Black Start Tariff
Technical White Paper
04/11/2006
Tariff Technical Issues Task Team
Will Behnke
Alliant Energy
Francis Esselman Chair
American Transmission Co.
Jeff Hackman
Ameren Services
Dan Herring
DTE Energy
Doug Rempel
Manitoba Hydro
Martin Trence
Xcel Energy Services
Dale Zahn
We Energies
Submittal requested by the MISO Reliability Sub Committee through the Emergency
Preparedness & Power System Restoration Working Group by the Black Start Tariff
Technical Task Team.
This Black Start Service Tariff White Paper is intended to address technical issues and provide
technical details for consideration in support of implementing a Black Start Service Tariff to be
included in the MISO OATT.
Document Control Information
Document Name: Black Start Tariff Technical White Paper
Section
Number:
Section
Name:
Owner:
Creation Date:
All
Black Start Tariff Technical White Paper
EP/PSRWG
04/11/2006
18
Opt Out Provisions
EP/PSRWG
11/17/2006
i
Table of Contents
EXECUTIVE SUMMARY: ............................................................................................................................. III
GENERAL DEFINITIONS.............................................................................................................................. IV
1
CONSIDERATION OF A MISO BLACK START ANCILLARY SERVICE TARIFF ....................................... 1
2
GROUP GUIDING PRINCIPLES ............................................................................................................ 2
3
MAJOR COMPONENTS OF BLACK OUT PLANNING ............................................................................. 2
3.1.
Black Start Equipment ............................................................................................................ 2
3.2.
Black Start Unit ...................................................................................................................... 2
3.3.
Black Start Facility................................................................................................................. 2
3.4.
Restoration Service................................................................................................................. 3
4
CONSIDERATION OF THE ISOLATION OF UNITS AS ALTERNATIVE TO BLACK START........................... 3
5
USEFULNESS OF BLACK START FACILITIES ....................................................................................... 3
6
ZONAL VS. MISO WIDE REVENUE REQUIREMENT.............................................................................. 4
7
BLACK START EQUIPMENT REQUIREMENTS ..................................................................................... 4
8
BLACK START UNIT REQUIREMENTS ................................................................................................ 5
9
BLACK START FACILITY REQUIREMENTS ......................................................................................... 5
10 SELECTION CRITERIA FOR BLACKSTART UNITS AND FACILITIES ...................................................... 6
11 NON MISO SUPPLIERS ...................................................................................................................... 7
12 SUMMARY OF BLACK START UNIT PERFORMANCE STANDARDS....................................................... 8
12.1.
Documentation........................................................................................................................ 8
12.2.
Conflicting or Parallel Contractual Arrangements ................................................................ 8
13 OUTAGE RESTRICTIONS .................................................................................................................... 9
14 MAINTENANCE.................................................................................................................................. 9
15 TESTING ............................................................................................................................................ 9
16 CRITERIA FOR TESTS ......................................................................................................................... 9
17 PENALTIES ........................................................................................................................................ 9
17.1.
Test Failures:.......................................................................................................................... 9
17.2.
Failure to perform ................................................................................................................ 10
18 CONSIDERATION OF AN “OPT OUT” PROVISION .............................................................................. 10
19 COMPONENTS OF COMPENSATION .................................................................................................. 11
19.1.
Training ................................................................................................................................ 11
19.2.
Testing costs ......................................................................................................................... 11
19.3.
Carrying cost of fuel ............................................................................................................. 11
19.4.
Incentive to build .................................................................................................................. 11
20 INCENTIVE TO MAINTAIN CURRENT CAPABILITY ............................................................................. 11
21 FIXED AND VARIABLE COST COMPONENTS ...................................................................................... 12
22 CAPITAL COST RECOVERY FORMULA: ............................................................................................. 12
23 UNIT AND FACILITY CAPABILITY FORMULA: ................................................................................... 13
24 RE: SELECTION CRITERIA FOR BLACKSTART UNITS AND FACILITIES ............................................. 13
References........................................................................................................................................... 14
ii
Executive Summary:
This paper regarding technical aspects of Black Start service is presented through the committee
process within MISO to support the development of a MISO Ancillary Service Tariff for Black Start
service.
This paper was commissioned by the MISO Reliability Subcommittee (RSC) through the
Emergency Preparedness and Power System Restoration Working Group (EP-PSRWG). A
drafting task team was formed by the EP-PSRWG and started work on this paper in February of
2006.
