Carbon of 7. IS-CMS-MUC/Mu Javier Castro. Telefax:

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1 TÜV SÜD Industrie Service GmbH Munich Germany CDM Executive Board DAP-PL DAP-IS DAP-PL DAP-PL DAP-IS DPT-ZE ZLS-ZE-219/99 ZLS-ZE-246/99 Your reference/letter of Our reference/name Tel. extension/ Fax extension Date/Document Page IS-CMS-MUC/Mu Javier Castro of 7 Response to Rquest for Review Dear Sirs, Please find below the response to the request for review formulated for the CDM project with the registration number In case you have any further inquiries please let us know as we kindly assist you. Yours sincerely, Javier Castro Carbon Management Servicee Headquarters: Munich Trade Register: Munich HRB Supervisory Board: Dr.-Ing. Axel Stepken (Chairman) Board of Management: Dr. Peter Langer (Spokesman) Dipl.-Ing. (FH) Ferdinand Neuwieser Telefon: Telefax: TÜV SÜD Industrie Service GmbH Niederlassung München Umwelt Service Westendstrasse Munich Germany

2 Page 2 of 7 Response to the CDM Executive Board Request 1, 2 and 3 Issue: 1. The monitoring frequency or the monitoring method of the parameters including the electricity generation, auxiliary electricity consumption, the volume of HSD, and NCV of HSD stated in the monitoring plan is not in accordance with the. Further clarification is required how the DOE verified that the monitoring plan is in accordance with the. 2. The volume of the HSD was not continuously measured. Although this is in line with the monitoring plan, this is not in line with the methodology which requires this parameter to be continuously measured. Further clarification is required on how the DOE verified this parameter in line with the methodology. Response by PP: Thank you for your review questions. From the above, we understand that the members are concerned whether the registered monitoring plan is in accordance with the ACM0004 version 02 (3rd March 2006). In this regard we would like to highlight the extracts from the validation opinion presented by the validating DoE to EB, UNFCCC, during request for registration of the project activity. The Validation Report (Report No: , rev. 02) mentioned that In summary, it is DNV s opinion that the 12MW Captive Power Project based on Waste Heat Recovery of Industrial Waste Gases in India, as described in the PDD of 30 May 2006, meets all relevant UNFCCC requirements for the CDM and all relevant host country criteria and correctly applies the baseline and monitoring methodology ACM0004. DNV thus requests the registration of the project as a CDM project activity. Further under Section D1.3 of the validation report and validation protocolconfirms that the monitoring parameters and the frequency of recording of the data are in line with the requirements of the approved consolidated methodology ACM The monitoring parameters and the frequency of recording of the data are in line with the requirements of the approved consolidated methodology ACM0004. With this background, we proceed to reconfirm to the EB members that the registered monitoring plan and the monitoring protocol followed during the crediting period are in accordance with the approved methodology. The justification on how the monitoring plan is in accordance with methodology has been presented below: - E GEN As mentioned in the monitoring report the total electricity generated by the CPP is

3 Page 3 of 7 Definition - Total electricity generated (by the CPP within the project boundary) online on continuous through online dedicated meter (Sl No ) connected to the turbine generator b) the meter records the electricity generated on a continuous. Further, as per the standard operating procedure followed for the project activity, certified under the ISO 9000 as well as ISO (process certifications) calibrated spare meter is kept as a stand-by for replacement during calibration and or malfunction of the meter. The meters are calibrated once in two years as per the frequency allowed by the host country and delineated in the ISO procedure. Further more, as a best practice, every month, electricity generated is reconciled with electricity consumed as power plant auxiliary and other in-house manufacturing process and export to the local grid, also measured through dedicated online meters recording consumption continuously. Please note that it is impossible to manually record the generation on continuous. The meters are connected in DCS system. Thus, daily at 6 am, integrated readings from the dedicated meter (from DCS) is noted in the plant logsheet which is then compiled as monthly report and sent to the management through an MIS system for internal audit. The integrated daily data as well as the monthly data is archived (paper) further for the entire crediting period as the electronic DCS back up is only for 7 days. Based on the above series of evidence it is justified that the practice followed for monitoring and recording of the total electricity generated by the project activity is in line the applied methodology and is completely reconcilable through the audit trail of various information sources. Since we are already recording this parameter on a continuous by the online meter, we shall mention continuously (in place of monthly ) under the column of Recording frequency in the Monitoring Report and submit the revised monitoring plan to EB before starting the next verification of upcoming crediting period.

4 Page 4 of 7 E AUX Definition - Auxiliary Electricity consumed by the project (CPP) online on continuous As mentioned in the monitoring report the total auxiliary units consumed by the CPP is c) measured through online dedicated meter (Slno / ) installed at the line feed to the power plant auxiliary d) the meter records the total electricity consumed by the CPP on continuous from sources, of both own generation by CPP and grid (when CPP is not generating ) Further, as mentioned above for parameter E GEN, similar SOPcalibration procedure and MIS practices are followed as well for auxiliary meter in order to reduce uncertainty. Please note that it is impossible to manually record the generation on continuous. The meters are connected in DCS system. Thus, daily at 6 am, integrated readings from the dedicated meter (from DCS) is noted in the plant logsheet which is then complied as monthly report and send to the management through an MIS system for internal audit. The daily data as well as the monthly record is archived (paper) further for the entire crediting period as the electronic DCS back up is only for 7 days. Based on the above series of evidence it is justified that the practice followed for monitoring and recording of the total electricity generated by the project activity is in line the applied methodology and is completely reconcilable through the audit trail of various information sources. Since we are already recording this parameter on a continuous by the online meter, we shall mention continuously (in place of monthly ) under the column of Recording frequency in the Monitoring Report and submit the revised monitoring plan to EB before starting the next verification of upcoming crediting period Qi Definition Volume of HSD used Prior to further detailing on this parameter, we would like to bring to EB s notice, that the HSD consumed in DG sets is not the auxiliary fuel that is considered by the to be fired for generation startup, in emergencies, or to provide additional heat gain before entering the Waste Heat Recovery Boiler, and therefore its emission is not project

