NATIONAL GRID

Generator Testing Issues

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Table of Contents
1. INTRODUCTION.3 2. GENERATOR TESTING, SECTION 1......................................................................4 S 1.1 Commissioning Tests 5 S 1.1.2 Operational Tests.6 3. GENERATOR TESTING, SECTION 2......................................................................8 S 2.1 Introduction..9 S 2.2 The Costs associated with generator testing9 S 2.3 Trading & Settlement Code.9

4. APPENDIX A: GENERATOR TESTING CHARGES ....................................16

A 1. - A1.5..17-20 5. APPENDIX B: TRADING & SETTLEMENT ...........................................................21 B1 - B521-24

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Introduction Shortly, the first large generators since the introduction of deregulation in Ireland will be commencing their programme of testing and commissioning in order to prove their plant design and to prove compliance with the Grid Code industry standards. However there is at present a degree of uncertainty among the industry participants with respect to how the whole area of testing is to be dealt with through the Connection Agreement, the Grid Code and the Trading and Settlement Code. The main questions being posed relate to: 1. The definitions relating to commissioning as stated in the Connection Agreement and Grid Code and how it relates to the overall programme of generator testing which a Generator will require. 2. The commercial arrangements applicable to a generator while exporting to the Transmission System during a testing programme. This paper sets how ESBNG (as TSO and SSA) proposes to provide for tests under the headings described above. Section 1: deals with the definitions relating to generator testing and commissioning and how discrepancies in the definition need to be rectified to provide for the tests that Generators will wish to carry out. Section 2: considers the commercial implications between Customer and the TSO/SSA, which will arise when generator testing involves the export of MW onto the Transmission System. For instance under subsection 2.1 the paper discusses the costs, which may be incurred in securing the overall network against the unstable nature of testing. It continues to recommend how these costs may be quantified and how they may be recovered. The question also arises as to how the energy produced during Generator Testing may be traded under the current Trading and Settlement Code. Subsection 2.2 explains the trading rules, which ESBNG proposes should apply during a Generator Testing period. ESBNG would like to point out that this paper can only at best assume and take into consideration the likely views of Generators with respect to the above issues. ESBNG therefore would welcome comment from generators on the assumptions and proposals outlined in this paper.

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Generator Testing Section 1: The Definitions relating to Commissioning

