N-52024-2025 Bates White FAM Audit Report - Redacted
31 passages
XI – Commitment and Dispatch Conclusion XI-2: The processes that NSPI uses for committing, scheduling, and dispatching units were not changed during the period before the cyber event, January 1, 2024 through April 25, 2025. The concerns th...
AI summary The audit findings highlight that NSPI's commitment and dispatch processes remained unchanged during the 2024-2025 period, with frequent manual adjustments to optimization plans. The low capacity factors of generation units suggest inefficiencies, and a new Economic Dispatch Optimization Solution is expected in 2026. Lingan 2 was kept online for extended periods for system security, and the Board is recommended to establish criteria for its operation.
III.B.1.c. System Losses and Unbilled Sales Physical losses in NSPI's transmission and distribution system plus any energy generated and sold but not yet billed averaged 6.6 percent of NSR over the past five years and are forecast to remai...
AI summary System losses and unbilled sales averaged 6.6% of NSR over the past five years and are expected to remain between 6.0% and 7.0% over the next decade, according to FAM Reports from Q4 2024 and Q4 2025.
III.B.2.e. PLEXOS Input Information Origination and Maintenance Appendix B of the FAM Plan of Administration documents the FAM Fuel Forecasting Methodology governing the process and assumptions used by NSPI to produce the fuel forecast req...
AI summary This section discusses the origination and maintenance of input information for PLEXOS, including data sources, update procedures, and modeling assumptions used by NSPI. It highlights the roles of EAM and ERM, the exclusion of major unplanned outages, and the modeling of operating reserves in accordance with reliability requirements.
Figure III-6: PLEXOS Assumptions - Q4 2025 Fuel and Purchased Power Forecast Group PLEXOS Assumptions Update Required Notes Update Received Date GHG Shadow price / GHG limits No Cap-and-trade replaced by OBPS. Permanent OBPS No No Changes...
AI summary The document outlines PLEXOS assumptions for Q4 2025 fuel and purchased power forecast, including updates related to GHG shadow price, OBPS, system constraints, reserve requirements, and transmission capabilities. Notable assumptions include the replacement of cap-and-trade with OBPS and constraints on wind generation and NB imports.
Train Derailment at Sydney Coal Railway NSPI reported a single instance of a train derailment during the Audit Period. On October 6, 2025, there was a derailment of five railcars of a northbound, 21-car coal train on the Sydney Coal Railwa...
AI summary A train derailment occurred on the Sydney Coal Railway on October 6, 2025, causing five railcars to derail. The incident was attributed to track defects, non-routine track usage, and a defective switch not inspected due to a lockout. While no costs were incurred by NSPI, the report recommends tracking improvements to ensure railway safety and prevent future disruptions to the fuel supply chain.
Figure X-7: Percentage of Hours NSPI's Thermal Units Operated at Economic Minimum (or Lower) During Audit Period 398 Thermal Plant Economic Minimum (MW) % of Hours Operating at Eco Min or Below Lingan 1 60 37.3% Lingan 2 60 82.3% Ligan 3 6...
AI summary The data in Figure X-7 shows that NSPI's thermal generators operated below economic minimum levels for a significant portion of the audit period. The text discusses the implications of this, noting that NSPI continues to generate less energy due to the rise of wind generation in Nova Scotia. NSPI maintains various operating reserves to ensure reliability, and surplus reserves were observed during the audit period, except for a period affected by a cyber event.
399 NSPI must carry enough 10-minute reserve to cover its largest single contingency and enough 30-minute reserve to at least equal half of its second largest contingency. 400 NSPI carries at least 50 MW of 30-Minute Reserve. 401 NSPI carr...
AI summary NSPI is required to maintain specific levels of operating reserves, including 10-minute and 30-minute reserves, based on contingency analysis. The document notes that NSPI has met these requirements and that long-term resource planning has been transitioned to the IESO, so no further recommendations are made regarding reserve surpluses.
X.B.2.a.iv. DAFOR The third performance metric we examine is the DAFOR. DAFOR represents the percentage of time that a unit was in forced outage. DAFOR includes both forced outage hours as well as adjusted de-rated hours; it does not inclu...
