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BAL-002-WECC-2 Compliance Monitoring or an Auditors View of the Standard

BAL-002-WECC-2 Compliance Monitoring or an Auditors View of the Standard. Phil O’Donnell Manager, Operations and Planning Audits podonnell@wecc.biz. Auditable Parts of a Standard. Part A Introduction Section 3 – Purpose Section 4 - Applicability Section 5 - Effective Date

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BAL-002-WECC-2 Compliance Monitoring or an Auditors View of the Standard

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  1. BAL-002-WECC-2Compliance Monitoring or an Auditors View of the Standard Phil O’Donnell Manager, Operations and Planning Audits podonnell@wecc.biz

  2. Auditable Parts of a Standard • Part A Introduction • Section 3 – Purpose • Section 4 - Applicability • Section 5 - Effective Date • Section 6 - Background • Part B Requirements and Measures • Requirements • Measures • Part C Compliance or Compliant Monitoring Process • Authority • Processess • Retention • Additional Compliance Information Sometimes Yes Yes Yes

  3. Why does WECC Need this Standard? BAL-001 Real Power Balancing and Control – Compliance with this should ensure adequate regulating reserves and small (non-reportable) contingencies. BAL-002 Disturbance Control Performance – BA/RSG Compliance with this should ensure adequate Contingency Reserves for all reportable disturbances. However BAL-002 R2 states: • Each Regional Reliability Organization, sub-Regional Reliability Organization or Reserve Sharing Group shall specify its Contingency Reserve policies. • WECC as a Region has selected to do this with a Regional Standard

  4. Reliability Standard Audit Worksheet (RSAW)

  5. RSAW Parts • Cover page and disclaimer • Findings Table/Recommendations/Area of Concerns (For the Auditors) • Subject Matter Experts-(For entity to complete) For Each Requirement: • Text of the Requirement - Info • Registered Entity Narrative Response for Compliance: (For Entity to complete) • Questions for Registered Entity. (For Entity to complete) (BAL-002-WECC-2 has questions for R3 & 4) • Registered Entity Evidence (For Entity to complete) • Compliance Assessment Approach: (Auditor guidance) • Compliance Summary: (For Auditor use to facilitate reporting)

  6. Part of the Disclaimer… • While the information included in this RSAW provides some of the methodology that WECC has elected to use to assess compliance with the requirements of the Reliability Standard, this document should not be treated as a substitute for the Reliability Standard or viewed as additional Reliability Standard requirements. In all cases, the Regional Entity should rely on the language contained in the Reliability Standard itself, and not on the language contained in this RSAW, to determine compliance with the Reliability Standard.

  7. BAL-002-WECC-2 In a Nutshell R1 specifies you must maintain a specific total amount of Contingency Reserve and defines the acceptable characteristics of that Contingency Reserve R2 places a restriction to R1 and requires a specific part of the total Contingency Reserve (50%) to meet the definition of Operating Reserve - Spinning. R3 Requires additional Operating Reserve in excess of R1 for specific interchange energy transactions. R4 Requires additional Operating Reserve in excess of R1 for specific Operating Reserve Transactions. Auditors will use the definitions (traits) of Contingency Reserve and Operating Reserve contained in the requirements of the standard.

  8. General Audit Approach • Maintaining reserves is an ongoing 24/7 requirement. • Will be looking at Hourly Data during the audit period. • Up to 35040 chances to fail during the data retention period. • Auditors will be reviewing entity policies, procedure and tools to understand how the entity ensures compliance. • Auditors will then test compliance by selecting sample times and performing a detailed assessment of obligations and available reserves for those selected time periods.

  9. Data and Evidence Required First Level of Data Should be provided with intial RSAW: • Completed RSAW • Copies of Policies, Procedures and Protocols for calculating Contingency Reserve obligations and available Contingency Reserves including how Generation and Load are determined. • Any Delegation or Compliance Assignment agreements which assign compliance of all or part of a standard to another party. • Entity Examples of Contingency Reserve Obligations and Availability showing how the policies were implemented. • Screenshots or other evidence showing how Contingency Reserves are monitored and deviations identified in real time.

