Your reference/letter of Our reference/name Tel. extension/ Fax extension Date/Document Page

Transcription

1 TÜV SÜD Industrie Service GmbH München Germany CDM Executive Board Your reference/letter of Our reference/name Tel. extension/ Fax extension Date/Document Page IS-USC-MUC/rum of 5 Michael Rumberg Michael.rumberg@tuev-sued.de Request 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, Werner Betzenbichler Carbon Management Service Michael Rumberg Headquarter: München Trade Register: München HRB Supervisory Board: Dr. Axel Stepken (Chairman) Board of Management: Dr. Manfred Bayerlein (Chairman) Dr. Udo Heisel Christian von der Linde Telefon: Telefax: TÜV SÜD Industrie Service GmbH Certification Body "Climate and Energy" Westendstraße München Germany

2 Page 2 of 5 Our reference/date: IS-USC-MUC/rum/ Response to the CDM Executive Board Issue 1: The PDD mentions version 5 of SSC methodology I.D.; this version was only valid up to 11 October The PDD has to be adjusted to current version 8. The PDD has been adjusted to the current version 8 of the SSC methodology I.D. Response and concluding assessment by TÜV SÜD: The same has been verified and is deemed to be correct now. Issue 2: The correctness of the determined Build Margin, Operating Margin and Combined Margin CO2 emission factor of the Northern Grid cannot be confirmed based on PDD information. The project participant has chosen only 1 year instead of a three year-average for determining the Approximate Operating Margin. The PDD has been revised as per the current version 8. As per Version 8, the emission factor has been calculated using three year average for the determination of Approximate Operating margin. Please refer the attached Baseline excel sheets for detailed calculations. Response and concluding assessment by TÜV SÜD: The same has been verified and is deemed to be correct now. Issue 3: Information provided in Table 1, page 52 of the PDD seems incomplete and not precise enough. Does the data characterise generation data for the entire Northern Grid? The table lists 38 different items (some of which lump together all plants operating within one State) while the Table 2, power plants considered for calculating the BM CO2 emission factor, lists 33 generation facilities, often at a sub-plant level. It is thus impossible to check consistency of Tables 1 and 2. Northern regional electricity grid has been taken as the baseline for the project activity. Please refer the attached baseline excel sheets for the emission factor calculation. The generation data comprise of all the Central and State owned power plants supplying power to the Northern regional grid. The State owned power plants has been lumped based on the type (coal, gas, hydro etc.). The following grouping has been provided in the Northern Region Electricity Board (NREB) annual reports. NREB is the nodal agency for providing the northern region electricity generation data. The list of power plants operating in the northern region can be found in the attached NREB annual report (

3 Page 3 of 5 Our reference/date: IS-USC-MUC/rum/ The 33 generating facilities are the most recent capacity additions to the grid used for Build margin calculation. Response by TÜV SÜD: The differences in number of plants is due to the different references made to OM and BM set of plants as well as the fact that for BM also added units have been considered. The same has been verified and is deemed to be correct now. Issue 4: The project developers use default coal and gas power plant efficiencies derived from an IEA report. This would require a request for deviation. Please refer the revised grid emission factor calculation. In this calculation no efficiency value has been used for coal based power plants. For gas based power plants a conservative figure of 50% efficiency has been taken from page number 156 of "Emission Baselines-Estimating the Unknown, which is an OECD document. The value taken is specific for India and not a worldwide default value. The complete document is available at the following link: The conservativeness is also demonstrated by the fact that the figure given by Ministry of Non-conventional Energy Sources (MNES), Government of India, for gas based plants is 42%. Response by TÜV SÜD: In emission factor calculation no efficiency value has been used for coal based power plants. For gas based stations the chosen figure is 50% and the same is deemed to be conservative as compared to figures provided by the government (MNES: 42%). Issue 5: The application of the monitoring methodology should differentiate monitoring of different types of biomass, e.g. mustard crop residues and rice husk. As stated in the PDD, rice husk could be used in the event of shortages of mustard crop residues. Consumption quantities of each type of biomass and calorific values as per the type of biomass should be monitored. The biomass availability study conducted for the project activity indicates surplus availability of Mustard crop residue availability in the site. However, the monitoring of quantity and calorific value of each type of biomass used in the project activity would be carried out as per the revised monitoring plan, section D.3., Table (b) of the PDD. Response by TÜV SÜD: The methodology applied requires the monitoring of amounts of biomass and calorific values of fuels used only in case of co-firing of fossil fuels. The same is not to be expected. The parameters listed in the revised PDD can nevertheless be used for assurance and plausibility checking of data. Issue 6: The claimed Combined Margin CO2 emission factor for the Northern Indian Grid as according to the present PDD is kg CO2/kWh. A previously registered CDM biomass based power