AI summary The DAFOR metric measures the percentage of time a unit was in forced outage, including adjusted de-rated hours but excluding planned outages. It is compared to the industry average and is used as a proxy for the NERC Equivalent Forced Outage Rate (EFOR). The metric is used to assess the reliability of NSPI's thermal fleet.
Figure X-12: NSPI's DAFOR, by Unit, by Year, Compared to GADS EFOR Standard 416 Thermal Plant DAFOR (2024) DAFOR (2025) GADS EFOR Standard Lingan 1 5.2% 5.8% 11.5% Lingan 2 2.6% 1.2% 11.5% Lingan 3 0.1% 3.2% 11.5% Lingan 4 0.6% 1.8% 11.5%...
AI summary Figure X-12 compares NSPI's DAFOR by unit and year against the GADS EFOR standard. NSPI's thermal fleet generally outperformed the industry average, with Trenton 5 and Tufts Cove 4 being the only units to underperform in both 2024 and 2025.
X.B.3.b.ii. Performance Test Results at Units 2, 4, 5, and 6 During the Audit Period, NSPI conducted performance tests on unit 2 as well as the combined-cycle plant (units 4-6). The performance test for unit 2 tested its output capability...
AI summary During the audit period, NSPI conducted performance tests on Unit 2 and the combined-cycle plant (Units 4-6). The test on Unit 2 was conducted under NERC Standard MOD-025-2 and was the first such test since 2023. Results are addressed in a later section.
Figure X-20: DAFOR, Availability Factors of NSPI's Seven Combustion Turbines (2024-2025)444 Unit DAFOR (2024) DAFOR (2025) GADS EFOR Standard Availability Factor (2024) Availability Factor (2025) GADS AF Standard Burnside 1 93.9% 8.2% 23.2...
AI summary The document presents availability factors for NSPI's seven combustion turbines in 2024 and 2025, showing significant variations between actual and expected performance. It also notes discrepancies between NSPI's PLEXOS modeling forecasts and actual generation output from the turbines.
cludes ongoing access to specialized parts, service capabilities, spare engines, and technical expertise that are critical to maintaining the reliability of NS Power's legacy combustion turbine fleet. When we requested NSPI's estimate of t...
AI summary The document discusses the maintenance and reliability of NS Power's legacy combustion turbine fleet, including the use of a leased engine to avoid displacement of generation to higher-cost resources. It also highlights the need for NSPI to confirm whether incremental FAM costs were incurred during an outage and to refund them if so. NSPI is conducting third-party audits to evaluate vendor refurbishment practices.
Maintenance and Condition Review No indications from the PDM or PDP programs prior to the failure date were observed. Vibrations and temperatures were normal on both motors prior to the failure. Compliance with PMs associated with the CW m...
AI summary The maintenance and condition review discusses the failure of the West CW motor due to moisture management issues and non-functional cabinet heaters, leading to a 38-day forced outage. The East CW motor was in better condition after refurbishment. NSPI recommends calculating the FAM costs of the outage. A second Root Cause Analysis addressed air ingress into heat exchangers, which was repaired and has not recurred.
X.B.3.h.ii. Root Cause Analysis Review We were provided and reviewed one Root Cause Analysis related to PHB. The Root Cause Analysis, published December 3, 2025, addressed an event on May 31, 2024, when the PHB unit was forced offline due...
AI summary A root cause analysis was conducted following an event where a critical spare part, the Low-Pressure Steam Extraction Control Valve Rod, broke at the PHB unit, causing an 18-day forced outage. NSPI was unable to locate the spare Rod in inventory, leading to temporary repairs and procurement delays. NSPI has since implemented inventory control improvements, but has not yet calculated the FAM costs of the event.
AM cost of this outage, NSPI indicated that it did not conduct this calculation. We recommend NSPI provide an estimate of the incremental FAM costs incurred during this event. (Recommendation X-2) Conclusion X-18: NSPI's diesel-fired combu...
AI summary The document discusses NSPI's performance of diesel-fired combustion turbines, noting that their availability factors exceeded industry averages, while DAFORs were below average in 2024 but improved in 2025. It also recommends NSPI provide an estimate of the incremental FAM costs from an outage.
