Consolidated Report on the Findings of the … › Admin › Document › Editor › file ›...

Consolidated Report on the Findings of the Electricity Generation Industry Compliance audits Conducted in 2016/17 FY

I

Consolidated Report on the Findings of the

Electricity Generation Industry Compliance

Audits Conducted in 2016/17

Financial Year


I

All enquiries and correspondence to be directed to the Head of Department unless

indicated otherwise by means of a formal letter signed by the Head of Department:

Electricity Licensing, Compliance and Dispute Resolution.

Tel : +27 (0)12 401 4794

National Energy Regulator

Kulawula House

526 Madiba Street

Arcadia, Pretoria

0083

PO Box 40343

Arcadia

0007

Tel : +27 (0)12 401 4600

Fax : +27 (0)12 401 4700

Website : www.nersa.org.za

http://www.nersa.org.za/


II

TTAABBLLEE OOFF CCOONNTTEENNTTSS

ABBREVIATIONS ............................................................................................................ III

DEFINITIONS .................................................................................................................. IV

EXECUTIVE SUMMARY .................................................................................................. VI

1. INTRODUCTION .................................................................................................... 1

2. AUDIT OBJECTIVES ............................................................................................. 3

3. AUDIT PROCESS .................................................................................................. 3

4. AUDIT METHODOLOGY ....................................................................................... 4

5. SCOPE OF WORK ................................................................................................. 4

6. CHALLENGES FOR THE SOLAR FARMS ............................................................ 5

7. FACTS AND FIGURES .......................................................................................... 5

8. SUMMARY OF OBSERVATIONS AND AUDIT FINDINGS .................................... 6

8.1 ELECTRICITY GENERATION LICENCE...................................................................... 7

8.2 DISTRIBUTION INFORMATION EXCHANGE CODE ..................................................... 8

8.3 DISTRIBUTION NETWORK CODE ........................................................................... 9

8.4 THE GRID CONNECTION CODE FOR RENEWABLE POWER PLANTS ........................ 10

8.5 DISTRIBUTION SYSTEM OPERATING CODE .......................................................... 11

8.6 GENERATION MAINTENANCE STRATEGY ............................................................. 11

8.7 PLANT PERFORMANCE AND KEY PERFORMANCE INDICATORS (KPIS) ................... 12

8.8 OUTAGE MANAGEMENT ..................................................................................... 12

8.9 ASSET MANAGEMENT ........................................................................................ 13

8.10 REFURBISHMENT AND EXPANSION PLANS ........................................................... 13

9. PLANT INSPECTION ........................................................................................... 13

9.1 SCOPE OF PLANT INSPECTION ........................................................................... 13

9.2 ON-SITE OBSERVATIONS .................................................................................... 13

10. CONCLUSION...................................................................................................... 19

11. RECOMMENDATION ........................................................................................... 20


III

AABBBBRREEVVIIAATTIIOONNSS

DoE Department of Energy

DCUOSA Distribution Connection Use of System Agreement

GCR Grid Code Requirement

HV High Voltage

MW Megawatt

MV Medium Voltage

NERSA National Energy Regulator

OEM Original Equipment Manufacturer

PPA Power Purchase Agreement

SAGC South African Grid Code

SAP System Application and Production


IV

DDEEFFIINNIITTIIOONNSS

Buyer

The legal entity designated by the Minister in the Determination as the buyer of Energy

from Sellers in terms of Power Purchase Agreements entered into pursuant to the

Independent Power Producer Procurement Programme.

Distributor

A legal entity that owns or operates/distributes electricity through a Distribution System.

Distribution System

An electricity network consisting of assets operated at a nominal voltage of 132 kV or less.

Generator

A legal entity licensed to engage in the production of electricity through an electricity

generation facility.

Grid Code

The ‘South African Grid Code’, which consists of the following documents, as approved by

NERSA and updated from time to time by the Secretariat:

Preamble;

Governance Code;

Network Code;

System Operation Code;

Metering Code;

Tariff Code; and

Information Exchange Code.

It also includes the Distribution Code, which consists of the following:

Distribution Code Definitions;

Distribution Information Exchange;

Distribution Network Code;

Distribution System Operation Code;

Distribution Metering Code; and

Distribution Tariff Code.

Licensees

AE-AMD Independent Power Producer 1 (Pty) Ltd;

Core Energy (Pty) Ltd;

CPV Power Plant no.1 (Pty) Ltd;

Droogfontein Solar Power (RF) (Pty) Ltd;


V

De Aar Solar Power (RF) (Pty) Ltd;

Firefly 253 Investments (Pty) Ltd;

Oakleaf Investments Holdings 79 (Pty) Ltd;

RustMo1 Solar Farm (Pty) Ltd;

Slimsun (Pty) Ltd;

Solar Capital De Aar (Pty) Ltd;

Sevenstones 159 (Pty) Ltd; and

Scatec Solar SA 166 (Pty) Ltd.

