Combustion Turbine

Operations Task Force (CTOTF)

NERC Overview &
generation Protection
System Presentation
John Pasierb
Senior Project Manager April 14, 2011
Transmission Services
john.pasierb@gdsassociates.com
770.425.8100
 Reliability Standards

June 18, 2007

Mandatory Enforceable

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Electric Reliability Authority
Congress
• Energy Policy Act of 2005

FERC
• Establishes ERO

NERC
• Drafts Policy

Regional Entities
• Enforces Policy
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 Reliability Prior to
June 18, 2007

NERC Standards NERC Standards NERC Standards

were good were not were not
industry practice mandatory enforceable

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Reliability After June 18, 2007
Mandatory Compliance Applicability
• Mandatory compliance with • Standards apply to 15
Electric Reliability functional entity types
Organization (ERO) • Standards apply to "users,
Standards owners, and operators of the
Bulk Power System."

Regulatory Actions Due Process

• Allowed penalty actions by • Due process at the ERO, then
RE, ERO, or FERC: FERC
• Monetary fines
• Non-monetary sanctions
• Operational restrictions

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 Bulk Power System
NERC Rules of Procedure consider
the bulk power system to include:
• Electrical generation resources
• Transmission lines
• Interconnections with neighboring systems
• Associated equipment
• Generally operated ≥100 kV
With the catch:
• “…if the consequences of an entity's actions
or inactions could have a material impact
on the bulk power system, that entity may
be considered a user of the bulk power
system."
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 Registration & Compliance
Responsibilities

NERC Registration: Regions Registration: Entities Registration:

Delegated to Maintain current Maintain accurate
Regions registry of entities registration with
and functions region

Enforcement: Enforcement: Enforcement:

Delegated to Analyze Alleged Develop Internal
Regions Violations Compliance
Program

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 NERC Basis for Registration

Users, Owners and Operators of:

Transmission Generation Distribution

Voltage Single Aggregate Connected to

>100 kV Generator ≥20 Generation the Bulk Power
(Typically) MVA ≥75 MVA System

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NERC Regional Entities

WECC SPP SERC

TRE FRCC MRO

RFC NPCC

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 NERC Reliability Standards
Compliance Monitoring & Enforcement

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 Compliance Monitoring

Self Certification
Audit Spot Check • Periodic Data
Submittal May Apply
to Some Standards

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 Handling Violations

Violation Discovery
• Flaw in compliance found and reported

Mitigation Plan
• Implementing changes to prevent reoccurrence

Penalties and Settlements

• Different tracks for resolution of violation

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 Violation Discovery

Audit • Auditor discovers non-compliance event

• Potentially similar scenario to an Audit

Spot Check • Regional Entity can make a Data Request
• Self Certification

Self • Company discovers non-compliance during preparation for

Certification Self-Certification

• Company discovers non-compliance and files report outside

Self Report the above events

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 Mitigation Plans
Development Required
• Agreed and approved by • Must be made for each
Regional Entity Standard violated

Milestones Schedule
• Must have milestone and • Must remain on schedule,
conclusion dates additional penalties may
be assessed for missed
deadlines

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 Penalties and Settlements

• Typically results in lower penalties

• Perform beyond base requirements to enhance
Settlements reliability
• May include training, awareness programs or ICP

• Formal penalty process

Violation • May include hearings
Process • Typically assessed greater penalties

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Penalty Determination
Mitigating Factors
• Good Internal Compliance Program
• Cooperation with Regional Entity
• Timely completing the Mitigation
Plan

Aggravating Factors
• Intentionally violating the Standards
• Misleading Regional Entity
• Not completing the Mitigation Plan
on time

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 Base Penalty Amounts

Violation Severity Level

Violation
Lower Moderate High Severe
Risk Range Limits Range Limits Range Limits Range Limits
Factor Low High Low High Low High 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

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 NERC Standards in 2011
Number of Reliability Standards

Year 2007 2008 2009 2010 2011

Compliance Audit 39 60 49 56 38

Self-Certification 39 60 52 60 51

Periodic Data Submittals -- -- 12 13 14

Exception Reporting -- -- 14 19 13

Spot Check 0 0 13 19 14
Subject to Compliance
Violation Investigation -- -- 94 95 102

Subject to Self-Reporting -- -- 94 95 102

Subject to Complaint -- -- 94 95 102

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NERC Reliability Standard PRC-005
Maintenance and Testing of
generation Protection Systems

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 Defining generation Protection
Systems

Protection System Components

Associated Voltage and

Protective Station DC Control
Communication Current Sensing
Relays Batteries Circuitry
Systems Devices

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Maintenance and Testing: Program
Specification

Interval • Can be any reasonable period

• Must include maintenance and testing periods

• Why you chose the interval

Basis • Must be defendable

• Usually rooted in a National Standard (IEEE, ANSI)
• NERC and Regional Entities frown upon Good Utility Practice

• List of maintenance tasks to be performed

Summary • List of testing to be performed

• Not an exhaustive list, enough to provide an auditor with
general idea of what is being performed

