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Home Communications In the News NERC Self-Reporting: How to Make the Best of a Bad Situation

9.25.2018

NERC Self-Reporting: How to Make the Best of a Bad Situation

by Daniel Jenkins  – NERC Reliability Specialist, NAES Corporation

From time to time, we all find ourselves in the awkward position of having to admit we made a mistake.   It could be something minor, like forgetting your key card to get into work – or something bigger and messier, like a NERC violation. NAES holds itself to the highest standards of safety and reliability in operating power plants, and with that comes a commitment to regulatory compliance. If you’ve identified a possible NERC violation at your facility, here are some suggestions on how to proceed and what you might expect.

First, don’t hold back: share your concern immediately. Let your plant manager, compliance manager and corporate support personnel know as soon as possible. They can help determine what the issue is and what corrective action should be taken. If there’s a possible violation of a NERC Standard or Requirement, we support the NERC guidance that recommends filing a Self-Report. It demonstrates a strong culture of compliance and a proactive approach to maintaining reliability.

NAES NERC Reporting PhotoSecond, start an internal investigation of the event immediately by gathering evidence, documentation and statements from all personnel who had any involvement in the event. With this information in hand, you can put together a timeline and review the scenario to determine if there has in fact been a NERC violation. As part of your investigation, create a list of possible root causes. These will help your team brainstorm preventive measures to avoid a recurrence of similar actions or inaction. They can also be included in a Mitigation Plan, if your Regional Entity determines that you need to submit one. (More about that later.)

Once you know exactly what has happened, you should start your Self-Report. To put it in proper contexts, note the NERC Rules of Procedure: a Self-Report should be filed ‘when a Registered Entity becomes aware that it has or may have violated a Reliability Standard or when the Violation Severity Level of a previously reported violation has changed.’

The Rules of Procedure also set forth a specific protocol to be followed once a Self-Report is filed. When your Regional Entity’s compliance department receives it, they will complete a Preliminary Screening within five days. If the screening determines that 1) the entity is a registered entity, 2) the standard being reported is applicable to the entity, and 3) there is not a duplicate possible violation currently being processed, the Self-Report will be moved on to the Enforcement Actions process. From there, the Regional Entity will further evaluate it and issue either a Compliance Exception; a Find, Fix and Track; or a Notice of Alleged Violation, depending on the severity and risk of the non-compliance.

In the end, your Regional Entity should feel confident that you have both corrected the issue and taken internal actions to prevent a recurrence. If you haven’t demonstrated this convincingly in your Self-Report, you may be required to submit a formal Mitigation Plan, which will need to be approved and then tracked. When all actions have been completed, you’ll receive a Notice of Completion of Enforcement Action to close out the violation. Your organization should then review this process in order to document lessons learned, develop internal controls and take any other action deemed necessary to support continuous improvement.

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    CAISO Generator Modeling Process and Data Requirements

    Don’t wait until the last minute. You should allow time for at least one iteration with CAISO so that you are complete and deemed compliant before your deadline.

    On August 1, 2018, CAISO introduced a revised Business Practice Manual for Transmission Planning Process (BPM), which includes new data requirements for interconnected generation resources within the ISO’s footprint. Section 10 of the BPM establishes revised data requirements and compliance procedures for all participating generators including non-NERC registered entities. While additional requirements have been placed on larger NERC registered facilities, these changes may pose an even greater burden to entities that have been exempt from NERC mandated modeling and protection requirements.

    New data requirements include voltage and frequency protection models, power flow models, and in some cases, sub-synchronous resonance models. These models must be verified using criteria listed in the BPM, which can only be performed by entities with modeling software and knowledge of modeling practices.

    NAES is prepared to assist entities with data aggregation, modeling, and testing to ensure compliance with CAISO’s data requests. The following links will allow entities to determine when to expect their individual data requests (phase) and what data will be required (category).

    Business Practice Manual (BPM)

    Entity Category and Phase Listing

    CAISO Transmission Planning Website

    TPL-007

    TPL-007 establishes planning criteria for induced currents caused by geomagnetic disturbances. The standard is applicable to facilities using transformer(s) with a high side, wye grounded winding operated above 200 kV and can require both submittal of general geomagnetic data (R2) and thermal impact assessments (R6) depending on results of Planning Coordinator analysis.

    VOLTAGE AND REACTIVE (VAR) STANDARDS

    VAR-501-WECC

    VAR-501-WECC requires applicable entities within the WECC region to confirm performance settings and characteristics of Power System Stabilizers (PSS). NAES provides physical testing and reporting services to address WECC’s specific PSS requirements.

    PERSONNEL PERFORMANCE, TRAINING AND QUALIFICATIONS

    PER-006

    PER-006 requires Generator Operators to provide training to personnel who are responsible for the Real-time control of a generator. NAES has developed specific protection system training materials suitable for compliance with the Standard and provides this training both on and off site

    PROTECTION AND CONTROL (PRC) STANDARDS

    PRC-001

    PRC-001 requires entities to coordinate protection system changes with other affected parties. NAES offers both procedural documentation and engineering services to establish the required coordination for both PRC-001 and PRC-027.

    PRC-002

    PRC-002 requires the installation and operation of disturbance monitoring equipment (DME) for applicable entities. NAES can assist with the design and installation of DME as well as ongoing compliance support.

    PRC-019

    PRC-019 requires applicable entities to show coordination between voltage regulating controls, limiters, equipment capabilities, and protection settings. NAES produces PRC-019 specific coordination studies for both traditional generators and renewable projects to establish compliance with the Standard.

    PRC-023

    PRC-023 requires load responsive protective relays be set according to criteria within the Standard to ensure settings do not limit transmission loadability. NAES provides full engineering analyses to maintain compliance with this Standard.

    PRC-024

    PRC-024 requires applicable entities to ensure generator protective relays do not trip within predefined frequency and voltage limits. NAES can complete protection settings analyses and provide compliance documentation that clearly identifies protection settings as they relate to NERC’s “no trip” zones.

    PRC-025

    PRC-025 establishes minimum settings requirements for load-responsive relays protecting generators, step up transformers, and auxiliary transformers. NAES utilizes predefined calculation options as well as simulations to determine a facility’s compliance status and development of new relay settings if required.

    PRC-026

    PRC-026 requires applicable entities to perform load responsive relay settings analyses based on criteria identified within the Standard. Entities are typically notified by the Planning Coordinator when an analysis is required. NAES performs all required studies to establish compliance.

    MODELING, DATA, AND ANALYSIS (MOD) STANDARDS

    MOD-025

    MOD-025 requires Real and Reactive Power capability testing for individual generating units over 20 MVA or facilities with over 75 MVA of generation capacity. NAES offers site specific test procedures and/or complete onsite testing services to meet the requirements of this standard.

    MOD-026

    MOD-026 requires verification of excitation or volt/var control dynamic models through utilization of either system disturbances or physical testing. NAES offers full testing and modeling services to meet the requirements of this standard.

    MOD-027

    MOD-027 requires verification of governor or active power/frequency control dynamic models through utilization of either system disturbances or physical testing. NAES offers full testing and modeling services to meet the requirements of this standard.