2014 Annual Compliance Assessment

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3 2014 Annual Compliance Assessment 3/5/2015 Nevada Irrigation District Report on Compliance with the NERC and WECC Reliability Standards

4 NEVADA IRRIGATION DISTRICT 2014 ANNUAL REPORT ON COMPLIANCE Introduction This report represents the first annual report on Nevada Irrigation District s compliance with the North American Electric Reliability Corporation (NERC) and Western Electricity Coordinating Council (WECC) mandatory Reliability Standards. 1 This annual report is required by the NID internal compliance program (ICP) to inform the NID Board and management of the status of NID s NERC and WECC compliance program. Table of Contents Introduction... 2 Table of Contents... 2 Executive Summary... 4 Background... 4 NID Compliance Activities... 6 Generator Owner Compliance... 6 Generator Owner Reliability Standards... 6 CIP Cyber Security Critical Cyber Asset Identification... 8 CIP Cyber Security Security Management Controls... 8 EOP Event Reporting... 8 FAC Facility Connection Requirements... 9 FAC Coordination of Plans for New Facilities... 9 FAC Facility Ratings... 9 IRO-010-1a Reliability Coordinator Data Specification and Collection... 9 MOD Steady-State Data for Transmission System Modeling and Simulation... 9 MOD Dynamics Data for Transmission System Modeling and Simulation The use of capitalized terms in this document indicates that the term is a defined term from either the NERC Glossary of Terms Used in Reliability Standards or Appendix 2 to the NERC Rules of Procedure: Definitions Used in the Rules of Procedure. Page 2 of 19

5 PRC a Analysis and Mitigation of Transmission and Generation Protection System Misoperations PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation PRC b Transmission and Generation Protection System Maintenance and Testing PRC Special Protection System Data and Documentation PRC Special Protection System Misoperations PRC Special Protection System Maintenance and Testing PRC Disturbance Monitoring Equipment Installation and Data Reporting PRC and PRC Transmission Relay Loadability VAR-002-2b and VAR Generation Operation for Maintaining Network Voltage Schedules. 13 Generator Operator Compliance Generator Operator Reliability Standards BAL b Automatic Generation Control COM Communication and Coordination EOP System Restoration from Blackstart Resource IRO Reliability Coordination Responsibilities and Authorities IRO a Reliability Coordination Current Day Operations PRC System Protection Coordination TOP-001-1a - Reliability Responsibilities and Authorities TOP b Normal Operations Planning TOP Planned Outage Coordination TOP Monitoring System Conditions VAR and VAR Voltage and Reactive Control VAR-002-2b and VAR Generator Operation for Maintaining Network Voltage Schedules VAR-002-WECC-1 Automatic Voltage Regulators VAR-501-WECC-1 Power System Stabilizers The Year Ahead Compliance Outlook for Conclusion Page 3 of 19

6 Executive Summary The Nevada Irrigation District (NID) is compliant with the applicable Reliability Standards for the Generator Owner for which it is registered with the Western Electricity Coordinating Council (WECC). NID is also compliant with the limited Generator Operator Reliability Standards Requirements that NID has agreed to comply with if NID must remain registered as a Generator Operator. NID s registration status as a Generator Operator, however, remains unanswered. As described below, NID is currently embroiled in a dispute with the North American Electric Reliability Corporation (NERC) and WECC, and PG&E, over whether NID should be registered as a Generator Operator. This issue should be resolved in NID has made significant strides in its first year of meeting the requirements of NERC and WECC Reliability Standards. In 2014, NID took commendable steps to develop, train, and implement the required policies, procedures, and organizations to become and maintain compliance with the applicable Reliability Standards. This report summarizes the reliability compliance efforts put forth by NID in 2014 and anticipates the efforts needed in 2015 and beyond to remain compliant with the NERC and WECC Reliability Standards. Background The implementation of first voluntary and, more recently, mandatory reliability standards has been a classic tale of cause and effect, action and reaction. In 1965, a blackout cut off the power to over 30 million people throughout the northeastern U.S. and eastern Canada. Shortly thereafter, in 1967, Congress passes the U.S. Electric Power Reliability Act which proposes the creation of a council on power coordination. In 1968, the National Electric Reliability Council (later the North American Electric Reliability Council, then the North American Electric Reliability Corporation) is formed to coordinate regional power coordination organizations and to exchange operational information and best practices. In 1977, another East Coast blackout led to the first electric reliability legislation which enabled the federal government to propose voluntary standards, an authority never exercised. Then, in August of 1996, two large scale outages on the Western Interconnection led to the creation of the first mandatory reliability standards through the contractual Reliability Management System managed by the Western Systems Coordinating Council (which later became the Western Electricity Coordinating Council). About this time, legislation calling for enforceable mandatory reliability standards began to be introduced to Congress. On August 14, 2003, a cascading outage left over 50 million people throughout the northeastern U.S. and eastern Canada. In response, Congress included Section 1211 in the omnibus Energy Policy Act of This section modified the Federal Power Act to require the creation of an Electric Reliability Organization under the oversight of the Federal Energy Regulatory Commission (FERC), and the development of mandatory and enforceable reliability standards for operations and planning as well as Critical Infrastructure Protection (CIP). NERC would become certified as the Electric Reliability Page 4 of 19

