WECC Compliance Open Web Thursday, November 20, 2014 W E C C E - - PowerPoint PPT Presentation

WECC Compliance Open Web

Thursday, November 20, 2014

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Agenda

• Internal Compliance Program Assessment 2015

and 2015 Implementation Plan – Duane Cooke

• EOP-010 - Michele Mizumori, Peak Reliability
• SOL Exceedances - Phil O’Donnell

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2015 ICPA and CMEP IP Updates

Duane Cooke Compliance Analyst November 20, 2014

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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

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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

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2015 CMEP IP Update

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Risk-based Compliance Oversight Framework

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)

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Questions?

Duane Cooke Compliance Analyst Western Electricity Coordinating Council dcooke@wecc.biz 801-819-7639

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Michelle Mizumori Operations Director

RC GMD Operating Plan November 20, 2014

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• 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.

NERC Standard EOP-010-1

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• 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

NERC Standard EOP-010-1

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• Description of activities to mitigate the effects
• f GMD events on the reliable operation of

the BES within the RC Area

• Activities dependent on SWPC GMD Watch,

Warning or Alert

• Potential activity list sent to TOPs on Nov 1,

2014

RC GMD Operating Plan

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RC GMD Operating Plan

RCSO Actions

Situational Awareness Safe System Posturing (if supported by study) System Reconfiguration (if supported by study) GMD Watches (G scale ≥ 3) 1-3 days in advance

• f potential storm

Issue a GMD Watch reliability message to RC Area TOPs Prepare for return of outage equipment to service (especially series capacitors) Request applicable entities review their GMD Operating Procedures or Operating Processes Prepare for delay of planned outages Assess readiness of black start generators and cranking paths Prepare for removal of shunt reactors GMD Warnings (K index≥7 or G scale≥3) day of event, hours in advance of imminent storm Issue a GMD Warning reliability message to RC Area TOPs Coordinate with entities to enter conservative

• perations with possible

reduced transfer limits Coordinate with applicable entities to implement their GMD Operating Procedures

• r Operating

Processes Coordinate with entities to ensure series capacitors are in-service Monitor Reactive Reserves Monitor for unusual voltage or MVAR swings Prepare for unplanned capacitor bank, SVC

• r HVDC tripping

Prepare for possible false SCADA (ICCP) indications if telecommunications systems are disrupted GMD Alerts (K index≥7 or G scale≥3) real-time conditions during storm Issue a GMD Alert reliability message to TOPs in the RC Area Coordinate with entities for selective load shedding Coordinate with entity to remove transformer(s) from service if in danger of imminent damage due to

• verheating

Coordinate with applicable entities to implement their GMD Operating Procedures

• r Operating

Processes Coordinate with entity on increasing thermal margins

• n selected transformers

(starting fans and pumps) Coordinate with entity to remove lines from service Request entities to report unusual

• perating conditions in

real-time attributed to the GMD to the RCSO Request entities to report any mitigating actions taken due to the GMD to the RCSO Return to Normal Operations Typically TOPs should return to normal operation two to four hours after the last

• bserved geomagnetic activity

F o r i l l u s t r a t i v e p u r p o s e s o n l y

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• Process to review TOP GMD Operating

Procedures

• Review focused on coordinating TOPs

procedures will be done within 30 days

• TOPs will receive an email letter from the RC

that the review is complete or that conflicts have been discovered.

• If conflicts are discovered, RC will coordinate

with affected TOPs to resolve issues

RC GMD Operating Plan

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• Process to review TOP GMD Operating

Procedures

• Applicable TOPs are required to have an RC

reviewed GMD Operating Procedure by April 1, 2015.

• Peaks Operating Plan requests a 30 day review

period.

• Goal is to have the TOP GMD Operating

Procedures to Peak by March 1, 2015.

EOP-010-1 Timing Issue

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• 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.

RC GMD Notifications

System Operating Limits & Coordination with RC

Phil O’Donnell, Manager of Operations and Planning Audits

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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

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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.

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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.

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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.

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System Operating Limits (SOL)

• Determined by TOP per FAC-014 but…
• Must be in accordance with RC SOL

Methodology

• SOL’s must satisfy real time actual limitations

AND must provide for satisfactory BES performance following contingencies.

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RC SOL Methodology

Please review: Appendix II Acceptable Thermal Performance Example

https://www.peakrc.com/SOLDocs/Peak%20RC %20SOL%20Methodology%20for%20the%20Op erations%20Horizon%20v7.0.pdf

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Exceedance vs Violation

• TOP Standards use term “SOL Violation”
• Some IRO Standards and Peak RC

Methodology use term “SOL Exceedance”

• These terms should be considered

interchangeable.

• “SOL Violation” does not directly translate to

“Compliance Violation”

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Key SOL Standards

TOP-002-2.1b

• R6. Each Balancing Authority and Transmission

Operator shall plan to meet unscheduled changes in system configuration and generation dispatch (at a minimum N-1 Contingency planning) in accordance with NERC, Regional Reliability Organization, subregional, and local reliability requirements.

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Key SOL Standards

• TOP-004-2 R1
• Each Transmission Operator shall operate

within the Interconnection Reliability Operating Limits (IROLs) and System Operating Limits (SOLs).

• Notice there is no “grace period” or Allowed

Time limit specified in the requirement.

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Key SOL Standards

• TOP-006-2 R5
• Each Reliability Coordinator, Transmission

Operator, and Balancing Authority shall use monitoring equipment to bring to the attention of operating personnel important deviations in operating conditions and to indicate, if appropriate, the need for corrective action.

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Key SOL Standards

• TOP-008-1 R1
• The Transmission Operator experiencing or

contributing to an IROL or SOL violation shall take immediate steps to relieve the condition, which may include shedding firm load.

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Key SOL Standards

• TOP-008-1 R2
• Each Transmission Operator shall operate to

prevent the likelihood that a disturbance, action,

• r inaction will result in an IROL or SOL violation

in its area or another area of the Interconnection. In instances where there is a difference in derived

• perating limits, the Transmission Operator shall

always operate the Bulk Electric System to the most limiting parameter.

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Key SOL Standards

• TOP-008-1 R4
• The Transmission Operator shall have

sufficient information and analysis tools to determine the cause(s) of SOL violations. This analysis shall be conducted in all operating

• timeframes. The Transmission Operator shall

use the results of these analyses to immediately mitigate the SOL violation.

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How does the RC define SOL exceedance?

• Actual flow is above the continuous Facility Rating.
• Actual flow on a Facility is higher than the continuous

Facility Rating.

• Actual flow on a Facility or grouping of monitored

Facilities is over the transient or voltage stability limit. RTCA indicates that post-Contingency flow on a Facility is higher than the highest available Facility Rating.

• Voltage at a bus is outside the TOP-defined pre-

contingency voltage limits.

• Post-contingency flow is above the highest available

Facility Rating.

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Contact Information

Phil O’Donnell, Manager Operations and Planning Audits podonnell@wecc.biz

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Phil O’Donnell podonnell@wecc.biz

Upcoming Events

• TFE module update trainings
• WECC Compliance Open Webinar – December 18, 2014
• WECC Compliance 101 Webinar – January 15, 2015
• WECC CUG/CIPUG Meetings, Anaheim, CA –

– January 27 – 29, 2015

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