QUESTION NO. : 15-1 RESPONSE:

Size: px

Start display at page:

Download "QUESTION NO. : 15-1 RESPONSE:"

Cori Baker
6 years ago
Views:

1 QUESTION NO. : 15-1 Q. In their response to PPRP DR No. 7-10(a), Applicants state that the DC vendor has not been selected at this time and the vendor s selection is not expected until the third quarter of a. Will the DC portions of the MAPP project still use VSC technology? Please begin your answer with a yes, no, or Applicant cannot answer yes or no. If your answer begins with either a no or Applicant cannot answer yes or no, please explain your answer with reasonable specificity. b. Is all the technical information concerning the DC portions of the MAPP project, as presented in the direct testimony and exhibits of William Gausman, still accurate? Please begin your answer with a yes, no, or Applicant cannot answer yes or no. If your answer begins with either a no or Applicant cannot answer yes or no, please identify with specificity those parts of such technical information which are no longer accurate, and provide updated accurate information. c. Please describe with reasonable specificity the impact (if any) which the selection of the DC vendor may reasonably have on estimated costs for the MAPP project? A. a. Yes, the DC portions of the MAPP project will use VSC technology. b. Yes, the technical information presented in the direct testimony and exhibits of William Gausman is accurate. VSC technology offers many benefits over both AC and conventional DC technologies, including reduced footprint, dynamic control of system voltage, dynamic control of both the power flow and direction, the ability to use XLPE cables containing no fluid and black start capability. c. The selection of the DC vendor, based on those presently under consideration, should allow the MAPP project to be constructed within the budget estimate of $1.2 billion. SPONSOR: William M. Gausman

2 QUESTION NO. : 15-2 Q. Page 19 of the direct testimony of Paul McGlynn makes reference to a Capacity Emergency Transfer Obligation ( CETO ) that PJM establishes for each load deliverability area. Although Mr. McGlynn s direct testimony does not address the method for determining CETO, in Maryland PSC Case No. 9223, Mr. McGlynn s Supplemental Direct Testimony dated September 14, 2010 stated: The CETO calculated for the load deliverability tests is the import capability required for the area to meet a Loss of Load Expectation ( LOLE ) risk level of one day in twenty-five years. Please refer to Mr. McGlynn s response to OPC DR No. 4-6 in Case No. 9223, a copy of which is attached hereto and incorporated herein as if restated in full. In this regard: a. Is the CETO calculated by PJM for the load deliverability tests the import capability required for the area to meet a Loss of Load Expectation ( LOLE ) risk level of one day in twenty-five years? Please begin your answer with a yes or a no. If your answer is in the negative, please state how PJM calculates CETO and explain your answer with reasonable specificity. b. Please explain with reasonable specificity why the LOLE used in calculating CETO one day in 25 years rather than one day in 10 years. c. If the one day in 10 year standard had been used in calculating CETO, what would the CETO have been? d. If the one day in 10 year standard had been used in calculating CETO, state how and why this would (or would not) have affected PJM s conclusions as to the need for the MAPP Project? e. Provide all workpapers supporting any analyses done on a revised LOLE/CETO calculation. f. Please explain with reasonable specificity why an LOLE of 1/15, or an LOLE of 1/20, provides an insufficient margin to ensure that the transmission risk does not appreciably diminish the overall target of a 1/10 LOLE? In your answer, please do not simply refer to a PJM document but rather write out your explanation with reasonable specificity. (1) Provide the formulae and workpapers which support your answer.

