Wind power NERC compliance challenges
Whether you are building, buying, owning, or operating a wind farm connected to the bulk electric system (BES), you need to understand the impact created by the North American Reliability Corporation’s (NERC) Reliability Standards. A wind power entity that is registered as a generator operator (GOP) and generator owner (GO) is subject to a minimum of 80 primary NERC reliability requirements. If an entity is required to register as both a transmission operator (TOP) and transmission owner (TO) due to a radial tie line, that number almost triples. Failure to comply or document how the requirements have been met can result in significant monetary penalties for the entity.
NERC compliance starts before synchronization
Wind power owners and operators must register with NERC prior to synchronization to the grid, and, as of the day of their registration, they must be compliant with all requirements related to their registration. For each wind farm, a GOP and a GO must be compliant with all NERC requirements that have been approved by the Federal Energy Regulatory Commission (FERC), and they should expect to be audited within the first six years of their registration. They will need to provide evidence of compliance back to their registration date, which includes recorded evidence of all facility studies and system protection coordination, testing, and maintenance. Each piece of evidence must meet specified criteria—this helps the regional entity’s auditor to have a clear picture that all sub requirements have been met.
Using third-party maintenance or operations
If a wind farm owner registers with NERC and arranges to have a third party perform operations or maintenance duties, complications will arise if the third party does not adhere to the NERC requirements and maintain evidence that NERC requirements have been met. When the periodic six-year audit is performed, gaps in evidence of compliance are considered noncompliant. It is important for the registered entity to ensure that the third party performs as required and maintains evidence of compliance. The common rule is if it isn’t documented, it didn’t happen.
Know your NERC regulatory interfaces
It is important for a wind power entity to know who its balancing authority (BA), TOP, reliability coordinator (RC), and Regional Entity (RE) are, and the requirements of each. Those requirements will include dispatch, automatic voltage regulation, communication, and data/reporting. These requirements are also related to compliance, so the entity must maintain evidence that they are all satisfied.
Cyber security impact
A problem that has been evolving for wind power producers is when they register with NERC as a GOP but use a third party to perform their operations, and the third party is performing that function for numerous wind farms. The third party’s operation center then becomes a control center. Under NERC cyber security version 5, it will be categorized as a medium level critical asset (CA), at least. Each entity that is registered as a GOP and uses that control center may be required to provide evidence of cyber security compliance for the third party’s control center. Even before that occurs, version 4 of the cyber standards will become enforceable on April 1, 2014. Under version 4, a control center that controls more than 1,500 MW in a single interconnection may well be classified as a CA and become a high-level CA in version 5. (Refer to the TECH Notes feature on NERC Critical Infrastructure Protection for more information.)
Develop a culture of compliance
Compliance with NERC requirements starts with a comprehensive compliance program. Evidence of a good culture of compliance goes a long way with NERC and FERC when it comes to resolving future compliance issues. The culture of compliance must start at the top if the subject matter expert and staff are expected to perform their procedures in a compliant fashion.
For additional insight into NERC compliance solutions, contact our expert:
Raymond Gilby, DNV GL Energy & Sustainability principle consultant
Read Gilby’s former blog post, “Wind power: industry highlights and key trends.”
This article is featured for DNV GL’s June 2012 issue of TECH Notes, a monthly publication that provides business and technical insights for secure transmission and distribution systems. Sign up to receive advance notification.