While the industry continues transition from the integrated electric utility era to the market concept
there has been pressure put on many of the traditional utility services such as the requirement to
restore the system following a blackout. This includes reluctance to build and maintain such
facilities due to inequitable cost allocation associated with the management of the risks of
potential blackout.
As part of this paper we attempt to document the many concepts of what the task team envisions
as being the foundations for a reasonable Black Start Service market design. The intent is to
show the basis for what is seen as necessary and reimbursable services that can and should be
compensated for in hedging the risk of a blackout in a manageable way meeting accepted
industry standards.
It is important to consider that a Black Start tariff is only part of what is needed to ensure the
recoverability of the system after a black out. In many documents within the industry it is nearly
impossible to differentiate the differences between Black Start Service and Restoration Service.
The task team believes that this paper clarifies what Black Start Service is and suggests that
there is a need to continue iterations so the industry recognizes these differences.
The primary intent of this white paper is to provide guiding technical principles for MISO tariff
development. This includes items such as defining the service, what is expected, compliance,
incentives, and what is reimbursable. The drafting task team and members of EP-PSRWG may
eventually have comment to the tariff development group on pricing mechanisms through the
tariff development processes; however as a guiding principle within this technical document we
restricted ourselves from positioning with regard to these mechanisms as much as practical. In an
equitable market all participants must share not only the benefit, but also the costs incurred to
hedge for failure.
As chair of this task team I want to recognize the efforts and contributions of the team. Their
professionalism and willingness to share ideas, concepts, and solutions was outstanding.
Francis Esselman
iii
General Definitions
Ancillary Services Group:
A working group of the RSC within MISO that advises the RSC on issues related to Ancillary
Services.
Black Start Equipment:
The incremental equipment required within a facility that is required to make the facility black start
capable.
Black Start Facility:
A generation facility containing at least one black start unit. The facility requires no outside source
of electrical energy to go from shutdown to in service other than that supplied by at least one
black start unit within the facility.
Black Start Tariff:
A stand alone or attachment to the MISO Open Access Transmission Tariff.
Black Start Unit:
A generating unit that has Black start equipment attached to it that allows the unit to be started
without assistance other than that from the black start equipment.
Black Out Planning
The process inclusive of all four stages of reinstating the network to full operation following a
regional blackout.
EP-PSRWG:
A working group within MISO advising to the RSC on Emergency Preparedness and Power
System Restoration Issues.
Market Participant:
An entity that (i) has successfully completed the registration process with the Transmission
Provider and is qualified by the Transmission Provider as a Market Participant, (ii) is financially
responsible to the Transmission Provider for all of its Market Activities and obligations, and (iii)
has demonstrated the capability to participate in its relevant Market Activities.
MISO:
Midwest Independent Transmission System Operator.
MISO Restoration Sub-Region:
Facilities and Members in a specific geographic area of MISO as part of the MISO wide
Emergency Preparedness and Power System Restoration Working Group.
NERC:
North American Electric Reliability Organization.
Regional Reliability Organization:
A NERC Reliability Organization such as Reliability First or MRO.
Restoration Service:
The process used by the Transmission Provider, Load Serving Entities, and Generator Operators
to reenergize (to a fully operational state) the entire transmission network and the remainder of
the delivery system to normal operation.
iv
RSC:
The Reliability Sub committee of MISO.
Useful Energy:
Energy that meets frequency, voltage, and of sufficient quantity as to meet the needs of serving
load, or the restoration plan. This includes sufficient reactive power regulating capability to
support the restoration plan.
v
1 Consideration of a MISO Black Start Ancillary Service Tariff
1.1.
Currently, most registered black start capable generation within the MISO footprint is
supplied by a relatively small number of entities. The costs associated with
maintaining this capability and development of the plans to utilize this capability are
not distributed equitably among all MISO participants. Subsequently, some loads pay
for a black start service through the individual black start capable generator owners’
local rates, while others share no cost burden associated with compliance to this
NERC requirement.
1.2.
Historically, most “vertically integrated” utilities met their obligation to NERC Policy by
planning for emergencies and ensuring their individual Control Area system black
start and restoration capability should a failure of the network as a whole occur.
