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Texas QSE To Pay $35,000 Under Settlement To Resolve Alleged Violations Related To Reactive Capability Testing

September 20, 2016

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Copyright 2010-16 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

Luminant Energy Company LLC would pay $35,000 under a settlement with Staff of the Public Utility Commission of Texas to resolve Luminant's alleged violation of 16 Tex. Admin. Code (TAC) § 25.503(f)(2), concerning compliance with ERCOT Protocols § 8.1.1.2.1.4 and Operating Guide § 3.3.2.2, relating to maximum leading reactive capability testing.

Luminant is the QSE for the Resource Entity (RE) Luminant Generation Company LLC (Luminant Generation). Luminant Generation is the RE for the Black Start Generation Resource units identified as MGSES_CT4 (Morgan Creek) and SCSES_UNIT1A (Stryker Creek).

ERCOT Protocols § 8.1.1.2.1.4(2) requires REs to, "conduct reactive capacity qualification tests to verify the maximum leading and lagging reactive capability of all Generation Resources required to provide [Voltage Support Service (VSS)]." Under this section, tests must be, "performed on initial qualification and at a minimum of once every two years[,]" but an RE, "is not obligated to place Generation Resources On-Line solely for the purposes of testing."

ERCOT Protocols § 8.1.1.2.1.4(4) requires that the "[m]aximum leading power factor reactive operating limit must be demonstrated during light Load conditions, with the Generation Resource operating at a typical output for that condition, or the normal expected output level for solid fuel Generation Resources during light Load conditions, insofar as system voltage conditions and other factors will allow."

ERCOT Operating Guide§ 3.3.2.2(6) states that, "ERCOT shall have the option to waive the requirement to test and verify the maximum leading reactive capability of any Generation Resource that seldom runs during such light Load periods[,]" and said waiver shall be effective for two years.

According to the settlement, Luminant did not submit maximum leading reactive capability test results for Morgan Creek or Stryker Creek within two years following Luminant's submission of each unit's respective most recent test results.

The settlement states that Luminant submitted a maximum leading reactive capability test result for Morgan Creek on October 26, 2013 and again on January 27, 2016 (93 days late) and for Stryker Creek on January 23, 2014 and again on February 26, 2016 (34 days late).

Luminant and Staff disagree over whether Luminant violated the Protocols or Operating Guide requirements relating to maximum leading reactive capability tests with respect to Morgan Creek or Stryker Creek.

Luminant generally conducts maximum leading reactive capability tests within the last six months of the two-year testing window, which it argues to be a reasonable application of the testing requirements because this practice ensures that tests are not conducted too closely together in time.

Luminant contends that a successful maximum leading reactive capability test for these particular units requires that a companion unit be On-Line at the same time (i.e., an additional unit at each of Morgan Creek's and Stryker Creek's respective facilities).

During the last six months of the applicable two-year testing periods for Morgan Creek and Stryker Creek, market conditions did not warrant bringing Morgan Creek and Stryker Creek On-Line along with a companion unit at their respective facilities during light load conditions.

Therefore, in order to test the units within Luminant's six-month testing window during the respective two-year timeframes, Luminant would have had to bring units On-Line solely for the purpose of testing, which ERCOT Protocols § 8.1.1.2.1.4(2) expressly excuses REs from doing, Luminant argues

Luminant did not seek a waiver under ERCOT Operating Guide § 3.3.2.2(6), because Luminant contends that the Protocols already excused it from bringing units On-Line solely for the purpose of testing during its 6 month testing windows.

Staff argued that while the RE is not required to use the waiver provision, Staff contends that the RE has committed a violation of the testing requirement if: (1) the generation unit was not tested within the two-year testing period, and (2) a waiver has not been granted by ERCOT

Staff also disagrees with Luminant that testing during the last six months of the two-year testing period {April 23-October 23 for Morgan Creek; July 23-January 23 for Stryker Creek) is the "reasonable" time to perform the required tests. Staff emphasizes the plain meaning interpretation of, "at a minimum of once every two years."

Staff said that during the respective two-year testing periods, Luminant had at least 29 opportunities at Morgan Creek and 19 opportunities at Stryker Creek to run maximum leading reactive capability tests when both the unit in question and a backup unit were already On-Line for other purposes, when load conditions were light.

While seeking the waiver is optional for the RE, Staff contends that if market conditions do not warrant bringing Generation Resources On-Line during light load conditions at any point during the two-year test period, then the RE must obtain a waiver from testing requirements in order to avoid violating ERCOT Protocols § 8.1.1.2.1.4.

Docket 46377

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