Validation Report

Validation Report
South Pole Carbon Asset Management Ltd.
VALIDATION OF THE CDM-PROJECT:

PFC EMISSION REDUCTION AT PT. INDONESIA ASAHAN ALUMINIUM (PT. INALUM) KUALA TANJUNG
REPORT NO. 1179637
20 April 2010
TV SD Industrie Service GmbH Carbon Management Service Westendstr. 199 - 80686 Munich GERMANY
Validation of the CDM Project: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Page 1 of 21
Report No. 1179637
Date of first issue 14-07-2009
Revision No. 1.3
Date of this revision 20-04-2010
Certificate No. -
Subject: Validation of a CDM Project Accredited TV SD Unit: TV SD Industrie Service GmbH Certification Body climate and energy Westendstr. 199 80686 Munich Germany Project Participants: PT. Indonesia Asahan Aluminium (Inalum) PO BOX 1, Kuala Tanjung, North Sumatra Province, Indonesia South Pole Carbon Asset Management Ltd. Technoparkstrasse 1 Zurich Switzerland 8005 TV SD Contract Partner: TV SD Industrie Service GmbH Carbon Management Service Westendstr. 199 80686 Munich Germany Project Site: Kuala Tanjung, Batubara regency, North Sumatra Province, Indonesia latitude - 03 2147.96 North longitude - 99 2740.67 East
Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Applied Methodology / Version: AM0030 / Ver. 03 Scope(s): 9 9.2
Technical area(s): First PDD Version: Date of 1 issuance: 16-05-2008 Version No.: 01
st
Final PDD version: Date of final issuance: Version No.: 22-09-2009 05
Starting Date of first GSP: 27-05-2008 Date of 2nd issuance: 12-02-2009 Version No.: 03
Starting Date of second GSP: 27-02-2009 Estimated Annual Emission Reduction: Assessment Team Leader: Nikolaus Krger Assessment Team Member: Sandeep Kanda Trainee: Jayme Boehnert 78,041 tCO2e Responsible Certification Body Member: Thomas Kleiser
Summary of the Validation Opinion: The review of the project design documentation and the subsequent follow-up interviews have provided TV SD with sufficient evidence to determine the fulfilment of all stated criteria. In our opinion, the project meets all relevant UNFCCC requirements for the CDM. Hence TV SD will recommend the project for registration by the CDM Executive Board in case letters of approval of all Parties involved will be available before the expiring date of the applied methodology(ies) or the applied methodology version respectively. The review of the project design documentation and the subsequent follow-up interviews have not provided TV SD with sufficient evidence to determine the fulfilment of all stated criteria. Hence TV SD will not recommend the project for registration by the CDM Executive Board and will inform the project participants and the CDM Executive Board on this decision.
Abbreviations
AE AM CAR CDM CDM EB CER CMP CR / CL DNA DOE EF EIA / EA ER FAR FTIR GHG IAI IPCC IRL IRR KP MP NGO NPV PDD PFC PP TV SD UNFCCC USEPA VVM Anode Effect Approved Methodology Corrective Action Request Clean Development Mechanism CDM Executive Board Certified Emission Reduction Conference of the Parties serving as the Meeting of the Parties to the Kyoto Protocol Clarification Request Designated National Authority Designated Operational Entity Emission Factor Environmental Impact Assessment / Environmental Assessment Emission Reduction Forward Action Request Fourier Transform Infrared GreenHouse Gas(es) International Aluminium Institute Intergovernmental Panel on Climate Change Information Reference List Internal Rate of Return Kyoto Protocol Monitoring Plan Non Governmental Organisation Net Present Value Project Design Document Perfluorocarbons Project Participant TV SD Industrie Service GmbH United Nations Framework Convention on Climate Change United States Environmental Protection Agency Validation and Verification Manual
Table of Contents
1 1.1 1.2 2 2.1 2.2 2.3 2.4 2.5 2.6 3 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 4 5
Page
INTRODUCTION ........................................................................................................ 5 Objective .................................................................................................................... 5 Scope ......................................................................................................................... 5 METHODOLOGY ....................................................................................................... 6 Appointment of the Assessment Team ...................................................................... 7 Review of Documents ................................................................................................ 7 Follow-up Interviews ................................................................................................... 8 Further cross-check .................................................................................................... 9 Resolution of Clarification and Corrective Action Requests ....................................... 9 Internal Quality Control ............................................................................................... 9 FINDINGS ................................................................................................................ 10 Approval ................................................................................................................... 10 Participation .............................................................................................................. 10 Project design document .......................................................................................... 10 Project description .................................................................................................... 11 Baseline and monitoring methodology ..................................................................... 11 Additionality .............................................................................................................. 15 Monitoring plan ......................................................................................................... 18 Sustainable development ......................................................................................... 18 Local stakeholder consultation ................................................................................. 18 Environmental impacts ............................................................................................. 19 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS ................................... 20 VALIDATION OPINION ............................................................................................ 21
Annex 1: Validation Protocol Annex 2: Information Reference List
1 INTRODUCTION 1.1 Objective

The validation objective is an independent assessment by a Third Party (Designated Operational Entity = DOE) of a proposed project activity against all defined criteria set for the registration under the Clean Development Mechanism (CDM). Validation is part of the CDM project cycle and will finally result in a conclusion by the executing DOE whether a project activity is valid and should be submitted for registration to the CDM Executive Board (CDM-EB). The ultimate decision on the registration of a proposed project activity rests at the CDM-EB and the Parties involved. The project activity discussed by this validation report has been submitted under the project title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung
1.2 Scope
The scope of any assessment is defined by the underlying legislation, regulation and guidance given by relevant entities or authorities. In the case of CDM project activities the scope is set by:
The Kyoto Protocol, in particular 12 and modalities and procedures for the CDM Decision 2/CMP1 and Decision 3/CMP.1 (Marrakech Accords) Further COP/MOP decisions with reference to the CDM (e.g. decisions 4 8/CMP.1) Decisions and specific guidance by the EB published under http://cdm.unfccc.int Guidelines for Completing the Project Design Document (CDM-PDD), and the Proposed New Baseline and Monitoring Methodology (CDM-NM) Baselines and monitoring methodologies (including GHG inventories) Management systems and auditing methods Environmental issues relevant to the sectoral scope applied for Applicable environmental and social impacts and aspects of CDM project activity Sector specific technologies and their applications Current technical and operational knowledge of the specific sectoral scope and information on best practice
The validation is not meant to provide any consulting towards the project participant (PP). However, stated requests for clarifications, corrective actions and/or forwards actions may provide input for improvement of the project design. Once TV SD receives a first PDD version, it is made publicly available at the UNFCCC webpage and at TV SDs webpage for starting a 30 day global stakeholder consultation process (GSP). In case of any request a PDD might be revised (under certain conditions the GSP could be repeated) and the final PDD will form the basis for the final evaluation as presented in this report. Information on the first and the final PDD version is presented in page 1. The only purpose of a validation is its use during the registration process as part of the CDM project cycle. Hence, TV SD cannot be held liable by any party for decisions made or not made based on the validation opinion, which will go beyond that purpose.
2 METHODOLOGY
The project assessment applies standard auditing techniques to assess the correctness of the information provided by the project participants. The assessment is based on the Clean Development Mechanism Validation and Verification Manual version 01. The work starts with appointment of team covering the technical area(s), sectoral scope(s) and relevant host country experience for evaluating the CDM project activity. Once the project is made available for the stakeholder consultation process, members of the team carry out the desk review, follow-up actions, resolution of issues identified and finally preparation of the validation report. The prepared validation report and other supporting documents then undergo an internal quality control by the CB climate and energy before submission to the CDM-EB. In order to ensure transparency, assumptions are clear and explicitly stated; the background material is clearly referenced. . TV SD developed methodology-specific checklists and protocol customised for the project. The protocol shows, in a transparent manner, criteria (requirements), the discussion of each criterion by the assessment team and the results from validating the identified criteria. The validation protocol serves the following purposes: It organises, details and clarifies the requirements a CDM project is expected to meet; It ensures a transparent validation process where the validator will document how a particular requirement has been validated and the result of the validation and any adjustment made to the project design. The validation protocol consists of three tables. The different columns in these tables are described in the figure below. The completed validation protocol is enclosed in Annex 1 to this report.
Validation Protocol Table 1: Conformity of Project activity and PDD Checklist Topic / Question Reference Comments GSP PDD Final PDD
The checklist is organised in sections following the arrangement of the applied PDD version. Each section is then further sub-divided. The lowest level constitutes a checklist question / criterion.
Gives reference to documents where the answer to the checklist question or item is found in case the comment refers to documents other than the PDD.
The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is further used to explain the conclusions reached. In some cases sub-checklist are applied indicating yes/no decisions on the compliance with the stated criterion. Any Request has to be substantiated within this column
Conclusions are presented based on the assessment of the first PDD version. This is either acceptable based on evidence provided (), or a Corrective Action Request (CAR) due to noncompliance with the checklist question (See below). Clarification Request (CR) is used when the validation team has identified a need for further clarification. Forward action request to highlight issues related to project implementation that require review during the first verification.
Conclusions are presented in the same manner based on the assessment of the final PDD version and further documents including assumptions presented in the documentation.
Validation Protocol Table 2: Resolution of Corrective Action and Clarification Requests Clarifications and corrective action requests Ref. to table 1 Summary of project owner response Validation team conclusion
If the conclusions from table 1 are either a Corrective Action, a Clarification or a Forward action Request, these should be listed in this section.
Reference to the checklist question number in Table 1 where the issue is explained.
The responses given by the client or other project participants during the communications with the validation team should be summarised in this section.
This section should summarise the discussion on and revision to project documentation together with the validation teams responses and final conclusions. The conclusions should be reflected in Table 1, under Final PDD.
In case of a denial of the project activity more detailed information on this decision will be presented in table 3.
Validation Protocol Table 3: Unresolved Corrective Action and Clarification Requests Clarifications and corrective action requests Id. CAR/CR of Explanation of the Conclusion for Denial
If the final conclusions from Identifier of This section should present a detail explanation, why table 2 results in a denial the the the project is finally considered not to be in referenced request should Request. compliance with a criterion with a clear reference to be listed in this section. the requirement which is not complied with.
2.1 Appointment of the Assessment Team

According to the technical area, sectoral scopes and experiences in the national business environment TV SD has composed a project team in accordance with the appointment rules of the TV SD certification body climate and energy. The composition of an assessment team has to be approved by the Certification Body (CB) ensuring that the required skills are covered by the team. The CB TV SD operates four qualification levels for team members that are assigned by formal appointment rules:
Assessment Team Leader (ATL) Greenhouse Gas Auditor (GHG-A) Greenhouse Gas Auditor Trainee (T) Experts (E)
It is required that the technical area and sectoral scope linked to the methodology is covered by the assessment team. Name Nikolaus Krger Sandeep Kanda Jayme Boehnert Qualification ATL GHG-A T Coverage of technical area Coverage of sectoral scope Host country experience
Nikolaus Krger is an environmental engineer and expert for emissions monitoring and quality assurance at the department TV SD Carbon Management Service. He is located in the TV SD Hamburg office and is also engaged as personally accredited verifier in the EU-ETS serving the Northern German market. Being GHG auditor for sectoral scopes 1, 4, 5, 8, 9, 10, 11, 12, 13 and asassessment team leader for CDM and JI projects he has already been involved in several CDM/JI activities with a special focus on industrial non-CO2 projects. Constitutive on 13 years experience at the department Environmental Service he has verified many metallurgical plants, refineries, chemical plants, waste treatment, power plants and process engineering in many types of facilities. One of his former focal points had been implementation and calibration of complex automatic EnvironmentData-Systems. Sandeep Kanda is an auditor for CDM / JI projects and energy and environment field expert at TV SD Industrie Service GmbH. He holds a master degree in energy systems engineering and also industrial safety and environmental management. Before joining the TV SD Industrie Service GmbH he has worked extensively on projects in energy sector, manufacturing industries, chemical industries and metal production. He has carried out energy audits and worked on development of CDM projects and methodologies in the aforementioned sectors. Jayme Boehnert is GHG auditor trainee for CDM projects. He holds a degree in mechanical engineering and is a qualified auditor for Quality management System (ISO 9001) based in TV SD PSB Philippines Inc. He has received extensive training in the CDM Validation and Verification processes and participated already in several CDM project assessments.
2.2 Review of Documents

A first version of the PDD was submitted to the DOE in May 2008. Subsequently, a request for deviation followed by a request for revision was submitted leading to revision of the methodology to version 3. This revision of the methodology was with regards to the adaption of AM0030 to newly available data provided by the most recent IAI Survey. The revised PDD following version 3 of the methodology was submitted in February 2009. This PDD version submitted by the PP and additional background documents related to the project design and baseline were then further reviewed to verify the correctness, credibility and interpretation of the presented information, furthermore a cross check between information provided and information from other sources have been done as initial step of the validation process. A complete list of all documents and proofs reviewed is attached as annex 2 to this report.
2.3 Follow-up Interviews

During the period 15-04-2009 to 17-04-2009, TV SD performed interviews, telephone conferences and physical site inspection with project stakeholders to confirm relevant information and to resolve issues identified in the document review. The table below provides a list of all key persons interviewed in this context. Name Mr. N. A. Setiawan Mr. Harmon Yunaz Mr. Ivan Mr. Faisal Hidayat Ms. Alin Pratidina Mr. Patrick Horka Title / Organisation Director, Production / Inalum Deputy General Manager, Production / Inalum Assistant Manager, Safety & Environment / Inalum Project Team Support / Inalum CDM Development Manager / South Pole Carbon Asset Management Ltd. Project Manager / South Pole Carbon Asset Management Ltd.
Ms. Syahrina Anggraini
Program Director / CER Indonesia
2.4 Further cross-check

During the validation process, the audit team also cross checked information provided in the PDD and information from sources other than that provided by the PP. The audit team performed an independent background investigation through search over the internet. Reference(s) to available information related to similar projects or technologies as the CDM project activity has been made. The documentation has also been reviewed against the approved methodology applied to confirm the appropriateness of formulae and correctness of calculations.
2.5 Resolution of Clarification and Corrective Action Requests

The objective of this phase of the validation is to resolve the requests for corrective actions and clarifications and any other outstanding issues which needed to be clarified for TV SD`s conclusion on the project design. The CARs and CRs raised by TV SD were resolved during communication between the client and TV SD. To guarantee the transparency of the validation process, the concerns raised and responses that have been given are documented in more detail in the validation protocol in annex 1. The final PDD version that was submitted in September 2009 serves as the basis for the final assessment presented herewith. Changes are not considered to be significant with respect to the qualification of the project as a CDM project based on the two main objectives of the CDM, i.e. to achieve a reduction of anthropogenic GHG emissions and to contribute to a sustainable development.
2.6 Internal Quality Control