Deregulation and open access within the industry have opened market participation
to non-vertically integrated generation ownership without a requirement or obligation
to supply emergency services such as black start services. New entities continue to
enter the market without the obligation or financial recovery mechanisms to supply
these necessary services. Simply stated, many new generating stations proposed for
construction cannot justify the current potentially non-recoverable costs associated
with the inclusion of black start capabilities added to their proposed facilities.
1.3.
Incumbent black start capable facilities, more often than not, previously owned and
operated by the remnants of the vertically integrated utility era are in some cases
considering the retirement of these resources as they age, and/or are coming under
considerable environmental licensing pressure. Although most of these incumbent
facilities are fully depreciated through utility rate recovery, the ongoing Operational
and Maintenance costs as well as potential equipment upgrades should be
considered for separation into a wider area ancillary service cost recovery
mechanism, such as this MISO tariff, rather than an integrated utility rate structure.
1.4.
Inherent within the industry is some differentiation in assumptions as to what is
deemed to be adequate when considering the timeframe required to restart the
system following a total failure, or near total failure.
A perennial question is where the investment is adequate and diminishing returns
become common.
To assist in recognizing the parts of black out planning a paper on technical aspects
of system black start equipment capability needs to include the four distinct major
stages of system Black Out Planning.
Stage 1: Initial start up of black start equipment and units
Stage 2: Restoration of service to critical electrical delivery facilities
Stage 3: Energization of the transmission network to reestablish the interconnection
Stage 4: Restoration of load and resumption of normal market
1.5.
The time required to complete any stage can have an exponential affect on the
timeframe of a following stage. An example would be the restoration to critical
electrical delivery facilities such as large fossil and nuclear fueled generating plants.
Delays in supplying off site power to fossil and combined cycle plants in particular will
result in many challenges to the capability to restart the plant. Issues like dry drum,
freezing of process equipment including boilers and heat recovery steam generators
in cold weather, are just a couple of examples where problems in stage 1, or 2 can
affect the ultimate time required to get to stage 4.
1
2 Group Guiding Principles
2.1.
The tariff technical group will not recommend or suggest any pricing mechanisms for
a proposed tariff.
2.2.
Recognition of the need to maintain at a minimum the current level of participation of
black start service we have in place today.
2.3.
It is the intention of those involved with this development that creating a Black Start
Tariff would not be prudent (certainly not in the best interest of our stakeholders) if
the MISO cost for administering the Tariff exceed the value of the tariff.
3 Major Components of Black Out Planning
It is important for guidance in the development of this technical document to illustrate the
differences between “Black Start Equipment”, “Black Start Unit”, “Black Start Facility”, and
“Restoration service”.
3.1.
Black Start Equipment
Black Start Equipment is the incremental equipment required within a facility that is
required to make the facility black start capable. This required equipment is proposed
to be included in the recoverable capital investment portion within the tariff.
3.2.
Black Start Unit
A Black Start Unit is a generating unit that has Black start equipment attached to it
that allows the unit to be started without assistance other than that from the black
start equipment.
3.3.
Black Start Facility
A Black Start Facility is a generation facility containing at least one black start unit
The facility requires no outside source of electrical energy to go from shutdown to in
service other than that supplied by at least one black start unit within the facility. A
facility must meet the restoration plan needs with regard to real and reactive power
capability.
A Black Start Facility may in some instances include generation that is not located in
an immediate congruous area. A facility may include generation in a local area that is
under the control of a single plant operator. (Some facilities may have minimal
distance between units) For purpose of this document we will state that a facility is
Black Start Tariff qualified as long as the stations meet the regional restoration plan
criteria which considers distance / time and electrical capability between the source,
etc. as a portion of the criteria.
2
3.4.
Restoration Service
Restoration Service is the process used by the Transmission Provider, Load Serving
Entities, and Generator Operators to reenergize to a fully operational state the entire
transmission network and the remainder of the delivery system to normal operation.
This process includes systematic start up of black start units via black start
equipment, energizing transmission to critical facilities such as larger generating
units, energizing to the largest generators to facilitate the restoration of system loads.
4 Consideration of the isolation of units as alternative to Black
Start
4.1.
The group considered the potential to include isolation schemes within this proposal.
