PDD Kelar
PDD Kelar
PDD Kelar
Complete this form in accordance with the Attachment “Instructions for filling out the project design document
form for CDM project activities” at the end of this form.
Title of the project activity Kelar Natural Gas Combined Cycle Project
Kelar Natural Gas Combined Cycle Project (hereinafter referred to as the Project or indistinctively
Kelar Project) consists in a Greenfield natural gas fired combined cycle power plant located in the
community of Mejillones in the north of Chile (hereafter, the “Host Country”) and connected to the
Grand North Interconnected System (hereinafter, the SING).
The Project was conceived by BHP Chile Inc. (hereinafter, BHP) with the aims of guaranteeing
electricity supply to cover the future demand of its mines Minera Escondida Limitada (hereinafter
“Escondida”) and “Cerro Colorado”.
The project was originally planned - in 2005 - as a 500 MW sub-critical coal fired power plant as
evidenced by the project EIA submitted to the national Environmental Impact Assessment System
(abbreviated in Spanish as SEA) on 09/11/2006 and approved on 26/10/2007.1
Nonetheless, in 2012, before the coal plant started construction, BHP decided to switch the fuel
source from coal to natural gas. The main reasons that justified this decision were:
i) New energy requirements from 2016: replace expiring contracts and supply project´s additional
energy needs;
ii) Kelar as a strategic asset to new players entering the market;
iii) Secure access to LNG re-gasification terminal in Mejillones (near Kelar site);
iv) Switching to gas could reduce GHG emissions and is technically friendly with intermittent
renewable energy (wind and solar) in terms of electricity supply stability, in opposition to coal
fueled units and
v) BHP strategy of providing secure, sustainable and price competitive power.
As a result, in 2012 BHP launched an international tender process for the construction, operation
and maintenance of Kelar project, which was, granted to the consortium integrated by Korea
Southern Power Co. (Kospo) and Samsung C&T Corporation, which signed a Build, Own, and
Operation and Maintenance (BOOM) contract with BHP by the end of 2013. As stated in the BOOM
contract2, the Consortium is considered as the Independent Power Producer (IPP), and its main roles
and functions in Kelar Project are to finance, develop, build, own, operate and maintain the project
in order to provide the agreed services to BHP. BHP is the power plant license owner that pays the
IPP for the services according to the long-term agreement and assumes the project´s commercial
risk by being responsible for the purchase of natural gas and electricity sales. The Consortium has
transferred, assigned and passed, with full legal and beneficial title guarantee, all right, title, benefit
and interest, present and future, in the present CDM project and its CERs to BHP.3
The gas-steam combined cycle generation system consists of 2 gas turbine units 2 Heat Recovery
Steam Generator units and 1 steam turbine. The guaranteed capacity of the natural gas combined
cycle is 516.775 MW. The 10 years’ crediting period average load factor of the power plant is
estimated to be 71.05%. Therefore, the estimated annual net electricity generation is 3,216,521
MWh/yr.
As a Greenfield power plant, the scenario existing prior to its implementation was the generation of
the equivalent amount of electricity to be delivered to the SING by the Project, by the operation of
1 Kelar Coal Thermal Power Plant EIA approval process and documents; General Background; SEA
webpage. Available at:
http://seia.sea.gob.cl/expediente/expedientesEvaluacion.php?modo=ficha&id_expediente=1853582
2 BOOM Contract, page 1. Available to the DOE at validation.
3 BOOM contract, article 7. Available to the DOE at validation.
the power plants connected to the SING. The SING is the second major electricity system of the
country4, representing 22% of the installed capacity and 26% of the electricity generated in the
country in 20155. The system is highly reliant on coal based thermal generation that reached the
76% of the electricity generated by the power plants connected to this system.
The baseline scenario, as identified in section B.4 below, is the construction of a new subcritical
coal power plant connected to the SING.
The estimated annual average and total GHG emissions reductions for the 10 years crediting period
are 203,344 tCO2e/year and 2,033,440 tCO2e, respectively.
Additionally, the project will contribute to the sustainable development of Chile, by, among others:
- Diversifying the energy matrix through the implementation of a cleaner and more efficient
technology in a country and particularly an electricity system (SING) where coal is the
predominant source of energy for electricity generation;
- Improving local air quality by reducing local air pollutants (SO2, NOx and PM) emissions produced
by coal based power plants, and thus, enhancing public health;
- Increasing employment opportunities in the area where the project is located, leading to a general
increase in local/community income;
- Encouraging the development of further modern and more efficient energy units throughout the
country; and
Finally, it is confirmed that the proposed CDM project activity is not a CPA that has been excluded
from a registered CDM PoA as a result of erroneous inclusion of CPAs.
Chile
4 The Chilean electricity matrix consists of four independent electricity systems: SIC, SING, Magallanes and
Aysén.
5 National Commission of Energy (CNE); Statistics/Energy/Electricity/Production and Consumption/Gross
generation SIC and SING; Gross generation Magallanes; and Gross generation Aysén;
http://www.cne.cl/estadisticas/energia/electricidad. Accessed on: 18/09/2016.
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CDM-PDD-FORM
Community of Mejillones
The project is located in an area of 26.01 hectares of land called “Lot Block 20", in the Industrial
Port Zone of the Community of Mejillones. The project geographical coordinates are:
The project is a Greenfiend Combined Cycle Gas Turbine (“CCGT”) power plant connected to the
Grand North Interconnected System (SING).
The net guaranteed installed capacity of the CCGT is 516.775 MW and the layout is based on a “2-
2-1” configuration: two gas turbo-generators, two HRSGs and one steam turbine (double casing
double shell condensing steam turbine type skoda with steam reheating).
Value/Description Reference
Gas turbine generators (2)
Brand Alstom Nameplates photos
Topair
Model Nameplates photos
Turbogenerator
PM 100128 / PM
Serial numbers Nameplates photos
100124
Type 50WY21Z-095 Nameplates photos
Nameplate installed capacity
191.25 Nameplates photos
(MW)
As indicated in the above table, the 10 years crediting period (01/12/2017-30/11/2027) and the 30
years project lifetime (01/10/2016 – 30/09/2046) plant load factors (PLF) have been calculated
according to the plant generation profile in the SING Electrical System, established in the BOOM
contract (Part II; 6.15 Communication; 29/11/2013)6. The generation profile was elaborated by BHP
based on a modelling projection of the National Energy Commission (CNE) and taken into
consideration: the demand projection of the SING, the introduction of NCRE power plants in the
project time horizon and the dispatch merit order.
The 30 years’ project lifetime PLF is higher than the 10 years’ crediting period PLF mainly because
from 2021 onwards it is projected an increase of the electricity system demand due to the operation
start of new mining projects as illustrated in the demand forecasts of the SING customers (Customers
Demand 2013-2027 First Semester 2013) informed to the National Electric Coordinator (ex CDEC-
SING).7
Furthermore, it is important to consider that all power plants connected to the SING system operate
according to the National Electric Coordinator orders which daily determines the generation program
of the grid based on the marginal costs of the power plants8. Therefore, the dispatch ability of the
power plants is related to their marginal cost, which in the case of fossil fuel power plants is mainly
related to the fossil fuel (coal, fuel-oil, natural gas) costs that rely exclusively on market prices9.
Hence, the primary fuel cost highly impacts the power generation costs and determines if a power
plant is dispatched or not. As a result, fossil fuel power plants connected to the SING cannot be
deemed must-run. The CDEC-SING has confirmed that the generation program of the SING units is
carried out by them based on current regulations and in accordance with the Procedures established.
This regulation establishes that the planning, programming and operation of the system is done in
order to obtain the minimum overall cost, subject to security constraints, technical characteristics of
the transmission system, technical characteristics of generation units and projected demands. As a
result, the condition and dispatch level for each generation unit of the SING is obtained. Thus, in the
SING none of the power plants (coal, fuel oil and natural gas) are considered low-cost/must-run.10
Moreover, Kelar PLF projections for the first years (51% in 2016 and 56% in 2017) has been
compared with the real PLFs of the two similar NGCCs connected to the SING that started to operate
in 2014: CTM3 (361.12 MW) and U16 (250.75 MW)11,12. The PLFs of these power plants have been:
11.4% and 41.8% in 2015, respectively; 20.5% and 30.6% in 2016, respectively; and 15% and 22.7%
in 2017 (until 13/07/2017), respectively.13,14
6
Available to the DOE at validation.
7
Available at: http://cdec2.cdec-
sing.cl/pls/portal/cdec.pck_web_coord_elec.sp_pagina?p_id=5047&p_id_public_web=437&p_periodo=# Accessed on: 07/08/2017
8
Procedure short-term operational program; CDEC-SING; v1.0. Available at: http://cdec2.cdec-
sing.cl/pls/portal/cdec.pck_proc_dodp_pub.proced_hist_dodp_item?p_id=22&p_clasif_direcc=2&p_tipo_proc=DO&p_de_donde=W.
Accessed on: 08/08/2017.
9
Procedure cost of fuels of power plants; CDEC-SING; v04. Available at: http://cdec2.cdec-
sing.cl/pls/portal/cdec.pck_proc_dodp_pub.proced_hist_dodp_item?p_id=29&p_clasif_direcc=2&p_tipo_proc=DO&p_de_donde=W.
Accessed on: 08/08/2017.
10
CDEC-SING communication; 07/02/2013. Provided to the DOE.