As final step of a validation the final documentation including the validation report and the protocol have to undergo an internal quality control by the CB climate and energy, i.e. each report has to be finally approved either by the head of the CB or the deputy. In case one of these two persons is part of the assessment team approval can only be given by the other one. After confirmation of the PP the validation opinion and relevant documents are submitted to the EB through the UNFCCC web-platform.
3 FINDINGS
The assessment work and the main results are described below in accordance with the VVM reporting requirements. The reference documents indicated in this section and Annex 1 Validation protocol (VP) are stated in Annex 2 Information reference list (IRL).
3.1 Approval
The project participants are PT. Indonesia Asahan Aluminium (Inalum) from Indonesia (Host country) and South Pole Carbon Asset Management Ltd. (South Pole) from Switzerland (Annex-1 country. The host Party Indonesia and further participant Switzerland meet the requirements to participate in the CDM. The Designated National Authority (DNA) of Indonesia has issued a LoA (E. 280 /Dep.III/LH/07/08) [IRL#79] on 31 July 2008 authorizing PT. Indonesia Asahan Aluminium as a project participant. The DNA of Switzerland has also issued a LoA (G514-3487) [IRL#80] on 25 May 2009 authorizing South Pole Carbon Asset Management Ltd. as a project participant. TV SD received these letters from the project participants directly and considers the provided letters as authentic. The LoA from Indonesia has further been cross-checked with the CDM project webpage sponsored by the Indonesian DNA, National Comission for CDM in Indonesia (NC-CDM) (http://dnacdm.menlh.go.id), which further confirms the approval of this CDM project. Furthermore, after checking the provided LoAs, TV SD confirms that both letters refer to the precise proposed CDM project activity title in line with the title in the PDD PFC Emission Reduction at PT. Indonesia Asahan Aluminium (INALUM) Kuala Tanjung. Both letters also indicate that each participating Party is a Party to the Kyoto Protocol, and that the participation in the PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung project is voluntary. The LoA from Indonesia also confirms that the proposed CDM project activity contributes to the sustainable development of Indonesia (host country). Based on the information given in these letters, TV SD considers the approval as unconditional with respect to these items. Both LoAs have been issued by the respective Partys DNA, National Commission on CDM (KOMNAS MPB), Indonesia and Federal Office for the Environment FOEN, Climate Unit, Switzerland, respectively. TV SD considers the requirements of the VVM ( 45-48) to be complied with. The LoAs do not specify a version number of the PDD or validation report. The corresponding references included to LoAs, PDD and validation report are consistent.
3.2 Participation
The participants of the project activity have been approved by the corresponding Parties, which is confirmed by the issued LoAs. The means of validation were equivalent to those described in section 3.1 in regard to the approval process of the project activity.
3.3 Project design document

The PDD is compliant with relevant form and guidance as provided by UNFCCC.
The most recent version of the PDD form was used. TV SD considers that the guidelines for the completion of the PDD in their most recent version have been followed. Relevant information has provided by the participants in the applying PDD sections. Completeness was assessed through the checklist included to Annex 1 of this report.
3.4 Project description

The following description of the project as per PDD could be verified during the on-site audit: The project activity involves the reduction of perfluorocarbons (PFC) emissions in the Aluminium smelting facility of Inalum. The Aluminium smelting facility at Inalum was started in 1982 uses the center work pre-bake cell technology with bar brake (CWPB) and consists of 3 pot lines with 510 pots. The facility is located in Kuala Tanjung, 115 kilometers South East of Medan, the capital city of North Sumatera Province, Republic of Indonesia [IRL#4-10]. The project activity is Per-Fluorocarbons (PFCs) emission reduction project through anode effect (AE) reduction by incorporating a new algorithm in the control system of the Aluminium smelters, at Inalum. The AE reduction is being achieved by replacement of the software and hardware from CEGELEC (baseline) with a new ALCAN ALESA system (project) [IRL#11-13]. The information presented in the PDD on the project description is consistent with the actual planning and implementation of the project activity. This was validated during the on-site audit wherein relevant stakeholder and personnel with knowledge of the project were interviewed. The information provided was also cross-checked through the submitted documentary evidence as indicated in the annex-2: information reference list. In light of the above, TV SD confirms that the project description as included to the PDD is sufficiently accurate and complete in order to comply with the requirements of the CDM.
3.5 Baseline and monitoring methodology

3.5.1 Applicability of the selected methodology
Compliance with each applicability condition as listed in the chosen baseline and monitoring methodology AM0030, Version 03 has been demonstrated. The assessment was carried out for each applicability criteria and included among others the compliance check of the local project setting with the applicability conditions in regard to baseline setting and eligible project measures. This assessment also included the review of secondary sources which sustain that applicability conditions are complied with. The Methodology specific protocol included to the Annex 1 documents the assessment process, including the steps taken. The results on the compliance check as well as the relevant evidence are explicitly presented in annex 1. INALUM uses center work pre-bake cell technology with bar brake (CWPB) as checked through physical inspection and other documents. The production capacity, before and after the project activity was checked through the past 5 years audited annual reports. Other documentary evidence for supporting the same has been provided which indicate that the aim of the project is primarily to reduce the PFC emissions [IRL#4, 10, 21]. The start date of the INALUM Aluminium smelting facility has been indicated as January 1982 in the PDD. The same has been verified from various sources as follows: (http://www.genisim.com/aluminum/smelters/inalum.htm www.expozaragoza2008.es/ContenidosAgenda/tda/ST0921.pdf). List of primary Aluminium smelters and producers of the world has been provided. Other documentary evidence for
supporting the same has been provided which indicate that the start date of the facility is much before 31 December 2002 [IRL#5-10]. As the project activity start date is after 31 December 2005, the historical data before the project activity, from April 2004 to September 2007 has been provided regarding current efficiency, anode effect and Aluminium production. The same has been checked during the onsite visit. Documentary evidence supporting the same has been provided [IRL#21, 22, 56]. The Aluminium smelting facility comprises before and after project implementation 3 potlines with 510 pots in total. The same has been verified during the on-site visit [IRL#4, 10, 21]. The historical data provided for the project indicates that by increasing the electric current in the pots the Aluminium production gets increased. The correlation between monthly Aluminium production and the monthly electricity consumption from April 2004 until project implementation start in October 2007 has been checked. The data used arrives from normal operation conditions showing stable production process also with higher currents [IRL#21, 22, 56, 57]. TV SD confirms that the chosen baseline and monitoring methodology is applicable to the project activity. Emission sources which are not addressed by the applied methodology and which are expected to contribute more than 1% of the overall expected average annual emissions reduction have not been identified.
3.5.2 Project boundary

The project boundary was assessed in the context of physical site inspection, interviews and based on the secondary evidence received on the design of the project. The project boundary encompasses the physical site of the smelter facility pot-lines, containing three pot-lines (pot-line No. 1, 2 and 3) with a total of number of 510 pots (170 pots per pot-line). The most relevant documentation assessed in order to confirm the project boundary have been validated during the validation process using standard audit techniques, furhter details of any observation are transparently presented in the annex 1. Hence TV SD confirms that the identified boundary and the selected sources and gases (CF4 and C2F6) as documented in the PDD are justified for the project activity.
3.5.3 Baseline identification

As per the methodology, the PDD applies steps of the latest approved version 5.2 of the Tool for the demonstration and assessment of additionality to identify the baseline scenario. As per Step 1, all the baseline scenarios as indicated in the methodology have been considered and discussed in the methodology. The following scenarios have been considered: 1. The proposed project activity not undertaken as a CDM project activity. 2. All other plausible and credible anode effect mitigation alternatives to the project activity that deliver outputs with comparable quality, properties, and application areas: Control measures (automatic and manual control system improvements); Quality measures (changing the type of alumina). 3. No implementation of any anode effect mitigation measure. It was clarified during the on-site audit that Inalum is not a party to the International Aluminium Institute (IAI) PFC initiative. The actions taken in the past for improvements have been voluntary initiatives. The voluntary actions taken by Inalum in the past (2003 - 2007) have been validated during the on-site audit based on documentary evidences [IRL#4, 23-29]. Discussion on alternative 2 has been indicated and is considered not as a baseline scenario, as in the past various upgrades have been carried out by Inalum with the primary intention of increasing production. Automatic controls
have been already carried out in the past, manual controls are not considered. The documentary evidence to support the upgrades depicted have been submitted [IRL#23, 24, 28, 29]. As several suppliers deliver the Alumina, it faces a strict quality control. Related quality standard documents have also been checked during site visit [IRL#4, 25-27]. The PDD section B.4 has been revised indicating continuation of situation before the project activity as a feasible baseline scenario. The baseline scenario alternatives are in compliance with all applicable legal and regulatory requirements existing in Indonesia. As per Step 2, steps 2 and 3 of the Tool for the demonstration and assessment of additionality have been used for assessment and exclusion of the alternatives selected in the first step from further consideration to identify the baseline scenario. The resulting scenario corresponds to absence of implementation of any anode effect - continuation of current practice without any implementation of any anode effect mitigation measure. Thus, the following baseline scenario has been defined: Baseline scenario - The baseline scenario has been identified as Scenario 3: No implementation of any anode effect mitigation measure. The information presented in the PDD has been validated by a first document review of all the data, further confirmation based on the on-site visit and a final step by cross checking the information with documentary evidences and similar relevant projects. The sources referenced in the PDD have been quoted correctly. A verifiable description of the baseline scenario has been included to the PDD. In regard to item 86 of VVM, TV SD confirms that: 1. All the assumptions and data used by the project participants are listed in the PDD, including their references and sources; 2. All documentation used is relevant for establishing the baseline scenario and correctly quoted and interpreted in the PDD; 3. Assumptions and data used in the identification of the baseline scenario are justified appropriately, supported by evidence and can be deemed reasonable; 4. Relevant national and/or sectoral policies and circumstances are considered and listed in the PDD. 5. The approved baseline methodology has been correctly applied to identify the most reasonable baseline scenario and the identified baseline scenario reasonably represents what would occur in the absence of the proposed CDM project activity.
3.5.4 Algorithm and/or formulae used to determine emission reductions

TV SD has assessed the calculations of project emissions, baseline emissions, leakage and emission reductions. The parameters and equations presented in the PDD and further documentation have been compared with the information and requirements presented in the methodology, AM0030, Version 03. Corresponding calculations were carried out based on calculation spreadsheets. The equation comparison has been made explicitly following all the formulae presented in the calculation files.
3.5.4.1 Baseline Emissions

The calculation of the baseline emissions follows the procedures described in the methodology. The methodology requires that: historical data of the facility with respect to current efficiency, Aluminium production, and anode effect are available for three or more years prior to the project implementation; the stability of the anode effect is to be observed taking into account specific PFC emission trends; to determine the baseline emission factor, data is to be selected for a period of measurement corresponding to the most stable and lowest anode effect (anode effect frequency, duration and/or
overvoltage); the minimum period being 6 months, with the number of measurements statistically representative for the period. Thus, in accordance with the methodology, Tier 3 method has been selected as the manual termination of anode effects is less than 95%. The over-voltage method has been adopted for baseline due to slow, repetitive anode effect kill practices. Baseline emissions were calculated using the overvoltage method, as it is considered the most suitable and conservative option as the baseline CEGELEC system killed anode effects with a slow, repetitive practice and emerges in a lower emission factor when comparing with the derived emission factor based on the slope method which is applicable for aggressive fast kill anode effect practices. The formulae required for the determination of baseline emissions, enabling a complete identification of parameter to be used has been correctly presented, as per the methodology. Over-voltage coefficient has been determined by simultaneous measurements of emissions and collection of anode effect data over an appropriate period of time defined as atleast 72 hours. The measurements have been carried out before the project implementation for more than 72 hours and reported by an independent measurement team, in accordance with the IAI / USEPA protocol. The measurements have been carried out to calculate the IPCC Tier 3 baseline OVC and weight fraction of C2F6/CF4 from the PFC measurements. CF4 and C2F6 measured in the exhaust ducts of Aluminium electrolysis cells by Fourier Transform Infrared (FTIR) spectrometry. The baseline AEO is based on statistically corrected 2 years historical data available before the project implementation. To account for uncertainty the 95% confidence interval (Students tdistribution) values is determined. The lower bound of 95% is chosen to result in a conservative value of the emission factor [IRL#4, 54, 56-59] Further, as per the methodology, as the baseline emissions per tonne of Aluminium produced (t CO2e/t Al) are more than the average value of PFC emission per tonne of Aluminium produced according to the most recent published IAI Survey for the current technology (t CO2e/tAl) [IRL#55]. Thus the later has been taken as the baseline emission factor. The values presented in the PDD are considered reasonable based on the documentation reviewed, further references and the result of the interviews [IRL#4, 54-60]. The baseline methodology has been correctly applied following the requirements. The estimated baseline emissions can be confirmed as the same have been replicated by the audit team using the information provided. Detailed information on the verification of the parameters used in the equations can be found in annex 1.
3.5.4.2 Project emissions

The slope method is considered for the calculation of emission factors for project emissions as it is applicable for aggressive fast kill anode effect practices. For ex-ante estimation of project emissions, the IPCC default slope coefficient and weight fraction values adjusted by uncertainty is used together with the targeted AEF and AED after project implementation to determine the ex-ante emission factor. AEF and AED will be measured continuously during the whole project period and will be used for ex-post emission factor calculation. The ex-post slope coefficient and C2F6 / CF4 weight fraction will be defined by conducting on-site measurements every three years or less during the crediting period following the IAI / USEPA Protocol as described in the methodology.
3.5.4.3 Leakage
There is no leakage expected to occur in this type of projects.
3.5.4.4 Emission Reductions

In summary, the calculation of the baseline emissions, project emissions and the emission reductions, respectively, can be considered as correct. The assumptions and data used to determine the emission reductions are listed in the PDD and all the sources have been checked and confirmed
[IRL#4, 54-60]. Based on the information reviewed it can be confirmed that the sources used are correctly quoted and interpreted in the PDD.
3.6 Additionality
The additionality of the project has been presented in the PDD in accordance with the methodology using the latest approved version 5.2 of the Tool for the demonstration and assessment of additionality. The considerations incorporated in the methodology to the additionality tool to ensure consistency between the procedure to identify the most plausible baseline scenario and the determination of additionality has been applied correctly. The approach used in the PDD has been assessed first based on desk review followed by on-site audit. On site the additionality has been discussed principally with: Mr. Harmon Yunaz, Deputy General Manager, Production, Inalum. Furthermore, documents have been reviewed on-site (for details please refer annex 2 - IRL). The data, rationales, assumptions, justifications and documentation provided have been checked using local knowledge and sectoral and financial expertise. The assessment of the additionality has been done as per the following steps.
3.6.1 Prior consideration of the clean development mechanism

