ERCOT Compliance ERCOT Compliance AuditsAudits

Robert PottsRobert Potts

Sr. Reliability AnalystSr. Reliability Analyst

March 23, 2005March 23, 2005

NERC StandardsNERC Standards

NERC Operating StandardsNERC Operating Standards NERC Planning StandardsNERC Planning Standards

NERC Operating StandardsNERC Operating Standards P4T2-System Coordination/Operational Security P4T2-System Coordination/Operational Security

Information.Information. P4T4 Coordination and Reporting of Scheduled OutagesP4T4 Coordination and Reporting of Scheduled Outages P5T1 Implementation of Capacity and Energy Emergency P5T1 Implementation of Capacity and Energy Emergency

Plans and Coordination with other systems.Plans and Coordination with other systems. P6T1 Emergency Operations/ Preparation of capacity and P6T1 Emergency Operations/ Preparation of capacity and

Energy Emergency PlansEnergy Emergency Plans P6T2 Emergency Operations/ Preparation of Restoration P6T2 Emergency Operations/ Preparation of Restoration

PlansPlans P6T3 Emergency Operations/ Loss of Primary Controlling P6T3 Emergency Operations/ Loss of Primary Controlling

FacilityFacility P8T3 Operator Personnel and Training/ Training ProgramP8T3 Operator Personnel and Training/ Training Program Vegetation Management (Transmission Operations)Vegetation Management (Transmission Operations)

NERC Planning Standards for NERC Planning Standards for TDSP ParticipantsTDSP Participants

IAM1 Simulated system performance under normal (no IAM1 Simulated system performance under normal (no contingency) conditionscontingency) conditions

IAM2 Simulated system performance following the loss of a IAM2 Simulated system performance following the loss of a single bulk system elementsingle bulk system element

IAM3 Simulated system performance following loss of two or IAM3 Simulated system performance following loss of two or more bulk system elementsmore bulk system elements

IAM4 Simulated system performance following extreme events IAM4 Simulated system performance following extreme events resulting in the loss of two or more bulk system elementsresulting in the loss of two or more bulk system elements

IICM1 Methodology(ies) for determining electrical facility IICM1 Methodology(ies) for determining electrical facility ratingsratings

IIIAM4 Documentation and implementation of Transmission IIIAM4 Documentation and implementation of Transmission protection system maintenance and testingprotection system maintenance and testing

IIIAM5 Analysis and reporting of Transmission protection IIIAM5 Analysis and reporting of Transmission protection misoperationsmisoperations

NERC Planning Standards for NERC Planning Standards for TDSP Participants (Cont.)TDSP Participants (Cont.)

IIIDM2 UFLS programs with Regional UFLS requirementsIIIDM2 UFLS programs with Regional UFLS requirements IIIDM3 Implementation and documentation of UFLS IIIDM3 Implementation and documentation of UFLS

equipment maintenance programequipment maintenance program IIIEM3 Technical assessment of the design and IIIEM3 Technical assessment of the design and

effectiveness of the UVLS programseffectiveness of the UVLS programs IIIEM4 Under voltage load shedding system maintenance IIIEM4 Under voltage load shedding system maintenance

and testingand testing IIIEM5 Analysis and documentation of UVLS program IIIEM5 Analysis and documentation of UVLS program

performanceperformance IIIFM5 Notification and analysis of SPS misoperation and IIIFM5 Notification and analysis of SPS misoperation and

corrective action planscorrective action plans IIIFM6 Special Protection System maintenance and testingIIIFM6 Special Protection System maintenance and testing

ERCOT RequirementsERCOT Requirements

There are the ERCOT Protocols and There are the ERCOT Protocols and ERCOT Guides that incorporate the ERCOT Guides that incorporate the NERC Standards, but also NERC Standards, but also “specialize” the needs of ERCOT as “specialize” the needs of ERCOT as an Operating Entity.an Operating Entity.

Are You Compliant?Are You Compliant?

ERCOT Operating Guides and Protocols ERCOT Operating Guides and Protocols spell out the requirements that ERCOT spell out the requirements that ERCOT QSE and Transmission Operator QSE and Transmission Operator Participants must adhere to.Participants must adhere to.

Participants are to be compliant with these Participants are to be compliant with these from the time they register.from the time they register.

ERCOT Compliance Audits are a means for ERCOT Compliance Audits are a means for ERCOT to assess whether Participants and ERCOT to assess whether Participants and ERCOT itself are compliant with the ERCOT itself are compliant with the Protocols and Operating Guides.Protocols and Operating Guides.

QSE Audit QuestionsQSE Audit Questions

There are a series of questions in the There are a series of questions in the audit that are derived from ERCOT audit that are derived from ERCOT Protocol and Guide References.Protocol and Guide References.

These questions are designed to help These questions are designed to help Compliance determine if QSE Compliance determine if QSE Participants are operating within the Participants are operating within the requirements of these documents.requirements of these documents.

Guide and Protocol requirements are Guide and Protocol requirements are not new!not new!