11
Generation Installed Capacity, CNE. Available at: http://www.cne.cl/estadisticas/electricidad/ Route of access: CNE website /
Statistics/Electricity/Infraestructure/Generation Installed Capacity.
12
It is important to take into account that these projects started commercial operation after the start date of the proposed project activity
(29/11/2013). Thus, they are not included in the common practice analysis. Atacama CC2 (384.7 MW) also started to operate in 2014, but
this NGCC as well as Atacama CC1 (which was included in the common practice analysis) PLFs cannot be compared with Kelar NGCC
because, as illustrated in the documentation provided to the DOE for validation, their PLFs are very low given that they operate mainly
with diesel.
13
Calculated according to data available in Electricity Generation Monthly Report; CDEC-SING; Available at: http://cdec2.cdec-
sing.cl/pls/portal/cdec.pck_web_coord_elec.sp_pagina?p_id=5169
14
Data and calculations provided to the DOE at validation.
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CDM-PDD-FORM
Therefore, Kelar PLF projections are higher and can be deemed conservative.
- Energy flow and balance of the system and equipment included in the project (including
monitoring equipment)
The schematic representation of the energy flow and balance of the system and equipment included
in the project is presented in Section B.3 below.
The scenario existing prior to its implementation is the generation of the equivalent amount of
electricity to be delivered to the SING by the Project, by the operation of the power plants
connected to the SING given that this is a Greenfield project. Thus, there were no facilities,
systems and equipment in operation in the project site prior to its implementation.
- Baseline scenario:
The baseline scenario, as identified in section B.4 below, is the construction of a new subcritical
coal power plant connected to the SING. The facilities, systems and equipment under this scenario
are:
15
Kelar coal power plant EIA approval; RCA 0341/2007; SEA. Available at:
http://seia.sea.gob.cl/externos/admin_seia_web/archivos/6488_2007_10_26_RE.pdf
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CDM-PDD-FORM
Regarding the baseline power plant load factor, as illustrated in the table, it has been calculated to
dispatch the same amount of electricity of the project power plant. The justification of this approach
is that, as above stated, Kelar project was originally planned in 2005 as a 500 MW sub-critical coal
fired power plant. The generation profile indicated in the EIA of this power plant elaborated in 2006
corresponded to a modelling projection of the SING electricity system made by that time and no
longer valid in 2012, when BHP decided to switch the fuel source from coal to natural gas.
Additionally, as above mentioned, all power plants connected to the SING system operate according
to the National Electric Coordinator orders which daily determines the generation program of the grid
based on the marginal costs of the power plants. Therefore, the dispatch ability of the power plants
is related to their marginal cost, which in the case of fossil fuel power plants is mainly related to the
fossil fuel (coal, fuel-oil, natural gas) costs that rely exclusively on market prices. Hence, the primary
fuel cost highly impacts the power generation costs and determines if a power plant is dispatched or
not. As a result, fossil fuel power plants connected to the SING cannot be deemed must-run.
Furthermore, it is important to consider that, Kelar NGCC was conceived to provide the same output
than Kelar coal thermal power but updated to electricity generation projections elaborated in 2013.
Given that coal power plants generation costs are lower than natural gas power plants generation
costs they are dispatched before natural gas power plants, i.e.: coal thermal power plants PLF are
higher than natural gas power plants PLF.
Due to this reason, Kelar NGCC net installed capacity (516.775 MW) is higher than Kelar coal
thermal power plant (443.2 MW) to be able to generate and dispatch the same amount of electricity.
Moreover, the baseline coal thermal power plant PLFs (from 59.47% in 2016 up to 92.35% from
2023 onwards and 87.76% corresponding to the 30 years average) have been compared with the
actual PLFs of all operative coal thermal power plants connected to the SING in 2015, 2016 and
2017 (until 13/06/2017). The PLFs of these power plants is in average 68%; the lowest PLF is 53.3%
and the highest PLF is 91.3%.16,17,18
All baseline coal thermal power plant PLFs (the lowest, the highest and the lifetime average) are
higher that the above-mentioned values. Therefore, Kelar coal thermal PLFs can be deemed
conservative.
Important note: The construction and operation of Kelar project was granted by BHP to the
consortium integrated by Korea Southern Power Co. (Kospo) and Samsung C&T Corporation. The
Consortium is called the Independent Power Producer (IPP), and its main roles and functions in
Kelar Project are: investor, operator, plant owner. BHP is the plant license owner and assumes the
project´s commercial risk by being responsible for the purchase of natural gas and sale of
electricity.
16
Generation Installed Capacity, CNE. Available at: http://www.cne.cl/estadisticas/electricidad/ Route of access: CNE website /
Statistics/Electricity/Infraestructure/Generation Installed Capacity
17
Calculated according to data available in Electricity Generation Monthly Report; CDEC-SING; Available at: http://cdec2.cdec-
sing.cl/pls/portal/cdec.pck_web_coord_elec.sp_pagina?p_id=5169
18
Data and calculations provided to the DOE at validation.
The Consortium has transferred, assigned and passed, with full legal title and beneficial guarantee,
all right, title, benefit and interest, present and future, in the present CDM project and its CERs to
BHP.
The table below demonstrates how the applicability conditions of the selected methodology
ACM0025 Version 2.0 are met by the project activity and explains the documentation that has been
used to prove it:
on: 20/09/2016
21 Available at: https://cdm.unfccc.int/methodologies/PAmethodologies/tools/am-tool-03-v3.pdf; Accessed on:
03/12/2017
22 Available at: https://cdm.unfccc.int/methodologies/PAmethodologies/tools/am-tool-07-v6.pdf; Accessed on:
03/12/2017
23 Available at: http://cdm.unfccc.int/methodologies/PAmethodologies/tools/am-tool-09-v2.0.pdf; Accessed on:
20/09/2016
24 Available at: http://cdm.unfccc.int/methodologies/PAmethodologies/tools/am-tool-15-v2.0.pdf; Accessed on:
20/09/2016
25 Available at: https://cdm.unfccc.int/methodologies/PAmethodologies/tools/am-tool-05-v3.0.pdf; Accessed
on: 3/12/2017.
26 Available at: https://cdm.unfccc.int/methodologies/PAmethodologies/tools/am-tool-27-v8.pdf; Accessed on :
03/12/2017.
27 Available at: https://cdm.unfccc.int/methodologies/PAmethodologies/tools/am-tool-24-v1.pdf; Accessed on:
14/03/2017.
ACM0025 (Version 2.0) applicability Project compliance with the Documentation that has
criteria applicability condition been used to prove it
(a) The project activity is the The project activity is the Environmental Qualification
construction and operation of a construction and operation of Resolution (“RCA” due to its
new natural gas fired power plant a new natural gas combined acronym in Spanish)
that supplies electricity: (i) to the cycle power plant that supplies 0155/201328; and its
electric power grid; or (ii) to the electricity to the SING power modification RCA 0047/201529
electric power grid and to an grid.
electricity consuming facility(ies);
(b) If the project activity power plant Not applicable. The project EIA30
co-generates heat, no emission does not co-generate heat.
reductions can be claimed for the
generated heat;
(c) Natural gas is used as main fuel Natural gas will be the primary EIA
in the project power plant. Small fuel. In fact, the location of the
amounts of other start-up or project was decided so as to
auxiliary fuels can be used, but secure access to LNG re-
they shall not comprise more gasification terminal in
than one per cent of total fuel Mejillones (near Kelar site).
used annually, on an energy Black Start Diesel Generator
basis; will be used, but will comprise
no more than 1% of total fuel
use, on energy basis.
(d) Natural gas and/or Liquefied Natural gas is sufficiently References provided below.
Natural Gas (LNG) is sufficiently available in the region or
available in the region or country, country as below
e.g. future natural gas based demonstrated.
power capacity additions,
comparable in size to the project
activity, are not constrained by
the use of natural gas in the
project activity.
In 2012, LNG accounted for just 14%31 of total electricity generation in the SING, while coal was the
dominant fuel in the system. According to different specialists there is an important available capacity
to increase the production of electricity based on this fuel in the region. If Mejillones LNG terminal is
expanded, through relatively small investments, it could reach a regasification capacity of nearly
2,000 MW, an amount that is equivalent to the consumption of the whole SING. In fact, as it is
mentioned in GNL Mejillones web site32, the company is developing an expansion project to double
the regasification capacity of the terminal to 8.25 million m³/d increasing the equivalent capacity in
800 MW. This amount will almost double the fuel needs of Kelar Project.
28 Available at:
http://seia.sea.gob.cl/expediente/ficha/fichaPrincipal.php?modo=ficha&id_expediente=7547573; Accessed
on: 19/07/2016
29 Available at:
http://seia.sea.gob.cl/expediente/ficha/fichaPrincipal.php?modo=ficha&id_expediente=2129735252;
Accessed on: 19/07/2016
30 Available at:
http://seia.sea.gob.cl/expediente/expedientesEvaluacion.php?modo=ficha&id_expediente=7547573;
Accessed on: 19/07/2016
31 http://www.gnlm.cl/sitio/acerca-del-gnl/gnl-en-chile/
32
http://www.gnlm.cl/sitio/proyectos/cuarto-tren-de-regasificacion/
Beside the Mejillones LNG expansion project, another option to increase the availability of LNG in
the SING, as informed in Systep Ingenieria report33, would be through Gas Atacama project. Their
intention is to develop a Floating Storage and Regasification Unit (FRSU), already awarded to Golar
LNG. However, to start its construction the company requires the signature of supply contracts with
major consumers for over 500 MW. This has not happened yet but it surely will if the demand
requests it.
