What Corrective Action would you suggest in this instance?

S

samsung

#11
Re: What Corrective Action would you suggest in this instance ?

The Objective is directly in line with the Environmental policy ...:agree1:
The target of 5% for 2009 was based on good assessment of availability of required alternate resource... :agree1:
Achieving 2.7% while looking at 5% has indeed made progress towards meeting the intent of your E policy ... :agree1:
Now I still will look to meet my E policy in 2010 and having studied and assessed the alternate resource I will re-set my objective to meet say 4% as against my optimistic target of 5%.
I will continue this into 2010 and see where I am and what is the status of alternate resource as 2011 approaches. (I may even exceed the 4% that I have re-set)
If it looks promising (meet and exceed) I will go back to 5%, if not I will strive to touch and keep at 4% atleast.
ISO 14K provides for objectives and targets to be planned and to be in line with business objectives and economic dynamics.
Let the internal auditor learn what the ISO 14K opening pages says.
There is nothing more to prevent here, and you are already doing and preventing what you have best planned as your objectives and targets which is in line with the E policy.
Why is the auditor here thinking of the word "cost saving" ?
Since the objective was related to EMS, he never conceived that after all it's a business aspect and in view of unexpected price hike, the organization temporarily suspended pursuing this particular environmental objective. His contention was that since the rainfall was low in a particular area, it could have been imported from other states where the material was available in abundance, but on a higher market price, in order to (anyhow) meet the environmental objective.

The auditor is new to auditing and now, based on this discussion and subsequent learning, I can coach him properly.
 
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#12
Dear Samsung,

I have a fundamental question about biomass being used as a substitute for coal to reduce GHG emissions. If one calculates KCal/Kg of CO2 emission, one will find that biomass is not that attractive compared to coal. If we calculate Kg of CO2 emission/Kg of mass we may come to the faulty conclusion that biomass is an attractive alternative. I would be interested to know the basis for concluding that biomass is better than coal with respect to GHG emissions.

As for the discussion on objectives and targets, generally I agree with the line in which the discussion is proceeding. Your management review can address the issue and make recommendations for the mid-term correction of the target.

With kind regards,

Ramakrishnan
 
S

samsung

#13
Dear Samsung,

I have a fundamental question about biomass being used as a substitute for coal to reduce GHG emissions. If one calculates KCal/Kg of CO2 emission, one will find that biomass is not that attractive compared to coal. If we calculate Kg of CO2 emission/Kg of mass we may come to the faulty conclusion that biomass is an attractive alternative. I would be interested to know the basis for concluding that biomass is better than coal with respect to GHG emissions.

As for the discussion on objectives and targets, generally I agree with the line in which the discussion is proceeding. Your management review can address the issue and make recommendations for the mid-term correction of the target.

With kind regards,

Ramakrishnan
Biomass is a carbon neutral fuel and hence Kg of CO2 emitted per Kg of Biomass used is almost zero. Although the combustion of biomass as a fuel also returns CO2 to the atmosphere, yet this CO2 is the part of the current carbon cycle; i.e.; an equivalent amount of it was absorbed by the biomass from the atmosphere during the growth of the plant (through photosynthesis process) over the years. In this way, a sustainable balance is maintained between the part of carbon emitted and absorbed.

However, despite being marked out as a 'carbon neutral fuel', it's not perfectly carbon 'zero'. If we look at its entire life cycle from cradle to cremation, the carbon is usually emitted as a result of its planting, harvesting, processing, transport and the like processes. But the impact of all these processes (other than transport) in terms of additional resource utilization is taken into account only if it's exclusive produced for the purpose of burning as fuel. But it's not the case, as a matter of fact, the biomass normally used in industries as a replacement fuel, is the agriculture waste unsuitable for any other purposes (as fodder, fuel, etc.).

How we do:

1. It is sourced locally that contributes to improving the local economy in addition to reducing the cost & fuel consumed in transportation.

2. Based on the quantity and the heating value of the equivalent amount of coal saved, amount of CO2 is worked out.

3. CO2 contribution from the fuel consumed in it's transportation is calculated and subtracted from the gross CO2 contribution to calculate the net CO2 saved by using x quantity of biomass in a year.

4. It's storage may pose certain problems other than fire hazard. The stuff, under damp conditions, may decay allowing to generate methane whose Global Warming potential (GWP) is 21 times more than that of CO2. Means 1 Kg of methane = 21 Kg of CO2. So, if it happens, we shall have to subtract 21 Kg from the gross contribution for each Kg of methane we allowed to emit into the atmosphere.

