Validated situation
Conclusion
SECTION 3. Modalities of communications
1
Validate the corporate identity of all the PPs and the focal
point included in the MoC letter:
- Validate the signatures
- Validate the employment status.
To validate this use any of the following options:
a. Directly checking with evidence from PPs and the
corresponding companies, for example, contracts,
personal identity card or passport, HR records.
b. Notarised documentation, e.g power of attorney for
signing on behalf of the company and the other PPs.
c. Written confirmation from the PP that all the personal
details are valid and accurate.
2
If a written confirmation (option c) is chosen from the
options above, the following issues shall be validated:
- The PP sending the written confirmation and signing
it shall be the one signing the contract with LRQA.
- The person signing the written confirmation and the
person signing the MoC (if they are different persons)
are duly authorised to do so on behalf of all the PPs,
that is, they have a signed authorisation from the
other PPs and the identity and role of the person who
has signed this authorisation has been checked.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Validation team confirmed the corporate identity of the PPs from the signed
validation contract, HRSG contract and ERPA term sheet.
Further, written confirmation has been submitted by the PT. Wirajaya Packindo
on the corporate identity, name & employment status and specimen signatures
of the signatory of MoC.
OK
Corporate identity, name, employment status and specimen signature were
confirmed from the note by Board of Directors of KfW, ERPA and website of
KfW.
The written confirmation by the PP was submitted. The signature in the written
confirmation was checked with other contracts of the PP made available for
validation.
Page 25 of 92
Revision 0.9, 07 November 2012
OK
3
Has the MoC been completed as per the latest
“Procedures for MoC between the project participants
and the Executive Board”?
- No modifications to the template / form should be made
and each document should be clearly dated
- Title of the project and names of project participants and
focal points should be fully consistent with those
indicated in all other project documentation
- Focal point scopes should be clearly and correctly
indicated
- Contact details and specimen signatures of focal point
entities including those of project participants in Annex 1
should be correctly entered. Only one telephone, fax,
email contact should be entered per authorized
signatory. In cases where additional contact details are
included, only the first indicated information will be taken
into account and only the official business address of the
proposed entity should be provided on the F-CDMMOC form.
- The Statement of Agreement in Section 3 should be
signed by one authorized signatory for each project
participant; signatures made available in Section 3
should correspond to those indicated in the related
Annex 1 document; focal point entities who are not
designated as project participants should not sign
Section 3.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Yes
No
NA
OK
MoC is consistent with the PDD.
Validation team confirms that:
1. No modification in the template has been made.
2. Dates have been clearly mentioned in the MoC.
3. Title of the project and names of project participants and focal points are
fully consistent with the PDD. The PPs, PT. Wirajaya Packindo and KfW,
consistent between PDD, and the MoC.
4. Focal point scopes are clearly and correctly indicated
5. Statement of Agreement in Section 3 is signed by one authorized
signatory of project participant.
Page 26 of 92
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Validated Situation
Conclusion
SECTION 4. Project design document
1. Is the project activity Small Scale or Normal Scale?
2. Has the PDD used the latest template and guidance
from the CDM Executive Board available on the
UNFCCC CDM Website?
Check outputs from the completeness check.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Normal Scale
Small Scale
(cross as appropriate)
Yes
Bundled Small Scale
No
OK
OK
F-CDM-SSC-PDD template Version 04.1 and Guidelines for Completing the
Project Design Document form for small-scale CDM project activities, version
01.0, which are the current versions for CDM VVS track available in UNFCCC
CDM website, are used.
Page 27 of 92
Revision 0.9, 07 November 2012
Validated situation
Conclusion
SECTION 5. Project description
1. Describe the process undertaken to validate that the
description of the proposed CDM project activity as
contained in the PDD sufficiently covers all relevant
elements, is accurate, and that it provides the reader
with a clear understanding of the nature of the
proposed CDM project activity.
The project activity is recovery of waste heat from the existing 12MW gas
turbine to generate steam. The steam generated from the project activity will be
used in the existing and new paper production lines. The project activity involves
installation of waste heat recovery boiler of capacity 50TPH. The waste heat
recovery boiler uses waste heat from the gas turbine. Additional energy for
generation of steam will be supplied through natural gas. Prior to the project
activity the equivalent steam would have been generated through the existing
coal based boilers. In the absence of the project activity, the equivalent steam
would have been generated from the existing coal based boilers. The project
activity reduces the GHG emissions from the utilisation of waste heat and use of
cleaner fossil fuel.
CL-02
OK
During the process of validation, LRQA confirmed the capacity, unique
identification of project activity, estimated steam generation, technical
specification and necessary clearances required/taken for the project activity.
The list of documents reviewed during the course of validation is presented
under Appendix B.
CL 02 was raised on inconsistency in the capacity of gas turbine. In response to
the finding, the PP has clarified that designed capacity was based on
International Standards Organisation (ISO) test conditions whereas actual
capacity was based on site conditions. Relevant section of the PDD was
corrected. The resolution is detailed in the findings section of this protocol.
2. Confirm that the exact project location is provided in
the PDD with Geographical coordinates, check the
accuracy of them and the format of the notation
(Grades, minutes, seconds or decimal indicating
latitude N or S and Longitude E or W)
Please include here the Geographical coordinates:
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
The PDD provides the exact project location with geographical coordinates.
The project activity is located at Koang Jaya village, about 1 hour drive north
west of Jakarta, the capital city of Indonesia. The geographical coordinates of
the project activity are:
6°12’14.03’’ S and 106° 37’18.80’’ E
The geographical coordinates of the project site were confirmed through
document review, i.e. Google website, and during the site visit.
Page 28 of 92
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OK
Conclusion
Validated situation
3. Confirm that the physical site inspection reflects the
description in the PDD of the proposed CDM project
activity.
The physical site inspection was conducted during the site visit. During the site
visit, construction of the project was under progress. The process steam
required for the paper mill is being generated by the existing coal fired boilers.
Existing gas turbine was used to meet the electricity requirement of the paper
mill. Waste heat from the gas turbine was released in the atmosphere.
Therefore, team confirms the description given in the PDD to be accurate.
OK
4. If the team did not undertake a physical site
inspection, describe the justification as approved by
the CDM Quality Manager. (VVM 01.2: 60-61)
The team has visited the site from 13/12/2011 to 14/12/2011. During this period,
the team visited the manufacturing facility including paper mill, gas turbine
generator unit, and waste heat recovery boiler, gas supplier, official
departments.
OK
Describe briefly the physical site inspection: Travel
details and installations, facilities and buildings visited.
5. If the proposed CDM project activity involves the
alteration of an existing installation or process, ensure
that the project description clearly states the
differences resulting from the project activity compared
to the pre-project situation.
6. Potential public funding for the project from Parties in
Annex I shall not be a diversion of official development
assistance (ODA).
Pre-project
No waste heat recovery system was
installed at gas turbine
Steam sourced from the existing coal
fired boilers.
Project activity
OK
Recovery and utilisation of waste heat
from the existing gas turbine to
generate steam. Natural gas will be
used as supplementary fuel of the new
waste heat recovery boiler.
PDD section A.4.4 confirms that there is no public funding or Official
Development Assistance from Annex I countries.
OK
The validation team interviewed the PP and the stakeholders and confirmed that
the project activity is funded by equity of the private investors and loan from the
private banks. However, the debt/equity ratio of the project activity is not yet
determined.
7. If the project activity is a small scale one, confirm that
it is not a debundled component of a large scale
project, in line with appendix C of the simplified M&P
for SSC CDM project activities and the Guidelines for
assessment of de-bundling for SSC project activities.
PDD Section A.4.5 confirming that it is not a debundled component of a large
scale project, in line with appendix C of the simplified M&P for SSC CDM project
activities and the Guidelines for assessment of de-bundling for SSC project
activities.
Through site visit, the validation team confirmed that there was no similar project
whose project boundary is within 1 Km of the project boundary of the project
activity.
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OK
Validated situation
Conclusion
SECTION 6. Baseline and monitoring methodology
1. Have the baseline and monitoring methodologies selected by
the project participants been previously approved by the CDM
Executive Board, that is, does it appear on the methodologies
page of the UNFCCC website?
2. If the project activity is a Small Scale one; does it qualify within
the threshold of the three possible types of small scale
projects? Confirm information provided in the PDD.
3. If the project activity is a Small Scale one; which approved
small scale methodology does the project apply? Confirm that
the SSC methodology is applied with the general guidelines to
SSC CDM methodologies.
4. Determine whether the methodology selected is applicable to
the project activity including that the used version is valid.
Describe steps taken to assess the relevant information contained in the
PDD in the table below.
Yes
No
NA
The project activity applies the small-scale methodology, AMS-III.Q
version 4.0 “Waste Energy Recovery (gas/heat/pressure) Projects”.
CL-04 was raised on application of combination of methodologies
AMS.III.Q and AMS.II.D. PP has removed the methodology AMS.II.D.
The resolution is detailed in the findings section of this protocol.
CL-04
OK
The project activity recovers and utilises waste heat from the existing
gas turbine. Therefore, the project activity is characterised as ‘Type III’
activity. Validation team confirms from the review of the PDD and its
supporting evidence; and its sectoral expertise that the estimated
annual emission reduction from the project activity is 56,427
tCO2e/annum, less than 60,000 tCO2e/year, every year throughout the
crediting period.
The project applies the methodology of “Waste Energy Recovery
(gas/heat/pressure) Projects” AMS-III.Q, in conjunction with the general
guidelines of SSC-CDM methodologies.
OK
The project activity applies the version 4.0 of the small-scale
methodology AMS.III.Q. This version of the methodology is the most
recent during the completion of this report.
CL 03 was raised as applicable version of the guidelines was not
referred in the PDD. PP has revised the PDD to mention the applicable
version of guidelines. The resolution is detailed in the findings section
of this protocol.
CL-03
OK
OK
No.
Applicability conditions in the AMS-III.Q
version 4.0
Information in the PDD
Steps taken to assess PDD
information
Conclusion
1
The category is for project activities that utilize
The project will utilise waste heat generated
The proposed project utilises waste heat
OK
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waste gas and/or waste heat at existing
facilities as an energy source for:
(a) Cogeneration; or
(b) Generation of electricity; or
(c) Direct use as process heat; or
(d) Generation of heat in elemental process
(e.g. steam, hot water, hot oil, hot air); or
(e) Generation of mechanical energy.
at the existing facility as an energy source for
generation of heat in elemental process (i.e.
steam)
for generation of steam. Validation team
confirmed the description from the review
of PDD, EPC contract for waste heat
recovery boiler and site visit.
2
The category is also applicable to project
activities that use waste pressure to generate
electricity at existing facilities
The Project does not involve the use of waste
pressure
OK
3
The recovery of waste gas/heat/pressure
should be a new initiative (no waste
gas/heat/pressure was recovered from the
project activity source prior to the
implementation of the project activity)
Measures are limited to those that result in
emission reductions of less than or equal to
60 kt CO2 equivalent annually
Prior to the implementation of the project, no
waste gas/heat/pressure was recovered from
the project activity source
Not relevant.
Validation team confirmed from the
review of PDD, EPC contract for waste
heat recovery boiler, and site visit that
the project activity does not involve use
of waste pressure.
Validation team confirmed the description
from the review of EIA report,
manufacturer’s specification of gas
turbine, and site visit.
The project activity is expected to result in
emission reductions of less than 60kt of CO2
equivalent annually
Validation team confirmed from the
review of PDD and emission reduction
spreadsheet that the emission reduction
for the project has been correctly
calculated as 56,427tCO2e/annum,
every year during the crediting period.
OK
The steam produced using the waste heat is
measurable
Validation team confirmed from the
review of PDD, site visit and its sectoral
expertise that energy output from the
steam produced is measurable.
OK
Energy generated in the project activity is
entirely used within the industrial facility
Validation team confirmed from the
review of PDD, interview of the PP, site
visit and its sectoral expertise that energy
OK
4
5
(a)
(b)
OK
The category is applicable under the following
conditions:
The energy produced with the recovered waste
gas/heat/pressure should be measurable;
Energy generated in the project activity may be
used within the industrial facility or exported to
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other industrial facilities (included in the project
boundary);
(c)
Electricity generated in the project activity may
be exported to the grid or used for captive
purposes;
(steam) produced by the project activity
will be used within the paper mill.
The project activity does not involve the
generation of electricity. The project activity
recovers heat from an on-site electricity
power plant
Validation team confirmed from the
review of PDD, EPC contract for waste
heat recovery boiler, site visit and its
sectoral expertise that the project activity
does not involve installation of combined
cycle power plant.
OK
The project activity recovers waste heat from
one source only and uses it for steam
generation
Validation team confirmed from the
review of the PDD, site visit and its
sectoral expertise that the project activity
uses waste heat from a single source,
i.e. gas turbine.