7 Organization by FERC the following year. The regulations established under this regime require utilities over the threshold of NERC s Compliance Registry Criteria 2 to register with their Regional Entity, such as WECC, and comply with the reliability standards that apply to their registered functions (e.g. Generator Owner, Generator Operator, or Balancing Authority). The Reliability Standards became effective on June 18, 2007 for the operations and planning standards and on July 1, 2008 for the initial version of the CIP standards. For generation, the Registry Criteria require registration with the Regional Entity and NERC for those units that are at least 20 MVA, or an aggregate 75 MVA for generation units connected at one interconnection point. As a Generator Owner that exceeds the NERC registry criteria (Dutch Flat 2 operates at 26.0 MVA, Chicago Park at 41.5 MVA) NID is required to register as a Generator Owner. NID submitted its initial registration application to WECC for its Generator Owner function on April 1, 2014 and was entered on the NERC Compliance Registry as both a Generator Owner and Operator on May 21, According to NERC and WECC, each Generator Owner must also have an attendant Generator Operator. PG&E has operated NID s hydroelectric Facilities at Chicago Park and Dutch Flat 2 since their initial construction, under the terms of the Partnership Agreement. This underlying relationship between NID and PG&E was reaffirmed under NID s Power Purchase Agreement (PPA) with PG&E (with a term that began on July 1, 2013 and terminates on July 1, 2033), where PG&E remains primarily responsible for the generator operations and also performs the Scheduling Coordinator function for NID in the California Independent System Operator (CAISO) electricity market. It is because of this arrangement that NID challenged its registration as a Generator Operator. In preparing for this registration appeal, NID worked closely with Peter Harman from the Minasian Law Firm and GridSME to put forth legal and technical arguments detailing why NID has been incorrectly registered as a Generator Operator. Currently, the registration appeal is scheduled to be heard by the NERC Board of Trustees Compliance Committee (BOTCC) on April 13, 2015 but that date is subject to change. If NID loses the appeal, it could still appeal that decision to FERC and eventually to the United States Court of Appeals for District of Columbia Circuit. NID has also pursued a second track to ensure compliance with the Reliability Standards if its registration appeal is not successful. NID and PG&E have agreed to split the obligations of the Generator Operator under a Coordinated Functional Registration (CFR) Agreement if NID s registration appeal is rejected by the NERC BOTCC. A CFR is type of agreement is authorized by the NERC Rules of Procedure where two or more entities (parties) agree in writing upon a division of compliance responsibility among the parties for one or more Reliability Standard(s) applicable to a particular function, and/or for one or more Requirement(s)/sub-Requirement(s) within particular Reliability Standard(s). 2 Statement of Compliance Registry Criteria, Appendix 5B to the NERC Rules of Procedure (2012). Available at Page 5 of 19

