EOP-011-1 - North American Electric Reliability Corporation Technical...•An informal comment...

EOP-011-1Project 2009-03 Emergency Operations

Technical ConferenceJune 24, 2014

RELIABILITY | ACCOUNTABILITY2

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NERC Public Announcement


• Administrative• NERC Antitrust Guidelines and Public Announcement• Background and overview• FERC Directives• Attachment 1 of EOP-011-1 and BAL-002 coordination• Project moving forward• Discussion and recommendations

Agenda


EOP Standard Drafting Team

Member OrganizationDavid McRee, Chair Duke EnergyBob Staton, Vice Chair Xcel EnergyWill Behnke Alliant Energy

Richard Cobb Midcontinent ISO, Inc.Jen Fiegel Oncor Electric DeliveryFran Halpin Bonneville Power AdministrationHal Haugom Madison Gas and ElectricSteve Lesiuta Ontario Power Corporation, Inc.Connie Lowe Dominion Resources Services, Inc.Greg LeGrave Wisconsin Public Service Corp.Brad Young LG&E/KU


• Present information regarding EOP-011-1• Question and Answer (Q&A) at the end of each presentation Q&A session is intended to improve overall understanding Submit questions and comments via the chat feature Some question may require additional team consideration Webinar and chat comments are not part of the project record

• Discussion and Recommendations Submit questions, discussion points and recommendations via the chat

feature Some discussion topics may require additional team consideration Webinar and chat comments are not part of the project record

Conference Objectives


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• Five-Year Review Overview Part of NERC’s broader objective to transition to a clear, concise, and

stable body of world-class, high-quality reliability standards Five-year reviews must be conducted on current standards that are due for

assessment and have not been revised in recent standards development projectso Required by ANSI-accredited Reliability Standards development process

Industry Webinar: Five-Year Review Projects Overview 05/2013

Five-Year Review Projects

http://www.nerc.com/pa/Stand/WebinarLibrary/Five-Year_Review_Webinar_May_8_2013_wjm.pdf


• Five-Year Review Process Standard identified as due for five-year review Standards Committee (SC) appoints a review team of subject matter

experts (SMEs) Recommendation to affirm, revise, or withdraw Recommendations posted for 45-day comment period SC considers commentso Reaffirmed recommendation submitted to NERC Board of Trustees (Board) for

approvalo Revised or withdrawn recommendation results in Review Team developing a

Standard Authorization Request (SAR)



• Five-Year Review Objective Determine whether the Reliability Standard should be:o (1) affirmed;o (2) revised; oro (3) withdrawn.

• Elements of the Five-Year Review FERC directives Stakeholder requests for clarity or revision Results-Based Standards (RBS) principles Paragraph 81 principles



• Five-Year Review Teams Appointed by the SC Comprehensive five-year review of the standard in accordance with NERC’s

Five-Year Review Templateo Template developed with a small team of SC advisorso NERC Staff to perform preliminary FERC directives, RBS, and Paragraph 81

evaluations Review teams include mix of:o Previous members of Drafting Team(s) that wrote the standard(s) being

reviewedo Other industry subject matter experts with relevant experience



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• Nov. 11, 2010 – NERC SC authorized moving the Project 2009-03 Emergency Operations SAR forward to standard drafting and appointed a Standard Drafting Team.

• Project 2009-03 involved reviewing and revising EOP-001-0 EOP-002-2 EOP-003-1 IRO-001-1

• Project 2009-03 was placed on hold in late 2010/early 2011 due to project prioritization.

Project 2009-03 Background


• April 22, 2013 – NERC SC appointed eight SMEs to serve on the Emergency Operations Five-Year Review Team (EOP FYRT) to review and make recommendations regarding: EOP-001-2.1b EOP-002-3.1 EOP-003-2

• August 6–September 19, 2013 – The EOP FYRT developed a set of recommendations which were posted for a 45-day.



• October 17, 2013: NERC SC accepted the recommendations of the EOP FYRT Appointed a drafting team Authorized posting the SAR developed by the EOP FYRT

• November 6–December 5, 2013: SAR posted for comment period.



• EOP-011-1 was drafted by the Emergency Operations Standard Drafting Team (EOP SDT) through the examination and consideration of: Applicable FERC directives EOP FYRT recommendations Independent Expert Report Paragraph 81 criteria SAR

• EOP-011-1 posted for informal comment period so industry could review and help guide the current body of work.Project 2009-03 EOP - Project Page


http://www.nerc.com/pa/Stand/Pages/Project-2009-03-Emergency-Operations.aspx


• An informal comment period for EOP-011-1 was open until Friday, April 28.