OK
However, the methodology is not applicable to
projects where the waste gas/heat/pressure
recovery project is implemented in a singlecycle power plant (e.g. gas turbine or diesel
generator) where heat (energy) generated onsite is not utilizable for any other purposes onsite except to generate power. Such project
activities shall consider AMS-III.AL
“Conversion from single cycle to combined
cycle power generation”. Projects recovering
waste energy from such power plants for the
purpose of generation of heat only can apply
this methodology;
(d)
For a project activity which recovers waste
gas/heat/pressure for power generation from
multiple sources (e.g. kiln and single-cycle
power plant), this methodology can be used in
combination with AMS-III.AL provided that:
(i)
Within the project activity it is possible to
distinguish two distinct waste energy
sources such that:
•
Waste energy source-I (e.g. kiln)
belongs to such waste heat sources
which are eligible under AMS-III.Q;
•
Waste energy source-II (e.g. single-
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cycle power unit) belongs to such
waste heat sources which are eligible
under AMS-III.AL;
(e)
(ii)
It is possible, for each waste energy
source, to determine the baseline
according to the specific methodology
referred to;
(iii)
It is possible to objectively allocate the
electricity produced in the project activity
to each waste energy source, by means
of one of the following methods:
•
Through separate measurements of
the electricity produced by utilizing
waste energy from each waste energy
source; or
•
Through separate measurements of
the energy content of the waste
energy carrying medium (WECM)
streams used for electricity production;
or
•
Through separate measurements of
the energy content of the waste
energy streams that are associated
with each waste energy source and
used for electricity production or for
the WECM generation in a common
waste heat recovery system (e.g. if
steam is generated by waste heat from
a kiln and waste heat from an internal
combustion engine in a common
waste heat recovery boiler);
The emission reductions are claimed by the
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
The emissions reductions are claimed by the
project proponent which is the generator of
Date 04/12/2012
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Validation team confirmed from the
interview of the PP, and site visit that
OK
generator of energy using waste energy;
(f)
(g)
In cases where the energy is exported to other
facilities (included in the project boundary), the
following are required:
(i)
All historical information from the
recipient plants;
(ii)
An official agreement exists between
the owners of the project energy
generation plant (henceforth referred
to as generator, unless specified
otherwise) and the recipient plant(s)
that the emission reductions would
not be claimed by the recipient
plant(s) for using a zero-emission
energy source;
For those facilities and recipients which are
included in the project boundary, that prior to
implementation of the project activity (current
situation) generated energy on-site (sources of
energy in the baseline), the credits can be
claimed for minimum of the following time
periods:
(i)
The remaining lifetime of
equipments currently being used;
and
(ii)
Crediting period;
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
the energy using waste energy
The energy is not exported to other facilities
but is used within the same facility
The remaining lifetime of the current
equipment is estimated to be 17 years.
Credits are only claimed for a non-renewable
10 year term.
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emission reductions are claimed by the
PP, PT. Wirajaya Packindo, generator
and consumer of steam from the waste
gas.
Not relevant.
The energy (steam) produced by the
project activity is consumed within the
facility.
Validation team confirmed from the
review of remaining lifetime from the
review of local regulations.
OK
OK
(h)
The waste gas/heat/pressure utilized in the
project activity would have been flared or
released into the atmosphere in the absence of
the project activity. This shall be proven by
one of the following options:
(i)
By direct measurements of energy
content and amount of the waste
gas/heat/pressure for at least three
years prior to the start of the project
activity;
(ii)
Energy balance of relevant sections
of the plant to prove that the waste
gas/heat/pressure was not a source
of energy before the implementation
of the project activity. For the
energy balance representative
process parameters are required.
The energy balance shall
demonstrate that the waste
gas/heat/pressure was not used and
also provide conservative
estimations of the energy content
and amount of waste
gas/heat/pressure released;
(iii)
This is demonstrated by option (ii) and (iv):
This is demonstrated by option (iv):
Manufacturer’s original diagram from the
construction of the facility that waste heat
was released in the atmosphere in absence
of the project activity.
Further, quantity and energy content of the
waste heat was taken from the energy
balance using simulation by technology
supplier.
Date 04/12/2012
Based on the energy balance based on
simulation and technical specification
and technical drawings of the gas turbine
system validation team confirmed the
description. Further, the energy balance,
the process design at full load of
12.124MW was considered, and it gives
an estimate of energy content and
amount of waste heat released.
Team confirmed based on the design
drawing number 10932.T1.OG.001
General Layout prepared by Turbomach
and Gas Stack drawing prepared by IAC
Colpro.
Team confirmed the quantity and energy
content of waste heat from the results of
simulation software by the turbine
manufacturer. Team further confirmed
the quantity and energy content of waste
gas from the review of data sheet
prepared by the WHRB manufacturer for
boiler design.
Suitability of input values used for mass
and heat balance is provided in section
6c of the Protocol below.
Energy bills (electricity, fossil fuel)
to demonstrate that all the energy
required for the process (e.g. based
on specific energy consumption
specified by the manufacturer) has
been procured commercially.
Project participants are required to
demonstrate through the financial
documents (e.g. balance sheets,
profit and loss statement) that no
energy was generated by waste
gas/heat/pressure and sold to other
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
OK
The waste heat utilized by the project would
have been released into the atmosphere in
the absence of the project activity.
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facilities and/or the grid. The bills
and financial statements should be
audited by competent authorities;
(iv)
6
Process plant manufacturer’s
original specification/information,
schemes and diagrams from the
construction of the facility could be
used as an estimate of quantity and
energy content of waste
gas/heat/pressure produced for
rated plant capacity per unit of
product produced.
For the purpose of this category waste energy
is defined as: a by-product gas/heat/pressure
from machines and industrial processes having
potential to provide usable energy, for which it
can be demonstrated that it was wasted. For
example gas flared or released into the
atmosphere, the heat or pressure not
recovered (therefore wasted). Gases that
have intrinsic value in a spot market as energy
carrier or chemical (e.g. natural gas, hydrogen,
liquefied petroleum gas, or their substitutes)
are not eligible under this category.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
The waste energy used by the project is a byproduct heat from a gas turbine and it would
otherwise have been wasted. The exhaust
gas/heat from the turbine has no intrinsic
value in spot market.
Date 04/12/2012
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Validation team confirmed from the
sectoral expertise and host country
expertise that there is no spot market for
waste heat from the gas turbine.
OK
Conclusion
Validated situation
5. Confirm that any specific guidance provided by the CDM
Executive Board in respect to an approved methodology has
been correctly applied.
Two clarification related to this project were requested to CDM-EB, i.e.
SSC_579 and SSC_582.
OK
In SSC_579, it was clarified that for integrated burners where energy
output cannot be apportioned between fossil fuel and waste heat, and
calculation of fWCM is practically not possible, it should be considered
as 1. Emissions from consumption of supplementary fossil fuel should
be considered as project emissions. This has been correctly applied for
the project activity.
In SSC_582, it was clarified that AMS.III.Q only was the most
appropriate methodology for combination of waste heat recovery, and
fossil fuel switch. This has been correctly applied for the project
activity.
6. If a determination regarding the applicability of the selected
methodology to the proposed CDM project activity cannot be
made, request clarification of the methodology in line with the
guidance provided by the CDM Executive Board.
Describe the clarification request and response.
Not Applicable
The project activity satisfies all the applicability conditions.
-
7. If the Validation Team determines that the proposed CDM
project activity does not comply with the applicability conditions
of the methodology, the Team may proceed by means of
requesting revision to or deviation from the methodology in line
with the guidance provided by the CDM Executive Board.
Describe the request for revision or deviation and approval by the CDM
Executive Board.
Not Applicable
The project activity satisfies all the applicability conditions.
-
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Validated situation
Conclusion
SECTION 6a. Project boundary
1. Does the project boundary include physical,
geographical site of the industrial facility,
processes, or equipment that are affected by the
project activity?
OK
Yes
No
NA
The description presented in the PDD includes the gas turbine generator system,
waste heat recovery boiler system and paper mill where steam will be consumed.
The Validation team confirmed that there is no issue related to the project boundary
based on AMS.III-Q.
2. If the proposed project activity has both
Afforestation/Reforestation (A/R) and non-A/R
components, to avoid double counting of emission
sources, LRQA shall confirm that the emissions
associated with the A/R activity will be accounted
for and documented by the A/R project activity.
Validation team confirms from the project documentation, site visit, and its sectoral
expertise that the project does not have any Afforestation/Reforestation (A/R)
component.
OK
3. If there are any GHG emissions occurring within
the proposed CDM project activity boundary,
which are not addressed by the applied
methodology and which are expected to
contribute more than 1% of the overall expected
average annual emissions reductions as a result
of the implementation of the project, LRQA shall
request clarification of, revision to, or deviation
from the methodology as appropriate.
The validation of the project activity did not reveal any other greenhouse gas
emissions occurring within the proposed project activity boundary as a result of the
implementation of the proposed CDM project activity which is expected to contribute
more than 1% of the overall expected average annual emission reduction, which are
not addressed by the applied methodology.
OK
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Validated situation
4. Confirm that all sources and GHGs required by
the methodology have been included within the
project boundary.
Describe here if any emission source that will be
affected by the project activity and is not
addressed by the approved methodology, has
been identified. In such case request clarification
of, revision to or deviation from the methodology
in accordance with EB guidance.
Use the table below for this purpose:
As per Methodology has been included all sources and GHGs required, i.e. Project
emissions include emissions due to combustion of auxiliary fuel to supplement waste
gas and emissions due to consumption of electricity by the project activity.
Validation team confirms the emission sources and gases from the review of applied
methodology, review of project documentation, site visit and its sectoral expertise.
Conclusion
OK
Validation team confirms that there is no emission source affected by the project
activity and not addressed by the applied methodology.
Gases and Sources Included In The Project Boundary
PROJECT
BASELINE
Source
Fossil fuel
consumption in
element process
for supply of
process heat
(portion of the
fossil fuel
displaced by
waste heat)
Supplemental
fossil fuel
consumption at
the project plant
Gas
Justification PDD
CO2
Included
Main emission source
CH4
Excluded
Excluded for simplification. This is
conservative
N2O
Excluded
Excluded for simplification. This is
conservative
CO2
Included
Main emission source
CH4
Excluded
Excluded for simplification. This is
conservative
N2O
Excluded
Excluded for simplification. This is
conservative
LRQA Reference: ENQ/2607/11/IRE
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Inc./Exc.
Pdd
Date 04/12/2012
Steps Taken To Assess PDD Justification
Conclusion
As CO2 is the main emission source, hence
inclusion of this gas in project boundary is
appropriate.
CH4 emissions would be minor in nature.
Hence it is appropriate to exclude this gas.
OK
N2O emissions would be minor in nature.
Hence it is appropriate to exclude this gas.
OK
CO2 emissions from the combustion of fossil
fuels shall be accounted for as project
emissions.
CH4 emissions would be minor in Combustion
of natural gas. Hence it is appropriate to
exclude this gas.
N2O emissions would be minor in nature.
Hence it is appropriate to exclude this gas.
OK
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OK
OK
OK
Validated situation
Conclusion
SECTION 6b. Baseline identification
1. Determine whether the PDD provides a verifiable
description of the identified baseline scenario,
including a description of the technology that
would be employed and/or the activities that
would take place in the absence of the proposed
CDM project activity.
2. Confirm that any procedure contained in the
methodology to identify the most reasonable
baseline scenario, has been correctly applied.
The PDD describes the baseline scenario as continued release of waste gas to
atmosphere and steam generation from the existing coal fired boiler.
OK
The Validation team has reviewed the baseline scenario and confirmed that the
provided description is verifiable
Yes
No
OK
NA
The applied methodology does not describe the procedure to identify the most
reasonable baseline scenario. The baseline has been determined using the process
prescribed in the methodology. The baseline is steam sourced from the coal boilers
and continued venting of waste gas (scenario existing prior to the project activity).
This is in accordance with paragraph 8of the applied methodology. Validation team
confirms that identified alternatives are credible and complete.
3. Check each step in the procedure described in the
PDD to identify the baseline scenario against the
requirements of the methodology. (Note that if the
methodology requires use of tools, that is, such as
the tool for the demonstration and assessment of
additionality and the combined tool to identify the
baseline scenario and demonstrate additionality,
the guidance in the methodology shall supersede
it in the tool.)
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
The baseline was determined using the approach prescribed in paragraph 8 of the
applied methodology, benchmark analysis was conducted.
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OK
Conclusion
Validated situation
4. Based on financial expertise and local and
sectoral knowledge, determine whether all
scenarios that are considered by the project
participants and are supplementary to those
required by the methodology, are reasonable in
the context of the proposed CDM project activity
and that no reasonable alternative scenario has
been excluded. Use the table below for this
purpose:
Alternative
Scenario Ref.