  10. Data and Evidence Required Follow up Data Requests: • List of Events when reserves were activated. (Not necessarily “Reportable Events”) • Hourly Data for any hour during the audit period which includes: • Most Single Severe Contingency Value specified hour • Generation Value for specified hour • Load Value for specified hour. • Value of Total Contingency Reserve Obligation • Value of Available Contingency Reserve • Identification of type of Contingency Reserves which make up the total • Interchange Transactions or Reserve Transactions which can impact Obligations. • How are ramp rates or other generation limitations addressed when considering availability. • Auditor should be able to use your hourly data elements and calculate the same Contingency Reserve Obligation as you. • Auditor should be able to verify your amount of Contengency Reserve satisfied the requirements. • Auditor should be able to verify the type of Contingency Reserve satisfied the requirements.

  11. Some points to consider Average Hourly Data Will be used for assessment of historical values. But… Standard waives Contingency Reserve obligations for only 60 minutes following an event requiring activation of reserves. Expect to see a request for Obligation and Available Reserves at 61 minutes after event intiation. You can use average for hour if you want but that may not be in your best interest. We will take value at the 61 minute point for remainder of hour. Example: Event at 10:50 you must demonstrate compliance at 11:51. Providing only Hourly Average for HE 12 may not be compliant.

  12. What is Generation and Load? • Exact Method of Determination of BA or RSG Generation and Load is not specified in standard or defined in NERC Glossary of terms. • You must provide explaination of how this is determined. • Since requirements are not specific this is somewhat subjective and therefore may change. • BA/RSG Load is considered within metered boundary of BA/RSG • BA/RSG Generation is considered as generation within metered boundary of BA/RSG. Some discussion in the non enforceable part of the standard about pseudo-ties, dynamic schedules and joint owned units. It is not mentioned in the requirments. Any deviations or “thinking outside the box” for definition of Generation or Load must be verified it does not reduce the total amount of reserves that would exist if the boundaries were strictly enforced.

  13. Time is important! Easy to overlook. • All Contingency Reserve which is included in total must be available in 10 minutes. • Synchronized Machine 500 MW, only loaded at 100 MW • Ramp rate of 20MW per minute • Only 200 of the 400 unloaded MW can be counted as either Operating Reserve – Spinning or Operating Reserve – Supplemental. • The rest is not countable. • How do you account for this?

  14. Requirement 1 R1. Each Balancing Authority and each Reserve Sharing Group shall maintain a minimum amount of Contingency Reserve, except within the first sixty minutes following an event requiring the activation of Contingency Reserve, that is: 1.1 The greater of either: • The amount of Contingency Reserve equal to the loss of the most severe single contingency; • The amount of Contingency Reserve equal to the sum of three percent of hourly integrated Load plus three percent of hourly integrated generation. 1.2 (Acceptable types - next page) 1.3 Based on real-time hourly load and generating energy values averaged over each Clock Hour (excluding Qualifying Facilities covered in 18 C.F.R.§ 292.101, as addressed in FERC Order 464). 1.4 An amount of capacity from a resource that is deployable within ten minutes.

  15. Requirement 1 continued 1.2 Comprised of any combination of the reserve types specified below: • Operating Reserve – Spinning • Operating Reserve - Supplemental

  16. Requirement 1 continued • Interchange Transactions designated by the Source Balancing Authority as Operating Reserve – Supplemental • (E-tag would demonstrate) • Reserve held by other entities by agreement that is deliverable on Firm Transmission Service. • Evidence of Contract or Agreement, and Firm Transmission Service must include time for full delivery. These seem very similar but etag may not exist until dispatched for second type.