From the same report, when the electricity demand is analyzed more than 90% of the SING is
represented by large customers, both miners and service providers related to mining. The average
annual rate of growth in the electricity demand for the period 1998-2011 was 6.2%, and it is expected
to be maintained in the future according to the National Energy Commission (CNE), as reported in
April 2012 for the period 2012- 2022 in the Node Price Fixing for the SING.
To cover this demand, by August 2012, the highlights of the conventional generation projects
portfolio were: Mejillones No. 4 and No. 5 (750 MW coal units), Cochrane AES Gener (532 MW coal
unit), Pacific Rio Seco SA (350 MW, coal unit), BHP Billiton Kelar (500 MW, coal, evaluating to
convert into LNG) and Central Patache SA (110 MW, coal unit).
Therefore, the mere existence of these projects allows concluding that a great part of the future
electricity demand would be covered by other type of fuel source than LNG.
Hence, its availability for Kelar project would be secured.
This is even clearer when the two previously mentioned LNG projects are considered (Mejillones
LNG expansion and Gas Atacama LNG floating terminal), increasing the availability of LNG in the
region and not limiting future natural gas based power capacity additions in the region.
Both requirements are not applicable to the present project activity given that it supplies electricity
to the SING power grid.
Power
CH4 No Excluded for simplification. This is conservative
generation
N2O No Excluded for simplification. This is conservative
Project activity
The flow diagram provided below illustrates the equipment, systems and flows of mass and energy
including the emissions sources and GHGs included in the project boundary:
Project boundary
Legend:
Ga s flow
CO2 emissions
Stea m flow
Power flow
El ectricity
meter
Project activity new power plant
Ga s meter
CO2 emissions
CO2 emi ssions
Gas Turbine
HRSG 1
Generator 1
LNG Steam
Turbine SING
Pipeline
Gas Turbine Generator
HRSG 2
Generator 2
Step 1: Identification of alternatives to the project activity consistent with current laws and
regulations
Taken into consideration paragraph 19 of ACM0025, Version 2.0, the following alternatives are
analyzed to determine if they are realistic and credible alternatives available to the project
participants or similar project developers that provide outputs or services comparable with the
proposed CDM project activity.
P1: The construction of one or several other power plant(s) using natural gas, but technologies other
than the project activity;
P2: The construction of one or several other power plant(s) using fossil fuels other than natural gas;
P3: The construction of one or several other power plant(s) using renewable power generation
technologies; and
P4: The proposed project activity undertaken without being registered as a CDM project activity;
To conduct this analysis, is important to take into consideration that, as above mentioned:
i) The proposed project activity has been conceived by BHP Chile Inc. with the aims of guaranteeing
firm electricity supply to cover the future demand of its mines “Escondida” and “Cerro Colorado”;
ii) It was originally planned as a sub-critical coal fired power plant; and
iii) It is connected to the SING given that the mining sector is located in the north of the country and
thus, connected to this system.
Chilean electricity matrix consists of four independent grids: SIC, SING, Magallanes and Aysén. The
SIC (Central Interconnected System) and SING are the main ones representing 74% and 25% of
the installed capacity and 73% and 26% of the electricity generated in the country in 2015,
respectively34.
Both systems - particularly the SING which has a very limited hydropower potential - have been
historically highly reliant on fossil fuels thermal power generation, mainly from coal that has
significantly increased its participation in the past 10 years as showed below.
Natural gas and LNG have been introduced in Chilean electricity matrix in recent years. Between
1996 and 1999 Chile made substantial investments in gas pipelines from Argentina, mainly to supply
the electricity sector. By 2003 Chile was almost completely reliant on Argentina natural gas imports
(more than 90%). Thus, the country was deeply impacted in 2004 by Argentina’s natural gas
shortage and later cut of supply that jeopardized the electricity generation sector.35 36
The natural gas crisis led to a radical change in the electricity matrix which returned to be based on
coal thermal power plants complemented with diesel oil as a substitute for Argentine natural gas.
Since 2010, when Mejillones LNG terminal started to operate, the LNG has replaced a significant
portion of diesel oil and the installation of new coal power plants is putting back this source as the
main electricity generation source of the country. 37
In consequence, the SIC and the SING remain highly dependent on coal based power plants which
is the main energy source for electricity generation in the country representing 40% of the total
electricity generated by both systems and almost 76% of the electricity generated in the SING, in
2015.
Furthermore, according to future projection of the electrical grid contained in the Energy Agenda
2014 of the Ministry of Energy, new coal based thermal power plants (under construction and
projected) will be introduced and as a result, coal based electricity generation will continue to be the
main energy source with the 39% of the total electricity generated by the SIC and the SING by 2024
and the construction of 1.309 MW of new coal power plants of which 624 MW where under
construction in 2014 when the report was issued. Meanwhile, diesel oil participation will be reduced
up to 1% as a result of no capacity addition of power plants based on this source and the LNG
displacement of this fuel. Finally, LNG participation is expected to increase up to 15% with the
addition of 517 MW in the SING - which corresponds to Kelar project installed capacity - and 325
MW in the SIC of which only 50 MW were under construction by 2014 when the Energy Agenda was
issued.38
The SING concentrates the 58% of the electricity demand of the country´s mining industries and the
mining sector represents 79% of the net electricity commercialized in this system39. Due to the high
dependence of this sector on firm electricity, power generation by third parties entrusted by mining
companies has become a strategic input crucial for the sector development.
Due to the above and taking into consideration that the project developer planned to construct a coal
based power plant in 2005, the construction of one or several other power plant(s) using coal is a
realistic and credible alternative to the project activity.
35 Energy Supply Security: Emergency response of IEA countries 2014; Page 517; IEA. Available at:
https://www.iea.org/publications/freepublications/publication/ENERGYSUPPLYSECURITY2014.pdf
Accessed on: 12/03/2017
36 Resolution 265/2004 (Prevention measures to avoid natural gas internal supply crisis); Secretariat of Energy;
Argentina. http://mepriv.mecon.gov.ar/Normas/265-04.htm Accessed on: 12/03/2017
37 Power Plants and Projects survey, Chile, 2014-2015; “Electricidad – La revista energética de Chile”; Page
14. Available at: http://www.mch.cl/wp-content/uploads/sites/4/2014/09/CCPE-muestra.pdf; Accessed on:
21/07/2016
38 Energy Agenda - A challenge for the country, progress for everyone; Ministry of Energy; Government of
Chile; May 2014; Annex 5; Pages 116-120; Available at:
http://www.energia.gob.cl/sites/default/files/energyagendaweb.pdf Accessed on: 23/09/2016
39 Updated report of cooper mining energy consumption up to 2015; Chilean Commission of Cooper; Ministry
o Mining. Available at:
https://www.cochilco.cl/Mercado%20de%20Metales/Informe%20de%20Consumo%20de%20Energ%C3%
ADa%202015%20RBA%20versi%C3%B3n%20final.pdf#search=demanda%20de%20energia%20electric
a%20y%20seguridad%20de%20suministro Accessed on: 12/10/2016
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Meanwhile, the construction of one or several other power plants using refined oil products (mainly,
diesel oil) is not a reasonable alternative for a power plant project developer in Chile. The reason is
that, as above illustrated, the introduction of diesel oil and fuel oil was only the result of the
Argentinean natural gas shortage. The participation of this fuels has decreased in the recent years
due to the introduction of LNG and is expected to continue decreasing up to 1% of the electricity
generation of the SIC and SING by 2024 with no introduction of new power capacity from this source
as stated in the Energy Agenda 2014 of the Ministry of Energy.
Regarding the construction of one or several other power plant(s) using natural gas, but technologies
other than the project activity, despite the construction of a natural gas open cycle power plant is a
technically feasible alternative, it is not a realistic and credible baseline scenario considering that, as
illustrated in the common practice analysis performed bellow, natural gas open cycle power plants
similar to the project activity have not been constructed recently. Furthermore, as above mentioned,
the CNE projections up to 2024 do not consider the introduction of new natural gas power plants in
the SING other than Kelar.
Finally, regarding renewable power generation technologies, firstly, there is not hydropower potential
in the SING system. Secondly, in recent years wind and solar power plants have been introduced in
the SING system (as well as the SIC). Those projects have been driven by the NCRE Law (Law
20.257) as well as the CDM benefits. This Law was modified in 2013 by Law N°20.698 (Law 20/25)i,
which establishes a 20% NCRE commitment by 2025, as an alternative to the prevailing fossil fuel
based expansion of the Chilean power sector. Nevertheless, as showed in the above graphics, the
participation of these energy sources is still incipient. Furthermore, it is important to consider that not
only most of these projects have been developed as CDM projects but due to the intermittent nature
of these renewable sources, they require firm and flexible thermal power plants, like Kelar project,
to complement their power production.
Due to the above stated, and considering that the project participant as a mining company relies on
firm power generation, the construction of one or several other power plant(s) using renewable power
generation technologies (alternative P3) is not a realistic and credible alternative available to the
project participants or similar project developers, give that, hydropower is not technically feasible in
the SING system and NCREs do not provide services (firm electricity) comparable with the proposed
CDM project activity.
