Demande R-3549-2004
RÉPONSES DU TRANSPORTEUR À LA DEMANDE DE
RENSEIGNEMENTS NUMÉRO 1 DE LA RÉGIE DE L'ÉNERGIE
Réponse R25.3
Original : 2004-12-07
HQT-10, Document 1.3
(En liasse)
NERC Reliability Authority Audit 2002
TransEnergie
Reliability Authority
Audit
Audit Report,
August 2002
June 18–19, 2002
Montreal, Canada
Conducted By:
Denis Grandmont — IMO
Jason Jett El Paso — Merchant Energy
Larry Kezele — NERC
Quoc Le — NPCC
Ev Lucenti — Power Decisions Consulting Inc.
______________________________________________________________________________________
1
Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
http://www.powerdecisionsconsult.com
NERC Reliability Authority Audit 2002
Table of Contents
• Introduction and Audit Process
Page 3
• Participants
Page 4
• Executive Summary
Page 4-6
• Recommendations
Page 6-7
• On-site Review Notes
Page 7-22
• Attachments
(B)-List of the operating instructions, procedures and reference
documents provided by TransEnergie during the on-site review
(C)-List of Exhibits provided by TransEnergie during the on-site review
(D, E, F)-Neighbor Responses
(G)-Self-Assessment
Audit Process
______________________________________________________________________________________
2
Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
http://www.powerdecisionsconsult.com
NERC Reliability Authority Audit 2002
In the fall of 2001, NERC initiated a Pilot Program to Audit eight Reliability
Authorities to ensure compliance with Policy 9 and Appendix 9D. The NERC OC
requested that NERC continue with the audit process in 2002 to complete the RAs
that were not audited during the Pilot Program in the fall of 2001. The RA Audit
program for 2002 has been revised to include lessons learned during the Pilot
Program.
The Audit Team assesses the degree to which the RA met the intent of the NERC
Operating Policies including:
Ø Policy 9, Version 2 and Appendices
Ø NERC Reliability Authority (Security Coordinator) Standards of Conduct
With Reference to:
Ø TLR process
Ø System Restoration
Ø Backup Control Centers
The audit process includes:
Ø A self-assessment questionnaire to the RA being audited
Ø A questionnaire to neighboring RAs
Ø A questionnaire to sub RA Operating Entities
Ø An on-site audit by a selected audit team
Neighboring Reliability Authorities and sub RA Operating Entities responded to
questionnaires that were designed to evaluate the working relationship between them
and the RAs being audited. Questionnaire responses, including the self-assessment
are included as appendices to this report.
Pre-audit information was sent to the audit team, consisting of responses to the selfassessment questionnaire, questionnaire responses, a set of questions and guidelines
to assist them in the on-site audit, and copies of some of the documentation provided
by the RA being audited, to assist them in their evaluation of compliance. The team
met prior to the on-site audit, to discuss and review interview assignments, the audit
process, interview questions, questionnaire responses and complete necessary
preparations for the audit.
Participants
Michel Armstrong - Director - System Control
Gratien Charest – Manager – Control Center
Joseph Fox – Compliance Advisor
Julien Gagnon – Manager – System Control Scheduling
______________________________________________________________________________________
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Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
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NERC Reliability Authority Audit 2002
Richard Mailhot - Manager – Technical Support
Albert Poiré – Manager Operating Rules
Jacques Audet – Technical Advisor
Lyne Blais – Training Advisor
Patrick Doyle - Training Advisor
Rémy Bouchard - System Operator – Transmission (RA)
Serge Boucher – System Operator - Exchange
Executive Summary
Prior to the on-site review, a list of the “audit topics” was sent to TransEnergie to
help them prepare for the audit. TransEnergie staff compiled a book of
information to assist the auditors in their review. The book provided a
comprehensive overview of how TE meets each of the requirements. Reference to
documents was provided, summary information compiled and copies of pertinent
information and actual documentation was made available.
The information provided was very extensive. To give the reader an idea of the
detail, I have included two extra attachments:
1. A list of the exhibits that were included in the information package
2. A list of the operating instructions, procedures and reference
documents
TransEnergie (TE), a division of Hydro Quebec, performs the Reliability
Authority role. The RA authority and responsibilities are documented in operating
procedures, job descriptions, and in Mission Statements. The shift staff
interviewed reported that they understood their authority and expect that the
TransEnergie management staff will support their decisions. The System
Operator-Transmission (RA) has authority to take action in the interest of system
reliability, up to and including load shedding.
In Quebec, there is only one RA. Its authority over other operating personnel
within the Quebec area is well established. The Regional Operating personnel will
follow the direction provided by the RA. There have been no incidents where the
Regional Operators have refused to follow direction.
Hydro Quebec implemented a functional separation between TransEnergie and its
merchant function in 1997, and at the same time, implemented an internal
standard of conduct to ensure that the RA(s) will act first and foremost in the
interest of the overall reliability of the Security Area/Interconnection, before any
purchasing/selling entities.
There are three shift operating positions in the Control Room (CCR): System
Operator – Transmission (Reliability Authority), System Operator – Load and
______________________________________________________________________________________
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Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
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NERC Reliability Authority Audit 2002
Generation Balancing (Balancing Authority), System Operator – Exchange
(Interchange Authority). The System Operator – Transmission (RA) holds the
final authority over reliability decisions. Each position has 6 assigned people for a
total of 18 NERC Certified operators. TE also has three new staff in training.
The TE training program is very comprehensive, and begins with the selection
from among the TE most experienced operating staff. The auditors were
impressed with the effort that is given to training the TE shift staff.
The TE main Control Center is supported by an operational back- up facility
(BUCC) that mimics the main facility. The BUCC is continually in a hot standby
mode. The auditors visited the site and the report is included in the body of this
document. The plans for use of the back-up and the training provided are good.
The auditors are concerned that the present transfer procedure from CCR to
BUCC may not be as complete as it should be. (See Recommendations)
The computer EMS facilities and the communication facilities are very well
designed for effectiveness and reliability. The Shift Staff who were interviewed
were very happy with the capability of the facilities. The auditors were given an
excellent demonstration of the displays and output of the EMS, as well as an
informative tour of the Telecommunications center.
