RSC: Proposed BPM-008 Changes for Attachment D (20220428)

Xcel Energy appreciates the opportunity to provide feedback regarding the Proposed BPM-008 Changes for Attachment D.  Based on stakeholder discussions at the RSC on 4/22/22, we believe it may be helpful to add language in the BPM-008 that clarifies the following:

1. Sub-cause codes are not required;
2. Wind and solar derates for weather events should only be submitted if a MP submits their own RT intermittent forecast to MISO.  Since these weather-related derates are already calculated and forecasted by MISO's forecasting software based on parameters required at commercial model registration, these type of derates should not be submitted in CROW if an MP does not submit their own RT forecast.

Make cause codes editable after initial selection for implemented emergency CROW tickets. 

WEC Energy Group supports the addition of the "Unkown" cause code to BPM-008.  Our understanding of the discussion at the RSC is that once the "Unkown" cause code is utilized, the ticket can be updated later once a more appropriate case is identified.  We recommend including this language in the BPM.

WPPI appreciates the opportunity to review and provide feedback on the proposed edits to BPM-008 Outage Operations, Attachment D – Guidance Selecting Appropriate Cause Codes for Outage Submission. We emailed our feedback to Stakeholder Relations (we added our feedback, in redline, to the word document posted with the RSC, 4/28/2022 meeting materials, Item 05 Guidance Selecting Appropriate Cause codes BPM 008 Attachment D Redline).

I would like to thank MISO for the opportunity to provide feedback on this very critical issue.

Duke would make some suggestions for other categories that could be considered force.

Communication issues 130, Staffing 131, Solar Issues 132, and Wind Issues 133 should fall in the forced category.

Blade Damage at a wind form should be considered forced.

Communication loss or sudden loss of staffing could be considered forced.

As far as planned changes, Duke feels that vibration and turbine issues could be considered as a planned outage.

Thanks,

Bryan Garnett

MEMORANDUM
TO: MISO RELIABILITY SUBCOMMITTEE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: GENERATION OUTAGE CAUSE CODE REVIEW
DATE: MAY 12, 2022

The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the April 28, 2022, Reliability Subcommittee (RSC) meeting concerning MISO’s proposed Attachment D of BPM-008 redlines and the final outage cause code list that is used when a generator enters its reason for an outage in MISO’s outage coordination system (CROW). 

Given MISO’s proposed changes, the BPM-008 Attachment D edits seem appropriate. 

In regard to the final outage cause code list, the EOCs suggest that in addition to “Nuclear Regulatory Commission Restrictions (135)”, which should be infrequent, that the following nuclear outage causes, which are more likely, also be added to the list: 

1.            Nuclear Refuel Outage

2.            Nuclear Unit Start-Up

3.            Sequence Exchange

4.            Rod Pattern Adjustment

5.            Power Suppression Test

6.            Nuclear Rx Trip

7.            Nuclear Rx Derate 

The EOCs appreciate the opportunity to comment.