Transcript FRCC On-Site Compliance Audit Introduction

FRCC
Registration and Compliance
Overview
Linda Campbell
FRCC Director of Reliability and
Compliance
FRCC
Entity Registration
Overview
Registered Functions
• BA, Balancing Authority
• DP, Distribution Provider
• GOP, Generator
Operator
• GO, Generator Owner
• LSE, Load Serving
Entity
• PA, Planning Authority
• PSE, Purchasing-Selling
Entity
• RC, Reliability
Coordinator
• RSG, Reserve Sharing
Group
• RP, Resource Planner
• TO, Transmission
Owner
• TOP, Transmission
Operator
• TP, Transmission
Planner
• TSP, Transmission
Service Provider
Registration Criteria
• Load Serving Entities (LSE)
Peak Load > 25 MW or,
Responsible for UFLS facilities or,
Responsible for UVLS facilities
Registration Criteria
• Distribution Provider (DP)
System serving > 25 MW or,
Responsible for UFLS facilities or,
Responsible for UVLS facilities or,
Responsible for required SPS
Registration Criteria
• Generator Owner/Operator
(GO or GOP)
Individual Generating Unit > 20 MVA
Generating Plant/Facility > 75 MVA
Any blackstart unit that is part of
entities restoration plan
Any generator, regardless of size that
is material to reliability
Registration Criteria
• Transmission Owner/Operator
(TO or TOP)
Owns or operates transmission
element 100 KV or above, or lower
voltage defined by FRCC as
necessary for reliable operation of the
grid, or that is included on a critical
facilities list defined by FRCC.
Registration Criteria
• Joint Action Agency or Similar
Organization
May register on behalf of one or more
of its members
Must accept compliance reporting
responsibility for all standards
applicable to the members
Shall provide FRCC with an annual
“Agency Member Registry”
Registration Timeline
• December 14, 2006 – NERC
implements Revision 2 to Registry
Criteria
• December 20, 2006 – FRCC
submitted update of “non-binding”
compliance registry
• January 10, 2007 – Review of
“non-binding” registry by NERC
and Regional Compliance
Managers
Registration Timeline (con’t)
• Late January, 2007 FRCC initiate
final update of Compliance Registry
• March 2, 2007 – FRCC to submit to
NERC a final Compliance Registry
• March 12, 2007 – Final review of
Compliance Registry by NERC and
Regional Compliance Managers
FRCC
Compliance Program
Overview
What is Compliance
Monitoring?
• Process by which a Registered
Entity’s performance is measured
against:
– NERC Reliability Standards
– FRCC Regional Reliability Standards
• Does not review anything that is not
included in the standards
Who does Compliance
Monitoring?
• FRCC will be a Regional Entity with
delegated responsibility and authority
from NERC and FERC
• FRCC monitors registered entities in our
region
• NERC provides oversight of FRCC
compliance program
• FERC provides oversight of both NERC
and FRCC
What are Violations?
• Violations occur when a Registered
Entity does not comply with a
requirement of a Reliability Standard that
is applicable to that entity
• Alleged violations are required to be
reported to NERC and FERC
• Confidentiality of the entity will be
maintained until the alleged violation is
confirmed
Sources of Violations
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On-site Compliance Audits
Annual Self Certification
Spot Audits
Compliance Violation Investigations
Complaints
Self-Reporting
Periodic Data Submittal
Exception Reporting
Processing Alleged
Violations
• Entity provided with written notice of
alleged violation
• Entity can accept or object to the
alleged violation
– Accept : Reported to NERC, Mitigation
Plan prepared by entity
– Contest : Entity request FRCC
Hearing Process be initiated
What are Sanctions and
Penalties?
• FERC has identified June 2007 as the time period
for which compliance with Reliability Standards will
be mandatory and enforceable
 Sanctions (Non-Monetary)
– Letters to company officers
– Require actions to be taken
– Placement on “watch list”
 Penalties (Monetary Fines)
– Calculated by FRCC Compliance Staff
• Base penalty adjusted by mitigating or aggravating
factors
How are Sanctions and Penalties
determined?
• Example in current standard
BASE PENALTY TABLE
• Future
Violation
Risk
Factor
Violation Severity Level
Lower
Range Limits
Low High
Moderate
Range Limits
Low High
High
Range Limits
Low High
Severe
Range Limits
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
On-Site Compliance Audits
• Audits are performed by the FRCC
• Based on “pro-forma” program developed
by NERC
• Performed every three years for RC, BA
and TOP, others to be on a schedule
determined by NERC
• Will include all standards applicable to
entity that were monitored in the annual
implementation plans since last audit
Audit Report
• A Final Report of the audit will be
prepared by the audit team
– Audited entity will review and provide
factual or technical corrections
• Submit to the FRCC Compliance
Committee for review
• Final Report will be posted on the
FRCC website
Mitigation Plans
• Mitigation Plans are required for every
confirmed violation
• Must identify how the entity plans to come
into compliance with the requirement
• Will be approved by the FRCC
Compliance Committee
• Must include milestones if longer than 3
months to correct.
FRCC Hearing Process
• Registered Entity must contest or respond
to notice of violation within 30 days.
– If no response, violation is considered to be
accepted
• If objection not resolved with 40 days of
entity response, must request hearing
• Hearing Body is the FRCC Board
Compliance Committee
• If Registered Entity does not agree with
outcome of FRCC Hearing, may appeal at
NERC.
Questions?