On October 20, 2006, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) to facilitate the acceptance of 87 reliability standards submitted by the North American Electric Reliability Council (NERC). That's both good news and a signal to those of us responsible for reliability. Now that the wheels of federal endorsement and enforcement have begun to turn in earnest, it's time to begin planning our compliance strategies.
In addition to the 87 standards that FERC proposes to accept, NERC submitted 20 of the "fill-in-the-blank" variety that require regional reliability organizations (RROs) to develop certain procedures and protocols but do not address the specifics of those plans. Critical Infrastructure Protection standards will be dealt with in a separate rule-making.
By now, those charged with complying with reliability standards should be well on their way toward "entity registration" in their regions. Such registrations require submitting the name of a primary contact responsible for internally coordinating a company's compliance. Most also require designation of an officer of the company who will sign off on the compliance reports periodically sent to the RROs.
Enforcement of the mandatory reliability standards—and penalties for failing to comply with them—won't begin until this summer. However, FERC has made it clear that in the interim, all responsible entities are expected to meet their requirements as a matter of good utility practice.
In the October NOPR, the commission also made clear that the standards will be applied on a case-by-case basis. For example, there will be no blanket exemptions for small users of the bulk power system who might plead that their actions and degree of compliance affect overall system reliability far less than those of larger users.
NERC will be immediately addressing the revisions and clarifications in the standards listed as high priorities in an attachment to the NOPR. This rule-making is an opportunity for all stakeholders in system reliability to inform FERC of any concerns with standards under consideration. It also is a wake-up call to ensure that internal business and operational practices are shipshape for navigating the twists and turns of mandatory compliance. As with all trips, the better one is prepared, the easier the journey.
—By Jim Stanton, POWER contributing editor and project manager at ICF International. He can be reached at 713-445-2000 or jstanton@icfi.com.
UNDERWATER INSPECTION
To drain or not to drain
A little over a year ago, the operations and engineering staff of FirstEnergy Corp.'s Seneca Station faced a very difficult decision: Should a required inspection of the pumped-storage facility's upper reservoir be performed underwater or with the reservoir in a dewatered state? In the end, the decision was made to use a remotely operated vehicle (ROV) to do the inspection underwater, eliminating the need to drain the reservoir and shaving days and dollars from the project. The lessons learned during the decision-making process can benefit other hydro plant operators facing the same choice.
The Seneca Station is located at the Kinzua Dam, near Warren, Pa. The dam was originally built by the Army Corps of Engineers to regulate the Allegheny River for flood control. It created the Allegheny Reservoir, a lake that stretches 25 miles upriver. Seneca Station (Figure 1), rated at 435 MW, began commercial operation in 1970.
1. Pumped up. The 435-MW Seneca pumped-storage station began commercial operation in 1970. Courtesy: FirstEnergy Corp.
Email
Comments
Print
Reuse