X.D. Recommendations Recommendation X-1: NSPI should provide the Board an update on the status of the remaining 27 recommendations from the Root Cause Analyses at the end of 2026. Recommendation X-2: NSPI should provide its estimate of the...
AI summary The recommendations focus on NSPI providing updates and cost estimates related to forced outages and compliance costs. Key topics include FAM costs, forced outages at various facilities, and reconciliation of OBPS compliance costs.
of Wreck Cove, PH Paper's demand, the PT Biomass unit, generator operational issues, changes in wind generation, transmission constraints, system interchange, and natural gas burn, among other things. In summary, the Day Ahead schedule is...
AI summary The Day Ahead and Intra-Day scheduling processes are used to manage the electricity system, with the Day Ahead schedule applying for 24 hours or 72 hours on weekends. Real-time dispatch uses tools like RTED and SCADA/EMS, with units on AGC dispatched automatically and others manually. The process prioritizes reliability but may result in inefficiencies due to disjointed optimization and manual adjustments.
XI.B.2.a. Dispatch Tracking – Exceptional Dispatch NSPI uses a protocol for applying manual adjustments to PortOps schedules and documenting these decisions that are made outside of the PortOps software.552 The protocol is used to manually...
AI summary NSPI uses a protocol for manual adjustments to PortOps schedules during exceptional dispatch events, which occur when inputs cannot be precisely quantified or modelled. These adjustments are documented in Shift Reports and are used to address deviations in generator availability, wind, load, and system security. The audit period saw exceptional dispatch due to PortOps being non-operational and a cyber incident affecting records.
XI.B.2.c. Summary We find, like we have found in prior audits, that numerous commitment and dispatch decisions are made outside of PortOps. Many of those decisions are based on experience and knowledge of the marketing desks and NSPSO. For...
AI summary The summary highlights that many commitment and dispatch decisions are made outside of PortOps, often by NSPSO in real time without sufficient cost information. These decisions are influenced by factors like fuel supply and unit restartability. NSPI committed to addressing these issues through the Economic Dispatch Optimization Solution.
system to replace lost generation or accommodate increased generation, to maintain reserves, to balance the gas position, to accommodate energy trading, or to respond to other real-time system needs. During the audit period, Wreck Cove uni...
AI summary Wreck Cove units were frequently out of service during the audit period due to the Life Extension and Modernization Project, impacting real-time dispatch capabilities. The NSPSO had to rely on less flexible coal and gas units when Wreck Cove was unavailable, leading to higher dispatch costs and reduced flexibility.
Figure XI-7: Operating Intervals during Audit Period, Lingan 2 Event No. Start Date End Date Number of Days Net Generation (MWh) 1 1/23/24 6:00 PM 2/1/24 1:00 AM 8 21,631 2 2/6/24 8:00 PM 2/14/24 1:00 AM 7 16,765 3 2/21/24 3:00 AM 2/28/24...
AI summary Figure XI-7 presents the operating intervals of Lingan 2 during the audit period, showing the start and end dates, number of days, and net generation for each event. Lingan 2 was used more heavily than in the prior audit period due to large supply deficiencies, with system margins ranging between 80 MW and 275 MW. It was dispatched economically through the PortOps model or Plexos during different periods.
erve on mainland Nova Scotia, or imported energy may become the largest possible contingency, requiring additional ten-minute reserve. In these cases, NSPI will hold reserves above the 168 MW minimum. Energy and operating reserves (10-minu...
AI summary The document discusses the management of energy and operating reserves in Nova Scotia, including the impact of a cyber event on data availability for 2024 and early 2025. It highlights that reserve deficiencies occurred in 42 hours for 10-minute reserves and 23 hours for 30-minute reserves during the available data period.
Figure XI-14: Number of Hours with Reserve Deficiencies, 2020-2025575 Year 10-Minute Reserve Deficiencies 30-Minute Reserve Deficiencies 2020 4 76 2021 49 222 2022 121 1,410 2023 56 883 2024 Data unavailable due to the cyber incident 2025...
AI summary Figure XI-14 presents the number of hours with reserve deficiencies from 2020 to 2025, showing a significant increase in both 10-minute and 30-minute deficiencies over the years. Data for 2024 is unavailable due to a cyber incident. Figure XI-15 indicates that the most frequent range of hourly operating reserves was between 218 MW and 400 MW above the minimum requirement.