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S 1.1 Test Types For the purpose of this paper Generator Testing can be broadly categorised under two main types of test. Test Type 1 Commissioning Tests Test Type 2 Operational Tests S1.1.1 Commissioning Tests This type of testing may be described, as all those tests required, to bring a generating facility fully up to its Operational Date. There are a number of stages involved in this process, which may be described as follows: Stage 1: Once the connection works are complete testing begins to ensure the generating plant and transmission connection have been constructed in accordance with the proposed design. These tests involve separate testing of the generating plant by the generator ("the Customer") and separate testing of the transmission connection by the TSO ("the Company"). The customer tests to be carried out at this early stage would mainly be those specifically called for by its Engineering Procurement Contract (EPC). Stage 2: Stage 1 is followed by a programme of joint testing whereby a number tests by the Customer are conducted simultaneously with tests of the Company. These are required to prove the design of the interface between the generating plant and the Transmission System. Some of these t ests are specified by the Grid Code. Stage 3: Once the joint testing has been completed satisfactorily the connection can be energised, (the Connection Date), between the new generating facility and the Transmission System. However in order to arrive at the operational date stage 3 of testing is required. This stage includes the Capacity tests and Grid Code tests called for by the Company (TSO), and those commissioning tests specific to the Customers Engineering Procurement Contract. Stage 3 testing can only be carried out after the connection date as they involve the export of MW to the Transmission System. So in theory all of the above stages should fall under the definition of Commissioning as specified in the Connection Agreement and Grid Code to w hich an IPP must abide. However the current definition of Commissioning in the Connection Agreement and Grid Code is as follows: Activities involved in undertaking the Commissioning Test or implementing the Commissioning Instructions pursuant to the terms of the Connection Agreement or as the context requires the testing of any item of users equipment required pursuant to this Grid Code prior to connection or re-connection in order to determine that it meets all requirements and standards for connection to the Transmission System. It also includes activities that determine the new values of parameters that apply to it following a material alteration or modification and in addition those activities involved in undertaking the Commissioning Tests or implementing the Commissioning Instructions as the context requires". The Grid Code also defines "Testing" and "Tests" as only those carried out by ESBNG pursuant to the Connection Conditions.
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These definitions therefore, do not include those tests required after the Connection Date i.e. stage 3 testing which are required to bring a generating facility up to its Operational Date. Although there are separate definitions given in the Connection Agreement and the Grid Code for Grid Code" tests and Capacity tests, t hey do not fall under the heading of commissioning which is required in order to make the procedures outlined in the Connection Agreement and Grid Code work. For example: Grid Code CC.15.3. sets out the various notice provisions relating to dispatch for testing purposes. Since the definition of commissioning is defined as those tests carried out prior to connection of the equipment to the transmission system (i.e. before synchronisation) and to tests carried out by ESBNG after synchronisation, any testing and commissioning to be carried out by the Customer after connection (i.e. commissioning of the generators to meet Grid Code specifications and the Capacity Test referred to in the Connection Agreement) are not included. Therefore CC.15.3 does not provide f or the Customer to request a dispatch for the latter. In addition there is no specific mention or definition of those tests, which the customer may wish to undertake Engineering Procurement Contract testing (EPC that are neither Grid Code nor Capacity tests. Therefore it is proposed that the current definitions of Commissioning and Testing as defined in the Grid Code and Connection Agreement be reviewed in light of the above and revised through the appropriate review channels, (see S1.1.3 Resolution Proposed below). S1.1.2 Operational Tests Operational tests may be described as all those tests carried out after the Operational Date. This includes a wide variety of tests including; EPC testing by the customer, operational tests as defined and specified b y 1 the Grid Code and testing required both during and after a scheduled plant maintenance overhaul . The definition given in the Grid Code for Operational Testing is as follows: Tests carried out by ESBNG in order to maintain and develop operational procedures, to train staff and to acquire information in respect of Transmission System behaviour under normal and abnormal system conditions, and also tests carried out by other Users for similar purposes in respect of their plant. This definition (which is deemed to be appropriate) needs to be added to the list of definitions presented in the Connection Agreement. S1.1.3 Resolution Proposed The definition of commissioning should be redefined in the Connection Agreement and Grid Code, in order that it includes the full complement of tests (stage1, 2, 3) required to bring a generating facility up to its Operational Date as opposed to just beyond its connection date. All testing required after the Operational Date will be defined as Operational Tests the definition of which is given in the Grid Code (subject to an alternative resolution of the issue raised in footnote 1).
1

Testing both during and after a scheduled plant maintenance overhaul may be less reliable in terms of scheduling and output than most other types of operational test. In fact it may be more appropriate in some circumstances, and at the discretion of the generator, to treat such tests as a form of Commissioning test. This would most likely arise only following major overhauls or refits/refurbishment(generator's views on this issue are requested).However for the purpose of this paper testing both during and after an operational test will be classified as an Operational Test.

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The definition of Testing should be redefined as all testing both pre and post Operational Date. It is proposed that the definitions of Commissioning and Testing be revised by means of the Grid Code modification procedure. If approved, the appropriate amendments will be made to the Grid Code and Connection Agreement definitions. It is also proposed that the current definition of Operational Testing be retained. However this definition should be added to the definitions given in the Connection Agreement.

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Generator Testing Section 2: The Commercial Arrangements

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S2.1

Introduction

The purpose of section 2, is to propose a set of commercial arrangements to address the issue of generator testing; that is, tests required by a Generator on its plant, (or tests called for by the TSO), which may require special running or may create difficulties or risks for the operation of the transmission system and/or impact on other system users. These issues have recently arisen primarily in relation to generator commissioning requirements. However, for the purposes of context and completeness, the paper addresses both commissioning tests and routine tests or Operational Tests as may be required by the generator or TSO at any time during the Generators operational life. ESBNG suggests however, that there is a distinct difference between (1) a generator carrying out tests in the lead up to commissioning and achievement of its Operational Date, and (2) a generator carrying out tests at a later time. The following subsections try to account for these differences and outlines ESBNGs views, on how tests might best be provided for commercially, with respect to Transmission System cost recovery and the trading arrangements for energy produced from generator testing. S2.2 The costs associated with generator testing