Solar Farm

The licensed Photovoltaic (PV) power generation facility.

System Operator

A legal entity licensed to be responsible for short-term reliability of the interconnected

power system, which is in charge of controlling and operating the transmission system

and dispatching generation (or balancing the supply and demand) in real time.

Transmission System

The transmission system consists of all lines and substation equipment where the nominal

voltage is above 132 kV. All other equipment operating at lower voltages are either part of

the distribution system or classified as transmission transformation equipment.


VI

EEXXEECCUUTTIIVVEE SSUUMMMMAARRYY

The Electricity Regulation Act, 2006 (Act No. 4 of 2006) (‘the Act’), stipulates that the

Regulator must enforce performance, compliance and take appropriate steps in the case

of non-performance.

Pursuant to Section 4(a)(vii) of the Act, all licensed entities are subject to an audit for

compliance with licence conditions imposed by the Energy Regulator. The audit objectives

are to assess compliance with applicable regulatory requirements, validate evidence of

self-reported non-compliances, document the licensees’ compliance level and plans, and

monitor the implementation of corrective action plans.

There are approximately 150 electricity generation licensees; the state-owned entity,

municipal generation, and independent power producers. The total number of licensed

generation facilities consists of about 305 operational, 7 non-operational or

decommissioned and 27 new-build facilities. The total capacity is apportioned as follows:

operational capacity is about 52 133MW, decommissioned capacity is 1 058MW and

capacity under construction equates to 10 979MW. The selection criteria for the

representative sample of generation facilities audited is based on:

the type of licensee, for example municipal generators may be audited together so as

to establish common practices and challenges;

information submitted to NERSA through G-forms, production figures or any other

forms;

the audit cycle in terms of the compliance framework;

the power contribution or impact of the generation facility on the national grid;

research or data collected through desktop monitoring or media; and

a mixture of age, type of technology and location.

The twelve licensees that were audited in the 2016/17 financial year operate Photovoltaic

(PV) solar farms and supply power to the grid. All licensees are part of the Department of

Energy (DoE) Renewable Energy Independent Power Producer procurement programme,

which was initiated by the Ministerial Determination issued by the Minister of Energy on 02

July 2011. Table 1 shows a list of licensees that were audited.


VII

Table 1: List of licensees audited for 2016/17 financial year

Licensee Solar Farm Name Contracted

Capacity in MWh

Audit Date

AE-AMD Independent Power

Producer 1(Pty) Ltd

Greefspan PV

Power Plant

9.9 27 September

2016

Core Energy (Pty) Ltd Witkop Solar Park 30 19 July 2016

CPV Power Plant no.1 (Pty) Ltd CPV Power Plant

No 1

36 27 October 2016

De Aar Solar Power (RF) (Pty)

Ltd

De Aar Solar Power 45.6 24 August 2016

Droogfontein Solar Power (RF)

(Pty) Ltd

Droogfontein Solar

Power

48.5 23 August 2016

Firefly 253 Investments (Pty) Ltd Letsatsi Solar PV

Power Station

64 14 July 2016

Oakleaf Investments Holdings

79 (Pty) Ltd

Lesedi PV 64 07 September

2016

RustMo 1 Solar Farm (Pty) Ltd RustMo1 Solar

Farm

6.93 07 September

2016

Scatec Solar SA 166 (Pty) Ltd Kalkbult 75 25 October 2016

Sevenstones 159 (Pty) Ltd Aries Solar PV

Facility

10 29 September

2016

SlimSun (Pty) Ltd Slimsun Swartland

Solar Park

5 21 June 2016

Solar Capital De Aar (Pty) Ltd Solar Capital De

Aar

75 30 August 2016

The two-fold audit included a compliance assessment and plant inspection. The audited

licensees are in compliance with the licence conditions. Table 2a and 2b below represent

a snap-shot of the compliance status of the licensees.

Table 2a: A snap-shot of compliances

Compliance requirement Licensees’ compliance status

8.1 Compliance with Electricity Generation Licence

All Licensees have valid electricity

generation licences and comply with

licence conditions, such as to submit

production figures for the solar farms in

a manner prescribed by NERSA, and

submitted audited financial statements

for the 2014/15 financial year.

8.2 Compliance with the Distribution Network Code

All Licensees have a maintenance

agreement in place which details the

responsibility of the Licensee and the

Distributor for equipment at point of

connection.


VIII

Table 2b: A snap-shot of non-compliances

Compliance requirement Licensees’ compliance status

8.5 Compliance with the Distribution System Operating

Code

Approximately 30% of the Licensees do

not have a procedure for fault reporting

and incident investigations and 15% do

not have a procedure for outage

scheduling.