The project start date has been validated as 27th February 2007, based on the signed purchase contract between Inalum and Alcan Alesa, to replace the process control system. Since the start date was before the validation information on the delay and early consideration of CDM was provided and the same has been validated in accordance with EB-49, Annex-22, as follows: Description Awareness of the CDM prior to the project activity start date Communications with the Environmental agency of North Sumatera on CDM Decision by the Board of Directors to implement the project activity taking CDM into consideration Project start date Continuing and real actions to secure CDM status Communications with the CDM consultants - CER Indonesia (Cerindo) and South Pole Agreement between Inalum and South Pole for CDM development. Order to DOE for validation 12th Feb 2007 - 16th Jul 2007 30th Aug 2007 8th April 2008 40 - 44 45 46, 47 29th Sep 2003 - 8th Jun 2006 2nd Oct 2006 27th Feb 2007 30 33, 36 38 69 Timeline IRL # (Annex 2)
The documentation submitted as proofs to justify these events demonstrated that the project proponents had considered CDM since the inception of the project and continuing and real actions were taken to secure CDM status for the project in parallel with its implementation.
3.6.2 Identifications of alternatives

The list of alternatives presented in the PDD includes the project activity undertaken without being registered as CDM project and all plausible scenarios taking into account the local and sectoral situations. Hence the list of alternatives is considered to be complete. For further details, please refer section 3.5.3 Baseline identification.
3.6.3 Investment analysis

Investment analysis has been carried out for the project. Investment comparison analysis with NPV as an indicator has been opted for carrying out the investment analysis and the same has been found to be the appropriate analysis method. The two cases that have been considered by the PP for the NPV analysis are as follows: Case 1: Introduction of the new process control system leading to energy efficiency and Aluminium production increase (Project activity); and Case 2: No introduction of the new process control system i.e., continuation of current practice without any implementation of any anode effect mitigation measure and at the same time Aluminium production increase by increasing the electric current in the pot (resulting in higher electricity consumption). In accordance with the methodology: For Case 1, the PP has calculated the NPV taking into account: - Cash inflows due to electricity saving potential and the Aluminium production increase potential due to the project activity; and - Cash outflows associated with the Aluminium production (non-electricity portion) and the new process control system. The electricity savings and the Aluminium production increase is on account of the reduced anode effects (frequency and duration) due to the project activity. As the project is already implemented, therefore the indicated electricity saving potential and the Aluminium production was checked during the on-site validation audit and can be confirmed. For Case 2, the PP has calculated the NPV taking into account: - Cash inflows due to incremental Aluminium production; and - Cash outflows associated with Aluminium production (non-electricity portion); and due to the higher electricity demand to increase the Aluminium production, indicated as Aluminium production cost (electricity portion). The estimation of the electricity that would have been required in the absence of the project activity to achieve the same amount of production as in the project activity is based on the historical electricity consumption per unit Aluminium production. It is assumed that the electricity required per unit of incremental Aluminium production would be similar to the historical electricity consumption per unit Aluminium production. Further, as the estimate of this parameter is to be used in the NPV analysis therefore the expense associated with the parameter has been directly presented in monetary terms. The estimation of the expense towards electricity required for the incremental Aluminium production is based on the incremental Aluminium production multiplied with the electricity cost associated with per unit Aluminium production i.e., Aluminium production cost (electricity portion). The approach used by the PP for the estimation of electricity for case 2 is considered appropriate and deemed acceptable owing to the demonstrated operational stability. The PP has submitted the spreadsheet for the investment analysis. The indicated values have been checked from the stated sources in the spreadsheet. The guidance on the assessment of investment analysis (EB39, Annex 35) has been followed. The input values for the analysis have been validated through the indicated sources and the NPV calculation is deemed to be correct [IRL#4, 22, 48, 49, 50, 51, 69]. The Aluminium production costs (non-electricity portion and electricity portion), Aluminium sales price and electricity purchase rate have been validated from the Financial Statement and Annual Reports for Financial Year 2005 [IRL#22, 49];
Incremental Aluminium production and additional electricity savings have been checked from the internal document indicating comparison of old and new system Merit-Demerit of Renewal Procom and further cross-checked with actual data during on-site audit and can be confirmed [IRL#4, 49, 50]; The estimation of the expense towards electricity required for the incremental Aluminium production is based on the incremental Aluminium production multiplied with the electricity cost associated with per unit Aluminium production i.e., Aluminium production cost (electricity portion) validated from the Financial Statement for Financial Year 2005 [IRL#22, 50]; The cost associated with the new process control system has been validated from the Contract agreement with Alcan Alesa [IRL#69]; and Discount rate for the NPV analysis is based on the prevalent interest rate for investments before project activity start date obtained from www.bi.go.id [IRL#51].
The NPV analysis has been restricted to 10 years based on the contractual agreement provided by the Alcan Alesa to Inalum stating the spare part availability and life time up to 10 years [IRL#69, 70]. The submitted referenced documents have been found to be relevant and consistent with the information provided in the PDD for the investment analysis [IRL#49-51]. Based on the above the input values have been found to be reasonable and correct. The financial calculations are correct [IRL#48]. The NPV of the project comes out to be negative without CDM revenues. The baseline scenario gives a positive NPV and is therefore higher than the project activity NPV. Further, it has been checked that even if the NPV analysis is extended for a period 20 years then also the outcome of the investment comparison analysis remains unaltered with Case 1 (project activity) having negative NPV and Case 2 (baseline) still having positive NPV. The sensitivity analysis is carried out for 10% variation of the following key parameters project cost and electricity price. The sensitivity analysis indicated that the project NPV remains negative even with 10% variation of the above said parameters. TV SD confirms that the underlying assumptions are appropriate and the financial calculations are correct.
3.6.4 Barrier analysis

The project participants have also used the barrier analysis in order to demonstrate the additionality of the project. The prevailing practice barrier has been presented in the PDD. Inalum is the only Aluminum smelting plant in the host country Indonesia. The analysis has therefore been carried out for the Asian region. The control system (Blue Box) has been provided by Alcan Alesa. The reference letters from Alcan Alesa indicate that no smelter uses any version of Blue Box within Asia and no smelter with a CWPB system uses any kind of Blue Box versions globally. This barrier does prevent the project activity and would not prevent the baseline of the project; this can be confirmed based on the documentation review, interviews and local and sectoral expertise of the assessment team [IRL#4, 52, 53]. Taking into account the description of the validation of the barrier presented above, the assessment team can confirm with reasonable certainty that the barrier is credible and correctly presented to demonstrate the additionality of the project.
3.6.5 Common practice analysis

The region for the common practice analysis has been defined as Indonesia and further extended even till Far East Asia region. The project activitys technology can be found in different country regions, where different situations can appear. Hence the region has been defined taken into account
the kind of technology and the industry type. The assessment team has reviewed the approach presented in the PDD and can confirm that the relevant parameters as location, infrastructure, economical situation and development has been taken into account in order to define the region to be use for the common practice. The publication, Primary Aluminium Smelters and Producers of the World from Aluminium-Verlag Marketing & Kommunikation GmbH Duesseldorf [IRL#53] gives credible reference to all existing worldwide Aluminum smelters. Hence the presented region can be considered appropriate for the common practice analysis. The project activity is demonstrated as the first of its kind as it is the only smelter operating in Indonesia. Further, supporting evidences have also been provided by the PP indicating that in Far East Asia region also there is no smelter wherein the new technology of Blue Box by Alcan Alesa has been installed. This has been validated based on the reference list of Alcan Alesa Pot Control Systems in the World Summary and the letter from Alcan Alesa [IRL#52]. The documents indicate that Inalum is the only company in Asia with CWPB pot type that is using Alcan Alesa technology. This information confirms that the project is first of its kind, as stated in the PDD is correct. Hence it can be confirmed that the proposed CDM activity is not a common practice in the defined region.
3.7 Monitoring plan

The monitoring plan presented in the PDD complies with the requirement of the methodology. The assessment team has checked all the parameters presented in the monitoring plan against the requirements of the methodology; no deviations relevant for the project activity have been found in the plan. The monitoring plan given in the PDD is as per the methodology. As Slope method is applied for calculating the project emissions the parameters anode effect duration (AED), anode effect frequency (AEF), Slope Coefficient and Weight fraction are included in the monitoring plan along with the Aluminium production. AEF and AED will be measured continuously during the whole project period. The slope coefficient and C2F6 / CF4 weight fraction will be defined by conducting on-site measurements every three years or less during the crediting period following the IAI / USEPA Protocol as described in the methodology. The procedures have been reviewed by the assessment team through document review and interviews with the relevant personnel; this information together with a physical inspection allows the assessment team to confirm that the proposed monitoring plan is feasible within the project design. The major parameters to be monitored have been discussed with the PPs especially regarding the metering, the data management and in general the quality assurance and quality control procedures to be implemented in the context of the project. Hence it is expected that the PPs will be able to implement the monitoring plan and the emission reductions achieved can be reported ex-post and verified [IRL#4, 61-68].
3.8 Sustainable development

The project has received the host country approval letter which indicates that the project will contribute to the sustainable development in Indonesia [IRL#79].
3.9 Local stakeholder consultation

Relevant stakeholders have been consulted, namely the employees, local residents, local Government bodies and other local agencies. Documents supporting the same have been checked during the onsite visit. Invitation letters have been used to invite the local stakeholders for a meeting. There
were no adverse comments received for the project. The stated information in the PDD has been validated based on the submitted documents as follows: 1. Invitation for stakeholder consultation meeting [IRL#75]; 2. List of the participants in the local stakeholder consultation meeting [IRL#76]; 3. Minutes of meeting of the stakeholder consultation meet [IRL#77]. As a result, TV SD considers the applied process for the local stakeholder consultation as adequate and appropriate [IRL#78].
3.10 Environmental impacts

There are no negative environmental impacts expected from the project activity as it pertains only to the implementation of improved control measures through the new process control system hardware and software implementation. For implementing the project activity there is no requirement from the Indonesian Government (Host country) to carry out an EIA. Evidence pertaining to the EIA carried out earlier and the subsequent environmental clearances have been checked during the on-site visit. Further, the plant has all the necessary clearances and was under operation as checked during the on-site visit [IRL#71-74].
4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS

TV SD published the project documents on UNFCCC website by installing a link to TV SDs own website and invited comments by Parties, stakeholders and non-governmental organisations during a period of 30 days. The following table presents all key information on this process:
webpage: First GSP: http://www.netinform.de/KE/Wegweiser/Guide2_1.aspx?ID=5184&Ebene1_ID=26&Ebene2_ID=1524&mode=1 Second GSP: https://cdm.unfccc.int/Projects/Validation/DB/H3WT2G9YSO8XP4IL4SHDDNMG0XQCKJ/view.html Starting date of the global stakeholder consultation process: Starting Date of first GSP: 27-05-2008
Starting Date of second GSP: 27-02-2009 Comment submitted by: None Response by TV SD: Issues raised: -
5 VALIDATION OPINION
TV SD has performed validation in accordance with the VVM, version 1, (EB44, Annex 3) of the following proposed CDM project activity: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Standard auditing techniques have been used for the validation of the project. Methodology-specific protocol customised for the project has been prepared to carry out the audit and present the outcome in a transparent and comprehensive manner. The review of the project design documentation, the subsequent follow-up interviews and the further cross check of references have provided TV SD with sufficient evidence to determine the fulfilment of stated criteria in the protocol. In our opinion, the project meets all relevant UNFCCC requirements for the CDM. Hence TV SD will recommend the project for registration by the CDM Executive Board. An analysis as provided by the applied methodology demonstrates that the proposed project activity is not a likely baseline scenario. Emission reductions attributable to the project are hence additional to any that would occur in the absence of the project activity. Given that the project is implemented as designed, the project is likely to achieve the estimated amount of emission reductions in a measurable and verifiable manner as specified within the final PDD version. The validation is based on the information made available to us and the engagement conditions detailed in this report. The validation has been performed following the VVM requirements. The only purpose of this report is its use during the registration process as part of the CDM project cycle. Hence, TV SD can not be held liable by any party for decisions made or not made based on the validation opinion, which will go beyond that purpose.
Munich, 20-04-2010
Hamburg, 20-04-2010
Thomas Kleiser Certification Body climate and energy TV SD Industrie Service GmbH
Nikolaus Krger Assessment Team Leader
Validation of the CDM Project: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung
Annex 1: Validation Protocol
Validation Protocol (VP)

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42
Table 1: Conformity of Project activity and PDD

CHECKLIST TOPIC / QUESTION Ref. COMMENTS GSP PDD Final PDD
A. General description of project activity

A.1. Title of the project activity
A.1.1. Does the used project title clearly enable to identify the unique CDM activity? 1 The project activity clearly enables to identify the project activity as a PFC emission reduction project in the Aluminium manufacturing facility at Indonesia Asahan Aluminium (INALUM) Kuala Tanjung. The revision number and the date are indicated in the submitted PDD. Yes, the date is consistent with the time line of the projects history.
A.1.2. Are there any indication concerning the revision number and the date of the revision? A.1.3. Is this consistent with the time line of the projects history?
A.2.
Description of the project activity

A.2.1. Is the description delivering a transparent overview of the project activity? 1, 3, 4, 510 Yes, the description is delivering a transparent overview of the project activity. The project activity is Per-Fluorocarbons (PFCs) emission reduction project through anode effect (AE) reduction by incorporating a new algorithm in the control system of the Aluminium smelters, at INALUM. The Aluminium smelting facility uses center work pre-bake cell technology with bar brake (CWPB). The INALUM plant has a capacity of producing 250,000 tonnes per annum (TPA) of Aluminium, has 510 pots and 3 pot-lines. The AE reduction is being achieved by reduction in AE frequency and AE duration by replacement of the software and hardware from CEGELEC (baseline) with a new ALCAN ALESA system (project). The contribution of the project activity to sustainable development is through improved process control system. The description provided in the PDD was validated during the on
Table 1 is applicable to AM0030, Version 03
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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. COMMENTS site audit and also through the submitted documentary evidence as indicated in the annex-2: information reference list (IRL). A.2.2. What proofs are available demonstrating that the project description is in compliance with the actual situation or planning? A.2.3. Is the information provided by these proofs consistent with the information provided by the PDD? A.2.4. Is all information presented consistent with details provided by further chapters of the PDD? 1, 310 1, 310 1 The project activity has been implemented and the switching over details has been provided. Documentary evidence supporting the same have been submitted and indicated in the IRL. The submitted documents support the project description and its compliance with the actual situation. This has been checked during on-site audit. Yes, the information presented in consistent. GSP PDD Final PDD
A.3.
Project participants
A.3.1. Is the form required for the indication of project participants correctly applied? A.3.2. Is the participation of the listed entities or Parties confirmed by each one of them? 1, 2 1, 7981 1 Yes, the form required for the indication of project participants has been correctly applied Clarification Request No. 1. Please submit documents indicating the confirmation of the listed project participants - PT. Indonesia Asahan Aluminium (INALUM) and South Pole Carbon Asset Management Ltd. Yes, the information on participants provided is consistent with the details provided by further chapters of the PDD (in particular annex 1). CR1
A.3.3. Is all information on participants / Parties provided in consistency with details provided by further chapters of the PDD (in particular annex 1)?
A.4.
Technical description of the project activity

