Texas QSE To Pay $125,000 Under Settlement With PUC Staff

September 25, 2023

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Copyright 2010-23 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Brazos Electric Power Cooperative, Inc. (BEPC) would pay $125,000 under a settlement with Staff of the Texas PUC to resolve alleged violations of ERCOT Nodal Protocols §§ 8.1.1.3(3), related to ancillary service capacity compliance criteria and 8.1.1.4.3(3)(b), related to non-spinning reserve service energy deployment criteria.

ERCOT Nodal Protocols § 8.1.1.3(3) requires QSEs not providing sufficient ancillary service (AS) capacity to, within ten minutes of notification: (a) correct any telemetry issue, or (b) provide to ERCOT appropriate justification and a plan to correct the shortfall.

The settlement states that, on June 5, 2021, BEPC failed to telemeter the entire amount of its AS resource responsibility for Non-Spin Reserve Service (NSRS), Regulation-UP (Reg-Up) and Responsive Reserve Service (RRS) yielding the following shortages:

a. NSRS: 13.1 megawatts (MW) over five security-constrained economic dispatch (SCED) intervals between 11:35 and 11:55.

b. Reg-Up: 12 MW over five SCED intervals between 11:35 and 11:55.

c. RRS: 30 MW over four SCED intervals between 11:35 and 11:50.

The settlement states that, on November 24, 2021, BEPC failed to telemeter any of its 12 MW Reg-Up AS resource responsibility for a total of eleven consecutive SCED intervals between 15:00 and 15:50.

The settlement states that, on March 13, 2022, BEPC failed to telemeter any of its 35 MW NSRS AS resource responsibility for a total of twelve consecutive SCED intervals between 01:00 and 01:55.

According to ERCOT Nodal Protocols § 8.1.1.4.3(3)(b), off-line generation resources providing NSRS must, within twenty-five minutes after a deployment instruction: a. be on-line with an Energy Offer Curve; and b. have telemetered net generation greater than or equal to the resource’s telemetered Low Sustained Limit (LSL) multiplied by P1.2

The settlement states as follows:

• On April 11, 2021, ERCOT sent BEPC deployment instructions for NSRS at 7:21PM.

• At that time BEPC showed an LSL of 35 MWs. Thus, BEPC had to show the unit as “ON” and generating at least 31.5 MWs (35*.9) by 7:46PM.

• However, at 7:46PM the unit showed “OFFNS” and generating 0 MWs. BEPC failed to correctly update the resource status code and was 31.5 MWs short of its deployment requirement.

• On September 26, 2021, ERCOT sent BEPC deployment instructions for NSRS at 7:06PM.

• At that time BEPC showed an LSL of 35 MWs. Thus, BEPC had to show the unit as “ON” and generating at least 31.5 MWs (35*.9) by 7:31PM.

• However, at 7:31PM the unit showed “OFFNS” and generating 20.866 MWs. BEPC failed to correctly update the resource status code and was 10.63 MWs short of its deployment requirement. • On August 28, 2022, ERCOT sent BEPC deployment instructions for NSRS at 1:00PM.

• At that time BEPC showed an LSL of 35 MWs. Thus, BEPC had to show the unit as “ON” and generating at least 31.5 MWs (35 *.9) by 1:25PM.

• However, at 1:25PM the unit showed “OFFNS” and generating 33.546 MWs. BEPC failed to correctly update its resource status code.

• On August 31, 2022, ERCOT sent BEPC deployment instruction for NSRS at 1:47PM.

• At that time BEPC showed an LSL of 35 MWs. Thus, BEPC had to show the unit as “ON” and generating at least 31.5 MWs (35*.9) by 2:12PM.

• However, at 2:12PM the unit showed “ON” and generating 23.513 MWs. BEPC was 7.99 MWs short of its deployment requirement.

• On September 5, 2022, ERCOT sent BEPC deployment instructions for NSRS at 1:30PM.

• At that time BEPC showed an LSL of 35 MWs. Thus, BEPC had to show the unit as “ON” and generating at least 31.5MWs (35*.9) by 1:55PM.

• However, at 1:55PM the unit showed “OFFNS” and generating 0 MWs. BEPC failed to correctly update the resource status code and was 31.5 MWs short of its deployment requirement.

• On September 11, 2022, ERCOT sent BEPC deployment instructions for NSRS at 6:42PM.

• At that time BEPC showed LSL of 35 MWs. Thus, BEPC had to show the unit as “ON” and generating at least 31.5 MWs (35*.9) by 7:07PM.

• However, at 7:07PM the unit showed “ON” and generating at 8.4328 MWs. BEPC was 23.0672 MWs short of its deployment requirement.

• On September 28, 2022, ERCOT sent BEPC deployment instructions for NSRS at 6:46PM.

• At that time BEPC showed an LSL of 35 MWs. Thus, BEPC had to show the unit as “ON” and generating at least 31.5 MWs (35*.9) by 7:11PM.

• However, at 7:11PM the unit showed “ON” and generating 5.3551 MWs. BEPC was 26.1449 MWs short of its deployment requirement.

• On October 1, 2022, ERCOT sent BEPC deployment instructions for NSRS at 6:54PM.

• At that time BEPC showed an LSL of 35 MWs. Thus, BEPC had to show the unit as “ON” and generation at least 31.5 MWs (35*.9) by 7:19PM.

• However, at 7:19PM, the unit showed “OFFNS” and generating 0 MWs. BEPC was 35MWs short of its deployment requirement.

• BEPC asserts that several of the instances of delayed NSRS deployment identified above involve delays of less than two minutes in updating telemetry or reaching 90% of LSL and difficulties in meeting the required time frames occurred due to the manual nature of both the communication of instructions from QSE to plant and the start processes of the affected units.

The settlement states that BEPC asserts that it took the following corrective measures in an attempt to prevent additional violations of the ERCOT Nodal Protocols from occurring:

a. As of June 7, 2023, BEPC ceased representing any generation as a QSE, and, as of June 12, 2023, BEPC sold all of its power plants to another unrelated entity.

b. Prior to the sale, BEPC made improvements to Miller Units 4 and 5 which will allow these units to be started via a single button, reducing the impacts of the manual startup process on the provision of offline NSRS.

The settlement states that, "the execution of this agreement does not admit the truth or accuracy of any such disputed claims."

Docket No. 55444

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