8 NID and PG&E reached agreement on the terms of a CFR Agreement in negotiations that concluded on January 22, The CFR Agreement includes a backdate to May 21, 2014 when the NID was originally registered with NERC. This CFR Agreement reaffirms PG&E s role as the Generator Operator for the NID s hydroelectric Facilities and limits NID s Generator Operator compliance activities to very limited activities and circumstances. The CFR Agreement is currently in the process of receiving signatory execution by PG&E. NID Compliance Activities On January 22, 2014, NID adopted an Internal Compliance Program (ICP) which established the Reliability Oversight Compliance Committee (ROCC). A robust ICP, such as the one established by NID, is strongly encouraged by FERC, NERC, and WECC. It is the belief of these regulators that a well-designed and implemented ICP will help prevent, minimize, and effectively mitigate reliability issues. Consequently, NERC and WECC therefore assign mitigating credit to entities with effective ICPs thereby reducing penalty assessments following compliance violations. Throughout 2014, NID s ROCC met regularly, as required by their ICP, to discuss NERC and WECC reliability compliance and other associated issues affecting NID. The ROCC is comprised of NID management including the Assistant General Manager (Tim Crough), Hydroelectric Manager (Keane Sommers), the Hydroelectric Compliance Analyst (Jacqueline Longshore), and the Information Technology Analyst (JR Lewis). This annual reliability compliance report is prepared under the requirements of NID s Internal Compliance Program. To monitor the progress of NID s compliance activities, GridSME conducted a table top audit and review of NID s NERC and WECC compliance by reviewing NID s evidence and the WECC-distributed Reliability Standard Audit Worksheets (RSAWs) on October 24, This session focused on the three standards most likely to result in a violation for NID (1) PRC b Transmission and Generation Protection System Maintenance and Testing, (2) CIP Cyber Security Critical Cyber Asset Identification, (3) PRC a - Analysis and Mitigation of Transmission and Generation Protection System Misoperations (4) PRC System Protection Coordination. On December 10, 2014, GridSME and NID conducted an RSAW training session in which we reviewed evidence supporting NID s compliance with FAC Facility Ratings Methodology and PRC b in detail. Finally, on January 5, 2015, as part of the annual compliance review for NID s first self-certification of compliance, NID and GridSME reviewed the entirety of NID s compliance with the Reliability Standards for While no potential violations were discovered during this review, several areas for improvement were noted and such changes are currently under development. NID submitted the self-certification results to WECC on February 2, 2015 and the NID Board of Directors on February 11, Generator Owner Compliance Generator Owner Reliability Standards Generator Owner Reliability Standards Title Page 6 of 19

9 CIP Cyber Security Critical Cyber Asset Identification CIP EOP FAC FAC FAC IRO-010-1a MOD MOD MOD MOD PRC a PRC-004-WECC-1 PRC b PRC PRC PRC PRC PRC-023-2, PRC Cyber Security Security Management Controls Event Reporting Facility Connection Requirements Coordination of Plans for New Facilities Facility Ratings Reliability Coordinator Data Specification and Collection Steady-State Data for Transmission System Modeling and Simulation Dynamics Data for Transmission System Modeling and Simulation Verification of Models and Data for Generator Excitation Control System or Plant Volt/Var Control Functions Verification of Models and Data for Turbine/Governor and Load Control or Active Power/Frequency Control Functions Analysis and Mitigation of Transmission and Generation Protection System Misoperations Protection System and Remedial Action Scheme Misoperation Transmission and Generation Protection System Maintenance and Testing Special Protection System Data and Documentation Special Protection System Misoperations Special Protection System Maintenance and Testing Disturbance Monitoring Equipment Installation and Data Reporting Transmission Relay Loadability CIP-002-3, CIP-003-3, and EOP apply to both the Generator Owner and Generator Operator function but do not require specific actions for each function. Therefore, this report only describes the compliance activities for these standards once in the Generator Owner section. Page 7 of 19

10 VAR-002-2b, VAR Generator Operation for Maintaining Network Voltage Schedules CIP Cyber Security Critical Cyber Asset Identification Standard CIP requires the identification and documentation of the Critical Cyber Assets associated with the Critical Assets that support the reliable operation of the Bulk Electric System. NID and GridSME developed a Risk-Based Assessment Methodology (RBAM) for the identification of Critical Assets in accordance with the requirement R1 of CIP NID conducted the RBAM on March 24, The result of the RBAM confirms that NID does not own or operate any Critical Assets. Accordingly, NID does not own or operate any Critical Cyber Assets. Specifically, the RBAM team of Hydroelectric Manager (Keane Sommers), Senior Hydroelectric Systems Technician (Bob Carr), Hydroelectric Systems Technician (Steve Wilson), and Hydroelectric Generation Supervisor (Jerry Green) analyzed the Chicago Park and Dutch Flat 2 Powerhouses and switchyards and determined that none of those Facilities are Critical Assets under the NID RBAM. Keane Sommers, acting as the CIP Senior Manager, signed off on the procedure attesting that the null list is complete and accurate on March 24, This RBAM requires annual approval by the CIP Senior Manager. CIP Cyber Security Security Management Controls CIP requires applicable entities to have certain security management controls in place to protect their Critical Cyber Assets including cyber security policies, cyber security leadership, information protection, and access controls. However, because much of CIP only applies to entities that own Critical Cyber Assets and NID does not have any Critical Cyber Assets, NID only needs to comply with Requirement R2 of CIP In accordance with R2, NID designated Keane Sommers, NID s Hydroelectric Manager, as the CIP Senior Manager for NID on April 11, This satisfies Requirement R2. An acknowledgement form was signed by Remleh Scherzinger and Keane Sommers on February 2, 2014 and October 21, Currently, there are no delegations of CIP Senior Manager authority from Keane Sommers to any other NID staff member. EOP Event Reporting This standard became effective January 1, NID upheld compliance with this standard throughout 2014 including filing quarterly reports with WECC on October 1, 2014 and January 8, There were no events in 2014 that required the initiation of NID s Emergency Operations Plan. Under the CFR Agreement with PG&E, NID is responsible for EOP as it pertains to its own Facilities and operations. NID will notify PG&E and local law enforcement, as necessary, in accordance with their Emergency Operations Plan. This standard also requires that NID validate its contact information at least annually. In 2014, NID validated its contact information with PG&E s Drum Switching Center and the California ISO (CAISO) through its normal course of business. NID also participated in a regional Emergency Action Plan which involved the Placer County Sheriff s Office, Nevada County Sheriff s Office, and California Highway Patrol, among several others, on October 29, As part of the Emergency Page 8 of 19