Based on the above analysis, the realistic and credible alternative scenarios to the project activity
are:
P2: The construction of one coal subcritical power plant; and
P4: The proposed project activity undertaken without being registered as a CDM project activity.
In line with ACM0025, Version 02.0, paragraph 22, a clear description of each baseline scenario
alternative, including information on the technology, such as the efficiency and technical lifetime, is
presented in section A.3 above.
According to ACM0025, Version 02.0 paragraph 23, the economically most attractive baseline
scenario alternative is identified using an investment comparison analysis, by applying Step 2
(Option II) of the “Tool for the demonstration and assessment of additionality” v07.0.0”.
The investment analysis is carried out in real terms and is based on the unit cost of service, i.e.: the
levelized cost of electricity production in $/kWh.
A summary of the parameters utilized for the analysis is presented below. All values are expressed
in real terms:
Kelar CCGT
Therefore, the LCOE of a coal subcritical power plant of similar characteristics to Kelar CCGT project
is 24.6% lower than Kelar CCGT LCOE.
According to the above results, the economically most attractive baseline scenario alternative is the
construction of a new subcritical coal thermal power plant. A sensitivity analysis is conducted in
section B.5 below to determine if this conclusion is robust to reasonable variations in the critical
assumptions and thus, to prove the project additionality.
According to paragraphs 8 and 12 of the CDM project cycle procedure, Version 9.0:
• “For project activities with a start date on or after 2 August 2008, the project participants shall
notify the designated national authority (DNA) of the host Party of the project activity, if the DNA
exists, and the secretariat in writing of the commencement of the project activity and their intention
to seek the CDM status within 180 days of the start date of the project activity as defined in the
“Glossary of CDM terms”, by using the “CDM project activity prior consideration form” (CDM-PC-
FORM). Such notification is not necessary if a PDD regarding the project activity has been
published for global stakeholder consultation in accordance with paragraphs 20−22 below.”
• “The project participants of project activities referred to in paragraph 8 above shall inform the
secretariat of the progress of the project activity every two years after the initial notification, using
the “CDM project activity prior consideration form” (CDM-PC-FORM) until the PDD regarding the
project activity has been published for global stakeholder consultation.”
According to the CDM Glossary of terms, the start date is defined as: “In the context of a CDM project
activity or CPA, the earliest date at which either the implementation or construction or real action of
a CDM project activity or CPA begins…”
The start date of Kelar Natural Gas Combined Cycle power plant has been identified as the date
when BHP Chile Inc. and the consortium integrated by Korea Southern Power Co. (Kospo) and
Samsung C&T Corporation signed the BOOM contract: 29/11/2013.
Given that the start date of the proposed CDM project activity is after 02/08/2008 but prior to the date
of publication of the PDD for the global stakeholder consultation, the project developer submitted to
the Chilean DNA and the UNFCCC secretariat the prior consideration of the CDM on 20/05/2014.
Furthermore, considering that two years after the initial notification the PDD had still not been
published for global stakeholder’s consultation, the project developer submitted on 02/05/201642 a
notification of the progress of the project activity to the UNFCCC secretariat. This is in line with
paragraph 10 of the CDM Project Cycle Procedure, Version 09.0.
Additionality
According to the applicable methodology ACM0025 v02.0 additionality shall be demonstrated by
applying the “Tool for the demonstration and assessment of additionality” v07.0.0.
Step 1 Identification of alternatives to the project activity consistent with mandatory laws and
regulations
The sensitivity analysis is performed by altering the main variables of the NGCC and the coal
subcritical power plant +/- 10% and by calculating the variations necessary to reach NGCC’ LCOE
equal to coal subcritical power plant’ LCOE.
• CAPEX decrease
• OPEX decrease
• Natural gas price decrease
• Plant load factor increase
LCOE
Parameter Variation Notes
(USD/kWh)
CAPEX (kUSD) = 455,980
CAPEX -10% 0.0820
CAPEX/MW (kUSD/MW) = 882
LCOE
Parameter Variation Notes
(USD/kWh)
Irrational solution. Even with zero CAPEX the
CAPEX -131% 0.0630
project LCOE >coal subcritical power plant
Irrational solution. Even with zero OPEX the
OPEX -1,771% 0.0630
project LCOE >coal subcritical power plant
The likelihood of the variations for each parameter is discussed below based on the market
projections, articles and/or technical data:
- CAPEX: The project CAPEX has been communicated to the National Commission of Energy
(CNE).
The 980 kUSD/MW NGCC project CAPEX is a realistic value considering its starting date
(November 2013) given that according to the National Commission of Energy (CNE) Final
Technical Report of the Node price determination in the SING, from October 2013 43 the
investment cost of a new NGCC power plant was around 1,000 USD/kW.
A reduction of 131% in the project CAPEX required to reach the coal power plant LCOE led to
an irrational solution given that the NGCC investment should be an income instead of an outcome.
- Opex: the operating cost of Kelar NGCC is established in the BOOM contract.
There is no rational solution to reach the coal thermal power plant LCOE given that the OPEX
should be reduced 1,771%, meaning that it should be a an income instead of an outcome.
- Natural gas price: the natural gas price projection is based on CNE data.
CNE projections are considered accurate and conservative, therefore a reduction of 31% in the
natural gas price is not considered a feasible variation.
Mathematically, there is not a possible variation of the NGCC plant load factor that could make
NGCC LCOE = coal subcritical power plant LCOE.
Even with a plant load factor of 100% every year of the 30 years’ project lifetime, the resulting
NGCC’ LCOE is 0.0786 USD/kWh, higher than the coal subcritical power plant LCOE.
• CAPEX increase
• OPEX increase
• Coal price increase
• Plant load factor decrease
LCOE
Parameter Variation Notes
(USD/kWh)
CAPEX (kUSD) = 880,000
CAPEX +10% 0.0655
CAPEX/MW (kUSD/MW) = 1,760
OPEX +10% 0.0633 OPEX, 30 years average (kUSD/yr) = 11,754
Coal price +10% 0.0665 Coal price, 30 years' average (USD/t) = 124.60
Load factor -10% 0.0659 30 years average load factor = 81.02%
LCOE
Parameter Variation Notes
(USD/kWh)
CAPEX (kUSD) = 1,460,720
CAPEX 83% 0.0836
CAPEX/MW (kUSD/MW) = 2,921
OPEX 655% 0.0836 OPEX, 30 years average (kUSD/yr) = 80,645
Coal price 60% 0.0836 Coal price, 30 years' average (kUSD/t)= 180.84
30 years average load factor = 49.84%
Load factor -44.6% 0.0836
Lowest load factor (year 2016) = 32.92%
The likelihood of the variations for each parameter is discussed below based on the market
projections, articles and/or technical data:
- CAPEX: as illustrated in the table above, to reach the LCOE of the NGCC project the CAPEX of
the coal thermal power plant would have to be increased 83% up to 2,921 kUSD/MW.
According to the National Commission of Energy (CNE) Final Technical Report of the Node price
determination in the SING, from October 201344 the investment cost of a new coal thermal power
plant is around 2,500 USD/kW. The report clarifies that this cost includes the investment in ports
to unload and store the coal.
Therefore, an increase of the coal subcritical power plant CAPEX up to 2,921 kUSD/MW is not
considered a plausible variation.
- OPEX: the OPEX value of the coal subcritical power plant corresponds to the average Opex cost
of coal thermal power plants operational in Chile by October 2013, according to data provided in
National Commission on Energy (CNE) in the Node price determination in the short term, SING,
Final Technical Report from October 2013.45
CNE data is considered accurate. Therefore, an increase of 655% in the coal subcritical power
plant OPEX is not considered a possible variation.
- Coal price: the coal price projection is based on CNE data. CNE projections are considered
accurate and conservative, therefore an increase of 60% is not considered a feasible variation.
- Load Factor: to reach the LCOE of the NGCC the load factor of the subcritical coal power plant
shall decrease 44.6%, resulting in a 30 years’ average load factor of 49.84% and a lowest plant
load factor 32.92% in 2016.
As explained in section A.3 above, the coal thermal power plant load factors (from 59.47% in
2016 up to 92.35% from 2023 onwards and 87.76% corresponding to the 30 years average) have
been compared with the actual PLFs of all operative coal thermal power plants connected to the
SING in 2015, 2016 and 2017 (until 13/06/2017). The average PLF of these power plants is 68%;
the lowest PLF is 53.3% and the highest PLF is 91.3%.46,47,48 Therefore, the PLFs results from
the sensitivity analysis (49.84% (the 30 years’ average load factor) and 32.92% (the lowest plant
load factor in 2016)) are not reasonable PLF values for a coal thermal power plant connected to
the SING.
In conclusion, the results prove that only with highly unrealistic and very favourable circumstances
Kelar CCGT’ LCOE could reach the coal thermal power plant’ LCOE.
Therefore, the proposed project activity is robust to reasonable variations on main parameters.
Outcome of step 2:
After the sensitivity analysis it can be concluded that Kelar natural gas combined cycle project is
unlikely to be the most financially/economically attractive alternative.
Sub-step 4a:
The proposed CDM project activity applies measures that are listed in the definitions’ section of
theTool for the demonstration and assessment of additionality, Version 07.0.0. Therefore, the
common practice analysis is conducted as per the stepwise approach established in the latest
version of the “Methodological tool: Common practice” (version 03.1).