• The EOP SDT held a drafting team meeting May 13–15 to review comments and further develop the EOP-011-1 standard.

• EOP-011-1 is scheduled to be posted for the first formal comment period and ballot July 1st.

• Submittal to the Board and subsequent regulatory filing is targeted for the end of 2014 or early 2015.

Key Milestones


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• Project 2009-03 EOP consolidates and replaces EOP-001-2.1b, EOP-002-3.1, and EOP-003-2 with EOP-011-1.

• Project 2008-02 UVLS consolidates and replaces PRC-010-0, PRC-020-1, PRC-021-1, and PRC-022-1 with PRC-010-1.

• The respective performance formerly required by EOP-003-2, Requirements R2, R4, and R7 is reflected in PRC-010-1.

• The EOP and UVLS projects are progressing simultaneously to properly align legacy standard retirements and revised standard implementations.April 10, 2014 EOP and UVLS Joint Webinar

EOP and UVLS Project Coordination

http://www.nerc.com/pa/Stand/WebinarLibrary/UVLS_EOP_UVLS_Webinar_040814.pdf


• Please contact the respective NERC Standards Developers for more information, to schedule an outreach session, or to be added to a project’s email distribution list: Project 2009-03 EOP: Laura Anderson at [email protected] Project 2008-02 UVLS: Erika Chanzes at [email protected]

Additional Information

http://www.nerc.com/pa/Stand/Pages/Project-2009-03-Emergency-Operations.aspx

mailto:[email protected]

http://www.nerc.com/pa/Stand/Pages/Project-2008-02-Undervoltage-Load-Shedding.aspx

mailto:[email protected]



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EOP-011-1 Definition Revision

Proposed revised definitions:Energy Emergency - A condition when a Load-Serving Entity or Balancing Authority has exhausted all other resource options and can no longer meet its expected Load obligations.

This defined term was revised to provide clarity that an Energy Emergency is not necessarily limited to a Load-Serving Entity.


EOP-011-1 Definition Revision

This defined term, or variations of it, is also used in the instances below. The EOP SDT does not believe that the proposed revisions change the reliability intent of these standard or definitions.• BAL-002-WECC – Contingency Reserve• IRO-005-3.1a — Reliability Coordination — Current Day

Operations • MOD-004-1 — Capacity Benefit Margin• INT-004-3 – Dynamic Transfers• Defined term Emergency Request for Interchange

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BAL-002-WECC – Contingency Reserve: This standard becomes enforceable on October 1st, 2014. The EOP SDT does not believe that the proposed definition revision will create any redundancies or gaps in reliability. IRO-005-3.1a — Reliability Coordination — Current Day Operations - This standard was revised under Project 2006-06 and the reference to Energy Emergency was removed from the standard. The standard was approved by the NERC BOT and filed with FERC. NERC has requested that FERC defer action on its petition and is revising this standard under project 2014-03, TOP / IRO Revisions. This project is scheduled to be completed no later than January 31, 2015. The two standard drafting teams are coordinating the definition revision to ensure there are no redundancies. MOD-004-1 — Capacity Benefit Margin: This standard is being retired and replaced with MOD-001-2 — Modeling, Data, and Analysis — Available Transmission System Capability (NERC BOT approved February 6, 2014). The term “energy emergency” is not used in the new standard. The EOP SDT does not believe that the proposed definition revision will create any redundancies or gaps in reliability to the existing approved standard. INT-004-3 – Dynamic Transfers: This standard was a revision to INT-004-2 under Project 2008-12. INT-004-3 was approved by the NERC BOT and filed with FERC. The EOP SDT does not believe that the proposed definition revision will create any redundancies or gaps in reliability. Defined term Emergency Request for Interchange: This term is not used in any existing approved standard.


EOP-011-1 Purpose Statement

Purpose:To mitigate the effects of operating Emergencies by ensuring each Transmission Operator and Balancing Authority has developed Emergency Operating Plans, and that those plans are coordinated within a Reliability Coordinator Area.