11 Action Plan NID updates contact information with all local and many State/Federal Emergency response agencies. FAC Facility Connection Requirements This standard requires Generator Owners to establish Facility connection and performance requirements. However, this standard does not apply to NID, as NID does not currently have an executed Agreement to evaluate the reliability impact of interconnecting a third party Facility to the Generator Owner s existing Facility that is used to interconnect to the interconnected Transmission systems. FAC Coordination of Plans for New Facilities The FAC Reliability Standard requires the coordination of plans for the interconnection of new Facilities. This standard does not apply to NID, as NID is not, nor does it plan to interconnect additional generation facilities. NID maintains a signed affidavit that attests to this fact. The affidavit was signed by Keane Sommers on March 24, FAC Facility Ratings The purpose of this standard is to ensure that Facility Ratings used in the reliable planning and operation of the Bulk Electric System is based on technically sound principles. These Facility Ratings, in turn, are used to develop System Operating Limits. Accordingly, this standard requires NID to have a documented methodology for determining its Facility Ratings. NID is compliant with this standard. NID implemented its facility ratings methodology in July, IRO-010-1a Reliability Coordinator Data Specification and Collection IRO-010-1a Requirement R3 requires Generator Owners and Operators to submit data to their Reliability Coordinator upon request. NID signed an affidavit on June 4, 2013 attesting to the fact that, it has not had any affirmative duties under IRO-010-1a. That remains true as of this writing. Additionally, in the Western Interconnection the Reliability Coordinator, Peak Reliability, does not seek information directly from Generator Owners and PG&E has agreed to be the responsible party to perform this Requirement on behalf of the Generator Operator. MOD Steady-State Data for Transmission System Modeling and Simulation MOD-010 requires generators to prepare and provide steady state equipment characteristics, system data, and existing and future Interchange Schedules to its Regional Entity upon request. Historically, PG&E has been responsible for modeling NID s hydroelectric projects and providing that data to the proper parties, when necessary. In 2013, NID hired Kestrel Power Engineering to perform its MOD Steady-State and MOD Dynamic Modeling. This modeling was completed for the Chicago Park Powerhouse on April 30, 2014 with a final report complete on July 24, The modeling was completed for the Dutch Flat No. 2 Powerhouse on May 1, 2013 with a final report complete on July 24, Accordingly, NID is fully compliant with MOD-010 and MOD-012. Page 9 of 19

12 MOD Dynamics Data for Transmission System Modeling and Simulation Similar to MOD-010-0, MOD requires generators to provide modeling data upon request but for dynamic system modeling data. Historically, PG&E has been responsible for modeling NID s applicable hydroelectric Facilities and providing that data to the proper parties, when necessary. In 2013, NID hired Kestrel Power Engineering to perform its MOD Steady-State and MOD Dynamic Modeling. This modeling was completed for the Chicago Park Powerhouse on April 30, 2014 with a final report complete on July 24, The modeling was completed for the Dutch Flat No. 2 Powerhouse on May 1, 2013 with a final report complete on July 24, Accordingly, NID is fully compliant with MOD-010 and MOD-012. MOD Verification of Models and Data for Generator Excitation Control System or Plant Volt/Var Control Functions MOD is a new standard that became effective on July 1, The purpose of this standard is: To verify that the generator excitation control system or plant volt/var control function model (including the power system stabilizer model and the impedance compensator model) and the model parameters used in dynamic simulations accurately represent the generator excitation control system or plant volt/var control function behavior when assessing Bulk Electric System (BES) reliability. Requirements R2, R3, R4, and R5 of this standard are applicable to NID. None of these Requirements mandate affirmative action at this time. While the majority of the standard became enforceable in 2014, Requirement R2 of the standard will not become enforceable until July 1, However, under Requirement R4 NID will need to provide revised modeling data to its Transmission Planner (CAISO) for its units that exceed 75MVA within 180 days of making a change to the excitation control system or plant volt/var control function that alter the equipment response characteristic. No action is currently required for the remaining Requirements unless and until NID receives a request from its Transmission Planner. When R2 becomes effective in 2018, NID will need to submit the specified modeling information to its Transmission Planner on or before July 1, MOD Verification of Models and Data for Turbine/Governor and Load Control or Active Power/Frequency Control Functions MOD is a new standard that became effective on July 1, NERC has stated that the purpose of this standard is: To verify that the turbine/governor and load control or active power/frequency control model and the model parameters, used in dynamic simulations that assess Bulk Electric System (BES) reliability, accurately represent generator unit real power response to system frequency variations. Page 10 of 19