45 Source: Node price determination in the short term, SING, Final Technical Report; National Commission on
Energy (CNE); Oct 2013; Page 9; Chart 4 (OPEX variable costs). Available at:
http://www.cne.cl/tarificacion/electrica/precio-nudo-corto-plazo/. Pdf file " ITP SING OCT 13"
46
Generation Installed Capacity, CNE. Available at: http://www.cne.cl/estadisticas/electricidad/ Route of access: CNE website /
Statistics/Electricity/Infraestructure/Generation Installed Capacity
47
Calculated according to data available in Electricity Generation Monthly Report; CDEC-SING; Available at: http://cdec2.cdec-
sing.cl/pls/portal/cdec.pck_web_coord_elec.sp_pagina?p_id=5169
48
Data and calculations provided to the DOE at validation.
- Step 1: Calculate applicable capacity or output range as +/-50% of the total design capacity or
output of the proposed project activity.
The Kelar Natural Gas Combined Cycle project total installed capacity is 516.775 MW.
Hence, the applicable capacity range is: 258.388 MW – 775.163 MW.
- Step 2: identify similar projects (both CDM and non-CDM) which fulfil all of the following
conditions:
(b) The projects apply the same measure as the proposed project activity;
(c) The projects use the same energy source/fuel and feedstock as the proposed project activity,
if a technology switch measure is implemented by the proposed project activity;
(d) The plants in which the projects are implemented produce goods or services with comparable
quality, properties and applications areas (e.g. clinker) as the proposed project plant;
(e) The capacity or output of the projects is within the applicable capacity or output range
calculated in Step 1;
(f) The projects started commercial operation before the project design document (CDM-PDD)
is published for global stakeholder consultation or before the start date of proposed project
activity, whichever is earlier for the proposed project activity.
According to the Tool, the applicable geographical area should be the entire host country. Therefore,
the geographical area of the common practice analysis is Chile.
According to data from the National Commission of Energy (CNE)49 of Chile, the following plants
meet the stated conditions:
Gross
Electricity Operation Installed
N° Power Plant Fuel CDM? Similar?
System start date Capacity
(MW)
TERMOELÉCTRICA
1 SING 11/4/2011 Coal 276.9 No No
ANGAMOS 1 (ANG1)
TERMOELÉCTRICA
2 SING 11/4/2011 Coal 281.3 No No
ANGAMOS 2 (ANG2)
3 SING ATACAMA (CC1) 15/9/1999 Natural gas 395.9 No No
4 SIC Antuco 1/1/1981 Hydro 320.0 No No
5 SIC Bocamina II 28/10/2012 Coal 350.0 No No
6 SIC Campiche 15/3/2013 Coal 272.0 No No
7 SIC Colbún 1/1/1985 Hydro 474.0 No No
8 SIC El Toro 1/1/1973 Hydro 450.0 No No
9 SIC Nehuenco 1/1/1998 Natural gas 368.4 No No
- Step 3: within the projects identified in Step 2, identify those that are neither registered CDM
project activities, project activities submitted for registration, nor project activities undergoing
validation. Note their number Nall.
Based on the information provided in the UNFCCC website, none of the identified projects are
CDM project activities. Therefore,
Nall = 19
- Step 4: within similar projects identified in Step 3, identify those that apply technologies that are
different to the technology applied in the proposed project activity. Note their number Ndiff.
As above mentioned, traditionally thermal power plants in Chile were coal based. It was not until
1997, when a natural gas pipeline from Argentina was constructed to supply natural gas to Chile,
that natural gas based thermal power plants were constructed.
Nevertheless, the Argentinean natural gas shortage in 2004 led to a radical change in the
operation of all those thermal power plants that were forced to replace the Argentinean natural
gas with diesel oil to be able to operate.50,51
It was not until 2009 and 2010 that the LNG regasification terminals GNL Quintero (in the SIC)
and GNL Magallanes (in the SING) started to operate, allowing the displacement of the diesel oil
consumption in the originally natural gas based power plants and the construction of new natural
gas based power plants.52
Due to the above evidences, all natural gas based thermal power plants that started to operate
until 2004 in Chile are deemed different technologies compared to Kelar natural gas combined
cycle. The investment climate on November 2013 - when the investment decision on the present
project activity was taken - was different than before 2004 due to the inaccessibility to natural gas
from Argentina (access to technology).
The only power plant that can be categorized as similar to Kelar is San Isidro II combined cycle
which was stopped in 2004 due to the Argentinean natural gas supply shortage and re-started
50 SOFOFA Communications and Declarations; Colbún repairs Nehuenco I before expected. Available at:
http://www.sofofa.cl/mantenedor/detalle.asp?p=60&s=0&n=25834 Accessed on: 14/07/2016
51 Fuel Consumption SIC and SING 2008-2015; CNE; Available at: http://www.cne.cl/estadisticas/electricidad/
only after there was confidence in the availability of LNG in Chile.53 Nevertheless, as can be
noticed in the CNE statistics on fuel consumption in the SIC (2008-2015) San Isidro II operated
all along 2008 until august 2009 with diesel oil.
Ndiff = 18
Step 5: calculate factor F = 1 – Ndiff / Nall representing the share of similar projects (penetration
rate of the measure/technology) using a measure/technology similar to the measure/technology
used in the proposed project activity that deliver the same output or capacity as the proposed
project activity.
The proposed project activity is a “common practice” within a sector in the applicable geographical
area if the factor F is greater than 0.2 and Nall – Ndiff is greater than 3.
F = 1 – 18 / 19 = 0.01
Nall – Ndiff = 1
As the factor F is not greater than 0.2 and Nall – Ndiff is not greater than 3, the proposed project
activity is not a common practice.
- Outcome of step 4:
The procedures to determine the emission reductions attributable to the Project activity are described
below, according to the selected approved methodology ACM0025 version 02.0.
Project emissions
Project emissions result from the combustion of natural gas and small amount of other start-up or
auxiliary fuels for the generation of electricity in the project power plant.
To calculate the project emissions (PEy), the “Tool to calculate project or leakage CO2 emissions
from fossil fuel combustion”, Version 03 is applied.
As per ACM0025 Version 02.0, the parameter PEy corresponds to PEFC,j,y in the tool, where j is the
combustion of natural gas and small amounts of other start-up or auxiliary fuels in the project activity
power plant, as follows:
53 Available at:
http://www.mercuriovalpo.cl/prontus4_noticias/site/artic/20050602/pags/20050602024451.html Accessed
on: 14/07/2016
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Where:
PEy = Are the CO2 emissions from fossil fuel combustion in the project power plant
during year y (tCO2/yr);
FCi,y: = Is the quantity of fuel type i combusted in the project power plant in the year y
(mass or volume unit/yr)
COEFf,y : = Is the CO2 emission coefficient of fuel type y in year y (tCO2/mass or volume unit)
The CO2 emission coefficient COEFi,y can be calculated using one of the two options provided in the
“Tool to calculate project or leakage CO2 emissions from fossil fuel combustion”, Version 03,
depending on the availability of data on the fossil fuel type i.
Option B has been selected. Thus, the CO2 emission coefficient COEFi,y is calculated based on net
calorific value and CO2 emission factor of the fuel type i, as follows:
Where:
NCVi,y : = Is the weighted average net calorific value of the fuel type i in year y (GJ/mass or
volume unit)
EFCO2,f,y : = Is the weighted average CO2 emission factor of fuel type i in year y (tCO2/GJ)
i = Are the fuel types combusted in the project power plant during the year y
Baseline emissions
According to ACM00025 Version 02.0, baseline emissions (BEy) are calculated as a sum of two
components: emissions from electricity generated and supplied by the project power plant to the grid
and to the electricity consuming facility(ies). Each component is determined by multiplying the
amount of electricity (EGPJ,grid,y, EGPJ,facility,i,y) with a respective baseline emission factor (EFBL,grid,CO2,y,
EFBL,facility,CO2,i,y).
Given that the project power plant only supplied electricity to the grid, baseline emissions are
calculated by multiplying the electricity generated and supplied by the project power plant to the grid
(EGPJ,grid,y) with a baseline CO2 emission factor (EFBL,grid,CO2,y), as follows:
Furthermore, ACM00025 Version 02.0 establishes that for construction of large new power capacity
additions under the CDM, there is a considerable uncertainty relating to which type of other power
generation is substituted by the power generation of the project plant. As a result of the project, the
application of an alternative power generation technology(ies) could avoided, or the construction of
a series of other power plants could simply be delayed. Furthermore, if the project were installed
sooner than these other projects might have been constructed, its near-term impact could be largely
to reduce electricity generation in existing plants. This depends on many factors and assumptions
(e.g. whether there is a supply deficit) that are difficult to determine and that change over time. Thus,
in order to address this uncertainty in a conservative manner, project participants shall use the
following emission factors to determine the parameter EFBL,grid,CO2,y as the minimum among the three
options:
EF1 The build margin, calculated according to “Tool to calculate emission factor for an
electricity system” Version 06.0 (EFBL,grid,CO2,y = EFgrid,BM,y); and
EF2 The combined margin, calculated according to “Tool to calculate emission factor for
an electricity system”, Version 06.0, using a wOM = 0.5 and wBM = 0.5 weight
(EFBL,grid,CO2,y = EFgrid,CM,y) for the crediting period;
EF3 The emission factor of the technology and fuel (EFBL,Tech,CO2) identified as the most
attractive baseline scenario among alternatives P1 to P4 (refer to section B.4 above)
and calculated as follows:
EF BL
EF BL ,Tech ,CO 2 = * 3 .6
η BL
Where:
Leakage
Leakage may result from fuel extraction, processing, liquefaction, transportation, re-gasification and
distribution of fossil fuels outside of the project boundary.