But since it's locally sourced, we don't have to store large quantities at site and hence the risk of methane formation is unlikely.

However, some organic wastes such as rubber tyres, sludge, slaughter house residues, paper waste, paint residues etc. used as alternative sources of energy, are non-fossil but aren't carbon neutral fuels like biomass, yet they help to conserve fossil fuel such as coal.
 
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#14
Dear Samsung,

Thanks for the response. Please don't mistake me; my aim is to bring to your notice an important issue which we normally miss because of the popular perceptions.

I am aware of the points that you have made. It is a myth that biomass is a carbon-neutral fuel.

Still I am looking for an evidence in the form of "solid" numbers to prove that using biomass instead of coal brings down the CO2 emission for unit production. In fact, I raised this issue with one of the most eminent ecologists of India; I got only a silence as an answer. I do not question the use of biomass as an alternative fuel, which we have been doing in India for centuries. My question is about the claim that it reduces GHG emissions compared to fossil fuels per unit work (when you calculate the total CO2 emission please also consider, apart from what you have already indicated, that plants do breath, i.e. give out carbon dioxide in the process that takes place all the 24 hours). If you are using agricultural waste such as straw or husk, you may have to consider CH4 emission of paddy in the paddy field.

Fine tuning the wording of your objectives and targets will help you to avoid future questions from auditors.

With kind regards,

Ramakrishnan
 
S

samsung

#15
Dear Samsung,

Thanks for the response. Please don't mistake me; my aim is to bring to your notice an important issue which we normally miss because of the popular perceptions.

I am aware of the points that you have made. It is a myth that biomass is a carbon-neutral fuel.

Still I am looking for an evidence in the form of "solid" numbers to prove that using biomass instead of coal brings down the CO2 emission for unit production. In fact, I raised this issue with one of the most eminent ecologists of India; I got only a silence as an answer. I do not question the use of biomass as an alternative fuel, which we have been doing in India for centuries. My question is about the claim that it reduces GHG emissions compared to fossil fuels per unit work (when you calculate the total CO2 emission please also consider, apart from what you have already indicated, that plants do breath, i.e. give out carbon dioxide in the process that takes place all the 24 hours). If you are using agricultural waste such as straw or husk, you may have to consider CH4 emission of paddy in the paddy field.

Fine tuning the wording of your objectives and targets will help you to avoid future questions from auditors.

With kind regards,

Ramakrishnan
Hi Dr. Ramakrishnan,

You have indeed raised a very good point for discussion. Let me try to explain it.

I agree that the plants do breath and emit CO2 during the period they aren't busy with photosynthesis. But while considering the 'zero CO2 emissions' from the biomass, what matters most is the net weight of carbon that's finally assimilated/ fixed by the plants inside the tissues. They are carbon neutral as long as they are used as an alternative source of energy, else they are carbon positive (if prevented from landfilling or open burning). The energy so stored is also renewable in the sense that it's derived directly from the sun.

On the other hand, although the fossil fuels too have their origin in biomass (in ancient times), they are not considered 'carbon neutral' because they contain carbon that has been "out" of the (current) carbon cycle long back and their combustion therefore disturbs the carbon dioxide concentration in the atmosphere.

Let's look at it other way. What would happen to the biomass residue (Agro waste), if it isn't used as an alternative fuel ? It would either be landfilled or burnt in open; the former will generate methane under anaerobic conditions while the later would pose significant hazards to environment & also to human health as a result of generation of CO2 & other toxic gases. If biomass isn't used as a source of energy, an equivalent amount of coal would have to be used which in any case, is not a carbon neutral fuel.

Use of biomass is one of our CDM projects that utilizes the UNFCCC's approved baseline methodology ACM 003, ("Emissions reduction through partial substitution of fossil fuels with alternative fuels in cement manufacture") for arriving at the net GHG contribution. UNFCCC too has recognized the biomass as carbon neutral fuels (subject to fulfillment of certain conditions) and has laid down detailed criteria for project monitoring as well as for assessment of GHG emissions. Copy of ACM003 is attached for reference. Other related docs. are also available here.

Carbon credits, in this project, are basically awarded not only for conserving coal but also for avoiding methane generation by preventing disposal of the stuff into lnadfills or it's uncontrolled burning in open.

I welcome yours as well as of other members' views & opinion on this interesting subject.

Thanks,
 

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