13 The form of MOD closely parallels that of MOD As with MOD-026-1, NID will not be required to affirmatively perform any actions at this time. Also, like MOD-026-1, Requirement R2 will not become effective until July 1, On or before that date, NID will need to provide a verified turbine/governor and load control or active power/frequency control model to its Transmission Planner for its units that exceed 75MVA. Additionally, Requirement R4 requires NID to provide revised model data to its Transmission Planner for an applicable unit within 180 calendar days of making changes to the turbine/governor and load control or active power/frequency control system that alter the equipment response characteristic. Finally, Requirement R3 will only require action by NID, if NID receives a written request from its Transmission Planner to provide information. PRC a Analysis and Mitigation of Transmission and Generation Protection System Misoperations The PRC a Reliability Standard aims to ensure all transmission and generation Protection System Misoperations affecting the reliability of the Bulk Electric System (BES) are analyzed and mitigated. This standard requires NID is required to analyze its BES generators and generator interconnection Facilities Protection System Misoperations, and develop and implement a Corrective Action Plan to avoid similar future Misoperations. NID developed a Misoperations Reporting Procedure and Trip Reporting Procedure and Form in accordance with PRC-004-2a and WECC criteria PRC-003-WECC-CRT-1.2. NID implemented its Misoperation Protection System Reporting procedure on June 4, Since registration, there have not been any Misoperations that necessitated the submission of an operations report to WECC. NID files quarterly reports with WECC indicating whether there were any operations of its applicable Protection Systems during the previous quarter. Quarterly data submittals to WECC were entered into WECC s secure compliance portal webcdms on October 8, 2014 and January 13, PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation PRC-004-WECC-1 is a FERC-approved WECC regional Reliability Standard that seeks to ensure all transmission and generation Protection System and Remedial Action Scheme (RAS) Misoperations on Transmission Paths and RAS defined in [ the Major WECC RAS table] are analyzed and/or mitigated. NID is not subject to PRC-004-WECC-1. PRC-004-WECC-1 only applies to generators in the WECC region that own (RAS) equipment listed in the Table titled Major WECC Remedial Action Schemes (RAS) provided at % pdf. Even though NID does not own or operate any RAS equipment, NID is still required to submit, and has submitted, quarterly reports to WECC on this standard via webcdms on October 8, 2014 and January 13, 2015 Page 11 of 19

14 PRC b Transmission and Generation Protection System Maintenance and Testing The purpose of PRC b is to ensure all transmission and generation Protection Systems affecting the reliability of the Bulk Electric System (BES) are maintained and tested. PRC b is also one of the most commonly violated Reliability Standards. This standard requires applicable entities to have a maintenance and testing plan, that includes maintenance and testing intervals and their basis, and to implement that plan in a manner that ensures the intervals are not exceeded. NID has developed and implemented a Protection System Maintenance Program in accordance with PRC b. This Protection System Maintenance Program sets the maintenance and testing intervals for NID s BES Protection Systems, and sets forth the bases for those intervals. NID s Protection System Maintenance Program was approved by NID management on May 14, NID has not been requested to provide any information on its Protection System Maintenance Program by its Regional Entity (WECC) for evidence in support of PRC b Requirement R2. NID has done an excellent job of maintaining and testing its Protection Systems in accordance with its Protection System Maintenance Program. Jacqueline Longshore maintains an evidence folder of all maintenance and testing activities performed by NID maintenance and operations staff. Moreover, NID is already prepared for the upcoming PRC Reliability Standard that will become effective on April 1, In developing the current Protection System Maintenance Program, GridSME and NID made sure that the program adopted by NID would address both the current and future version of the standard. Following the table-top audit and RSAW training seminar, NID and GridSME have undertaken efforts to improve NID s data organization and storage of PRC-005 evidence, which will facilitate knowledge transfer within NID and, if necessary, with WECC auditors. PRC Special Protection System Data and Documentation PRC requires that Special Protection Systems are properly designed, coordinated, and meet performance requirements. NID does not own any special protection systems and is therefore not subject to this standard. NID maintains an affidavit signed by Keane Sommers on March 24, 2014 affirming this fact. PRC Special Protection System Misoperations Similar to PRC a, PRC requires that responsible entities perform an analysis of operations that occur on their special protection systems. NID does not own any special protection systems and is therefore not subject to this standard. PRC Special Protection System Maintenance and Testing This standard is very similar to PRC b, in that it requires a maintenance and testing plan, but is only for special protection systems. NID does not own any special protection systems and is therefore not subject to this standard. This standard will be retired on April 1, Page 12 of 19