For the purpose of estimating leakage, the quantity of natural gas consumed by the project power
plant in year y is multiplied with an emission factor for upstream emissions (EFNG,upstream) from natural
gas consumption and subtract the emissions occurring from fossil fuels used in the baseline (i.e. due
to electricity supplied to the grid and/or to the electricity consuming facility(ies)), as follows:
Where:
= Leakage emissions in year y (t CO2e)
, = Quantity of natural gas combusted in the project plant in year y (m³)
! "
Average net calorific value of the natural gas combusted during the
, =
year y (GJ/m³)
,#$%& '( = Emission factor for upstream emissions of natural gas (t CO2/GJ)
Quantity of electricity generated in the project power plant and supplied
, , =
to the grid in year y (MWh)
Emission factor for upstream emissions occurring in the baseline due to
,#%, , =
electricity supplied to the grid (t CO2/MWh)
Quantity of electricity generated in the project power plant and supplied
,+' , & , , =
to the electricity consuming facility(ies) i in year y (MWh)
Emission factor for upstream emissions occurring in the baseline due to
,#%,+' , & , , =
electricity supplied to the consuming facility (t CO2/MWh)
The emission factor for upstream emissions from natural gas (EFNG,upstream) is determined using the
latest version of the tool “Upstream leakage emissions associated with fossil fuel use” Version 02.0.
The project participant decided to include emissions occurring from fossil fuels used in the baseline
for leakage determination. Therefore, the following guidance provided in ACM00025 Version 02.0 is
used.
The emission factor for upstream emissions occurring in the baseline (EFBL,us,grid,y or EFBL,us,facility,i,y) is
calculated consistent with the baseline emission factor (i.e. EF1, EF2, EF3) selected above, as
follows:
FF j, k, y × NCVj, k, y × EFk,upstream,CH4
EF1 EFBL,us, grid,y , orEFBL,us, facility,y = j k
× GWPCH 4
EG
j
j, y
FF j, k, y × NCV j, k, y × EF k, upstream, CH4 FF i, k, y × NCV i, k, y × EF k, upstream, CH4
EF2 EF BL, us, grid, y = 0.5 × + 0.5 × × GWP CH 4
j k i k
EG j, y i EG i, y
j
EFk,upstream,CH4
EF3 EFBL,us, grid,y , orEFBL,us, facility,y = × 3.6 × GWPCH 4
ηBL
Where:
,#%, , = Emission factor for upstream emissions occurring in the baseline due
to electricity supplied to the grid (t CO2/MWh)
,#%,+' , & , = Emission factor for upstream emissions occurring in the baseline due
to electricity supplied to the consuming facility (t CO2/MWh)
. = Plants included in the build margin
/,0, = Quantity of fuel type k (a coal or oil type) combusted in power plant j
included in the build margin in year y (mass or volume units)
! "/,0, = Average net calorific value of fuel type k (a coal or oil type)
combusted in power plant j included in the build margin in year y
(GJ/mass or volume units)
0,#$%& '(,123 = Emission factor for upstream fugitive methane emissions from
production of the fuel type k (a coal or oil type) (tCH4/GJ)
/, = Electricity generation in the plant j included in the build margin in
year y (MWh)
The determination of EFBL,us,grid,y and EFBL,us,facility,i,y is based on the source of baseline emission factor
(e.g. for EF1 - technology and fuel used by power plants included in the build margin) and is made
once at the validation stage based on an ex ante assessment and determined using the tool
“Upstream leakage emissions associated with fossil fuel use”, Version 03.0.
If the baseline emission factors EFBL,grid,CO2,y is determined as EF1 or EF2 the calculation will be
consistent with the calculation of CO2 emissions in the build margin and the combined margin, i.e.
the same cohort of plants and data on fuel combustion and electricity generation should be used,
and the values for FF and EG should be those already determined through the application of “Tool
to calculate the emission factor for an electricity system”.
Where total net leakage effects are negative (LEy<0), it will be assumed LEy=0.
Emission Reductions
Where:
ERy = Emissions reductions in year y (t CO2e)
BEy = Emissions in the baseline scenario in year y (t CO2e)
PEy = Emissions in the project scenario in year y (t CO2e)
LEy = Leakage in year y (t CO2e)
Choice of data or According to "Thermal generation: coal, key in the energetic matrix"54
Measurement more than 90% of the coal consumed in Chile is imported and is of the
methods and type bituminous coal.
procedures
Purpose of data Calculation of baseline emissions.
Additional comment -
Source of data Table 3. Default emission factors for upstream emissions for different
types of fossil fuels; Tool: Upstream leakage emissions associated with
fossil fuel use; version 03.0.; Coal/lignite (unknown mine location(s) or
coal/lignite not 100 per cent sourced from within host country); Surface
mine, or any other situation55
Value(s) applied 0.0028
Choice of data or As established by ACM00025, v02.0
Measurement
methods and
procedures
Purpose of data Calculation of leakage.
Additional comment -
Baseline emissions
EFBL,grid,CO2,y the lowest emission factor among the following three options:
As above stated, according to ACM00025 Version 02.0 EF1 shall be calculated ex post as described
in the “Tool to calculate the emission factor for an electricity system”.
Option B of step 5 of the “Tool to calculate the emission factor for an electricity system”, Version 06.0
establishes: “For the first crediting period, the build margin emission factor shall be updated annually,
ex post, including those units built up to the year of registration of the project activity or, if information
up to the year of registration is not yet available, including those units built up to the latest year for
which information is available.”
Thus, the calculation of the Build Margin emission factor for the SING has been carried out based
on the latest entire year for which information is available: 2016 data.56
According to the tool, no capacity additions from retrofits have been included in the calculation of the
Build Margin emission factor.
55 Selection based on "Thermal generation: coal, key in the energetic matrix", Revista EI; 06/05/2014;
http://www.revistaei.cl/reportajes/generacion-termoelectrica-carbon-clave-en-la-matriz-energetica/
56 Up today (21/03/2018) there is information available on new power units and their fuel consumption until
August-September 2017. SING power plants: http://cdec2.cdec-
sing.cl/pls/portal/cdec.pck_web_cdec_sing.sp_pagina?p_id=5187; SING fuels consumption:
https://www.cne.cl/estadisticas/electricidad/
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The sample group of power units m used to calculate the Build Margin has been determined as per
the procedure established in the mentioned tool. The result has been that in 2016 the SET≥20% had
a larger production than SET5 units, so SET≥20% has been considered the sample set (SET sample).
Where:
EF grid,BM,y Build Margin CO2 emission factor in year y (tCO2/MWh)
EG m,y Net quantity of electricity generated and delivered to the grid by power unit m in year
y (MWh)
EF EL,m,y CO2 emission factor of power unit m in year y (tCO2/MWh)
m Power units included in the Build Margin
y Most recent historical year for which power generation data is available.
Due to the kind of set of plants/units used for the calculation of the Build Margin emission factor of
the SING and in accordance to the Tool, only option A2 from guidance in Step 4 (a) could be used
in this calculation:
Where:
EF EL, m, y = CO2 emission factor of power unit m in year y (tCO2/MWh)
EF CO2, m, i, y = Average CO2 emission factor of fuel type i used in power unit m in year y
(tCO2/GJ)
η m, y = Average net energy conversion efficiency of power unit m in year y (%).
y = The most recent historical year for which power generation data is available.
η m,y values have been conservatively estimated ex ante in accordance to the “Tool to calculate the
emission factor for an electricity system”, Version 06.0, utilizing the default values provided in Table
2, Appendix of Tool09: ”Determining the baseline efficiency of thermal or electric energy generation
systems"; Version 02.0.
Based on 2016 data, the resulting build margin emission factor is:
Calculated according to steps established in the “Tool to calculate emission factor for an electricity
system”, Version 06.0, using a wOM = 0.5 and wBM = 0.5 weight for the crediting period.
- Step 2: Choose whether to include off-grid power plants in the project electricity system
Project participants may choose between the following two options to calculate the operating margin
and build margin emission factor:
Off-grid power generation is not significant in the SING given that it is a reliable and stable electricity
grid. Hence, only grid power plants are included in the calculation (option I).
The “Tool to calculate the emission factor for an electricity system” (version 06.0) provides four
methods to calculate the Operating Margin.
The selected method to calculate the OM of the SING has been the Simple OM given that low-
cost/must-run (hydro, solar, biomass and wind) resources accounted for less than 50% of total grid
generation over the five most recent years with information available (2012-2016) as below
demonstrated:
Regarding fossil fuel power plants dispatch in the SING, it is important to consider that all power
plants connected to this system operate according to the Economic Dispatch Center (CDEC-SING)
orders which determine daily the generation program of the grid based on the marginal costs of the
power plants.58, 59. Therefore, the dispatch ability of the power plants is related to their marginal cost,
which in the case of fossil fuel power plants is mainly related to the fossil fuel (coal, fuel-oil, natural
gas) costs that rely exclusively on market prices60. Hence, the primary fuel cost highly impacts the
power generation costs and determines if a power plant is dispatched or not. As a result, fossil fuel
power plants connected to the SING cannot be deemed must-run. To reinforce the above mentioned,
the CDEC-SING has confirmed that in the SING none of the power plants (coal, fuel oil and natural
gas) are considered low-cost/must-run.61
In conclusion, the operating margin emission factor (EFgrid,OM,y) for the SING is calculated ex ante
according to the Simple OM method.