Transmission Operator AuditsTransmission Operator Audits

Questions here are geared to Questions here are geared to Transmission requirements set forth Transmission requirements set forth in the ERCOT Operating Guides and in the ERCOT Operating Guides and Protocols.Protocols.

Questions are geared to help Questions are geared to help Compliance assess if requirements Compliance assess if requirements are being followed.are being followed.

The ERCOT Operating Guide and The ERCOT Operating Guide and Protocol Requirements are not new!Protocol Requirements are not new!

How Do Audits Work?How Do Audits Work?

ERCOT Compliance will send the ERCOT Compliance will send the questionnaire to the Participant.questionnaire to the Participant.

The Participant will have one month The Participant will have one month to answer the questions and return to answer the questions and return them to Compliance.them to Compliance.

Compliance will review the answers Compliance will review the answers and arrange a date to do a site visit and arrange a date to do a site visit to discuss questions with to discuss questions with management and operations staff.management and operations staff.

What Happens Next?What Happens Next?

Compliance issues a report consisting of Compliance issues a report consisting of findings that were identified at the audit findings that were identified at the audit and shares this with the Participant.and shares this with the Participant.

Non-Compliance items will be Non-Compliance items will be addressed and posted on the addressed and posted on the Compliance Web site.Compliance Web site.

Depending on the seriousness of the Depending on the seriousness of the violation, different levels of non-violation, different levels of non-compliance will be initiated.compliance will be initiated.

What is the end result?What is the end result?

Participants will be aware if they are Participants will be aware if they are not compliant.not compliant.

Participants will provide corrective Participants will provide corrective actions for non-compliance issues.actions for non-compliance issues.

Compliance will do follow up on Compliance will do follow up on suggestions made and corrective suggestions made and corrective action plans of Participants.action plans of Participants.

How Often are Audits Conducted? How Often are Audits Conducted?

ERCOT Compliance will conduct ERCOT Compliance will conduct Audits on a three year cycle or at any Audits on a three year cycle or at any time deemed necessary.time deemed necessary.

Audits Audits

ERCOT Compliance will audit ERCOT ERCOT Compliance will audit ERCOT Operations in August of this yearOperations in August of this year

ERCOT Operations will be audited by NERC in ERCOT Operations will be audited by NERC in October of this year.October of this year.

There are some self certification documents There are some self certification documents that are sent out from NERC to ERCOT.that are sent out from NERC to ERCOT.

There are some Self Certification Documents There are some Self Certification Documents sent from ERCOT to the Participants as a part sent from ERCOT to the Participants as a part of the Compliance process.of the Compliance process.

InvestigationsInvestigations

What triggers an investigation?What triggers an investigation? Who performs an investigation?Who performs an investigation? What is the process?What is the process? What is the outcome?What is the outcome?

Types of InvestigationsTypes of Investigations

Incident InvestigationIncident Investigation

1. Usually initiated by ERCOT 1. Usually initiated by ERCOT Operations.Operations.

2. Can be initiated from findings by 2. Can be initiated from findings by

ERCOT Compliance.ERCOT Compliance. Event InvestigationsEvent Investigations

These are investigations that are These are investigations that are triggered by an event in the ERCOT triggered by an event in the ERCOT System.System.

Incident TriggerIncident Trigger

ERCOT Operations flags a possible ERCOT Operations flags a possible Protocol Violation that can not be Protocol Violation that can not be resolved between Operations and the resolved between Operations and the Participant.Participant.

The Possible Protocol violation is The Possible Protocol violation is escalated from Operations to escalated from Operations to Compliance.Compliance.

ERCOT Compliance finds Protocol ERCOT Compliance finds Protocol Violations through other means. Violations through other means. Audits, Spot Checks, Self Certification…Audits, Spot Checks, Self Certification…

Who performs investigations?Who performs investigations?

ERCOT Operations Support sometimes ERCOT Operations Support sometimes does preliminary investigations.does preliminary investigations.

ERCOT Compliance does most follow up ERCOT Compliance does most follow up investigations.investigations.

ERCOT Compliance weighs all evidence ERCOT Compliance weighs all evidence in an investigation.in an investigation.

The investigation can lead to The investigation can lead to Compliance finding ERCOT Operations Compliance finding ERCOT Operations non-compliant. non-compliant.

Incident InvestigationsIncident InvestigationsWhat is the Process?What is the Process?

ERCOT Operations identifies a possible ERCOT Operations identifies a possible Protocol or Operating Guide Violation.Protocol or Operating Guide Violation.

They try to work out the problem with They try to work out the problem with the Participant.the Participant.

If they can not, an Incident Report is If they can not, an Incident Report is written up by the Shift Supervisor and written up by the Shift Supervisor and sent to the Chief System Operator. sent to the Chief System Operator.

The CSO reviews the incident and The CSO reviews the incident and decides whether or not to send to the decides whether or not to send to the Participant.Participant.

