In the March 3, 2022, meeting of the Reliability Subcommittee (RSC), stakeholders were invited to submit feedback on the Generation Outage Cause Code Review. Please review the Generation Outage Cause Code List and provide suggestions on adding new selectable Cause and Subcause Codes in CROW for Generation Outages.
Please provide feedback by March 17, 2022.
MidAmerican appreciates the opportunity to provide feedback on the Generation Outage Cause Code Review.
MidAmerican is concerned that at the time of a forced outage, the cause of the unit outage may not be known, and it is unclear why MISO even needs outage codes for forced outages. When a unit is forced offline, the unit operators may not know the cause for several hours. CROW should have the ability to change cause codes later or MISO should let stakeholders know if it is more important to wait until the cause is known or put the CROW in immediately with an “unknown” cause.
MISO indicated in the RSC meeting that this change was required so MISO could ask to reschedule an outage for a planned outage so MidAmerican would suggest that outage codes not be required except for scheduled outages. If MISO requires additional details for forced outages, they can always use GADS data.
WPPI offers the following feedback on the Generation Outage Cause Code List discussed at the RSC 3/3/2022:
(1.) WPPI reviewed its CROW submissions for the last two years (since 2020 Jan) where Cause Code = “Other” (n=303) and, using MISO’s proposed complete list of codes, we were able to identify a Cause and Sub Cause Code for each (see qualifier below).
(2.) (Qualifier) We suggest adding the two Sub Cause Codes below. We suggest these additions because for us they are fairly common and the appropriate Sub Cause Code from the currently proposed complete list of codes wasn’t clear-cut.
(3.) How are the seemingly same Cause Codes “Electrical Equipment Failure (105)” and “Equipment Failure (XXX)” intended to be used? In general, we would expect to use the Cause Code “Equipment Failure” in the case of an Emergency or Forced outage and we expect we’ll have limited information at the time. In which case, we would select Sub Cause Code “Generator,” which is listed under the Cause Code “Electrical Equipment Failure (105).” If it was possible to update the Sub Cause Code, after we learn what the problem was, we could update the Sub Cause Code to one of the options listed under the Cause Code “Equipment Failure (XXX).”
(4.) We would request that MISO provide the final, consolidated list of Cause and Sub Cause Codes in Excel (similar to the Excel file provided as 20220303 RSC Item 08 Generation Outage Cause Code List).
Xcel Energy has no feedback to provide on the list of outage cause codes. However, one concern that was raised during the discussion at the 3/3/2022 RASC was that once a cause code is entered it cannot be updated. Since MISO stated that they would look into this, we would like to provide an alternative recommendation. If MISO allowed overlapping derates then the need to change the cause code or update the note field would be decreased.
If MISO determines that overlapping derates would be unreasonable, then changing the cause code is a good first step, but it would be even more helpful to be able to change the note field so you can add to it the new reason for the derate change as well. For example if the original derate was due to a boiler feed pump then the appropriate cause code would be selected. But if the mills go down during the same time frame, we are unable to note that it now includes the mill issue. So someone looking at that ticket would see the boiler feed pump cause code and not realize that the mills are also out. Increasing the availability of the note field would provide more transparency to MISO and others of the reason for the derate.
MEMORANDUM
TO: MISO RELIABILITY SUBCOMMITTEE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: GENERATION OUTAGE CAUSE CODE REVIEW
DATE: MARCH 17, 2022
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the March 3, 2022, Reliability Subcommittee (RSC) meeting concerning MISO’s proposed changes to the generation outage cause codes and subcauses that are used when a generator enters its reason for an outage in MISO’s outage coordination system (CROW).
The EOC’s support MISO’s desire to move away from the overuse of the “other” outage code but do not think this code should be eliminated as an option. We also agree that knowing the reason of an outage could aid MISO in both forward and backward-looking analysis of outages.
As discussed during the Reliability Subcommittee meeting, if not already possible, the generator operator needs the ability to edit and/or update the cause and subcause codes after the outage is initially input. Due to the timing and nature of some outages, the cause may not be known until further investigation is performed. If there are instances in which CROW does not currently allow these changes or if generator operators are not aware of this ability, this may be a driver for the overuse of “other”.
Alternatively, a new outage cause of “investigating” could be initially used until the cause is identified. Or there could be a relaxation of the current time limit to enter an outage in CROW, with the operator updating the real-time commit status to “outage” that MISO would use in the interim. If it were decided to use the “investigating” cause code, MISO could key on this code daily and follow up with generator operators if not updated timely.
MISO should also provide clarity related to the potential impacts related to the inadvertent use of the wrong cause code. If a generator operator is concerned about potential penalties or reporting error violations, this too may foster the continued use of “other”.
In any event, the updating of an outage code to reflect the correct coding should not result in any impacts to exemption status or other timing rules.
The EOCs appreciate the opportunity to comment.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
WEC Energy Group appreciates MISO's outreach to Market Participants and the opportunity to provide feedback on the CROW outage codes.
We have the following comments on the proposed changes to the outage codes:
Regardless of outage priority type, all outage cause codes & sub-cause codes should be available. The submittal time lines associated with outage priority type seem arbitrary as it relates to a cause/sub-cause of an outage or derate.
For renewables, wind & solar issue cause codes, icing, weather and wind speed should be added. Or additional weather-related sub-cause codes should be added to the Weather cause code for use by renewable resources.
MISO should consider the use of Other as a sub-cause code as a catch-all under all cause code types.
We are a strong proponent of having the ability to update a CROW ticket with better cause information once it is known, i.e. the ability to change “unknown” status later.