3 g. Please explain with reasonable specificity how PJM knows whether an LOLE of 1/25 is itself sufficient to ensure that the transmission risk does not appreciably diminish the overall target of a 1/10 LOLE for PJM. h. Understanding that PJM has not previously calculated CETOs using a 1-in-10 LOLE, please perform the calculation and state the resulting CETO if the one day in 10 year standard had been used in the calculation. Please provide the workpapers or active Excel spreadsheets showing how the result was determined. i. With reference to the result obtained in your response to subpart (h) above, please state with reasonable specificity how this result affects (or does not affect) PJM s conclusions as to the need for the proposed MAPP transmission line project. A. In addition to the objections set forth in the cover letter incorporated in all responses, Applicants object to any requests to conduct new studies not already performed. a. Yes. The aggregate loss-of-load risk to the customer is a combination of reserve adequacy risk and transmission risk. The one-day in-25 years is the transmission risk associated with a one-day in ten reserve adequacy risk. The PJM Planning and Engineering Committee determined (more than 10 years ago) that a 1D/25 Y transmission risk level was sufficiently small and that any greater level of risk was not. See also response to OPC-15-2-(b). b. PJM does not calculate a LOLE transmission risk for every possible level of capacity; capacity levels can and do vary, even more so since the implementation of the PJM RPM auction capacity construct. Given the reality of changing capacity levels, the PJM Planning Committee (more than 10 years ago) discussed and selected 1-in-25 as a reasonably small transmission LOLE risk to reasonably ensure that a 1-in-10 aggregate overall LOLE risk criteria is maintained. Mathematically, a 1-day-in-10-years LOLE is the same as 0.1 days-per-year. Likewise, a 1-day-in-15-years LOLE is the same as days-per year; 1- day-in-20-years is the same as 0.05 days-per-year and 1-day-in-25-years is the same as 0.04 days-per year. The PJM Planning Committee decided that the transmission risk should not be more than one-half of the overall generation capacity risk of 1-day-in-10-years. As a result, the Planning

4 Committee selected the 1-in-25 LOLE criteria, given that 0.04 is less than ½ of 0.1. c. PJM presumes that the question is asking what the CETO values would be on a 1-day-in-10-years LOLE basis for the Eastern MAAC and MAAC LDAs, per the limiting NERC reliability criteria voltage violations listed in Exhibit PFM-1-1 of Mr. McGlynn s November 3, 2010 Direct Testimony. Eastern Mid-Atlantic 1-day-in-10 years 7260 Mid-Atlantic 1-day-in-10 years 4940 d. RTEP analysis was not performed for CETO values at a transmission risk other than the 1-day-in-25 years associated with a one-day in ten reserve adequacy risk. See response to OPC-15-2-(a). e. Without waiving the objections to this request, no such work papers exist. The CETO values provided in response to OPC-15-2-(c) are the output of software applications. f. See responses to OPC-15-2-(a) and (b). g. See responses to OPC-15-2-(a) and (b). h. Without waiving the objections to this request, see response to OPC-15-2-(c). i. See response to OPC-15-2-(c). SPONSORS: Paul F. McGlynn Steven R. Herling

5 QUESTION NO. : 15-3 Q. For your responses to this Data Request, please refer to the questions in, and Paul McGlynn s responses to, OPC DR No in Case No. 9223, a copy of which is attached hereto and incorporated herein as if restated in full. a. For each of Mr. McGlynn s answers to OPC DR No in Case No. 9223, respectively, please state whether those answers regarding the CETOs used by PJM are accurate as to determining the need for MAPP in the instant case. For each respective answer, please begin your response with either Yes, that answer remains accurate, No, that answer is now inaccurate or Cannot state whether that answer remains accurate. b. If any answer is no to any subpart of OPC DR No. 15-3(a) immediately above, please explain with reasonable specificity why it is not accurate as regards the determination of the need for MAPP; and, please explain with reasonable specificity what the correct answer should be. c. If any answer is cannot answer yes or no to any subpart of OPC DR No. 15-3(a) above, please explain with reasonable specificity the reasons and bases for your answer. A. a. Yes, PJM s 2010 CETOs were accurate in light of PJM s answers to OPC DR No in Case No See explanation provided in OPC-15-2-(a) and (b). Notwithstanding, while PJM s CETO methodology has not changed in 2011, PJM s 2011 cycle of analyses are likely to include different CETO values than those used in 2010 based on updated load forecast, generation and other system changes. Subsequent to its April 5, 2011 meeting, the PJM Board requested that additional sensitivity analyses be completed by August Results of the same will be provided to the Board and to stakeholders as completed, beginning in April b. See response to OPC-15-3-(a). c. See response to OPC-15-3-(a). SPONSOR: Paul F. McGlynn