15 PRC Disturbance Monitoring Equipment Installation and Data Reporting PRC sets forth requirements for disturbance monitoring equipment installation and data reporting. NID does not own any disturbance monitoring equipment and is therefore not subject to this standard. NID maintains an affidavit signed by Keane Sommers on March 24, 2014 affirming this fact. PRC and PRC Transmission Relay Loadability PRC replaced PRC on October 1, PRC (like PRC-023-2) addresses transmission relay loadability but only applies to a limited set of generators that have a load-responsive phase protection system(s). NID does not own any of the equipment listed in Attachment A to this standard and is therefore not an applicable entity for compliance. VAR-002-2b and VAR Generation Operation for Maintaining Network Voltage Schedules VAR replaced VAR-002-2b on October 1, These standards require Generator Owners to provide their Transmission Operator and Transmission Planner with certain information regarding its step-up and auxiliary transformers within 30 calendar days of a request and ensure that transformer tap positions are changed according to the specifications provided by the Transmission Operator. Thus far, NID has neither received a request from its Transmission Operator for this information nor has it been provided specifications for setting the transformer tap settings. If NID receives a request for either, it will fulfill the request. The one major change between VAR-002-2b and VAR is that Generator Owners, not generator Operators, are now responsible for ensuring that transformer tap positions are changed according to the specifications provided by the Transmission Operator, unless such action would violate safety, an equipment rating, a regulatory requirement, or a statutory requirement. Additionally, if the Generator Owner cannot comply with the Transmission Operator s specifications, the Generator Owner shall notify the Transmission Operator and shall provide the technical justification. NID did not receive any requests from its Transmission Operator to change its tap positions. If NID receives such a request, NID intends to fully comply with such a request or provide justification for why the request cannot be fulfilled. Generator Operator Compliance Generator Operator Reliability Standards Generator Operator Reliability Standards BAL b CIP Title Automatic Generation Control Cyber Security Critical Cyber Asset Identification Page 13 of 19

16 Generator Operator Reliability Standards CIP COM EOP EOP IRO IRO a PRC TOP-001-1a TOP b TOP TOP VAR-001-3, VAR VAR-002-2b, VAR VAR-002-WECC-1 VAR-501-WECC-1 Title Cyber Security Security Management Controls Communication and Coordination Event Reporting System Restoration from Blackstart Resources Reliability Coordination Responsibilities and Authorities Reliability Coordination Current Day Operations System Protection Coordination Reliability Responsibilities and Authorities Normal Operations Planning Planned Outage Coordination Monitoring System Conditions Voltage and Reactive Control Generator Operation for Maintaining Network Voltage Schedules Automatic Voltage Regulators Power System Stabilizers BAL b Automatic Generation Control This requirement mandates that each generator operator ensures that its Facilities are within the metered bounds of a Balancing Authority. Currently, this requirement is to be performed solely by PG&E. NID does not need to take any action to comply with this standard at this time. COM Communication and Coordination The goal of the COM Reliability Standard is to ensure Generator Operators have adequate communications and that these communications capabilities are staffed and available for addressing a real-time emergency condition. Specifically, this standard requires that Generator Operators have voice and data links with its Transmission Operator, Balancing Authority, and Reliability Coordinator. This requirement is to be performed solely by PG&E under the terms of the CFR Agreement. Page 14 of 19

