Electric Reliability Organization
Compliance Analysis Report
Reliability Standard TOP-002
Normal Operations Planning
October 2011
3353 Peachtree Road NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com
Table of Contents
Table of Contents .............................................................................................................................ii
ERO TOP-002 Compliance Analysis Report ..................................................................................... 1
Summary of Practical Information and Suggestions....................................................................... 2
Overview of the TOP-002 Standard ................................................................................................ 3
Metrics of TOP-002 Violations ........................................................................................................ 4
Analysis of TOP-002 Violation Descriptions .................................................................................... 7
Conclusion ..................................................................................................................................... 12
ii
ERO Compliance Analysis Report – TOP-002 – October 2011
ERO Compliance Analysis Report
ERO Compliance Analysis Report
NERC and the Regional Entities have completed eight Compliance Analysis Reports to date.
Their focus has been on those Reliability Standards most violated and having the highest actual
or potential impact on reliability. NERC welcomes feedback on which Reliability Standards
should be analyzed for Compliance Analysis Reports as well as important issues once a report
has been announced and posted. NERC recently published a VAR-002 Compliance Analysis
Report addendum that addressed a specific issue with the VAR-002 report.
The purpose of this TOP-002 Compliance Analysis Report is to provide information to the
industry on common violation descriptions and provide feedback on how entities can be
compliant with the Requirements of this standard.
There are three main reasons TOP-002 was chosen for a Compliance Analysis Report:
1. TOP-002 is the 4th most violated non-CIP standard, all-time;
2. TOP-002 is the 5th most violated non-CIP standard in the last 12 months; and
3. TOP-002 is applicable to over 63% of Registered Entities.
ERO Compliance Analysis Report – TOP-002 – October 2011
1
Summary of Practical Information and Suggestions
Summary of Practical Information and Suggestions
This summary is intended to capture the analysis detailed below by providing some essential
elements of the Requirements, and by offering some suggestions for industry consideration. It
is not a complete list of all possible elements or actions. Evaluating or undertaking such actions
or suggestions does not guarantee compliance and does not replace the NERC Reliability
Standards language.
TOP-002 Overview (Common violation descriptions are provided later in this report)
Of the five Requirements with double digit violations:
o Requirement R1 had five of 11 violations self-identified where a lack of
documentation for proving compliance was the main finding.
o Requirement R3 had 16 of 18 violations self-identified where a lack of
documentation for proving compliance was the main finding.
o Requirement R11 had eight of 15 violations self-identified. Most of the seven
violations not self-identified had a potential moderate to severe impact on
reliability. Entities should maintain documentation that it is performing
seasonal, next-day and current day studies.
o Requirement R14 had nine of 11 violations self-identified. Of the two not selfidentified, one had a potential severe impact to reliability as the entity did not
notify their BA and TOP of changes in real and reactive output capabilities. The
generating unit could not come on line at the request of the Independent System
Operator (ISO) due to ongoing maintenance work.
o Requirement R18 had 20 of 22 violations self-identified. Requirement R18 will
be deleted and incorporated into COM-003-1 when it becomes effective.1 The
current draft of COM-003-1 Requirement R7, developed in response to
Recommendation 26 of Final Report on the August 14, 2003 Blackout,2 states:
“Each Reliability Coordinator, Balancing Authority, Transmission Owner,
Transmission Operator, Generator Operator, Transmission Service Provider, Load
Serving Entity and Distribution Provider shall use pre-determined identifiers for
interface Elements/Facilities during verbal and written Operating
Communications.”
Recommendation 26 reads, “Tighten communications
protocols, especially for communications during alerts and emergencies.
Upgrade
communication
system
hardware
where
appropriate.”
1
From the Project 2007-02 Standard Authorization Request (SAR): Operating Personnel Communications
Protocols.
2
Final Report on the August 14, 2003 Blackout in the United Stated and Canada: Causes and Recommendations,”
U.S.-Canada Power System Outage Task Force, April 5, 2004.
