WECC Compliance Open Web Thursday, November 20, 2014 W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
2 Agenda • Internal Compliance Program Assessment 2015 and 2015 Implementation Plan – Duane Cooke • EOP-010 - Michele Mizumori, Peak Reliability • SOL Exceedances - Phil O’Donnell W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
2015 ICPA and CMEP IP Updates Duane Cooke Compliance Analyst November 20, 2014 W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
4 2015 ICPA Update • Key Modifications to 2015 Internal Compliance Program Assessment (ICPA) Document (v5): – Expanded Appendix B – Selected example ICP practices • 2015 ICPA Timeline: – Mid-December 2014 – Introductory email message to U.S. entities – February 2, 2015 – Email message with ICPA letter and version 5 document attached – April 1 – May 1, 2015 ICPA submittal period W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
5 2015 CMEP IP Update • 2015 ERO Compliance Monitoring and Enforcement Implementation Plan (CMEP IP) – Historic approach: • Specified Reliability Standards and Requirements to be actively monitored by the Regions • Actively Monitored List (AML) – New approach: • Risk Based – Focus on identifying and prioritizing risks • Reliability Assurance Initiative (RAI) • Risk Elements and Associated Reliability Standard Requirements • Inherent Risk Assessment (IRA) • Internal Controls Evaluation (ICE) – Voluntary • Note: Still have basic list of Standard Requirements subject to monitoring by Regions W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
6 2015 CMEP IP Update Risk-based Compliance Oversight Framework W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
7 2015 CMEP IP Update • 2015 WECC CMEP IP (2015 ERO CMEP IP Appendix A8) • Highlights: – WECC Regional risk focus areas and associated Reliability Standard Requirements – Compliance Oversight Plan • Compliance Audits, Annual Self-Certification, Periodic Data Submittal (PDS) • Reliability Standards Subject to WECC Monitoring - 2015 – Summary of Standard Requirements listed in 2015 WECC CMEP IP (similar format to prior AML document) W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
8 Questions? Duane Cooke Compliance Analyst Western Electricity Coordinating Council dcooke@wecc.biz 801-819-7639 W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
RC GMD Operating Plan November 20, 2014 Michelle Mizumori Operations Director
NERC Standard EOP-010-1 • RC Requirements • R1. Each Reliability Coordinator shall develop, maintain, and implement a GMD Operating Plan that coordinates GMD Operating Procedures or Operating Processes within its Reliability Coordinator Area. At a minimum, the GMD Operating Plan shall include: • 1.1 A description of activities designed to mitigate the effects of GMD events on the reliable operation of the interconnected transmission system within the Reliability Coordinator Area. • 1.2 A process for the Reliability Coordinator to review the GMD Operating Procedures or Operating Processes of Transmission Operators within its Reliability Coordinator Area. 2
NERC Standard EOP-010-1 • RC Responsibilities continued • R2. Each Reliability Coordinator shall disseminate forecasted and current space weather information to functional entities identified as recipients in the Reliability Coordinator's GMD Operating Plan. • Note: R2 not effective until the day following the retirement of IRO-005-3.1a 3
RC GMD Operating Plan • Description of activities to mitigate the effects of GMD events on the reliable operation of the BES within the RC Area o Activities dependent on SWPC GMD Watch, Warning or Alert o Potential activity list sent to TOPs on Nov 1, 2014 4
RC GMD Operating Plan RCSO Actions Situational Safe System Posturing System Reconfiguration Awareness (if supported by study) (if supported by study) SWPC Level Prepare for return of outage Issue a GMD Watch equipment to service reliability message to (especially series RC Area TOPs capacitors) GMD Watches Request applicable (G scale ≥ 3) entities review their Prepare for delay of GMD Operating 1-3 days in advance planned outages Procedures or of potential storm Operating Processes Assess readiness of Prepare for removal of black start generators shunt reactors and cranking paths Coordinate with entities to Issue a GMD Warning enter conservative reliability message to operations with possible RC Area TOPs reduced transfer limits Coordinate with applicable entities to Coordinate with entities to implement their GMD ensure series capacitors Operating Procedures are in-service or Operating GMD Warnings (K index≥7 or G Processes scale≥3) Monitor Reactive F o r i l l u s t r a t i v e Reserves day of event, hours Monitor for unusual in advance of voltage or MVAR imminent storm p u r p o s e s o n l y swings Prepare for unplanned capacitor bank, SVC or HVDC tripping Prepare for possible false SCADA (ICCP) indications if telecommunications systems are disrupted Coordinate with entity to Issue a GMD Alert remove transformer(s) from Coordinate with entities for service if in danger of reliability message to selective load shedding TOPs in the RC Area imminent damage due to overheating Coordinate with applicable entities to Coordinate with entity on GMD Alerts implement their GMD increasing thermal margins Coordinate with entity to (K index≥7 or G Operating Procedures on selected transformers remove lines from service scale≥3) or Operating (starting fans and pumps) Processes real-time conditions Request entities to during storm report unusual operating conditions in real-time attributed to the GMD to the RCSO Request entities to report any mitigating actions taken due to 5 the GMD to the RCSO Return to Normal Typically TOPs should return to normal operation two to four hours after the last Operations observed geomagnetic activity
RC GMD Operating Plan • Process to review TOP GMD Operating Procedures o Review focused on coordinating TOPs procedures will be done within 30 days o TOPs will receive an email letter from the RC that the review is complete or that conflicts have been discovered. o If conflicts are discovered, RC will coordinate with affected TOPs to resolve issues 6
EOP-010-1 Timing Issue • Process to review TOP GMD Operating Procedures o Applicable TOPs are required to have an RC reviewed GMD Operating Procedure by April 1, 2015. o Peaks Operating Plan requests a 30 day review period. o Goal is to have the TOP GMD Operating Procedures to Peak by March 1, 2015. 7
RC GMD Notifications • Reliability Message (currently WECCNet) • GMD Watches, Warnings, Alerts and Event Termination • Although not enforceable until retirement of IRO-005-3.1a, Peak currently disseminates this information. 8
System Operating Limits & Coordination with RC Phil O’Donnell, Manager of Operations and Planning Audits W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
2 Peak RC and Compliance Interface • Hold meetings from time to time in the interest of Western Interconnection Reliability. • Names of entities are not shared during these meetings. • Trends and Concerns are communicated W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
3 Concern over operation within SOL’s Issue: • RC has identified situations where it believes system is being operated in a manner in which post contingency BES performance may not be met. • RC has communicated this information and concern to TOP’s and TOPs have asked RC to issue a directive if they desire TOP to take corrective action. W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
4 TOP-001-1a R1 • Each Transmission Operator shall have the responsibility and clear decision-making authority to take whatever actions are needed to ensure the reliability of its area and shall exercise specific authority to alleviate operating emergencies. • TOP’s requesting directives to take actions to ensure reliability is directly contrary to this requirement. W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
5 Expectations • Disagreements are inevitable in some conditions. – Differences in modeling, mitigation systems or procedures • Directives should not be considered a means to shift responsibility for actions. W E C C E S T E R N L E C T R I C I T Y O O R D I N A T I N G O U N C I L
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