There are many types of tests, which can arise (as outlined in Section 1), and their i mpact on the operation of the generator and the system varies considerably. For example, some tests require the generator to run at a particular output (e.g. efficiency tests) but otherwise do not affect its operation and impact on the transmission system or other users. On the other hand, some tests involve a high risk of the generator tripping (or even a programmed trip) and therefore may have a very significant effect on the system, the system configuration during the test, and on other system users. The costs and impacts of tests on the operation of the system can also vary substantively for reasons such as system demand, or specific conditions of the system at the time of the test. Therefore in general, it is desirable that tests are scheduled in a manner that results in least cost and minimum impact on the operation of the system and other system users. S2.2.1 Routine or Operational Testing The position of a generator carrying out tests during its normal operational life (i.e. at any time following the Operational Date) can be categorised as follows: There may be a variety of test requirements, such as a requirement to run in accordance with a particular load pattern, a requirement to test a control system with an inherent risk of loss of output during the test, a load rejection test, testing after a major overhaul2 , or others.

Testing both during and after a scheduled plant maintenance overhaul may be considered more risk adverse for the Transmission System than most other Operational Tests. Although the associated costs incurred by the TSO will be established on a case by case basis as for all other Operational Tests, it is worth noting that the resulting charges may be quite similar to those applied for commissioning type tests.

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However, in general it is possible for the generator to predict the test requirements reasonably accurately, and to schedule the tests at a time when the system can accommodate the tests with minimum disruption, and at least cost (whether that cost arises solely to the generator and/or to other parties).

In these circumstances, it is proper that the costs of tests and their impact on the system should be addressed on a case-by-case basis, rather than having a generic set of costs for different test types. If a generic set of costs not reflecting the specific system conditions were used, then there would be no incentive on the generator to conform to a test schedule (derived by the TSO) that minimises the overall cost to the system. The procedures addressing the scheduling, implementation, revision (where necessary) and reporting of operational tests are provided in Grid Code OC8. This includes arrangements for the expediting o f tests, which are of a more minor nature and which do not significantly impact on the operation of the system or on other users. Additional procedures to facilitate smooth implementation of the tests will be derived as necessary. It should be noted that while the aim of OC8 is to produce test schedules which mitigate system impact and cost to the generator, the procedures do not prevent the generator opting for a higher cost option, where other factors outweigh the additional cost to the generator of performing the test at a time other than the optimal time from a system and cost perspective. The generic approach to costing of operational tests is outlined further in Appendix A. More detailed costing mechanisms will be developed and made available as required. S2.2.2 Commissioning Tests Pre -Operational Date The position of a generator carrying out tests in the period prior to the Operational Date is rather different from that which applies during its operational phase. Key aspects can be categorised as follows: It is of major commercial importance to the generator that it achieves its Operational Date as soon as possible. The test programme, while to some extent predictable, is subject to rapid alteration. For the above reasons, the generator may want to vary its test programme with the least possible constraints and at minimum notification requirements. This would occur largely regardless of the commercial consequences arising from test costs differing at certain times of the day or under different system conditions, as these costs may be "swamped" by the commercial impact of delays in completion of the generator's test programme. For much of the programme (though perhaps not all), the generator is inherently unreliable. Therefore it is at an unusually high risk of tripping, or subject to having significant variations in its energy

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output at comparatively short notice (either due to technical reasons or due to wishing to have the freedom to alter the test schedule at minimum notice). Notwithstanding the above, in the interests of system security and minimising impact on the operation of the system and on other users, there is always a requirement on the generator which is testing to notify the TSO to the greatest extent possible of its test requirements. While the TSO will endeavour to accommodate the test requirements, there will be times at which test requirements cannot be accommodated due to system conditions 3 . All tests will be subject to dispatch by the TSO. A further relevant consideration is the status of the generator in relation to access to the transmission system and liability for transmission use-of-system (TUoS) charges. If tests were taking place in advance of the Connection Date, then the Generator would have non-firm access to the system only and would pay only the appropriate TUoS charges. It is also possible that the necessary reinforcements to the system to permit full physical access of the generator's output to the system are not complete, or full physical access can only be accommodated by the TSO constraining the output of other generation in the area, or the shallow connection is not fully complete; e.g. a temporary means of connection may be facilitated to allow earliest possible testing by the generator.