1

11.. IINNTTRROODDUUCCTTIIOONN

The National Energy Regulator (NERSA) derives its mandate to conduct compliance

audits for licensed electricity Generators from the Electricity Regulation Act, 2006 (Act

No. 4 of 2006) ('the Act'). The Act empowers the National Energy Regulator as the

custodian and enforcer of the regulatory requirements.

The Regulator is empowered to execute functions such as to enforce performance

and compliance, and take appropriate steps in the case of non-performance.

There are approximately 150 electricity generation licensees, including the state-

owned entity, Eskom, municipal generation, and independent power producers. The

total number of licensed generation facilities consists of about 305 operational, 7 non-

operational or decommissioned and 27 new-build facilities. The total capacity is

apportioned as follows: operational capacity is about 52 133MW, decommissioned

capacity is 1 058MW and capacity under construction equates to 10 979MW. The

selection criteria for the representative sample of generation facilities audited is based

on:

the type of licensee, for example municipal generators may be audited together so

as to establish common practices and challenges;

information submitted to NERSA through G-forms, production figures or any other

forms;

the audit cycle in terms of the compliance framework;

the power contribution or impact of the power station on the national grid;

research or data collected through desktop monitoring or media; and

a mixture of age, type of technology and location.

In the 2016/17 financial year, NERSA conducted audits for the electricity generation

industry, specifically the renewable power plants operated by Independent Power

Producers (IPPs). All of the licensees that were audited are part of the Department of

Energy (DoE) Renewable Energy Independent Power Producer procurement

programme, which was initiated by the Ministerial Determination issued by the

Minister of Energy on 02 July 2011. Table 3 provides a list of licensees that were

audited in the 2016/17 financial year.


2

Table 3: The licensees audited in the 2016/17 financial year

Licensee Solar Farm

Name

Capacity in MW Status of the

Solar Farm

Audit Date

Lic

en

sed

Co

ntr

acte

d

AE-AMD

Independent

Power Producer

1(Pty) Ltd

Greefspan PV

Power Plant

10 9.9 Operational 27 September

2016

Core Energy

(Pty) Ltd

Witkop Solar

Park

30 30 Operational 19 July 2016

CPV Power

Plant no.1 (Pty)

Ltd

36 36 Operational 27 October

2016

De Aar Solar

Power (RF)

(Pty) Ltd

De Aar Solar

Power

50 45.6 Operational 24 August

2016

Droogfontein

Solar Power

(RF) (Pty) Ltd

Droogfontein

Solar Power

50 48.5 Operational 23 August

2016

Firefly 253

Investments

(Pty) Ltd

Letsatsi Solar PV

Power Station

64 64 Operational 14 July 2016

Oakleaf

Investments

Holdings 79

(Pty) Ltd

Lesedi PV 64 64 Operational 07 September

2016

RustMo 1 Solar

Farm (Pty) Ltd

RustMo1 Solar

Farm

7 6.93 Operational 07 September

2016

Scatec Solar SA

166 (Pty) Ltd

Kalkbult 75 75 Operational 25 October

2016

Sevenstones

159 (Pty) Ltd

Aries Solar PV

Facility

10.75 10 Operational 29 September

2016

SlimSun (Pty)

Ltd

Slimsun

Swartland Solar

Park

5 5 Operational 21 June 2016

Solar Capital De

Aar (Pty) Ltd

Solar Capital De

Aar

75 75 Operational 30 August

2016


3

22.. AAUUDDIITT OOBBJJEECCTTIIVVEESS

All licensed entities are subject to an audit for compliance with licence conditions as

imposed by the Regulator. The audit objectives are to:

assess compliance with the requirements of the Electricity Generation Licence

conditions and the South African Grid Code;

validate evidence of self-reported non-compliances;

document the licensees’ compliance level and plans; and

monitor and enforce the implementation of corrective action plans.

33.. AAUUDDIITT PPRROOCCEESSSS

The compliance audit assessment and site visit serve as an information gathering

process. The information that is collected together with evidence that is submitted by

the licensee is analysed. Subsequently, an audit report detailing the record of

observations, findings and recommendations is compiled for each licensee according

to the number of its generation facilities. The reports are sent to the licensee for

comments. On receipt of the comments, the audit report is finalised and a

consolidated audit report detailing a summary of observations, findings and

recommendations for all the power stations that were audited in the financial year is

prepared for approval by the Energy Regulator. The approved reports are sent to the

licensees, who must develop a corrective action plan to address the findings of the

audit. NERSA then monitors and enforces the implementation of the corrective action

plan to assist the licensees to comply with its licence conditions. The various stages

of the audit process involve the following activities, as outlined in Table 4 below.