XI.B.10.a. Unit Loading Levels and Start-up Costs NSPI's coal and gas-fired units achieve their lowest average cost when operated near maximum output. Operating fewer units at higher levels, when possible, can reduce costs to FAM customers...
AI summary NSPI's coal and gas-fired units operate most efficiently at maximum output. However, capacity factors for some units have decreased, potentially indicating inefficiencies. Data glitches were identified during the audit period, and the use of the new Economic Dispatch Optimization Solution may improve efficiency.
XI.C. Conclusions Conclusion XI-1: NSPI, to its credit, was able to keep its system running reliably through the period following the cyber event. However, the loss of automation and information required for scheduling and dispatch would h...
AI summary The document highlights NSPI's ability to maintain system reliability post-cyber event but notes inefficiencies and increased costs due to lost automation. It identifies issues with scheduling processes, RTED functionality, and dispatch of PH Biomass. There are concerns about understated system marginal costs and increased GHG emissions. A new Economic Dispatch Optimization Solution is expected to address some inefficiencies.
XII.B.1.c.i.2. Reliability Imports In our review of import transaction samples, we noted days during the Audit Period when NSPI imported energy for system reliability purposes. As NSPI has explained to us in the past, all reliability impor...
AI summary During the audit period, NSPI imported energy for system reliability, with transactions sourced from New Brunswick, ISO New England, and Newfoundland and Labrador. The highest-priced reliability import occurred in Allegro at $ /MWh, though the transaction ultimately saved USD $ due to system conditions and real-time pricing.
to those of the previous period, import volume is 6% higher than the previous Audit Period. This is the result of deliveries of larger amounts of Muskrat Falls energy delivered via the Maritime Link. Conclusion XII-7: NSPI was a net import...
AI summary The text discusses NSPI's power import activities, including increased imports from Muskrat Falls via the Maritime Link, reliability-based imports, and the resolution of undelivered energy balances. NSPI's actions were deemed reasonable despite high import prices, and underdeliveries were minimal after reaching zero undelivered volumes for Base and Supplemental Blocks.
XV.B.1. Implementation of the ELIADC There are several important features of the ELIADC that relate to active demand control and pricing: - PHP's load is incorporated within PortOps during the Day Ahead and Intra Day schedule creation and...
AI summary The ELIADC (Extra Large Industrial Active Demand Control Tariff) incorporates PHP's load into PortOps for scheduling and optimization, with fixed rate payments based on forecasted costs. Due to the 2025 cyber incident, PortOps was unavailable for a period, leading to manual scheduling using PLEXOS and impacting real-time schedules until August 2025.
s load without triggering a "deviation." Figure XV-6 shows a plot of PHP loading levels within OM 4 during the audit period. This high level of load variation is found within all OM levels except OM1. Figure XV-7 below shows the number of...
AI summary The document discusses the operation and scheduling of PHP load within different operating modes (OMs) during 2024 and 2025, highlighting variations between actual and scheduled loads. It also emphasizes the importance of pulp storage levels at the mill in determining PHP load dispatch, as storage capacity affects the ability to operate at high load.
XV.B.4.b. The Number of PHP Deviations from Schedule During the audit period, we identified hours with a deviation from schedule when in the same hour NSPI did not. Also, we identified hours in which we found no deviation but NSPI did find...
AI summary The audit identified discrepancies in the number of PHP deviations from schedule compared to NSPI's findings, attributed to ramping issues and measurement problems. It recommends hourly identification of deviations for consistency with independent system operators. Cause Code 3 (PFL) and 5 (PDN) deviations show varying trends over the 2020-2025 period, with PNA deviations doubling between 2023 and 2024. In 2025, deviations were not tracked during a cyber event.
Measurement - (a) PHP's final intra-day schedule is indicative of the OM level, but does not necessarily represent the actual load level at which PHP is operating. For example, the final intra-day schedule may be MW placing PHP in OM-8, bu...
AI summary The text discusses discrepancies in measuring PHP's real-time deviations from its intra-day schedule, noting that NSPI's method may not align with actual load levels due to variability in operating points and SCADA metering tolerances. It recommends measuring deviations on an hourly basis for consistency with independent system operators' methods.