ERO Compliance Analysis Report – TOP-002 – October 2011
2
Overview of the TOP-002 Standard
Overview of the TOP-002 Standard
Background
Titled Normal Operations Planning, the purpose of the TOP-002 Reliability Standard is to ensure
that current operations plans and procedures essential for reliable operations are in place,
including planned response to unplanned events. TOP-002-2a is the current version of the TOP002 standard in effect. The NERC Board of Trustees adopted the standard on February 10,
2009, and the effective date was immediately after FERC approval on December 2, 2009. There
are 19 high level Requirements, with three sublevel Requirements. The five registered
functions that TOP-002 applies to are: Balancing Authority (BA), Transmission Operator (TOP),
Generator Operator (GOP), Load Serving Entity (LSE) and Transmission Service Provider (TSP).
As of May 10, 2011, the regional breakdown of the five applicable functions is:
TOP-002 is applicable to 1,216 of the 1,920 Registered Entities, or approximately 63% of all
Registered Entities.
For the 2012 Actively Monitored List (AML), TOP-002 R17 and R18 are both Tier 1 Requirements
and must be audited while all other Requirements for this standard are Tier 2. Tier 1
Requirements are the most critical to the purpose of the Reliability Standard and address the
ERO high risk priorities. Tier 1 requirements represent the minimum audit scope. Tier 2
Requirements are critical to the purpose of the Reliability Standard, but less so than Tier 1. Tier
2 Requirements support the ERO high risk priorities but to a lower degree than Tier 1
Requirements.
ERO Compliance Analysis Report – TOP-002 – October 2011
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Metrics of TOP-002 Violations
Metrics of TOP-002 Violations
TOP-002 Violations by Requirement
Requirement
Violations
Percentage
R1 – BA and TOP maintaining of current plans to evaluate options and set
procedures for reliable operation
11
7.9%
R2 – BA and TOP ensuring its operating personnel participate in system planning
and design study processes
6
4.3%
R3 – LSE and GO coordinating its current-day, next-day, and seasonal operations
with its BA and TSP; BA and TSP coordinating same operations with its TOP
18
12.9%
R4 – BA and TOP coordinating its current-day, next-day, and seasonal operations
with neighboring BAs, TOPs and with its RC
8
5.8%
R5 – BA and TOP planning to meet scheduled system configuration, generation
dispatch, interchange scheduling and demand patterns
6
4.3%
R6 – BA and TOP planning to meet unscheduled changes in system configuration
and generation dispatch
6
4.3%
R7 – BA planning to meet capacity and energy reserve requirements
2
1.4%
R8 – BA planning to meet voltage and/or reactive limits
0
0.0%
R9 – BA planning to meet Interchange Schedules and ramps
1
0.7%
R10 – BA and TOP planning to meet all System Operation Limits (SOLs) and
Interconnection Reliability Operating Limits (IROLs)
2
1.4%
R11 – TOP performing current-day, next-day, and seasonal studies to determine
SOLs; TOP update and make available
15
10.8%
R12 – TSP including known SOLs and IROLs within its area and neighboring areas
0
0.0%
R13 – At request of BA or TOP, GOP shall perform generating real and reactive
capability verifications and provide the results to the BA or TOP as requested
4
3.0%
R14 – GOP notifying their BA and TOP of changes in capabilities and characteristics
in changes in real output capabilities
11
7.9%
R15 – GOP providing a forecast of expected real power output
3
2.2%
R16 – TOP notifying their BA and RC of changes in capabilities and characteristics
in transmission facility status or rating
7
5.0%
R17 – BA and TOP communicating information in R1 through R16 to RC
9
6.5%
R18 – BAs, TOPs, GOPs, TSPs, and LSEs using uniform line identifiers referring to
transmission facilities on an interconnected network
22
15.8%
R19 – BA and TOP maintaining accurate computer models for planning system
operations
8
5.8%
139
100%
Totals
ERO Compliance Analysis Report – TOP-002 – October 2011
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Metrics of TOP-002 Violations
As indicated in the table on the previous page, there are a total of 139 violations of TOP-002.
All of the violations discussed in this report were submitted to NERC by the Regional Entities
prior to July 1, 2011 and relate to both TOP-002-2 and TOP-002-2a.
