CTOTF NERC Reliability Standards Presentation

8/7/2019 CTOTF NERC Reliability Standards Presentation

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Combustion TurbineOperations Task Force (CTOTF)

NERC Overview &

generation ProtectionSystem Presentation

April 14, 2011John PasierbSenior Project ManagerTransmission Services

[email protected]


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Reliability Standards

June 18, 2007

Mandatory Enforceable

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Electric Reliability Authority

Congress Energy Policy Act of 2005

FERC

Establishes ERO

NERC

Drafts Policy

Regional Entities

Enforces Policy

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Reliability Prior toJune 18, 2007

NERC Standardswere goodindustry practice

NERC Standardswere notmandatory

NERC Standardswere notenforceable

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Reliability After June 18, 2007

Mandatory Compliance Mandatory compliance with

Electric ReliabilityOrganization (ERO)Standards

Applicability Standards apply to 15

functional entity types

Standards apply to "users,owners, and operators of the

Bulk Power System."

Regulatory Actions

Allowed penalty actions byRE, ERO, or FERC:

Monetary fines

Non-monetary sanctions

Operational restrictions

Due Process

Due process at the ERO, thenFERC

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Bulk Power System

NERC Rules of Procedure considerthe bulk power system to include:

Electrical generation resources Transmission lines

Interconnections with neighboring systems

Associated equipment

Generally operated 100 kV

With the catch:

if the consequences of an entity's actionsor inactions could have a material impacton the bulk power system, that entity maybe considered a user of the bulk powersystem."

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Registration & ComplianceResponsibilities

Registration:

Delegated toRegions

Enforcement:

Delegated toRegions

NERC Registration:

Maintain currentregistry of entitiesand functions

Enforcement:

Analyze AllegedViolations

Regions Registration:

Maintain accurateregistration withregion

Enforcement:

Develop InternalComplianceProgram

Entities

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NERC Basis for Registration

Users, Owners and Operators of:

Transmission

Voltage>100 kV

(Typically)

Generation

SingleGenerator 20

MVA

AggregateGeneration75 MVA

Distribution

Connected tothe Bulk Power

System

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NERC Regional Entities

WECC SPP SERC

TRE FRCC MRO

RFC NPCC

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NERC Reliability Standards

Compliance Monitoring & Enforcement

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Compliance Monitoring

Audit Spot Check

Self Certification

Periodic Data

Submittal May Applyto Some Standards

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Handling Violations

Violation Discovery

Flaw in compliance found and reported

Mitigation Plan

Implementing changes to prevent reoccurrence

Penalties and Settlements

Different tracks for resolution of violation

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Violation Discovery

Auditor discovers non-compliance eventAudit

Potentially similar scenario to an Audit

Regional Entity can make a Data Request

Self CertificationSpot Check

Company discovers non-compliance during preparation forSelf-Certification

SelfCertification

Company discovers non-compliance and files report outsidethe above eventsSelf Report

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Mitigation Plans

Development Agreed and approved by

Regional Entity

Required Must be made for each

Standard violated

Milestones

Must have milestone and

conclusion dates

Schedule

Must remain on schedule,

additional penalties maybe assessed for misseddeadlines

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Penalties and Settlements

Typically results in lower penalties

Perform beyond base requirements to enhancereliability

May include training, awareness programs or ICP

Settlements

Formal penalty process

May include hearings Typically assessed greater penalties

Violation

Process

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Penalty Determination

Mitigating Factors

Good Internal Compliance Program

Cooperation with Regional Entity

Timely completing the Mitigation

Plan

Aggravating Factors

Intentionally violating the Standards

Misleading Regional Entity

Not completing the Mitigation Planon time

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Base Penalty Amounts

Low High Low High Low High Low High

Lower $1,000 $3,000 $2,000 $7,500 $3,000 $15,000 $5,000 $25,000

Medium $2,000 $30,000 $4,000 $100,000 $6,000 $200,000 $10,000 $335,000

High $4,000 $125,000 $8,000 $300,000 $12,000 $625,000 $20,000 $1,000,000

Violation

RiskFactor

High Severe

Violation Severity Level

Range Limits Range Limits Range Limits Range Limits

Lower Moderate

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NERC Standards in 2011

Number of Reliability Standards

Year 2007 2008 2009 2010 2011

Compliance Audit 39 60 49 56 38

Self-Certification 39 60 52 60 51

Periodic Data Submittals -- -- 12 13 14

Exception Reporting -- -- 14 19 13

Spot Check 0 0 13 19 14

Subject to ComplianceViolation Investigation -- -- 94 95 102

Subject to Self-Reporting -- -- 94 95 102

Subject to Complaint -- -- 94 95 102

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NERC Reliability Standard PRC-005

Maintenance and Testing of

generation Protection Systems

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Defining generation ProtectionSystems

Protection System Components

ProtectiveRelays

AssociatedCommunication

Systems

Voltage andCurrent Sensing

Devices

StationBatteries

DC ControlCircuitry

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Maintenance and Testing: ProgramSpecification

Can be any reasonable period

Must include maintenance and testing periodsInterval

Why you chose the interval

Must be defendable

Usually rooted in a National Standard (IEEE, ANSI)

NERC and Regional Entities frown upon Good Utility PracticeBasis

List of maintenance tasks to be performed

List of testing to be performed

Not an exhaustive list, enough to provide an auditor withgeneral idea of what is being performed

Summary

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Maintenance and Testing:Program Data Collection

Evidence when last maintained

Evidence when last tested

Must match intervals described in Requirement 1.1Intervals

When was the last maintenance performed

When was the last testing performedDates

Test reports

Maintenance sheets, logbooks, etc.