Table 4: The various stages of the audit process

Stage 1:

Pre-site visit activities

Establish an audit team.

Establish communication with the licensees to be audited.

Prepare audit questionnaire.

Compile audit programme, agenda, and presentation.

Prepare audit packages.

Travelling to site and logistics.

Stage 2:

On-site visit activities

Presentations detailing the aim of the audit and the audit

process.

Conduct compliance audits assessment on the licensee

and take notes.

Conduct plant inspection.

Stage 3:

Post-site visit activities

Consolidate licensee responses.

Compile licensee individual audit reports.

Send individual audit reports to the audited licensees for

comments.

Incorporate the licensees’ comments and finalised audit

reports.

Compile a consolidated audit report.

Prepare submissions to the Energy Regulator.

Request licensees to submit corrective action plans.

Monitor the implementation of the corrective action plans.


4

44.. AAUUDDIITT MMEETTHHOODDOOLLOOGGYY

An audit questionnaire is the main document used to facilitate the audit and to

determine the level of the licensees' compliance. It was sent to the licensees before

the day of the audit for preparation. The following documents are the basis for the

audit questionnaire:

the Electricity Regulation Act, 2006 (Act No. 4 of 2006);

the Generation Compliance Monitoring Framework;

the Electricity Generation Licence issued to the licensee;

the National Environmental Management Act, 1998 (Act No. 107 of 1998);

the Occupational Health and Safety Act, 1993 (Act No.85 of 1993);

the Grid Connection Code for Renewable Power Plants connected to the electricity

Transmission System or the Distribution System in South Africa, version 2.8 of July

2014 and

the South African Grid Code (SAGC), version 9.0 of July 2014, including the

Distribution Code, version 6.0 of July 2014.

The questionnaire is divided into 13 sections; the five compliance requirement

sections relate to:

the Electricity Generation Licence conditions;

the South African Grid Code – Distribution Information Exchange Code;

the South African Grid Code – Distribution Network Code;

the Grid Connection Code for Renewable Power Producers; and

the South African Grid Code – Distribution System Operating Code.

The other eight sections of the questionnaire are aimed at establishing whether the

licensees align themselves with the industry standards and best practices with regard

to reliability, safe and sustainable operation of the licensed facilities. The sections are

as follows:

Generation Maintenance Strategy;

Plant Performance;

Outage Management;

Asset Management;

Refurbishment and Expansion Plans;

Environmental Assessment;

Occupational Health and Safety Assessment and

Business Assessment.

55.. SSCCOOPPEE OOFF WWOORRKK

The scope of work involved the activities detailed in Section 3 (‘Audit Process’) of this

report. Table 5 indicates the solar farms that were audited in the 2016/17 financial

year.


5

Table 5: The solar farms audited in 2016/17 financial year

Licensee Solar Farm Name

AE-AMD Independent Power Producer 1(Pty) Ltd

Greefspan PV Power Plant

Core Energy (Pty) Ltd Witkop Solar Park

CPV Power Plant no.1 (Pty) Ltd CPV Power Plant No 1

De Aar Solar Power (RF) (Pty) Ltd De Aar Solar Power

Droogfontein Solar Power (RF) (Pty) Ltd Droogfontein Solar Power

Firefly 253 Investments (Pty) Ltd Letsatsi Solar PV Power Station

Oakleaf Investments Holdings 79 (Pty) Ltd Lesedi PV

RustMo 1 Solar Farm (Pty) Ltd RustMo1 Solar Farm

Scatec Solar SA 166 (Pty) Ltd Kalkbult

Sevenstones 159 (Pty) Ltd Aries Solar PV Facility

SlimSun (Pty) Ltd Slimsun Swartland Solar Park

Solar Capital De Aar (Pty) Ltd Solar Capital De Aar

66.. CCHHAALLLLEENNGGEESS FFOORR TTHHEE SSOOLLAARR FFAARRMMSS

All licensees are experiencing challenges; some challenges are common to a number

of licensees, whereas others are unique to a particular licensee or solar farm. For

example, a few of the solar farms experienced lightning strikes on the PV modules

and the reason for the incidents is currently unknown. One of the solar farms had a

unique challenge as it was unable to reach its estimated P50 MWh forecast due to

low irradiance.

77.. FFAACCTTSS AANNDD FFIIGGUURREESS

The 12 solar farms supply power up to the contracted capacity that the licensee and

Eskom (‘the Buyer’) agreed on in the Power Purchase Agreement (PPA). The energy

contribution from the audited solar farms is as outlined in Table 6 below.

