PJM stakeholders unanimously endorsed an issue charge aimed at developing a cost recovery mechanism for generators forced to upgrade their facilities to comply with certain NERC Critical Infrastructure Protection (CIP) standards regarding interconnection reliability operating limits (IROLs).

Darrell Frogg, senior engineer for generation at PJM, reviewed the problem statement and issue charge of the proposal at last week’s Operating Committee meeting. He first presented the issue at the March OC meeting. (See “Cost Recovery for ‘IROL-critical’ Generators?” PJM Operating Committee Briefs: March 11, 2021.)

PJM proposed allowing generators deemed critical for determining interconnection reliability operating limits to recover required upgrade costs. An IROL is any system operating limit that, if exceeded, could jeopardize the entire grid.

Frogg said PJM is required to develop a list of “IROL-critical” facilities in the fall, and generators on the list may then be required to upgrade their units to meet reliability requirements. He said PJM is solely responsible for creating the list, and generation owners have no control over the IROL-critical designation.

PJM made the proposal on behalf of generator owners because the classification of a generator as IROL-critical is considered critical energy and electric infrastructure information.

“We want to get the generation owners the opportunity to recover costs before the next annual list is created in the fall,” Frogg said.

With the endorsement of the issue charge, stakeholders will study the relevant CIP standards, review how a generator’s status is determined by PJM and consider the types of costs that generators incur from being designated. Stakeholders will look at how other RTOs and ISOs have addressed the issue, such as FERC OKs Payment Rules for IROL Facilities.) Stakeholders will also discuss which costs should be recovered and how, and ensure the entire process is transparent.

Frogg said work on the issue is expected to take three to six months with a recommendation brought to the Markets and Reliability Committee at the end of the process. The Market Implementation Committee will be updated on the work since some of the issues are related to that committee.

In response to a question from Becky Robinson of Vistra, Frogg said PJM isn’t seeking to complete the work ahead of deadline because it anticipates adding an unusually high number of IROL-critical facilities to the list in the fall.

“There could usually be a fluctuation of one or two units, but there’s nothing significant,” Frogg said.

COVID-19 Update

Stakeholders questioned PJM officials about the RTO’s stance on the vaccination of staff for COVID-19.

Paul McGlynn of PJM said as the infection rates started to drop in early March, PJM decided to end the sequestration of its control room operators at the end of the month.

The RTO began sequestration of critical staff in early December as case numbers were increasing, McGlynn said, rotating staff in and out of sequestration monthly.

Control room staff continue to be split between two locations and are practicing social distancing protocols and enhanced cleaning processes, McGlynn said. A third emergency control room set up at the beginning of the pandemic continues to be available if necessary and can be converted to real-time operations from its current training purposes within a few hours.

“Today we’re currently in our normal configuration, operating out of the two main control rooms,” McGlynn said. “Hopefully we’re done with sequestering staff at this stage of the game.”

As far as vaccinations, McGlynn said, access to shots is “improving” while the demand remains high. He said most PJM staff are eligible to be vaccinated.

Greg Poulos, executive director of the Consumer Advocates of the PJM States (CAPS), asked what importance PJM is placing on staff receiving the vaccine and the impact on reopening the RTO’s campus. Poulos also asked if the vaccine will be mandatory.

McGlynn said that while PJM took early steps to ensure availability of the vaccine to essential staff, it not requiring employees to receive the vaccine.

Paul Sotkiewicz of E-Cubed Policy Associates said he was “concerned” by PJM’s stance of not mandating vaccination and asked whether that could create a potential health and safety problem.

McGlynn said PJM has taken the position that it cannot require employees to be vaccinated. As long as protocols remain in place, including social distancing, the RTO will be able to manage the situation safely, he said.

“There’s a lot of reasons why people choose to be vaccinated, and there’s a lot of reasons why people choose not to be vaccinated,” McGlynn said.

Sotkiewicz said universities in the Northeast are requiring students to receive a vaccine to come back to campuses in the fall. He said because of PJM’s importance in the reliability of maintaining the grid, it would be “perfectly reasonable” to require vaccines for at least essential staff.

“I’m concerned this is setting us up for potential problems down the road,” Sotkiewicz said.

Winter Operations Review

Rebecca Carroll of PJM reviewed the 2020-21 winter operations summary, including the impacts on the RTO from the unprecedented energy emergencies in ERCOT, SPP and MISO in February.

Temperatures in most of the PJM footprint were average or slightly above normal during the winter, while the RTO’s western zones were below average, Carroll said.

Four cold weather alerts were issued during the season, all in February. The alerts occurred primarily in PJM’s western zones, and only two coincided with the mid-month cold snap that gripped much of the middle of the country.

During Washington’s Birthday week, the Midwest faced temperatures that dipped as much as 28 degrees below normal lows, while most of PJM’s footprint was spared the extreme cold, experiencing lows much closer to normal.

Carroll said PJM’s real-time LMPs averaged $29.79/MWh, much lower than previous winters that experienced significant weather-related events, including the 2014 polar vortex ($72.50/MWh) and the January 2018 cold snap ($46.66/MWh). Last winter LMPs hit an all-time low of $21.31/MWh as PJM experienced mild temperatures for most of the season.

Carroll said the “magnitude of exports” constituted the biggest story for PJM during the emergency, with the RTO exporting about 16,000 MW on average compared with the more typical 5,000 MW.

During the top-10 peak hours, interchange activity was more than three times above the 2020/21 winter average with PJM exporting more than five times as many megawatts as it was importing, she said. Exports during the cold snap were 2.5 times higher than the 2020/21 winter average, with 68% going to MISO, she said. The 1.6 TWh of exports during the event accounted for 10% off PJM’s entire winter exports.

Carroll called the export numbers “remarkable.”

Manual 03 First Read

Lagy Mathew of PJM provided a first read of changes to Manual 03: Transmission Operations, which are part of a periodic review. Mathew said substantial changes were proposed for the manual, including the addition of Attachment G: Transmission Outage Ticket Best Practices.

Section 3.4.2 and 3.5.4 regarding the nuclear plant interface requirement (NPIR) language changes for eDART nuclear voltage limits also saw significant changes, Mathew said, and PJM received feedback from stakeholders who said they were not ready to implement the changes in their operations.

Mathew said the updated language was not available at the OC meeting because it was still being reviewed by staff. He said PJM plans to bring the updated manual language for a first read at the April Markets and Reliability Committee meeting.

Sharon Midgley of Exelon said she was “not comfortable” with PJM considering the presentation a first read without making the language available for review by stakeholders. Midgley said Exelon is still working on potential implementation of the NPIR language changes and wants to review the language to determine the exact impacts.