Anything showing the task was performed and documentedEvidence

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generation Protection SystemDocumentation

Provide Maintenance and TestingProgram To the Regional Entity andNERC on request

Program

Must show that the Programdeveloped has been implementedImplementation

Must provide to the Regional Entityand/or NERC within 30 calendar daysof request

Fulfillment

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So Why is the g in generationProtection System Lowercase?

So what makes up a gPS?

Varies between RegionalEntities

but typically includes

Capitalized letters indicate a NERC defined term in the NERCGlossary of Terms

Protection System is defined inNERC Glossary of Terms

but generation ProtectionSystem (gPS) is not.

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Typical gPS Components

GeneratorLockout Relays

Unit LockoutRelays

Direct Trip ofGenerator

Circuit Breaker

Overcurrent

Loss of

Excitation orField Failure

Underfrequency

orOverfrequency

BackupDistance

Volts per Hertz Over ExcitationField

OvercurrentField Ground

Generator orUnit Differential

GSU Differential Stator Ground Out of step

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Where do we go wrong?

It does still happenNo Program

Identification is a difficult task becauseguidance is marginal

Incomplete gPSIdentification

Especially common with maintenance

records Record keeping becomes a big issue

InsufficientDocumentation

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Failed to test or maintain within theintervals established by your own plan

MissedTesting or

Maintenance

New or removed items are not removedfrom the device listing

Causes items either to be missed orappear to have missed testing

Inventory is

Out-of-Date

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Good utility practice just doesnt cut it anymoreInsufficient

Interval Basis

Summary maintenance on equipment; may include:

Check tightness of connections

Burnish contacts

Verify LEDs

NoMaintenanceProcedureSummary

Similar to Maintenance Summary. May include: Apply appropriate current and voltages at proper phase angles

Verify ratio by voltage or current methodology

Power factor

No TestingProcedureSummary

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PRC-005 Violations by Region

53 56

31

112 110

57

30

208

0

50

100

150

200

250

FRCC MRO NPCC RFC SERC SPP TRE WECC

Adapted from http://www.nerc.com/files/March%202011%20Workshop_Day%20Three%20Presentations.pdfData current as of March 1, 2011

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http://www.nerc.com/files/March%202011%20Workshop_Day%20Three%20Presentations.pdfhttp://www.nerc.com/files/March%202011%20Workshop_Day%20Three%20Presentations.pdf


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PRC-005 Violations byEntity Type

TO84 Violations

13% DP74 Violations

11%

MultipleFunctions

181_Violations

28%

GO319 Violations

48%


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PRC-005 Violations byDiscovery Type

Self Report323 Violations

49%

Spot Check23 Violations

3%

Audit208 Violations

32%

Investigation6 Violations

1%

Self Certification98 Violations15%


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PRC-005 Violations are MostCommon

0

100

200

300

400

500

600

700

Adapted from http://www.nerc.com/files/Feb%20Public%20Posting%20Statistics.pdfData current as of February 28, 2011

PRC

CIP

FAC

VAR

EOP

Other

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http://www.nerc.com/files/Feb%20Public%20Posting%20Statistics.pdfhttp://www.nerc.com/files/Feb%20Public%20Posting%20Statistics.pdf


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NERC Reliability Standard PRC-005

Avoiding Violations:

Best Practices & Common Pitfalls

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Know Your Protection Systems

Protection Systems

Batteries Communications DC Circuitry Instrument Transformers

CTs

CCVTs

PTs

CVTs

Linear Couplers

ProtectiveRelays

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Keep Meticulous Records

Develop checklists for maintenance items

Allows for documentation of the task ascompleted

Checklists

Have a robust database for recordkeeping

Possibly look to 3rd party vendors if internalexpertise is not available

Database

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Know Your Intervals

Intervals include maintenance and testing

Have a grace period for your interval

Use a good basis for your interval and foryour grace period

Good utility practice does not cut it anymore;use an authoritative source

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Inventories and Summaries

Keep your generation Protection Systemuniverse up to date:

Remove or notate retired equipment

Make sure new equipment is added right away

Inventory

Have a good summaries of maintenance andtesting procedures

Include details sufficient to address concerns of anAuditor

Dont include every single detail

Summaries

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And in General

Perform a self assessment of all Standardsapplicable to your registration type

Suggest an annual review

Self report any possible violations you find

Acts as a mitigating factor in penalty determination

Self-Assess

Look into developing an Internal ComplianceProgram

Auditors are reviewing entities responses to the FERC

13 questions This is also a mitigating factorICP

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As always, live, breathe and

exude a culture of compliance

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Documents

CTOTF NERC Reliability Standards Presentation