EOP-011-1 Functional Entities

Functional Entities:• Balancing Authority• Reliability Coordinator• Transmission Operator


EOP-011-1 Requirement R1

R1. Each Transmission Operator shall develop, maintain and implement a Reliability Coordinator-approved Emergency Operating Plan to mitigate operating Emergencies on its Transmission System. At a minimum, the Emergency Operating Plan shall include the following elements: [Violation Risk Factor: High] [Time Horizon: Real-Time Operations, Operations Planning]



1.1. Roles and responsibilities to activate the Emergency Operating Plan;1.2. Strategies to prepare for and mitigate Emergencies including, at a minimum:

1.2.1. Notification to the Reliability Coordinator, to include current and projected System conditions, when experiencing an operating Emergency;1.2.2. Controlling voltage;1.2.3. Cancelling or recalling Transmission and generation outages;1.2.4. System reconfiguration;1.2.5. Requesting the redispatch of generation;1.2.6. Operator-controlled manual Load shedding plan coordinated to minimize the use of automatic Load shedding;1.2.7. Mitigation of reliability impacts of extreme weather conditions; and

1.3. Strategies for coordinating Emergency Operating Plans with impacted Transmission Operators and impacted Balancing Authorities.

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Rationale for Requirement R1: The EOP SDT examined the recommendation of the EOP FYRT and FERC directive to provide guidance on applicable entity responsibility that was included in EOP-001-2.1b. The EOP SDT removed EOP-001-2.1b, Attachment 1, and incorporated it into this standard under the applicable requirements. This also establishes a separate requirement for the Transmission Operator to create an Emergency Operating Plan. Requirement R1 Part 1.2. was added to this standard for the Transmission Operator to address strategies to prepare for and mitigate Emergencies using voltage control methods, which could include switching of capacitor and reactor banks, generator reactive output and the use of synchronous condensers. If any Parts of Requirement R1 are not applicable, the TOP should note “not applicable” in their plan. The EOP SDT retained the statement “Operator-controlled manual Load shedding,” as it was in the current EOP-003-2 and clarifies the intent of the EOP SDT. The EOP SDT also clarifies the intent of the reference to automatic Load shed schemes that includes both UVLS and UFLS (Comment A – see below) The EOP SDT’s intent is to keep manual and automatic Load shed schemes as separate as possible, but realizes that sometimes, due to system design, there will be overlap. The reference in Requirement R1 Part 1.2.5. and Part 2.2.8. to being “coordinated” is that these mentioned manual and automatic systems be coordinated with each other as to minimize overlap on these systems, it is not intended as a reference to coordinate with other entities. (Comment B – see below)



R2. Each Balancing Authority shall develop, maintain and implement a Reliability Coordinator-approved Emergency Operating Plan to mitigate Capacity and Energy Emergencies. At a minimum, the Emergency Operating Plan shall include the following elements: [Violation Risk Factor: High] [Time Horizon: Real-Time Operations, Operations Planning]

2.1. Roles and responsibilities to activate the Emergency Operating Plan;2.2. Notification to the Reliability Coordinator, to include current and forecasted conditions, when experiencing a Capacity Emergency or Energy Emergency;2.3. Criteria to declare an Energy Emergency Alert, per Attachment 1;



2.4. Strategies to prepare for and mitigate Emergencies including, at a minimum:

2.4.1. Generating resources in its Balancing Authority Area:2.4.1.1. capability and availability;2.4.1.2. fuel supply and inventory concerns; 2.4.1.3. fuel switching capabilities;2.4.1.4. environmental constraints.

2.4.2. Voluntary Load reductions; 2.4.3. Public appeals;2.4.4. Requests to government agencies to implement their programs to achieve necessary energy reductions;2.4.5. Reduction of internal utility energy use;



2.4.6. Customer fuel switching; 2.4.7. Use of Interruptible Load, curtailable Load and demand response;2.4.8. Operator-controlled manual Load shedding plan coordinated to minimize the use of automatic Load shedding; and2.4.9. Mitigation of reliability impacts of extreme weather conditions.

2.5. Strategies for coordinating Emergency Operating Plans with impacted Balancing Authorities and impacted Transmission Operators.

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Rationale for Requirement R2: The EOP SDT took the recommendation of the FYRT and the FERC directive to provide guidance on applicable entity responsibility in EOP-001-2.1b, Attachment 1. The EOP SDT removed EOP-001-2.1b, Attachment 1, and incorporated it into this standard under the applicable requirements. This also establishes a separate requirement for the Balancing Authority to create its Emergency Operating Plan to address Capacity and Energy Emergencies. If any Parts of Requirement R2 are not applicable, the Balancing Authority should note “not applicable” in their plan. The EOP SDT retained the statement “Operator-controlled manual Load shedding,” as it was in the current EOP-003-2 and clarifies the intent of the EOP SDT. The EOP SDT also clarifies the intent of the reference to automatic Load shed schemes that includes both UVLS and UFLS. The EOP SDT’s intent is to keep manual and automatic Load shed schemes as separate as possible, but realizes that sometimes, due to system design, there will be overlap. The reference in Requirement R2 Part 2.2.5. and Part 2.2.8. to being “coordinated” is that these mentioned manual and automatic systems be coordinated with each other as to minimize overlap on these systems. It is not intended as a reference to coordinate with other entities. The EOP SDT retained Requirement R8 from EOP-002-3.1 and added it to the Requirement R2 parts.