Discussion centered on the plausibility of such schemes for reimbursement under the
tariff. Although as Operators of the grid would attest the best way to restart the
system is first to avoid the failure in the first place, next to isolate islands for a faster
recovery, and lastly to have a viable black start plan. The consensus of the group is
that, although isolation schemes are a preferable attribute to system operating, they
should not fall under the auspice of “black start”. Isolation schemes are part of an
overall risk mitigation strategy not unlike many reliability initiatives. Another potential
problem with consideration of isolation schemes as a reimbursed item within a tariff is
the substantial reluctance to actually test such schemes. Substantiation of a schemes
capability to work would require actual testing, which we believe entities would be
reluctant to perform.
4.2.
The recommendation is that this tariff be focused on the black start issue with the
assumption that all such reliability schemes failed, and we find ourselves in a regional
blackout.
4.3.
The RSC may want to consider this issue, or pass it to the Ancillary Services Group
at a later date to conduct investigation into the value / risks associated with isolation
schemes and potential for future revision of this or a separate isolation scheme
reimbursement.
5 Usefulness of Black Start Facilities
5.1.
The group has discussed at length a quandary regarding the potential to have
numerous entities apply for recovery for facilities that do not meet the needs of the
customers in a reasonable fashion. An example of this could be the insistence by a
generator owner that their unit should be eligible for rate recovery under the tariff.
Although one perception may be that more is better, this is a definite case where the
customer cannot justify payment for over duplication of service. There are limitations
on the number of black start facilities that can be used during the restoration process.
With this stated this group recognizes a need to have an oversight body to make
impartial and sound decisions applicable to which facilities are accepted,
reimbursable, and therefore deemed useful.
3
5.2.
Communications to the black start equipment, black start unit(s), and facility control
rooms or RTU’s with start and command logic must not use the PSTN (Public
Switched Telephone Network), or cellular technology. It is highly recommended that
the communications circuits be at minimum the same communications reliability used
for intra control center communications circuits within the MISO Sub-Region in which
the facility is located
6 Zonal vs. MISO wide revenue requirement
6.1.
Black Start Service as well as Restoration Service is more of a local ancillary service
comparable to reactive reserves. The overall consensus of the team is that revenues
be collected to support the service on a zonal basis. There is concern that
socialization of black start service on a MISO wide footprint basis has the potential to
penalize areas that are currently black start sufficient, or near sufficient. Sufficiency is
not defined on a national or regional level as it pertains to the timeliness of
restoration capabilities. It is best left to sub regions to determine the overall
timeliness of a restoration plan as the speed of restoration is affected in diminishing
return to the cost of services to due to a number of factors. The MISO area has been
divided into PSR Sub-Regions. These Sub-Regions are a logical choice for
consideration for use as the basis for a zonal revenue requirement, or an alternative
may be based on zonal reactive capability zones.
7 Black Start Equipment Requirements
7.1.
Black Start Equipment is defined as the equipment that when added to a unit, of a
facility make the unit, and therefore the facility capable of being started during black
out conditions without the aid of an external to station power source.
7.2.
The group will not attempt to define all of the potential types of “black Start
equipment” that could be developed, is in service, or could be developed in the
future. There is a number of differing machinery that can be applied to units within
facilities to make the facility black start capable. Some examples of current methods
include but are not limited to:
7.2.1.
Diesel or other prime mover equipment mechanically coupled directly to a gas
turbine that through design brings the unit up to ignition speed.
7.2.2.
Diesel Generation equipment connected to a small generator that supplies
electrical power to an integrated turbine generator electric starting system to
bring the unit up to ignition speed.
7.2.3.
Air-pack systems that use injection of compressed air to bring a gas turbine up to
ignition speed.
7.2.4.
Equipment utilizing the gas pressure of natural gas pipeline pack pressure to
bring the unit up to ignition speed
7.2.5.
House units capable of starting from a complete shutdown state, without any
external supply.
4
7.3.
Up to 2 separate and redundant “black start equipment” groups per facility will be
considered for reimbursement under the tariff.
8 Black Start Unit Requirements
8.1.
A Black Start Unit typically comprises a simple cycle unit fueled by gas and oil, (dual
fuel) combustion turbines capable of immediately operating in simple cycle mode,
hydro units or diesels with sufficient rotational inertia and voltage regulation capability
to add load as required (eg: starting large auxiliary power motors for steam plants) to
meet restoration plan goals, with a minimum operating capacity of 10 mw.
8.2.
The unit fitted with black start equipment as part must have the capability to close to
a dead bus.
8.3.