Baseline scenario considered in the PDD is reasonable in the context of the
proposed CDM project activity.
Description in the PDD
Cross-checked with
1
Waste heat of the existing gas turbine is released
to atmosphere and steam sourced from the
existing coal fired boilers with higher utilisation.
2
Installation of new waste heat recovery equipment
with supplementary natural gas firing. (Project
activity)
5. Determine whether the baseline scenario
identified is reasonable by validating the
assumptions, calculations and rationales used, as
described in the PDD. It shall be ensured that
documents and sources referred to in the PDD
are correctly quoted and interpreted. Cross check
the information provided in the PDD with other
verifiable and credible sources, such as local
expert opinion. The table above may be used for
this purpose.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Validation team cross-checked this
alternative from the site visit, EIA
report, sectoral and host country
expertise.
Validation team cross-checked this
alternative from the site visit, EIA
report, sectoral and host country
expertise.
Validation Opinion
Validation team confirms from its sectoral expertise
that this is a credible alternative. This alternative is
in compliance with local regulations.
Validation team confirms from its sectoral expertise
that this is a credible alternative. This alternative is
in compliance with local regulations.
Validation team confirms that the baseline scenario is reasonable from the review
PDD, host country regulations, and project documentation. The baseline scenario is
also considered reasonable based on the host country and sectoral expertise of the
team.
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OK
OK
6. Is the identified baseline scenario in line with
regulatory or legal requirements and does it take
into account relevant national and/or sectoral
policies?
The identified baseline scenario is in line with regulatory and legal requirements, as
well as taking into account relevant national policies.
OK
7. Is this identification supported by official and/or
verifiable documents (for example, studies, web
pages, certificates, etc)?
The Validation team were able to interview official from the local environmental
agency to confirm the above alternatives.
OK
Validated situation
Conclusion
SECTION 6c. Algorithms and/or formulae used to determine emission reductions
1. Compare the equations and parameters in the
PDD to those in the selected approved
methodology and determine if they have been
correctly applied to calculate project emissions,
baseline emissions, leakage, and emission
reductions.
Confirm that adequate justification has been provided for
selection between different options.
The methodology applied for emission calculation is AMS-III.Q version 4.0.
Equations and parameters were compared with that in the PDD and the applied
methodology & Tool. Further, adequate justification has been provided in the PDD
for selecting between different options.
Justification and assessment is as follows.
Emission reductions
As provided in the methodology, emission reduction is calculated from the equation:
ERy = BEy – PEy – LEy
BEy:
PEy:
LEy:
ERy:
Baseline emissions in the year y (tCO2e/y)
Project emissions in the year y (tCO2e/y)
Leakage emissions in the year y (tCO2e/y)
Emission Reductions in the year y (tCO2e/y)
Baseline Emission:
The project activity recovers waste heat and produces only thermal energy.
Therefore, equation (4) in the paragraph 8(c) of AMS III.Q ver 4.0 has been applied
for baseline emission calculations. Further, it was confirmed during the site visit and
project documentation that no mechanical energy is generated by the project activity.
Therefore, the baseline emission calculation equation inline with the applied
methodology is:
LRQA Reference: ENQ/2607/11/IRE
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CAR 02
OK
Validated situation
BETher , y = f cap * f wcm * ∑∑ ( HG j , y + MG i,j,y,tur /η mech,tur ) * EFheat , j , y
i
j
Where:
BETher , y
HG j , y
Baseline emissions from displacing coal-based steam with wasteheat (WH) based steam during year y in tons of tCO2
Net quantity of heat (enthalpy) supplied to Wirajaya paper mill by the
Project during the year y in TJ.
This parameter is expressed as the difference in energy contents
between the total steam supplied by project activity to the recipient
plant and the total feed water into the boiler.
The distinction of total steam from steam generated only
from waste-heat is taken care of by parameter
described below;
f wcm
EFheat , j , y
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
The enthalpy of feed water to the boiler takes into account
the enthalpy of condensate returning into the boiler and any
other waste heat recovery including economiser, blow down
heat recovery. Within the project activity, no additional fossil
fuel apart from natural gas to the project burner is
added/fired to pre-heat the feed water.
Fraction of total heat generated by the project activity using waste
energy.
The HRSG uses both waste heat and supplement natural gas
th
burning. This factor is 1 as per the ruling given by the 35 meeting of
the SSC_WG (in response to clarification request SSC_579
http://cdm.unfccc.int/methodologies/SSCmethodologies/clarifications
/40482).
The CO2 emission factor of the coal boiler that would have supplied
the paper mill in the absence of the project activity, expressed in
tCO2/TJ
Calculation of this parameter is to be done using Error! Reference
source not found. described (below).
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Conclusion
Validated situation
f cap
MG i,j,y,tur
η mech,tur
Capping factor to exclude increased waste energy utilization in the
project year y due to increased level of activity of the plant, relative
to the level of activity in the base years before project start. The
ratio is 1 if the waste energy generated in project year y is same or
less than that generated in base years. fcap shall be estimated
according to the corresponding section of ACM0012.
Mechanical energy generated and supplied to the recipient j, which
in the absence of the project activity would receive power from a
steam turbine i, driven by steam generated in a fossil fuel boiler (TJ)
The efficiency of the baseline equipment (steam turbine) that would
provide mechanical power in the absence of the project activity
Validation team confirmed from the site visit that the above equation has been
correctly applied. Further, each of the above parameters has been appropriately
justified.
The net quantity of heat supplied is based on the post-expansion case where the
steam demand will be 50TPH, multiplied by average operational days of plant based
on historical data. The net quantity of heat supplied estimated as.
Fraction of total energy generated using waste gas, fWCM, was considered as 1 based
on SSC_579 (Ref:
http://cdm.unfccc.int/methodologies/SSCmethodologies/clarifications/40482).
No mechanical energy was used in the project activity. This was confirmed from the
project documentation and site visit.
Parameters, emission factor of steam boilers and capping factors are calculated
based on the equations described below.
CO2 emission factor for coal boilers
The emission factor associated with generating steam in the baseline coal boiler is
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calculated using the following equation:
EFheat , j , y = ∑ wsi , j
i
EFCO 2,i , j
η EP ,i , j
Where:
EFCO 2,i , j
CO2 emission factor of coal in tCO2/TJ
η EP ,i , j
Efficiency of the baseline twin coal boilers. This value is taken as
option (c) of the methodology i.e. 100% so as to be conservative.
wsi , j
Fraction of total heat that is used by the paper mill in the absence of
the project activity would have been supplied by the coal boilers.
This value is 100% on consideration that, in absence of project
activity, all steam to be used by all paper mills, would have been
generated using the existing twin coal boilers.
Emission factor of coal was estimated based on the IPCC 2006 Guidelines. Emission
factor of bituminous coal was used as it was the closest based on the NCV
measurement data. The emission factor was sourced from table 2.2 of chapter 2:
Stationary Combustion, Volume 2 Energy.
Efficiency of the coal boiler system has been conservatively considered as 100% as
a default value based on option (c) of the applied methodology.
Further, during the site visit, it was noted that in the baseline scenario, the steam
was generated only from coal boilers and there was no other source available at site.
Therefore, fraction of total heat used by the paper mill in absence of project activity
will be 100% from coal based boilers.
Capping factor:
In accordance with the applied methodology, the guidance on capping factor has
been sourced from the methodology ACM0012, Version 04.0.0. This version is the
latest at the time of preparation of this report.
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Method-1 cannot be used as the data for operation of full plant, both the existing and
new line, is not available for last 3 years.
Method-2 cannot be applied as quantity of waste heat cannot be measured at the
exhaust and before the HRSG as it is integrated system. Further, the quantity of
waste gas cannot be measured at the exhaust (chimney) of the HRSG system due to
high turbulence and asymmetric flow. High turbulence and asymmetric flow remains
for the aspect ratio and expansion ratio.
Therefore, method-3 has been applied for the project activity.
The fcap is the ratio of maximum energy recovered (MER) by the waste heat recovery
unit to the actual energy recovered under the project activity.
The calculations are:
f cap =
QOE , BL
QOE , y
Where:
QOE,BL
Output/intermediate energy that can be produced (TJ), to be
determined on the basis of maximum energy that could be recovered
from the WECM (MER), which would have been released (or WECM
would have been flared or energy content of WECM would have
been wasted) in the absence of CDM project activity.
QOE,y
Quantity of actual output/intermediate energy generated during year
y (TJ)
The capping factor will be determined based on the maximum energy recoverable
sourced from the manufacturer’s specification. This approach is in accordance with
the case 1 of applied methodology. The maximum energy that could be recovered
(MER) from the waste gas is calculated by deducting energy from the fossil fuel from
total energy recovered. Total energy recovered or useful energy recovered is the
useful energy gained in the process to produce steam. The energy from the fossil
fuel is the product of quantity of fossil fuel, its NCV, efficiency of the system, i.e.
HRSG and efficiency of burner.
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Calculation of QOE,y
PP has calculated Actual energy recovered based on the difference of actual energy
recovered by the HRSG in generating steam to energy sourced from supplementary
natural gas. The detailed calculations are as follows:
QOE,y = HGj,y – (NCVNG × FCNG × ηHRSG × ηNG-Burner)
Where:
QWCM,BL
Average quantity of WECM released (or flared or wasted) in
atmosphere prior to the start of the project activity – as per
manufacturer's specifications (this is data from simulations as
calculated by the manufacturer).
ηHRSG
ηNG-Burner
HGj,y
Efficiency of the HRSG as specified by manufacturer.
Efficiency of the Natural Gas Burner as specified by manufacturer.
Net quantity of heat (total steam energy) supplied to Wirajaya paper
mill by the Project during the year y in TJ. Monitored parameter as
described in section B.7.1.
FCNG,y
Amount of natural gas consumed by the HRSG during the year y.
Monitored parameter as described in section B.7.1.
NCVNG
Net calorific value of Natural Gas used in HRSG-burner. Monitored
parameter as described in section B.7.1.
Determination of QOE,BL
QOE,BL is based on the designed parameters, reflects to maximum energy that could
have been recovered. It is derived based on equation above.
The input values for QOE,BL were validated as below:
HGj,y or quantity of heat was estimated as the product of the average steam output,
average working hours, and enthalpy gained during steam production.
The average steam output was validated from the capacity of the waste heat
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recovery boiler, i.e. 50 TPH.
Average working hours in a year was validated to be 7656 hours from the sectoral
expertise of the team.
Enthalpy gained was calculated as difference in enthalpy of output steam and feed
water.
o
The feed water will be at temperature of 105 C with enthalpy of 440.19 kJ/kg. The
o
process steam will be at 194 C and 13 bar (atmosphere) with enthalpy of 2791.93
kJ/kg.
The quantity of heat was estimated to be about 900.24 TJ/yr.
The parameter FCNG or amount of fossil fuel (natural gas) required in the waste heat
recovery boiler was estimated as the different in enthalpy of waste gas after the
turbine and that required for the boiler.
The enthalpy of exhaust air from turbine was validated to be 558.74kJ/kg of quantity
165800Kg/hr. This was confirmed from the heat balance presented by the PP. This
value was cross-verified from the data sheet used for design of waste heat recovery
boiler.
Enthalpy of air intake to WHRB was validated to be 875.66kJ/kg of quantity
166951kg/hr. This was confirmed from the data sheet used for design of waste heat
recovery boiler.
Quantity of natural gas was estimated from the heat balance as 1439kg/hr or
11028295 kg/yr.
QOE,BL = HGj,BL – (NCVNG × FCNG × ηHRSG × ηNG-Burner)
6
= 900.24 – (37.59 × 11,017,295 × 81% × 99%/10 )
= 567.8 TJ/yr
The net quantity of heat available, and amount of natural gas fired was estimated
based on heat and mass balance, the efficiency of HRSG and burner was based on
manufacturer’s specification, and NCV of natural gas was based on the specification
of the gas supplier.
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Validation team confirms that the approach used for capping factor is appropriate
and inline with the applied methodology.
Capping factor is considered 1 for ex-ante emission reduction estimation.
Validation of heat balance over gas turbine:
Mass and Heat balance was done when turbine is operating at maximum
instantaneous capacity using simulation software of technology supplier.
Air intake to the turbine was validated to be 162417.6 Kg/hr
Team confirmed the suitability of air intake from the result of simulation software
Enthalpy of inlet air was validated to be 71.74 kJ/kg
o
Team confirmed the suitability of enthalpy air at ambient temperature of 30 C and
relative humidity of 60%. Team confirmed from its host country expertise that these
are standard conditions in Indonesia. Team further confirmed from its sectoral
expertise that enthalpy of air has been correctly calculated.
Fuel intake (natural gas) was validated to be 3382.2 kg/hr
Team confirmed the suitability of fuel intake from the simulation.