The RA has full authority in the implementation of the System Restoration Plan.
The plan provides very detailed advice to the RA on how to begin and direct
restoration. Each day the plan is updated to ensure new facilities and outages are
taken into consideration. Testing and training is done on a regular basis, and black
start facilities are also tested on a routine schedule.
TE has signed appropriate standards of conduct and also has an extensive
company standard of conduct. All of the TE employees related to RA function are
provided with copies of the NERC Standards of Conduct, and all TE employees
have been given instruction on the HQ Company Standards of Conduct. Refresher
training and reminders are provided.
At the present time there are no responsibilities delegated to sub-operating
entities, however, the auditors are recommending that such delegation might be
advisable for the specific situation requiring the evacuation of the main control
center.
In some emergency operating situations a "war room" (system control emergency
centre) may be set up to help with special operating situations. This last occurred
about 3-years ago during a HQ strike by union other than CCR system operators.
The shift operators raised a concern that the role of staff that “man” the war room
______________________________________________________________________________________
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376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
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NERC Reliability Authority Audit 2002
should be more clearly defined since a situation did occur that saw an officer of
the company issuing direction to the shift operator.
Recommendations
The audit team commends TE on the excellent back up facility that will be used if
the main control facility is evacuated.
However, the team has two concerns that TE should consider:
1. The TE expectation that the BUCC could be up and running in less than 1
hour could be optimistic. It is possible that if there is a serious incident such
as a chemical spill or large toxic fire that makes the main center unavailable,
there could be a significant delay in staffing and bringing the back up facility
up to a full monitoring and operating mode. The team recommends that the
TE ensure that a delay of 1 to 4 hours should be considered in their planning.
2. The existing procedure requires some level of direction to be available from
the CCR staff to help the regional operators maintain the system after the
CCR is evacuated. The team recommends that TE assess the value of working
with the Regional Center Operators to provide them with training and
authority to monitor and operate the TE transmission system on their own, to
provide a minimum level of reliability for a period of time that would be
reasonable to allow the back up facility to be implemented.
Response to recommendation: “TÉ will make sure to have an efficient plan
for as long as it takes the BUCC to take the control of the system.”
The auditors discussed the shift operator concerns about authority and
responsibility during situations when the “war room” is functioning. The
management staff who participated in the audit stated that they agree that the final
operating authority rests with the shift operators. Since this is a concern, however
they will take steps to ensure that the authority is clearly understood, by
strengthening the wording in procedures to be followed during operation of the
“war room.”
Response to recommendation: “An action plan on the above
Recommendations will be prepared for the end of September 2002.”
On-site Review Notes
1. The Reliability Authority (RA) must have the authority to take action.
In Quebec, the Reliability Authority role is performed by TransÉnergie (TE), a
division of Hydro-Québec (HQ). TransÉnergie has the authority to take action and
the shift staff has the required operating knowledge and experience in order to
properly apply their authority. This authority is reflected in the mission of the
______________________________________________________________________________________
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Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
http://www.powerdecisionsconsult.com
NERC Reliability Authority Audit 2002
System Control (Contrôle des mouvements d’énergie) and is documented in
operating procedures as well as in the job descriptions. HQ and TE mandates are
registered with the Quebec Energy Board (Régie de l'énergie).
All directives have an effective date, and they are reviewed and updated on a
periodic basis at least every three years, and more frequently as needed. NERC
and NPCC documents are updated as required, and are translated into French,
with a reference note back to the original documents. A formal documentation
revision process is in place and the documentation was reviewed by the auditors.
(Ref List of Exhibits, section G)
Managers are ensured that operators recognize their authority from every day
actions and from post analysis of major disturbances. Management reviews
operator logs to determine execution of authority. Operators and management
have been given authority to maintain reliability via their job descriptions
approved by TransEnergie CEO.
The shift operator authority is evident in a 1998 incident when during a sys tem
disturbance the system operator took the control action of shedding load in the
Montreal area to minimize the disturbance. The action was taken without
management input at the time, and the decision was supported by Management
staff in the after-the-fact analysis.
The shift operators that were interviewed indicated that they know they have the
authority to act and the training provided and job descriptions etc. support that
authority. The System Operators also have authority over all Control Area
operations to assure reliability, and both management staff and operating staff are
confident that the regional operating staff recognizes the CCR authority and will
follow direction given to maintain reliability of the Quebec system.
Regional personnel as well as other Operating Authorities (i.e. Maclaren/Alcan)
are aware that CCR is the Reliability Authority in Quebec. The auditors were
provided with common system operating instructions between RA and other
Operating Authorities (GEN-C-xxx documents), plus Operating directives.
Supporting Documentation
CCR System Operator Transmission job description directs the Transmission
operator to:
Ø Decide upon and apply preventive measures in order to avoid outages
and disturbances.
Ø Decide upon and apply emergency measures to restore service and a
secure system configuration when outages or disturbances occur.
______________________________________________________________________________________
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Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
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NERC Reliability Authority Audit 2002
-Op Procedure 33199-D/I-001,“…energy shortfalls may only be declared
by the Generation Dispatcher-CCR…”
-33199-D-014, 33199-D/I-004
-Mission statement (Directors Job Description)
-CCR Managers Job Description
2. The RA must have a clear set of responsibilities.
TE has a complete set of Operating Procedures and Operating Reference
documents for System Control personnel that reflect shift staff responsibilities and
RA personnel have clear, documented responsibilities in their job description.
These Operating Procedures are in compliance with NERC Policies and NPCC
Criteria.
The shift staff interviewed indicated that they are aware of their responsibilities,
accountabilities, and the specific policies, procedures and guidelines that define
their responsibilities.
The TE responsibilities are in line with those of the NERC Reliability Model
regarding the Security (Reliability) Authority, Balancing Authority and
Interchange Authority.
Meetings are held presenting the new responsibilities to the RA. These meetings
cover changes to operating procedures and also industry changes.
