VALLEY FORGE, Pa. — About 1,900 MW of behind-the-meter generation may be unavailable because of tightened environmental rules, PJM told the Operating Committee last week.
PJM shared with the committee new EPA guidance issued in response to an appellate court decision last year that voided a rule exempting diesel generators providing demand response from air emissions limits.
EPA had exempted reciprocating internal combustion engines providing “emergency demand response” from emissions limits for up to 100 hours each year. The D.C. Circuit Court of Appeals ruled that the agency had “cavalierly sidestepped its responsibility to address reasonable alternatives” to the use of the generators. (See Appellate Court Rejects EPA Rule on Back-Up Generators.)
As a result of the ruling, EPA said such an engine “may not operate … for any number of hours per year unless it is in compliance with the emission standards and other applicable requirements for a nonemergency engine.”
That means behind-the-meter generation may only be used if it can respond when dispatched by PJM and comply with local, state and federal laws, including environmental permits, PJM said. Demand response that fails to perform when dispatched by PJM will be penalized, and there are no exceptions for the status of environmental permits.
“We have reached out and talked to our [curtailment service providers], and virtually everyone we talked to has made arrangements so they can meet their commitment for the summer,” PJM’s Pete Langbein said. “We at PJM do not see an impact going into the summer on capacity.”
Generators Employing Best Practices for Winterization
ReliabilityFirst Corp. gave the Operating Committee a lessons learned presentation resulting from its plant winterization visits since 2014.
PJM members have deployed “inventive solutions,” including additional enclosures to prevent freezing, portable heaters and a downspout system to divert rain and moisture away from inlet air filters, ReliabilityFirst said.
It identified just three areas for improvement: routinely operate any idle or standby equipment; make sure heat “tracing” or freeze protection is installed on any vulnerable equipment; and ensure the plant instrument air system is continuously supplying moisture-free air.
PJM Proposes to Sunset SIS, Move Topics to DMS
PJM is proposing to sunset the Systems Information Subcommittee and move some of its discussion topics to the Data Management Subcommittee, whose charter would be expanded.
Those topics relate to inter-control center communication protocol data links, Manual 01 changes and phasors.
The proposal also includes creating an “implementation forum,” which will be the primary venue for PJM to communicate technical changes to members and vendors.
Summer Base Case Study Yields No Reliability Issues
No reliability issues were identified in the 2016 summer base case study.
Off-cost generation re-dispatch and switching was required to control local thermal or voltage violations in some areas.
All voltage violations on networked transmission were controlled by capacitors, and all other such violations were caused by radial load, PJM said.
– Suzanne Herel