NCV of natural gas was validated to be 37.59 MJ/kg
Team confirmed the NCV from actual measurement results of natural gas. Team
further confirmed the suitability of NCV from its sectoral expertise
Electricity output was validated to be 12.124MW
Team confirmed the suitability of electrical energy output from the results of
simulation software.
Useful energy output was validated to be 46152.48 MJ/kg
Team confirmed the suitability of useful energy output from the result of simulation
software.
Team confirmed that this is a calculated value for electrical energy output by
adjusting to efficiency factors of generator, and turbine deviation from ideal system,
i.e. isentropic system.
Team confirmed from its sectoral expertise that 98% generator efficiency and
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96.50% as deviation of real turbine from ideal system is suitable.
Enthalpy of exhaust gas was validated to be 558.74 kJ/kg
Team confirmed the suitability of enthalpy of output energy from the result of
simulation software.
Team also checked and confirmed that same value was used for designing of waste
heat recovery system.
Quantity of exhaust gas was validated to be 165800 kg/hr
Team confirmed the suitability of quantity of exhaust gas from the result of simulation
software.
Team also checked and confirmed that same value was used for designing of waste
heat recovery system.
The validation team was able to confirm that the above equations are correctly
applied for the baseline emission of project activity.
Project Emission:
Based on the methodology, the project emissions include emissions from
combustion of supplementary fuel, i.e. natural gas. The emissions from
supplementary fuel are calculated using “Tool to calculate project or leakage CO2
emissions from fossil fuel combustion” (Version 02). PP has used option B by using
CO2 emission factor of the fossil fuel. The calculation for project emission is as
follows:
PE FC , j , y = ∑ FC i , j , x × NCVi , y × EFCO 2,i , y
i
Where:
PEFC,j,y
FCi,j,y
COEFi
CO2 emissions from fossil fuel combustion in process j during the year
y (tCO2/yr);
Quantity of fuel type i combusted in process j during the year y (mass
or volume unit/yr)
CO2 emission coefficient of fuel type i in year y (tCO2/mass or volume
unit)
,y
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NCVi,y
EFCO2,i
Net calorific value of the fuel type i in year y (GJ/mass or volume unit)
Weighted average CO2 emission factor of fuel type i in year y
(tCO2/GJ)
,y
i
Fuel types combusted in process j during the year y. In this case,
Natural Gas
The validation team was able to confirm that the above equation is correctly applied
for the project emission of project activity.
Quantity of natural gas is estimated based on energy balance and NCV of the
natural gas has been sourced from the supplier invoices. These parameters will be
monitored during monitoring.
Specific enthalpy of flue gas before firing was estimated from the heat balance
provided by the turbine equipment manufacturer. These results are based on
simulation software. The results from the software shows the exhaust temperature of
o
514 C having specific enthalpy of 558.74kJ/kg and exhaust gas quantity of about
165,800kg/hr.
Detailed validation is provided in the heat balance section above.
Specific enthalpy of flue gas after firing was confirmed from the heat balance
provided by the waste heat recovery boiler manufacturer. These results were the part
of boiler design for the designed output capacity of 50TPH steam. The results by the
o
boiler manufacturer are: temperature of 757 C with specific enthalpy of 875.66kJ/kg,
and quantity of 166,951 kg/hr.
The emission factor for Natural Gas has been sourced from the IPCC 2006 national
greenhouse gas inventories for stationary combustion. Validation team confirms from
its host country and sectoral expertise that manufacturer does not provide emission
factor value.
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Conclusion
Validated situation
Leakage:
The validation confirmed from the review of EPC contract, interview and site visit that
there is no equipment transferred from another activity for this project, therefore,
leakage emissions are considered nil in accordance with the paragraph 15 of the
applied methodology.
CAR 02 was raised as use of different options prescribed by the applied
methodology was not described. PP has revised the PDD describing the options
used for emission reduction calculations. The resolution is detailed in the findings
section of this protocol.
2. Verify the justification given in the PDD for the
choice of data and parameters used in the
equations to determine estimated emission
reductions.
If data and parameters will not be monitored throughout
the crediting period and will remain fixed, assess that all
data sources and assumptions are appropriate and
calculations are correct, applicable to the proposed CDM
project activity and will result in a conservative estimate
of the emission reductions.
If data and parameters will be monitored on
implementation and hence become available only after
validation of the project activity, confirm that the
estimates provided in the PDD for these data and
parameters are reasonable.
List all data and parameters provided in the PDD in the
tables in next column.
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Data/Parameter title: EFCO2,coal
Title in line with methodology?
Fixed throughout the crediting period?
Data unit correctly expressed?
Appropriate description of parameter?
Source clearly referenced?
Value provided is considered reasonable?
Has this value been verified?
Choice of data correctly justified?
Measurement method correctly described?
Comments
Yes
No, monitored ex-post
Yes
Yes
Yes
2006 IPCC Guidelines for
National Greenhouse Gas
Inventories Vol.2 Energy.
Lower value of 95%
confidence interval for ‘Other
bituminous coal’ was
considered.
Yes
Yes
Yes
Yes
Data/Parameter title: HGj,y
Title in line with methodology?
Fixed throughout the crediting period?
Data unit correctly expressed?
Appropriate description of parameter?
Source clearly referenced?
Comments
Yes
No, monitored ex-post
Yes
Yes
Yes
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Conclusion
Validated situation
Value provided is considered reasonable?
Has this value been verified?
Choice of data correctly justified?
Measurement method correctly described?
Data/Parameter title: NCVNG
Title in line with methodology?
Fixed throughout the crediting period?
Data unit correctly expressed?
Appropriate description of parameter?
Source clearly referenced?
Value provided is considered reasonable?
Has this value been verified?
Choice of data correctly justified?
Measurement method correctly described?
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Total enthalpy is the
difference of enthalpy of
steam and feed water.
Validation team confirmed
that steam enthalpy was
correctly determined based
on the characteristics of the
steam and standard steam
table.
Yes
Yes
Yes
Yes
Comments
Yes
No, monitored ex-post
Yes
Yes
Yes
Based on invoice from NG’s
supplier.
The NCV value was correctly
converted to standard units.
Yes
Yes
Yes
Yes
Conclusion
Validated situation
Data/Parameter title:
Title in line with methodology?
Fixed throughout the crediting period?
Data unit correctly expressed?
Appropriate description of parameter?
Source clearly referenced?
Value provided is considered reasonable?
Has this value been verified?
Choice of data correctly justified?
Measurement method correctly described?
Data/Parameter title: EFCO2,NG
Title in line with methodology?
Fixed throughout the crediting period?
Data unit correctly expressed?
Appropriate description of parameter?
Source clearly referenced?
Value provided is considered reasonable?
Has this value been verified?
Choice of data correctly justified?
Measurement method correctly described?
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Yes
No, monitored ex-post
Yes
Yes
Yes; Ex-ante value sourced
from mass and energy
balance conducted by the
supplier of waste heat
recovery boiler.
Yes
Yes
Yes
Yes
Comments
Yes
No, monitored ex-post
Yes
Yes
Yes
2006 IPCC Guidelines for
National Greenhouse Gas
Inventories Vol.2 Energy
Yes
Yes
Yes
Yes
Conclusion
Validated situation
Data/Parameter title: QOE,y
Title in line with methodology?
Fixed throughout the crediting period?
Data unit correctly expressed?
Appropriate description of parameter?
Source clearly referenced?
Value provided is considered reasonable?
Has this value been verified?
Choice of data correctly justified?
Measurement method correctly described?
Data/Parameter title: QOE,BL
Title in line with methodology?
Fixed throughout the crediting period?
Data unit correctly expressed?
Appropriate description of parameter?
Source clearly referenced?
Value provided is considered reasonable?
Has this value been verified?
Choice of data correctly justified?
Measurement method correctly described?
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Comments
Yes
No, monitored ex-post
Yes
Yes
Yes
Based on monitored useful
energy (steam), quantity and
NCV of natural gas used.
Yes
Yes
Yes
Yes
Comments
Yes
Yes, fixed ex-ante
Yes
Yes
Yes
Based on design
specification of HRSG using
equations above.
Yes
Yes
Yes
N/A
Conclusion
Validated situation
Data/Parameter title:
η EP ,i , j
Title in line with methodology?
Fixed throughout the crediting period?
Data unit correctly expressed?
Appropriate description of parameter?
Source clearly referenced?
Value provided is considered reasonable?
Has this value been verified?
Choice of data correctly justified?
Measurement method correctly described?
Data/Parameter title: wsi,j
Title in line with methodology?
Fixed throughout the crediting period?
Data unit correctly expressed?
Appropriate description of parameter?
Source clearly referenced?
Value provided is considered reasonable?
Has this value been verified?
Choice of data correctly justified?
Measurement method correctly described?
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Comments
Yes
Yes, fixed ex-ante
Yes
Yes
Yes
100% baseline efficiency was
used based on option (c) of
the applied methodology.
Yes
Yes
Yes
N/A
Comments
Yes
Yes, fixed ex-ante
Yes
Yes
Yes
Based on the manufacturing
plant. No other source of
steam generation other than
existing coal based boilers
was identified during the site
visit.
Yes
Yes
Yes
NA
Validated situation
Conclusion
3. Confirm that all assumptions and data used by
PPs are listed in the PDD including their
references and sources, and that the
documentation used as the basis for these
assumptions and source of data is correctly
quoted and interpreted in the PDD.
All assumption and data used by PP have been listed in the PDD including the
references and sources. The team confirmed this has been correctly quoted and
interpreted.
OK
4. Confirm that all estimates of the baseline
emissions can be replicated using the data and
parameter values provided in the PDD.
All estimation of the baseline emissions are also provided in the spreadsheet format
therefore can be replicated.
OK
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SECTION 7. Additionality of a project activity
1. Does the PDD clearly describe how the proposed
CDM project activity is additional?
Yes
No
The PDD clearly describes the additionality of the project; that NPV of the project is
negative.
OK
2. List the documents and tools provided by the
CDM Executive Board used to demonstrate the
additionality
Guidelines on the demonstration of additionality of small-scale project activities,
Version 09.0
OK
Additionality for small-scale project activities
Determine whether the proposed project activity is additional in accordance with CDM requirements applicable for small-scale project activities: Attachment A to
Appendix B of 4/CMP 1 annex II and “non binding best practice examples to demonstrate additionality for SSC project activities”
3. Describe and assess the relevant criteria for the
automatic additionality of the following cases:
a) Type I project activities up to 5 MW that
employ renewable energy as their primary
technology,
b) Type II energy efficiency project activities
that aim to achieve energy savings at a scale
of no more than 20 GWh per year,
c) Type III project activities that aim to achieve
emissions reductions at a scale of no more
than 20 ktCO2e per year.
Not applicable.
Automatic additionality has not been used
Validated situation
-
Conclusion
SECTION 7a. Prior consideration of the clean development mechanism
1. Does the PDD clearly indicate the start date of the
project activity in format: dd/mm/yyyy, and is it in
line with the Glossary of CDM Terms?
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Yes
No
The starting date of the project is 01/08/2011 which is the date for signing of EPC
contract with PT. Indoturbine.
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Conclusion
Validated situation
If the PDD was published for Global Stakeholder Consultation process after the start date, check that the CDM benefits were considered necessary in the decision
to undertake the project activity as a CDM project, following the below queries.
2. For a project activity with a start date on or after
the 02 August 2008, confirm that the PPs have
informed the host party DNA and the UNFCCC
secretariat in writing of their intention to seek
CDM Status.
PP has submitted the notification to the DNA of Indonesia and UNFCCC secretariat
on 20/07/2011. Validation team confirmed the notification from the list of notifications
available at UNFCCC website, copy of email sent to the DNA and acknowledgement
received from the DNA, dated: 25/07/2011. The notification was made within 180
days of the start date of the project activity.
OK
N/A
-
If such a notification has not been provided by the PPs
within 180 days of the project activity start date, determine
that the CDM was not seriously considered in the decision
to implement the project activity.
For a project activity with a start date before 02 August 2008
3. Check the following requirements through
document reviews to assess the PPs prior
consideration of the CDM:
(a) Evidence that must indicate that awareness
of the CDM before the project activity start
date, and that the benefits of the CDM were
a decisive factor in the decision to proceed
with the project.
(b) Reliable evidence from project participants
that must indicate that continuing and real
actions were taken to secure CDM status for
the project in parallel with its
implementation.
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4. Describe the process for cross-checking the
evidence.
The assessment of real and continuing actions should
focus on real documented evidence, including an
assessment of the authenticity of the evidence, that is,
letters, email exchanges and other documented
communications. These shall be considered as evidence
only after assessing the reliability and authenticity of them,
inter alia through cross-checking (for example, interviews)
N/A
-
5. The time gap between the documented evidence
of prior CDM consideration and continuing and
real actions shall be within the following period:
(a) Less than two years: continuing and real
actions were taken to secure CDM status for
the project activity;
(b) Greater than two years and less than three
years: justify any positive or negative validation
opinion based on the context of the evidence
and information assessed;
(c) Greater than three years: continuing and real
actions were not taken.