Table 6: Energy contributed by the audited solar farms in 2014, 2015 and 2016

Name of audited

licensee

Energy generated

(MWh) in 2014

Energy generated

(MWh) in 2015

Energy generated

(MWh) in 2016

AE-AMD

Independent Power

Producer 1(Pty) Ltd

19 012 26 869 27 471


6

Name of audited

licensee

Energy generated

(MWh) in 2014

Energy generated

(MWh) in 2015

Energy generated

(MWh) in 2016

Core Energy (Pty)

Ltd

18 431 66 493 64 346

CPV Power Plant

no.1 (Pty) Ltd

6 434 69 050 74 364

De Aar Solar Power

(RF) (Pty) Ltd

83 917 94 368 96 728

Droogfontein Solar

Power (RF) (Pty) Ltd

81 931 94 178 92 889

Firefly 253

Investments (Pty) Ltd

92 236 145 990 143 407

Oakleaf Investments

Holdings 79 (Pty) Ltd

93 324 148 706 150 878

RustMo 1 Solar Farm

(Pty) Ltd

11 811 11 978 12 427

Scatec Solar SA 166

(Pty) Ltd

150 528 143 433 143 531

Sevenstones 159

(Pty) Ltd

21 050 20 256 20 900

SlimSun (Pty) Ltd 0 4 705 10 520

Solar Capital De Aar

(Pty) Ltd

64 777 151 309 111 219

643 451 977 335 948 680

The total power contribution for 2014, 2015 and 2016 was 643 451MWh, 977

335MWh and 948 680MWh respectively.

88.. SSUUMMMMAARRYY OOFF OOBBSSEERRVVAATTIIOONNSS AANNDD AAUUDDIITT FFIINNDDIINNGGSS

Observations and findings related to compliance with the licence conditions, the

South African Grid Code, and best engineering practices were identified and shared

with the licensees. Where applicable, possible options for corrective actions were

discussed with the licensees during the audit process. Furthermore, the individual

audit reports present recommendations to address the audit findings and non-

compliances. Each subheading below briefly discusses the findings and status of

compliance of the licensees.


7

In each compliance requirement section, the total compliance rating equates to 100%,

and the compliance rating is apportioned equally according to the number of

compliance items within the section. The outcome compliance status of the licensees

is then graphically represented in Graph 1.

8.1 ELECTRICITY GENERATION LICENCE

The licence conditions stipulate the conditions under which the generation

facility must operate to ensure compliance with the regulatory requirements. It

stipulates that the licensee must maintain separate accounts for the solar farm,

submit annual financial information, production figures and any other

information as prescribed by NERSA. It also states that the licensee must

inform NERSA of any change of company details or the process of generation

or the operational status of the solar farm.

Table 7 below contains a summary of electricity generation licence compliance

requirements and the licensees’ compliance status.

Table 7: Licensees’ compliance status with electricity generation licence

Licence condition

requirement

Compliance

rating (%)

Compliance Status

Compliant Non-

Compliant

Maintain separate accounts and

submit audited financials for the

generation facility.

16.7

A, B, C, D, E, F,

G, H, I, J, K, L

Submit production figures in a

manner prescribed by NERSA.

16.7

A, B, C, D, E, F,

G, H, I, J, K, L

Validity of the electricity

generation licence.

16.7

A, B, C, D, E, F,

G, H, I, J, K, L

Changes of details of licensee.

16.7

A, B, C, D, E, F,

G, H, I, J, K, L

Changes in operational status or

generation process of the Solar

Farm.

16.7

A, B, C, D, E, F,

G, H, I, J, K, L

Validity of PPA and contracted

capacity.

16.7

A, B, C, D, E, F,

G, H, I, J, K, L

Total compliance rating 100%(16.7x 6)


8

Key to Table 7

A: AE-AMD Independent Power Producer 1(Pty) Ltd

B: Core Energy (Pty) Ltd

C: CPV Power Plant no.1 (Pty) Ltd

D: De Aar Solar Power (RF) (Pty) Ltd

E: Droogfontein Solar Power (RF) (Pty) Ltd

F: Firefly 253 Investments (Pty) Ltd

G: Oakleaf Investments Holdings 79 (Pty) Ltd

H: RustMo 1 Solar Farm (Pty) Ltd

I: Scatec Solar SA 166 (Pty) Ltd

J: Sevenstones 159 (Pty) Ltd

K: SlimSun (Pty) Ltd

L: Solar Capital De Aar (Pty) Ltd

8.2 DISTRIBUTION INFORMATION EXCHANGE CODE

The code defines the reciprocal obligations of parties, the Generator and

Distributor, with regard to the provision of information for the implementation of

the Grid Code. The information requirements are divided into planning

information, operational information, post-dispatch information and treatment of

confidential information. The code requires both the Generator and the

Distributor to designate personnel for information exchange. Table 8 contains a

summary of the licensees’ compliance status with the Distribution Information

Exchange Code.