Location of the project activity 1, 4 Yes, the information provided on the location of the project activity allows for a clear identification of the project site. The smelter pot A.4.1.1.Does the information provided on the location of the project activity allow for a
A.4.1.
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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION clear identification of the site(s)? Ref. COMMENTS lines and the port delivering Alumina can be seen on the Google earth picture. The GPS coordinates have been confirmed during on-site visit. 1, 411 No licenses or ownership documents are needed as the project activity simply replaces an existing system within the aluminium plant. The contract with the process control system provider (Alcan Alesa) and the permission to operate the plant has been checked during on-site visit. The project activity belongs to Category 9 Metal Production, as per the CDM sectoral scope, the same has been correctly identified and indicated in the PDD. Corrective Action Request No.1. Please correct the version of the methodology stated in section A.4.2 of the PDD. The scenario existing prior to the start of the implementation (baseline) and the ones being implemented within the project activity, with a list of the equipment(s) and systems are indicated. The stated hardware and software configuration for the project activity and baseline system indicates that the technical design corresponds to current good practice. The project activity system has higher processing speed, quicker data measurement capacity and is user friendly, as compared to the baseline system. The automation supplier website: (http://www.alcanalesa.com/en/4_2_pcu_blue_box.html) and the International Aluminium Institute (IAI) report on the Aluminium industrys global Perfluorocarbon gas emissions reduction Pro GSP PDD Final PDD
A.4.1.2.How is it ensured and/or demonstrated, that the project proponents can implement the project at this site (ownership, licenses, contracts etc.)? A.4.2. Category(ies) of project activity
A.4.2.1.To which category(ies) does the project activity belonging to? Is the category correctly identified and indicated?
1-4
CAR1
A.4.3.
Technology to be employed by the project activity 1, 12, 13, 55
A.4.3.1.Does the technical design of the project activity reflect current good practices?
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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. COMMENTS gramme Results of the 2005 anode effect survey, 9th May 2007 and subsequently the Results of the 2006 anode effect survey, 1st July 2008 have also been checked. The documents supporting the information have been provided. Technology related documents have been checked during the onsite visit A.4.3.2.Does the description of the technology to be applied provide sufficient and transparent input/ information to evaluate its impact on the greenhouse gas balance? A.4.3.3.Does the implementation of the project activity require any technology transfer from annex-I-countries to the host country? A.4.3.4.Is the technology implemented by the project activity environmentally safe? 1, 3 Yes, it is indicated that the accurate and fast response by the project activity system would reduce the anode effect and thereby the PFC emissions emanating from the same. Further the project activity system has three input parameters current, voltage and beam position (for anode cathode distance) which results in better control. Yes, it has been indicated in the PDD that the technology transfer from annex-I-countries to the host country is involved in the project activity. Technology from ALCAN (from annex-I-country) is being used in the project activity. The technology implemented by the project activity through the change of control system - installation of hardware and software system does not contain any safety or health risks and are considered to be environmentally safe. Yes, the information provided is in compliance with the actual situation. The same has been verified during the on-site audit. INALUM is the only Aluminium smelting facility in the host country, Indonesia. The CF4 emission factor of the smelter after implementing the new technology is expected to be half of the global median value of the CF4 emission factor according to the IAI report. As it has been stated in the PDD that guaranteed software sup GSP PDD Final PDD
1, 39, 69 1
A.4.3.5.Is the information provided in compliance with actual situation or planning? A.4.3.6.Does the project use state of the art technology and / or does the technology result in a significantly better performance than any commonly used technologies in the host country? A.4.3.7.Is the project technology likely to be
1, 4 1, 4
1, 4,
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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION substituted by other or more efficient technologies within the project period? Ref. 70 COMMENTS port and hardware replacement parts will be provided during ten years, thus it is unlikely that the project technology will get substituted within the project period. This has been further validated from the letter on renewal of process control system and as per contractual agreement provided by Alcan Alesa to Inalum stating the life time up to 10 years. Guarantee and other associated supporting documents have been checked during on-site visit. Overseas training at Alesas office in Zurich, Switzerland has been carried out by the plant professionals and regular in-house trainings have been carried out. Documents supporting the same have been submitted. The same has been confirmed during onsite interviews. The report on the overseas training carried out by the plant professionals and the in-house training module and schedule has been submitted. The project has been implemented. All the pots have been switched to the new control system as indicated in section A.2.2 of the PDD. The completion of installation / commissioning certificate has been checked during on-site visit. Yes, the form required for the indication of projected emission reductions has been correctly applied. Corrective Action Request No.2. Please correct the figure of Total estimated reductions (tonnes of CO2e) in the table in section A.4.4 of the PDD. GSP PDD Final PDD
A.4.3.8.Does the project require extensive initial training and maintenance efforts in order to be carried out as scheduled during the project period? A.4.3.9.Is information available on the demand and requirements for training and maintenance? A.4.3.10. Is a schedule available for the implementation of the project and are there any risks for delays? A.4.4.
1, 14, 16, 17 1, 15, 18 1, 4, 11
Estimated amount of emission reductions over the chosen crediting period 1, 2
A.4.4.1.Is the form required for the indication of projected emission reductions correctly applied? A.4.4.2.Are the figures provided consistent with other data presented in the PDD? A.4.5. Public funding of the project activity
CAR2
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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION A.4.5.1.Is the information provided on public funding provided in compliance with the actual situation or planning as available by the project participants? A.4.5.2.Is all information provided consistent with the details given in remaining chapters of the PDD (in particular annex 2)? Ref. 1, 20 COMMENTS It has been indicated that the project has been fully financed by INALUM. The investment approval letter by the Board of Directors checked during the on-site audit thus demonstrates that there is no ODA funding involved in the project activity. Yes, the information provided is consistent with the details given in remaining chapters of the PDD (in particular annex 2). GSP PDD Final PDD
1, 20
B. Application of a baseline and monitoring methodology

B.1. Title and reference of the approved baseline and monitoring methodology
B.1.1. Are reference number, version number, and title of the baseline and monitoring methodology clearly indicated? 1, 2, 3 Corrective Action Request No.3. Although, the reference number (AM0030), title of the baseline and monitoring methodology and the associated tools has been clearly indicated, please correct the version numbers of the methodology and the tool. Although the GSP PDD applies version 03 of the methodology, which is the most recent one, it is wrongly indicated in section B.1 of the GSP PDD. Please refer above. CAR3
B.1.2. Is the applied version the most recent one and / or is this version still applicable?
1, 2, 3
B.2.
Justification of the choice of the methodology and why it is applicable to the project activity
B.2.1. Is the applied methodology considered the most appropriate one? B.2.2. Criterion 1: Aim of project Is the project activity primarily aimed at measures to reduce the PFC emissions in Aluminium smelting facilities that use center work pre-bake cell technology with bar brake (CWPB) or point feeder systems 1, 2, 3 1, 3, 4, 10, Yes, the methodology is considered to be the most appropriate one. All the applicability conditions of the applied methodologies have been justified. Applicability checklist Criterion discussed in the PDD? Compliance provable? Compliance verified? Yes / No Yes Yes Yes
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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION (PFPB) and not towards aiming at increasing Aluminium production, with emission avoidance as a side-effect? Ref. COMMENTS INALUM uses center work pre-bake cell technology with bar brake (CWPB) as checked through physical inspection and other documents. The production capacity before and after the project activity was checked through the past 5 years audited annual reports. Other documentary evidence for supporting the same has been provided which indicate that the aim of the project is primarily to reduce the PFC emissions. 1, 510 Applicability checklist Criterion discussed in the PDD? Compliance provable? Compliance verified? Yes / No Yes Yes Yes GSP PDD Final PDD
B.2.3.
Criterion 2: Start date of the facility Did the Aluminium smelting facilities started operations before 31 December 2002?
The start date of the INALUM Aluminium smelting facility has been indicated as January 1982 in the PDD. The same has been verified from various sources as follows: http://www.genisim.com/aluminum/smelters/inalum.htm www.expozaragoza2008.es/ContenidosAgenda/tda/ST0921.pdf List of primary Aluminium smelters and producers of the world has been provided. Other documentary evidence for supporting the same has been provided which indicate that the start date of the facility is much before 31 December 2002. B.2.4. Criterion 3: Historical data Is at least three years of historical data available regarding current efficiency, anode effect and Aluminium production of the industrial facility from 31 December 2002 onwards or, in case of project activi1, 21, 22, 56 CAR4 Applicability checklist Yes / No Criterion discussed in the PDD? Yes Compliance provable? Yes Compliance verified? Yes As the project activity start date is after 31 December 2005, the
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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION ties with a starting date before 31 December 2005, from 3 years prior to the implementation of the project activity onwards, until the starting date of the project activity? Ref. COMMENTS historical data before the project activity, from April 2004 to September 2007 has been provided regarding current efficiency, anode effect and Aluminium production. The same has been checked during the on-site visit. Documentary evidence supporting the same has been provided. Corrective Action Request No.4. Please indicate the values of the historical data in the PDD along with the reference. 1, 4, 10, 21 Applicability checklist Yes / No Criterion discussed in the PDD? Yes Compliance provable? Yes Compliance verified? Yes The Aluminium smelting facility comprises before and after project implementation 3 potlines with 510 pots in total. The same has been verified during the on-site visit. Applicability checklist Yes / No Criterion discussed in the PDD? Yes Compliance provable? Yes Compliance verified? Yes The historical data provided for the project indicates that by increasing the electric current in the pots the Aluminium production gets increased. The correlation between the monthly aluminium production and the monthly electricity consumption from April 2004 until project implementation start has been indicated. The data used arrives from normal operation conditions showing the stable production process also with higher currents. Pilot test was
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GSP PDD
Final PDD
B.2.5. Criterion 4: Number of potlines and pots The existing number of potlines and pots within the system boundary is not increased during the crediting period at the facilities. The methodology is only applicable up to the end of the lifetime of existing potlines if this is shorter than the crediting period? B.2.6. Criterion 5: Operational stability Where it is demonstrated that, due to historical improvements carried out, the facility achieved an operational stability associated to a PFC emissions level that allows increasing the Aluminium production by simply increasing the electric current in the pots. This can be demonstrated for example by providing results of pilot tests carried out by the company? (The stability of the anode effect should be observed taking into account specific PFC emission trends)
1, 21, 22, 56, 57

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. COMMENTS not necessary as the production under normal conditions already varied by approximately 16% due to fluctuation in electricity supply. The same has been checked during the on-site visit. Documentary evidence supporting the same has been provided. GSP PDD Final PDD
B.3.
Description of the sources and gases included in the project boundary

B.3.1. Source: Anode effects in pots Gas: CF4 Type: Baseline Emissions 1, 3 Boundary checklist Source and gas discussed in the PDD? Inclusion / exclusion justified? Explanation / Justification sufficient? Consistency with monitoring plan? 1, 3 Boundary checklist Source and gas discussed in the PDD? Inclusion / exclusion justified? Explanation / Justification sufficient? Consistency with monitoring plan? 1, 3 Boundary checklist Source and gas discussed in the PDD? Inclusion / exclusion justified? Explanation / Justification sufficient? Consistency with monitoring plan? 1, 3 Boundary checklist Source and gas discussed in the PDD? Inclusion / exclusion justified? Explanation / Justification sufficient? Yes / No Yes Yes Yes
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Yes / No Yes Yes Yes Yes Yes / No Yes Yes Yes Yes Yes / No Yes Yes Yes Yes
B.3.2. Source: Anode effects in pots Gas: C2F6 Type: Baseline Emissions
B.3.3. Source: Anode effects in pots Gas: CF4 Type: Project Emissions
B.3.4. Source: Anode effects in pots Gas: C2F6 Type: Project Emissions

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION B.3.5. Is the spatial extension of project boundary clearly described? Does the geographical delineation of the project boundary encompass the physical site of the potlines involved in the project activity at the Aluminium production facility? B.3.6. Do the spatial and technological boundaries as verified on-site comply with the discussion provided by / indication included to the PDD? Ref. 1, 3 COMMENTS Consistency with monitoring plan? Yes CAR5 Yes, the spatial extension of project boundary has been clearly described. The 510 pots of the 3 lines have been included in the project boundary. Corrective Action Request No.5. Please correct the version of the methodology. GSP PDD Final PDD
1, 3, 4
The spatial and technological boundaries checked during the onsite visit confirm the compliance of information provided in the PDD.
B.4.
Description of how the baseline scenario is identified and description of the identified baseline scenario
B.4.1. Are the steps of the latest approved version of the Tool for the demonstration and assessment of additionality used in order to identify the baseline scenario? B.4.2. Step 1: Identification of baseline scenario candidates Have all technically feasible baseline scenario alternatives to the project activity been identified and discussed by the PDD? 1, 2, 3 Yes, the steps of the latest approved version of the Tool for the demonstration and assessment of additionality have been used to identify the baseline scenario. As per Step 1, all the baseline scenarios as indicated in the methodology have been considered and discussed in the methodology. The following scenario have been considered: 1. The proposed project activity not undertaken as a CDM project activity. 2. All other plausible and credible anode effect mitigation alternatives to the project activity that deliver outputs with comparable quality, properties, and application areas: Control measures (automatic and manual control system improvements);
1, 2, 3
Page A-10

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. COMMENTS Quality measures (changing the type of alumina). 3. No implementation of any anode effect mitigation measure. B.4.2.1.Is there discussion on scenario 1: The proposed project activity not undertaken as a CDM project activity (e.g. to fulfill voluntary initiatives as part of the IAI PFC initiative) 1, 2, 3, 4 Yes, it is indicated that scenario 1 is one of the baseline scenario candidates. Corrective Action Request No.6. Please indicate in the PDD details on the voluntary initiatives as part of the IAI PFC initiative. The description provided for the scenario is not consistent with the requirements. Please revise accordingly. Yes, discussion on alternative 2 has been indicated. Alternative 2 is not a baseline scenario as in the past various upgrades have been carried out with the primary intention of increasing production. Automatic controls have been already carried out in the past. Manual controls are not considered. The documentary evidence to support the upgrades depicted have been submitted. As several suppliers deliver the Alumina, it faces a strict quality control. Related quality standard documents have been checked during site visit Corrective Action Request No.7. Please correct the dates of the improvement stated. CAR6 GSP PDD Final PDD
B.4.2.2.Is there discussion on scenario 2: All other plausible and credible anode effect mitigation alternatives to the project activity that deliver outputs with comparable quality, properties, and application areas; for example Control measures: Automatic control system improvements - These improvements could be focused on the following aspects: feeding system, anode change, metal tapping, anode effect occurrence, etc; Improvements in the manual control focused on those aspects not embraced by the current automatic control system: increasing sampling frequency, increasing the manual killing of anode effect by
1, 2, 3, 4, 2329
CAR7
Page A-11