The average number of violations per Requirement is 7.3, with R18 having 22 violations (most)
with R8 and R12 having zero violations (least). A graphical representation of the TOP-002
violations by Requirement is shown below.
TOP-002 Violations by Requirement
25
2
20
Violations
2
15
7
10
5
16
2
5
6
6
6
1
2
5
4
0
R1
R2
R3
R4
R5
R6
2
20
2
8
2
R7
1
R8
R9
2
1
3
9
3
5
3
6
4
4
R10 R11 R12 R13 R14 R15 R16 R17 R18 R19
Requirement
Self-Identified
Other
Violations by Method of Discovery
An important metric is the number of violations by method of discovery.
TOP-002 Violations by Method of Discovery
Self-Certification
42, 30%
Spot-Check
2, 1%
Complaint
1, 1%
Compliance Audit
25, 18%
Self-Report
61, 44%
Investigation
8, 6%
ERO Compliance Analysis Report – TOP-002 – October 2011
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Metrics of TOP-002 Violations
Self-reports and self-certifications account for 74% of the violations. Registered Entities are
encouraged to self-identify possible violations. This metric shows an active and aggressive
compliance monitoring program and a good internal compliance program (ICP). Next, there
were eight violations discovered through investigations. Of the 78 violations in WECC, 29 (or
37% in WECC) resulted from forced and abrupt registration changes. These 29 violations also
represent over 20% of the total 139 violations.
Violations by Region
This section of the TOP-002 Compliance Analysis Report covers the violations by Region.
Violations
Violations by Region
90
80
70
60
50
40
30
20
10
0
78
14
6
FRCC
0
3
5
MRO
NCEA
NPCC
13
17
3
RFC
SERC
SPP
TRE
WECC
Region
Violations by Date
Trending by violation date shows how the industry is complying with the standard as a whole.
With 15 violations in the first half of 2011, TOP-002 remains a frequently violated standard.
Violations
Violations by Quarter & Year
30
25
20
15
10
5
0
28
23
16
16
7
15
11
5
2Q 3Q 4Q 1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q 1Q 2Q
2007
2008
2009
2010
2011
Quarter & Year
ERO Compliance Analysis Report – TOP-002 – October 2011
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Analysis of TOP-002 Violation Descriptions
Analysis of TOP-002 Violation Descriptions
This section of the TOP-002 Compliance Analysis Report covers common violation descriptions
and recommendations by Requirement.
Requirement 1
R1. Each Balancing Authority and Transmission Operator shall maintain a set of current plans that are
designed to evaluate options and set procedures for reliable operation through a reasonable future time
period. In addition, each Balancing Authority and Transmission Operator shall be responsible for using
available personnel and system equipment to implement these plans to ensure that interconnected
system reliability will be maintained.
Violation Descriptions
Entity states that this Requirement is the responsibility of another entity but has no
documentation to support that another entity has accepted delegation of this
responsibility.
Entity does not have written current day plans for maintaining system reliability,
complete with assessment of current conditions and options for contingencies.
Entity failed to maintain a set of current plans designed to evaluate options and set
procedures for reliable operation through a reasonable future time period.
Suggested Enhancements with R1
If the set of current plans designed to evaluate options and set procedures for reliable
operations are the responsibility of another entity, the Registered Entity needs to have
an agreement in place showing the other entity has accepted delegations of this
responsibility.
Requirement 3
R3. Each Load Serving Entity and Generator Operator shall coordinate (where confidentiality
agreements allow) its current-day, next-day, and seasonal operations with its Host Balancing Authority
and Transmission Service Provider. Each Balancing Authority and Transmission Service Provider shall
coordinate its current-day, next-day, and seasonal operations with its Transmission Operator.
With 18 violations in five different Regions, there is a need for guidance to the industry on
compliance information with this Requirement. Eight of the violations were from entities
registered as GOPs, nine from entities registered as LSEs, one from an entity registered as both
a GOP and LSE, and one from entity registered as a BA. It is important to note that all violations
were self-identified.
Violation Descriptions
With the exception of one of its facilities, the entity did not provide evidence that
current-day, next-day and seasonal operations had been coordinated with its host
Balancing Authority and Transmission Service Provider.