Supporting Documentation
GEN-C-xxx documents, HQ Code of Conduct, Operating Documentation (D/R/I)
As part of their training a checklist of all responsibilities for each job function is
documented. There is also a list of tools and methods used to perform these
duties.
a. Example of Transmission operator “Know How List”
i. Maintain voltage levels, Static VAR Compensation and Synchronous
Condenser within prescribed limits.
ii. Maintain the Power system within thermal and stability limits.
iii. Operate controls according to the most recent operating procedure.
iv. Authorize or refuse the withdrawal, return or restart of equipment’s
protection devices.
v. Maintain the adequate equipment number for each Power System
configuration.
vi. Coordinate the Power System Restoration following a major shutdown.
______________________________________________________________________________________
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NERC Reliability Authority Audit 2002
vii. Operate the Power System under unfavorable weather or atmospheric
conditio ns
viii. Operate Protections according to the most recent operating procedure.
ix. Write System Operations Reports
x. Assume the duties related to Operations.
xi. Assume the RA duties for any section of the Hydro-Quebec
Transmission System.
xii. Train new System Operators
Shift personnel were interviewed and specific responsibilities were discussed.
Information is provided in the following paragraphs, and where appropriate,
documentation nomenclature is included as an indication of auditors review.
Ø Shift staff monitors ACE and take action when necessary.
(33199-D/R/I-001)
Most of the HQ generation is operated on AGC. The AGC system
is very reliable. AGC is spread over so many facilities that if
telecommunication failures occur, control is transferred to other
facilities. Inadvertent with neighbors is checked daily.
Ø Shift staff monitors reserve generation and takes action when necessary.
(33199-D/R/I-001)
There is a reserve requirement of about 1500MW that is distributed
across many generating units. There is spinning and non-spinning
reserve requirements, and interruptible loads are part of the
operating reserve calculation.
Ø Shift staff monitors voltages and frequency.
System parameters are adequately monitored. The frequency is
monitored at 7 key locations within the Province, and each
Regional control center also monitors frequency.
Ø Shift actions are appropriately coordinated with neighboring RAs.
Direct telephone is used to contact neighbors when conditions and
actions require it. TE assesses that the telephone is more practical
than the SCIS (RAIS) during such incidents.
Ø The critical outages are adequately planned and appropriate system studies
are completed.
All outages are scheduled and displayed in EMS. LIMSEL (limits)
studies are provided for each outage. The RA has the authority to
cancel scheduled outages if system conditions warrant.
______________________________________________________________________________________
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NERC Reliability Authority Audit 2002
Planned outages are coordinated internally, and discussed with
neighboring RA(s). The shift staff interviewed reported that the
outage control process is acceptable, and they have adequate
support (on-call procedure) with system engineers/system studies
group to provide any required extra information or studies.
Ø The System Operator – Exchange, monitors tagging, schedules and flows,
parallel flow impacts, and implementation of TLR.
To monitor transactions and implement TLR(s), the System
Operator – Exchange makes use of OASIS, ETAG and its EMS
Software application.
Ø Energy Emergency Alerts are issued as required. (33199-D/R/I-001)
Ø The shift operators will implement emergency actions, transmission
overload actions, load shedding, restoration etc as required.
The shift staff has the necessary authority to implement emergency
procedures, and the procedures are covered in several related
documents.
(33199-D/R/I-001,-004, 33199-D-014, 33199-U-001, 33199-D050, GEN-D-003,010,011,012,044,052,064,089,144,165,168, plus
related GEN-R-xxx reference docs.)
Ø Other shift responsibilities include:
• SMD notification
• Time error correction (done automatically via AGC)
• Hot line usage
3. The RA must have the authority to direct actions to be taken by other Operating
Authorities within the Security Area.
The TE RA has authority over all other operating personnel within the Quebec
Control Area. TransÉnergie has the role of Reliability Authority, Balancing
Authority and Interchange Authority, and monitors and can direct the operation of
facilities that may affect the reliability of the power system.
Responsibilities of generating plants, regional centers and CCR are clearly
defined. Operating Agreements are in place where necessary to support the RA
authority to take and direct action to maintain Quebec system reliability.
Supporting Documentation
GEN-D-101,-103, plus Common operating instructions GEN-C-xxx docs
______________________________________________________________________________________
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Power Decisions Consulting, Inc.
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NERC Reliability Authority Audit 2002
GEN-D-002-A, GEN-D-040-A with other operating Authorities within the
reliability area
GEN-C-042-TE-ISO NE (Common instruction with ISO-NE) (reference to this
document provided for illustration; there are instructions with all the Operating
Authorities and Interconnects)
4. The RA must act first and foremost in the interests of the “reliability” of the
overall Security Area/Interconnection before any other entity (Control Area,
Purchasing -Selling Entity, etc.).
In 1997 Hydro-Québec implemented internal Standards of Conduct and has also
signed the NERC Reliability Authority Standards of Conduct. TE complies with
reliability standards identical to, and in some cases more stringent than, NERC
and NPCC requirements.
The system operators who were interviewed indicated that they always make
decisions in the interest of system reliability before any cost considerations.
Operators are given training on NERC code of conduct and company standards of
conduct and indicated that they are well versed in the NERC confidentiality
agreement.
Michel Armstrong signed the NERC Standards of Conduct for TE. Individual on
shift Operators are not required to sign the NERC Standards of Conduct, however,
they are aware of the document and understand its requirements. (Refresher
training is provided along with self-directed training (intranet).
Supporting Documentation
Functional Separation Document 44 D-2002-95, R-3401-98, Quebec Régie de
l’énergie that includes comment on the HQ Standards of Conduct as well, and
supports the TE's functional separation
33199-D/R/I-001,-004, (Access Restrictions)
HQ Standards of Conduct
5. The RA must have decision-making process that is independent of control by
any market participant or class of participants.