Recognising the above, and particularly that the generator will wish to proceed on its own test schedule to the maximum possible extent4, ESBNG makes the following basic proposals as to how commissioning tests and their associated costs should be dealt with5 . Test costs will be charged to the Generator based on a schedule of published charges, most likely published in the TSO's Statement of Charges and Payments. Charges would be revised from time to time depending on changes in system conditions (possibly on an annual basis). The reasoning behind providing published charges on an ex-ante basis is that it promotes certainty for the Generator. In addition, there is less benefit in reflecting the actual costs (based on actual system conditions), than there is in normal operational tests, because the Generator is less concerned with the cost signals and

By way of example, it may not be possible to accommodate a large load rejection test at times, e.g. times of minimum system demand or times of rapid demand rise.
4

That is, without knowledge of, the impact on system operating costs, though still from time to time restricted by TSO due to system conditions.
5

While some of these issues can also arise in relation to tests carried out during normal operation, the basic approach proposed here is to keep a separation between commissioning tests and other (operational) tests. In this section therefore we are dealing only with commissioning tests.

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will wish to proceed with its tests as scheduled, regardless of cost signals. An outline of how ESBNG proposes to establish these charges is detailed in Appendix A. The published charges would provide for a number of different types of tests, depending on the cost impact of the tests to the system, the output of the unit under test at the time, and so on6 . The charges will be intended to reflect on average the additional system costs seen by the TSO; however as these are set in advance, on any individual occasion the costs charged to the generator and the costs seen by the TSO may differ. Because the output of the unit under test is likely to vary widely without notice (due to technical reasons), the TSO will generally commit other plant recognising that the output of the unit under test may become zero even at times when it is scheduled to run7 . Therefore when the unit is actually running, the Settlement System will show a number of constrained units with associated costs to the TSO8 . If the unit is not running, then there would be no additional constraint cost to the TSO as all necessary plant is already committed (other than some costs while the TSO is adjusting the dispatch in the event that the testing units output reduced to zero unexpectedly). Derivation of the likely cost of this to the TSO will be reflected in the published charge of the test. As the unit is at a high risk of tripping, there will be a need to carry extra Operating Reserve on the system, particularly if the unit is large and is running at high output9 . To the extent that some of the costs of providing the additional operating reserve overlap with the cost of constraining other units to accommodate the testing unit's output (see last bullet), this would be taken into account in the derivation of the test charges. Where the generation unit is carrying out a load rejection test from a high output, there will be a need to carry still further Operating reserve to mitigate the impact on the system frequency and on other system users including demand customers. This would apply for only a limited duration at and around the time of the load rejection test. Again, to the extent that some of the costs of providing the additional operating reserve overlap with the costs of constraining other units to accommodate the testing unit's output, this would be taken into account in the derivation of the test charges.

This is described further in the following paragraphs; however the proposed approach to the derivation of the costs, and description of the cost components, is elaborated upon more fully in Appendix A.
7

This condition could be deemed to be alleviated at a point in the commissioning schedule, e.g. when the unit has successfully completed a period of [72 hours] of its reliability run. It should be noted though, that the TSO would reserve the right (acting reasonably and in accordance with prudent utility practice) to impose restrictions on the operation of a generation unit including the provision of extra reserve to the cost of the generator (following discussion with the generator), where the TSO is of the opinion that the operation of the unit is endangering the secure operation of the transmission system or causing an unacceptable impact on other system users. Therefore were the generation unit to exhibit significant and repeated unreliability at a later time, the TSO may re-impose restrictions.
8

There will be little or no net MW constraint as a result of this approach, as the testing unit's XNOM will be set in EPUS equal to its IQ (Instructed quantity). However as more units are running than would be anticipated with perfect foresight, there will be a series of units dispatched at other than nominated output, some at more and some at less, receiving constraint payments from the TSO.
9

This condition could be deemed to be alleviated at a point in the commissioning schedule, which is suggested to be deemed as the time at which the unit has successfully completed a period of [72 hours] of its reliability run.

