Professional Documents
Culture Documents
2
Electric Reliability Authority
Congress
• Energy Policy Act of 2005
FERC
• Establishes ERO
NERC
• Drafts Policy
Regional Entities
• Enforces Policy
3
Reliability Prior to
June 18, 2007
4
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."
5
Bulk Power System
6
Registration & Compliance
Responsibilities
7
NERC Basis for Registration
8
NERC Regional Entities
RFC NPCC
9
NERC Reliability Standards
Compliance Monitoring & Enforcement
10
Compliance Monitoring
Self Certification
Audit Spot Check • Periodic Data
Submittal May Apply
to Some Standards
11
Handling Violations
Violation Discovery
• Flaw in compliance found and reported
Mitigation Plan
• Implementing changes to prevent reoccurrence
12
Violation Discovery
13
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
14
Penalties and Settlements
15
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
16
Base Penalty Amounts
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
17
NERC Standards in 2011
Number of Reliability Standards
Compliance Audit 39 60 49 56 38
Self-Certification 39 60 52 60 51
Exception Reporting -- -- 14 19 13
Spot Check 0 0 13 19 14
Subject to Compliance
Violation Investigation -- -- 94 95 102
18
NERC Reliability Standard PRC-005
Maintenance and Testing of
generation Protection Systems
19
Defining generation Protection
Systems
20
Maintenance and Testing: Program
Specification
21
Maintenance and Testing:
Program Data Collection
Intervals
• Evidence when last maintained
• Evidence when last tested
• Must match intervals described in Requirement 1.1
Evidence
• Test reports
• Maintenance sheets, logbooks, etc.
• Anything showing the task was performed and documented
22
generation Protection System
Documentation
• Provide Maintenance and Testing
Program Program To the Regional Entity and
NERC on request
23
24
So Why is the g in generation
Protection System Lowercase?
Capitalized letters indicate a NERC defined term in the NERC
Glossary of Terms
25
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
26
Where do we go wrong?
27
Where do we go wrong?
Missed
• Failed to test or maintain within the
Testing or intervals established by your own plan
Maintenance
28
Where do we go wrong?
29
PRC-005 Violations by Region
250
200
208
150
50
53 56 57
31 30
0
Multiple
Functions
181_Violations
28%
Audit
208 Violations
32%
Spot Check
23 Violations
3%
300 VAR
200 EOP
100
Other
0
34
Know Your Protection Systems
Protection Systems
Protective
Batteries Communications DC Circuitry Instrument Transformers
Relays
CCVTs CVTs
35
Keep Meticulous Records
36
Know Your Intervals
37
Inventories and Summaries
38
And in General…
39
As always, live, breathe and
exude a culture of compliance
40