Download Stakeholder Comment and Rationale Form AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft

Stakeholder Comment and Rationale Form
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
Date: 2011-12-06
Proposed New ISO Rules Section 502.5 Generating Unit Technical Requirements (“New ISO Rules Section 502.5”)
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
2011/12/06
2011/12/06
Comments From:
Capital Power Corporation
Date [yyyy/mm/dd]:
2012/02/14
through
2012/01/31
Contact:
Amber Kirby
Phone:
403-717-4677
E-mail:
[email protected]
Listed below is the summary description of changes for the proposed new, removed or amended sections of the ISO Rules. Please refer back to the Letter of Notice under the “Attachments to Letter of
Notice” section to view the actual proposed content changes to the ISO Rules. Please place your comments / reasons for position underneath (if any).
2. ISO Rules
Subsection 2 – Requirements – New Generating Unit
Subsection 2 sets out, with clarity, the provisions that apply to a new generating
unit.
Stakeholder Comments and/or Alternate Proposal
Comment # 6:
Capital Power thanks the AESO for the opportunity to
comment on the proposed ISO Rule 502.5 Generating
Unit Technical Requirements. Capital Power
appreciates the AESO’s and specifically the TOAD
initiative’s efforts to review the authoritative documents
and redraft where necessary to improve clarity and
eliminate any duplication of obligations.
AESO Replies
Capital Power believes that the list of exceptions listed
in subsection 2(2) and 2(3) should be exhaustive or
would be better included in the individual sections to
which the exemptions apply. If only some of the
exemptions are listed, market participants will not be
able to rely on this subsection to determine applicability
and may not refer back to this subsection when
reviewing the specific requirements. Therefore, the
individual subsections from which some units may be
exempt should be stated within those subsections for
clarity and ease of reference. For example, rather than
Issued for Stakeholder Consultation: 2011-12-06
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Public Information
stating in Subsection 2(2) that a new unit connected to
the in-plant distribution of an industrial complex with 2 or
more voltage transformers is exempt from subsections
24-28, subsection 24-28 should state that those units
are exempt from that subsection.
Subsection 2(3) should also be removed and subsection
9 should state that it does not apply to new generating
units for the same reasons explained above.
Subsection 2(4) states that if any of the facilities of an
existing generating unit are “subsequently modified”
then the unit will be required to comply with ISO rule
502.5. It is not clear what is meant by “subsequently
modified”. Capital Power suggests the AESO establish
a clearer threshold for determining what would be
considered “subsequently modified” in this context.
Subsection 9(8) specifies a capacity increase amount
as a threshold. Although increased capacity may not be
the only modification to be considered but equipment
changes that are required for standard operations and
maintenance should not require existing generators to
comply with all subsections applicable to new
generating units.
Is it the intent of subsection 2(5) to imply that new
generating units that have not been energized but were
issued a functional specification from the AESO before
the effective date of the proposed rule 502.5 are not
required to comply with the standard but only with the
unit specific functional specification? This seems
contradictory to subsection 3 Existing Generating Unit
as existing units are required to comply with certain
subsections within the new proposed rule as well as
their unit specific functional specifications. If that is not
the intent of subsection 2(5) it should be moved to be
included in subsection 3(1).
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Subsection 3 – Requirements – Existing Generating Unit
Subsection 3 sets out the provisions that apply to an existing generating unit,
including clarifications as to what subsections of proposed New ISO Rules
Section 502.5 are not applicable.
Subsection 6 – Operating Voltage Requirements
Subsection 6 requires the market participant to clearly state the voltages to which
the generating unit will be designed at both the point of connection and the
generator terminals.
In Alberta, the voltage levels may vary considerably from the nominal voltage,
therefore, having the legal owner clearly stating the values to be voltages at the
point of connection and the generating unit terminals allows the AESO to fairly
ensure the compliance of all legal owners with regard to:
(a) The voltage ride-through requirements;
(b) Voltage regulation; and
(c) The reactive power requirements of the generating unit.
This subsection also makes the legal owner aware of the voltage range at that
facility so that they may properly specify, design and purchase the appropriate
equipment.
Subsection 7 – Maximum Authorized Real Power
Subsection 7 requires the participant to submit in writing the maximum value that
the generating unit can ever be operated at, under ideal circumstances while
meeting other requirements of proposed New ISO Rules Section 502.5.
Issued for Stakeholder Consultation: 2011-12-06
Comment # 7:
The same comments provided for subsection 2(2)-(4)
apply to subsections 3(2)-(4). Please see above.
Comment # 10:
Subsection 6(1) applies to “new or modified existing
generating units”. It is not clear what qualifies as a
modification to an existing generating unit from the
AESO’s perspective and when that modification would
have taken effect. It is not clear from subsection 6(1)
which units will be required to submit their proposed
operating values without being specifically requested to
do so by the AESO as described in subsection 6(3).
