SOUTHERN REGIONAL LOAD DESPATCH CENTRE Vs. SR. VICE PRESIDENT (FINANCE), MEENAKSHI ENERGY PRIVATE LIMITED AND ORS.
CENTRAL ELECTRICITY REGULATORY COMMISSION
Southern Regional Load Despatch Centre
Sr. Vice President (Finance), Meenakshi Energy Private Limited And Ors.
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(1.) THE petitioner, Southern Regional Load Despatch Centre, has filed the present petition seeking direction to the respondent, Meenakshi Energy Private Limited, to maintain the injection of power strictly as per the schedule in terms of the provisions of the Central Electricity Regulatory Commission (Indian Electricity Grid Code) Regulations, 2010 (Grid Code) and the Central Electricity Regulatory Commission (Unscheduled Interchange Charges and related matters) Regulations, 2012 (Ul Regulations).
(2.) THE petitioner has submitted as under:
(a) Meenakashi Energy Private Limited (hereinafter referred to as MEPL) has set up a generating station comprising of two units of 150 MW, each.
(b) MEPL has been violating the limit of under -injection on time block basis as well as on daily aggregate basis as specified in Regulation 7(2) of the Ul Regulations which provides that under -injection by a seller shall not exceed 12% of the scheduled injection when the frequency is below 49.80 Hz and 3% on daily aggregate basis for all time blocks when the frequency is below 49.80 Hz.
(c) MEPL contracted for sale of power through Medium Term Open Access (MTOA), Short Term Open Access (STOA) and Power Exchange (PX) transactions from time to time. Based on the contracts entered into by MEPL, block -wise day ahead and daily schedule of injection were issued by SRLDC. MEPL has been deviating from the schedule through consistent under injection beyond the limits specified in the Ul Regulations. The extent of deviation ranged from 20% to 100% and in many instances, the violation was continuous for more than 50% of the day. The petitioner in support of its contention has submitted the following data regarding violation of grid discipline through under -injection by MEPL during the period 1.1.2013 to 10.9.2013:
(d) During the period of violation of grid discipline, i.e. 1.1.2013 to 10.9.2013, SRLDC issued directions to MEPL through real time messages to increase the generation up to the injection schedule. Since, the response to the real time messages was not satisfactory, the matter was taken up with the senior officers of MEPL informing them of consistent violation of the provisions of the Grid Code.
(e) Since under injection was continued by MEPL, the matter was reported to Member Secretary, Southern Regional Power Committee under Regulation 1.5 of Grid Code to resolve the issue. On 18.3.2013, 18.7.2013 and 16.9.2013, Member Secretary, Southern Regional Power Committee (SRPC) convened special meetings to resolve the issue of under -injection.
(f) In the said special meetings, MEPL was advised to take prompt action to comply with the provisions of the regulations and to revise MTOA. In the said meetings, MEPL expressed technical difficulties for proper assessment of generation level due to coal quality and machine performance. However, MEPL assured that it would comply with the provisions of Grid Code and Ul Regulations. Despite the assurance given by MEPL, there was no improvement in the scheduling by MEPL.
(g) As per Regulation 6.4.19 of the Grid Code, Inter -State Generating Station (ISGS) is required to demonstrate the declared capability of its generating station as and when asked by the RLDC. However, it does not make any regulatory provision for demonstration of declared capacity for Captive Power Plant having his own load as well as load of multiple transactions. Therefore, it is essential that the sellers ensure strict compliance of the provisions of relevant Regulations to maintain injection of power strictly as per the schedule issued by RLDC.
(h) During the special meetings convened by Member Secretary, SRPC, the following measures were suggested to MEPL to streamline the technical difficulties:
(i) Assess the injection capability properly and maintain adequate margin by entering into MTOA/STOA sale transactions conservatively. Any surplus margin observed in the day ahead, may be dealt through contingency/PX transaction.
(ii) Assess the coal quality properly and apply for STOA revision two days in advance to avoid deviation in injection of power w.r.t. schedule.
(iii) While declaring expected time of restoration of units followed by tripping of units, consider adequate margin of time based on past experience.
(iv) If there is delay in restoration beyond the expected declared time block, explore necessary procurement action on contingency/Power Exchange transaction.
(v) Since the present transactions are being carried out with the distribution companies of Andhra Pradesh, MEPL should explore the possibility of counter STOA transactions during outage of unit beyond expected restoration schedule which would facilitate Andhra Pradesh to get reduce its schedule proportionate to the injection level of MEPL.
(i) Despite the above suggestions, MEPL continues under -injection beyond the specified limit of Ul Regulations which has impact in system security as well as declaration of Available Transfer Capability/Total Transfer Capability (ATC/TTC) between S1 -S2 control areas. However, the buying regional entity i.e. APTRANSCO continues to draw the power as per its schedule despite the fact of less injection by MEPL.
In the above background, the petitioner has made the following prayers:
"(a) To maintain the injection of power strictly as per schedule in line with the relevant provisions of IEGC and Ul Regulations;
(b) To comply with the directions of SRLDC and act in accordance with the messages issued by SRLDC; and
(c) Pass any such order as deemed fit under the circumstances of the case."
(3.) THE petition was heard on 24.10.2013. The parties were directed to complete the pleadings. Reply to the petition has been filed by Meenakshi Energy Private Limited (MEPL) and APTRANSCO.;
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