A Black-start unit must be designed and tested capable of supplying Useful Energy to
the station bus within 30 minutes from receipt of a start signal and within 40 minutes
of a request by an authorized person to start at least one unit within the facility.
8.4.
The Black Start unit must have the ability to operate for at a minimum 5 minutes at 0
load, or the period that is required to meet the restoration plan goals with the ability to
pick up 5 to 7% of the black start unit capacity during each 5 minute period when
called upon up to the unit minimum continuous operating level.
8.5.
The generating unit must have the ability to have its auto load feature disabled or be
loaded manually.
8.6.
The generating unit at minimum must have sufficient reactive reserve capability to
allow energization of the transmission system within the station to supply the facility
with restoration power.
8.7.
The black start unit (s) within the facility must have a fuel supply (useable under black
out conditions) in sufficient quantity to operate at accredited capacity for a minimum
of 20 hours and/or at 50% of accredited capacity for 40 hours.
9 Black Start Facility Requirements
9.1.
Many discussions were held within the group with regard to the attributes of an
adequate black start facility. Location, overall capability from a reactive and real
power output capability, ability to run at low generation level, fuel types, and
connection types, etc. The group makes the following recommendations.
9.2.
In order to qualify for reimbursement under the tariff the facility containing the
Black-start unit with Black-start equipment must also meet certain requirements:
9.2.1.
Facilities have generating capacity in sufficient quantity to facilitate a restoration
plan that can allow loads to be added during restoration in sufficient increments
so as to minimize the need for micromanaged load control during the restoration
of the grid.
5
9.2.2.
The facility must contain at least one qualified Black Start unit that is fitted with
Black Start Equipment
9.2.3.
At least one unit inclusive of the black start unit within the facility must be
connected to the network system in such a manner to provide adequate fault
current to support proper relay protection for faults during the restoration process
(e.g.: Generating units or facilities connected to the transmission network through
any Delta electrical configuration may not qualify as useable facilities) unless
special provisions have been made and agreed upon by the TO.
9.2.4.
The unit, either by itself or in conjunction with other units at the same station
making up the facility, must have the proven ability to energize transmission and
provide stabilizing load capability within and remote from the station while
maintaining adequate voltage and stable frequency.
9.2.5.
If more than one unit is required online in order to energize the transmission
system from the station, then the minimum number of units required to be online
to energize the transmission inherently is a “Black-start Facility”.
9.2.6.
When more than one generator is required online to energize transmission out of
the station, the governors must be tuned or be able to operate in parallel without
conflict. (Requirement to have this capability either through simulation or actual
testing including the ability to run multiple units synchronized at low loads without
governor response being affected - stable operation, not fighting each other). It is
preferable, but not always necessary, for at least one unit within the facility to
have the ability to operate in “isolated precise” frequency control mode.
9.2.7.
The facility must at minimum have the capability to energize the transmission
system from the station to meet the needs of a viable restoration plan to another
Critical Facility while maintaining adequate voltage.
9.2.8.
Some stand alone diesel facilities may be considered a facility; however this
would be on an as needed local requirements basis. Proof of adequate mass to
support the needs of the system restoration plans would be required for the
diesel site to be considered for certification as a black start facility.
9.2.9.
The facility owner must affirm that the operators of the facility inclusive of black
start equipment, and black start units have been trained in response to Black
Start conditions. Documentation of training records will be kept and made
available to the MISO EP PSRWG or the tariff administrator as requested.
10 Selection Criteria for Blackstart Units and Facilities
10.1.
A number of evolutionary discussions evolved throughout the process of writing this
paper and included a sometimes very lively debate on how any entity would go about
approving or denying selection as a tariff reimbursed black start site (equipment, unit,
or facility). We have agreed on the following principles:
10.1.1. The selection of new black start sites should look at the efficiency of logical
restoration to critical facilities as the primary criteria for selecting the sites. The
major criteria is timing, and if a new unit proposal that includes black start
6
capability can significantly decrease the time of restoration to a critical facility or
overall to critical facilities then it should be chosen over the less timely facility.
10.1.2. The Midwest ISO Black Start tariff needs to recognize the amount of effort that is
intrinsic in developing, testing, and training on the system restoration plans. Any
changes to the black start facility locations can create a need for extensive work
and revision to the restoration plans placing an additional burden for operator
training within the region. Therefore, we recommend that selection as a tariff
qualified Black Start facility remains effective for a minimum 5 years period.
10.2.