Table 8: Licensees’ compliance status with the Distribution Information Exchange

Code

Distribution Information

Exchange Code requirements

Compliance

rating (%)

Compliance Status

Compliant Non-

Compliant

Procedures to address the

requirements of the Distribution

Information Exchange Code e.g.

appointment of designated person

to facilitate communication with the

Distributor or Network operator,

method of communication.

25

A, B, C, D, E,

F, G, H, I, J, K,

L

Operational data storage, the

provision of a storage facility,

access control and data retention

period.

25

A, B, C, D, E,

G, H, I, J, K, L

Submission of information to the

Distributor regarding new or altered

equipment at point of connection.

25

A, B, C, D, E,

G, H, I, J, K, L

Commissioning and notification

procedure in place.

25

A, C, D, E, G,

H, I, J, K, L

B

Total compliance rating 100% (25 x 4)


9

Key to Table 8













The licensees cite the PPA and the Distribution Connection and Use of System

Agreement (DCUOSA) as documents that contain the procedures relating to the

requirements of the Distribution Information Exchange Code. All licensees do

not have standalone formal procedures related to transfer of information,

submission of information related to new or altered equipment at point of

connection, data storage and archiving of operational information; and

commissioning and notification. However, some have designated persons to

facilitate communication with the Distributor, submit information of new or

altered equipment at point of connection, established appropriate data storage

facilities with access control features and capability to retain data for more than

five years.

8.3 DISTRIBUTION NETWORK CODE

The code requires the licensee and the Distributor to conclude a connection and

supply agreement, whereby the parties agree on connection conditions and

responsibilities of each party in terms of maintenance and operation of

equipment at the point of connection. The Distributor stipulates protection

equipment requirements for generators prior to connection to the network. Table

9 below shows the compliance status of the licensees.

Table 9: Licensees’ compliance status with the Distribution Network Code

Distribution Network Code

requirements

Compliance

rating (%)

Compliance Status

Compliant Non-Compliant

Maintenance agreement for

equipment at point of

connection.

25

A, B, C, D, E, F,

G, H, I, J, K, L

Connection and supply

agreement in place.

25

A, B, C, D, E, F,

G, H, I, J, K, L

Capability to remotely report

any status change of any

critical function that may

25

A, B, C, D, E, F,

G, H, I, J, K, L


10


requirements

Compliance

rating (%)

Compliance Status


negatively impact on the

quality of supply on the

Distribution system

(telemetry).

Does the licensee dispatch or

synchronise its plant using

appropriate equipment and in

line with the code

requirements.

25

A, B, C, D, E, F,

G, H, I, J, K, L

Total compliance rating 100% (25x4)

Key to Table 9













All of the above listed requirements are implemented through the DCUOSA and

PPA.

8.4 THE GRID CONNECTION CODE FOR RENEWABLE POWER PLANTS

The Grid Connection Code for Renewable Power Plants requires all Renewable

Power Plants (RPPs) to demonstrate compliance with all applicable

requirements specified in the code and any other applicable code or standard

approved by NERSA before being allowed to connect to the Distribution System

or the Transmission System and operate commercially.

Almost half of the plants do not comply with certain requirements under

Abnormal Operation Conditions, Reactive Power Capabilities, Power Quality

and the Provision of Data and Dynamic Simulation Models. All the licensees

were granted temporary exemptions while investigating possible solutions to

address the non-compliances. However, some of the exemptions have expired

while the non-compliances have not been addressed. The licensees need to

apply for the extension of the exemptions and ensure that the non-compliances

are addressed.


11

8.5 DISTRIBUTION SYSTEM OPERATING CODE

The code sets out the responsibilities and roles of those connected to the

network as far as the operation of the Distribution System is concerned and

more specifically, issues such as economic operation, reliability and security of

the Distribution System, operation under normal and abnormal conditions,

maintenance coordination/outage planning and safety of personnel. Table 10

below contains the licensees’ compliance status with the Distribution System

Operating Code.

Table 10: Licensees’ compliance status with the Distribution System Operating

Code


requirements

Compliance

score (%)

Compliance Status


Cooperation with the Distributor

in executing all the operational

activities during an emergency

generation condition.

33.3 A, B, C, D, E, F

G, H, I, J, K, L

Procedure for outage

scheduling and safety co-

ordination.

33.3 A, C, D, E, F, G,

H, I, J, K

B, L

Procedure for fault reporting

and analysis/Incident

Investigations.

33.3 A, C, F, G, H, I,

J, K, L

A, B, D, E

Total compliance rating 100%(33.3x3)

Key to Table 10













Although there are no procedures in place for most solar farms, the activities

that would have been documented in the procedures are implemented to a

larger extent. The licensees need to formalise the activities in writing.