- Step 4: Calculate the operating margin emission factor according to the selected method
It is calculated according to “Option B” (calculation based on total fuel consumption and electricity
generation of the system) of Step 4 of the tool, given that:
− The necessary data for Option A is not available. However, the total net electricity generation of
all power plants serving the system and the fuel types and total fuel consumption of the project
electricity system are available; and
− Only renewable power generation are considered as low-cost/ must-run power sources and the
quantity of electricity supplied to the grid by these sources is known; and
− Off-grid power plants have not been included in the calculation (see Option I chosen in Step 2).
Under this option, the simple OM emission factor is calculated based on the net electricity supplied
to the grid by all power plants serving the system, not including low-cost/must-run power plants/units,
and based on the fuel type(s) and total fuel consumption of the project electricity system, as follows:
Where:
EF grid,OMsimple,y = Simple Operating Margin CO2 emission factor in year y (tCO2/MWh);
FC i,y = Amount of fossil fuel type i consumed in the project electricity system in year
y (mass or volume unit);
NCV i,y = Net calorific value (energy content) of fossil fuel type i in year y (GJ/mass or
volume unit);
EF CO2,i,y = CO2 emission factor of fossil fuel type i in year y (tCO2/GJ);
EG y = Net electricity generated and delivered to the grid by all power sources
serving the system, not including low cost/ must run power plants/units, in year
y (MWh);
i = All fuel types combusted in power sources in the project electricity system in
year y.
y = The relevant year as per the data vintage chosen in step 3.
60 Procedure cost of fuels of power plants; CDEC-SING; v04. Available at: http://cdec2.cdec-
sing.cl/pls/portal/cdec.pck_proc_dodp_pub.proced_hist_dodp_item?p_id=29&p_clasif_direcc=2&p_tipo_pr
oc=DO&p_de_donde=W. Accessed on: 18/08/2016.
61 CDEC-SING communication; 07/02/2013. Provided to the DOE.
The sources of data used to determine the Simple Operating Margin of the SING are:
EFCO2,i,y IPCC default values at the lower limit of the uncertainty at a 95% confidence interval65
Based on 2016 data, the resulting operating margin emission factor is:
Where:
EFgrid,BM,y = Build margin CO2 emission factor in year y (tCO2/MWh)
EFgrid,OM,y = Operating margin CO2 emission factor in year y (tCO2/MWh)
wOM = Weighting of operating margin emissions factor (%)
wBM = Weighting of build margin emissions factor (%)
Based on 2016 data and wOM and wBM, equal to 0.5 each one for the first crediting period (according
to ACM00025 v02.0), the resulting build margin emission factor is:
- Option 3 (EF3): The emission factor of the technology and fuel (EFBL,Tech,CO2) identified as
the most attractive baseline scenario among alternatives P1 to P4 (refer to section B.4 above)
and calculated as follows:
62 SING Fuels consumption (2008-2016); CNE website / Statistics / Electricity / Production and Consumption
/ SING Fuels Consumption; http://www.cne.cl/estadisticas/electricidad/ Accessed on: 08/08/2016
63 Electricity Generation Annual Detail (GWh); CDEC-SING web page: Home page/ Operational data / Real
EF BL
EF BL ,Tech ,CO 2 = * 3 .6
η BL
Where:
As can be noticed, ex ante the lowest emission factor among the three options is the BM emission
factor o the SING system in 2016.
66 According to "Thermal generation: coal, key in the energetic matrix" (Revista EI; 06/05/2014;
http://www.revistaei.cl/reportajes/generacion-termoelectrica-carbon-clave-en-la-matriz-energetica/), more
than 90% of the coal consumed in Chile is imported and is of the type bituminous coal.
67
According to Kelar coal power plant EIA, page I-33, the efficiency of the power plant would be 35 – 36%.
Thus, for conservativeness, the default efficiency for coal subcritical grid connected power plants
commissioned after 2012 (39%) has been selected according to the methodological tool “Determining the
baseline efficiency of thermal or electric energy generation systems”; Version 02.0.
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Therefore, this is the baseline EF to be utilized to estimate the potential emission reductions of the
project:
Project emissions
Leakage
Emission reductions
Annual
average over
1,720,839 1,252,573 264,922 203,344
the crediting
period
68 CNE, Exempt Resolution Nº 108, Technical Document 1 “Quality requirements for the measurement
Measurement Volume meters. GNLM (the natural gas provider) measures natural gas
methods and at a metering station consisting of two ultrasonic flow meters and one
procedures analysis station (including a gas chromatograph, a H2S analyzer and a
H2O Analyzer).
Monitoring frequency Continuously
QA/QC procedures The consistency of metered fuel consumption quantities will 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 will also be cross-
checked with available purchase invoices from the financial records.
Purpose of data Calculation of project emissions
Additional comment -
71 Available at:
http://dataset.cne.cl/Energia_Abierta/Reportes/Minenergia/Reporte%20BNE%202015.pdf; Accessed on:
21/03/2018
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Description Weighted average CO2 emission factor of fuel type i (natural gas,
diesel, etc.) in year y
Source of data IPCC default values at the higher limit of the uncertainty at a 95%
confidence interval. 2006 IPCC Guidelines on National GHG
Inventories, Vol. 2 (Energy), Chapter 1, Table 1.4, Pages 1.23 and 1.24
Value(s) applied Natural gas: 0.0583; Diesel: 0.0748
Measurement -
methods and
procedures
Monitoring frequency Annually
QA/QC procedures -
Purpose of data Calculation of project emissions.
Additional comment -
72 Route of access: CDEC-SING web page: Home page/ Operational data / Real Operation / Energy
Generation / Energy Generation Annual Detail 2004-2016. http://cdec2.cdec-
sing.cl/pls/portal/cdec.pck_oper_real_pub.rpt_gen_centrales_sing_x_annos
73 Route of access: CDEC-SING web page: Home page/ Operational data / Real Operation / Energy
Generation / Energy Generation Annual Detail 2005-2017. http://cdec2.cdec-
sing.cl/pls/portal/cdec.pck_oper_real_pub.rpt_gen_centrales_sing_x_annos Accessed on: 21/03/2018
74 Route of access: CNE website / Statistics / Electricity / Production and Consumption / SING Fuels
Consumption. http://www.cne.cl/estadisticas/electricidad/ Accessed on: 21/03/2018
75 Route of access: CNE website / Statistics / Electricity / Production and Consumption / SING Fuels
Consumption. http://www.cne.cl/estadisticas/electricidad/ Accessed on: 21/03/2018
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Description CO2 emission factor of fuel type i used in power unit m in year y
Source of data IPCC default values at the lower limit of the uncertainty at a 95%
confidence interval. 2006 IPCC Guidelines on National GHG
Inventories, Vol. 2 (Energy), Chapter 1, Table 1.4, Pages 1.23 and 1.24
Value(s) applied Coal: 0.0895
Diesel: 0.0726
Fuel oil: 0.0755
Natural gas: 0.0543
Measurement -
methods and
procedures
Monitoring frequency Annually
QA/QC procedures -
Purpose of data Calculation of baseline emissions.
Additional comment -
Not applicable.
Monitoring tasks must be implemented according to the monitoring plan in order to ensure that the
real, measurable and long-term greenhouse gas (GHG) emission reduction for the proposed project
is monitored and reported.
Roles and responsibilities will be defined for the relevant staff involved in CDM monitoring. The
prospect of nominating a CDM Manager will be considered. If appointed, he will have the overall
responsibility for the monitoring system on this Project including the reviewing of project data, quality
assurance and quality control and definition of monitoring duties and responsibilities of project staff.
• Data Collection:
o The net quantity of electricity supplied by the project activity to the grid will be monitored
continuously by the main and cross-check electricity meters. The meters are bi-directional
Class 0.2 s meters with high accuracy measurements. All monitored parameters will be
recorded in the meter memory and automatically send to an internal software. Electricity
measurements will be made in accordance with national procedures and standards.
Invoices shall be collected on a monthly basis and used to cross-check the information
obtained from direct measurement.
o The natural gas consumed by the project will be monitored continuously by a volume
meter.
• Data Calibration:
o The energy meter will be calibrated annually by an external testing facility accredited under
Chilean standards.
o The natural gas meter will be calibrated annually
• Data Report: Internally, data recorded will be consolidated on a monthly basis and will be
checked for quality control purposes, by the appointed staff in the project developer’s head
office.
• Data Archives: The data recording, the data report and the invoices will be filed together with
this monitoring plan. The data archives shall be kept for 2 years after the end of the last
crediting period.
As mentioned above, the meter used for determining the energy supplied to the grid is a high
accuracy measurement device. In order to assure the quality of measurements, the meter will be
synchronized on a monthly basis with CDEC-SING time measurement equipment.
Procedures for maintenance of the monitoring equipment will be developed and recorded prior to
the start of Project’s operation.