An officer of TransÉnergie has signed the NERC Reliability Authority Standards
of Conduct, and TE maintains independence from any merchant functions as
required by FERC Orders #888 & #889. In 1997 Hydro-Québec implemented a
functional separation between TransÉnergie, serving as RA of the Quebec Control
Area, and its merchant function. TransÉnergie complies with the NERC
Reliability Model, and has adopted a Standard of Conduct, to which all RA
______________________________________________________________________________________
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Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
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http://www.powerdecisionsconsult.com
NERC Reliability Authority Audit 2002
personnel are subject to. TransÉnergie customers have been informed of the
existing process ensuring independence of the decision making process from the
influence of customers. TE operating procedures also reflect the independence of
the system control operations.
Supporting Documentation
Functional Separation Document 44 D-2002-95, R-3401-98, Quebec Régie de
l’énergie that includes comment on the HQ Standards of Conduct as well, and
supports the TE's functional separation
33199-D/R/I-001,-004, (Access Restrictions)
HQ Standards of Conduct
6. The RA must know that under Emergency circumstances that jeopardize
operational security, the RA may take whatever steps are necessary to maintain
system security.
The TE Operating Procedures show that the RA has the authority to take
necessary actions in emergency situations, and the shift staff has been instructed
and understands that under emergency circumstances they are expected to take
whatever steps deemed necessary to maintain system security.
System operators must resolve operating security limit (OSL) violations within 15
minutes, which is more stringent than the NERC or NPCC 30 minute standards.
Once the violation is noted by the EMS, a timer starts to let the operator know
how much time remains to resolve the OSL violation. If the violation is not
cleared within the limit time, the RA must complete an event report that is used as
a tool for post event analysis.
In some emergency operating situations a "war room" (system control emergency
center) may be set up to help with special operating situations. This last occurred
about 3-years ago during a HQ strike by union other than CCR system operators.
The shift operators raised a concern that the role of staff who man the war room
should be more clearly defined since a situation did occur that saw an officer of
the company issuing direction to the shift operator.
The shift operators were asked if the y felt that they had authority as described in
the following statement, and concurred that they agree that they have that
authority.
From Supporting Documentation
“If the transmission loading condition is deemed critical to bulk system
reliability by a Re liability Authority, the Reliability Authority has the
authority to immediately direct the Control Areas in his Security Area to redispatch generation, reconfigure transmission, or reduce load to mitigate the
critical condition until Interchange Transactions can be reduced utilizing a
______________________________________________________________________________________
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Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
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NERC Reliability Authority Audit 2002
transmission loading relief procedure, or other procedures, to return the
system to a reliable state.”
Supporting Documentation
(33199-D/R/I-001,-004, 33199-D-014, 33199-U-001, 33199-D-050, GEN-D003,010,011,012,044,052,064,089,144,165,168, plus related GEN-R-xxx docs.)
Emergency Assistance letters to adjacent RA
CCR System Operator training program
7. The Reliability Authority must have adequate staff for 24 hours/day, 7days/week shift coverage by NERC Certified staff.
TE has adequate NERC Certified personnel for 24 hours/day, 7-days/week shift
coverage. Shift operating staff certification numbers were provided and verified
against NERC records. The previous three months’ shift coverage was provided
for review at the on-site audit, and all shifts were covered by NERC Certified
staff.
The three shift positions (Interconnection, Generation and Transmission) are
staffed by six people in each position, and three new staff have been hired in
preparation for expected staff retirements.
8. The RA must have a comprehensive understanding of their Security Area and
the interface with neighboring Security Areas.
TE selects their RA staff from among the most experienced operating personnel.
They have a formal initial training program (approximately 6 months), and a
continuous training program to assure that the RA staff has a comprehensive
understanding of the Security Area and the interface with neighboring Security
Areas.
The Hydro-Quebec’s System Operators Training Document provides a complete
overview of the training requirements and process for System Operators to
specialize in Transmission, Generation, and Interconnection. The document
identified comprehensive level of knowledge and understanding required by each
type of operator. Some of know how requirements are identified below:
Ø Maintain power system within thermal and stability limits
Ø Coordinate power system restoration following a major system shutdown.
Ø Analyze system reserves projections
Ø Manage flows in accordance with procedures for constraints and
preventive measures.
Ø Control active and reactive power and voltage limits on the
interconnections
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NERC Reliability Authority Audit 2002
Shift staff is placed in the “Reliability Authority” (Transmission) position based
on training, and the seniority level the operator has gained in the CCR, and
extensive experience in stations and regional operation. To become an RA, (i.e.
System Operator - Transmission) most of the time, the operator has previously
worked on the generation and exchange desks.
TransEnergie has developed modules for training operators in NERC operating
policies, and requires operators to attend two NPCC seminars a year as part of the
training requirements. NERC certification training begins from the time they are
hired as operators. NERC certification is required before taking over a position.
The trainer uses the EMS study mode, LASER (Security Network Analysis) and
LIMSEL (Limit Selection) study modes to demonstrate operations of the system.
There is also a post analysis after major events. The details of this analysis are
then discussed with the system operators involved. Internal presentations are
arranged from vendors and outside consultants. Some coaching on the job is
provided. The “coach” determines when a trainee is ready to assume shift. Each
position has its own training program. The Transmission desk (RA) has overall
responsibility of assuring system reliability.
Staff meetings and training are held in the spring and the fall to review procedures
for the upcoming season.
Ø During light load conditions such as the June 24 provincial holiday,
some EHV lines are switched out of service. Special system studies
are done by staff engineers.
Ø Heavy loads occur in December and January, winter peaking. System
restoration training is given in the fa ll of each year in preparation for
winter peaks season.
If SMD(s) are projected then special operating procedures are put in effect.
(GEN-D-151) This is true of electrical storms (thunderstorms) (GEN-D-052) and
ice storms as well. (GEN-D-064) TE has a meteorologist on staff.
As rules of operations change, the changes are communicated to each operator by
e-mail and hard copy. Time is provided in the schedule to allow operators to keep
up-to-date with changing procedures. (Operators can come in up to 1- hour before
shift starts to review system conditions after being away a few days.) In addition,
operators are allotted normal shift turnover time (~ 20 minutes). The operators are
required to attend monthly system operator meetings. (Major changes are usually
not implemented until all shift personnel have reviewed them.)