6 QUESTION NO. : 15-4 Q. For your responses to this Data Request, please refer to the questions in, and Paul McGlynn s responses to, OPC DR No. 4-6, including Attachment OPC 4-6-A, in Maryland PSC Case No. 9223, a copy of which is attached hereto and incorporated herein as if restated in full. a. For each of Mr. McGlynn s answers to OPC DR No. 4-6 in Case No. 9223, respectively, please state whether those answers regarding the CETOs used by PJM are accurate as to determining the need for MAPP in the instant case. For each respective answer, please begin your response with either Yes, that answer remains accurate, No, that answer is now inaccurate or Cannot state whether that answer remains accurate. b. If any answer is no to any subpart of OPC DR No. 15-4(a) immediately above, please explain with reasonable specificity why it is not accurate as regards the determination of the need for MAPP; and, please explain with reasonable specificity what the correct answer should be. c. If any answer is cannot answer yes or no to any subpart of OPC DR No. 15-4(a) immediately above, please explain with reasonable specificity the reasons and bases for your answer. A. a. Yes, PJM s 2010 CETOs were accurate in light of PJM s answers to OPC DR No. 4-6, including Attachment OPC 4-6-A, in Maryland PSC Case No See explanation provided in OPC-15-2-(a) and (b). Notwithstanding, while PJM s CETO methodology has not changed in 2011, PJM s 2011 cycle of analyses are likely to include different CETO values than those used in 2010 based on updated load forecast, generation and other system changes. Subsequent to its April 5, 2011 meeting, the PJM Board requested that additional sensitivity analyses be completed by August Results of the same will be provided to the Board and to stakeholders as completed, beginning in April b. See response to OPC-15-4-(a). c. See response to OPC-15-4-(a). SPONSOR: Paul F. McGlynn

7 QUESTION NO. : 15-5 Q. For your responses to this Data Request, please refer to the questions in, and Paul McGlynn s responses to, OPC DR No. 4-7 in Maryland PSC Case No. 9223, a copy of which is attached hereto and incorporated herein as if restated in full. A. a. For each of Mr. McGlynn s answers to OPC DR No. 4-7 in Case No. 9223, respectively, please state whether those answers regarding the CETOs used by PJM are accurate as to determining the need for MAPP in the instant case. For each respective answer, please begin your response with either Yes, that answer remains accurate, No, that answer is now inaccurate or Cannot state whether that answer remains accurate. b. If any answer is no to any subpart of OPC DR No. 15-5(a) immediately above, please explain with reasonable specificity why it is not accurate as regards the determination of the need for MAPP; and, please explain with reasonable specificity what the correct answer should be. c. If any answer is cannot answer yes or no to any subpart of OPC DR No. 15-5(a) immediately above, please explain with reasonable specificity the reasons and bases for your answer. a. Yes, PJM s 2010 CETOs were accurate in light of PJM s answers OPC DR No. 4-7 in Maryland PSC Case No See explanation provided in OPC (a) and (b). Notwithstanding, while PJM s CETO methodology has not changed in 2011, PJM s 2011 cycle of analyses are likely to include different CETO values than those used in 2010 based on updated load forecast, generation and other system changes. Subsequent to its April 5, 2011 meeting, the PJM Board requested that additional sensitivity analyses be completed by August Results of the same will be provided to the Board and to stakeholders as completed, beginning in April b. See response to OPC-15-5-(a). c. See response to OPC-15-5-(a). SPONSOR: Paul F. McGlynn

