PJM Outlines for EPA the Need to Coordinate Outages Resulting From Coal Combustion Rule

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PJM, as the independent system operator and planning authority for the grid spanning 13 states and the District of Columbia, last week asked the U.S. Environmental Protection Agency to coordinate the timing of proposed coal plant outages as generators plan upgrades or retirements in response to the EPA’s new Coal Combustion Residuals Rule.

In its comments, PJM noted that 16% of its capacity resources – close to 29,000 MW of PJM’s generation – are impacted by the Coal Combustion Residuals (CCR) Rule. “Coordination between PJM and the EPA regarding the sequencing of coal unit outages and retirements as part of the CCR Rule implementation is necessary to ensure the reliability of the bulk electric system,” PJM stated in its comments.

The CCR Rule “establishes technical requirements for CCR landfills and surface impoundments under subtitle D of the Resource Conservation and Recovery Act (RCRA), the nation’s primary law for regulating solid waste,” according to the EPA. The regulations are meant to mitigate risks from coal ash contaminants leaking into groundwater, becoming airborne as dust or escaping during failure of surface impoundments.

PJM does not take a position on the merits of the rule, focusing instead on its generation outage scheduling process and detailing the “fact-specific, case-by-case determination PJM is required to make to ensure the reliability of the bulk electric system when an outage request is submitted for review.”

PJM requests and recommends a formal process in which:

  • The EPA solicits a recommendation from PJM on the outage scheduling for generators seeking to comply with the new CCR Rule requirements.
  • PJM would then “endeavor to complete an analysis and tender a recommendation within 60 days as to the sequencing and timing of needed planned outages that would allow for the EPA’s directives to be timely effectuated while ensuring the continued reliability of electric service in the PJM region.”

Ensuring Reliable Operations Year-Round

PJM’s outage coordination request is rooted in specific bulk electric system requirements to reliably fulfill electricity demand, especially during unexpected events.

For example, special attention and flexibility may be required for generator outage requests proposed around summer, when electricity usage is the highest of the year, PJM said.

“This coordination is necessary because … PJM cannot allow planned outages in the summer months, as they pose a reliability risk. Additionally, multiple outage request periods that overlap could cause reliability issues and would not be allowed, thus requiring the staggering of outages,” PJM stated.  

In PJM and the Midcontinent Independent System Operator to date, approximately 7,662 MW of coal facilities have indicated plans to cease firing coal (ether through retirement or conversion to another fuel) by the end of 2023, according to PJM’s filing. Proposed plant deactivations may further complicate the scheduling of outages within a restricted period.

“The EPA has asked whether 135 days from the date of the final decision provides sufficient time to accommodate the normal process of obtaining approval for a planned outage. PJM anticipates that the EPA, in consultation with PJM, should prepare to offer extensions to the extent necessary to address grid reliability issues,” PJM said in its filing.

As the neutral operator of the bulk electric system, PJM added, it will act with sound planning and operations procedures to ensure reliability while “also providing for compliance by affected units as soon as feasible.”