N/A
-
6. If authentic evidence to support the serious prior
consideration of the CDM as indicated above is
not available, determine that the CDM was not
considered in the decision to implement the
project activity
N/A
-
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Conclusion
SECTION 7b. Identification of alternatives
1. Does the PDD identify credible alternatives to the
project activity, to determine the most realistic
baseline scenario?
Assess this list of alternatives and ensure that:
(a) The list of alternatives includes as one of the options
that the project activity is undertaken without being
registered as a proposed CDM project activity.
(b) The list contains all plausible alternatives considered
to be viable means of supplying the outputs or
services that are to be supplied by the proposed CDM
project activity.
(c) The alternatives comply with all applicable and
enforced legislation.
LIST OF ALTERNATIVES
No
Description in the PDD
OK
Describe why it is credible and
complete
1
Release of waste gas in
atmosphere and steam
sourced from the existing
coal boilers with higher
utilisation
This alternative is scenario existing
prior to the project activity. Based on
the host country expertise of the team it
was confirmed that steam generation
using existing coal fired boilers is in full
compliance with host country rules.
2
Installation of waste heat
recovery boilers with natural
gas as supplementary fuel
without being registered as
CDM project activity
This is a project activity without being
registered as proposed CDM project
activity. This is in compliance with all
the legal regulations.
Validation team confirms from its host country and sectoral expertise that above list
contains all the plausible alternatives to the project activity.
Validated situation
SECTION 7c. Investment analysis
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Conclusion
1. Verify the accuracy of financial calculations
carried out for the investment analysis:
(a) Conduct a thorough assessment of all
parameters and assumptions used in
calculating the relevant financial indicator,
and determine the accuracy and
suitability of these parameters.
(b) Cross-check the parameters against
third-party or publicly available sources,
such as invoices or price indices.
(c) Review feasibility reports, public
announcements and annual financial
reports related to the proposed CDM
project activity and the project
participants.
All the relevant parameters are sourced from quotation, coal price invoice, gas price invoice and
local taxation laws. Validation team confirmed these parameters from the documentation, host
country and sectoral expertise of the team.
The investment analysis has been applied for the technical lifetime of the project.
Depreciation has not been accounted in cash-flow calculations.
Input values sourced from quotation, invoices were available at the time of investment decision.
All the investment analysis spreadsheets are in readable formats and all relevant cells are
viewable and unprotected.
The portion of investment costs funded by equity has been considered for calculation of equity
NPV.
For cash flow on real terms, PP has correctly applied default values in the Appendix of the
Guideline on the assessment of investment analysis, Version 05.
CL 05 was raised as input values were not adequately justified. The resolution is detailed in the
findings section of this protocol.
CL 05
OK
2. Assess the correctness of computations
carried out and documented by the project
participants
NPV based on equity cash flows in real terms is USD -1.35 Million. Based on the host country
expertise and from the review of investment analysis spreadsheet, validation team confirms that
computation has been correctly carried out and documented.
OK
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3. Assess the sensitivity analysis by the project
participants to determine under what
conditions variations in the result would occur,
and the likelihood of these conditions.
The revised PDD presents the sensitivity over following parameters:
• CAPEX
• Coal Price
• Amount of Coal required in the Baseline
• Gas Price
• Amount of Gas required in the Project
Investment analysis has been reviewed to confirm parameters used for sensitivity analysis as
below:
Values in Million USD in table below
Parameters
10.00%
-3.26
Threshold
Gas Price
-10%
0.56
Coal Price
-3.48
0.78
6.35%
CAPEX
-1.08
-1.62
-49.77%
O&M Costs
Gas quantity
required
Coal quantity
required
-1.27
-1.44
NA
0.56
-3.26
-3.48
0.78
-7.085%
-7.085%
6.35%
1. Project CAPEX
Estimated total capital expenditure required for the Project Activity is mostly comprised
of the costs of the HRSG and its installation. This cost is now agreed and finalised, as
per signed contracts with the EPC/ HRSG provider. No decrease in this cost is possible.
2. Coal price
The estimated price for coal used in the investment analysis USD95.8/tonne. The coal
price was confirmed based on the actual invoices of the existing coal based boiler.
Change in coal price during the project operational period is influenced by inflation and
need not be considered for cash flow in real terms.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 63 of 92
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Conclusion
OK
Conclusion
Validated situation
3. Amount of coal required in the Baseline
For estimation of amount of coal required was based on the designed efficiency of the
coal based boiler. The designed efficiency was used for estimation of both coal and
natural gas requirement. Higher costs due to lower actual efficiency of the gas used in
HRSG will be compensated by lower actual efficiency of coal boilers. Therefore,
decrease in savings of coal is not envisaged.
4. Gas price
Gas prices in Indonesia are regulated by government and not by market. Therefore,
there is a lag in price change by inflation in gas prices. The gas prices are determined
based on the actual gas price and expected increase envisaged at the time of
investment decision.
An expected increase of 30% in the actual value was considered conservative when
compared to increase of 50% or above elsewhere in Indonesia. The actual increase in
gas price was confirmed from the letter given by gas supplier to the PP dated:
08/05/2012, where gas price was 17% higher than that considered in the investment
analysis.
5. Amount of natural gas required
Amount of natural gas was based on the designed efficiency. The actual efficiency will
be lower than the designed efficiency. However, increased cost of natural gas will be
compensated by lower actual efficiency of the coal based boilers. Comparison of the
design efficiency of investment analysis was considered appropriate.
6. O&M Cost
NPV does not turn positive even if O&M cost is considered nil.
Use the table below to list all the inputs to the investment analysis and to describe how each parameter has been validated:
Parameter/input
Capacity of steam
Symbol/Unit
Value
ton per hour
50
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Source
EIA report
Means of validation
Validation team confirmed the designed capacity
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Conclusion
OK
output
Capital cost of HRSG
HRSG contract agreement
with PT. Indoturbine
USD
3,800,000
Total investment cost
USD
USD/yr
Source of data has been cross check from the
quotation from the supplier from EPC contract of
HRSG dated: 01/08/2011, and based on sectoral
expertise for minor erection and commissioning
cost, bank fee and statutory fee.
OK
Historical record
The Validation Team confirmed that the O & M
from the cost of quote insurance and the Sector
expert confirmed that the O&M cost for HRSG
and back up coal boiler 2.5 % of Capex is
appropriate.
Validation team confirmed the gas price from the
actual receipts for September 2011 dated:
04/10/2011 available at the time of investment
decision and news article on expected gas price
increase.
Validation team also confirmed the suitability of
gas price from the actual prices available during
validation from PGN communication Ref:
069900.S/PP.01.01/SBU1/2012.
Validation Team confirmed the price from the PO
price of coal for a period from July 2009 to August
2011. Coal price, unlike natural gas price,
fluctuates on daily basis as it is market
determined.
The figure is conservative that has considering
about 2 month of stop within one year.
Operational hours were also confirmed during the
site visit based on historical operational data from
November 2009 to December 2010.
OK
181,500
Gas price
Gas receipts
USD/MMBTU
6.897
Coal price
Coal receipts
USD/ton
95.8
Operating hours per
year
Assumption
hours
7,656
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
OK
Calculated
4,236,500
Operating and
maintenance cost
from the EIA report. Further, suitability of the
capacity was confirmed from the review of HRSG
contract, specification of HRSG and site visit.
Validation team confirmed the offer of supplier
capital cost from the review of EPC contract
dated: 01/08/2011, capital finance document from
Caterpillar dated: 08/09/2011.
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OK
OK
OK
HRSG residual value
10% of original equipment
cost
US$
380,000
Project life
Turbine Manual
years
17
Loan interest rate
Assumption
%
6
Inflation projection till
2016 for USD
IMF World Economic
Outlook
%
1.04
Inflation on real basis
Calculated
%
4.96
Bank loan
2
US$
Assumption
2,118,250
Validation team confirmed it from its sectoral
expertise.
Validation team confirmed that the value is
conservative, considering remaining life time of
HRSG. Validation team also confirmed the
residual value from Government Regulation on
Tax No.62/2008 which states 10% of equipment
cost.
Validation team confirmed the remaining life time
based on the lifetime prescribed by the equipment
manufacturer in section 8.5.3.3 of chapter 8 ‘Risk
assessment’ turbine manual dated: 23/03/2009,
which states 20 years and actual operation time of
3 years confirmed from the start of Wira paper
mill.
Validation team confirmed the suitability of
interest rate from the review of USD denominator
loans from the review of section I.27 ‘Interest rate
of US Dollar Loans by Group of banks’ for
Indonesian financial statistics published by Bank
2
of Indonesia .
Validation team confirmed the suitability of
forecasted inflation rate from the review of IMF
World Economic outlook database September
2011 for US.
Validation team confirmed from the review of
investment analysis spreadsheet that the
calculation of real interest rate based on the
Fisher equation has been correctly applied.
Validation team confirmed the suitability of
funding sourced from short term finance offered
by Caterpillar dated: 08/09/2011.
http://www.bi.go.id/web/en/Statistik/Statistik+Ekonomi+dan+Keuangan+Indonesia/Versi+HTML/Sektor+Moneter/Sektor+Moneter.htm#
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 66 of 92
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OK
OK
OK
OK
OK
OK
Validated situation
4. Confirm the suitability of any benchmark
applied in the investment analysis:
(a) Determine whether the type of
benchmark applied is suitable for the type
of financial indicator presented.
(b) Ensure that any risk premiums applied in
determining the benchmark reflect the
risks associated with the project type or
activity.
(c) Determine whether it is reasonable to
assume that no investment would be
made at a rate of return lower than the
benchmark by, for example, assessing
previous investment decisions by the
project participants involved and
determining whether the same
benchmark has been applied or if there
are verifiable circumstances that have led
to a change in the benchmark.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
PP has calculated NPV based on equity cashflow in real terms. The default value mentioned in
the Appendix is a suitable discount rate (benchmark) for expected return on equity after tax on
real terms. Therefore, validation team confirms that suitability of the benchmark with the type of
financial indicator.
The PP has applied default value for Group 2 for Indonesia. Group 2 includes sectoral scope 4
‘Manufacturing industries’ which is relevant as the project can be invested by the PP.
Validation team confirms from the interview of the PP that no similar investment was made in
waste heat recovery by the PP prior to the project activity.
Date 04/12/2012
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Conclusion
OK
Validated situation
2.
If the project participants rely on values
from a Feasibility Study Report (FSR)
approved by any national authority, the team
is required to ensure that:
(a) The FSR has been the basis of the
decision to proceed with the investment in
the project, that is, that the period of time
between the finalization of the FSR and
the investment decision is sufficiently
short for the DOE to confirm that it is
unlikely in the context of the underlying
project activity that the input values would
have materially changed.
(b) The values used in the PDD and
associated annexes are fully consistent
with the FSR and, where inconsistencies
occur, the DOE should validate the
appropriateness of the values.
(c) On the basis of its specific local and
sectoral expertise, confirmation is
provided, by cross-checking or other
appropriate manner, that the input values
from the FSR are valid and applicable at
the time of the investment decision.
Conclusion
Not applicable. No FSR was prepared for this project activity.
OK
Use the table below to cross-check input
values and describe here the results of the
comparison.
Comparison to similar registered project in the region: N/A since there is no similar project in the host country
CDM Ref
Investment
cost
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Tariff
O&M cost
Date 04/12/2012
Capacity
Output
Investment
cost per
output
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Load factor
O&M relative
to
investment
O&M per
output
Validated situation
Conclusion
N/A
-
SECTION 7d. Barrier analysis
1. Does the PDD demonstrate that the proposed
project activity faces barriers that prevent its
implementation and do not prevent at least the
implementation of one of the alternatives?
Provide here an overall determination of the
credibility of the barrier analysis.
Use the below table to list each barrier considered
in the PDD and to describe how the team undertake
their validation.
Barriers are issues in project implementation that could prevent a potential investor from pursuing the implementation of the proposed project activity. The identified
barriers are only sufficient grounds for demonstration of additionality if they would prevent potential project proponents from carrying out the proposed project activity
undertaken without being registered as a CDM project activity.
Type of
Barrier
Determination
Description in the PDD
Barriers are real
Prevent implementation
of PA
Access to
finance
Risks related
barriers
Technological
Due to
prevailing
practice
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 69 of 92
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Do not prevent
implementation of BL
Conclusion
Other
First of its kind
Conclusion
Validated situation
SECTION 7e. Common practice analysis
1. Describe how the geographical scope of the common
practice analysis has been validated.
