Transcript ERCOT Compliance

ERCOT Compliance
Audits
Robert Potts
Sr. Reliability Analyst
March 23, 2005
NERC Standards
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NERC Operating Standards
NERC Planning Standards
NERC Operating Standards
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P4T2-System Coordination/Operational Security Information.
P4T4 Coordination and Reporting of Scheduled Outages
P5T1 Implementation of Capacity and Energy Emergency Plans and
Coordination with other systems.
P6T1 Emergency Operations/ Preparation of capacity and Energy
Emergency Plans
P6T2 Emergency Operations/ Preparation of Restoration Plans
P6T3 Emergency Operations/ Loss of Primary Controlling Facility
P8T3 Operator Personnel and Training/ Training Program
Vegetation Management (Transmission Operations)
NERC Planning Standards for
TDSP Participants
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IAM1 Simulated system performance under normal (no contingency)
conditions
IAM2 Simulated system performance following the loss of a single
bulk system element
IAM3 Simulated system performance following loss of two or more
bulk system elements
IAM4 Simulated system performance following extreme events
resulting in the loss of two or more bulk system elements
IICM1 Methodology(ies) for determining electrical facility ratings
IIIAM4 Documentation and implementation of Transmission
protection system maintenance and testing
IIIAM5 Analysis and reporting of Transmission protection
misoperations
NERC Planning Standards for
TDSP Participants (Cont.)
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IIIDM2 UFLS programs with Regional UFLS requirements
IIIDM3 Implementation and documentation of UFLS equipment
maintenance program
IIIEM3 Technical assessment of the design and effectiveness of the
UVLS programs
IIIEM4 Under voltage load shedding system maintenance and
testing
IIIEM5 Analysis and documentation of UVLS program performance
IIIFM5 Notification and analysis of SPS misoperation and corrective
action plans
IIIFM6 Special Protection System maintenance and testing
ERCOT Requirements
There are the ERCOT Protocols and ERCOT
Guides that incorporate the NERC
Standards, but also “specialize” the needs
of ERCOT as an Operating Entity.
Are You Compliant?
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ERCOT Operating Guides and Protocols spell out
the requirements that ERCOT QSE and
Transmission Operator Participants must adhere
to.
Participants are to be compliant with these from
the time they register.
ERCOT Compliance Audits are a means for
ERCOT to assess whether Participants and
ERCOT itself are compliant with the Protocols
and Operating Guides.
QSE Audit Questions
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There are a series of questions in the
audit that are derived from ERCOT
Protocol and Guide References.
These questions are designed to help
Compliance determine if QSE Participants
are operating within the requirements of
these documents.
Guide and Protocol requirements are not
new!
Transmission Operator Audits
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Questions here are geared to Transmission
requirements set forth in the ERCOT
Operating Guides and Protocols.
Questions are geared to help Compliance
assess if requirements are being followed.
The ERCOT Operating Guide and Protocol
Requirements are not new!
How Do Audits Work?
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ERCOT Compliance will send the
questionnaire to the Participant.
The Participant will have one month to
answer the questions and return them to
Compliance.
Compliance will review the answers and
arrange a date to do a site visit to discuss
questions with management and
operations staff.
What Happens Next?
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Compliance issues a report consisting of
findings that were identified at the audit
and shares this with the Participant.
Non-Compliance items will be addressed
and posted on the Compliance Web site.
Depending on the seriousness of the
violation, different levels of noncompliance will be initiated.
What is the end result?
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Participants will be aware if they are not
compliant.
Participants will provide corrective actions
for non-compliance issues.
Compliance will do follow up on
suggestions made and corrective action
plans of Participants.
How Often are Audits Conducted?
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ERCOT Compliance will conduct Audits on
a three year cycle or at any time deemed
necessary.
Audits
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ERCOT Compliance will audit ERCOT Operations
in August of this year
ERCOT Operations will be audited by NERC in
October of this year.
There are some self certification documents that
are sent out from NERC to ERCOT.
