ReliabilityFirst 3/6/08 RC Meeting 1 Reliability Standards Update ReliabilityFirst Corporation RFC Compliance Workshop Columbus, Ohio September 29 & 30, 2008 Presented By: Bob Millard
Jan 11, 2016
ReliabilityFirst 3/6/08 RC Meeting 1
Reliability Standards Update
ReliabilityFirst Corporation
RFC Compliance Workshop
Columbus, Ohio
September 29 & 30, 2008
Presented By: Bob Millard
ReliabilityFirst 3/6/08 RC Meeting 2
What’s Up at the Board
The following will be discussed at the RFC Board meeting in Chicago 10/8/08
• Automatic Reserve Sharing (BAL-501-RFC-01)
– Day One standard approved 12/12/05
– SAR stated “standard” no longer needed for reliability
– Map to RTO documents showed complete overlap
– Unanimous vote to retirement
ReliabilityFirst 3/6/08 RC Meeting 3
What’s Up at the Board
• Operating Reserve (BAL-002-RFC-02)
– Day One standard approved 12/12/05 & revised 5/9/07
– Establish optional methodology per NERC BAL-002
– Submitted for NERC/FERC approval process
– NERC comments focused on % of spinning fulfilled by interruptible
– Recommend reclassify as regional CRITERION until NERC makes a final decision on whether revised BAL-002 needs support by regional standard
ReliabilityFirst 3/6/08 RC Meeting 4
What’s Up at the Board
• Disturbance Monitoring (PRC-002-RFC-01)
– Regional standard support shown in NERC Standards Work Plan
– Referenced in NERC Board approved PRC-002 (a Fill-in-the-Blank standard)
– Referenced in FERC approved PRC-018
– Used as a starting point by NERC drafting team
– NERC 1st draft still to be posted
– RFC standard will replace legacy documents
ReliabilityFirst 3/6/08 RC Meeting 5
What’s Up at the Board
• Disturbance Monitoring (continued)
– Did not pass 1st or 2nd ballot after 7 comment postings
– Major issue: Joint responsibility (TO and GO) for DME installations at generating facility interface
– Drafting team proposes to have RFC Board remand back to team to remedy major issue
– Drafting team remedy - monitoring provided by owner of monitored equipment (arrangements can still be made as to who owns DME)
– Informal survey by team suggests additional posting and ballot would be successful
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RFC Standards
• Resource Adequacy (BAL-502-RFC-02)
– Day Two standard approved by RFC Board 3/9/06
– ACTION PLAN to revise standard approved by RFC Board 8/9/07
• Based on legal advise
– Remove enforcement of requirement to secure resources
– Limit enforcement to reserve requirement analysis and assignment
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RFC Standards
• Resource Adequacy (continued)
– ACTION PLAN included:
• Addition of significant improvements from RFC experience & MRO development through MRO Board approval
• Modifications to conform to current RFC Standards Procedure (such as Violation Risk Factors)
– Supplemental SAR approved after 1st comment posting of proposed revision to revise applicability
ReliabilityFirst 3/6/08 RC Meeting 8
RFC Standards
• Resource Adequacy (continued)
– 2nd comment posting completed 9/16/08 and included:
• Removal of reference to LSE or PRSG due to removal of enforcement of securing reserves
• Addition of PC to reflect new focus of standard toward analysis
– Revised standard ready for balloting and preparation for action by RFC Board at December meeting
ReliabilityFirst 3/6/08 RC Meeting 9
RFC Standards
• Gen MW verification (MOD-024-RFC-01)
– Based on 3/10/06 SAR by Day Two team
– Replace legacy documents per intent of By-laws
– Comply with NERC “fill-in-the-blank” NERC MOD-024-1
– FERC confirmed “warrant continued monitoring”
– Provide verification for “planning reserve” analysis
– NERC drafting underway but no posting yet
– Fill gap until NERC complete (possible 2 years)
– Used as starting point for NERC drafting team
ReliabilityFirst 3/6/08 RC Meeting 10
RFC Standards
• Gen MW verification (continued)
– 4th comment posting completed 9/11/08
– Major applicability issue removed by defaulting to unit size values specifically listed in NERC Compliance Registry Guidelines
– SDT reviewing comments to determine next move
– Comments now range from “requirements are too detailed” to “not detailed enough”
– ULTIMATELY when NERC standard is approved, RFC requirements will be retired or become a variance in the NERC standard
ReliabilityFirst 3/6/08 RC Meeting 11
RFC Standards
• Gen MVAR verification (MOD-025-RFC-01)
– Based on 3/10/06 SAR by Day Two team
– Replace legacy documents per intent of By-laws
– Comply with NERC “fill-in-the-blank” NERC MOD-025-1
– FERC confirmed “warrant continued monitoring”
– NERC drafting underway but no posting yet (scheduled behind NERC MOD-024-1)
– Fill gap until NERC complete ( 2+ years)
– Used as a starting point by the NERC drafting team
ReliabilityFirst 3/6/08 RC Meeting 12
RFC Standards
• Gen MVAR verification (continued)
– 2nd comment posting completed 8/31/08
– Variety of comments reflect the technical complexity of the standard
– SDT reviewing comments to determine next move
– ULTIMATELY when NERC standard is approved, RFC requirements will be retired or become a variance in the NERC standard
ReliabilityFirst 3/6/08 RC Meeting 13
RFC Standards
• Under Frequency Load Shed (PRC-006-RFC-01)
– RFC Board approved Day Two standard rescinded early 2006 due to generator requirement ambiguity carried over from legacy documents
