Jay Loock SR Compliance Auditor

Audit Approach MOD-026 & MOD-027

CUG Meeting June 3 – 5

Salt Lake City, UT

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• Brief history of MOD Standards • Concerns / Questions • Applicability to what registered functions • Timelines • Audit approach for each requirement

Agenda

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• On March 20, 2014, FERC approved: o MOD-025-2 (MOD-024-1 and MOD-025-1

merge) effective date – July 1, 2016 o MOD-026-1 (New) effective date - July 1, 2014 o MOD-027-1 (New) effective date - July 1, 2014 o PRC-019-1 (New) effective date - July 1, 2016 o PRC-024-1 (New) effective date - July 1, 2016

FERC did what?

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• Later on May 1, 2014 FERC approved: o MOD-032-1(New) - Effective date - July 1, 2015 o MOD-033-1(New) - Effective date - July 1, 2017 o MOD-010-0 and MOD-12-0 (retired)

What else did FERC do?

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MOD-026 and MOD-027

• These standards are applicable to Transmission Planners (TP) and Generator Owners (GO).

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• Registered TPs here today? • Registered GOs here today? o How many have followed the WECC Generator

Testing Program?

Concerns / Questions

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What about those MODs?

• MOD-026 requires generator owners to verify that dynamic models of excitation controls are accurate and up-to-date;

• MOD-027 places the same requirements on dynamic models of governors and turbine controls.

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MOD-026 R1 (TP)

• R1 is intended to ensure that the TP provides information to the GO(s) necessary to ensure that they provide a useable model in an acceptable format (from an approved model list). This ensures that GOs can comply with Requirement R2.

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Within 90 days of a request from the GO the TP shall: • Provide a approved model list. • Provide data (model) being used historically

for the GO.

MOD-026 R1 - Audit approach

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• The purpose of R2 is to verify that the generator excitation control system or plant volt/var control function model and the model parameters used in dynamic simulations performed by the TP accurately represents the generator excitation control system or plant volt/var control function behavior when assessing BES reliability.

MOD-026 R2 (GO)

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Not auditable until July 1, 2018 • July 1, 2018 - 30% • July 1, 2020 - 50% • July 1, 2024 - 100%

MOD-026 R2 - Audit approach

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• Individual generating unit greater than 75 MVA (gross nameplate rating).

• Individual generating plant consisting of multiple generating units that are directly connected at a common BES bus with total generation greater than 75 MVA (gross aggregate nameplate rating).

MOD-026 R2 MVA Requirement

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or…. A technically justified unit that meets NERC registry criteria but is not otherwise included in the above applicability and is requested by the Transmission Planner. …this is footnote 2 page 2 of the standard

MOD-026 R2 MVA Requirement

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• R3 provides response requirements for a GO when it receives certain requests from the TP. This communication ensures that GOs have an obligation to respond in a timely fashion when there are demonstrated problems with a model that was provided by the GO.

MOD-026 R3 (GO)

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GO response to TP in 90 days when: • Model is unusable • Model has technical concerns • Model response concerns

• R3 details what should be in the GO

response

MOD-026 R3 - Audit approach

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• R4 ensures that when a GO makes a change to an applicable unit that would affect the model provided in accordance with Requirement R2, the GO then has an obligation to determine whether there is an impact on the model and to provide the TP with revised model data or plans to perform model verification.

MOD-026 R4 (GO)

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• Were changes made to the units? • Were models updated? • Were timelines met?

MOD-026 R4 - Audit approach

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• R5 ensures that there is a process for TP to request a model review for technically justified units not specified in the standard applicability section but that meet or exceed the Registry Criteria unit MVA thresholds.

MOD-026 R5 (GO) Footnote 2 & 6

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• Did GO provide a written response to the TP within 90 days?

• Do the details of the response address the requirement?

MOD-026 R5 - Audit approach

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• R6 requires the TP to inform the GO within 90 calendar days whether a model is useable or not. The response from the TP verifies that the TP has sufficient information and ensures that the verification process is complete.

MOD-026 R6 (TP)

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• TP communicated to the GO(s) that the model is or is not useable.

• TP shall provide a technical description why the model is not usable.

MOD-026 R6 - Audit approach

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Its purpose 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 reliability, accurately represent generator unit real power response to system frequency variations.

MOD-027-1 Purpose

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• R1 is intended to ensure that the TP provides information to the GO(s) necessary to ensure that they provide a useable model in an acceptable format (from an approved model list). This ensures that GOs can comply with Requirement R2.

MOD-027 R1 (TP)

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Within 90 days of a request from the GO the TP shall: • Provide a approved model list. • Provide data (model) being used historically

for the GO.

MOD-027 R1 - Audit approach

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• R2 requires GOs to provide TP with a verified turbine/governor and load control or active power/frequency control model for each applicable unit, including documentation and data in accordance with the periodicity specified in Attachment 1.

MOD-027 R2 (GO)

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Not auditable until July 1, 2018 • July 1, 2018 - 30% • July 1, 2020 - 50% • July 1, 2024 - 100%

MOD-027 R2 - Audit approach

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• R3 provides response requirements for a GO when it receives certain requests from the TP. This communication ensures that GOs have an obligation to respond in a timely fashion when there are demonstrated problems with a model that was provided by the GO.

MOD-027 R3 (GO)

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GO response to TP in 90 days when: • Model is unusable • Model has technical concerns • Model response concerns

• R3 details what should be in the GO

response

MOD-027 R3 - Audit approach

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• R4 ensures that when a GO makes a change to an applicable unit that would affect the model provided in accordance with Requirement R2, the GO then has an obligation to determine whether there is an impact on the model and to provide the TP with revised model data or plans to perform model verification.

MOD-027 R4 (GO)

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• Were changes made to the units? • Were models updated? • Were timelines met?

MOD-027 R4 - Audit approach

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• R5 requires the TP to inform the GO within 90 calendar days whether a model is useable or not. The response from the TP verifies that the TP has sufficient information and ensures that the verification process is complete.

MOD-027 R5 (TP)

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• TP communicated to the GO(s) that the model is or is not useable.

• TP shall provide a technical description why the model is not usable.

MOD-027 R5 - Audit approach

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• Satisfies these two standards WECC Certification is the gold standard, ….with one caveat ……meet the timelines of the standards.

WECC Generator Testing Program

Jay Loock 801-883-6864 jay@wecc.biz

Questions?