The RA is aware of what contingencies will affect their neighbors and equipment
limitations on other RA systems that may limit TTC on each interconnect.
______________________________________________________________________________________
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NERC Reliability Authority Audit 2002
Because of Ontario deregulating, work load has increased, however the shift staff
feel that shift staffing is adequate at this time. There exists an opportunity to
review shift staffing levels at this time. Each interconnection has specified limits.
E-tag system is used. DC ties are controlled.
The New England ISO replied to their questionnaire indicating that the TE
Reliability Authority provides reliable, timely, day-ahead operating information.
“Because we interconnect through DC ties, our primary information exchange
relates to contract schedules for energy deliveries for the day-ahead commitment
decisions within New England.”
Supporting Documentation
CCR System Operator Training Program
9. The RA main control facility must be supported with a viable back up
operational plan in the event that the main control facility must be evacuated.
The TE main Control Center (CCR) is supported by an operational back-up
control center (BUCC) in the event that the main control room must be evacuated.
The travel time from the main control center to the BUCC is estimated to be about
20-30 minutes. Once the appropriate personnel are on site, it takes about 20-30
minutes to fully activate the facilities.
The BUCC is designed for long-term use and is based on the NERC reference
document. Access is restricted by control cards to a limited set of personnel, and
the facility is remotely monitored (24/7) by security staff at the main CCR.
The BUCC EMS system is a duplicate of the CCR EMS, and no special training is
required for system operators to operate the systems/computers. (GEN-D-089 is a
system operator directive for conditions requiring the transfer to the BUCC.) The
EMS is kept on hot standby, and the status of hardware and software is monitored
by CCR IT staff (24/7). The BUCC is equipped with an independent
communication system that provides all the required data and control capability
and requires no inputs from the main CCR EMS to operate.
Some IT support is required to activate certain software such as AGC and SPS
however, the regional centers can take control of frequency (and voltage) and
monitor SPSs status until the software is activated at the BUCC.
Seven days of historical information is always available at the BUCC. Some
contingencies are automatically responded to by the computer systems. For
example if the Churchill Falls corridor is lost, generation at Churchill is shutdown
and load is removed in Montreal automatically without system operator
intervention.
______________________________________________________________________________________
15
Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
http://www.powerdecisionsconsult.com
NERC Reliability Authority Audit 2002
Operating staff are regularly sent to the BUCC to update procedures and to verify
readiness. BUCC drills are conducted once a year. BUCC is kept up-to-date as
changes are made to the primary CCR (EMS). Activation of BUCC is
coordinated with neighboring RAs.
The BUCC can be activated if there is a loss of data acquisition at the CCR for 45
minutes or greater, or as required because of an evacuation of the CCR.
During either of these events the CCR RA keeps operational control, and some
supervision is continued to be provided to the regional operating centers. With the
help of the CCR staff, the regional centers are capable of assuring system integrity
during transfer to BUCC. Specific regional centers may be asked to monitor
voltage support, VAR support, frequency monitoring, generation/load balancing
and Churchill generation rejection set-points. The auditors are concerned that the
procedure may not be as complete as it should be. Their concern is that the CCR
staff may not be able to provide the on-going advice to the regional centers, prior
to making the BUCC operatio nal. A second concern is that the time to set up the
BUCC may be quite a bit longer than TE expects. The shift operators interviewed
indicated that they believe that expanded field staff training would be valuable.
The BUCC was actually used last year, when the old EMS was out of service for
about 8 hours due to an outage of the Cyber system at the main control center.
The required transfer to the BUCC went well.
A team consisting of operating personnel including three system operators who
are not on shift at the time and other IT support staff conducts the drill on the
BUCC once each year.
The ISO-NE reported that, “When actual evacuations or drills occur, the control
areas exchange voice communications information so constant contact can be
maintained.”
Typically, start up of the BUCC takes about 1-hour. During the 1- hour time
period the Regional centers perform certain operational activities. During transit
to BUCC the shift staff should have communication facilities to keep in contact
with the Regional centers. This requirement could be addressed, by the
availability of cell-phones and prepared telephone lists for the operators. Training
of regional center personnel in the conducting of activities when RA is in-transit
to BUCC may need to be addressed. RA management should take the lead in
addressing this Regional Center training need if one exists.
______________________________________________________________________________________
16
Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
http://www.powerdecisionsconsult.com
NERC Reliability Authority Audit 2002
TE gave a comprehensive presentation on the functionality and operation of its
BUCC, provided the team with the PPT presentation and two members of the
audit team were given a site visit to the BUCC.
Supporting Documentation
BUCC document on functions, testing and training
Operating procedure GEN-D-089
10. The RA must have effective, reliable tools and data to monitor the RA area and
to take appropriate actions to meet their responsibilities.
The TE RA has reliable, effective tools and data to monitor the RA area and take
appropriate actions to meet their responsibilities. They have internal performance
indicators on their main EMS functions and report their EMS performance to the
NPCC TFEMT (Task Force on Energy Management Technology.)
The EMS provides the tools needed to ensure reliability of the Security Area.
Management intends to continue to upgrade the operator tools as the industry
evolves. The new MCCR EMS installed in September 2001 has greatly improved
the operation and capability of the main control center and the BUCC. Scan rates
are 4-5 seconds. Many points are alarmed, and alarms are prioritized according to
importance and there are no problems in detecting problems, or interpreting
alarms.
The MCCR provides an environment that supports applications specific to the
nature of the TE power system and hydraulic generating plants, and complements
other tools such as Security Network Analysis Applications (LASER), Stability
Limits applications (LIMSEL), etc. A list of the main functions of the MCCR is
listed below for information:
Ø data acquisition and processing
Ø map-board interface
Ø disturbance data collection
Ø journals and chronological event summary
Ø equipment management
Ø historical and scheduled data
Ø interface with external systems
Ø automatic generation control
Ø interchange transaction scheduler
Ø generation, load and interchange management
Ø thermal limit calculation in study mode and study mode management
Ø hydraulic applications
______________________________________________________________________________________
17
Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
http://www.powerdecisionsconsult.com
NERC Reliability Authority Audit 2002
The auditors were given a demonstration of the EMS facility. An evaluation of the
new EMS system showed that it provides TE operating personnel with effective
and reliable tools and data to monitor and take appropriate actions to meet its
responsibilities as a Reliability Authority. (TE also utilizes other tools made
available through NERC such as the SCIS, the ISN, and ETAG.)