ERO Compliance Analysis Report – TOP-002 – October 2011
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Analysis of TOP-002 Violation Descriptions
The system operator was not required to significantly alter their dispatch operating plan
due to the unavailability of the Generator and has not otherwise made any findings of
adverse impacts to the Bulk Electric System due to the outage approval failure.
The entity did not provide the host BA the generation resources availability for one day.
The entity did not provide the host BA the load forecast for one day.
An entity had been providing a 14-day forecast of planned power exports. The export forecast
was emailed as updates that occurred, typically 2-3 times per week and not on weekends.
Upon discovering this information was not being sent daily, the entity self- reported a possible
violation and began emailing the two-week export forecast daily, including weekends.
Suggested Enhancements with R3
Processes and records of actions should be kept to verify the appropriate coordination is
completed.
Requirement 4
R4. Each Balancing Authority and Transmission Operator shall coordinate (where confidentiality
agreements allow) its current-day, next-day, and seasonal planning and operations with neighboring
Balancing Authorities and Transmission Operators and with its Reliability Coordinator, so that normal
Interconnection operation will proceed in an orderly and consistent manner.
There has been only one violation of Requirement R4 from the beginning of 2010.
Violation Descriptions
Interview confirmed the entity does not provide this information with its neighboring
BA, TOP, and RC.
Suggested Enhancements with R4
Procedure should be in place that identifies entities with which coordination should
occur.
Records of coordination should be maintained.
Requirement 11
R11. The Transmission Operator shall perform seasonal, next-day, and current-day Bulk Electric System
studies to determine SOLs. Neighboring Transmission Operators shall utilize identical SOLs for common
facilities. The Transmission Operator shall update these Bulk Electric System studies as necessary to
reflect current system conditions; and shall make the results of Bulk Electric System studies available to
the Transmission Operators, Balancing Authorities (subject to confidentiality requirements), and to its
Reliability Coordinator.
Roughly half of the violations of this Requirement were discovered through a compliance audit.
It is important to note that failing to perform current day and next day operational studies does
not prepare the TOP for what to expect for the next day of operations.
ERO Compliance Analysis Report – TOP-002 – October 2011
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Analysis of TOP-002 Violation Descriptions
Identifying critical issues that could cause a cascading failure is critical to understanding how
the system should be operated. Failing to understand this costs lots of time in an emergency.
Failure to perform assessment of current and next day studies when system conditions are in a
normal state could lead to a lack of situational awareness by Transmission Operators.
Furthermore, the operating personnel need to provide input on observed problems not
predicted by studies.
Violation Descriptions
Entity did not perform seasonal, next-day, and current-day BES studies to determine
SOLs. Therefore, the entity could not utilize identical SOLs for common facilities among
its neighboring TOPs and the entity could not update these BES studies as necessary to
reflect current system conditions and make the results of BES studies available to the
TOPs, BAs (subject to confidentiality requirements), and RC.
Entity did not produce any evidence that it independently performs these studies and
did not produce evidence that there is an agreement with the RC to produce studies
compliant with this requirement.
Entity failed to perform seasonal, next-day, and current-day BES studies to determine
SOLs.
Through the Registered Entities' notification at the spring 2010 Compliance Workshop,
the registered entity has stated that the RTO current and next-day studies are not
sufficient for a TOP to use to meet the requirements in TOP-002-2a R11. The Registered
Entity does not perform current and next-day studies and has relied on the RTO
reporting in the past.
Suggested Enhancements with R11
Entities must provide evidence that valid studies for current and next-day are available.
Requirement 14
R14. Generator Operators shall, without any intentional time delay, notify their Balancing Authority and
Transmission Operator of changes in capabilities and characteristics including but not limited to:
Changes in real output capabilities.
Violation Descriptions
Entity did not make timely notification of change in real-time output of units due to
reduction of the unit capability due to loss of fuel.
Changes in capabilities and characteristics are not being reported to the TOP.
Interview confirmed that the entity does not currently provide generator capability
updates to its BA.
Entity did not update RC on change in the capability of its generation resources on
11/29/07.