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION green poling, etc. Quality measures: Changing the type of alumina processed in order to improve alumina quality to avoid dissolution problems. B.4.2.3.Is there discussion on scenario 3: No implementation of any anode effect mitigation measure? This alternative might include: The implementation of any other measures focused on the improvement of the performance of equipment and/or the increase of the Aluminium production due to business-strategy practices; The continuation of the current situation (neither anode effect mitigation measures nor business-strategy practices are undertaken). B.4.3. Does the project identifies correctly and excludes those options not in line with regulatory or legal requirements? B.4.4. Have applicable regulatory or legal requirements been identified? B.4.5. Step 2: Identification of the baseline scenario Does the resulting scenario correspond to
Ref.
COMMENTS
GSP PDD
Final PDD
1, 2, 3, 4
Yes, discussion on alternative 3 has been carried out. Continuation of current practice has been stated as the possible baseline scenario. Corrective Action Request No.8. Is the continuation of the situation before the project activity not a feasible baseline scenario?
CAR8
1, 2, 3, 4 1, 4
Corrective Action Request No.9. Please indicate in the PDD details on the applicable legal and regulatory requirements. Corrective Action Request No.10. There is no identification of applicable regulatory or legal requirements identified in the PDD, please revise and indicate the same. Yes, the baseline scenario corresponds to continuation of current practice without any implementation of any anode effect mitigation measure.
CAR9
CAR10
1, 2, 3, 4
CAR11
Page A-12

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION no implementation of any anode effect mitigation measure? Ref. COMMENTS Corrective Action Request No.11. Please note that as per the methodology, if the resulting scenario does not correspond to absence of implementation of any anode effect mitigation measure, then this baseline methodology does not apply and another methodology should be used. GSP PDD Final PDD
B.5. Description of how the anthropogenic emissions of GHG by sources are reduced below those that would have occurred in the absence of the registered CDM project activity (assessment and demonstration of additionality):
B.5.1. If the starting date of the project activity is before the date of validation, is evidence available to prove that incentive from the CDM was seriously considered in the decision to proceed with the project activity? 1, 2, 4, 30 47, 69 The documentary evidence confirming the project chronology and CDM consideration has been checked during the on-site visit. Corrective Action Request No.12. Please indicate clearly the start date of the project activity in accordance with the CDM Glossary of terms. Further as the starting date of the project activity is before the start of validation, the complete chronology of the project from start date till date should be indicated in the PDD with evidences. Yes, investment analysis is being carried out for the project activity and after applying step 2a, benchmark analysis is opted. Clarification Request No. 2. Please submit the spreadsheet for the investment analysis. All formulas used in this analysis should be readable and all relevant cells viewable and unprotected. Please refer CR2 CAR12
B.5.2. In case of applying step 2 / investment analysis of the additionality tool: Is the analysis method identified appropriately (step 2a)?
1, 2, 3, 4, 48 51
CR2
B.5.3. In case of Option II (investment comparison analysis): Is the most suitable financial indicator clearly identified (IRR, NPV, cost benefit ratio, or (levelized) unit cost)? B.5.4. In case of Option III (benchmark analysis): Is the most suitable financial indicator
CR2
1, 2,
Please refer CR2
CR2
Page A-13

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION clearly identified (IRR, NPV, cost benefit ratio, or (levelized) unit cost)? B.5.5. In case of Option II or Option III: Is the calculation of financial figures for this indicator correctly done for all alternatives and the project activity? B.5.6. In case of Option II or Option III: Is the analysis presented in a transparent manner including publicly available proofs for the utilized data? Does the analysis consider the benefits associated with energy savings, increase of the alumina production, reduction of cost per tonne of aluminium, project aluminium cost, etc resulting from project activity B.5.7. Has the estimation been done for the electricity that would have been required in the absence of the project activity to achieve the same amount of production as in the project activity and the calculation of NPV done for this situation? B.5.8. Has the estimation of NPV done for the project activity? Is this NPV lesser than the above scenario? B.5.9. In case of applying step 3 (barrier analysis) of the additionality tool: Is a complete list of barriers developed that prevent the different alternatives to occur? B.5.10. In case of applying step 3 (barrier
Ref. 3 1, 2, 3
COMMENTS
GSP PDD
Final PDD
Yes, the investment analysis has been carried out for the project activity and the other alternative is the continuation of current practice that is no project. Further please refer CR2. Refer CR2 Corrective Action Request No.13. The estimation for the electricity that would have been required in the absence of the project activity to achieve the same amount of production as in the project activity and the calculation of NPV done is to be carried out for this situation. Please indicate the same in the PDD and provide the analysis. Refer CR2 and CAR13
CR2
1, 4, 48 51
CAR13
1, 4, 48 51
CR2 & CAR13
1, 4, 48 51 1, 4, 52, 53 1, 4,
Corrective Action Request No.14. The estimation of NPV has not been indicated in the PDD. Corrective Action Request No.15. Although barrier analysis has not been carried out for the project activity, for better clarity please indicate so in the PDD. Refer CAR 15
CAR14
CAR15
CAR15
Page A-14

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION analysis): Is transparent and documented evidence provided on the existence and significance of these barriers? B.5.11. In case of applying step 3 (barrier analysis): Is it transparently shown that the execution of at least one of the alternatives is not prevented by the identified barriers? B.5.12. Have other activities in the host country / region similar to the project activity been identified and are these activities appropriately analyzed by the PDD (step 4a)? Ref. 52, 53 1, 4, 52, 53 1, 4, 52, 53 Refer CAR 15 CAR15 COMMENTS GSP PDD Final PDD
Corrective Action Request No.16. Please provide further information on the other activities along with the supporting documents to substantiate the common practice analysis. INALUM is the only Aluminum smelting plant in the host country Indonesia. The common practice has therefore been carried out for the Asian region. The control system (Blue Box) has been provided by Alcan Alesa. The reference letters from Alcan Alesa indicate that no smelter uses any version of Blue Box within Asia and no smelter with a CWPB system uses any kind of Blue Box versions globally. Not applicable
CAR16
B.5.13. If similar activities are occurring: Is it demonstrated that in spite of these similarities the project activity would not be implemented without the CDM component (step 4b)? B.5.14. Is it appropriately explained how the approval of the project activity will help to overcome the economic and financial hurdles or other identified barriers (step 5)?
1, 4, 52, 53
1, 2, 3, 4, 48 53
Although there is no step 5 in the latest Tool for the demonstration and assessment of additionality, it has been indicated in the PDD that CDM revenues will help in improving the economics of this financially unattractive project.
Page A-15

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. COMMENTS GSP PDD Final PDD
B.6.
Emissions reductions
Explanation of methodological choices 1, 3 Yes, the explanation of the procedures provided in the methodology and its application to the project activity has been given appropriately. Tier 3 method has been selected as the manual termination of anode effects is less than 95%. B.6.1.1.Is it explained how the procedures provided in the methodology are applied by the proposed project activity? B.6.1.2.Is every selection of options/methods offered by the methodology (Tier 3 or Tier 2) correctly justified and is this justification in line with the situation verified on-site? (Tier 2 is applicable if it can be proven and documented that 95% of the anode effects are manually terminated (cell hood must be opened during termination of the anode effect), while in all other cases, tier 3 is applicable.) B.6.1.3.If Tier 3 method is used is appropriate justification (type of anode effect kill practice) given for the calculation method used? (1. The slope method should be used with aggressive fast kill anode effect practices; 2. The over-voltage method should be used with slow, repetitive anode effect kill practices.) B.6.1.4.Are the formulae required for the determination of project emissions correctly presented, enabling a complete
B.6.1.
1, 3, 4
1, 3, 4
The over-voltage method has been adopted for baseline due to slow, repetitive anode effect kill practices. The slope method has been adopted for project due to aggressive fast kill anode effect practices.
1, 3, 4
Yes, the formulae required for the determination of project emissions, enabling a complete identification of parameter to be used and / or monitored has been correctly presented, as per the
Page A-16

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION identification of parameter to be used and / or monitored? B.6.1.5.Are the formulae required for the determination of baseline emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? B.6.1.6.Are the formulae required for the determination of leakage emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? B.6.1.7.Are the formulae required for the determination of emission reductions correctly presented? B.6.2. 1, 3, 4 Ref. methodology. Yes, the formulae required for the determination of baseline emissions, enabling a complete identification of parameter to be used and / or monitored has been correctly presented, as per the methodology. As per the methodology, no leakage is expected to occur in this type of projects. COMMENTS GSP PDD Final PDD
1, 3
1, 3
Yes, the formulae required for the determination of emission reductions, enabling a complete identification of parameter to be used and / or monitored has been correctly presented, as per the methodology. Corrective Action Request No.17. Although the list of parameters is complete with regards to the requirement of the applied methodology. Some additional parameters have been stated which either are not required or need to be indicated in section B.7 of the PDD. Please revise accordingly. Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Yes / No Yes Yes Yes Yes No
Data and parameters that are available at validation 1, 3, 4 CAR17
B.6.2.1.Is the list of parameters presented in chapter B.6.2 considered to be complete with regard to the requirements of the applied methodology?
B.6.2.2.Parameter Title: 1, 3, Baseline Over Voltage Coefficient (OVC) 4, 54, 59
CAR18
Page A-17

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. COMMENTS Has this value been verified? No Choice of data correctly justified? No Measurement method correctly described? Yes The indicated baseline OVC is based on the measurements carried out before the project implementation. Corrective Action Request No.18. Please provide further justification for the choice of data regarding the baseline OVC. B.6.2.3.Parameter Title: Baseline Anode Effect Over-voltage (AEO) 1, 3, 4, 54, 56 Data Checklist Yes / No Title in line with methodology? Yes Data unit correctly expressed? Yes Appropriate description of parameter? Yes Source clearly referenced? Yes Correct value provided? No Has this value been verified? No Choice of data correctly justified? No Measurement method correctly described? No The indicated baseline AEO is based on historical data available before the project implementation. Corrective Action Request No.19. Please provide further justification for the choice of data regarding the baseline AEO. Provide justification for the period of measurement corresponding to the most stable and lowest anode effect. As per the methodology, the minimum period shall be 6 months, with the number of measurements statistically representative for that period. Data Checklist Title in line with methodology? Data unit correctly expressed? Yes / No Yes Yes CAR19 GSP PDD Final PDD
B.6.2.4.Parameter Title: Baseline Current Efficiency (CE)

1, 3, 4, 54,
CAR20
Page A-18

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. 56 COMMENTS Appropriate description of parameter? Yes Source clearly referenced? Yes Correct value provided? No Has this value been verified? No Choice of data correctly justified? No Measurement method correctly described? No The indicated baseline CE is based on historical data available before the project implementation. Corrective Action Request No.20. Please provide further justification for the choice of data regarding the baseline CE. Provide justification for the period of measurement corresponding to the most stable and lowest anode effect. As per the methodology, the minimum period shall be 6 months, with the number of measurements statistically representative for that period. Data Checklist Yes / No Title in line with methodology? Yes Data unit correctly expressed? Yes Appropriate description of parameter? Yes Source clearly referenced? Yes Correct value provided? Yes Has this value been verified? Yes Choice of data correctly justified? Yes Measurement method correctly described? Yes The indicated baseline weight fraction is based on the measurements carried out before the project implementation. The measurement report has been submitted. Not applicable since over-voltage method has been adopted for baseline emission calculations. GSP PDD Final PDD
B.6.2.5.Parameter Title: Baseline weight fraction of C2F6/CF4 (FC2F6/CF4)
1, 3, 4, 54, 59
B.6.2.6.Parameter Title: Baseline Anode Effect Frequency (AEF)

1, 3, 4
Page A-19

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION B.6.2.7.Parameter Title: Historical Anode Effect Duration (AED) B.6.2.8.Parameter Title: Baseline Slope Ref. 1, 3, 4 1, 3, 4 COMMENTS Not applicable since over-voltage method has been adopted for baseline emission calculations. Not applicable since over-voltage method has been adopted for baseline emission calculations. Data Checklist Yes / No Title in line with methodology? Yes Data unit correctly expressed? No Appropriate description of parameter? No Source clearly referenced? Yes Correct value provided? No Has this value been verified? No Choice of data correctly justified? NA Measurement method correctly described? NA Corrective Action Request No.21. According to the methodology, average value of PFC emission per tonne of Aluminium produced should be in accordance with the most recent published IAI Survey for the current technology (t CO2e/tAl). Baseline should be updated every year with the most recent values published by IAI. Please include the table for BEIAI as per the revised methodology. Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? Yes / No Yes Yes Yes Yes Yes Yes Yes Yes GSP PDD CAR21 Final PDD
B.6.2.9.Parameter Title: 1, 3, Average value of PFC emissions per 4, 55 tonne of Aluminium produced for CWPB technology (BEIAI)
B.6.2.10. Parameter Title: GWPCF4 Global Warming Potential of CF4
1, 3, 4
Page A-20

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION B.6.2.11. Parameter Title: GWPC2F6 Global Warming Potential of C2F6 Ref. 1, 3, 4 COMMENTS Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? Yes / No Yes Yes Yes Yes Yes Yes Yes Yes GSP PDD Final PDD
B.6.3.
Ex-ante calculation of emission reductions 1, 3 Yes, the projections are based on the same procedures as used for future monitoring. Yes, the GHG calculations have been documented in a complete and transparent manner. Clarification Request No. 3. Please provide the emission reduction calculation sheet. Yes, the data provided in this section consistent with data as presented in other chapters of the PDD
B.6.3.1.Is the projection based on the same procedures as used for future monitoring? B.6.3.2.Are the GHG calculations documented in a complete and transparent manner?
1, 3, 4, 60
CR3
B.6.3.3.Is the data provided in this section consistent with data as presented in other chapters of the PDD? B.6.4. B.6.4.1.Will the project result in fewer GHG emissions than the baseline scenario? B.6.4.2.Is the form/table required for the indication of projected emission reductions correctly applied? B.6.4.3.Is the projection in line with the enviTable 1 is applicable to AM0030, Version 03
Summary of the ex-ante estimation of emission reductions 1 1, 2 Yes, the project will result in fewer GHG emissions than the baseline scenario. Yes, the table required for the indication of projected emission reductions correctly applied. As the project is already implemented therefore the projections
1, 4,
Page A-21

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION sioned time schedule for the projects implementation and the indicated crediting period? B.6.4.4.Is the data provided in this section in consistency with data as presented in other chapters of the PDD? Ref. 11 COMMENTS are deemed to be in line with the schedule. GSP PDD Final PDD
Yes, the data provided in this section is consistent with data as presented in other chapters of the PDD.
B.7.
Application of the monitoring methodology and description of the monitoring plan

Data and parameters monitored 1, 3 Yes, the list of parameters presented in chapter B.7.1 is considered to be complete. B.7.1.1.Is the list of parameters presented in chapter B.7.1 considered to be complete with regard to the requirements of the applied methodology? B.7.1.2.Parameter Title: OVC Over-voltage coefficient B.7.1.3.Parameter Title: AEO Anode effect over voltage B.7.1.4.Parameter Title: CE Current efficiency B.7.1.5.Parameter Title: AED Anode effect duration
B.7.1.
1, 3 1, 3 1, 3 1, 3, 61 64
Not applicable since slope method has been adopted for project emissions calculations. Not applicable since slope method has been adopted for project emissions calculations. Not applicable since slope method has been adopted for project emissions calculations. Monitoring Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Has this value been verified? Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? Yes / No Yes Yes Yes Yes No No Yes Yes No
CAR22
Page A-22