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One further point that needs to be taken account of, is the situation whereby in order to accommodate the output of the generation unit during commissioning, the TSO has to constrain off particular generation units in the area of the testing generator. This would arise where the deep reinforcements necessary to accommodate the unit's output are not complete, which is quite possible as the unit is running for tests prior to the Connection Date. In this case, if the units being constrained are high-merit units, then the costs accruing to the TSO are higher than would be provided by the test charges discussed above. Two approaches are possible in these circumstances: 1. To increase the published test charges for all units, to provide for the fact that this situation will arise from time to time; 2. To apply the additional charge only when this situation arises. The situation will not always arise as in some cases the transmission system will be sufficient to allow the output of the testing unit without constraining high-merit plant. Indeed the constraint may only be required for a small portion of the total MW output of the generator test. The corresponding charge should similarly be only applied to the portion of MW with such non-firm access. ESBNG propose that the second option above would be preferable. Thus the increased charge would only be applied when this particular situation arises, and would not otherwise be charged to units when commissioning. It is the opinion of ESB National Grid, as TSO and manager of the above costs, that their recovery should be from the Generator requesting to test (as opposed to recovery by the TSO from all system users), as these costs are attributable to the risks imposed to the security of the system by the Generators testing programme. Although many of these tests are a requirement of the Grid Code, they are equally applicable to all new entrants in order to connect to the Transmission System and so can be classified as a form of connection charge. Appendix A presents ESB National Grids proposed charging policy for the costs incurred by the TSO for generation unit testing carried out prior to the Generators Operational Date. In general the charges are based on a function of MW output during testing, and may be minimised by the effective management by the Generator, of the testing programme itself. For instance it will inherently be in the Generators interest to limit the amount of additional testing or re-testing required, and it will be in the TSOs interest adopt a reasonable approach in the amount of testing which it calls for, in order that risk to the security of supply to existing connected customers, is minimised. Finally it should be noted that some of the costs described above are particular to the Irish Transmission System, due to its relatively small overall capacity with respect to the size of a typical new generation entrant. For instance a 400MW new generation plant wishing to connect to the Transmission System currently represents approximately 10% of the total peak generation demand.

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S2.3

Trading and Settlement Code

At present there is a potential problem concerning the operation of Electricity Trading and Settlement Rules (the Rules) during a period of Generating Unit testing. A Generator wishing to run tests on one of its Units may have a good idea about what days the tests will be run on, but will probably have an inaccurate view of the output that it will attain in any particular half-hour (Trading Period). The Rules, however, require it to submit a half-hour-by-half-hour energy nomination (ANOM) and the TSO is obliged to try and schedule the Units to their ANOMs. This would seem to be an unsatisfactory position for both the Generator and the TSO. In general the requirements of the generator and the TSO can be summarised as: 1) the Generator: a) b) c) 2) a) b) c) wants to know that the TSO will try and dispatch it to carry out its tests; would like some remuneration for the output it produces; does not want to have to pay unreasonable penalties; does not want to pay Instructed Imbalance Payments for allowing a Generator to test one of its Units; does not want to base its Generation Schedule on a basis that it knows is false or inherently likely to be subject to major change; wants to know that, even during testing, the Generator will try to follow instructions.

the TSO:

If the Generator had perfect foresight it would simply set ANOM equal to its desired running pattern. This would, if transmission constraints were not an issue, most likely give it a Tradable Quantity (XNOM) equal to its actual output. The TSO would also avoid having to pay for any Instructed Imbalances. Unfortunately, the Generator will not have perfect foresight. ESB National Grid has, however, already proposed a mechanism for achieving this match between ANOM and output. This is very similar to the solution proposed for Non-Firm Access in the CERs draft direction Firm and Non Firm Access to the Transmission System (ref. CER/01/60). The generator submits a set of ANOMs and a testing programme for the day ahead. ESBNG would prepare a generation schedule attempting, as far as possible, to schedule the generator to match its testing programme. On the day, ESBNG in dispatching plant would take account of any revisions to the generator's testing programme. For the purposes of the EPUS run only, the generators availability would be set equal to the level it was dispatched to (subject to some constraints). Thus the Generator would be remunerated as if it had nominated, day ahead, its availability equal to the level it was dispatched to. As ESBNG takes account of the testing programme in preparing the generation
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schedule and in dispatching plant, this should facilitate the testing, allow the generator be remunerated for its output while providing an incentive for it to follow any dispatch instructions issued by ESBNG. A more complete analysis of the issues and details of the proposed solution are contained in Appendix B.

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Generator Testing APPENDIX A: Generator Testing Charges

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A1.