4 Page 4 of 5 Our reference/date: IS-USC-MUC/rum/ project in Rajasthan has calculated a carbon emission factor of kg CO2/kWh for the Northern Indian Grid. This difference of the present emission factor for the same regional grid should be explained or corrected. All the references for the data taken for emission factor calculation by us have been given. Please refer the baseline excel sheets. The difference between the emission factors for the Northern regional grid might be arising due to the following reasons: i. The method of calculation adopted for the two projects are different. We have calculated the emission factor for the Northern regional grid as per the guidelines given in approved methodology ACM0002; however the other project activity has adopted some other method. ii. The years of reference are different for our project activity it is a three year average ( , , and ) whereas in the other project activity it is iii. The calorific value of coal taken for the project activity is as per the revised IPCC guidelines for National GHG inventory, page This is owing to the guidance given in paragraph 32, EB-23 meeting report ( wherein it is stated that IPCC default carbon emission factor can be used in the context of approved small scale methodologies. However the other project activity has directly used emission factors (tons of CO2/GWh) for various fuels (coal, gas) from the following report "Baselines for Renewable Energy Projects under Clean Development Mechanism". ( Response by TÜV SÜD: The audit team is aware of the issue of compiling the baseline determination data in various ways by making use of different sources. Given the ambiguity of data we therefore have explicitly asked for the approval of the use of IPCC data for calorific values in small scale CDM project activities, which also causes the main difference between the two projects referred to in issue 6 above. The data type has been approved by the EB. Issue 7: It remains unclear whether the crediting lifetime is planned to be renewed once or twice for up to 7 years by the project participant. Crediting lifetime is planned to be renewed twice. Please refer section C.2.1. of the revised PDD. Response and concluding assessment by TÜV SÜD: The revised PDD clarifies the issue. Issue 8: Seasonal availability in mustard crop residues is not discussed in the PDD and supply contracts seem not yet been established with farmers. Shortages on biomass residues during several months may result in lignite co-firing, which would have an impact on the CO2 emission reduction potential. A table showing monthly availability of mustard crop residues (and rice husk as supplementary fuel as mentioned in the PDD) together with a breakdown of suppliers should be provided to assess the conservativeness of Baseline setting. Where will the rice husk be supplied from if needed? Do biomass supplier contracts exist yet? This is unclear. Further, the

5 Page 5 of 5 Our reference/date: IS-USC-MUC/rum/ PDD mentions the set up of a separate fuel development organization. Its task will be to increase cultivable area, increase yield of crops and residues, etc. It is not clear whether there is indeed abundance of mustard crop residues today surrounding the new facility as mentioned in the PDD. The conservativeness of the CO2 emission reduction determination must thus be questioned. Biomass availability has been conducted for the project activity which has indicated that mustard crop residue is available in surplus in the region. Please refer the attached chapter of the Detailed Project Report (DPR) on the Biomass availability study carried out for the project activity. All types of biomass including rice husk would be supplied by the local farmers from the nearby region covering an area of 25 km radius. The seasonal variation would be addressed by storing the surplus biomass for firing during the off-season period. No contracts have been signed as yet but the surplus availability of biomass ensures that assured supply of biomass would be available for the project activity. The conservativeness of the CO2 emission reduction determination is ensured as provision for deducting any project activity related emissions arising due to coal firing were already included in the Section E of the PDD and the relevant monitoring parameters like coal consumption quantity and carbon content were included in section D.3. table (b) of the PDD. Response by TÜV SÜD: According to client documents the supply of biomass is ensured. In any other case the actual emission reduction will be determined in an ex post assessment by monitoring the amount of fossil fuels used. The approach is deemed plausible. Issue 9: At page 10 of the PDD it is mentioned that no transmission and distribution losses have been considered. However, in Enclosure I, transmission and distribution losses are accounted for with 2% per year. The figures of net export to the grid have been taken from the DPR prepared for the project activity. To be on the conservative side transmission and distribution losses have been taken into account and emission reductions have been calculated based on the net power getting exported to the grid. The required correction has been made in page 10 of the revised PDD. Response and concluding assessment by TÜV SÜD: The transmission losses are considered in the generation forecast. The inconsistent statement has been removed. The actual generation data will be obtained during the ex post verification. Issue 10: kwh should be used instead of unit. And million should be used for 10 lakh. The requisite changes have been made in the revised PDD. Response by TÜV SÜD: The same has been verified and allows a better readability of the PDD.