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. COMMENTS QA/QC procedures described? Yes QA/QC procedures appropriate? No Corrective Action Request No.22. Please indicate the value of AED used for ex-ante estimation of emission reduction in the table also. Indication of accuracy should be provided with further details on the QA/QC procedures? B.7.1.6.Parameter Title: AEF Anode effect frequency 1, 3, 61 64 Monitoring Checklist Yes / No Title in line with methodology? Yes Data unit correctly expressed? Yes Appropriate description of parameter? Yes Source clearly referenced? Yes Correct value provided for estimation? No Has this value been verified? No Measurement method correctly described? Yes Correct reference to standards? Yes Indication of accuracy provided? No QA/QC procedures described? Yes QA/QC procedures appropriate? No Corrective Action Request No.23. Please indicate the value of AEF used for ex-ante estimation of emission reduction in the table also. Indication of accuracy should be provided with further details on the QA/QC procedures? Monitoring Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Has this value been verified? Yes / No Yes Yes Yes Yes No No CAR23 GSP PDD Final PDD
B.7.1.7.Parameter Title: Slope Slope coefficient
1, 3, 4
CAR24
Page A-23

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. COMMENTS Measurement method correctly described? Yes Correct reference to standards? Yes Indication of accuracy provided? NA QA/QC procedures described? Yes QA/QC procedures appropriate? Yes Corrective Action Request No.24. Please indicate the value of Slope used for ex-ante estimation of emission reduction in the table also. B.7.1.8.Parameter Title: Weight fraction Weight fraction of C2F6/CF4 (FC2F6/CF4) 1, 3, 4 Monitoring Checklist Yes / No Title in line with methodology? Yes Data unit correctly expressed? Yes Appropriate description of parameter? Yes Source clearly referenced? Yes Correct value provided for estimation? No Has this value been verified? No Measurement method correctly described? Yes Correct reference to standards? Yes Indication of accuracy provided? Yes QA/QC procedures described? Yes QA/QC procedures appropriate? Yes Corrective Action Request No.25. Please indicate the value of Weight fraction used for ex-ante estimation of emission reduction in the table also. Monitoring Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Yes / No Yes No Yes Yes No CAR25 GSP PDD Final PDD
B.7.1.9.Parameter Title: PAl Aluminium production
1, 3, 4, 65, 68
CAR26
Page A-24

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. COMMENTS Has this value been verified? No Measurement method correctly described? Yes Correct reference to standards? Yes Indication of accuracy provided? No QA/QC procedures described? Yes QA/QC procedures appropriate? No Corrective Action Request No.26. Please indicate the value of PAl used for ex-ante estimation of emission reduction in the table. Data unit should be corrected to tonnes instead of tonnes/year. Indication of accuracy should be provided with further details on the QA/QC procedures? B.7.2. Description of the monitoring plan 1, 4, 66 1, 66, 67 1, 4 1 The operational and management structure has been briefly described. The same has been checked during the on-site visit. Corrective Action Request No.27. Please describe further the operational and management structure regarding the roles and responsibilities towards effective project monitoring. Yes, the monitoring plan reflects current good monitoring practice and was checked during the on-site visit. No significant information has been provided in annex 4 apart from the reference to the Protocol B.7.2.1.Is the operational and management structure clearly described and in compliance with the envisioned situation? B.7.2.2.Are responsibilities and institutional arrangements for data collection and archiving clearly provided? B.7.2.3.Does the monitoring plan provide current good monitoring practice? B.7.2.4.If applicable: Does annex 4 provide useful information enabling a better understanding of the envisioned monitoring provisions? GSP PDD Final PDD
CAR27
Page A-25

B.8. Date of completion of the application of the baseline study and monitoring methodology an the name of the responsible person(s)/entity(ies)
B.8.1.1.Is there any indication of a date when the baseline was determined? B.8.1.2.Is this consistent with the time line of the PDD history? B.8.1.3.Is the information on the person(s) / entity(ies) responsible for the application of the baseline and monitoring methodology provided consistent with the actual situation? B.8.1.4.Is information provided whether this person / entity is also considered a project participant? 1 1, 3 The baseline determination date has been indicated as 29/02/2008. Corrective Action Request No.28. Please revise the date as the methodology was revised in EB-44 after 28 November 2008. It has been indicated that the baseline study was prepared by INALUM and South Pole Carbon Asset Management Ltd., in cooperation with Carbon Environmental Research (CER) Indonesia. CAR28
Corrective Action Request No.29. Please include the information whether the person / entity is also considered a project participant.
CAR29
C. Duration of the project activity / crediting period

C.1. Duration of the project activity
C.1.1. Are the projects starting date and operational lifetime clearly defined and reasonable? 1, 2, 4, 69 Corrective Action Request No.30. The starting date of a CDM project activity is the earliest of the date(s) on which the implementation or construction or real action of a project activity begins/has begun (EB33, Para 76/CDM Glossary of terms/EB41, Para 67). The project start date has been indicated as 01/11/2007. The PDD should contain not only the date, but also a description of how this start date has been determined, and a description of the evidence available to support this start date. Further, the operation lifetime is not indicated in the PDD. Please provide the documentary evidence for the start date CAR30
Page A-26

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. COMMENTS and indicate the operational lifetime clearly in the PDD. GSP PDD Final PDD
C.2.
Choice of the crediting period and related information

C.2.1. Is the assumed crediting time clearly defined and reasonable (renewable crediting period of max 7 years with potential for 2 renewals or fixed crediting period of max. 10 years)? 1, 2, 4, 70 Fixed crediting period of 10 years has been chosen for the project activity and is deemed reasonable.
D. Environmental impacts
D.1. Documentation on the analysis of the environmental impacts, including trans-boundary impacts
D.1.1. Has the analysis of the environmental impacts of the project activity been sufficiently described? D.1.2. Are there any Host Party requirements for an Environmental Impact Assessment (EIA), and if yes, has an EIA been approved? D.1.3. Will the project create any adverse environmental effects? D.1.4. Were transboundary environmental impacts identified in the analysis? 1, 72 - 74 It has been indicated that the implementation of the project activity does not require an EIA to be carried out. Evidence pertaining to the EIA carried out earlier and the subsequent environmental clearances have been checked during the on-site visit. For implementing the project activity there is no requirement from the Indonesian Government (Host country) to carry out an EIA.
1, 71
1, 4
No negative environmental impacts are expected due to the project activity as it is implementation of improved control measures through hardware and software implementation. Not applicable.
D.2. If environmental impacts are considered significant by the project participants or the host Party, please provide conclusions and all references to support documentation of an environmental impact assessment undertaken in accordance with the procedures as required by the host Party
D.2.1. Have the identified environmental im1 Not applicable
Page A-27

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION pacts been addressed in the project design sufficiently? D.2.2. Does the project comply with environmental legislation in the host country? 1, 4, 73, 74 Yes, the plant has all the necessary clearances and was under operation as checked during the on-site visit. Ref. COMMENTS GSP PDD Final PDD
E. Stakeholders comments
E.1. Brief description how comments by local stakeholders have been invited and compiled
E.1.1. Have relevant stakeholders been consulted? 1, 4, 75 Yes, relevant stakeholders have been consulted, namely the employees, local residents, local Government bodies and other local agencies. Documents supporting the same have been checked during the onsite visit. Corrective Action Request No.31. Please indicate which media has been used to invite the local stakeholders. No such requirement exists.
E.1.2. Have appropriate media been used to invite comments by local stakeholders? E.1.3. If a stakeholder consultation process is required by regulations/laws in the host country, has the stakeholder consultation process been carried out in accordance with such regulations/laws? E.1.4. Is the undertaken stakeholder process that was carried out described in a complete and transparent manner?
1, 75
CAR31
1, 78
1, 75 - 78
Corrective Action Request No.32. Further description of the undertaken stakeholder process should be provided in the PDD.
CAR32
E.2. Summary of the comments received

E.2.1. Is a summary of the received stakeholder comments provided? 1 Yes, the summary of the received stakeholder comments has been provided.
Page A-28

E.3. Report on how due account was taken of any comments received
E.3.1. Has due account been taken of any stakeholder comments received? 1, 4 Yes, the stakeholder comments have been addressed appropriately.
F. Annexes 1 - 4
F.1. Annex 1: Contact Information
F.1.1. Is the information provided consistent with the one given under section A.3? F.1.2. Is the information on all private participants and directly involved Parties presented? 1 1, 81 Yes, the information provided is consistent with the one given under section A.3. Yes, all information has been provided. P.T. Inalum from Indonesia (Host country) and South Pole Carbon Asset Management Ltd. from Switzerland (Annex-1 country) are the private entities involved as project participants of the project.
F.2. Annex 2: Information regarding public funding

F.2.1. Is the information provided on the inclusion of public funding (if any) in consistency with the actual situation presented by the project participants? F.2.2. If necessary: Is an affirmation available that any such funding from AnnexI-countries does not result in a diversion of ODA? 1, 20 It has been indicated that no public funding from Annex-1 country is involved in the project activity. The project is fully equity funded.
Not applicable
F.3. Annex 3: Baseline information

F.3.1. If additional background information on baseline data is provided: Is this information consistent with data presented by other sections of the PDD?
1, 21, 22, 54 -
Reference to a baseline measurement report has been given. Corrective Action Request No.33. Please provide further information on the historical data, the baseline measurement undertaken and the results obtained.
CAR33
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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 CHECKLIST TOPIC / QUESTION Ref. 59 F.3.2. If additional background information on baseline data is provided: Is this information consistent with data presented by other sections of the PDD? F.3.3. Is the data provided verifiable? Has sufficient evidence been provided to the validation team? F.3.4. Does the additional information substantiate / support statements given in other sections of the PDD? 1 Not applicable COMMENTS GSP PDD Final PDD
No data has been provided in Annex-3
No significant additional information has been provided in Annex3
F.4. Annex 4: Monitoring information

F.4.1. If additional background information on monitoring is provided: Is this information consistent with data presented in other sections of the PDD? F.4.2. Is the information provided verifiable? Has sufficient evidence been provided to the validation team? F.4.3. Do the additional information and / or documented procedures substantiate / support statements given in other sections of the PDD? 1, 54 Reference to the Protocol and a separate spreadsheet model has been given.
Not applicable
Not applicable
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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42
Table 2
Resolution of Corrective Action and Clarification Requests

Ref. to table 1 A.3.2 Summary of project owner response The MoC between South Pole Carbon Asset Management Ltd. and PT. Indonesia Asahan Aluminium has been signed using the new UNFCCC MoC form and submitted to the DOE. Validation team conclusion Response from audit team The signed MoC has been submitted providing information on all the PPs. This issue is now resolved. Response from audit team The PDD section A.4.2 has been revised. This issue is now resolved. Response from audit team The PDD section A.4.4 has been revised. This issue is now resolved. Response from audit team The PDD section B.1 has been revised. This issue is now resolved. Response from audit team The historical data has been included in Annex-3 of the PDD. The indicated values
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Clarifications and corrective action requests by validation team Clarification Request No. 1. Please submit documents indicating the confirmation of the listed project participants - PT. Indonesia Asahan Aluminium (INALUM) and South Pole Carbon Asset Management Ltd. Corrective Action Request No.1. Please correct the version of the methodology stated in section A.4.2 of the PDD.
A.4.2.1
The methodology version has been revised in section A.4.2 of the PDD:
Corrective Action Request No.2. A.4.4.2 Please correct the figure of Total estimated reductions (tonnes of CO2e) in the table in section A.4.4 of the PDD. Corrective Action Request No.3. Although, the reference number (AM0030), title of the baseline and monitoring methodology and the associated tools has been clearly indicated, please correct the version numbers of the methodology and the tool. Corrective Action Request No.4. Please indicate the values of the historical data in the PDD along with the reference. B.1.1
The requested correction has been implemented in section A.4.4 of the PDD.
The versions of the methodology and the tool have been revised in section B.1 of the PDD.
B.2.4
The historical values have been indicated in section B.2.4 referring to Annex. 3.

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 have been validated from the audited annual reports of Inalum for the respective period. This issue is now resolved. Corrective Action Request No.5. Please correct the version of the methodology. B.3.5 The methodology version has been revised in section B.3 of the PDD: Response from audit team The PDD section B.3 has been revised. This issue is now resolved. Response from audit team The PDD section B.4 clarifies the voluntary actions taken by Inalum in the past. These have been validated during the on-site audit. Further it is also clarified that Inalum is not a party to the IAI PFC initiative. This issue is now resolved. Response from audit team The PDD section B.4 clarifies the voluntary actions taken by Inalum in the past. These have been validated during the on-site audit. This issue is now resolved.
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Corrective Action Request No.6. Please indicate in the PDD details on the voluntary initiatives as part of the IAI PFC initiative. The description provided for the scenario is not consistent with the requirements. Please revise accordingly.
B.4.2.1
Inalum did not take part in the IAI PFC initiative. This was a false assumption due to the several Anode Effect improvements in the smelter. However, all the improvements have made due to economical incentives and not ecological as explained in detail in section B.4 of the PDD.
Corrective Action Request No.7. Please correct the dates of the improvement stated.
B.4.2.2
The improvements in the period 2003 until 2007 have all been implemented internally. The test results dates are available which lead to the decision of the implementation of the improvement. As the exact date cant be shown through a third party document a time range is given for all the improvements explained in section B.4.

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 Corrective Action Request No.8. Is the continuation of the situation before the project activity not a feasible baseline scenario? B.4.2.3 Yes, it is. The PDD has been revised including scenario 3 as possible baseline scenario. Response from audit team The PDD section B.4 has been revised indicating continuation of situation before the project activity as a feasible baseline scenario. This issue is now resolved. Response from audit team The PDD section B.4 has been revised. The baseline scenario alternatives are in compliance with all applicable legal and regulatory requirements existing in Indonesia. This issue is now resolved. Response from audit team The PDD section B.4 has been revised. This issue is now resolved. Response from audit team The PDD section B.4 has been revised indicating continuation of situation before the project activity as a feasible baseline scenario. This issue is now resolved.
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Corrective Action Request No.9. Please indicate in the PDD details on the applicable legal and regulatory requirements.
B.4.3
Statements regarding the legal and regulatory requirements have been moved from section B.5 to B.4 in the PDD.
Corrective Action Request No.10. There is no identification of applicable regulatory or legal requirements identified in the PDD, please revise and indicate the same. Corrective Action Request No.11. Please note that as per the methodology, if the resulting scenario does not correspond to absence of implementation of any anode effect mitigation measure, then this baseline methodology does not apply and another methodology should be used..
B.4.4
Statements regarding the legal and regulatory requirements have been moved from section B.5 to B.4 in the PDD.
B.4.5
The baseline scenario has been wrongly defined. As justified already by the IRR calculation (in the draft PDD) in section B.5 scenario 1 cant be the resulting scenario. Section B.4 has been changed according to the results of section B.5. The baseline scenario is now defined as no implementation of any anode effect mitigation measure.

