SPP NERC Compliance

Experience

February 10, 2017

Douglas Bowman, P.E.

dbowman@spp.org

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Background
Section 1

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FERCs Role
Established 1977

Regulates the interstate transmission of

natural gas, oil, and electricity

Protects reliability of high voltage

interstate transmission through
mandatory reliability standards

Monitors and investigates energy

markets

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NERC
Authority given by FERC to develop and enforce
Reliability Standards

Assesses seasonal and long-term reliability

Monitors the bulk electric system through system

awareness

Educates, trains, and certifies industry personnel

Formed to promote reliability and adequacy of bulk

electric transmission system

Bulk electric system includes facilities operation at 100

kV or higher for Transmission Elements

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Regional Entities
NERC works with
REs to improve
reliability
REs monitor and
enforce compliance
on behalf of NERC
NERC oversees the REs
programs to ensure
consistency and fairness
REs are required by law to register with
NERC
REs provide technical expertise and
assistance to Bulk Power System owners
within its footprint
Funded by load-serving entities

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1920 About NERC:
Federal Water Reliability
Power Act created History
Federal Power Commission (FPC)
1935 Federal Power Act of 1935 passed
1977 FPC changed to Federal Energy Regulatory Commission (FERC)
1978 National Energy Act passed (Includes PURPA)
1992 Energy Policy Act of 1992 passed. NERC fosters transmission competition.
1996 FERC issues Order 888. Open Access to transmission facilities
1997 FERC issues Order 889. Required posting of transmission capacity on OASIS
1999 FERC issues Order 2000. NERC encourages participation in ISOs and RTOs
2002 First reliability standards become mandatory and enforceable
2003 Northeast Blackout II
2005 Energy Policy Act of 2005 passed.
2006 NERC applies & becomes an Electric Reliability Organization
2007 FERC issues Order 890. Ensured nondiscriminatory transmission service
2008 FERC issues Order 719
2011 FERC issues Order 1000. Reforms cost allocation requirements for trans

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providers
ISOs and RTOs

To provide improved reliability

Generation dispatched more
efficiently
Improved price transparency
Improved/Easier access to
infrastructure investment
Increased renewables, DR, EE,
Market monitoring results in improved
efficiencies
Greater market flexibility
Increased liquidity in the marketplace
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SPP Compliance
Efforts
Section 2

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Compliance
SPPs corporate wide adherence to national &
regional transmission system reliability
standards, as well as commercial business
practice standards.

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Engineering Standards For
Which SPP Must Be Compliant
FAC - Facilities Design, Connections, and Maintenance
TPL Transmission Planning
MOD Modeling, Data, and Analysis
PRC Protection and Control
CIP Critical Infrastructure Protection

http://www.nerc.net/standardsreports/standardssummary.aspx

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TPL, PRC, CIP
TPL-001-4
Transmission Planning
System performance test (Steady state & Dynamics)

PRC-002
Disturbance Monitoring and Reporting
Determine critical facilities needing disturba nce monitoring equipment

PRC-004-4
Protection System Misoperation

PRC-006-2
Automatic Underfrequency Load Shedding

CIP-002-5
BES Cyber System Categorization
Determining critical facilities for our members to apply cyber protection on for reliability

CIP-014-2

Physical Security

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Audits
Entity that audits SPP SERC
All 693 standards
Engineering (FAC,MOD,TPL,PRC,CIP)
Operations
(BAL,CIP,COM,EOP,INT,IRO,MOD,NUC,PER,TOP,VAR)
3 year cycle (Last audited 2016)
Next audit date will be 2019

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Consequences of Non-Compliance
Sanctions and penalties apply to all FERC
approved standards.
These could range from $1,000 -$1,000,000
per day per violation
The Base Penalty Amount Table
VRFs vs. VSLs
Violation Risk Factor: The impact to the BES
(Lower, Medium, High)
Violation Severity Level: How bad the entity
missed the mark (Lower, Moderate, High,
Severe)

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Consequences of Non-
Compliance

Violation Severity Level

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

Base Penalty Table

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Experience with TPL
Stability Assessments
Section 2

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Transmission Planning
Standards - TPL
System performance test (Steady state & Stability)
Pre-2015
TPL-001-0.1
System in-tact condition (Category A)
TPL-002-0b
Loss of a single BES element (Category A)
TPL-003-0b
Loss of two BES elements (Category A)
TPL-004-0a
Loss of multiple BES elements (Category A)
Beginning 2015
TPL-001-4
A combination of the four listed above
P1 to P7 and Extreme Events
By 12/21/2015
Assessment Complete.
Corrective action plans determined and tested for violations

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Transmission Planning Standard
TPL-001-4 ( Beginning 2015 )

Steady State and Stability System performance Testing

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Transmission Planning
Standard TPL-001-4

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Transmission Planning
Standard TPL-001-4

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TPL-001-4
SPP Assessment - Models

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TPL-001-4
SPP Stability Assessment Member
Events

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TPL-001-4 Stability Assessment
Monitored Parameters

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TPL-001-4 Stability Assessment
Performance Requirements

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TPL-001-4 Stability Assessment
Performance Requirements

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Assessment Plan
Retain member events
Build tool to convert submitted member events to PSS/E format
Build tool to automate PSS/E event simulations
Test Enfuzion Network
Build tool to post-process results
Rotor angle stability
Oscillation damping
Transient Voltage Response

Determine corrective action plans for revealed violations

Test corrective action plans for compliance

Submit final report by 12/31/2015

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TPL Automation Flowchart

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Events Assessed
Pre-2015
TPL-001 TPL-004
Up to 150 events assessed
2 cases
250 simulated events

2015
TPL-001-4
P1 to P7 and Extreme Events
4,582 events assessed
5 cases
22,910 simulated events

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Assessment Results

In December, 2015, SPP submitted a notice to NERC

notifying them of SPPs delay
Assessment Completed February, 2016, 2 months past
deadline
NERC determined SPP fully compliant despite missed
date.

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Lessons Learned
Opportunities for Improvement
Magnitude of the analysis underestimated
Computing resources inadequate for volume of study
Tools constructed on-the-fly required additional time
Lack of hard drive space for advanced analysis
Additional Enfuzion nodes needed to complete large runs created
stress on other SPP Engineering processes;
Limited ability to share resources on multiple machines to divide
large file analysis created delay in producing results
Multiple re-runs required due to invalid member events

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Lessons Learned Successes
3 corrective action plans identified despite high number of
contingencies received
Automated assessment tools developed and implemented
Built greater knowledge of transient stability within SPP staff
Teamwork was excellent
Good stakeholder communication
Good communication with NERC

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Conclusion
New TPL requirements significantly expanded scope of study
work required to maintain requirements with the standard
Required completion date missed
Non-compliance notice provided to NERC prior to expected
completion date
NERC determined SPP was fully compliant
SPP thoroughly assessed its system with respect to all aspects of
stability and found 3 violations requiring corrective action.
New processes, tools, and expertise resulted which will aid SPP in
subsequent annual TPL Stability studies

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