Introduction

The costs imposed on the Transmission System during testing prior to the Operational Date, may for the purpose of this paper be classified as follows: A1.1 The costs associated with committing additional generation plant due to the high risk that the testing generator may not produce all or any of its planned MW output due to a revision of its test schedule; The cost of holding additional reserve to maintain system security, that is, constraint costs associated with dispatching units for reserve, and reserve utilisation payments. These costs will overlap with the costs in A1.1 above. The costs of specific tests such as load rejection tests that cause stress to the transmission system and impact on other system users. System operating and generator rescheduling costs due to short notice changes to test schedule o r test cancellation (which will generally be small, if the approach to scheduling of commissioning tests proposed in this paper is adopted). Transmission constraint payments i.e. the cost of facilitating testing prior to the construction of the deep assets (firm access date). These costs will only arise for certain projects.

A1.2

A1.3 A1.4

A1.5

The proposed approach for evaluation of each of the charges on an ex-ante basis is described in the following sections. A1.1 Costs associated with committing additional generation plant due to the high risk that the testing generator may not produce all or any of its planned MW output due to a revision of its test schedule.

Under the proposed approach put forward in this paper, there should be little or no overall net decrement (in MW), as the testing unit will appear in the EPUS model as having an XNOM equal to its IQ (Instructed Quantity). Therefore the summed actual output of the remaining units will be equal to the sum XNOM quantities. However, within the portfolio of plant there will be a series of units, each of which will be constrained, each either incremented or decremented, as compared to the EPUS XNOM values. The extent of these constraints and the consequential additional constraint costs to be paid is to some extent dependent on the nomination strategy of all the generation units (other than the testing unit). ESBNG are working on a methodology for estimating the costs, and will make a proposal as to how the costs should be calculated, assuming that the broad principles laid out in this paper are found to be generally acceptable. It is likely that the methodology to be proposed will be based on either the "Prosym" or "Promod" modelling packages.

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The derived charge will be expressed as X/MWh, for every MWh produced by the testing unit in the period in question. A1.2 The cost of holding additional reserve to maintain system security, that is, constraint costs associated with dispatching units for reserve, and reserve utilisation payments. These costs will overlap with the costs in A1.1 above.

As discussed within this paper, the TSO may be required (depending on the output of the unit under test) to carry additional operating reserve during the period when the unit is testing, because the unit is at significantly higher risk of tripping and causing a frequency disturbance. Currently, Primary Operating Reserve is made up from "spinning reserve", which is provided by generation units, and "non-spinning reserve", which is, in the main, provided by interruptible load, t hat is, demand customers who have agreed to allow some or all of their demand to be interrupted in return for a payment from the TSO. The additional costs of reserve will manifest itself in two ways: 1. additional constraints payments to units which are being decremented to provide additional reserve; 2. reserve utilisation payments for the additional reserve amounts. Costs arising under (1) above are closely interlinked with the constraint costs arising under A1.1 above. Units being "dec-ed" under A1.1 will, in some cases, provide additional operating reserve also. To evaluate this cost separately from the cost calculated in A1.1 would be to incur a significant amount of "double counting". Therefore it is proposed that the costs arising from this element will be evaluated along with the costs arising under A1.1, and included in the same charge structure. Reserve utilisation payments are published in ESBNG's "Statement of Charges and Payments". The current payments for each of the five categories of Operating Reserve are: POR: 1.52/MWhr SOR: 1.38/MWhr TOR1: 1.26/MWhr TOR2: 1.26/MWhr RR: 0.95/MWhr The additional amount of Primary Operating Reserve (POR) carried by the TSO will be equal to Max (testing unit output (MW) - normal POR "spinning" (MW), 0)

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Only spinning reserve MW is used here, as ESBNG's current policy does not provide for utilisation of interruptible demand for the purpose of providing reserve for a known high-risk event. The level of spinning reserve being carried will vary somewhat from time to time depending on system maximum infeed and the contribution from non-spinning sources. At time of writing, the normal level of spinning reserve is [170MW]. Similar amounts of additional reserve will be carried in other reserve categories. Therefore the test charge under this heading would be (using the current SoCP reserve costs) Max (testing unit output (MW) - normal PORspinning (MW), 0) x 6.37 A1.3 The costs of specific tests such as load rejection tests that cause stress to the transmission system and impact on other system users.