8 QUESTION NO. : 15-6 Q. For your responses to this Data Request, please refer to the questions in, and Paul McGlynn s responses to, OPC DR No. 4-8 (but excluding Attachment OPC DR No. 4-8-A-CONF thereto) in Maryland PSC Case No. 9223, a copy of which is attached hereto and incorporated herein as if restated in full. a. For each of Mr. McGlynn s answers to OPC DR No. 4-8 in Case No. 9223, respectively, please state whether those answers regarding the CETOs used by PJM are accurate as to determining the need for MAPP in the instant case. For each respective answer, please begin your response with either Yes, that answer remains accurate, No, that answer is now inaccurate or Cannot state whether that answer remains accurate. b. If any answer is no to any subpart of OPC DR No. 15-6(a) immediately above, please explain with reasonable specificity why it is not accurate as regards the determination of the need for MAPP; and, please explain with reasonable specificity what the correct answer should be. c. If any answer is cannot answer yes or no to any subpart of OPC DR No. 15-6(a) immediately above, please explain with reasonable specificity the reasons and bases for your answer. d. Please provide the document supplied in Attachment OPC DR No. 4-8-A- CONF in Case A a. Yes, PJM s 2010 CETOs were accurate in light of PJM s answers to OPC DR No. 4-8 (but excluding Attachment OPC DR No. 4-8-A-CONF thereto) in Maryland PSC Case No See explanation provided in OPC-15-2-(a) and (b). Notwithstanding, while PJM s CETO methodology has not changed in 2011, PJM s 2011 cycle of analyses are likely to include different CETO values than those used in 2010 based on updated load forecast, generation and other system changes. Subsequent to its April 5, 2011 meeting, the PJM Board requested that additional sensitivity analyses be completed by August Results of the same will be provided to the Board and to stakeholders as completed, beginning in April 2011.

9 b. See response to OPC-15-6-(a). c. See response to OPC-15-6-(a). SPONSOR: Paul F. McGlynn

10 QUESTION NO. : 15-7 Q. On Page 89 of the 2010 PJM Regional Transmission Expansion Plan ( RTEP ) dated February 28, 2011, an operational solution to the delay in completing the Susquehanna Roseland 500 kv transmission line is described as including operating to the NERC category C double-circuit tower line contingencies that are driving the need for the line. a. Please describe what the phrase operating to the NERC category C double-circuit tower line contingencies that are driving the need for the line means in the way of operating the electric system, or in the way of planning to operate the system. b. Please describe how (if at all) this solution differs from PJM s normal operating policy, or from PJM s normal planning to operate the system. If this solution does not differ from PJM s normal operating policy, or from PJM s normal planning to operate the system, please explain why this is so. c. Please describe how this solution affects the treatment of demand resources, from both an operational viewpoint and from a planning viewpoint, respectively. A. a. In actual operations, PJM s normal operating policy requires real-time mitigation of first-contingency transmission constraints, or n-1 NERC Category B violations. The specific situation to which Question OPC-15-7 refers anticipates a likely delay in the availability of the Susquehanna Roseland 500 kv line, requiring PJM to take steps to ensure system reliability absent that line, given that it would otherwise solve the identified DCTL Category C common mode violations. In collaboration with PJM Operations staff, PJM has developed an operational solution to address the criteria violations that would otherwise be expected to occur in 2012 without the Susquehanna - Roseland line. The operational solution includes extending the RMR for Hudson Unit #1 into 2012 and operating to the NERC category C double-circuit tower line contingencies that are driving the need for the line. DCTL system

11 configurations will be treated in real-time operations as if they were an n- 1 event. Operating to the double circuit tower line contingencies will provide PJM Operations staff the time needed to implement Demand Resources to manage flow on constrained facilities once other generation redispatch options have been exhausted. Analysis shows the combination of retaining the Hudson Unit #1 on RMR along with implementing Demand Resources would be effective at controlling the thermal violations expected to occur in 2012 without the Susquehanna Roseland line. b. See response to OPC-15-7-(a). c. See response to OPC-15-7-(a). SPONSOR: Paul F. McGlynn