6

7

8

9

10

11 Generation Details ( ) Name Type Fuel Installed Capacity (MW) Generation (Million kwh) Coal Consumption (000' tonnes) 1 Badarpur TPS Thermal Coal Singrauli STPS Thermal Coal Rihand STPS Thermal Coal Dadri NCTPS Thermal Coal Unchahar-I TPS Thermal Coal Unchahar-II TPS Thermal Coal Tanda TPS Thermal Coal Anta GPS Thermal Gas Auriya GPS Thermal Gas Dadri GPS Thermal Gas Faridabad GPS Thermal Gas Bairasiul Hydro Hydel Salal Hydro Hydel Tanakpur HPS Hydro Hydel Chamera HPS Hydro Hydel Uri HPS Hydro Hydel RAPS-A Nuclear Nuclear RAPS-B Nuclear Nuclear NAPS Nuclear Nuclear Bhakra Complex Hydro Hydel Dehar Hydro Hydel Pong Hydro Hydel Delhi Thermal Coal Delhi Thermal Gas Haryana Thermal Coal Haryana Hydro Hydel H.P. Hydro Hydel J&K Hydro Hydel J&K Thermal Gas Punjab Thermal Coal Punjab Hydro Hydel Rajasthan Thermal Coal Rajasthan Thermal Gas Rajasthan Hydro Hydel U.P. Thermal Coal U.P. Hydro Hydel Uttaranchal Hydro Hydel TOTAL Source: Annual annual energy generation for has been taken as given in NREB Annual Report Source: Coal consumption has been taken from Performance Review of Thermal Power Station ; Section 9

12 Generation Details ( ) Name Type Fuel Installed Capacity (MW) Generation (Million kwh) Coal Consumption (000' tonnes) 1 Badarpur TPS Thermal Coal Singrauli STPS Thermal Coal Rihand STPS Thermal Coal Dadri NCTPS Thermal Coal Unchahar-I TPS Thermal Coal Unchahar-II TPS Thermal Coal Tanda TPS Thermal Coal Anta GPS Thermal Gas Auriya GPS Thermal Gas Dadri GPS Thermal Gas Faridabad GPS Thermal Gas Bairasiul Hydro Hydel Salal Hydro Hydel Tanakpur HPS Hydro Hydel Chamera HPS Hydro Hydel Uri HPS Hydro Hydel RAPS-A Nuclear Nuclear RAPS-B Nuclear Nuclear NAPS Nuclear Nuclear Bhakra Complex Hydro Hydel Dehar Hydro Hydel Pong Hydro Hydel SJVNL HEP Hydro Hydel Delhi Thermal Coal Delhi Thermal Gas Haryana Thermal Coal Haryana Hydro Hydel H.P. Hydro Hydel J&K Hydro Hydel J&K Thermal Gas Punjab Thermal Coal Punjab Hydro Hydel Rajasthan Thermal Coal Rajasthan Thermal Gas Rajasthan Hydro Hydel U.P. Thermal Coal U.P. Hydro Hydel Uttaranchal Hydro Hydel TOTAL Source: Annual annual energy generation for has been taken as given in NREB Annual Report Source: Coal consumption has been taken from Performance Review of Thermal Power Station ; Section 9 H % N % TG % TC %

13 Generation Details ( ) Name Type Fuel Installed Capacity (MW) Generation (Million kwh) Coal Consumption (000' tonnes) 1 Badarpur TPS Thermal Coal Singrauli STPS Thermal Coal Rihand STPS Thermal Coal Dadri NCTPS Thermal Coal Unchahar-I TPS Thermal Coal Unchahar-II TPS Thermal Coal Tanda TPS Thermal Coal Anta GPS Thermal Gas Auriya GPS Thermal Gas Dadri GPS Thermal Gas Faridabad GPS Thermal Gas Bairasiul Hydro Hydel Salal Hydro Hydel Tanakpur HPS Hydro Hydel Chamera HPS Hydro Hydel Uri HPS Hydro Hydel RAPS-A Nuclear Nuclear RAPS-B Nuclear Nuclear NAPS Nuclear Nuclear Bhakra Complex Hydro Hydel Dehar Hydro Hydel Pong Hydro Hydel SJVNL HEP Hydro Hydel Delhi Thermal Coal Delhi Thermal Gas Haryana Thermal Coal Haryana Hydro Hydel H.P. Hydro Hydel J&K Hydro Hydel J&K Thermal Gas Punjab Thermal Coal Punjab Hydro Hydel Rajasthan Thermal Coal Rajasthan Thermal Gas Rajasthan Hydro Hydel U.P. Thermal Coal U.P. Hydro Hydel Uttaranchal Hydro Hydel TOTAL Source: Annual annual energy generation for has been taken as given in NREB Annual Report ; Annexure 2.7 ( Source: Coal consumption has been taken from Performance Review of Thermal Power Station ;Section 9 ( H % N % TG % TC %