It is unclear what the intent of Subsection 6(3) is.
Subsection 6(3) requires existing generating units to
submit a proposed operating voltage value if requested
to do so by the AESO. The operating voltage levels of
each generating unit are defined within the functional
specifications provided by the AESO so the AESO
should already have copies of voltage information.
Therefore, it is not clear why the AESO would request
voltage information to be submitted again. Capital
Power understands that new generation connecting to
existing lines or general transmission degradation may
require additional operating voltage support in some
areas but existing generators should not be required to
upgrade equipment when the existing generator has not
been modified. Existing generating units should also
not be required to adjust their technical characteristics
at the AESO’s discretion.
Comment # 11:
Subsection 7(2) requires market participants to be “in
compliance with….. subsections 8 and 9 as applicable”.
Cross referencing within or across rules should be
avoided as a single incident of non-compliance would
result in a violation of several ISO rules. Avoiding
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Many generating units can operate above nameplate values under the proper
conditions, so to properly study the behaviour of the generating units in respect to
the transmission system, this maximum value needs to be clearly stated. This
value is also required to properly design the transmission system.
duplication of requirements is one of the fundamental
principles of the TOAD process and should be
maintained wherever possible. Therefore, subsection
7(2) should be removed as it is already covered by
subsections 8 and 9 and therefore redundant.
The Generating Unit Technical Requirements rule is
intended to describe the operational characteristics a
generating unit is required to satisfy in order to connect
to the AIES. Subsection 7(4) describes how a
generating unit should be operated. Rules regarding
unit operation should instead be covered in reliability
standards or ISO Rules 3 and 6.
Subsection 9 – Additional Reactive Power Requirements for a Generating
Unit with a Power Purchase Arrangement
This section requires the applicable participant to meet certain requirement in
regards to reactive power obligations under normal and abnormal system
conditions.
Most of this section covers policies already in place by the AESO, however for
clarity, these requirements have been incorporated into proposed New ISO Rules
Section 502.5 to allow participants to find all requirements to design, build,
maintain and/or modify facilities under dedicated ISO rules. For background
information please refer to the document Application Guideline Generator
Interconnection Requirements – Reactive Power available at:
http://www.aeso.ca/downloads/AESO_PPA_Reactive_Power_Guidelines.pdf
Of particular note, subsection 9(10) specifies the requirements that will be
applicable to generating units that are currently the subject of a power purchase
arrangement once that power purchase arrangement ends.
Issued for Stakeholder Consultation: 2011-12-06
Comment # 13:
Subsection 9(5) and 9(6) require generating units that
are subject to the reactive power requirements of a
power purchase arrangement (PPA) to operate outside
established power factor range under abnormal
conditions. Providing additional reactive power often
presents an opportunity cost in terms of forgone real
power production. Due to the necessity of reactive
power production and consumption to ensure the
reliable operation of the transmission system, the rules
for reactive power should encourage efficient and
reliable investment in the infrastructure needed and
should provide incentives for existing infrastructure to
provide reliable and efficient reactive power. Reactive
power can be supplied by transmission facilities or
generators. Since in Alberta, reactive power is typically
supplied by generators, opportunities for cost recovery
should be available as they would be if transmission
facilities were satisfying reactive power requirements.
The FERC Generation Interconnection Rule, Order No.
2003 stated that generators should not be compensated
for providing reactive power within the established
power factor range but should be compensated for
providing excess reactive power in the case of an
emergency. Many countries around the world
compensate generators for providing and consuming
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reactive power so it is unclear why Alberta has not
elected to do so thus far. Capital Power encourages the
AESO to investigate compensation options for reactive
power providers to ensure that sufficient incentives are
available to maintain the reliable operation of the AIES.
Subsection 9(8) explains that the AESO will consider a
generating unit operating under a PPA to be modified if
the real power output exceeds the committed capacity
specified in the PPA by 2%. Although Capital Power
appreciates the additional clarity the AESO provided
regarding the threshold for determining a modification, a
2% increase is insufficient. For example, for a 300MW
generating unit, 2% would only allow for an increase of
6MW. ISO Rule 6.6 permits generating units greater
than 200MW to vary output by 10MW so it does not
make sense than output that is still considered
reasonable under dispatch variance rules would result
in a generating unit being considered modified under
the Generating Unit Technical Requirements. Capital
Power suggests that a 10% increase would be more
reasonable as the effect on the system operation would
be more significant.
Subsection 10 – Voltage Ride-Through Requirements
All generating unit must have the capability to support the transmission system
during system disturbances. Therefore, each generating unit must have some
capability for voltage ride through.
The basic approach to the requirements for existing generating units has been
carried over from the existing Technical.
Subsection 10 allows new generating units to be able to ride through system
disturbances that result in voltages as low as 0% and as high 120% for specified
periods of time. This requirement has been amended to align with the direction
that the industry is taking for new generating units. Please refer to FERC orders
661 and 693.