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 Note: The IRR calculation in section B.5 has been replaced by a NPV analysis as requested by the methodology ACM0030 Version 3. Corrective Action Request No.12. Please indicate clearly the start date of the project activity in accordance with the CDM Glossary of terms. Further as the starting date of the project activity is before the start of validation, the complete chronology of the project from start date till date should be indicated in the PDD with evidences. B.5.1 The start date of the project activity has clearly been identified in the PDD as 27th February 2007 as the date where the contract has been signed to purchase Alcans new process control system. CDM related events have been added after the project activity start to show the continuous willingness to implement a carbon project and to explain the registration delays based on a request for deviation and a request for revision of AM0030 version 2. To better illustrate the CDM timeline project activity relevant dates have been included as well such as the preparing of a technical evaluation report. Response from audit team The PDD section B.5 has been revised indicating the start date in accordance with the guidance. Also as the start date is before the start of validation, the prior and serious ongoing consideration of CDM in accordance with EB-41, Annex 46 has been demonstrated. These have been validated based on the submitted documentary evidences. This issue is now resolved. Response from audit team The spreadsheet for the investment analysis has been submitted. The indicated values have been checked from the stated sources. All formulas used in this analysis are readable and all relevant cells viewable and unprotected.The NPV calculation is deemed to be correct. This issue is now resolved.
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Clarification Request No. 2. Please submit the spreadsheet for the investment analysis. All formulas used in this analysis should be readable and all relevant cells viewable and unprotected.
B.5.2
The investment analysis has been sent to the DOE. All sources of relevant parameters are listed in the analysis, have been sent to the DOE and checked on-site by the DOE.

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 Corrective Action Request No.13. The estimation for the electricity that would have been required in the absence of the project activity to achieve the same amount of production as in the project activity and the calculation of NPV done is to be carried out for this situation. Please indicate the same in the PDD and provide the analysis. B.5.6 The project owner has estimated the electricity saving potential and the aluminium production increase potential in order to elaborate the payback period of the investment. Relevant documents have been stated in the investment analysis and sent to the DOE. Based on the electricity savings, the additional aluminium production and other relevant parameters the NPV was calculated. The investment analysis has been sent to the DOE and the key results and analysis of the results are indicated in section B.5 of the PDD. Note: AM0030 Version 3 requests a NPV comparison, which can only be applied by following option III of the tool for the demonstration and assessment of additionality. Response from audit team The estimation of the expense for the electricity that would have been required in the absence of the project activity to achieve the same amount of production as in the project activity has been presented. The PDD section B.5 has been revised indicating the investment comparison analysis with NPV as an indicator. The spreadsheet for the investment analysis has been submitted. The indicated values have been checked from the stated sources. The NPV calculation is deemed to be correct. This issue is now resolved. Response from audit team The PDD section B.5 has been revised indicating the investment comparison analysis with NPV as an indicator. This issue is now resolved. Response from audit team The PDD section B.5 has
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Corrective Action Request No.14. The estimation of NPV has not been indicated in the PDD.
B.5.8
The investment analysis has been changed from a benchmark analysis towards an investment comparison analysis, which allows NPV estimation as requested by the methodology and indicated in section B.5.
Corrective Action Request No.15. Although barrier analysis has not been carried out for the project activity, for better clarity please inTable 1 is applicable to AM0030, Version 03
B.5.9
Although carrying out an investment analysis already has proved additionality a barrier analysis has been added in section B.5 of the PDD in terms of complete-

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 dicate so in the PDD ness. been revised including the barrier analysis. Prevailing practice barrier has been demonstrated. The project activity is demonstrated as the first of its kind as it is the only smelter operating in Indonesia. Further, supporting evidences have also been provided by the PP indicating that in Far East Asia region also there is no smelter wherein the new technology of Blue Box by Alcan Alesa has been installed. Response from audit team The PDD section B.5 has been revised including the barrier analysis. Prevailing practice barrier has been demonstrated. The project activity is demonstrated as the first of its kind as it is the only smelter operating in Indonesia. Further, supporting evidences have also been provided by the PP indicating that in Far East Asia region also there is no smelter wherein the new technology of Blue Box by Alcan Alesa
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Corrective Action Request No.16. Please provide further information on the other activities along with the supporting documents to substantiate the common practice analysis
B.5.12
Please note the additional information in section B.5 of the PDD. Following documents should be consulted to substantiate the common practice analysis, which also have been checked on-site: Primary Aluminium Smelter and Producers all_May 07.xls Alcan reference1.jpg Alcan reference2.jpg 16_Letter from AlcanAlesa.pdf

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 has been installed. Corrective Action Request No.17. B.6.2.1 Although the list of parameters is complete with regards to the requirement of the applied methodology. Some additional parameters have been stated which either are not required or need to be indicated in section B.7 of the PDD. Please revise accordingly. Corrective Action Request No.18. B.6.2.2 Please provide further justification for the choice of data regarding the baseline OVC. Section B.6.2 and section B.7 have been revised accordingly. Response from audit team The PDD has been revised. This issue is now resolved.
The choice of data has been justified more specifically in section B.6.2 for the parameter OVC. According to the methodology, over-voltage coefficient should be determined by simultaneous measurements of emissions and collection of anode effect data over an appropriate period of time (at least 72 hours). The measurements were made on a continuous basis from 26 February 2008 9:30am until 29 February 2008 10:30am on a pot-line section containing 19 CWPB pots operating with the process control system prior to project implementation. The measurement objective was to calculate the Intergovernmental Panel on Climate Change (IPCC) Tier 3 baseline over-voltage coefficient and weight fraction of C2F6/CF4 from the PFC measurements. CF4 and C2F6 were measured in the exhaust ducts of aluminium electrolysis cells by Fourier Transform Infrared (FTIR) spectrometry. The measurements were carried out according to the protocol and described in a report of an independent measurement team.
Response from audit team The PDD has been revised with the inclusion of the justification. The report and the data have been validated. This issue is now resolved.
Corrective Action Request No.19. B.6.2.3 Please provide further justification for the choice of
Further justification for the choice of data regarding the Response from audit team baseline AEO has been provided in the PDD. The PDD has been revised
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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 data regarding the baseline AEO. Provide justification for the period of measurement corresponding to the most stable and lowest anode effect. As per the methodology, the minimum period shall be 6 months, with the number of measurements statistically representative for that period. The historic data of the past 2 years prior to the project implementation is used to estimate the average and its standard deviation. To account for uncertainty the 95% confidence interval (Students t-distribution) values is determined. The lower bound of 95% is chosen to result in a conservative value of the emission factor. with the inclusion of the justification for the choice of data regarding the baseline AEO. The parameter has been indicated in accordance with the methodology. The data has been checked. This issue is now resolved. Response from audit team The PDD has been revised with the inclusion of the justification for the choice of data regarding the baseline CE. The parameter has been indicated in accordance with the methodology. The data has been checked. This issue is now resolved. Response from audit team The PDD has been revised in accordance with the methodology. The data has been checked. This issue is now resolved.
Corrective Action Request No.20. B.6.2.4 Please provide further justification for the choice of data regarding the baseline CE. Provide justification for the period of measurement corresponding to the most stable and lowest anode effect. As per the methodology, the minimum period shall be 6 months, with the number of measurements statistically representative for that period.
Further justification for the choice of data regarding the baseline CE has been provided in the PDD. The historic data of the past 2 years prior to the project implementation is used to estimate the average and its standard deviation. To account for uncertainty the 95% confidence interval (Students t-distribution) values is determined. The upper bound of 95% is chosen to result in a conservative value of the emission factor.
Corrective Action Request No.21. According to the methodology, average value of PFC emission per tonne of Aluminium produced should be in accordance with the most recent published IAI Survey for the current technology (t CO2e/tAl). Baseline should be updated every year with the most recent values published by IAI. Please include the table for BEIAI as per the revised methodology. Clarification Request No. 3. Please provide the emission reduction calculation
B.6.2.9
The most current BEIAI value (CWPB: 0.53 t CO2/t Al) is now displayed in the PDD and it is indicated that the values should be updated yearly according to the most recent published IAI report.
B.6.3.2
The emission reduction sheet and all other relevant calculation sheets such as the over-voltage coefficient
Response from audit team The ER calculation sheets

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Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 sheet. determination using baseline measurement data have been provided to the DOE. Relevant data has been checked during the site-visit. have been provided and the data used in the same has been also checked during the on-site visit. This issue is now resolved. Response from audit team The PDD has been revised with the indication of value of AED used for ex-ante estimation of emission reduction appropriately. This issue is now resolved. Response from audit team The PDD has been revised with the indication of value of AEF used for ex-ante estimation of emission reduction appropriately. This issue is now resolved. Response from audit team The PDD has been revised with the indication of value of Slope used for ex-ante estimation of emission reduction appropriately. This issue is now resolved.
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Corrective Action Request No.22. Please indicate the value of AED used for exante estimation of emission reduction in the table also. Indication of accuracy should be provided with further details on the QA/QC procedures?
B.7.1.5
The value applied for ex-ante calculation has been applied and details on the measurement and QA/QC procedures have been indicated.
Corrective Action Request No.23. B.7.1.6 Please indicate the value of AEF used for ex-ante estimation of emission reduction in the table also. Indication of accuracy should be provided with further details on the QA/QC procedures?
The value applied for ex-ante calculation has been applied and details on the measurement and QA/QC procedures have been indicated.
Corrective Action Request No.24. Please indicate the value of Slope used for exante estimation of emission reduction in the table also.
B.7.1.7
The value has been indicated in the table: 0.152 The IPCC default value of 0.143 (kg PFC/t Al)/(AEminute/pot.day) +6% uncertainty in terms of conservativeness.

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 Corrective Action Request No.25. Please indicate the value of Weight fraction used for ex-ante estimation of emission reduction in the table also. B.7.1.8 The value has been indicated in the table: 0.134 IPCC default value of 0.121 +11% uncertainty to be conservative Response from audit team The PDD has been revised with the indication of value of Weight fraction used for exante estimation of emission reduction appropriately. This issue is now resolved. Response from audit team The PDD has been revised with the indication of value of PAl used for ex-ante estimation of emission reduction appropriately. This issue is now resolved. Response from audit team The PDD has been revised including the operational and management structure regarding the roles and responsibilities towards effective project monitoring. This issue is now resolved. Response from audit team The PDD section B.8 has been revised. This issue is now resolved.
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Corrective Action Request No.26. Please indicate the value of PAl used for ex-ante estimation of emission reduction in the table. Data unit should be corrected to tonnes instead of tonnes/year. Indication of accuracy should be provided with further details on the QA/QC procedures?
B.7.1.9
The value has been indicated in the table and the unit adjusted: 248,542 t One year of data after project implementation is available and used to determine the ex-ante emission reduction (April 2008 March 2009). The measurement method and QA/QC procedures have been indicated in the PDD. Table 12 Operational and management structure of parameter monitored has been revised by adding the responsible department and sub-department of the person in charge of one specific monitoring parameter. In the case of reallocation of the person in charge to another department the responsibility of monitoring the parameter remains with the department. It is up to the department to define a new person in charge. The date when the baseline was determined has been revised to the most current date of 20 April 2009
Corrective Action Request No.27. Please describe further the operational and management structure regarding the roles and responsibilities towards effective project monitoring.
B.7.2.2
Corrective Action Request No.28. Please revise the date as the methodology was revised in EB-44 after 28 November 2008.
B.8.1.2

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 Corrective Action Request No.29. Please include the information whether the person / entity is also considered a project participant. B.8.1.4 The requested information has been added to the PDD: Response from audit team The PDD section B.8 has been revised. This issue is now resolved. Response from audit team The PDD section C.1 has been revised indicating the start date in accordance with the guidance. The start date has been validated from the contract between Inalum and Alcan Alesa (technology supplier), dated 27-02/2007. Further, the operational lifetime has been validated from the letter provided by the technology supplier. This issue is now resolved. Response from audit team The PDD section E.1 has been revised indicating the media used to invite the local stakeholders as invitation letters. The same have been validated. This issue is now resolved. Response from audit team
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Corrective Action Request No.30. The starting date of a CDM project activity is the earliest of the date(s) on which the implementation or construction or real action of a project activity begins/has begun (EB33, Para 76/CDM Glossary of terms/EB41, Para 67). The project start date has been indicated as 01/11/2007. The PDD should contain not only the date, but also a description of how this start date has been determined, and a description of the evidence available to support this start date. Further, the operation lifetime is not indicated in the PDD. Please provide the documentary evidence for the start date and indicate the operational lifetime clearly in the PDD Corrective Action Request No.31. Please indicate which media has been used to invite the local stakeholders.
C.1.1
The requested correction has been implemented in the PDD. The contract between Inalum and Alcan Alesa showing financial closure was shown to the DOE during site visit. The operational life-time of 10 years is assumed based on the technology providers statements in the following document: Installed system and operational life time.pdf
E.1.2
A written letter has been sent to the local stakeholder. Section E.1 has been adopted accordingly.
Corrective Action Request No.32. Further description of the undertaken stakeholder

E.1.4
Section E.1 has been enlarged with further description

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 Number of Pages: 42 process should be provided in the PDD. regarding the stakeholder process. The PDD section E.1 has been revised. This issue is now resolved. Response from audit team The PDD annex-3 has been revised providing further information on the historical data. Also the baseline measurement undertaken and the results obtained have been validated from the submitted report. This issue is now resolved.
Corrective Action Request No.33. Please provide further information on the historical data, the baseline measurement undertaken and the results obtained
F.3.1
Historical data including the results of a statistical student t-distribution analysis have been inserted in Annex. 3 relevant for emission reduction calculation. Information regarding the baseline measurements is provided in detail in two separate reports. One report solely explains the baseline measurements and is provided by an independent measurement company which was responsible to conduct the baseline measurements according to USEPA and IAI Protocol for Measurement of Tetrafluormethane (CF4) and Hexafluormethane (C2F6) Emissions from Primary Aluminium Production (May 2003). The second report describes the use of the measured baseline data to determine the over-voltage coefficient and the slope coefficient. This is not included in the PDD as it is not part of AM0030 Version 3. Only formulas explained in the methodology are listed in the PDD in terms of consistency.
Table 3
Unresolved Corrective Action and Clarification Requests (in case of denials)

Id. of CAR/CR Explanation of Conclusion for Denial -
Clarifications and / or corrective action requests by validation team -
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Validation of the CDM Project: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung
Annex 2: Information Reference List
Information Reference List (IRL)