17 EOP System Restoration from Blackstart Resource This standard addresses system restoration from a Blackstart Resource. PG&E has accepted responsibility for this standard; however, it is not applicable to NID. NID owns blackstart capable units but does not maintain a Blackstart Resource that is part of any Transmission Operator s system restoration plan. IRO Reliability Coordination Responsibilities and Authorities Requirement R8 of this standard requires that a Generator Operator comply with directives from its Reliability Coordinator unless such actions would violate safety, equipment, or regulatory or statutory requirements. Under those enumerated circumstances, the Generator Operator must immediately inform the Reliability Coordinator of the inability to perform the directive so that the Reliability Coordinator may implement alternate remedial actions. This requirement is to be performed solely by PG&E, and PG&E has accepted responsibility for this task under the terms of the CFR Agreement. Consequently, NID does not need to perform any actions to comply with this standard. IRO a Reliability Coordination Current Day Operations This standard addresses operating parameters and limits and requires that if there is a difference in derived limits between a Generator Operator and a reliability entity (i.e. a Reliability Coordinator, Balancing Authority, or Transmission Operator) Generator Operators must operate to the most limiting parameter. This requirement is to be performed solely by PG&E under the terms of the CFR Agreement. PRC System Protection Coordination NID is currently required to maintain compliance with three of the four Generator Operator requirements of this standard under the terms of the CFR. The purpose of this standard is to ensure system protection is coordinated among operating entities. Specifically, this standard requires that (Requirement R1) each Generator Operator be familiar with the purpose and limitations of protection system schemes applied in its area; (Requirement R2) Generator Operators shall notify their reliability entities of relay or equipment failures; (Requirement R3) coordinate new protective systems and changes; and (Requirement R5) coordinate changes in generation, transmission, load or operating conditions that could require changes in the protection systems of others. Currently, NID is responsible for performance of Requirement R1 and is partially responsible for Requirements R3 and R5; namely, NID must notify PG&E if NID makes changes in the protective system or changes that affect the generation or operating conditions of NID s Facilities. PG&E perform is wholly responsible for Requirement R2 under the terms of the proposed CFR. To satisfy Requirement R1, GridSME led a training session at NID s Colfax office for NID operators on December 16, The training courses provided an overview of the Protection and Control (PRC) family of Reliability Standards, an overview of relay protection schemes and devices, and best practices. Page 15 of 19

18 If NID is called upon to contact PG&E following changes to its Protection Systems or generating or operating conditions that may require changes to PG&E s Protection Systems, NID will need to maintain evidence of those instances. This will need to demonstrate that NID is coordinating new protective systems as well as generation and operation changes both internally and externally with PG&E. It may also be helpful for NID to develop an operator training policy which sets forth what type(s) of training or competencies operators must obtain and how often the operators must refresh their training. TOP-001-1a - Reliability Responsibilities and Authorities The requirements associated with this standard are performed solely by PG&E under the terms of the CFR Agreement. This standard requires that the Generator Operator comply with reliability directives issued by the Reliability Coordinator, and with reliability directives issued by the Transmission Operator, unless such actions would violate safety, equipment, regulatory or statutory requirements. This standard also requires Generator Operators to render all available emergency assistance to others as requested, provided that the requesting entity has implemented its comparable emergency procedures. Finally, the standards prohibits Generator Operators from removing Bulk Electric System Facilities from service if removing those facilities would burden neighboring. TOP b Normal Operations Planning This standard requires that NID use uniform line identifiers when referring to transmission facilities of an interconnected network. NID already utilizes uniform line identifiers with PG&E. This can be seen by looking at NID s and PG&E s single line diagrams. The remaining requirements of this Reliability Standard are performed solely by PG&E under the terms of the CFR Agreement. TOP Planned Outage Coordination This requirement is to be performed solely by PG&E under the terms of the CFR Agreement. This standard requires the Generator Operator to provide outage information daily to its Transmission Operator for scheduled generator outages planned for the next day (any foreseen outage of a generator greater than 50 MW); plan and coordinate scheduled outages of system voltage regulating equipment; and plan and coordinate scheduled outages of telemetering and control equipment and associated communication channels between the affected areas. TOP Monitoring System Conditions This requirement is to be performed solely by PG&E under the terms of the CFR Agreement. This standard requires the Generator Operator to inform its Balancing Authority and Transmission Operator of all generation resources available for use. VAR and VAR Voltage and Reactive Control VAR became effective January 1, 2014 and was replaced by VAR on October 1, This standard is actually a regional variance of the previous VAR standard. Unfortunately, the affected region is the WECC region. In the Western Interconnection Generator Operators have been added to the Page 16 of 19