Comment # 14:
The level of detail provided in Subsection 10(4) is
unnecessary and does not clearly indicate the intent of
this provision. The provision stated in Subsection
10(4)(a) should be sufficiently clear that the generating
unit and any other critical device must remain online
during the inception or post-fault transient period
following a transmission system disturbance. For
example, subsection 10(4)(b) is unnecessary as some
contactors may drop out but auxiliary equipment can
compensate automatically to prevent the generating unit
from tripping. This should be considered sufficient to
satisfy the intent of the voltage ride through
requirements.
Could the AESO provide an example of a synchronous
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generating unit that has been able to comply with the
0.0% voltage ride through requirement specified in
Subsection 10(5)?
Capital Power understands that Subsection 10(5) has
been included in anticipation of Reliability Standard
“PRC-024 - Generator Performance During Frequency
and Voltage Excursions” being approved, first by NERC
and subsequently by WECC and Alberta. Capital Power
does not support Alberta implementing more onerous
reliability requirements than the rest of North America
unless it is clearly necessary to maintain the reliability of
the AIES. PRC-024 has not been approved by NERC
and is not even listed on the Alberta Reliability
Standards implementation plan. It has not been clearly
communicated why new synchronous generators in
Alberta will be required to comply with a more stringent
requirement from a system reliability perspective.
Therefore, Subsection 10(5) should be removed and
new generators should be subject to Subsection 10(3)
instead.
It is also not clear what the AESO deems “critical” in this
context. The Critical Infrastructure Protection (CIP)
Alberta Reliability Standards (ARS) describe a very
specific definition of “critical” infrastructure. One of the
main principles of the TOAD initiative is to ensure that
defined terms are used consistently across all AESO
authoritative documents. If the term “critical” in this
context does not have the same meaning as it does in
the CIP ARS, another AESO authoritative document,
then it would not be appropriate to use it here. Further,
since the intent of the voltage ride through requirements
is to ensure the generating unit will not trip offline as a
direct result of a transmission disturbance, references to
other “critical devices” is unnecessary and should be
removed.
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Subsection 21 – Synchrophasor Measurement System
Subsection 21 requires new or existing units with an upgraded protection system
to install a synchrophasor measurement system.
The application of synchrophasor measurement systems on generating units will
allow the AESO to better analyze the response of the generating units to system
disturbances, which assist the AESO in developing mitigating requirements for the
reliability of the transmission system. It will also allow the AESO to better monitor
compliance to the ISO rules and requirements.
The generating unit owners and operators will also be able to use this data to
analyze the behaviour of the generating unit for the model revalidation
requirements and determine if the generating unit is operating as designed.
Comment # 25:
Capital Power does not support the inclusion of this
provision within the Generating Unit Technical
Requirements for multiple reasons.
Capital Power understands that the AESO and various
transmission facility owners installed synchrophasor
measurement systems at various generating units
several years ago and that the technical capabilities of
these units is such that one phasor measurement unit
(PMU) can monitor several generating units and
transmission facilities simultaneously. Therefore, it is
unnecessary to install equipment of this complexity on
each individual new generating unit.
Some, if not all PMUs currently in operation are
managed by transmission facility owners that have cost
recovery capabilities. If the AESO intends to require all
new generating units to install synchrophasor
measurement systems to support the reliable operation
of the AIES, cost recovery mechanisms should also be
made available.
Subsections 21(1) requires that a new generating unit or
existing generating unit that replaces its protections
system must have a synchronized phasor measurement
system that complies with the “AESO Requirements for
Phasor Measurement Units”. Subsection 21(3) also
requires generating units to comply with the reporting
requirements specified in the “AESO Requirements for
Phasor Measurement Units”. Cross referencing within or
across rules should be avoided as failure to comply with
subsection 21(1) or 21(3) would result in a violation of
the “AESO’s Requirements for Phasor Measurement
Units” rule as well. A single act should not result in
multiple fines for non-compliance. Avoiding duplication
of requirements is one of the fundamental principles of
the TOAD process and should be maintained wherever
possible. Therefore, subsection 21 should be removed
as it is already covered by a separate ISO rule and
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should not be the responsibility of new generators.
Subsection 24 – Testing Intervals
Subsection 24 sets out requirements to provide a model validation or reactive
power verification report in terms of both format and timing.
Issued for Stakeholder Consultation: 2011-12-06
Comment # 28:
Subsection 24(4) explains what the AESO considers a
modification to an existing generating unit that will
require testing. Replacement of existing equipment that
is required for standard operations and maintenance
should not be considered a modification and therefore
subject to the testing requirements specified in
subsections 24, 24 and 27. Subsection 24(4)(e)
describes any other modification that changes the
behavior of the generating unit. This is the more
appropriate threshold. Equipment replacements that
have the same capabilities and operate in the same
manner should not require additional testing.
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