Assess whether the geographical scope (for example,
the defined region) of the common practice analysis is
appropriate for the assessment of common practice
related to the project activity’s technology or industry
type.
2. Determine to what extent similar and operational
projects (for example, using similar technology or
practice), other than CDM project activities, have been
undertaken in the defined region.
3. If similar and operational projects, other than CDM
project activities, are already widely observed and
commonly carried out in the defined region, assess
whether there are essential distinctions between the
proposed CDM project activity and the other similar
activities.
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Not applicable.
The project is categorised as small scale project activity and hence, common
practice analysis is not required.
-
NA
-
NA
-
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Validated situation
Conclusion
SECTION 8. Monitoring plan
1. Compliance of the monitoring plan with the approved methodology. Confirm that the MP contains all the necessary parameters and that they are monitored in
accordance to the approve Methodology using the following table:
Parameter
HGj,y
Monitoring Methodology
description
Unit: TJ/year
Description: Net quantity
of heat (enthalpy) supplied
to the recipient plant j by
the project activity during
the year y
Source of data: measured
Value: measured data
Description of
measurement method: QA/QC procedures: -
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
PDD description
Unit: TJ/hr
Description: Net quantity
of heat (enthalpy) provided
by the project
Source of Data:
1. (Enthalpy = Temperature
& pressure) of steam
supplied to recipient plant.
2. (Enthalpy = Temperature
& pressure) of feed water.
3. Quantity of steam.
Value of Data: 900.24
Brief description of
measurements methods
and procedures to be
applied:
Standard thermometer
used for temperature
measurement. To be
measured continuously and
aggregated into average
hourly measurements.
Standard pressure gauges
used for pressure
measurement. To be
measured continuously and
aggregated into average
Date 04/12/2012
Validated situation
The unit and description of parameter are not as according
to the methodology, however the parameter title is not
according to the methodology, as mentioned in Section 5.c
of this validation protocol.
Further, source of data and value are by measurement and
not specified in the methodology.
Description of measurement method and QA/QC procedure
are also not specified in the methodology thus the PDD
description is considered appropriate.
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Conclusion
OK
hourly measurements.
Flow meter used for
quantity of steam. To be
measured continuously and
aggregated into total hourly
measurements.
QA/QC procedures to be
applied: Measuring
equipment shall be
calibrated annually in
accordance with industry
standards or
manufacturer’s instructions.
During the time of
calibration and
maintenance, alternative
equipment shall be used for
monitoring.
Data unit: GJ per mass or
volume unit
Description: Weighted
average net calorific value
of fuel type i in year y
NCVNG
Source of data: The
following data sources may
be used if the relevant
conditiions apply:
a) Values provided by the
fuel supplier in invoices; b)
Measurements by the
project participants; c)
Regional or national default
values; d) IPCC default
values at the upper limit of
the uncertainty at a 95%
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Unit: MJ/kg
Description: Net calorific
value of Natural Gas used
in HRSG-burner
Source of Data:
Natural gas supplier's
invoice, periodic NG
sampling sheet from
supplier.
Value of Data: 37.5905
Brief description of
measurements methods
and procedures to be
applied:
Natural gas specification
sheets to be requested
regularly from PGN
(National Gas Supplier) –
recorded as and when PGN
Date 04/12/2012
The unit and description of parameter are according to the
methodology. Further, source of data, value, description of
measurement method and QA/QC procedure are not
specified in the methodology thus the PDD description is
considered appropriate.
The validation team confirmed IPCC data shall be used for
the NCV of natural gas.
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OK
confiende inverval as
provided in Table 1.2 of
chapter 1 of Vol. 2 (Energy)
of the 2006 IPCC
Guidelines on National
GHG Inventories
Measurement procedure
(if any): For a) and b):
Measurements should be
undertaken in line with
national or international fuel
standards
Monitoring frequency: For
a) and b): The NCV should
be obtained for each fuel
delivery, from which
weighted average annual
values should be calculated
For c): Review
appropriateness of the
values annually; For d):
Any future revision of the
IPCC Guidelines should be
taken into account
provides specification
sheets. Gas invoice GCV
value to be recorded
monthly or as and when the
invoice is billed.
QA/QC procedures to be
applied:
Verify within the uncertainty
range of the IPCC default
values as provided in Table
1.2, Vol. 2 of the 2006
IPCC Guidelines. If the
values fall below this range
collect additional
information from the testing
laboratory to justify the
outcome or conduct
additional measurements.
The laboratories should
have ISO17025
accreditation or justify that
they can comply with
similar quality standards.
QA/QC procedures:
Verify if the values under
a), b) and c) are within the
uncertainty range of the
IPCC default values as
provided in Table 1.2, Vol.
2 of the 2006 IPCC
Guidelines. If the values fall
below this range collect
additional information from
the testing laboratory to
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
Page 73 of 92
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justify the outcome or
conduct additional
measurements. The
laboratories in a), b) or c)
should have ISO17025
accreditation or justify that
they can comply with
similar quality standards
Data unit: Mass or volume
unit per year
Description: Quantity of
natural gas combusted in
the process, in year y
(natural gas generator)
Source of data: Onsite
measurements
Measurement procedure
(if any): Use either mass or
volume meters. In cases
where fuel is supplied from
small daily tanks, rulers can
be used to determine mass
or volume of the fuel
consumed, with the
following conditions: The
ruler gauge must be part of
the daily tank and
calibrated at least once a
year and have a book of
control for recording the
measurements (on a daily
basis or per shift);
• Accessories such as
transducers, sonar and
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Unit: kg/hour
Description: Amount of
natural gas consumed by
the HRSG
Source of Data:
HRSG natural gas burner
Value if data : 1440
Description Measurement
method and procedures:
Standard flow meter to be
used.
Monitoring Frequency:
continuously and
aggregated into total hourly
measurements.
QA/QC Procedure:
Cross checked with
invoices of NG. Measuring
equipment shall be
calibrated annually in
accordance with industry
standards or
manufacturer’s instructions.
During the time of
calibration and
maintenance, alternative
equipment shall be used for
monitoring.
Date 04/12/2012
Data unit and description are described correctly.
The data source, measurement procedures, monitoring
frequency and QA/QC procedures are described in the
PDD and confirmed satisfying the requirements of the
monitoring methodology
OK
The validation team confirmed during site visit interviews
that a flow meter shall be installed at the output of the
natural gas. The reading will be taken every hourly.
The calibration frequency is considered to be appropriate
based on local and sectoral expertise.
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piezoelectronic devices are
accepted if they are
properly calibrated with the
ruler gauge and receiving a
reasonable maintenance;
• In case of daily tanks with
pre-heaters for heavy oil,
the calibration will be made
with the system at typical
operational conditions.
Monitoring frequency:
Continuously
QA/QC procedures: The
consistency of metered fuel
consumption quantities
should be cross-checked
by an annual energy
balance that is based on
purchased quantities and
stock changes.
Where the purchased fuel
invoices can be identified
specifically for the CDM
project, the metered fuel
consumption quantities
should also be crosschecked with available
purchase invoices from the
financial records.
Data unit: tCO2/GJ
EFCO2,NG
Description: Weighted
average CO2 emission
factor of fuel type i in year y
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Unit: kg/TJ
Description: Emissions
factor of natural gas
Source of Data : IPCC
default values at the upper
limit of the uncertainty at a
Date 04/12/2012
Data unit and description are described correctly.
The data source, measurement procedures, and monitoring
frequency are described in the PDD and confirmed
satisfying the requirements of the monitoring methodology.
Page 75 of 92
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OK
Source of data: The
following data sources may
be used if the relevant
conditiions apply:
a) Values provided by the
fuel supplier in invoices; b)
Measurements by the
project participants; c)
Regional or national default
values; d) IPCC default
values at the upper limit of
the uncertainty at a 95%
confiende inverval as
provided in Table 1.4 of
chapter 1 of Vol. 2 (Energy)
of the 2006 IPCC
Guidelines on National
GHG Inventories
Measurement procedure
(if any): For a) and b):
Measurements should be
undertaken in line with
national or international fuel
standards
Monitoring frequency: For
a) and b): The NCV should
be obtained for each fuel
delivery, from which
weighted average annual
values should be calculated
For c): Review
appropriateness of the
values annually; For d):
Any future revision of the
IPCC Guidelines should be
taken into account
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
95% confidence interval as
provided in table 1.4 of
Chapter1 of Vol. 2 (Energy)
of the 2006 IPCC
Guidelines on National
GHG Inventories
The validation team confirmed IPCC data shall be used for
the CO2 emission factor of natural gas.
Description of
measurement methods
and procedures:
Applicable where option B
is used. For a): If the fuel
supplier does provide the
NCV value and the CO2
emission factor on the
invoice and these two
values are based on
measurements for this
specific fuel, this CO2 factor
should be used. If another
source for the CO2 emission
factor is used or no CO2
emission factor is provided,
Options b), c) or d) should
be used.
Monitoring frequency:
Any future revision of the
IPCC guideline will be
taken into account
Date 04/12/2012
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QA/QC procedures:
Applicable where option B
is used. For a): If the fuel
supplier does provide the
NCV value and the CO2
emission factor on the
invoice and these two
values are based on
measurements for this
specific fuel, this CO2 factor
should be used. If another
source for the CO2 emission
factor is used or no CO2
emission factor is provided,
Options b), c) or d) should
be used.
Data unit: tCO2/GJ
Description: Weighted
average CO2 emission
factor of fuel type i in year y
EFCO2,Coal
Source of data: The
following data sources may
be used if the relevant
conditiions apply:
a) Values provided by the
fuel supplier in invoices; b)
Measurements by the
project participants; c)
Regional or national default
values; d) IPCC default
values at the upper limit of
the uncertainty at a 95%
confiende inverval as
provided in Table 1.4 of
chapter 1 of Vol. 2 (Energy)
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Unit: kg/TJ
Description: Emissions
factor of coal
Source of Data : IPCC
default values at the upper
limit of the uncertainty at a
95% confidence interval as
provided in table 1.4 of
Chapter1 of Vol. 2 (Energy)
of the 2006 IPCC
Guidelines on National
GHG Inventories
Description of
measurement methods
and procedures: The
IPCC default values at the
upper limit of the
uncertainty at a 95%
confidence interval as
provided in table 1.4 of
Date 04/12/2012
Data unit and description are described correctly.
The data source, measurement procedures, and monitoring
frequency are described in the PDD and confirmed
satisfying the requirements of the monitoring methodology.
The validation team confirmed IPCC data shall be used for
the CO2 emission factor of coal.
CAR 05 was raised as the parameter was fixed ex-ante
whereas applied methodology requires monitoring. The
resolution is detailed in the findings section of this protocol.
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CAR-05
OK
of the 2006 IPCC
Guidelines on National
GHG Inventories
Measurement procedure
(if any): For a) and b):
Measurements should be
undertaken in line with
national or international fuel
standards
Chapter1 of Vol. 2 (Energy)
of the 2006 IPCC
Guidelines on National
GHG Inventories
Monitoring frequency:
Any future revision of the
IPCC guideline will be
taken into account
Monitoring frequency: For
a) and b): The NCV should
be obtained for each fuel
delivery, from which
weighted average annual
values should be calculated
For c): Review
appropriateness of the
values annually; For d):
Any future revision of the
IPCC Guidelines should be
taken into account
QA/QC procedures:
Applicable where option B
is used. For a): If the fuel
supplier does provide the
NCV value and the CO2
emission factor on the
invoice and these two
values are based on
measurements for this
specific fuel, this CO2 factor
should be used. If another
source for the CO2 emission
factor is used or no CO2
emission factor is provided,
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
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Options b), c) or d) should
be used.
Data unit: TJ
Description: Quantity of
actual output/intermediate
energy generated during
year y
Source of data: From
standard data books
QOE,y
Measurement procedure
(if any): Directly measure
the actual output/
intermediate energy
produced by the project
activity
Monitoring frequency:
Measured daily,
aggregated annually
QA/QC procedures:
Not Applicable
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Unit: TJ
Description: Quantity of
actual output/intermediate
energy generated during
year y
Source of Data : Plant
records
Description of
measurement methods
and procedures: Based on
the measurement of HGj,y,
FCNG, and NCVNG.
Monitoring frequency: To
be measured continuously
and aggregated into yearly
values.
QA/QC procedures :
Measuring equipment shall
be calibrated annually in
accordance with national
standards or
manufacturer’s instructions.
During the time of
calibration and
maintenance, alternative
equipment shall be used for
monitoring.
Date 04/12/2012
Data unit and description are described correctly as per
methodology ACM00012. PP had selected method 3. As
the output of energy generate from steam in MWh, PP also
monitored the actual generated electricity from turbine in
MWh instead of TJ.
The data source, measurement procedures, and monitoring
frequency are described in the PDD and confirmed
satisfying the requirements of the monitoring methodology.