In addition, the accuracy of electricity field measurements will be assured by a coordinated work
between CDEC-SING system operators and project’s operators. Any measurement discrepancies
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can be detected by the CDEC-SING system operator who is responsible for undertaking an energy
balance in an hourly basis in each of the grid monitoring points. Energy balance allows the system
operator to identify possible erroneous measurements and define appropriate corrective actions. If
needed, all data generated by the project can be recovered by accessing the CDEC-SING’s system
(SCADA).
All people that participate in the CDM monitoring process will receive proper CDM training, in order
to assure the correct application of the monitoring plan of the Project
The monitoring report will be prepared by the monitoring personnel. It will contain the data report,
and the results of the emissions reductions of the project for the defined verification period.
The verification of the monitoring report is a mandatory process required for all CDM projects. The
main objective of the verification is to independently verify that the project has achieved the emission
reductions as effectively generated and projected in the PDD.
The quantity of natural gas delivered for combustion to Kelar project is measured by a meter located
at the entrance of the project which is under the control of GNLM, the natural gas provider.
Meanwhile, the quantity of other fuels (i.e.: diesel, etc.) that could be utilized for a black-start or under
an emergency, are inside Kelar project and under the control of Kelar operator (Kospo).
Regarding electricity measurements, Kelar Natural Gas Combined Cycle Project has a bidirectional
electricity meter (cross-check meter) located at Kelar substation.
All the net electricity generated by Kelar project is dispatched to the transmission line of about 15.2
km that connects the substation with Kapatur substation - property of Tamakaya (a company of BHP
Chile) and under the control of STN – which is the SING connection point.
At Kapatur substation there is only one bidirectional meter (the main meter) that measure the net
electricity dispatched to the SING by Kelar project.
Monthly aggregated monitoring electricity data from the meters is cross-checked between them and
with CDEC-SING Monthly detail of energy generation78 that are the reference documents to emit the
electricity sale receipts.
Kelar Kapatur
Substation Substation
22/03/2018
Adriana Torchelo
Prosustentia
atorchelo@prosustentia.com
Tel.: +598 99705146
29/11/ 2013
The date when the BOOM contract between BHP Chile and Korea Southern Power Co.
(Kospo) y Samsung C&T Corporation consortium was signed.
30 years 0 month.79
Fixed.
01/04/2018
79
BOOM, Article 2. Term, Page 28 to 29.
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10 years 0 month
As per the provisions established in Art. 10 of the Chilean Environmental Law Nº 19300/9480,
modified by Law Nº 20473/1081 and its Regulatory Decree 40 from 27/03/201482, all power plants
with installed capacity higher than 3 MW must submit the project to the national Environmental
Impact Assessment System (abbreviated in Spanish as SEA) to obtain the environmental approval.
Furthermore, according to the mentioned law, depending on the effects, characteristics and
circumstances of the projects, the project developer shall submit an Environmental Impact
Declaration (DIA) or an Environmental Impact Assessment (EIA) to the SEA.
Additionally, according to the SEA, each region in Chile has its own Regional Environmental
Commission (abbreviated in Spanish as COREMA) in charge of approving all new projects in the
respective region.
Due to the above and considering that the Project also includes the construction of a natural gas
pipeline to supply the fuel to the power plant, which is also subject of an environmental impact
assessment as per the provisions of the mentioned law, BHP elaborated and submitted the
Environmental Impact Assessment study (EIA) to the SEA on 20/11/201283.
For the present project, the Environmental Assessment Commission of Antofagasta Region issued
a favorable Environmental Qualification Resolution (RCA) (Nº0155/2013) on 20/06/201384.
The plant has been designed to comply with the thermoelectric plants emission standard
established in the DS 13/2011 of the Ministry of the Environment.
According to the EIA, 14 impacts were rated during the construction phase within 6 components
(air quality, noise, soil, fauna, marine environment and human environment). Of these 14 impacts,
only one resulted positive and it was associated with hiring of low hierarchy labor. For the same
period, the remaining environmental impacts were qualified as negative; being one of high rate
(loss of habitat for nesting Sterna lorata (gaviotín chico) caused by the plant construction and
access road expansion), while the remaining resulted of low rate.
For the operation stage 6 impacts were scored, resulting all of low hierarchy. They are related to
83 http://seia.sea.gob.cl/expediente/expedientesEvaluacion.php?modo=ficha&id_expediente=7547573
Accessed on 21/07/2016.
84 http://seia.sea.gob.cl/archivos/RCA_0155-2013_KELAR.pdf Accessed on: 11/10/2014.
85.
air quality and its effects on the health of people and natural resources; noise; water quality and
marine biota. Such low hierarchy is the result of considering mitigation measures incorporated into
the project design.
According to the EIA, besides the design conditions that minimize environmental impacts, the main
mitigation, restoration and compensation measures are:
Construction Stage: considering that the most significant impact is the loss of habitat for
nesting Sterna lorata, various mitigation and compensation measures and restoration were
proposed. The development of a compensatory measure was proposed to the local authority
through the enhancement of geographical areas that have been documented as important for
this species in the Region of Antofagasta (2 sites: Buchanan Jones and Playa Grande). It was
also considered, once construction is finished, the restoration of coastal areas and areas where
the pipeline is located. Some of the mitigation measures associated to fauna are: perimeter
isolation of project site during the construction phase, active support of the Foundation for
Sustainability of Gaviotín Chico; pipeline construction outside nesting season, among others.
Other measures during the construction phase that allowed qualify impacts on a low hierarchy
are: training workers to foster and promote responsible behavior towards the local community;
under similar conditions, to prioritize the purchase of supplies and materials from local
companies; food and transport services will be recruited preferably locally; wetting the areas of
work to minimize dust emissions; etc.
Operational Stage: regarding air quality: by design, the combined cycle plant incorporates
technology that enables compliance with the emission standard under any operating regime. In
relation to water quality and the potential impact on marine biota, the project design
incorporates a semi closed cooling system with cooling towers, making the amount of water
taken from the sea and discharged effluents to be considerably less than those required in an
open cycle.
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For further information about the institutions participating in the process please refer to the
Environmental Assessment Service of the Chilean Government webpage.87
Additionally, as part of the EIA approval process, several “activities of citizen participation” (as per
its name in Spanish in the SEA webpage) were conducted from 06/12/2012 up to 05/03/2013.
These activities include the presentation of the project developer presentation of the project to the
community of Mejillones on 17th and 18th of December of 2012. The registries of all these activities,
including lists of participants, meeting minute and photographic registry, are available at the SEA
webpage. 88
It is important to mention that the EIA states that Kelar Projet is a GHG mitigation project activity
and by implementing it the company achieves its goal of ensuring the supply of electricity for its
operations in a cleaner and sustainable manner. Moreover, indirect emissions of greenhouse
gases in mining are reduced due to electricity consumption in the production of copper.
After the EIA is sent to the Environmental Assessment Service to be available to the stakeholders,
it receives all kind of comments that are consolidated by the Regional Director in a report called
Consolidated Report of Clarifications, Corrections and Additions Requirements (ICSARA, in
spanish) to the Environmental Impact Assessment of the "Kelar Natural Gas Combined Cycle
Central". This report contains the observations generated by the organizations with environmental
competence who have participated in the EIA reviewing process. The answer to this Consolidated
Report must be expressed through a document called Addendum to the EIA which must be
submitted in 4 copies, in 90 working days.
For the case of Kelar Project 2 Consolidated Reports (No. 1 and No.2) where issued in 18th
January 2013 and 3rd May 2013 respectively.
The main comments received from the participating stakeholders were related to technical and
environmental aspects and suggestions in relation to the executive project, construction and
operation phases.
87http://seia.sea.gob.cl/expediente/expedientesEvaluacion.php?modo=ficha&id_expediente=7547573
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The Consolidated Report No.1 gathered comments on 10 different topics with various subtopics
(54 in total), which in turn were subdivided in minor topics. The main topics were:
− Project Description
− Compliance Plan of Applicable Environmental Law - Environmental Regulation
− Compliance Plan of Applicable Environmental Law - Sectoral Environmental Permits
− Effects, characteristics or circumstances of Article 11 of the Law that give origin to the need
for an EIA
− Baseline
− Prediction and assessment of impacts and risk situations
− Plan of mitigation, reparation and /or compensation measures
− Measures to prevent risks and accident control, if correspond
− Monitoring plan of relevant environmental variables that give rise to EIA
− Proposition of considerations or specific requirements that the owner should meet to run
the project or activity
−
The Consolidated Report No.2 gathered comments on 5 different topics with some subtopics (8 in
total), which in turn were subdivided in minor topics. The main topics were:
− Effects, characteristics or circumstances of Article 11 of the Law that give origin to the need
for an EIA
− Prediction and assessment of impacts and risk situations
− Plan of mitigation, reparation and /or compensation measures
− Monitoring plan of relevant environmental variables that give rise to EIA
− Proposition of considerations or specific requirements that the owner should meet to run
the project or activity
All questions related to the project EIA were answered in two addendums and submitted to the SEA89
on 5/04/2013 and 23/5/2013. Doubts were clarified and all relevant suggestions were considered.
The Letter of Approval from Chile, which authorize the voluntary participation of BHP Chile Inc. and
the present project activity in the CDM. has been issued on 01/03/2018.
-----
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Salutation Mrs.
Last name Torchelo
Middle name
First name Adriana
Department
Mobile +598 99705146
Direct fax
Direct tel. +598 27106662
Personal e-mail atorchelo@prosustentia.com
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.