One of the most challenging aspects of this tariffs administration will be selection of
“the entity” that has the authority to choose the “logical” location for black start
facilities. This is somewhat simplified by the fact that black start capability is not the
normal driving force behind the construction of generating facilities. It would be
foreseen that the current designated units would be used for several years until such
time that a new plant is considered for black start service and goes into operation. It
would also be foreseen that within the MISO generation siting queue request process
(performed by MISO staff) that a potential owner or site developer would make
notification that a potential facility would consider an offer for black start service
reimbursement in the queue request.
10.3.
If the group charged by MISO to do a preliminary review as to whether the unit
should be considered for Black Start service agrees that there is merit to study the
proposed facility as a black start facility, that study should be undertaken and a timely
notification of results should take place. A notification of the result of their
recommendation shall be supplied to the requestor as soon as practical.
10.4.
When and if the site is deemed to be viable as a black start unit or facility the
following process is recommended:
10.4.1. An agreement is executed between the Midwest ISO and the party that is
contracting to supply the service.
11 Non MISO suppliers
11.1.
To qualify for payments under the MISO tariff the payee must be a MISO Market
Participant. In cases where a black start equipment group or a unit connected to a
black start equipment group or a facility in whole or in part is not owned by MISO
entities we suggest the following remedy.
11.1.1. A MISO entity can contract with a non-MISO entity for supply of black start
service. Payments can be made to the MISO entity as reimbursement for costs of
the contract, not exceeding the amounts that would have been paid for the
service had the supplier been a MISO entity.
11.1.2. The MISO entity would be responsible for all reporting for the non MISO entity,
and the contract must provide for all requirements of the MISO tariff to be met as
if the MISO entity owned the equipment.
7
12 Summary of Black Start Unit Performance Standards
12.1. Documentation
12.1.1. The Transmission provider (MISO) shall maintain records of all contracts needed
for the facilitation of the tariff.
12.1.2. The Black Start equipment, unit, and facility owner shall supply all test records,
report all start failures, and other information as needed to ascertain unit
readiness to the Transmission Provider (MISO) at the time of this writing the
MRO and the RFC are drafting many of their own requirements. As the Reliability
Organizations evolve and change, the MISO requires providers under the tariff to
necessarily duplicate reporting to the MRO’s and MISO. At some time in the
future when the MRO’s have developed their standards completely the MISO
may adjust this duplication requirement and rely on the RRO documentation, or
collect the information for the RRO.
12.2. Conflicting or Parallel Contractual Arrangements
12.2.1. If the black start generator or facility owner elects to supply a higher standard of
restoration service via a separate contract or implied service agreement whether
for another entity or for their own load serving capability the facility will not be
considered for network black start reimbursement unless the contract or implied
service to a local load has a positive or neutral impact on the ability of the unit to
stabilize or supply black start capability to a restoration island. It must be deemed
by the Transmission Provider black start tariff review group that there is no
detrimental affect to the remaining network service customers by the owner
supplying this service.
12.2.2. The generator owner must affirm in writing to the transmission provider that the
intention is to give local load priority at the time the unit is offered as a network
black start resource and state the amount of load that will receive such priority
service.
12.2.3. In cases where the generator owner implements a higher local load priority either
implied or via contract the transmission provider reserves the right to deny any
reimbursement to the generator owner, therefore denying a contract for network
black start service, and/or prorating the reimbursement.
12.2.4. A generation facility owner may elect to install black start equipment at any given
site for the protection of the site equipment separate from the MISO restoration
tariff. Such a decision is solely within the rights of the owner, however, unless
approved by MISO as a qualified black start facility no reimbursement under this
tariff is allowed.
8
13 Outage Restrictions
13.1.
When practical the transmission provider will limit simultaneous planned maintenance
to one black start equipment group per MISO restoration sub-region.
13.2.
A black start facility notation shall be either noted in all outage requests for facilities
required for black start, or the MISO outage scheduler database will be updated to
reflect black start equipment, associated units, and facilities.
14 Maintenance
14.1.
Maintenance is limited to an aggregate of 2 weeks per year per black start unit.
Payments for service will be prorated for the total of planned and unplanned outages
that exceed this 2 week limitation. The facility or the black start equipment owner, in
cases where this is separate, shall track this availability and report any deviation of
the aggregate 2 week limit to the MISO.
15 Testing
15.1.