Thermal limits of lines are calculated on a real- time basis using weather specific
information. Real- time line loadings are projected on a map board in different
colors. LIMSEL and LASER are used to set system limits and to forecast
potential operating problems. A load flow can be used to snap-shot the system to
study specific operating conditions. Tools are very operator friendly. RAs
receive training in tool use, and operator training provided about a year before
new EMS was installed. The system operators that were interviewed indicated
that they are very happy with tools provided.
There is no integrated training simulator however there is a snapshot study mode
capability. Load Flow (and State Estimator) and LIMSEL capabilities are
available in the study mode. Management indicated that a ‘look ahead’ tool to
enable to predict load/generatio n/reserve would be valuable and such a tool is
being looked at. Improvements are underway to make the load flow tool (more
user friendly).
Supporting Documentation
Description of TE computer system for Reliability activities
CCR System Operator Training Program
11. The RA must have reliable voice communication facilities.
The RA has reliable voice communication facilities that meet all required NERC
standards and NPCC criteria related to communications.
TE operates and maintains a very reliable voice communication system with
redundancy (duplicate facilities) and diversity (alternate path) for control of the
main grid and communication among system control centers, telecommunication
centers, and neighboring control centers. Most of the dedicated and dial phone
lines are carried over private microwave, optical or power line carrier links that
are designed and used for all other important communication circuits needed to
operate the electric network, like protection and control circuits. These links are
designed to provide a high degree of reliability. Record showed that telephone
console failures are repaired within seven hours and all dedicated line failures are
back in service within 48 hours. Studies and tests are on-going to replace existing
equipment as required. The RA has the authority over telecom maintenance and
outages.
______________________________________________________________________________________
18
Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
http://www.powerdecisionsconsult.com
NERC Reliability Authority Audit 2002
There is a direct communication line with each regional center. Although the
control room communications equipment is older it is still very useable.
Supporting Documentation
TransEnergie Voice Communication Facilities
12. The RA must be familiar with each Sub-Control Authorities restoration plan
and the RA role in the plan to assist the Sub-member in controlling islanding
and to re-establish normal system configuration.
The TE system restoration plan is well defined and reviewed regularly as system
requirements change. There are 5 individual basic sub-systems to restoring the
system. The sub-systems are updated daily to reflect projected scheduled system
outages that might impact restoration plan. TE participates in the NPCC IRCWG
in coordinating region-wide system restoration and meets all the associated
NERC/NPCC plan requirements.
Black-start facilities are located throughout the TE service area. These facilities
are generally hydraulic units. Testing of black start facilities are performed as
required. Black start facilities are provided by the generation group as part of the
service contract required for reliability purposes.
Training on the system restoration plan takes place twice a year for the CCR
system operators and the regional operators, and a study case is used to “simulate”
a restoration during a desk top exercise that is held once each year.
Supporting Documentation
Network Restoration Strategy Document, 33199-U-001,
Examples of sub Control area restoration plans, 39198-U-952 Regional
emergency procedure for system restoration, and 19108-U-201 MANIC 2
generation station emergency procedures for system restoration
CCR System Operator Training Program
Past 3 years Black Start Testing results
13. Neighboring RA should have a basic level of knowledge of the RA restoration
plans.
The neighbors indicated that they have the necessary information available. The
ISO-NE replied, “We have information on their restoration plan including
facilities critical to their plan. Furthermore, we’ve focused specifically on what’s
needed to tie this RA and all others within the NPCC region together during a
system restoration. A separate document has been jointly prepared for this and
training of operators from all RAs within NPCC is done annually.”
______________________________________________________________________________________
19
Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
http://www.powerdecisionsconsult.com
NERC Reliability Authority Audit 2002
14. The RA must sign appropriate confidentiality documents and maintain the
proper confidentiality procedures and processes during the exercising of the RA
responsibilities.
TransÉnergie signed the “NERC Reliability Authority Standards of Conduct on
October 19, 2000.” TransÉnergie has also its own Standards of Conduct.
Employees related to RA functions have been instructed on the Standards of
Conduct and received a letter from their management reminding them of their
obligations to comply with this Standard. TransÉnergie ’s procedures and
processes ensure that the confidentiality is maintained during the exercising of the
RA responsibilities. Operators are given training on NERC code of conduct and
company standards of conduct, how to handle sensitive system information and
what qualifies as “sensitive information”. System Operators are aware of
confidentiality requirements and need to post information on OASIS if any
information was inappropriately released. Code of Conduct was recently reviewed
as part of web-based training program.
TE has established clear procedure for access to the main control center as well as
to the Back-up Control Center (BUCC). The CCR has a magnetic card entry
access system. One type of card is issued for the control room and a different one
for general access to the building. The CCR system operators must give
permission before a visitor can enter the control room. Security Guards (two) are
on duty at all times. Since September 11, TE no longer allows public visitors to
tour the control center.
TE has internal code of conduct for separation of merchant functions from
operating functions. Notification of personnel transferred from one organization
to another is posted on the OASIS website for 90 days.
Supporting Documentation
Signed NERC Standard of Conduct
Letter to employees on obligation to follow HQ Standards of Conduct
Training Documents
15. The RA must clearly document any RA function that is delegated to anothe r
Operating Authority and must recognize that the RA continues to be responsible
for that function.
At the present time there is no delegation of RA functions to any other Operating
Authority.
16. Examples of good and poor cooperation with neighbors and sub-Operating
Entities
______________________________________________________________________________________
20
Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
http://www.powerdecisionsconsult.com
NERC Reliability Authority Audit 2002
ISO-NE responded:
Ø Phase II imports are restricted by transmission conditions within New England
and within the NYISO and PJM Control Areas. TransEnergie cooperates
completely to support adjustments to those imports as restrictions occur.