Suggested Enhancements with R14
ERO Compliance Analysis Report – TOP-002 – October 2011
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Analysis of TOP-002 Violation Descriptions
Develop a process or procedure to inform both the BA and TOP of changes in real
output capabilities.
Develop a process to document such notifications.
Requirement 16
R16. Subject to standards of conduct and confidentiality agreements, Transmission Operators shall,
without any intentional time delay, notify their Reliability Coordinator and Balancing Authority of
changes in capabilities and characteristics including but not limited to: Changes in transmission facility
status or rating.
Violation Descriptions
Entity self-reported they did not notify their RC of a change in the facility rating of a
transformer.
Suggested Enhancements with R16
Implementation of a process or procedure to notify both the BA and the RC of such
changes.
Document, through e-mails, log entries or other such records, such notification.
Requirement 17
R17. Balancing Authorities and Transmission Operators shall, without any intentional time delay,
communicate the information described in requirements R1 to R16 above to their Reliability Coordinator.
Violation Descriptions
Study results not communicated to the RC.
Suggested Enhancements with R17
Document, through e-mails, log entries or other such records, such notification.
Requirement 18
R18. Neighboring Balancing Authorities, Transmission Operators, Generator Operators, Transmission
Service Providers and Load Serving Entities shall use uniform line identifiers when referring to
transmission facilities of an interconnected network.
Requirement R18 is an important Requirement and may not be as well understood to the
industry as it could be. Using the same uniform line identifiers for substations and transmission
lines is critical to real-time communications and operations. In one Region, the general practice
adopted is to identify substation to substation for developing uniform line identifiers. It is
supported by one of the RC’s outage scheduling tools, and thus is used by all of the appropriate
entities.
Exchanging naming conventions is the first step toward developing uniform line identifiers. This
may be an area where the industry lacks understanding as there may be a lack of explicit
coordination between the RCs, BAs, TOPs, GOPs, TSPs, and LSEs to use the same naming
conventions for substations and transmission lines. For example, there has been a concern
ERO Compliance Analysis Report – TOP-002 – October 2011
10
Analysis of TOP-002 Violation Descriptions
from the industry on why GOPs should have naming conventions for transmission lines when
they do not own them. As such, GOPs are not required to have naming conventions, but are
required to use uniform line identifiers when communicating with other entities, such as their
interconnecting TOP. Furthermore, as a good practice example, two TOPs discussing an outage
use the uniform line identifiers that relate to their RC’s outage scheduler.
As stated in the summary section earlier in this report, this Requirement will no longer be in
effect when COM-003-1 is effective.
Violation Descriptions
Entity was unable to demonstrate that transmission line and equipment identifiers used
were uniform with the identifiers used by the interconnected transmission operator.
Designators used on 115 kV devices not consistent with TOP/TSP designations.
Suggested Enhancements with R18
Identify all interconnection entities and exchange with them your naming conventions
for all affected transmission facilities.
Document a process that verifies with the appropriate interconnected entities that they
are using uniform line identifiers.
ERO Compliance Analysis Report – TOP-002 – October 2011
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Conclusion
Conclusion
TOP-002 is a NERC Reliability Standard that is critical to the reliability of the Bulk Power System.
As the violations continue to steadily accumulate, the ERO needs to provide feedback that will
aid the Registered Entities with compliance. Already in 2011 there have been 22 violations of
TOP-002, so this report was written to curtail that number for 2011 and inform the industry of
important compliance information with this standard.
Registered Entities should go through this report and read common violation descriptions, and
make sure they provide and maintain evidence that covers all facets of the Requirements. It is
also advised that the Registered Entities have an active and aggressive compliance monitoring
program, a strong internal compliance program, and a solid culture of compliance within their
organizations.
If you have any questions, please see below for contact information.
Contact Information
Mike Moon
Director of Compliance Operations
404.446.2567
Michael.Moon@nerc.net
ERO Compliance Analysis Report – TOP-002 – October 2011
Ryan Stewart
Engineer of Organization Registration,
Certification, and Compliance Monitoring
404.446.2569
Ryan.Stewart@nerc.net
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