Under normal circumstances, ESBNG would provide additional operating reserve for a planned (large) load rejection test. These costs may be quite substantial as it could involve reconfiguring the output of units in advance and start-up of additional units to provide reserve. Therefore were a large load rejection test being carried out on a generation unit under normal operational conditions, it is likely that a charge would be levied. However, in the approach proposed in this paper for units under commissioning, it is deemed that the additional costs of providing reserve for a unit carrying out a load rejection test would generally be small. This is because under the approach proposed, sufficient units are already being committed to provide the required reserve level, and although there may be some additional constraint cost associated with reconfiguring unit dispatches immediately prior to the test, this should be for a limited time period only and is deemed to be a small cost. Therefore it is proposed that for a commissioning unit carrying out a planned load rejection test, no further charge would be levied. A1.4 System operating and generator rescheduling costs due to short notice changes to test schedule or test cancellation (which will generally be small, if the approach to scheduling of commissioning tests proposed in this paper is adopted).

Again, under normal circumstances significant additional costs may be incurred by the TSO due to cancellation or variation of a planned test by a generator. However, in the approach proposed in this paper for commissioning units, sufficient plant is being committed to provide for the circumstances in which the generator varies its test schedule including reduction of its MW output to zero. There may be some additional costs for a period of time while the TSO reconfigures the overall system dispatch following a short notice change in the unit's output, but under the overall approach adopted in this paper, the time to implement the reconfiguration would be small and therefore the resultant costs are deemed to be small.

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Therefore it is proposed that no specific additional charge would arise due to a commissioning unit varying its test schedule10 .

A1.5

Transmission constraint payments i.e. the cost of facilitating testing prior to the construction of the deep assets (firm access date). These costs will only arise for certain projects.

As discussed in the paper, it is proposed that it is inappropriate to provide for an ex-ante general charge for this situation as costs will only arise for certain specific projects and the extent of the costs will depend on the specific conditions of the project in question. Therefore it is proposed that these costs would be calculated, in advance, but on a case by case basis.

Summary of Costs For each settlement period during which the unit being tested there will be a charge of: MWh output * X + max{ (MW output - Y), 0} * Z Where MWh output X MW output Y Z = MWh output during the settlement period = a value set ex-ante in accordance with pre-determined principles and revised from time to time as system conditions require = the average MW output of the unit in the settlement period = the spinning POR (in MW) carried on the system in accordance with the TSO's normal policy, currently [170MW] = the cost in of reserve utilisation summed across all reserve categories, as published in the TSO's Statement of Charges and Payments, current [ 6.37].

10

Although, of course, the charges paid under A1.1 and A1.2 will change as the output of the testing unit changes.

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Generator Testing APPENDIX B: Trading and Settlement

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B1

Introduction

At present there is a potential problem concerning the operation of Electricity Trading and Settlement Rules (the Rules) during a period of Generating Unit testing. A Generator wishing to run tests on one of its Units will have a good idea about what days the tests will be run on, but will probably have an inaccurate view of the output that it will attain in any particular half-hour (Trading Period). The Rules, however, require it to submit a half-hour-by-half-hour energy nomination (ANOM) and the TSO is obliged to try and schedule the Units to their ANOMs. This would seem to be an unsatisfactory position for both the Generator and the TSO. Below the issues associated with how to treat a unit undergoing tests are outlined including a proposal to modify the rule in accordance with the proposed solution. B.1 Issues

As was stated above, the Generator wanting t he test must submit ANOMs for its Units to be tested (and these form the basis for the Generation Schedule produced by the TSO). Under the current rules there would appear to be three options. The Generator could 1) 2) 3) submit a zero ANOM for the day; or submit a flat ANOM for the day, equal to the expected peak output during the tests; or submit a sculptured ANOM reflecting the planned start and finish times of the various tests and the output to be produced in each test.

It is thought that the third option (sculpted ANOM) is impractical as there will be uncertainties over the exact testing programme with the Generator having an inaccurate view of the output that it will attain in any particular half-hour. The issues associated with the other two options are discussed in more detail below. B.2 Option 1: Zero ANOM

With this option the Unit to be tested is probably not included in the Generation Schedule and the Generator will therefore be reliant on the TSO issuing it with a suitable dispatch instruction when it is ready for a test. The TSO can refuse to issue the instruction (and thus the Unit does not get tested). Alternatively, the TSO can issue the instruction (and thus the Unit does get tested). The TSO must then pay to the Generator an Instructed Imbalance Payment for the difference between the Instruction and XNOM (which, in this case, will probably equal ANOM = 0) and a Sync Payment. This is unlikely to be the minimum cost dispatch decision for the TSO unless the prices quoted by the Generator for this Unit are low (perhaps zero). If the Generator is required to quote zero prices and has an ANOM (and thus XNOM) of zero, it will get no remuneration for the energy it produces when testing. B.3 Option 2: Flat ANOM