8.6 GENERATION MAINTENANCE STRATEGY

The basis for maintenance planning is Original Equipment Manufacturer (OEM)

recommendations for all licensees. There is sufficient time to schedule planned


12

maintenance as the PV plants are only operational during daytime when there is

sunshine.

Some of the licensees have a maintenance planning system to schedule and

keep records of proactive, preventive and reactive maintenance, whereas

others do not have a maintenance planning system, but use Microsoft Office

software such as an Excel spreadsheet.

The licensees’ strategy to manage maintenance planning is in line with

international best practice aimed at ensuring that maintenance of equipment is

carried out timeously and in an orderly manner, deriving optimal performance

and preserving the life of the equipment.

8.7 PLANT PERFORMANCE AND KEY PERFORMANCE INDICATORS (KPIS)

The licensees submitted estimated energy generation and capacity factors for

the solar farms. Graph 1 below represents a comparison of the capacity factor

estimated during the licence application and the actual capacity factor.

The actual capacity factor for Solar Capital De Aar (Pty) Ltd (SCD) is 38% less

than the estimated, whereas that of CPV Power Plant No.1 (Pty) Ltd (CPV) and

RustMo1 Solar Farm (Pty) Ltd (RustMo1) is 45% and 33% above the estimate.

It would appear that the estimated capacity factor of 37% for SCD was

unrealistic or an error. On the other hand, CPV estimated an energy generation

of 46GWh for the first year of operation but the actual energy generation was

67GWh, hence, the 45% variance in capacity factor.

8.8 OUTAGE MANAGEMENT

The licensees undertake outage management in accordance with OEM

instructions. They take advantage of the night when the plants are not

generating to do planned and corrective maintenance to avoid outages during

the day when the solar farms are generating. In the event of forced outages that


13

will constitute a 10% loss of achieved capacity, the licensees immediately

notifies the System Operator or Distributor as per the agreement between the

parties stipulated in the PPA.

8.9 ASSET MANAGEMENT

The plant equipment in most of the audited solar farms is partially labelled so as

to identify the equipment on the asset register. Most of the solar farms use a

functional location system to identify equipment and a coding system for

identification of components. All assets, including plant equipment, are recorded

in the asset register, which is updated continuously.

8.10 REFURBISHMENT AND EXPANSION PLANS

All the solar farms are new as they were first commissioned between 2013 and

2014. Approximately 58% of the solar farms that were audited have an

expected lifespan of 20 years, while the remaining 42% are estimated at 25 and

30 years. The solar farms currently do not have any future expansion plans

beyond 20 years of PPA period.

99.. PPLLAANNTT IINNSSPPEECCTTIIOONN

9.1 SCOPE OF PLANT INSPECTION

The plant inspection was conducted as complementary to the audit

questionnaire.

The inspection covered the following aspects:

a) safety of equipment;

b) display of safety signs and emergency evacuation routes;

c) environmental issues;

d) housekeeping, for example cleanliness, neatness and tidiness; and

e) plant labelling.

The following areas were inspected:

a) PV modules;

b) Inverters;

c) MV switchgear;

d) transformers;

e) substation, station control and batteries;

f) critical spares storage; and

g) fire protection equipment.

9.2 ON-SITE OBSERVATIONS


14

It is essential to ensure that plant equipment is adequately labelled for safety

reasons. Equipment should be easily identifiable so that mistakes are avoided

where an employee might inadvertently work on equipment that is in service. In

addition, plant equipment labelling forms part of asset management.

Safety and evacuation signs are essential for the safety of personnel under

normal operations and in case of an emergency where personnel working in the

plant need to evacuate quickly. Table 11 to 16 indicates the areas that were

inspected as a sample representation of the solar farm.

Table 11: PV Modules inspection

A B C D E F G H I J K L

PV Modules

Check for

dust or

debris on

surface of

PV

Module

IO IO IO IO IO IO IO IO IO IO IO IO

Check for

physical

damage to

the PV

module


PV

module

labelling

PI PI IM IM IM IM IM IM IM IM IM IM

Check for

cable

conditions

e.g. wear

& tear,

burn

marks, hot

spots or

loose

connec-

tions


Safety

signs

clearly

displayed

PI IM PI IM IM PI PI IM PI PI IM PI

Key to Table 11 to Table 16










15





IM: Implemented to a large extent

IO: In order

NA Needs attention

PI: Partially implemented, there is room for improvement

N: Not implemented or do not exist

NI: Not inspected

NO None observed

Table 12: PV Inverter inspection


PV Inverter

Inverter

operational

data or plant

output e.g.

nameplate

info & display

parameters

such as

output

voltage, MW,

operating

temperature

IM IM IM IM IM IM IM IM IM IM IM IM

Check for

cable

conditions e.g.