The validation team confirmed IPCC data shall be used for
the CO2 emission factor of coal.
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OK
2. Implementation of the plan: confirm that the monitoring
arrangements described in the monitoring plan are
feasible within the project design.
Described the steps undertaken to assess this.
The monitoring plan describes the objective, organisational structure, roles and
responsibility, the monitoring instruments, data monitoring procedures and the
management system.
On site review and field interview were conducted and it confirmed that the
monitoring is planned in a reasonable manner and considered feasible to be
implemented by the PP.
CAR 04 is raised as accuracy, frequency of monitoring and data archiving procedure
was not described. In response to the finding, the PP has revised the PDD including
the accuracy, monitoring frequency and data archiving procedure. The resolution is
detailed in the findings section of this protocol.
CAR 04
OK
3. Implementation of the Plan: confirm that the means of
implementation of the MP, including the data
management and quality assurance and quality
control procedures, are sufficient to ensure that the
emission reductions achieved by / resulting from the
proposed CDM project activity can be reported ex post
and verified
The monitoring plan includes the internal quality control and assurance process, data
control system and regular calibration of the monitoring instruments as appropriate
that will ensure reliable monitoring and reporting of the ERs.
OK
LRQA Reference: ENQ/2607/11/IRE
MSBSF43847
Date 04/12/2012
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Validated situation
Conclusion
SECTION 9. Local stakeholder consultation
-
Determine whether comments by local
stakeholders that can reasonably be considered
relevant for the proposed CDM project activity,
have been invited.
Stakeholder consultation was conducted on 05/10/2011 at the Club House
Modernland and Country Golf, Tangerang. No negative comment was received
through the local stakeholders’ consultation processes.
In the stakeholders’ meeting, discussion was made on the project’s potential impact
to the local environment, potential adverse effects and the expected benefits to the
local community. Justification by the PP was presented during the meeting and it is
described in the PDD.
OK
-
Confirm that the summary of the comments
received as provided in the PDD is complete.
Summary of comments as stated in the PDD were confirmed during the site visit to
identify that there was no any objections or negative comments received from the
stakeholders which required the project owner to take specific action. This was
conducted through interview with representative of local stakeholders.
Initially, the evidence of stake holder meeting was not provided by PP for review.
Hence CL 07 was issued. Subsequently PP provided the evidence which confirmed
the meeting as describe in the PDD. The resolution is detailed in the findings section
of this protocol.
CL 07
OK
-
Confirm that the project participants have taken
due account of any comments received and
have described this process in the PDD.
The local stakeholders who participated in the consultation meeting included:
1. Local people
2. Chief of village
3. Local government of the nearby sub districts
4. The representatives of Local environmental agency (BLHD)
5. The representatives of PT. Wirajaya Pakindo management and staff
6. The representatives of KfW
No comment was received that requires further action to the PP, but to continue the
implementation of EIA
OK
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Validated situation
Conclusion
SECTION 10. Environmental Impacts
1. Is an EIA required by the environmental
legislation of the host country? Describe the
legislation applicable.
According to the legislation, PP is required to develop an Environmental Impact
Analysis (AMDAL) document. It is also stipulated in Government Regulation No.
41/1999 on Air Pollution Control, that PP is required to measure and monitor certain
pollution parameters which include: sulphur dioxide (SO2), carbon monoxide (CO),
nitrogen dioxide (NO2), total suspended particulates (TSP), ammonia (NH3) and
hydrogen sulphide (H2S).
OK
2. Confirm whether the project participants have
undertaken an analysis of environmental impacts
and, if required by the host Party, an
environmental impact assessment.
The PP has submitted an AMDAL report and a revision of that AMDAL report due to
the decision to use coal boilers that was not stated in the original AMDAL. The
document is called Addition to Environmental Management Plan and Environmental
Monitoring Plan (RPL/RKL tambahan) for the Construction of Coal Boilers.
Initially the AMDAL as well as the required monitoring report document has not
provided to be reviewed. Hence CL 07 was issued. Subsequently PP provided the
AMDAL and monitoring report that confirmed the PDD has accurately quoted the
environmental impact associated with the plant and the project. The resolution is
detailed in the findings section of this protocol.
CL 07
OK
3. Confirm that environmental impacts considered
significant by the PPs or the Host country are
described in the PDD, including mitigation
measures.
There is not any significant environmental impacts due to the project activity, thus it
is not described in the PDD
OK
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Findings3
1. Grade / Ref:
2. Date:
3. Status:
CAR 01
13/01/2012
4. Requirement:
Paragraph 38, 45 and 50 of CDM-VVSM, Version 03.0
5. Nature of the Issue Raised:
Letter of approval from host Party and Annex I Party DNA has not been provided for validation.
Closed
6. Nature of responses provided by the project participants:
LoA from the host Party DNA dated: 06/03/2012 and Annex I Party DNA dated: 01/08/2012 has been submitted.
7. Assessment of such responses:
PP has presented LoAs of the host Party and Annex I Party to the validation team. The title of the project, the name of the PPs and the name of the Party mentioned
in the LoAs match exactly with that in the revised PDD. LoAs meet the requirement of written approval, stating that the Party is the Party to the Kyoto Protocol,
voluntary participation, and host country LoA’s confirmation on contribution of the project towards sustainable development.
8. References to resulting changes in the PDD or supporting annexes:
Not Applicable
1. Grade / Ref:
2. Date:
3. Status:
CAR 02
13/01/2012
Closed
4. Requirement:
Paragraph 96 and 97 of CDM-VVS, Version 03.0
5. Nature of the Issue Raised:
PP to justify from different options prescribed by the applied methodology for calculation of fcap and fWCM which of the option has been applied and how it will be
monitored.
Efficiency of coal boilers is mentioned as 100% whereas the same section also refers the efficiency as 78%. PP to clarify
Notation in the PDD was inconsistent with the applied methodology.
3
Explanation of the Findings Log structure:
1. Grading and Sequential Number of the finding
6. Details of PP’s response
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2. Date of Original Finding
3. New, Open, Closed
7. Evaluation from the Validation team
Date 04/12/2012
4. Requirement (VVM, PDD-CDM, etc)
5. Reference to Protocol
8. List of changes made as a result of the finding
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PP to clarify the appropriateness of emission factor used for coal
6. Nature of responses provided by the project participants:
1. fcap : Method -3 of ACM0012 has now been used.
2. fWCM : PP has seek clarification made for a project under the same situation (SSC 579, SSC-WG (35)). SSC-579 allows fwcm to be set as 1 with condition
that the supplementary natural gas burning is considered as project emission. Accordingly, further calculation of fwcm has now been removed from the
PDD.
3. Coal Boiler Efficiency : The different references of coal boiler efficiency in earlier PDD was due to the variation of how efficiency is defined in the earlier
methodology (AMS-IIIQ and AMS-IID). However, with clarification made by SSC-WG in SSC_579, the PP decided to adopt only AMS-IIIQ, and remove
all references to AMS-IID from the PDD, including AMS-IID’s specific boiler efficiency. In the revised PDD, there is only 1 reference to boiler efficiency for
emission reduction calculation. As per paragraph 8 of AMS-III.Q., the PP now adopts the most conservative baseline efficiency value of 100% (option iii
under calculation of "efficiency of the element process")
4. Notations in the PDD are now consistent with the applied methodology.
5. The emission factor for coal is corrected and now referring to ‘Other bituminous coal’. GCV of the coal is 6180Kcal/Kg which is about 5871 Kcal/Kg of
NCV (NCV will be about 95% of GCV), closer to ‘other bituminous coal’. The emission factor is now used as lower value of 95% confidence interval for
‘Other bituminous coal’ sourced from IPCC 2006 guidelines for stationary combustion.
7. Assessment of such responses:
In response to the finding, the PP has revised the PDD. The revised PDD now presents and justifies the calculation procedure for fcap and fWCM. The parameter fcap
has been calculated using method 3 prescribed in the methodology ACM0012, Version 04.0.0. Validation team confirms from its sectoral expertise that historical
data and product specific waste gas data cannot be determined, therefore, method 3 is suitable to the project activity. The monitoring plan was correctly revised to
include the monitoring of QOE,y method 3 for fcap and project emissions from natural gas combustion. Further, PP has used fWCM as 1 based on the clarification
SSC_579 and included emissions from combustion of natural gas as project emissions. PP has now used baseline efficiency for coal based boiler as 100% from the
list of options given in the applied methodology. Validation team confirms that using 100% efficiency is conservative for emission reduction calculation. PP has
correctly revised the applied PDD and now consistent with the applied methodology. Emission factor of coal has been correctly applied. Therefore, finding was
closed.
8. References to resulting changes in the PDD or supporting annexes:
Section B.6, B.7
1. Grade / Ref:
CAR 03
4. Requirement:
5. Nature of the Issue Raised:
The monitoring plan in the PDD does not include:
1. Accuracy of the measurement method
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2. Date:
3. Status:
13/01/2012
Closed
Guidelines for completing the PDD for small scale project activities, Version 01.0
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2. Monitoring and recording frequency
3. Data archiving procedure
6. Nature of responses provided by the project participants:
At this stage, the PP has not yet finalized it’s instrumentation procurement, thus full specification is not available. The PP is committed to procure meters
meeting the accuracy standards of industry or national standards. The standards have now been mentioned in the PDD.
Monitoring frequency" has now been specified in the row, " Brief description of measurement methods and procedures to be applied:" {The monitoring
parameters table in the PDD is in accordance with the SSC_PDD guidelines, which does not specifically isolate "Monitoring Frequency" as an entry field}
incorporate how to summarise the continuous data to generate the emission calculation.
Data archiving procedure Changes has been made in the PDD to this effect.
7. Assessment of such responses:
The validation team confirmed standard used for meter has been described in the PDD. The frequency as well as how to summarised on the continuous
data to generate the emission calculation have been described. The data archiving has been stated in the PDD.
8. References to resulting changes in the PDD or supporting annexes:
Section B.6.2 and B.7.1
1. Grade / Ref:
2. Date:
CAR 04
13/01/2012
4. Requirement:
Para 131 and 132(a) of CDM-VVS, Version 03.0
5. Nature of the Issue Raised:
Though the applied methodology AMS.II.D, Version 12 requires monitoring of:
1. Specification of the equipment replaced
2. Metering the energy use of the facility
3. Calculation of energy savings using the metered energy in above
However, monitoring plan does not include these parameters
3. Status:
Closed
PP to clarify why following parameters are fixed ex-ante whereas the applied methodology does not mention:
1. Rated efficiency of HRSG
2. HRSG rated steam output
Though applied methodology AMS.III.Q, Version 04 requires monitoring of emission factor for coal, however, it has been fixed ex-ante in section B.6.2 of the
PDD.
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PP to clarify how monitoring plan is in accordance with the applied methodology.
6. Nature of responses provided by the project participants:
1. Metering requirement of AMS-IID.
AMS-II.D is no longer applied to this PDD following clarification made under SSC_579 in SSC-WG 35. (see CAR02)
2. HRSG’s rated efficiency & steam output.
These two parameters (HRSG’s rated efficiency and rated steam output) were relevant for the calculation of fwcm, but due to clarification in SSC_579, fwcm is
now set as 1 and thus these parameters has now been removed from the PDD as ex-ante values.
Furthermore we also remove the rated efficiency of coal boiler from ex-ante value, as this is no longer deemed relevant for emission reduction calculation.
3. The monitoring of emission factor of coal
Despite the specification in the methodology (IIIQ), the emission factor of coal has been set as a fix value parameter using conservative IPCC value, and
thus revisiting is only relevant during credit period change, which is not applicable as this project choose for fixed 10 years credit period
4. Additional correction from PP: emission factor of natural gas.
In addition to the above, the current version of PDD now includes “Emission factor of Natural Gas” as a monitored parameter in accordance to the “Tool to
calculate project or leakage CO2 emissions from fossil fuel combustion
5. General comments on compliance to monitoring methodology
The current version of PDD has now been updated toward compliance to methodology IIIQ taking into consideration the clarification of SSC_579, which
deemed many previously specified monitored parameter irrelevant.
Both efficiency of coal boilers fixed ex-ante, as well as w_s fixed ex-ante has been tabulated in section B6.2.
Emission factor of coal is now a monitored parameter.
Changes have been made appropriately in the PDD.
7. Assessment of such responses:
In response to the finding, the PP has revised the PDD. The revised PDD has removed the reference to AMS.II.D and relevant parameters to be monitored.