14 List of plants supplying power to Northern grid arranged in descending order of date of commissioning Total generation % of total generation Generation of the unit in (Million kwh) Coal Consumption (000' tonnes) Plant Date of commissioning MW Fuel Type 1 Chamera HEP-II (Unit 1) Hydro - 2 Chamera HEP-II (Unit 2) Hydro - 3 Chamera HEP-II (Unit 3) Hydro - 4 SJVPNL Hydro - 5 Baspa-II (Unit 3) Hydro - 6 Suratgarh-III (Unit-5) Coal Kota TPS-IV (Unit-6) Coal Baspa-II (Unit 1 & 2) Hydro - 9 Pragati CCGT (Unit II) Gas - 10 Pragati CCGT (Unit III) Gas - 11 Ramgarh CCGT Stage -II (GT-2) Gas - 12 Ramgarh CCGT Stage -II (GT-2) Gas - 13 Upper Sindh Extn (HPS)(1) Hydro - 14 Suratgarh stage-ii (3 & 4) Coal Upper Sindh Stage II (2) Hydro - 16 Malana-1 & Hydro - 17 Panipat TPS Stage 4 (Unit-6) Coal Chenani Stage III (1,2,3) Hydro - 19 Ghanvi HPS (2) Hydro - 20 RAPP (Unit-4) Nuclear - 21 Ranjit Sagar (Unit-1,2,3,4) Hydro - 22 Gumma HPS Hydro - 23 Faridabad CCGT (Unit 1) (NTPC) Gas - 24 Suratgarh TPS Coal RAPS-B (2) Nuclear - 26 Uppersindh-2 HPS # Hydro - 27 Faridabad GPS 1 & 2 (NTPC) Gas - 28 Unchahar-II TPS # Coal Unchahar-II TPS # Coal Suratgarh TPS # Coal GHGTPLM (Unit 1) Coal GHGTPLM (Unit 2) Coal Tanda TPS (Unit-4) Coal 649 Total 20% of Generation Source: Annual annual energy generation for has been taken as given in NRLDC Grid Report March 2005 ( Source: Coal consumption has been taken from Performance Review of Thermal Power Station ;Section 9 (

15 CALCULATION OF BASELINE EMISSION FACTORS-NORTHERN GRID Million kwh Million kwh Million kwh Generation by Coal out of Total Generation Generation by Gas out of Total Generation Estimation of Baseline Emission Factor (tco 2/GWH) Simple Operating Margin Fuel 1 : Coal Avg. Calorific Value of Coal used (kcal/kg) Coal consumption (tons/yr) 70,923,000 70,397,000 73,279,000 Emission Factor for Coal-IPCC standard value (tonne CO 2/TJ) Oxidation Factor of Coal-IPCC standard value COEF of Coal (tonneco 2/ton of coal) Fuel 2 : Gas Avg. Efficiency of power generation with gas as a fuel, % Avg. Calorific Value of Gas used (kcal/kg) Estimated Gas consumption (tons/yr) 2,868,924 3,365,827 3,305,807 Emission Factor for Gas- IPCC standard value(tonne CO 2/TJ) Oxidation Factor of Gas-IPCC standard value COEF of Gas(tonneCO 2/ton of gas) EF (OM Simple), tco 2/GWh Average EF (OM Simple), tco 2/GWh Considering 20% of Gross Generation Sector Thermal Coal Based Thermal Gas Based Hydro Nuclear Total Built Margin Fuel 1 : Coal Avg. calorific value of coal used in Northern Grid, kcal/kg 4772 Estimated coal consumption, tons/yr Emission factor for Coal (IPCC),tonne CO 2/TJ 94.6 Oxidation factor of coal ( IPCC standard value) 0.98 COEF of coal (tonneco 2/ton of coal) Fuel 2 : Gas Avg. efficiency of power generation with gas as a fuel, % 50 Avg. calorific value of gas used, kcal/kg Estimated gas consumption, tons/yr Emission factor for Gas (as per standard IPCC value) 56.1 Oxidation factor of gas ( IPCC standard value) COEF of gas(tonneco 2/ton of gas) EF (BM), tco 2/GWh Combined Margin Factor (Avg of OM & BM) Baseline Emissions Factor (tco 2/Wh)

16 Measurement unit Plant Capacity kw Plant Load Factor % Operating Period Hours Gross Power Generation Million kwh Auxiliary Consumption % Auxiliary Consumption Million kwh T & D Losses % T & D Losses Million kwh Wheeling & Banking Million kwh Net Power Generation Million kwh Emission reduction tons of CO2 26,220 29,185 32,213 35,303 38,456

17 ,203 41,203