12 QUESTION NO. : 15-8 Q. On pages 158 and 159 of the 2010 PJM RTEP, Figures 6.5, 6.6, and 6.7 chart the EMAAC maximum import limit in MW for the base case and for various combinations of reinforcement projects. These combinations all include PATH or a PATH alternative. Please provide similar data for the following reinforcement projects or combinations of reinforcement projects: a. The Mt. Storm to Doubs 500 kv rebuild. b. MAPP. c. The Northern Alternative. d. The Mt. Storm to Doubs 500 kv rebuild plus MAPP. e. The Mt. Storm to Doubs 500 kv rebuild plus the Northern Alternative. A. In addition to the objections set forth in the cover letter incorporated in all responses, Applicants object to any requests to conduct new studies not already performed, including with respect to combinations (a), (d) and (e), which have not been evaluated by PJM and would constitute new and original work. Without waiving the foregoing objections, Applicants respond as follows: Regarding the Mount Storm Doubs 500 kv transmission line rebuild, while the rating of the line will be higher, the rebuild does not materially affect the transmission system impedance matrix and, thus, does not materially affect the flows on other transmission lines. Therefore, PJM does not intend to conduct studies related to the need for the MAPP line with and without the Mount Storm Doubs line. Notwithstanding the aforementioned, Figures 6.6 and 6.7 referenced in the question both show the effect of Dominion Alternatives 1, 2 and 3, each of which included a rebuild of the Mt. Storm Doubs line along with other upgrades, as shown on Slide #16 of the November 10, 2010 PJM TEAC presentation materials, accessible form PJM s web site via the following URL link: reliability-and-market-efficiency-update.ashx

13 Combinations (b) and (c) were evaluated by PJM, per July 14, 2010 TEAC meeting materials, Slides #27 through 30, accessible from PJM s web site via the following URL link: SPONSOR: Paul F. McGlynn

14 QUESTION NO. : 15-9 Q. Pages 18 and 160 of the 2010 PJM RTEP state that, Analysis performed on the Preliminary 2011 PJM RTEP process analysis suggests that the need for the PATH line has moved several years beyond The outlook for a slower economic recovery reflected in the reduced load growth rates in PJM s January 2011 published forecast has led the PJM Board to direct transmission owners to suspend efforts on the PATH line pending a more complete analysis in 2011 of all RTEP upgrades, including MAPP. a. Please provide a copy of the 2011 PJM RTEP Retool for the MAPP project. b. If the 2011 PJM RTEP Retool for the MAPP project is not yet completed, please state whether it will be complete and provided by Friday, April 15, A. In addition to the objections set forth in the cover letter incorporated in all responses, Applicants object to any requests to conduct new studies not already performed. Without waiving these objections, Applicants respond as follows: a. See response to OPC-8-1-(a). b. Subsequent to its April 5, 2011 meeting, the PJM Board requested that additional sensitivity analyses be completed by August Results of the same will be provided to the Board and to stakeholders as completed, beginning in April The retool will not be completed by Friday April 15, SPONSOR: Paul F. McGlynn

4 Pepco Holdinqs Inc. April 23,2009. Re: DNR Data Request No. I - MAPP CN Dear Messrs. Hare and Bolea:

4 Pepco Holdinqs Inc. April 23,2009. Re: DNR Data Request No. I - MAPP CN Dear Messrs. Hare and Bolea: 4 Pepco Holdinqs Inc 701 Ninth Street, NW Suite 1100 Washington. DC 20068 202 872-2850 (DC Office) 202 872-3281 (Fax) jwboone@.pepcoholdings.com James W. Boone Assistant General Counsel April 23,2009 M.