19 list of applicable entities for the standard. The standard created three new requirements for Western Generator Operators. Specifically, (1) Generator Operators in WECC must convert each voltage schedule provided by the Transmission operator into the voltage set point for the generator excitation system (Equivalent Action EA 15 these have the same impact as a Requirement and are employed for Regional Variances); (2) provide its voltage set point conversion methodology within 30 calendar days of a request by its Transmission Operator (EA 16); and (3) meet certain control loop specifications if control loops are used external to the Automatic Voltage Regulators to manage MVar loading (EA 18). PG&E will be responsible for EAs 15 and 16 during the term of the current Power Purchase Agreement. EA 18 does not apply to NID as no control loops are used to control NID s hydroelectric Facilities. VAR-002-2b and VAR Generator Operation for Maintaining Network Voltage Schedules VAR replaced by VAR-002-2b on October 1, The VAR Reliability Standard has five Requirements, four of which must be adhered to by Generator Operators (see also the VAR section above for the Generator Owner Requirements). Specifically, a Generator Operator must: (R1.) operate each generator connected to the interconnected transmission system in the automatic voltage control mode (automatic voltage regulator in service and controlling voltage) with certain limited exceptions; (R2.) maintain the generator voltage or Reactive Power schedule (within applicable Facility Ratings) as directed by the Transmission Operator; (R3.) notify its Transmission Operator of a status change on the AVR, power system stabilizer, or alternative voltage controlling device within 30 minutes of the change; and (R4.) notify its associated Transmission Operator as soon as practical, but within 30 minutes of changes in reactive power capabilities (not including those conditions listed under R3). Under the terms of the CFR agreement, NID only needs to inform PG&E s Drum Operations Center when an issue arises under R4. NID will be developing a brief procedure that memorializes this requirement if NID is unsuccessful with its registration appeal at NERC. VAR-002-WECC-1 Automatic Voltage Regulators VAR-002-WECC-1 seeks to ensure that Automatic Voltage Regulators on synchronous generators and condensers shall be kept in service and controlling voltage. Specifically, this standard requires Generator Operators to have AVR in service and in automatic voltage control mode 98% of all operating hours for synchronous generators or synchronous condensers. Under the terms of the CFR agreement, PG&E will be fully responsible for compliance with the standard. VAR-501-WECC-1 Power System Stabilizers The VAR-501-WECC-1 regional Reliability Standard aims to ensure that Power System Stabilizers on synchronous generators are kept in service. Under the terms of the CFR agreement, PG&E is responsible for compliance with this standard. However, NID does not even own any Power System Stabilizers and is therefore not an applicable entity for this standard. Page 17 of 19

20 Looking Ahead Compliance Outlook for 2015 and Beyond Applicable Reliability Standards Function Effective Date PRC System Restoration from Blackstart April 1, 2015 Resources MOD Data for Power System Modeling and Analysis July 1, 2015 CIP CIP Cyber Security - BES Cyber System Categorization Cyber Security - Security Management Controls April 1, 2016 April 1, 2016 NID s NERC/WECC reliability compliance program is off to a strong start in 2015 Keane Sommers and Jacqueline Longshore are providing strong leadership for NID s NERC Compliance Program that exhibits organization, persistence, and awareness. In order to remain compliant, NID will need to keep this level of focus. The NERC Reliability Standards, especially the CIP standards, continue to evolve. Under the recently approved Version 5 CIP standards, NID will be required to implement increased protections for NID s control networks and cyber systems used to run their Bulk Electric System generation units (i.e. Chicago Park and Dutch Flat 2). These standards have a long lead time, are complex, and can be difficult and costly to implement. NID is currently working with GridSME to prepare for the increasing compliance requirements. NID has made significant steps to prepare for these standards but will need to maintain the focus and effort to be fully prepared when the new standards become effective. Additionally, NID s IT, Maintenance, and Operations departments have increased their communications with each other to develop a better understanding of each other s needs and implement controls to protect NID s operational technology and Facilities. Accordingly, these efforts will continue throughout 2015 and into Upcoming Schedule of Activities February 24, 2014 (and every two months thereafter) ICP/ROCC meetings March 2, 2015 Self-Certification Deadline April 20, July 20, and October 20, 2015 Quarterly Data Submittals Conclusion NID was compliant with all of the applicable Reliability Standards in 2014 and is on track to remain fully compliant in This demonstrates that NID exerted considerable effort to become compliant with the NERC and WECC Reliability Standards. Now that NID has enacted compliant policies and procedures, the work will focus on implementation, review and improvement. Maintenance schedules must be kept, employees must be trained, and, most important, procedures must be consistently followed. NID will also need to stay abreast of ongoing developments with the Reliability Standards including the CIP Page 18 of 19

21 standards. The foundation has already been established to ensure that NID is fully capable of handling these additional compliance burdens. NID management and staff should be proud of their considerable achievements in Page 19 of 19