There are some Self Certification Documents
sent from ERCOT to the Participants as a part of
the Compliance process.
Investigations
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What triggers an investigation?
Who performs an investigation?
What is the process?
What is the outcome?
Types of Investigations
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Incident Investigation
1. Usually initiated by ERCOT Operations.
2. Can be initiated from findings by
ERCOT Compliance.
Event Investigations
These are investigations that are triggered
by an event in the ERCOT System.
Incident Trigger
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ERCOT Operations flags a possible
Protocol Violation that can not be resolved
between Operations and the Participant.
The Possible Protocol violation is escalated
from Operations to Compliance.
ERCOT Compliance finds Protocol
Violations through other means.
Audits, Spot Checks, Self Certification…
Who performs investigations?
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ERCOT Operations Support sometimes
does preliminary investigations.
ERCOT Compliance does most follow up
investigations.
ERCOT Compliance weighs all evidence in
an investigation.
The investigation can lead to Compliance
finding ERCOT Operations non-compliant.
Incident Investigations
What is the Process?
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ERCOT Operations identifies a possible
Protocol or Operating Guide Violation.
They try to work out the problem with the
Participant.
If they can not, an Incident Report is
written up by the Shift Supervisor and
sent to the Chief System Operator.
The CSO reviews the incident and decides
whether or not to send to the Participant.
Process (cont.)
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Once the letter is sent to the Participant, they
have 5 business days to respond. (The letter is
copied to ERCOT Compliance and the PUCT as
well).
They must respond with a corrective action plan
that will remedy the problem and give a time
line as to when the action will be taken.
The Response may indicate that the Participant
does not feel that an infraction occurred.
If the response is not satisfactory, the CSO
escalates the matter to ERCOT Compliance.
Process (cont.)
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ERCOT Compliance will then initiate an
investigation that will include information
gained from ERCOT Operations and the
Participant.
Compliance will determine if there was a
Protocol Violation and take steps with
either the Participant and/or ERCOT
Operations to address the situation.
Process (continued)
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The results of the investigation will be
filed and the infraction will be handled in
the appropriate manner.
Lane Robinson will speak on the
consequences in a few moments.
Event Investigations
What is the process?
Event investigations are triggered by any
number of significant events that can
occur within the ERCOT System.
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These events are as follows:
EECP implementation
Emergency Notice issued
SPS Activation
Significant Event Triggers
Continued
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Simultaneous loss of any combination of
three generating units, transmission lines,
and autotransformers (138KV and above).
RAP implementation requiring load
shedding.
Sustained voltage deviations greater than
5% on the 345KV system.
Significant Event Triggers
Continued
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Under Frequency relay operations (or
frequency deviations greater than .7 Hz
from scheduled frequency.
First contingency security violations for
significant transmission elements (list of
elements to be defined).
Failure of computer systems at ERCOT, the
QSE or TO.
Significant Event Triggers
continued
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Voltage collapse on portions of the 138KV
or 345KV system.
Loss of an ERCOT, QSE, or ERCOT TO
control center.
Black Start Plan initiation.
Uncontrollable loss of 150MW or more of
firm load, shed for more than 15 minutes
from a single incident.
Significant Event Triggers
continued
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Any event determined by the ROS to be
significant.
Process for Significant Event
Investigation
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ERCOT Operations will notify Compliance
of a significant event.
ERCOT Compliance will investigate to find
the root cause using information from
ERCOT Operations and the Market
Participants.
Reports by ERCOT Operations or
Participants should be back to Compliance
and completed within 60 days.
Significant Event Process
Continued
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ERCOT Compliance will follow up with
ERCOT Operations, the Market Participants
or both on corrective action plans or other
solutions.
Investigations of this sort may or may not
lead to compliance issues.
Compliance will file and post the report
when it has been closed.
Bottom Line
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We are in this together
Compliance is determined to make sure
that all Participants and ERCOT follow the
rules contained in the NERC, ERCOT
Protocols and ERCOT Guides.
The System must be RELIABLE!
That is the bottom line!