In this case, the Generator submits a flat ANOM for the day, equal to the expected peak output during the tests. It will be in nobodies interest to dispatch the Unit if it is not ready to run (even though this is what the Generation Schedule might require). The Generator has two options. It could simply refuse an Instruction given when it is not ready (and chance its availability being set to zero and pick up a Short
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Notice Redec penalty). Alternatively it could use its availability declarations to try and control when it wants to run. Let us consider the case where the Unit has an ANOM 50MW. It has been declared as unavailable for a period, but is not ready for a test. The Units availability is set back to 50MWs. The TSO may have to wait some time before it can dispatch the Unit. For the period when availability = 0, XNOM = 0. It is, however, difficult to predict whether XNOM will equal ANOM, zero, or some value in between for the period of the test. Thus, it is difficult to predict either the size of the Instructed Imbalance or whether the TSO or the Generator will end up paying. In any case, the uncertainty that the TSO will have over the validity of the Generation Schedule for this Unit will cause additional work in the NCC and may increase, overall, constraint costs. B.4 Requirements

The options therefore that exist under the current version of the rules are inadequate and do not accord with overall proposed solution for unit testing. Following on from this we can sum up the requirements for the Generator and the TSO during such a testing period as follows: the Generator: a) b) c) the TSO: a) b) c) B.5 does not want to pay Instructed Imbalance Payments for the privilege of allowing a Generator to test one of its Units; does not want to base its Generation Schedule on a basis that it knows is false; wants to know that, even during testing, the Generator will try and follow instructions. Proposed Solution wants to know that the TSO will try and dispatch it to carry out its tests; would like some remuneration for the output it produces; does not want to have to pay unreasonable penalties;

If the Generator had perfect foresight it would simply set ANOM equal to its desired running pattern. This would, if transmission constraints were not an issue, most likely give it a Tradable Quantity (XNOM) equal to its actual output. The TSO would also avoid having to pay for any Instructed Imbalances. Unfortunately, the Generator will not have perfect foresight. ESB National Grid has, however, already proposed a mechanism for achieving this match between ANOM and output. This is very similar to the solution proposed for Non-Firm Access in the CERs draft direction Firm and Non Firm Access to the Transmission System (ref. CER/01/60). The main principals of the proposed approach are: 1) At the Day-Ahead stage the Test Unit submits an ANOM value, a set of Idling, INC, DEC 11 and Start Up Prices and its Operating Characteristics and its expected Testing programme (possibly

11

The DEC price is set to 0/MWh so that the Unit is unlikely to be DECd in EPUS and will not set the Spill Price.

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expressed as availability declarations). The ANOM profile and the Testing programme need not match (although the Testing programme should never require dispatch above ANOM). 2) 3) In preparing the Generation Schedule, ESB National Grid would treat the Test Unit in the same way as other Units, save that the Test Unit would be scheduled against its Testing programme. In making its actual dispatch decisions on the day, ESB National Grid will take account of availability notifications (or, possibly, revisions to the Testing Programme) from the Generator in respect of its Test Unit. A Test ANOM of the Test Units (which will be the basis of the Test Units ANOM for the EPUS run) is calculated. The Test ANOM would be the Test Units Instructed Quantity, IQ guh . The EPUS run will then carried out in the normal way save that for Test Units the Actual Availability (for EPUS) shall be set equal to the lower of the Units Test ANOM and the Units actual availability. This is necessary otherwise ESB National Grid could inadvertently provide additional firm transmission access for the Test Unit. an ANOM equal to its Instructed dispatch necessary to facilitate the run) will be capped at the lower of the unit. Also as the DEC price is no other unit with a DEC price

4) 5)

For the EPUS run therefore the unit that is testing will be given Quantity, which, under normal system conditions should reflect the requested testing programme. As the units availability (for the EPUS this ANOM and its actual availability, EPUS should not increment quoted should be zero it should not decrement the unit (unless there above zero that can be decremented).

Therefore the test unit should receive an XNOM equal to the Test ANOM which is based on the Instructed Quantity (unless the units actual availability falls below this). Thus the XNOM from EPUS should reflect the testing programme as facilitated by the TSO.

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