NERC compliance: Handling system disturbances
Ensuring timely, effective actions during and after system disturbance events
How did your equipment, customers and Operations fare in the face of a system disturbance? Did your Operations department react to the disturbances correctly and timely? Did they know a disturbance when they saw it? Do these questions plague your NERC Compliance Organization when requests for OE-417 or NERC Event Analysis reports are requested by your Regional Entity, NERC and FERC?
Too many small utility Operation’s Departments under estimate their importance when it comes to the reliability of the Bulk Electric System. That mind set needs to be changed such that there is no doubt in their minds what to do when the abnormal occurs. Automatic processes need to kick in when they see or learn of something that gets their attention. It can be a directive from the Reliability Coordinator, a heads-up call from a technician at a substation, a SCADA/EMS/communications issue or a voltage/frequency excursion.
When the abnormal occurs, there are logical steps they need to accomplish and document for post disturbance event analysis. Questions that run through their minds should include:
If this might be sabotage, I have specific questions such as threat to lives, calls to be made and paperwork.
If this a reliability issue, I have other operators that I need to call
If this is a disturbance as defined by DOE or NERC, there are forms to be filled out
After things have settled down, I need to look at the criteria for performing a NERC Event Analysis
After an area wide disturbance, the Compliance Department is busy processing Requests for Information (RFI) from entities including FERC, NERC and their RE. If due diligence was performed by Operations and supporting staff and evidence of compliance (paperwork) was created and stored in a repository available to the Compliance Department, this task can be streamlined and comfortable. If the above occurred but wasn’t documented, the task can resemble an exercise of pants on fire. If Operations didn’t do due diligence, we end up with PUSH (pray until something happens).
It becomes evident that what is often missing is:
Processes and procedures with an assigned actor and steps to be followed
Training of Operations and staff such that emergencies are associated documentation are come naturally
Compliance Department overseeing the state of compliance; this means they can’t be responsible for being compliant during a disturbance