  17. Requirement 1 continued • A resource, other than generation or load, that can provide energy or reduce energy consumption ???

  18. Requirement 1 continued • Load, including demand response resources, Demand-Side Management resources, Direct Control Load Management, Interruptible Load or • Interruptible Demand, or any other Load made available for curtailment by the Balancing Authority or the Reserve Sharing Group via contract or agreement. Seem like two bullets just continuing a description of load that may be used as Operating Reserve – Supplemental. Not Firm Load. Should be able to demonstrate how these are dispatchable within 10 minutes,

  19. Requirement 1 continued • All other load, not identified above, once the Reliability Coordinator has declared an energy emergency alert signifying that firm load interruption is imminent or in progress. The loophole • This is Firm Load… If you can use this as reserve no one would ever be short on Operating Reserve – Supplemental • Caviat is The RC has to declare an Emergency Alert Level 3 (Re: EOP-002) • Entry conditions for EEA 3 May include: Defecient Entity is carrying reserves below the required minimum. (already implies a violation) • Need evidence of EEA 3… Expect detailed assessment of reserves prior to declaration of EEA 3 • Possibly could help you restore within the 60 minutes. • Otherwise (without EEA) shedding Firm Load may help your ACE but will not help you comply with Reserve Obligations.

  20. Requirement 1 Audit Approach

  21. Requirement 2 Each Balancing Authority and each Reserve Sharing Group shall maintain at least half of its minimum amount of Contingency Reserve identified in Requirement R1, as Operating Reserve – Spinning that meets both of the following reserve characteristics. 2.1 Reserve that is immediately and automatically responsive to frequency deviations through the action of a governor or other control system; 2.2 Reserve that is capable of fully responding within ten minutes.

  22. Requirement 2 Audit Approach

  23. Requirement 3 • Each Sink Balancing Authority and each sink Reserve Sharing Group shall maintain an amount of Operating Reserve, in addition to the minimum Contingency Reserve in Requirement R1, equal to the amount of Operating Reserve–Supplemental for any Interchange Transaction designated as part of the Source Balancing Authority’s Operating Reserve–Supplemental or source Reserve Sharing Group’s Operating Reserve–Supplemental, except within the first sixty minutes following an event requiring the activation of Contingency Reserve.

  24. Requirement 3 Audit Approach RSAW Question: in you role as Sink BA/RSG • Did you have any Interchange Transaction designated as part of the Source Balancing Authority’s Operating Reserve–Supplemental or source Reserve Sharing Group’s Operating Reserve–Supplemental during the audit period? • If no, state so and describe the process used for knowing such an event did not occur. • If yes, provide the number of instances and associated evidence of compliance.

  25. Requirement 3 Audit Approach

  26. Requirement 4 • Each Source Balancing Authority and each source Reserve Sharing Group shall maintain an amount of Operating Reserve, in addition to the minimum Contingency Reserve amounts identified in Requirement R1, equal to the amount and type of Operating Reserves for any Operating Reserve transactions for which it is the Source Balancing Authority or source Reserve Sharing Group.

  27. Requirement 4 Audit Approach RSAW Question: In your role as a source BA/RSG • Did the you have any Operating Reserve transactions for which you were the Source Balancing Authority or source Reserve Sharing Group during the audit period? • If no, state so and describe the process used for knowing such an event did not occur. • If yes, provide the number of instances and associated evidence of compliance.

  28. Requirement 4 Audit Approach

  29. Monitoring Methods - Options • Compliance Audit • Self-Certification • Spot Checking • Compliance Investigation • Self-Reporting (Self-Monitoring) • Complaint Where is Periodic Data Submittal?

  30. Monitoring Plan • Not decided if this will be actively monitored next year. • Performance requirments of BAL-001 and BAL-002 subject to Periodic Data Submittal tend to be the canaries in the coal mine for reserve issues. • Event or Risk Considerations • May increase frequency of RSG audits.

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