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 Maintenance and Testing:
Program Data Collection

Intervals
• Evidence when last maintained
• Evidence when last tested
• Must match intervals described in Requirement 1.1

Dates • When was the last maintenance performed

• When was the last testing performed

Evidence
• Test reports
• Maintenance sheets, logbooks, etc.
• Anything showing the task was performed and documented

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 generation Protection System
Documentation
• Provide Maintenance and Testing
Program Program To the Regional Entity and
NERC on request

• Must show that the Program

Implementation developed has been implemented

• Must provide to the Regional Entity

Fulfillment and/or NERC within 30 calendar days
of request

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24
 So Why is the g in generation
Protection System Lowercase?
Capitalized letters indicate a NERC defined term in the NERC
Glossary of Terms

Protection System is defined in … but generation Protection

NERC Glossary of Terms… System (gPS) is not.

So what makes up a gPS?

Varies between Regional

…but typically includes…
Entities…

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 Typical gPS Components
Direct Trip of
Generator Unit Lockout
Generator
Lockout Relays Relays
Circuit Breaker

Loss of Underfrequency
Backup
Overcurrent Excitation or or
Distance
Field Failure Overfrequency

Field
Volts per Hertz Over Excitation Field Ground
Overcurrent

Generator or
GSU Differential Stator Ground Out of step
Unit Differential

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 Where do we go wrong?

No Program • It does still happen

Incomplete gPS • Identification is a difficult task because

Identification guidance is marginal

• Especially common with maintenance

Insufficient records
Documentation • Record keeping becomes a big issue

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 Where do we go wrong?

Missed
• Failed to test or maintain within the
Testing or intervals established by your own plan
Maintenance

• New or removed items are not removed

Inventory is from the device listing
Out-of-Date • Causes items either to be missed or
appear to have missed testing

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 Where do we go wrong?

Insufficient • Good utility practice just doesn’t cut it anymore

Interval Basis

No • Summary maintenance on equipment; may include:

Maintenance • Check tightness of connections
Procedure • Burnish contacts
• Verify LEDs
Summary

No Testing • Similar to Maintenance Summary. May include:

• Apply appropriate current and voltages at proper phase angles
Procedure • Verify ratio by voltage or current methodology
Summary • Power factor

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 PRC-005 Violations by Region
250

200
208

150

100 112 110

50
53 56 57
31 30
0

FRCC MRO NPCC RFC SERC SPP TRE WECC

Adapted from http://www.nerc.com/files/March%202011%20Workshop_Day%20Three%20Presentations.pdf

Data current as of March 1, 2011
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 PRC-005 Violations by
Entity Type
TO
84 Violations
13% DP
74 Violations
GO 11%
319 Violations
48%

Multiple
Functions
181_Violations
28%

Adapted from http://www.nerc.com/files/March%202011%20Workshop_Day%20Three%20Presentations.pdf

Data current as of March 1, 2011
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 PRC-005 Violations by
Discovery Type
Self Certification
Investigation 98 Violations
6 Violations 15% Self Report
1% 323 Violations
49%

Audit
208 Violations
32%
Spot Check
23 Violations
3%

Adapted from http://www.nerc.com/files/March%202011%20Workshop_Day%20Three%20Presentations.pdf

Data current as of March 1, 2011
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 PRC-005 Violations are Most
Common
700
PRC
600
CIP
500
400 FAC

300 VAR

200 EOP
100
Other
0

Adapted from http://www.nerc.com/files/Feb%20Public%20Posting%20Statistics.pdf

Data current as of February 28, 2011
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 NERC Reliability Standard PRC-005
Avoiding Violations:
Best Practices & Common Pitfalls

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 Know Your Protection Systems

Protection Systems
Protective
Batteries Communications DC Circuitry Instrument Transformers
Relays

CTs PTs Linear Couplers

CCVTs CVTs

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 Keep Meticulous Records

• Develop checklists for maintenance items

Checklists • Allows for documentation of the task as
completed

• Have a robust database for record

keeping
Database • Possibly look to 3rd party vendors if internal
expertise is not available

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 Know Your Intervals

• Intervals include maintenance and testing

• Have a grace period for your interval
• Use a good basis for your interval and for
your grace period
• Good utility practice does not cut it anymore;
use an authoritative source

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 Inventories and Summaries

• Keep your generation Protection System

Inventory universe up to date:

• Remove or notate retired equipment
• Make sure new equipment is added right away

• Have a good summaries of maintenance and

testing procedures
Summaries • Include details sufficient to address concerns of an
Auditor
• Don’t include every single detail

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 And in General…

• Perform a self assessment of all Standards

Self- applicable to your registration type
• Suggest an annual review
Assess • Self report any possible violations you find
• Acts as a mitigating factor in penalty determination

• Look into developing an Internal Compliance

Program
ICP • Auditors are reviewing entities’ responses to the FERC
13 questions
• This is also a mitigating factor

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As always, live, breathe and
exude a culture of compliance

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