– Day Two 2/10/06 SAR initiated drafting
– Replace legacy documents per intent of By-laws
– Comply with NERC “fill-in-the-blank” NERC PRC-006-1
– FERC confirmed “warrant continued monitoring”
ReliabilityFirst 3/6/08 RC Meeting 14
RFC Standards
• Under Frequency Load Shed (continued)
– NERC initial comment posting completed 8/15/08 stated that regional standard was required
– RFC 4th comment posting ends 10/4/08
– Major issues addressed: Applicability goes beyond Compliance Registry Criteria and issues dealing with areas of credible islanding
– Direction of RFC draft agrees with NERC initial draft
ReliabilityFirst 3/6/08 RC Meeting 15
Waiting in the Wings
• RFC SARs & SDT in queue – Sub-Regional Transmission Adequacy
Requirements SAR
• Complements RFC Resource Adequacy standard
• Developed with initial Resource Adequacy effort
• Intended to provide some level of confidence that transmission will be available for delivery
• Considers probability of transmission outage
• Establishes deliverability criteria to achieve a transmission import capability level for each sub-region to achieve an acceptable reliability level
ReliabilityFirst 3/6/08 RC Meeting 16
Waiting in the Wings
• RFC SARs & SDT in queue (continued)
– Special Protection System Requirements SDT• In line with NERC “fill-in-the-blank”
NERC PRC-012-0• Regional standard support shown in NERC
Standards Work Plan
• RFC has approved “procedure” today
• Also considers need for conditions on installation and duration (already discussed by NERC TPL SDT for consideration in draft)
ReliabilityFirst 3/6/08 RC Meeting 17
Waiting in the Wings
• RFC SARs & SDT in queue (continued)
– Blackstart Capability Plan SAR
• Intended to detail and enhance the system Blackstart Capability Plan (BCP) requirements stated in the NERC EOP standards and RFC EOP-007-RFC-01
• NERC Project 2006-03 well underway covers EOP-005 — System Restoration Plans
EOP-006 — Reliability Coordination - System Restoration
EOP-007 — Establish, Maintain, and Document a Regional
Blackstart Capability Plan
EOP-009 — Documentation of Blackstart Generating Unit Test
Results
ReliabilityFirst 3/6/08 RC Meeting 18
Waiting in the Wings
• RFC SARs & SDT in queue (continued)
– Sub-Regional Transmission Adequacy Requirements SAR
• Wait for outcome of Resource Adequacy standard and consider RTO practices
– Special Protection System Requirements SDT
• Wait for TPL & NERC Project 2010-05 activity
– Blackstart Capability Plan SAR
• Since NERC posted 3rd draft Spring 2008, may need to delete & modify related RFC standard
ReliabilityFirst 3/6/08 RC Meeting 19
We continue to evolve
Questions ON RFC
“STANDARDS”?
Our Goal
RELIABILITY
ReliabilityFirst 3/6/08 RC Meeting 20
Outside RFC Standards
WHAT’S UP AT NERC?
WHAT’S FERC DOING?
WHO’S IN CHARGE?
WHAT DO I WATCH FOR?
CAN I MAKE A DIFFERENCE?
ReliabilityFirst 3/6/08 RC Meeting 21
Understanding Standards
Legal
Purist
Out of Box
Folksy
Gut feel
Comfort Zone
Operating Manual
Planning Standards
Version 0
Improvement
Functional Model
Reliable System Customer Needs
ReliabilityFirst 3/6/08 RC Meeting 22
Understanding the FM
• Functional Model concept
– Start from clean slate
– Develop a group of “functions” that are needed to make the overall system work
• Realize that there can be more than one set of functions that can work
• Divorce from corporate structure but make sure they will blend
– FM provided basis/guideline for Version 0
ReliabilityFirst 3/6/08 RC Meeting 23
Understanding the FM
• FM continues to evolve
• Version 4 completing approval process through Standing Committees and on to NERC Board
• Latest Version 4 as presented to Committees includes original proposed changes, i.e. LSE, DP, GOP, etc but fell back to “planning functions” as stated in Version 3
• “Planning functions” will be major focus of Version 5 for next Spring
• “Planning functions” did not blend with structure across continent
ReliabilityFirst 3/6/08 RC Meeting 24
Understanding Compliance Registry Guidelines
• Registry created to administer technically based requirements established for applicable entities as specified in the standards using the FM as a guide
• Registry created to inform entities who will be monitored from a practical stand-point
• Registry does not list monitored facilities – but criteria can be used as default or specified in standard based on technical need
• Registry criteria can be driven/changed by technical needs of standards
ReliabilityFirst 3/6/08 RC Meeting 25
Understanding Standards
SO NOW YOU KNOW
• Where the terms came from
• All the components there had to be considered in drafting
• How entities are earmarked for compliance initially
• And what you know today may change tomorrow
• This presents a real opportunity to test your understanding and flexibility
ReliabilityFirst 3/6/08 RC Meeting 26
What’s Up at NERC
• What is NERC’s GRAND SCHEME ?– Reliability Standards Development Plan
alias Three year (???) Work Plan: 2009-2011
– Updated annually
– Presented by usual e-mail, at Standing Committees, at Standards Workshop
– Presented by WEBEX
• 8/28/08 slides at NERC website under “About Standards: Development Plan”
– Industry comments and suggestions solicited for gaps, priorities, improvement, new items
ReliabilityFirst 3/6/08 RC Meeting 27
“Work Plan”
• What is NERC’s GRAND SCHEME ?