The PDD also removes the parameters rated efficiency, and rated output which is not required by the applied methodology. Further, the PDD now include
the parameter emission factor of coal as parameter to be monitored. Validation team confirms that the changes in the PDD are in accordance with the
applied methodology, and monitoring plan is now in accordance with the applied methodology
8. References to resulting changes in the PDD or supporting annexes:
Section B.7
1. Grade / Ref:
CL 01
4. Requirement:
5. Nature of the Issue Raised:
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2. Date:
Date 04/12/2012
13/01/2012
Paragraph 45 of CDM-VVS, Version 03.0
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3. Status:
Closed
Name of the Project Participant from Annex I Party, i.e. Germany, is inconsistent in the PDD.
6. Nature of responses provided by the project participants:
Changes made accordingly in the PDD. All terms regarding "Project Participant" has now been made consistent as "KfW" (with small f in the middle)
throughout the document.
7. Assessment of such responses:
The PDD has using the correct and consistent name KfW. Validation team also confirmed the name of the PP from the ERPA term sheet dated:12/08/2011.
8. References to resulting changes in the PDD or supporting annexes:
Section A.3
1. Grade / Ref:
2. Date:
3. Status:
CL 02
13/01/2012
Closed
4. Requirement:
Paragraph 64 of CDM-VVS, Version 03.0
5. Nature of the Issue Raised:
Section A.2 of the PDD describes the capacity of the gas turbine as 15MW and the same section refers to capacity of gas turbine as 12MW. PP to clarify.
6. Nature of responses provided by the project participants:
The specified 15MW capacity of the turbine is the rated capacity of the gas turbine when tested under ISO testing conditions (at temperature of 15C, 60%
relative humidity and 1 atmosphere pressure). However, actual conditions in Indonesia are different and the actual turbine output works out to be
12.124MW. To avoid confusion the PDD has been corrected.
7. Assessment of such responses:
In response to the finding, the PDD was corrected to include the justification on actual generation capacity and name plate capacity. Validation team
confirmed the capacity of the turbine from its sectoral expertise.
8. References to resulting changes in the PDD or supporting annexes:
Section A.2
1. Grade / Ref:
2. Date:
CL 03
13/01/2012
4. Requirement:
Paragraph 71 of CDM-VVS, Version 03.0
5. Nature of the Issue Raised:
Why most recent version of the Guideline on the assessment of investment analysis is not referred in the PDD.
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3. Status:
Closed
6. Nature of responses provided by the project participants:
Changes has made in the PDD accordingly. There is no additional material effect relevant to this project associated with the version change.
7. Assessment of such responses:
PDD has been revised and now using the latest version of Investment guideline of version 05.
8. References to resulting changes in the PDD or supporting annexes:
Section B.5
1. Grade / Ref:
2. Date:
3. Status:
CL 04
13/01/2012
Closed
4. Requirement:
Paragraph 150 and 151 of CDM-VVS, Version 03.0
5. Nature of the Issue Raised:
Though the second sub-component, fuel switching and energy efficiency due to use of natural gas fired boilers, is primarily fossil fuel switching as confirmed
from the emission reduction calculations. PP to clarify why AMS.III.B will not be applied for this component.
The limit used for demonstration of small-scale limits for category II and III is not in accordance with the General Guidance on small-scale methodologies.
6. Nature of responses provided by the project participants:
AMS-II.D is no longer applied to the Project after ruling of the SSC_WG_35 response to clarification request SSC_579:
http://cdm.unfccc.int/methodologies/SSCmethodologies/clarifications/40482
Project emission is now estimated within context of AMS-IIIQ, and resulting emission reduction stays within the small scale limit of type III methodology by
adopting highest possible baseline boiler efficiency. All references to Type II limit has now been removed from the PDD.
7. Assessment of such responses:
Validation team confirms that the PP has correctly applied the methodology AMS.III.Q for the project activity. Further, the limit for small-scale projects has
been correctly revised.
8. References to resulting changes in the PDD or supporting annexes:
Section B.2, B.6, B.7 and emission reduction spreadsheet.
1. Grade / Ref:
4. Requirement:
CL 05
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2. Date:
Date 04/12/2012
3. Status:
13/01/2012
Closed
Paragraph 117 of the CDM-VVS, Version 03.0 and Guidelines of the assessment of investment
analysis, Version 05
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5. Nature of the Issue Raised:
PP to clarify the appropriateness of input values used in investment analysis:
1. How future or expected increase in gas price is considered appropriate for cash-flows on real basis.
2. How interest rate applied in the investment analysis is appropriate for cash-flows on real basis.
3. Why EPC and other cost is not depreciated.
4. How insurance cost is considered appropriate.
5. Though actual efficiency of the coal boilers based on historic data shows it about 60%, however, investment analysis spreadsheet presents designed
efficiency. PP to clarify how considering designed efficiency for coal boilers will be conservative in investment analysis.
6. Though total project costs includes EPC, PP to justify how additional head of EPC and other cost of USD 437,000is considered appropriate.
7. In accordance with Guidance 17 of Guidelines on the assessment of investment analysis, Version 05 default debt/equity ratio has been used in the
investment analysis. However, the same guidance requires long term debt/equity financing structure needs to used and only absence of that value default
values are used. PP to justify how considering default debt/equity ratio is considered conservative in investment analysis.
6. Nature of responses provided by the project participants:
1. The expected gas price increase adopted in the financial analysis is a one-time step increase occurred only in the first year of project operation, and the
same rate is assumed constant throughout the analysis year. PP underline that the gas price neither constitute an annual unit-price escalation nor
incorporate inflation or subsequent annual inflation. At the time of decision being made to switch from coal to natural gas, financially prudent investor would
have taken into consideration the potential step-increase of gas price, particularly in consideration where;
(a) other region has within recent months experienced steep increase;
(b) the contextual gas demand-supply situation at the project’s vicinity and
(c) future gas supply plan from PGN which intend to blend more expensive LNG from Eastern part of Indonesia, into the existing (non-LNG based) natural gas
supply sources.
The justification of magnitude of first year step-increase is elaborated in the PDD, and constitute best estimate of gas price closer to the time the project
entered into commissioning.
PP also referring to all recently increase of gas price more than 36 % to determine the conservative figure using 30 %.
2. 5 years average data has now been provided. The IMF World Economic Outlook database (http://goo.gl/5RwgN)(SD_096) provides 5 years GDP Deflator
data. Changes have been made appropriately in the financial model spreadsheet as well as the PDD.
3. Depreciation of EPC now has been applied for 16 years. Changes have been made appropriately in the PDD and financial excel sheet. This is for a
Category 3 (Kelompok 3) machine that can last for 16 years. Law of Indonesia No. 36, 2008, Page 18 (SD_090) is the appropriate supporting document for
this depreciation value applied.
4. PP consider that insurance costs as a real cost and incurred as consequence to the Project.
The construction and transportation insurance are capital investment costs associated with the risks of constructing and transporting the HRSG.
Given the baseline coal boilers are already installed and will be relegated from a main equipment into a back-up device, it’s insurance cost becomes
additional costs to the project’s insurance.
In addition to this, there is also on-going operational insurance associated with the risks of operating and maintaining the HRSG system itself. Given that
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the HRSG (at US$3.8m) is substantially more expensive than the coal boiler (of ~$US800k), the risk & insurance fee associated with the HRSG is clearly
higher demanding additional insurance premium.
5. In reviewing this information, it must consider the historical context of the paper mills which are taking the steam supply from the baseline coal boilers.
Whereas the coal boilers has been designed to supply steam demand of Paper Mill 1 and Paper Mill 2, Paper Mill 2 was still at construction stage by the
time the project entered into validation. Paper Mill 2 is not expected to enter commercial operation until April 2012. Consequently, the provided historical
efficiency value of 60% for the coal boiler were obtained using operational data which was based on load level well below it’s 50tonnes per hour capacity.
On average, the current operation of Paper Mill 1 requires only 29tonnes per hour of steam. At this utilization rate, the boiler can not reach it’s optimum heat
exchange efficiency, and hence the 60% historical efficiency is observed. Without the project, the commencement of Paper Mill 2 will increase the steam
demand to the full capacity of these boilers, and as such these boilers would be able to achieve efficiency closer to it’s manufacturer specifications.
Conservativeness of assumption: The use of manufacturer specification for calculating coal usage (associated with cost saving) is considered as best fit in
the context that same approach (manufacturer based information) is also taken to calculate the gas usage (project costs). Loss of efficiency can occur on
both equipment (which either increases saving or increases project costs), and thus in absence of better information, manufacturer specifications are
considered the best available information at the time of decision making.
6. The “EPC and other costs” refer to additional commissioning costs outside those that are covered by the EPC contractor.
This includes: PP’s staff costs associated with project supervisory (expert staff cost) and management; statutory/ admin costs, bank fees and legal fees.
These costs are the usual additional costs associated with developing & managing such project, and can-not be avoided despite the turn-key nature of the
project. These costs are approximately 10% of the total investment cost, non-recoverable and strongly associated with the project development. As such, it
is considered as an inseparable part of the overall project costs.
7. Paragraph 17 of the “Guidelines on the Assessment of Investment Analysis v5” is an appropriate guidance in situation where the company's internal
benchmark is used for the expected return on equity.
For the project similar investment was made by the PP to compare the benchmark value. The benchmark value used on the default value described in the
investment analysis guidelines.
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7. Assessment of such responses:
1. Validation team confirmed from the interview of the gas supplier and its host country expertise that in Indonesia gas prices are regulated by government and
usually there is lag in gas price from the inflation. Validation team also confirmed from the interview of gas supplier that gas price was increase in other
provinces and was known at the time of investment decision. Therefore, including an expected increase in gas price based on awareness of the PP through
local news is appropriate for the project activity. Further, validation team also confirmed from the gas increase from the communication made to the PP by
the gas supplier dated: 08/05/2012.
4
2. Interest rate has correctly calculated in real terms by adjusting to inflation in accordance with Fisher equation .
3. Depreciation of the EPC has been correctly calculated in accordance with the host country rules.
4. Validation team confirms that justification provided by the PP for insurance cost is acceptable. Validation team also confirmed the appropriateness of
insurance cost from its host country and sectoral expertise.
5. The efficiency used has been appropriately justified.
6. Validation team confirms this cost from its sectoral expertise.
7. Validation team confirms the justification provided by the PP is appropriate.
8. References to resulting changes in the PDD or supporting annexes:
Section B.5 and investment analysis spreadsheet
1. Grade / Ref:
CL 06
4. Requirement:
5. Nature of the Issue Raised:
2. Date:
3. Status:
13/01/2012
Closed
Guidelines for completing the PDD for small scale project activities, Version 01.0
Following are editorial corrections needs to be incorporated in the PDD:
1. The technical description of the project activity was not described in section A.4.2.
2. Though the starting date of the crediting period was considered from 01/07/2012. PP to clarify why emission reduction for the year 2012 was considered
from the full year.
3. Section C.1.1 of the PDD does not specify how the start date was determined.
4. Section C.2.2.1 of the PDD does not specify how crediting period will be started if date of registration is after the date mentioned in this section.
5. Though the project is a small scale project activity, PP to clarify why reference of Tool for demonstration and assessment of additionality is referred in the
PDD.
6. The units of the NCV of natural gas is inconsistent with emission reduction spreadsheet
6. Nature of responses provided by the project participants:
PP has revised the PDD accordingly. Technical description has been moved into section A.4.2. In the estimated amount of emission reduction, we no longer
4
http://en.wikipedia.org/wiki/Fisher_equation
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specify the year, and instead refer to Year 1 to Year 10. Thus, we consider the first year to start with the commencement date of credit period for a full year
duration. PP have now specify in Section C.1.1, that the starting date represents the date of which the EPC contract is signed. PP also have now rectify this
and specify that the start date of credit period is the specified date or the date of registration, whichever the later. PP have now removed all references to
the Tool for demonstration and Assessment of Additionally in the PDD, and instead complies with Attachment A of Appendix B (Version 08, EB63/Annex 24)
by demonstrating that the existing installation (coal boilers) is a financially more viable alternative relative to the project activity (HRSG) and continuation of
the coal boiler operation would have led to a much higher emission. The PDD is revised to correctly present the units of NCV consistent with the emission
reduction spreadsheet.
7. Assessment of such responses:
• The technical description of the project activity has been described in section A.4.2 of revised PDD.
• The PDD has been revised using general term instead state specific term of year.
• The revised PDD has specifies that the start date was determined from EPC contract signed with PT. Indoturbine.
• Section C.2.2.1 of the revised PDD has specified that the crediting period will start on 06/12/2012 or the date of registration whichever is later.
The revised PDD has removed the reference of Tool for demonstration and assessment of additionality and replace with Attachment A of Appendix B
(Version 08, EB63/Annex 24) by demonstrating that the existing installation (coal boilers) is a financially more viable alternative relative to the project activity
(HRSG) and continuation of the coal boiler operation would have led to a much higher emission.
Unit of NCV of natural gas in the PDD is now consistent with emission reduction spreadsheet.
8. References to resulting changes in the PDD or supporting annexes:
Section A.4.2, B.6.4 and C
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