Hyundai Steel Waste Energy Cogeneration Project

Audit Analysis

The Hyundai Steel Waste Energy Cogeneration Project is a VCS-registered avoidance project with a confirmed investment additionality test, but it carries an unusually large volume of material findings covering project boundary errors, baseline methodology non-compliance, emission factor miscalculations, and a KETS double-counting concern. While all corrective actions were resolved, the depth of initial design flaws and the project-specific baseline (contradicted by the monitoring report as jurisdictional) significantly undermine confidence in the robustness of the claimed reductions.

Project Description

Red Flags

• ⚠Material finding explicitly requires evidence that GHG reductions have not been counted under KETS (Korea ETS), raising a dual-channel double-counting risk that is not fully resolved in the extracted record
• ⚠Project boundary initially included combustion of waste gas for electricity and assigned zero value to purchased electricity — both corrected but indicating fundamental design errors in the PDD
• ⚠Baseline methodology did not follow the step-wise procedure of ACM0012, did not address Annex 1 or Annex 3, and the FWCM was not determined according to the methodology equations
• ⚠Emission factor calculation excluded specific KEPCO data set plants, did not apply the 95% confidence interval lower limit, and the step-wise electricity emission factor tool was not applied correctly
• ⚠Monitoring plan deviation: invoiced data used for electric generation instead of metered data as specified in the validated PDD; no standard meter for electricity consumption in actual operation

Credit Vintages