Federal emergency order let Louisa, Fauquier and Hanover peaker plants exceed permit limits during September grid squeeze

RICHMOND, Va. - Eleven combustion turbines at three sites in Louisa, Fauquier and Hanover counties were cleared to run beyond the limits in their environmental permits during a two-day federal grid emergency in September, according to records filed with the U.S. Department of Energy.

Energy Secretary Chris Wright signed Order No. 202-26-45 on Sept. 17, finding that "a statutory emergency exists" across the 13-state territory run by grid operator PJM Interconnection, which includes Virginia. The order, issued under Section 202(c) of the Federal Power Act, was effective Sept. 17 through Sept. 18.

Which Virginia units were listed

The order applies to a list of "Specified Resources" that PJM filed as Exhibit A. The second version of that list, submitted Sept. 17, includes:

• Louisa 1 through 5 combustion turbines in Gordonsville, dual-fuel gas and fuel-oil units rated at 77 megawatts each for the first four and 158 megawatts for the fifth, about 466 megawatts in all.

• Marsh Run 1 through 3 in Remington, Fauquier County, dual-fuel units rated at 161, 159 and 161 megawatts, about 481 megawatts.

• Four Rivers 1 and Doswell 2 and 3 in Ashland, Hanover County, dual-fuel units rated at 167, 162 and 162 megawatts, about 491 megawatts.

Together, the 11 turbines total roughly 1,438 megawatts of nameplate capacity. For each, Exhibit A lists the constraint being relaxed. The Louisa and Marsh Run entries cite short-term emissions limits for nitrogen oxides and carbon monoxide, visible emissions, and a 12-month rolling total on heat input from natural gas and fuel oil. The Ashland entries cite hourly limits on nitrogen oxides and carbon monoxide, plus peak firing and annual fuel usage.

The Doswell and Four Rivers turbines sit at the Doswell Energy Center, which a 2019 Federal Energy Regulatory Commission order describes as owned by Doswell Limited Partnership, a subsidiary of Gridiron Energy controlled by affiliates of LS Power. Ownership of the Louisa and Marsh Run units is not stated in Exhibit A, which uses PJM's "VP" prefix for the Dominion zone.

What the order allowed

The order directs PJM to dispatch the listed units "only as needed to maintain reliability" if PJM determines their output is necessary. PJM told DOE it anticipated the order "may result in exceedance of permit restrictions on sulfur dioxide, nitrogen oxide, carbon monoxide, wastewater release, and other air pollutants (including ammonia) or other limitations, such as fuel throughput."

The order also provides that emissions, hours of operation and fuel burned by listed units while it is in effect "will not be counted toward applicable rolling-average-based limitations." Operators must still comply with monitoring, reporting and recordkeeping requirements "to the maximum extent practicable," and the units must comply with state, local and federal rules once the order expires.

PJM said in its application that the units on the list "previously did not oppose the relief" it was requesting.

What the first report shows

The order requires PJM to send DOE a daily notice of each unit "designated to use the allowance and operated in reliance on the allowances." PJM's report for Sept. 17, dated Sept. 18, lists 11 generating units and several backup generators. None of the Louisa, Marsh Run, Four Rivers or Doswell turbines appear on it.

The report does not say whether those turbines ran at all that day. It lists only units operating in reliance on the order. A report for Sept. 18 operations could not be located on PJM's or DOE's websites.

Why the order was requested

PJM told DOE on Sept. 16 that it expected demand near 133,285 megawatts and that it was forecast to be about 700 megawatts below its reserve margin on Sept. 17. It cited elevated demand, about 33,191 megawatts of generation outages during the fall maintenance season, planned transmission work and firm export obligations. PJM said the strain was "experienced most acutely in BGE, PEPCO, and Dominion zones."

The Virginia State Corporation Commission's three commissioners, Chair Kelsey A. Bagot, Jehmal T. Hudson and Samuel T. Towell, were copied on the order, along with utility regulators in the other PJM states.

The order states that rate recovery for affected parties "is available" under the Federal Power Act, and it directs them to make any necessary tariff filings with the Federal Energy Regulatory Commission. No cost figures appear in the order or PJM's filings.

Documents

The order, PJM's application, its supplemental letter and Exhibit A are posted on the Department of Energy's 202(c) page for Order No. 202-26-45 at energy.gov. PJM's daily compliance report for Sept. 17 is posted at pjm.com.

Fauquier County is a county in Virginia's Piedmont. Its county seat is Warrenton. The county is governed by a five-member Board of Supervisors (Chairman Kevin T. Carter, Vice Chairman Richard R. Gerhardt, Edwin W. Broaddus, Daron L. Culbertson and A. Regan Washer), which appoints the County Administrator. Constitutional officers include Sheriff Robert P. Mosier and Commonwealth's Attorney Scott C. Hook. The Board of Supervisors office is at 29 Ashby Street, 4th Floor, Warrenton, and can be reached at 540-422-8020 or BOS@fauquiercounty.gov. Source: fauquiercounty.gov.

Hanover County is a county in the Richmond region. Its county seat is Hanover. The county is governed by a seven-member Board of Supervisors (Sean M. Davis, Susan P. Dibble, Faye O. Prichard, F. Michael Herzberg IV, Ryan M. Hudson, Danielle G. Floyd and Jeff S. Stoneman) and is administered by County Administrator John A. Budesky. The county also has a Sheriff and a Commonwealth's Attorney as elected constitutional officers. The County Administrator's Office can be reached at 804-365-6005 or ctyadm@hanovercounty.gov. Source: hanovercounty.gov.