5 Page 5 of 7 in DG set on continuous emission. The requirement of running DG sets and thus consumption of HSD arises only for start-up of power plant s supporting equipments and that too when grid electricity is not available for start-up. Therefore the consumption of HSD is in any case negligible and the uncertainties on its measurement are minimal. However, since the DG sets are dedicated to the project activity, as a conservative approach, emissions from HSD used in DG sets have been considered as project emission and monitoring of such parameter has been established during validation. As mentioned in the monitoring report, the practice followed to arrive at the total HSD consumed by the DG set is as follows : a) HSD consumed is measured through dipstick measurement. There are three DG sets that consume HSD within the project boundary. Each of the three DG sets are supplied HSD from connected day tanks. Daily Dipstick reading is taken at 6 AM irrespective of the DG sets running. This is to ensure continuity of the measurement which is in line with the methodology. To arrive at the actual volume of HSD consumed, the level measured by dipstick is multiplied with the corresponding multiplication factor for tank volume. b) Please note that the ACM 004 version 2 does not mention the requirement for online measurement of the fuel consumed unlike for parameter E GEN and E AUX for this type of use of HSD. Also, online measurement of HSD at DG set is no practically possible. Therefore, dipstick measurement was acceptable by the DOE during the validation and registration of the project since no specific method of measurement was indicated in the approved methodology c) Further, in order to reduce uncertainty in HSD consumption measurement, the following cross verification/ audit practice/ best practise of monitoring are followed: a. Dipsticks are calibrated every year by third party accredited laboratory, b. Tank measurements are redone every year by

6 Page 6 of 7 certified engineers (third party), c. During site verification all invoices related to HSD purchase, internal requisition slip, and reconciled data had been produced to the DoE for verification. NCVi Definition Net calorific value of HSD on monthly Prior to further detailing on this parameter, we would like to bring to EB s notice, that the HSD consumed in DG sets is not the auxiliary fuel that is considered by the to be fired for generation startup, in emergencies, or to provide additional heat gain before entering the Waste Heat Recovery Boiler, and therefore its emission is not project emission. The requirement of running DG sets and thus consumption of HSD arises only for start-up of power plant s supporting equipments and that too when grid electricity is not available for start-up. Therefore the consumption of HSD is in any case negligible and the uncertainties on its measurement are minimal. However, since the DG sets are dedicated to the project activity, as a conservative approach, emissions from HSD used in DG sets have been considered as project emission and monitoring of such parameter has been established during validation. NCV of the HSD used in the project is determined by conducting third party laboratory test on the composite sample (random) of the fuel as and when procured and recorded at source. The same is as per the monitoring plan of registered PDD. This is now justified that the monitoring of the NCV is as per the registered PDD monitoring plan and as there was no specific methodology requirement for this kind of application of HSD, we have followed the registered PDD monitoring plan only. Response by TÜV SÜD: Electricity generation and auxiliary electricity consumption According to the monitoring plan of approved methodology ACM 0004 version 02, electricity generation and auxiliary consumption should be measured online and recorded continuously. During the site visit, it was verified by audit team that separate online meters are installed for both generation and auxiliary

7 Page 7 of 7 consumption in the project. The meters are continuously measuring the data online (as confirmed on page 15 of 19 of the verification report) and also these meters are connected with DCS system where data is continuously recorded. Monthly data of the project activity which is used for emission reduction calculation is the compilation of daily records which project proponent has been taking from DCS systems where electricity generation and auxiliary consumption are recorded continuously. Based on this information, audit team confirms that recording methods of the said parameters are in line with monitoring plan of approved methodology. Additionally, PP has also confirmed to submit the revised monitoring plan with the changes of recording frequency from monthly to continuously as done in actual case before the issuance request of next monitoring period. Volume of the HCD and NCV of HSD Applicability of the project emission as per the approved methodology ACM0004 version 02 is Project Emissions are applicable only if auxiliary fuels are fired for generation startup, in emergencies, or to provide additional heat gain before entering the Waste Heat Recovery Boiler. But it has been verified by the DOE during the site audit that no fossils fuel are fired for generation startup, in emergencies or for additional heat gain. The Waste Recovery Boiler does not have any provision of auxiliary fuel firing. So project emission is not applicable for this project case as per the aproved methodology. The use of HSD is limited to DG set only. DG sets are used as backup electricity in case of failure from the grid electricity supply to run the auxiliary equipments like pumps, cooling tower etc during emergency condition. The methodology ACM0004 version 2 does not give any specific guidance on monitoring of the volume and NCV of the HSD used for DG set operation. However, as a conservative approach project proponent has shown that HSD consumption of DG sets as a project emission. The use of HSD has been specifically mentioned in the registered PDD also. As continuous recording of volume and monthly recording of NCV of HSD in DG set is not possible, PP has followed the monitoring plan of registered PDD only. DOE has accepted the monitoring method for these two parameters because the same are as per the monitoring plan of the registered PDD and approved methodology does not specify any specific requirement related to monitoring of these parameters.