Proposed Amendment for Minimum Turndown Level Protection in Electricity Grid Code

The presentation discusses the draft amendment to the Indian Electricity Grid Code regarding the minimum turndown level protection for generating stations. It suggests using Security Constrained Unit Commitment (SCUC) instead of SCED to ensure minimum turndown levels are met, as illustrated through a detailed justification based on actual schedule trends. The amendment aims to optimize unit dispatch while respecting operational constraints and ensuring economic despatch of power.

• Electricity Grid Code
• Amendment
• SCUC
• Turndown Level
• Power Generation

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1. NLC INDIA LTD Presentation on Presentation on CERC (Indian Electricity Grid Code) (First Amendment) Regulations, 2024 - DRAFT DRAFT CERC PUBLIC HEARING ON 14TH AUGUST 2024 1

2. Comment 1 (Minimum Turndown Level Protection) Addition of new sub-clause (a)(v-a) after sub-clause (a)(v) of Clause (2) of Regulation 49 of the Principal Regulations: In case a regional entity generating station, whose tariff is determined under Section 62 of the Act, gets a schedule below minimum turndown level for Off-Peak hours of the day, however, gets a schedule above minimum turndown level for Peak hours of the day, the schedule below the minimum turndown level may, on the request by such generating station to NLDC shall be adjusted under SCED NLCIL s Comment: Instead of SCED, SCUC may be used to assure Minimum Turndown level in the above case. Security Constrained Economic Despatch (SCED) : Optimised despatch of generating units subject to operational and technical limits of generation and transmission facilities. It is based on willingness of Generators under Section 62. Security Constrained Unit Commitment (SCUC) : Committing generating units while respecting limitations of the transmission system and unit operating characteristics. It is compulsory for Generators under Section 62. 2

3. Detailed Justification for Comment 1 Through Actual Schedule Trend for NLCIL s two Thermal Stations on 11.08.2024 TPS1EXPN (ECR: 2.84 Rs/unit & MTL: 248MW) (ECR: 4.16 Rs/unit & MTL: 521MW) NTPL To keep higher cost units on bar to meet peak demand, SCUC UP schedule was given to those high cost units & SCUC down Schedule was given during 1PM comparatively low cost stations like TPS1EXPN & NTPL. Beneficiary Schedule (MW) Station Schedule without SCUC (MW) SCUC Schedule (MW) Station Schedule with SCUC (MW) Beneficiary Schedule (MW) Station Schedule without SCUC (MW) SCUC Schedule (MW) Station Schedule with SCUC (MW) Time Block Time Desc 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 13:00-13:15 13:15-13:30 13:30-13:45 13:45-14:00 14:00-14:15 14:15-14:30 14:30-14:45 14:45-15:00 15:00-15:15 15:15-15:30 15:30-15:45 15:45-16:00 16:00-16:15 16:15-16:30 16:30-16:45 16:45-17:00 17:00-17:15 17:15-17:30 17:30-17:45 17:45-18:00 18:00-18:15 18:15-18:30 18:30-18:45 18:45-19:00 301 301 301 301 302 302 302 302 302 302 331 367 367 370 370 370 375 375 376 376 375 375 377 377 301 301 301 301 302 302 302 302 302 302 331 367 367 370 370 370 375 375 376 376 375 375 377 377 -53 -53 -53 -53 -53 -53 -53 -53 -53 -53 -24 -60 -60 -62 -62 -62 -68 -68 -68 -68 - - - - 248 248 248 248 248 248 248 248 248 248 307 307 307 307 307 307 307 307 307 307 375 375 377 377 166 166 166 203 203 203 278 286 286 361 473 473 525 525 600 750 750 723 723 723 729 729 804 828 450 450 450 450 450 450 450 450 450 450 473 473 525 525 600 750 750 723 723 723 729 729 804 828 - - - - - - - - - - - - 450 450 450 450 450 450 450 450 450 450 473 473 521 521 525 671 671 671 671 671 671 671 724 828 to 7PM to On the same day, for same NTPL MTL is not protected during 1PM to 4PM when its own schedule was < MTL. -4 -4 As SCUC is more on about bar -75 -79 -79 -52 -52 -52 -58 -58 -80 - keeping assuring MTL schedule and SCED is more about Economic Despatch of Power, So SCUC may be used instead of SCED in the proposed Amendment. units by 3

4. Comment 2 (Obligations in case of Unit Shut Down (USD) As proposed in the Draft Regulation, the schedule below the Minimum Turndown Level (MTL) will be adjusted up to MTL only if a Generator gets schedule from Beneficiaries above MTL during Peak Hours. NLCIL s Comment: If the aforementioned condition is not met and the generator does not receive a feasible schedule throughout the day, then the generator will have two options: Opt 1:The generator may opt to undergo USD and revise its DC to zero. In this scenario, there won t be any obligation for Generator but despite being ready to dispatch the power, the generator would incur losses in fixed costs, resulting in under-recovery of investment on the project, irrespective of having a Power Purchase Agreement (PPA). Opt 2: Alternatively, the generator may choose to undergo USD without revising its DC. As per the CERC IEGC Regulation 2023 (Principal Regulation), the generator is obligated to fulfil its obligations during hours where the schedule is available by procuring power from another source or market. This arrangement may lead to financial losses for the generator. Therefore, it is humbly submitted that if ensuring the maintenance of the Minimum Turn-Down Level (MTL) schedule by all beneficiaries throughout the day is not mandated, then the obligation for the generator to supply power during USD may not be enforced. 4

5. 5 Thank You NLC INDIA LIMITED