Process (cont.)Process (cont.) Once the letter is sent to the Participant, Once the letter is sent to the Participant,

they have 5 business days to respond. (The they have 5 business days to respond. (The letter is copied to ERCOT Compliance and letter is copied to ERCOT Compliance and the PUCT as well).the PUCT as well).

They must respond with a corrective action They must respond with a corrective action plan that will remedy the problem and give plan that will remedy the problem and give a time line as to when the action will be a time line as to when the action will be taken.taken.

The Response may indicate that the The Response may indicate that the Participant does not feel that an infraction Participant does not feel that an infraction occurred.occurred.

If the response is not satisfactory, the CSO If the response is not satisfactory, the CSO escalates the matter to ERCOT Compliance.escalates the matter to ERCOT Compliance.

Process (cont.)Process (cont.)

ERCOT Compliance will then initiate ERCOT Compliance will then initiate an investigation that will include an investigation that will include information gained from ERCOT information gained from ERCOT Operations and the Participant. Operations and the Participant.

Compliance will determine if there Compliance will determine if there was a Protocol Violation and take was a Protocol Violation and take steps with either the Participant steps with either the Participant and/or ERCOT Operations to address and/or ERCOT Operations to address the situation.the situation.

Process (continued)Process (continued)

The results of the investigation will The results of the investigation will be filed and the infraction will be be filed and the infraction will be handled in the appropriate manner.handled in the appropriate manner.

Lane Robinson will speak on the Lane Robinson will speak on the consequences in a few moments.consequences in a few moments.

Event InvestigationsEvent InvestigationsWhat is the process?What is the process?

Event investigations are triggered by Event investigations are triggered by any number of significant events that any number of significant events that can occur within the ERCOT System.can occur within the ERCOT System.

These events are as follows:These events are as follows: EECP implementationEECP implementation Emergency Notice issuedEmergency Notice issued SPS ActivationSPS Activation

Significant Event Triggers Significant Event Triggers ContinuedContinued

Simultaneous loss of any Simultaneous loss of any combination of three generating combination of three generating units, transmission lines, and units, transmission lines, and autotransformers (138KV and autotransformers (138KV and above).above).

RAP implementation requiring load RAP implementation requiring load shedding.shedding.

Sustained voltage deviations greater Sustained voltage deviations greater than 5% on the 345KV system.than 5% on the 345KV system.

Significant Event Triggers Significant Event Triggers ContinuedContinued

Under Frequency relay operations (or Under Frequency relay operations (or frequency deviations greater than .7 frequency deviations greater than .7 Hz from scheduled frequency.Hz from scheduled frequency.

First contingency security violations First contingency security violations for significant transmission elements for significant transmission elements (list of elements to be defined).(list of elements to be defined).

Failure of computer systems at Failure of computer systems at ERCOT, the QSE or TO.ERCOT, the QSE or TO.

Significant Event Triggers Significant Event Triggers continuedcontinued

Voltage collapse on portions of the Voltage collapse on portions of the 138KV or 345KV system.138KV or 345KV system.

Loss of an ERCOT, QSE, or ERCOT TO Loss of an ERCOT, QSE, or ERCOT TO control center.control center.

Black Start Plan initiation.Black Start Plan initiation. Uncontrollable loss of 150MW or Uncontrollable loss of 150MW or

more of firm load, shed for more than more of firm load, shed for more than 15 minutes from a single incident.15 minutes from a single incident.

Significant Event Triggers Significant Event Triggers continuedcontinued

Any event determined by the ROS to Any event determined by the ROS to be significant.be significant.

Process for Significant Event Process for Significant Event InvestigationInvestigation

ERCOT Operations will notify ERCOT Operations will notify Compliance of a significant event.Compliance of a significant event.

ERCOT Compliance will investigate to ERCOT Compliance will investigate to find the root cause using information find the root cause using information from ERCOT Operations and the from ERCOT Operations and the Market Participants.Market Participants.

Reports by ERCOT Operations or Reports by ERCOT Operations or Participants should be back to Participants should be back to Compliance and completed within 60 Compliance and completed within 60 days. days.

Significant Event Process Significant Event Process ContinuedContinued

ERCOT Compliance will follow up with ERCOT Compliance will follow up with ERCOT Operations, the Market ERCOT Operations, the Market Participants or both on corrective Participants or both on corrective action plans or other solutions.action plans or other solutions.

Investigations of this sort may or Investigations of this sort may or may not lead to compliance issues.may not lead to compliance issues.

Compliance will file and post the Compliance will file and post the report when it has been closed.report when it has been closed.

Bottom LineBottom Line

We are in this togetherWe are in this together Compliance is determined to make Compliance is determined to make

sure that all Participants and ERCOT sure that all Participants and ERCOT follow the rules contained in the follow the rules contained in the NERC, ERCOT Protocols and ERCOT NERC, ERCOT Protocols and ERCOT Guides.Guides.

The System must be RELIABLE!The System must be RELIABLE! That is the bottom line!That is the bottom line!