R3. Each Reliability Coordinator shall approve or disapprove, with stated reasons for disapproval, Emergency Operating Plans submitted by Transmission Operators and Balancing Authorities within 30 calendar days of submittal. [Violation Risk Factor: Medium] [Time Horizon: Operations Planning ]

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Rationale for R3: Since Requirements R1 and R2 both require a submittal for approval, Requirement R3 requires approval or disproval. This aligns with similar requirements in EOP-006-2, Requirement 5.1.



R4. Each Reliability Coordinator that receives an Emergency notification from a Transmission Operator or Balancing Authority shall notify, as soon as practical, other impacted Reliability Coordinators, Balancing Authorities and Transmission Operators. [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]

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Rationale for R4: The EOP SDT added the words “as soon as practical” to the requirement to point to the timeliness and to the relevancy of the Emergencies and to alleviate excessive notifications on Balancing Authorities and Transmission Operators. This was an existing requirement in EOP-002-3.1 for Balancing Authorities.



R5. Each Reliability Coordinator that has a Balancing Authority experiencing a potential or actual Energy Emergency within its Reliability Coordinator Area shall initiate an Energy Emergency Alert, as detailed in Attachment 1. [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]

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Rationale for R5: Requirement R5 was created to address the FERC directive to have the Reliability Coordinator involved to ensure that the Energy Emergency Alert gets initiated.



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FERC Directives

FERC DirectivesIn the development of the proposed EOP-011-1 reliability standard, the EOP SDT addressed the outstanding FERC directives in Order No. 693 related to Emergency Operations and planning.


FERC Directives

EOP-001-1 Emergency Operations Planning: • Include reliability coordinators as an applicable entity.• Consider Southern California Edison’s and Xcel’s suggestions in the

standard development process.• Clarify that the 30-minute requirement in requirement R2 to state

that Load shedding should be capable of being implemented as soon as possible but no more than 30 minutes.

• Includes definitions of system states (e.g., normal, alert, emergency), criteria for entering into these states. And the authority that will declare them.

• Consider a pilot program (field test) for the system states proposal.• Clarifies that the actual emergency plan elements, and not the “for

consideration” elements of Attachment 1, should be the basis for compliance.


FERC Directives

EOP-002-2 Capacity and Energy Emergencies: • Address emergencies resulting not only from insufficient

generation but also insufficient Transmission capability, particularly as it affects the implement of the capacity and energy Emergency plan.

• Include all technically feasible resource options, including demand response and generation resources.

• Ensure the TLR procedure is not used to mitigate actual IROL violations.


FERC Directives

EOP-003-1 Load Shedding Plans: • Develop specific minimum Load shedding capability that should

be provided and the maximum amount of delay before Load shedding can be implemented based on overarching nationwide criteria that take into account system characteristics.

• Require periodic drills of simulated Load shedding.• Suggest a review of industry best practices in determining

nationwide criteria.• Consider comments from APPA and ISO-NE in the standards

development process.


FERC Directives

• Order No. 693 at P 573 “Demand response covers considerably more resources than interruptible load. Accordingly, the Commission directs the ERO to modify the Reliability Standard to include all technically feasible resource options in the management of emergencies. These options should include generation resources, demand response resources and other technologies that meet comparable technical performance requirements.”

• Order No. 693 at P 595: “The Commission directs the ERO to address the minimum load and maximum time concerns of the Commission through the Reliability Standards development process.”


FERC Directives

• Order No. 693 at P 548: “Further we agree with SoCal Edison that clear direction is needed on which requirements should be exclusive to transmission operators and balancing authorities with the reliability coordinator being responsible for incorporating this information into its overarching plan. Accordingly, the Commission finds the reliability coordinator is a necessary entity under EOP-001-0 and directs the ERO to modify the Reliability Standard to include the reliability coordinator as an applicable entity. In addition, the ERO should consider SoCal Edison’s suggestion in the ERO’s Reliability Standards development process..”


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Attachment 1 – EOP and BAL-002

Attachment 1• Operating Reserves removed from EEA 2 and added it to EEA 3

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Please discuss EOP SDT removed the deployment of reserves from EEA 2 and added it in EEA 3. This resolves the issues with the present BAL-002 and EOP-002 requiring actions that are not in sync with each other.


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