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 IRL No. Document or Type of Information 1. PDD for CDM project, PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Version 01 Version 03 Version 05 UNFCCC web-page http://www.unfccc.int Approved methodology AM0030, Version 03 On-site interviews at PT. Indonesia Asahan Aluminium (Inalum) plant from 15-04-2009 to 17-04-2009 by TV SD Validation team : Mr. Sandeep Kanda TV SD Industrie Service GmbH Mr. Jayme Boehnert TV SD PSB Philippines Inc. Interviewed persons: Mr. N. A. Setiawan Mr. Harmon Yunaz Mr. Ivan Mr. Faisal Hidayat Ms. Alin Pratidina Ms. Syahrina Anggraini 5.
Page 1 of 7
Date of document
2. 3. 4.
16-05-2008 12-02-2009 22-09-2009 -------------------------------
Director, Production / Inalum Deputy General Manager, Production / Inalum Assistant Manager, Safety & Environment / Inalum Project Team Support / Inalum CDM Development Manager / South Pole Carbon Asset Management Ltd. Program Director / CER Indonesia Documents related to general description of the project activity 26-12-1975
Permohonan Nippon Asahan Aluminium Ltd. Corporation dan Pemerintah Republik Indonesia (Request letter from Nippon Asahan Aluminium Ltd. and Government of Indonesia to the Investment Coordination Agency to be allowed to invest in Indonesia through Hydroelectric plant and Aluminium Smelter plant construction. This letter also shows 12 Japanese investors that were jointly involved as the foreign investors)
6. 7.
HakAtasTanahuntukProyekAsahan (LandusepermitfromDepartmentofInternalAffairstobuildAluminiumSmelteratAsahanRegency)
Surat Keputusan Sementara Ketua Otorita Pengembangan Proyek Asahan tentang Penyerahan dari Project Area di Daerah Smelter Site untuk Keperluan Pembangunan Pabrik Peleburan Aluminium di Kuala Tanjung
24-10-1977 25-03-1978
TV SD INDUSTRIE SERVICE GMBH

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 IRL No. Document or Type of Information (Construction permit from the local government to construct Alumunium Smelter at Kuala Tanjung, Asahan Regency) Hak Atas Tanah untuk Proyek Asahan (Land use permit from Agency of Land use to build Aluminium Smelter at Asahan Regency) PT Inalum Annual Report FY 2006 (The document shows approximately Aluminium production and also Electricity consumption in FY-2006) Primary Aluminium Smelters and Producers of the World (Source: Aluminium-Verlag Marketing & Kommunikation GmbH Duesseldorf - The document shows that PT. INALUM started its operation in 1982. PT. INALUM is adopting CWPB pot type technology with 3 potlines and 510 pots. The smelter has been running for approximately 250000 tonnes per annum by consuming 603 MW electricity produced by Sigura-gura and Tangga hydropower plant. The document also shows a maximum current of 190kA and some of 200Ka.) Commissioning Certificate from Alcan Alesa indicating the dates of pots switching over from CEGELEC to Alcan Alesa Alcan Alesa Technology Manual indicating the Alcan Alesa technology specification Inalum System Specification File Chapter 1 from CEGELEC manual indicating the CEGELEC system specifications Overseas training module -- Electrolysis Seminar and Inalum Training from Alcan Alesa In-House Training Module of Renewal Process Control System Overseas training schedule Overseas training certificate from Alcan Alesa Engineering Ltd for PCU Hardware/Software In-house training schedule for Renewal on Process Control System at Reduction Daftar Hadir Peserta Pelatihan (On the job/off the job) In-house training attendance list
Page 2 of 7
Date of document
8. 9. 10.
22-04-1979 2006 May 2007
11. 12. 13. 14. 15. 16. 17. 18. 19. 20.
03-03-2008 27-07-2007 -------March 2007 01-05-2007 to 05-06-2007 12.01.2009 09.03.2009 11-04- 2009 14-05-2007
Request for Budget Approval indicating that PT. INALUM has fully financed the proposed project and no ODA is 18.05.2006 involved as the investment source Documents related to baseline and monitoring methodology Annual Reports for financial year (FY) 2003 to FY 2007 showing electricity consumption per month since FY 2003 to FY 2007 and also the smelter specification within the FY TV SD INDUSTRIE SERVICE GMBH --------
21.

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 IRL No. Document or Type of Information 22.
Page 3 of 7
Date of document
23. 24. 25. 26. 27. 28. 29. 30.
Financial Statement and Business Result Analysis of PT. INALUM showing the reduced metal per month data -------since FY 2005 to FY 2007. The document also gives data of Aluminium production costs (non-electricity portion and electricity portion), power cost, Aluminium ingot cost etc. Documents related to previous technical improvements that have been done by PT. INALUM since 1992 until -------the proposed project. Hardware memory upgrade proof 2003 Alumina specification check document showing the Alumina quality check before entering PT. INALUM Alumina Supply Agreement between PT. INALUM and Alcan Trading Limited Alumina Supply Agreement between PT. INALUM and Alakasa Company Ltd. Site photograph showing bar brake with original blade without teeth blade Site photograph showing bar brake with teeth blade (improvement) Documents related to serious consideration of CDM Proyek CDM (Letter from Local Environmental Agency of North Sumatera to all companies including PT. INALUM to reduce GHG emissions and also to perform CDM activities related to companys core business) Proyek CDM (a reply letter from PT. INALUM) (PT. INALUM replied and informed the Local Environmental Agency of North Sumatera that Inalum would try to study any possible efforts to reduce PFC emission. However, due to high investment cost, PT. INALUM asked any information whether the possible PFC reduction project would get any financial assistance) Proyek CDM (a progress letter from PT. INALUM to the Local Environmental Agency) (PT. INALUM sent out a letter to the Local Environmental Agency of North Sumatera that PT. INALUM has done several efforts to reduce AE e.g. a replacement of bar blade to teeth blade, which resulted in PFC emission reduction) Informasi Prosedur Proyek CDM (Letter from the Local Environmental Agency of North Sumatera based on their discussion with Ministry of Environment in Jakarta that informed PT. INALUM about DNA website to help searching any CDM information) Bidding invitation from PT. INALUM Bidding evaluation by PT. INALUM before choosing Alcan Alesa. TV SD INDUSTRIE SERVICE GMBH 29-09-2003 -------17.06.2005 15.07.2005 ---------------
31.
5-10-2003
32.
29-07-2005
33.
19-01-2006
34. 35.
24-01-2006 06-04-2006

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 IRL No. Document or Type of Information 36.
Page 4 of 7
Date of document
37.
38. 39. 40.
Business Contact Event Invitation by the Local Environmental Agency of North Sumatera inviting PT. INALUM 08-06-2006 to attend CDM development seminar (Business contact: CDM as Environmental Solution and Business Opportunity) Undangan Regional Workshop 28-08-2006 (Invitation from National Development Planning Agency to attend the Regional Workshop on Training of Trainer on CDM Project Development as part of ADB Technical Assistance grant in Padang from 4-6 September 2006) Minutes of Board Meeting that showed PT. INALUM has agreed to invest in the process control system 02-10-2006 Secrecy agreement with Alcan Alesa Bantuan Penyusunan Konsep Proyek CDM (Letter from CER Indonesia that informed CDM development (technical) assistance scheme e.g. PIN development from IGES in cooperation with Ministry of Environment) Permohonan Data (Letter from CER Indonesia that requested data support such as feasibility study, Long term ER projection, technology overview to develop PIN under CDM development (technical) assistance scheme from IGES) Kerjasama dalam Proyek CDM PT. INALUM ( PT. INALUM replied to CER Indonesia explaining their wish to cooperate with CER Indonesia in CDM development and ask CER Indonesia to provide project proposal and agreement) CDM development project proposal sent out by CER Indonesia to Inalum Offer from CER Indonesia and South Pole Carbon Asset Management Ltd. for CDM development project cooperation sent to PT. INALUM CDM Project Agreement for the project PFC Emission Reduction at PT. Indonesia Asahan Aluminium between PT. Indonesia Asahan Aluminium and South Pole Ltd. in cooperation with CER Indonesia Discussion with DOE Contract with DOE for project validation Documents related to demonstration of additionality Investment analysis calculation excel sheets Annual Reports for FY 2005 showing Aluminium production costs, Aluminium sales price and electricity purchase rate TV SD INDUSTRIE SERVICE GMBH 08-02-2007 12-02-2007
41.
16-03-2007
42.
16-03-2007
43. 44. 45. 46. 47. 48. 49.
23-03-2007 16-07-2007 30-08-2007 Februrary 2008 08-04-2008 ---------------

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 IRL No. Document or Type of Information 50. 51. 52. 53.
Page 5 of 7
Date of document -------September 2006 -------May 2007
Internal document indicating comparison of old and new system Merit-Demerit of Renewal Procom indicating incremental Aluminium production and additional electricity savings Discount rate based on the prevalent interest rate for investments before project activity start date obtained from www.bi.go.id Reference list of Alesa Pot Control Systems in the World indicating that PT. INALUM is the only company in Asia with CWPB pot type that is using Alcan Alesa technology (as the first of its kind proof). Title: Primary Aluminium Smelters and Producers of The World All (source: Aluminium-Verlag Marketing & Kommunikation GmbH Duesseldorf. Strict Copyright Protection). Documents related to estimation of emission reductions Protocol for measurement of Tetrafluoromethane (CF4) and Hexafluoroethane (C2F6) emissions from primary Aluminum production (EPA 43-R-03-006) The international aluminium institute report on the Aluminium industrys global Perfluorocarbon gas emissions reduction Programme - Results of the 2005 anode effect survey and Results of the 2006 anode effect survey. Smelter production and anode effect data for the period FY 2004 - 2007 Annual reports FY2003-2007 showing aluminium production and electricity consumption data Schedule Pengukuran PFC (PFC Measurement Campaign Schedule) Online PFC gas measurement report at PT. INALUM (DTPL/SP/1008) and associated spreadsheet data Excel sheets showing detailed ex-ante calculation of emission reductions Documents related to monitoring Internal pot control panel inspection procedure (SEM-W109-301/1) Calibration procedure (SEM-PM25-001/4) External calibration certificate for Yokogawa portable calibrator Document indicating quality control and assurance system of AEF and AED measurement (SRO-SD24-021/0) Weighing scale procedure (SSW-W125-221/4) Organizational chart Internal correspondence indicating list and calibration schedule TV SD INDUSTRIE SERVICE GMBH
54. 55. 56. 57. 58. 59. 60. 61. 62. 63. 64. 65. 66. 67.
May 2003 09-05-2007 and 01-072008 respectively 2004 - 2007 -------26-29 February 2008 20-05-2008 -------15-05-1999 01-08-2003 31-04-2004 20-06-2008 15-01-2009 19-01-2009 20-01-2009

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 IRL No. Document or Type of Information 68. 69. 70. Weighing scale certificate Documents related to start date and project lifetime Contract agreement with Alcan Alesa Letter from Alcan Alesa indicating that PT. INALUM has applied the latest hardware technology with the new software generation and the spare part availability up to 10 years Documents related to Environmental Impact Assessment Ministry of Environment Decree (Keputusan Menteri Negara Lingkungan Hidup No. Kep-30/MENLH/10/1999 tentang Panduan Penyusunan Dokumen Pengelolaan Lingkungan) (The Ministry of Environment Decree shows that the company that has been operated before 1986 must have Environmental Management Document (EMD), later on referred as and equal to Environmental Impact Assessment (EIA). Environmental Management Document/EMD (Dokumen Pengelolaan Lingkungan (DPL) Industri Aluminium Ingot) Confirmation letter (Konfirmasi Dokumen Pengelolaan Lingkungan (DPL) PT. INALUM) (With respect to the system control change, PT. INALUM has a confirmation from the Local Environmental Agency that their current Environmental Management Document (EMD) can be still applied and referred as an equal to Environmental Impact Assessment (EIA) following the applicable Indonesian Law and Regulation as shown In the letter) Laporan Berkala Dokumen Pengelolaan Lingkungan PT. INALUM (Industri Aluminium Ingot)/EMD Report (Environmental Semester report of PT. INALUM as referred to the EMD to Department of Industry) Documents related to stakeholder consultation (SC) Invitation letter for SC meeting SC Attendance list SC Minutes of Meeting DNA application form (http://dna-cdm.menlh.go.id/id/projects/formulir-aplikasi.pdf) (The document indicates that the Indonesian DNA asks the project proponent to have Minutes of Meeting of Stakeholder Consultation (in Bahasa: Catatan Konsultasi Publik) before they submit the registration form)
Page 6 of 7
Date of document 25-03-2009 27-02-2007 10.03.2009
71.
1999
72. 73.
June 2000 19-03-2008
74.
12-02-2009
75. 76. 77. 78.
09-01-2008 15-01-2008 15-01-2008 --------

Project Title: PFC Emission Reduction at PT. Indonesia Asahan Aluminium (PT. INALUM) Kuala Tanjung Date of Completion: 20-04-2010 IRL No. Document or Type of Information Letter of Approvals (LoAs) 79. 80. 81. LoA from Designated National Authority (DNA) of Indonesia (E. 280 /Dep.III/LH/07/08) LoA from DNA of Switzerland (G514-3487) Others Modalities of Communication
Page 7 of 7
Date of document 31-07-2008 25-05-2009 11-05-2009

Validation Report

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Validation Report

South Pole Carbon Asset Management Ltd.

VALIDATION OF THE CDM-PROJECT:

REPORT NO. 1179637

Report No. 1179637

Date of first issue 14-07-2009

Revision No. 1.3

Date of this revision 20-04-2010

Final PDD version: Date of final issuance: Version No.: 22-09-2009 05

Annex 1: Validation Protocol Annex 2: Information Reference List

1 INTRODUCTION 1.1 Objective

2.1 Appointment of the Assessment Team

2.2 Review of Documents

2.3 Follow-up Interviews

Ms. Syahrina Anggraini

Program Director / CER Indonesia

2.4 Further cross-check

2.5 Resolution of Clarification and Corrective Action Requests

2.6 Internal Quality Control

3.3 Project design document

3.4 Project description

3.5 Baseline and monitoring methodology

3.5.2 Project boundary

3.5.3 Baseline identification

3.5.4 Algorithm and/or formulae used to determine emission reductions

3.5.4.1 Baseline Emissions

3.5.4.2 Project emissions

3.5.4.4 Emission Reductions

3.6.1 Prior consideration of the clean development mechanism

3.6.2 Identifications of alternatives

3.6.3 Investment analysis

3.6.4 Barrier analysis

3.6.5 Common practice analysis

3.7 Monitoring plan

3.8 Sustainable development

3.9 Local stakeholder consultation

3.10 Environmental impacts

4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS

Nikolaus Krger Assessment Team Leader

Annex 1: Validation Protocol

Validation Protocol (VP)

Table 1: Conformity of Project activity and PDD

A. General description of project activity

Description of the project activity

Table 1 is applicable to AM0030, Version 03

Validation Protocol (VP)

Technical description of the project activity

Table 1 is applicable to AM0030, Version 03

Validation Protocol (VP)

Technology to be employed by the project activity 1, 12, 13, 55

Table 1 is applicable to AM0030, Version 03

Validation Protocol (VP)

Validation Protocol (VP)

1, 14, 16, 17 1, 15, 18 1, 4, 11

Estimated amount of emission reductions over the chosen crediting period 1, 2

Table 1 is applicable to AM0030, Version 03

Validation Protocol (VP)

B. Application of a baseline and monitoring methodology

Table 1 is applicable to AM0030, Version 03

Validation Protocol (VP)

Table 1 is applicable to AM0030, Version 03

Validation Protocol (VP)

1, 21, 22, 56, 57

Table 1 is applicable to AM0030, Version 03