– Volume I: Overview
• Plan Description – high level list of “Projects”
• Modifications since last revision
• FERC 15 point review list for approving standards
• General information on the how, why & what of standards
• Industry comments that helped create latest version
ReliabilityFirst 3/6/08 RC Meeting 28
“Work Plan”
• What is NERC’s GRAND SCHEME ?
– Volume II: List of “Projects”
• Tabulation listing each standard and indicating what Project it is part of
• Tabulation listing each Project and indicating which standards are included
• A selection is allocated to each Project giving its description, status, schedule and issues to be considered
ReliabilityFirst 3/6/08 RC Meeting 29
“Work Plan”
• What is NERC’s GRAND SCHEME ?
– Volume III: Regional Reliability Standards Projects
• Identifies 4 NERC standards anticipated to be supported by regional standards
– Project 2007-01 — Underfrequency Load Shedding (PRC-006)
– Project 2007-05 — Balancing Authority Controls (BAL-002)
– Project 2007-11 — Disturbance Monitoring (PRC-002)
– Project 2010-05 — Protection Systems {SPS} (PRC-003)
ReliabilityFirst 3/6/08 RC Meeting 30
“Work Plan”
• What is NERC’s GRAND SCHEME ?
– Volume III: Regional Reliability Standards Projects
• Identifies, by region, the regional reliability standards being developed
• NOTE: The term “standard” means that the requirements being developed are expected to be submitted for the regional/NERC/FERC approval process to received enforcement under law
The term “criterion” means that the requirements only apply to members of the region or other contract agreed to membership
ReliabilityFirst 3/6/08 RC Meeting 31
“Work Plan”
• What is NERC’s GRAND SCHEME ?
– How can I find the latest status of any one Project knowing that there are 39 active teams working right now?
– NERC website under “Standards” then under “Standards Under Development”
– Dave Taylor, Manager of Standards, prepares a monthly XCEL worksheet “Project Summary” for the NERC Standards Committee
– Part of NERC SC minutes (soon to have separate link????)
ReliabilityFirst 3/6/08 RC Meeting 32
Voluntary to Mandate
• What’s FERC’s involvement ?– Another layer of approval and commenting has been
added.
– FERC approval process is fairly obvious & related to legal and ERO processes
– INDUSTRY PARTICIPANTS MUST BE WATCHFUL FOR COMMENTING ON FERC ORDERS RELATED TO STANDARDS
– IF INDUSTRY DOES NOT FILE WITHIN 30 DAYS NOTICE on Directives in Orders to change “standards” or provide for the same intent are considered, IT IS ASSUMED INDUSTRY AGREES.
ReliabilityFirst 3/6/08 RC Meeting 33
Variance
• NERC Rules of Procedure and Standards Development Procedure sites “Variance”
Note: The term “difference” was changed August 2006
• A different or alternative way to meet the intent of a NERC standard requirement
– If it is the same, then there is no variance
– If it is needed not for meeting a NERC requirement, then it’s a local requirement
ReliabilityFirst 3/6/08 RC Meeting 34
Variance
• Who may ask for Variances?
– An Interconnection (e.g. WECC in FAC standard)
– A Region (Regional Entity, not the RRO)
– A sub-region
– Any entity that does things differently (e.g. MISO, PJM and SPP in the TLR standard)
• Variance can be added while drafting is underway
• If no drafting in progress, a SAR is needed
ReliabilityFirst 3/6/08 RC Meeting 35
Variance
• Example of a Variance?
– NERC standard requires at least 5% of “X” to be compliant
– An entity, let’s say an RE, requires at least 2% of “X”
– Since they both want a % of “X”, the 2% is a Variance
• If RFC drafts a standard on Resource Adequacy that is not covered by a NERC standard, it is a regional standard and not a Variance
• Request for Variance is a routine question for posting
ReliabilityFirst 3/6/08 RC Meeting 36
NERC Summary
• So keep an eye on the NERC Work Plan
• Keep an eye on the FERC Orders
• Keep an eye on postings for comment
• Participate on SDTs to help steer the team
• Submit comments, before the ballot, even if you agree, otherwise the draft will go a different way
• The opportunities are endless and challenging but once we get over first pass, we will know what we need to do to keep the lights on.
ReliabilityFirst 3/6/08 RC Meeting 37
We continue to evolve
Questions?
Our Goal
RELIABILITY