Ø Again, we constantly coordinate contract imports on the Phase II facility,
which can be restricted by transmission conditions in the entire Northeast.
Ø During emergency conditions TransEnergie does take immediate action to
relieve the HQ/NY interface when requested by the NYISO Control Room.
Conclusion
The Audit team would like to thank TransEnergie staff for their hospitality and
cooperation during the audit process. We especially want to thank the TE staff for their
effort in gathering the audit support information into a comprehensive set of documents
and also for providing the translations for us.
We trust that our findings are consistent with their understanding of the Reliability
Authority role and that the Audit Team recommendations will prove valuable to the
TransEnergie staff.
Ev Lucenti
Power Decisions Consulting Inc.
Powerdc@rogers.com
Phone 905-281-3494
FAX 905-281-2426
______________________________________________________________________________________
21
Power Decisions Consulting, Inc.
376 Karen Park Crescent, Mississauga, Ontario, Canada L5A 3C6
Tel: 905-281-3494 Fax: 905-281-2426
E-mail: powerdc@rogers.com
http://www.powerdecisionsconsult.com
1515 BROADWAY, NEW YORK, NY 10036-8901 TELEPHONE: (212) 840-1070 FAX: (212) 302-2782
QUEBEC AREA COMPLIANCE REVIEW REPORT
December 1, 2003
Prepared by
The Review Team
1.0
INTRODUCTION
This report provides a summary of the review and findings of the Québec Area
(QA) compliance review conducted on November 10, 2003, at Hydro-Québec
TransÉnergie (TÉ) offices in Montreal Quebec.
The review was conducted in accordance with the Review Process for NPCC
Reliability Compliance Program C-32.
2.0
OBJECTIVE
The primary objective of this review, as identified in the NPCC Review Process
for NPCC reliability Compliance Program, Document C-32, is to ensure that
NPCC meets its obligations in the following areas:
a)
b)
Compliance assessment of standards where the Area has the
reporting responsibility, and
Oversight of the Area compliance assessment
Specifically, the review was to review the QA compliance and processes related
to the following NPCC Compliance Program requirements, as selected by the
NPCC Compliance Monitoring and Assessment Subcommittee (CMAS):
1)
2)
3)
4)
Area Transmission Review (NPCC Compliance Template A2-1).
Generator Underfrequency Tripping (NPCC Criteria A-3, Section 4.9).
Bulk Power System Minimum Maintenance (NPCC, A-4).
Documentation of Protection System Misoperations, Analyses, and Corrective
Actions (NERC Planning Standard Measurement III.A.S3.M5).
3.0
REVIEW
3.1
Review Team Members
The QA review team consisted of the following members:
Mr. John L. Ciufo
Mr. Robert W. Creighton
Mr. Quoc Le
Ontario (Hydro One Networks Inc) TFSP
Maritimes (Nova Scotia Power)
TFSS
NPCC staff
TFSP, CMAS
Members of the TÉ team included:
M. Joseph Fox
M. Mario Pilot
M. Jean-Pierre Gingras
Quebec Area Compliance Review Report
December 1, 2003
TÉ Compliance Coordinator
TÉ PAAR
TÉ-PAAR
CMAS
TFSS
TFCP
1
M. Si Truc Phan
M. François Lévesque
M. Quang Minh Lê
M. Christian Deguire
M. Denis Larose
3.2
TÉ-PAAR
TÉ-PAAR
TÉ-ESTT
TÉ-ESTT
TÉ-ESTT
SS-38
TFSP
General
The review team compiled a series of questions in advance of the review date. TÉ
provided a timely response to the questions in advance of the November 10, 2003
meeting, which greatly expedited the process.
TÉ is to be commended for their complete and well-organized response, which
was provided electronically prior to the review.
This audit did not include specific operational policies because the TÉ Control
Centre was recently the subject of a complete Reliability Coordinator audit, which
CMAS agreed would be adequate, since the NERC audit report indicated full
compliance on all the related requirements. Moreover, TÉ participated to the
NERC/NPCC Compliance program since its launch (1999) providing all the
compliance reports for operation and planning on-time.
3.3
General Support Policies and Processes
With respect to non-affiliated entities TÉ, they have been cooperating and responded to request for data. Participants have always been informed of requirements
in the compliance program, including the annual NPCC compliance workshops.
Participants have maintained good utility practices. TÉ has in place new
agreement that deals with reliability and compliance to reliability standards and
has started to ask participants to sign the agreement. One has signed. The
agreement requires participants to comply with NPCC and NERC standards.
Sanction letters would go according to NPCC document A-08, and when
applicable to the Quebec regulator, the Régie de l’énergie (the Régie).
Although the Régie does not have a direct role in establishing bulk power reliability criteria, TE has provided details of the NPCC standards and compliance program, and any capital expenditures necessary for reliability are approved by the
Régie. The future role of reliability responsibilities is currently under discussion
with respect to the pending US legislation and the way it will interface with
Canadian jurisdictions.
It should be noted that, although there are several wholesale customers and nonaffiliated producers in the QA, only Churchill Falls Labrador is considered to own
bulk power facilities (Churchill Falls is part of the Québec Control Area, although
it is not located in the province of Québec and therefore would not fall under the
jurisdiction of the Régie).
Quebec Area Compliance Review Report
December 1, 2003
2
TÉ follows NPCC A-8, B-22, and C-32.
Organizational structure –
- support is provided through members on the NPCC Task Forces and Working Groups who are closest to the work. M. Fox coordinates and initiates
the process, assign to all members as appropriate.
Starting in 1999 TÉ has assumed responsibility and de facto authority on
compliance in the QA and is now working on new and formal contracts with
market participants.
All questions were answered to the Team’s satisfaction.
3.4
Requirement1 – Area Transmission Review
•
TÉ discussed its more stringent design requirements and principles, which
incorporate load characteristics, service continuity and consideration for
undesirable consequences of severe contingencies. Special Protection
Systems have a role in managing the consequences of extreme contingencies
within the QA.