wear & tear,

burn marks,

hot spots or

loose

connections


Ventilation IM IM IM IM IM IM IM IM IM IM IM IM

Safety signs

clearly

displayed


All plant

equipment

clearly

labelled


House-

keeping in

order



16

Table 13: Transformer inspection


Transformer

Controls are

locked off and

only

accessible on

authorisation


Oil-filled

transformers

are installed

inside bund-

wall area with

drainage


Access to

transformers

is restricted to

authorisation


Safety signs

clearly

displayed


The

transformers

and

accessories

are clearly

labelled


Evidence of oil

and water

leaks

NO NO NO NO NO NO NO NO NO NO NO NO

Silica gel and

oil bowl,

liquids at

correct levels

IM IM IM IM IM IM IM NA IM IM IM IM

Check for

cable

conditions e.g.

wear & tear,

burn marks,

hot spots or

loose

connections.



17

Table 14: MV Switchgear, Station Control and Substation inspection


MV Switchgear, Station Control and Substation

Switchgear room

accessible by

authorised

personnel and

access records in

place


Switchgear door

panels are locked

(circuit breaker

compartment)


All equipment

clearly labelled IM IM IM IM IM IM IM IM IM IM IM IM

Safety signs

clearly displayed IM IM IM IM IM IM IM IM IM IM IM IM

Emergency

evacuation signs

and route clearly

displayed


Firefighting

equipment clearly

marked with

instructions and

serviced

IM IM IM IM NA IM IM IM IM IM IM IM

Housekeeping in

order IO IO IO IO IO IO IO IO IO IO IO IO

Monitor display

working, able to

operate the plant

from the control

room and to view

status of the plant


Check for cable

conditions e.g.

wear & tear, burn

marks, hot spots

or loose

connections.



18

Table 15: Battery inspection


Battery

Check

conditions of

the room e.g.

ventilation,

water ingress


Batteries -

electrolyte

level, filler caps

and battery

check sheet

IM IM IM IM PI IM IM IM IM IM IM IM

Safety signs

clearly

displayed


Check for

cable

conditions e.g.

wear & tear,

burn marks,

hot spots or

loose

connections.


Eyewash

provided and

fire

extinguishers

and firefighting

equipment

marked with

instructions

and serviced.

IM IM PI PI IM PI PI IM PI PI IM PI

Housekeeping

in order.


Most of the plants do not have a dedicated battery room as there is only a small

quantity of batteries, which are only used as backup for communication and

emergency systems. Therefore, in most cases, the batteries are in the same

room as the metering panels and communication servers.


19

Table 16: Critical spares storage inspection


Critical Spares Storage

Spares stored

neatly IM IM IM PI IM IM IM IM IM IM IM IM

Spares clearly

labelled IM IM PI PI PI IM IM IM IM IM IM IM

Spares have

manuals IM IM IM IM IM IM IM IM IM IM IM IM

A list of spares

and spares

movement

tracking registers

are in place.


It is worth noting that no measuring standard was used for plant inspection,

however, a comparison between the audited licensees was used as reference.

For example, a solar farm that fared poorly in terms of plant equipment labelling

and a solar farm that implemented plant equipment labelling to a larger extent

are flagged and compared for the licensee who fared poorly to evaluate whether

is in line with the requirements of the applicable regulations. A similar approach

is adopted for the requirements for safety signs and evacuation signs.

1100.. CCOONNCCLLUUSSIIOONN

Detailed findings and recommendations of the audit for each licensee are presented

in the individual audit reports of the licensees. From the audit findings, it is evident

that the licensees have systems in place to implement the requirements of the licence

conditions, however, some do not have systems in place or programmes for

compliance with the South African Grid Code.

Graph 2 represents the compliance status of the licensees with the four compliance

requirement items, namely:

a) The Electricity Generation Licence – Table 7;

b) The Distribution Information Exchange Code – Table 8;

c) The Distribution Network Code – Table 9; and

d) The Distribution System Operating Code – Table 10.

In interpreting Graph 2, the following example is made:

In Table 10, Core Energy (Pty) Ltd (B) is compliant with two requirements of the

Distribution System Operating Code, hence, on Graph 2 its compliance status is

66.6% (33.3 x 2), whereas Slimsun (Pty) Ltd (K) is compliant with the three

requirements, therefore, its compliance status is 100% (33.3 x 3). This interpretation

method is applicable to the rest of the licensees’ compliance statuses on the graph.


20

1111.. RREECCOOMMMMEENNDDAATTIIOONN

It is recommended that licensees address the non-compliances and other issues that

are highlighted in this report, in particular those listed in the detailed individual audit

reports.


21

Date post:	30-Jun-2020
Category:	Documents
Upload:	others
View:	3 times
Download:	0 times

Consolidated Report on the Findings of the … › Admin › Document › Editor › file ›...

Documents