A newly qualified unit must successfully complete a test prior to the commencement
of payments under this tariff.
15.2.
Subsequent testing intervals will be at minimum one test per calendar year of each
black start equipment group. (This may or may not coincide with Regional Reliability
Organization testing requirements.) The Transmission Provider and the Transmission
Operator must be notified in writing of the plan for testing.
16 Criteria for tests
16.1.
The black start unit must be black started using its associated black start equipment
group and prove itself ready to supply Useful Energy to the grid.
16.2.
There is no tariff compensation for differential energy pricing output during testing; it
is recommended that the owner schedule the test during a period when energy
pricing is near unit energy cost.
17 Penalties
17.1. Test Failures:
17.1.1. One month black start service revenues are proposed to be forfeited for
equipment groups and units within the facility that fail a black start test and do not
9
successfully pass a test within a fourteen day grace period immediately following
a failed test;.
17.1.2. Units without a successful black start test on record as required in NERC
Reliability Standards or at minimum 13 months whichever is less will report the
condition to MISO. In the event that a unit continues to be untested, there will be
a subsequent forfeiture of 1 month revenue for each 10 subsequent days
following the 12 month anniversary of the last test.
17.2. Failure to perform
17.2.1. If a facility as a whole fails to provide service when required during an actual
emergency a penalty equal to all black start service revenue of 1 year would be
levied. If the unit was on MISO approved maintenance, or a declaration of force
majuere had been made prior to the event initiating the need for restoration, this
penalty is not enforced.
17.2.2. A failure to fulfill an agreement to continually supply service during the
commitment period will result in a 6 month revenue penalty.
18 Consideration of an “Opt Out” Provision
(Should this section be removed completely.)
18.1.
The election to “opt out” of participation in a proposed tariff is not necessarily within
the scope of a technical task team. However, one technical challenge that may be
posed by an “opt out” provision is the potential for fragmentation of the restoration
effort as a whole on a MISO wide basis.
18.2.
The team sees no conceptual benefit to allowing an opt out provision by any MISO
member based upon our teams belief that a well designed Black Start Service
Ancillary Market, whether on a MISO wide, or zonal basis, makes such an “opt out”
provision unnecessary. All load within MISO or a zonal rate should pay for the
service. Some of the discussion and reasons for this conclusion follow:
18.2.1. All entities within MISO benefit from restoring the grid as a whole to full reliable
market operation in a reasonable period of time following a black out event.
18.2.2. Any entity electing to “opt out” could be relying on available resources to restore
load, we suggest that as MISO members they should be offering those resources
for consideration within the MISO restoration effort.
18.2.3. Use of local non tariff participating black start units or facilities should be allowed
as long as they do not interfere with the systematic restoration of the grid as a
whole. These local schemes would be considered to be elective local restoration
service, and not part of a MISO tariff. (Supplying a higher priority to local service
which is discussed in section 12.2 of this White Paper).
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19 Components of Compensation
19.1. Training
19.1.1. The group supports a component payment for training of personnel specifically
for operation of the facility under simulated black start conditions. Training is an
element with a non definitive measurement. We suggest that since the
requirement to sign an affidavit that states that the operators at the facility are
trained by the generator owner is required, and that there are penalties for failure
of the facility to perform the intended function are an incentive for a well trained
workforce. We suggest that a fair amount of time for training is approximately 50
staff hours per year per facility.
19.2. Testing costs
19.2.1. The group supports a component payment for the start up cost for testing of up to
2 tests per year per black start equipment group. Successful testing is paid for 1
start up per year. This can either be a based on the average start up cost of the
unit(s) connected to the black start equipment group, or a fixed payment agreed
to within MISO or the zone. The payment should be made following the receipt of
a complete test report.
19.3. Carrying cost of fuel
19.3.1. The group neither supports nor rules out inclusion of any fuel carrying cost for the
facility as part of this tariff. Where a justification of fuel equipment and storage is
shown for the black start equipment group separate from the main facility fuel
facilities then cost of fuel can be included in the variable O&M component of the
tariff.
19.4. Incentive to build
19.4.1. The group believes that the incentive to build is included in the fixed black start
equipment capital cost recovery portion of the tariff. As stated we conclude that
power plant siting is not driven by black start capability.
20 Incentive to maintain current capability
20.1.