•
TÉ uses 2.4 hours per year probabilistic approach in resource adequacy
assessment, producing the same reserve requirements to meet the current
intent of the current A-2 wording “once in ten years”.
•
TÉ does not factor in reliability of HVDC as it is not worse than losing the
generation resource itself.
•
Interruptible loads are written into the contract and includes monetary penalty
for non-compliance. Mutually benefit both TÉ and customers.
•
TÉ has identified certain contingencies that require detailed modeling of local
and remote line clearing times in stability studies. They have demonstrated
that transfer limits on critical interfaces could be affected by these details. It
is suggested that other Areas might need to consider this approach. TÉ
provided a sample modeling procedure.
•
TÉ discussed its approach to determining the bulk power system elements,
acknowledging that this topic is under current review within NPCC. Its
approach has been thoroughly tested and may provide a valuable model for
other members of NPCC.
•
TÉ has developed detailed static load models using the EPRI LOADSYN
tools, and incorporates seasonal model variations into its planning studies.
Field measurements had been intended to verify these models, but have been
abandoned due to the great number of uncertainties associated with matching
Quebec Area Compliance Review Report
December 1, 2003
3
disturbances with recordings. There is still work ongoing to incorporate better
models for large industrial loads, especially where load dynamics and inertia
are important to results.
•
TÉ has considerable experience incorporating wind turbine technology into its
grid, and expects more generation in the near future. Although wind
generation is unlikely to form a significant portion of the QA overall, local
transmission and operational issues will require greater attention in the future.
All questions were answered to the Team’s satisfaction. TE should be
recognized for the attention to detail and the extensive documentation
associated with Transmission Area Reviews. The latest Comprehensive Area
Review met the requirements of B-4 and they demonstrated adequately that the
QA is fully compliant with the A-2 Criteria.
3.5
Requirement 2- Generator Underfrequency Tripping (A3, Sec. 4.9)
Only a very few number of generators are equipped with under frequency tripping
relays (most HQ hydro units are not equipped, since they are not a sensitive to
off-frequency operation).
TÉ is an island. – Quebec doesn’t share the frequency of the Eastern Interconnection, although it is no longer considered to be a separate interconnection. The loss
of generation or load on Quebec system results in more impact on its own
frequency. TÉ shares the NPCC objective of frequency recovery. It adjusts its
internal frequency-shedding scheme to meet the objective by using both threshold
and rate of change of frequency to discriminate different system conditions. TÉ
uses a substation adaptive scheme to ensure adequate loading is shed.
TÉ requires Independent Power Producers (IPPs) to meet A-3, Section 4.9, via
their Interconnection Agreements. The following documents were provided in
support:
Entente de raccordement pour l’integration d’une centrale au réseau d’HydroQuébec, dated March 19, 2003.
Sample Interconnection agreement which references the following two standards:
Standard E.12-01 for Distribution, dated February 2002
Exigences relatives au raccordement des centrales au réseau de distribution
d’Hydro-Québec.
Exigences techniques relatives à l'intégration des centrales au réseau de
transport d’Hydro-Québec, dated May 1999.
All questions were answered to the Team’s satisfaction.
Quebec Area Compliance Review Report
December 1, 2003
4
3.6
Requirement 3- Bulk Power System Minimum Maintenance (A4)
TÉ presented to the team their process for protection system scheduling and
maintenance. They use a MAXIMO database program that tracks protection
systems, maintenance, frequencies, and due dates. A list of protection
maintenance scheduled for calendar year 2004 was presented.
TÉ uses an in-house developed database (SAFIR) to generate and distribute relay
settings. SAFIR is also used to record and manage relay calibration test results,
which is an integral part of the relay-setting package.
TÉ uses testing software (SERA) to “drive” automatic test equipment, and
generate test results that are managed via SAFIR. Test records are kept locally
for five years and than archived. The database keeps the last settings applied to
relay and results of latest relay test record.
The Team verified calibration test records for a sample set of selected facilities.
All questions were answered to the Team’s satisfaction.
3.7
Requirement 4- Protection System Misoperations, Analyses, and Corrective
Actions (NERC, III.A.S3.M5)
TÉ presented to the review team their process for analyzing, reporting, and
tracking protection system misoperations. TÉ has a two-part process:
a) Produces analysis report following a disturbance on the system; and
b) Produces follow-up recommendation report resulting from the event analysis
process.
TÉ uses an in-house developed database system called SADA to manage their
event reports and follow up actions. TÉ uses a software tool called SAME to
gather information form Sequence of Event Recorders to aid the analysis and
reporting. SADA tracks all recommendations and follow up actions - issues biannual summary reports. SADA maintains records of system events since 1980.
All supporting DFR and SER records are copied to DVDs.
The review team was presented with the requested documentation for two
incidents, which provided events of full compliance.
All questions were answered to the Team’s satisfaction. TÉ is commended for
their well managed system and use of software tools to automate, and effectively
track protection misoperation events.
Quebec Area Compliance Review Report
December 1, 2003
5
4.0
RECOMMENDATIONS
TÉ provided supporting information, evidence, and answered all questions to the
review team’s satisfaction.
For future audits, it is recommended that some of the key supporting documentation be translated or updated as English versions, which would provide more
efficient information exchange for English speaking auditors. As an alternative,
CMAS could recruit auditors who have a working knowledge of the French
language.
The expertise of TÉ in power system modeling should be acknowledged and
referenced by other Areas.
As the role of NERC and NPCC evolve as US comprehensive energy legislation
brings a new focus to the regulation of reliability, TÉ (as all Canadian members of
NPCC) must ensure that local regulators and market participants continue to be
included in the reliability standards compliance.
5.0
CONCLUSIONS
The review team has found that the Québec Area to be in full compliance with the
NPCC compliance requirements as defined in Section 2.0 above.
The review team would like to commend TransÉnergie for their thorough and
well-organized response, and their well managed reliability monitoring and
compliance systems.
Quebec Area Compliance Review Report
December 1, 2003
6