The group supports grandfathering of black start facilities that are currently part of the
regional restoration plans or registered as black start units with test results on file
with a Regional Reliability Organization. The Group supports a make whole
mechanism to these currently registered Black Start Units for cost recovery of
maintenance, equipment upgrades, testing and training. We realize that this will
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require a transition from current rate structure to reimbursement under this tariff.
There is a need also to set minimum standards for future equipment that may not
necessarily match up with what is currently used in the footprint. Most of the existing
black start capable facilities were placed in service during the vertically integrated
utility planning process, and were placed in service to fill the need for an individual
control area or geographic area usually under the control of the local utility. In many
cases, rate base constructs include the current costs for keeping these facilities
operational as black start. Some of these units are located at sites that would not be
considered today to be the most logical choice from an emergency restoration
planning standpoint. Under any transition the units that are in the current restoration
plans are recommended to receive payments or credits toward their owner obligation
to encourage retaining the current capability.
20.2.
The group does not support “Duplication” of cost recovery for equipment or
processes which have already been fully compensated
20.3.
This raises the question as to whether there is sufficient incentive to maintain current
capabilities with blackstart equipment O&M as the only revenue source. The group
believes that this proposal does accomplish that goal since the owner is maintained
whole.
21 Fixed and variable cost components
21.1.
There are differing mechanisms that can be applied for black start service payment
formulas to the providers of black start.
21.2.
A capital cost recovery mechanism for black start incremental equipment plus
variable O&M, inclusive on limitation of attached unit and facility size.
21.3.
A formula that is based on the attached unit and facility capability inclusive of
minimum criteria for the black start incremental equipment.
21.4.
In the scope of the group charter we are limited from directing any specific
methodology or suggested payment levels but are allowed to point out benefit of
either formula.
22 Capital cost recovery formula:
22.1.
Pros: This methodology seems fair to the service purchaser as only the incremental
cost of supplying the black start equipment, and the incremental O&M for that
equipment is reimbursed.
22.2.
Cons: This methodology does not incent the location of black start equipment at units
or facilities that supply a wide range of operating capabilities, except as defined in the
minimum operating requirements section of this whitepaper.
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23 Unit and Facility capability formula:
23.1.
Pros: This methodology may incent the location of black start equipment at units or
facilities that supply a wide range of operating capabilities.
23.2.
Cons: There would still need to be limitation within the formula of what is useful
capability. E.g. a facility or its units may contain a high MW capability, but its
minimum operating levels may be restricted to greater than what is required of the
plan. Also the higher capacity may be nice, but may exceed that needed to meet the
goal of restoring the base transmission system. So it is at that point performing its
primary function of serving load.
24 RE: Selection Criteria for Blackstart Units and Facilities
24.1.
Cancellation of a unit service contract by either party should have penalties
associated with the cancellation, unless mutual agreement to alter or cancel exists.
We also recognize that substantial investment may have been made in qualifying
black start equipment associated with facilities. Once a facility is selected there is a
need to make whole the capital investment in the black start equipment. This can be
done by a revenue guarantee for the specified depreciation period with potential
option of a write down of the black start equipment asset in the case of cancellation.
24.2.
When the new facility goes into commercial operation, and the black start capability
tests are completed, a notice of change to current tariff reimbursement to an existing
supplier, (if that site was being replaced as the supplier), would be made. The
replaced unit or units (if any) would continue to be reimbursed for the minimum 5
year cancellation period, as long as the unit continued to meet its requirements of the
tariff during the period. As stated above MISO would guarantee the revenue
sufficiency remaining on the capital portion of any cancelled service contract when
MISO exercises the cancellation.
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References
NERC Standards
Reliability Standards Approved:
http://www.nerc.com/~filez/standards/Reliability_Standards.html
EOP-007-0 – Establish, Maintain, and Document a Regional Blackstart Capability
Plan.
“A system Blackstart Capability Plan (BCP) is necessary to ensure that the quantity and
location of system blackstart generators are sufficient and that they can perform their
expected functions as specified in overall coordinated Regional System Restoration
Plans (SRP).”
NERC Operating Manual
Reference Documents:
http://www.nerc.com/~oc/opermanl2.html
(Click on the “Operating Manual in Adobe Acrobat” link to download the latest version of
the Operating Manual, the reference document is listed under Reference Documents).
Electric System Restoration Reference Document
“This document provides general guidelines to be followed in the event of a partial or
complete collapse of any of the interconnected electric systems in the North American
continent.”
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