Confidential Information (including Privileged and Critical Energy Infrastructure Information)
Has Been Removed
Compliance Audit Report
Public Version
Millennium Power Partners, LP
NERC ID# NCR07144
Confidential Information (including Privileged and
Critical Energy Infrastructure Information)
Has Been Removed
Date of Audit: February 21 to March 25, 2011
Confidential Information (including Privileged and Critical Energy Infrastructure Information)
Has Been Removed
TABLE OF CONTENTS
Executive Summary ........................................................................................................................ 1
Audit Process .................................................................................................................................. 1
Objectives .................................................................................................................................... 2
Scope ........................................................................................................................................... 2
Confidentiality and Conflict of Interest .................................................................................. 2
Methodology ............................................................................................................................... 3
Company Profile ......................................................................................................................... 3
Audit Participants ....................................................................................................................... 4
Audit Results................................................................................................................................... 4
Findings ...................................................................................................................................... 5
Compliance Culture .................................................................................................................... 5
Millennium Power Partners, LP Compliance Audit Report
March 25, 2011
Page i of 5
Confidential Information (including Privileged and Critical Energy Infrastructure Information)
Has Been Removed
Executive Summary
A compliance audit of Millennium Power Partners, LP (MPP), NERC ID # NCR07144 was
conducted from February 21, 2011 to March 25, 2011. At the time of the audit, MPP was
registered for the GO and GOP functions.
The audit team evaluated MPP for compliance with seventy-four (74) of the seventy-seven (77)
requirements/sub-requirements in the 2011 NERC Compliance Monitoring and Enforcement
Program (CMEP). The audit team assessed compliance with the NERC Reliability Standards and
applicable Regional Reliability Standards for the period of June 21, 2007 to February 21, 2011.
MPP submitted information and documentation for the audit team’s evaluation of compliance
with the requirements. The audit team reviewed and evaluated all information provided by MPP
to assess compliance with standards applicable to MPP at this time.
Based on the information and documentation provided by MPP, the audit team found MPP to
have no findings of non-compliance with forty-one (41) applicable requirements/subrequirements. The audit team determined that thirty-three (33) requirements/sub-requirements
were not applicable to MPP. Three (3) of the requirements/sub-requirements were not audited,
as they are involved with a pending investigation of a Self-Reported Violation. The audit team
identified Zero (0) Possible Violation(s).
There were no ongoing or recently completed mitigation plans and therefore none were reviewed
by the audit team. There is a pending investigation of a self-report by MPP regarding VAR-0021.1b R3 which was not included as part of this audit review.
Any Possible Violations were processed through the NERC and NPCC CMEP. The following is
a link to the general NOP page located on the NERC public website:
http://www.nerc.com/filez/enforcement/index.html
The NPCC audit team lead certifies that the audit team adhered to all applicable requirements of
the NERC Rules of Procedure (ROP) and Compliance Monitoring and Enforcement Program
(CMEP). *
Audit Process
The compliance audit process steps are detailed in the NPCC CMEP. The NPCC CMEP
generally conforms to the United States Government Accountability Office Government
Auditing Standards and other generally accepted audit practices.
*
This statement replaces the Regional Entity Self-Certification process.
Millennium Power Partners, LP Compliance Audit Report
March 25, 2011
Page 1 of 5
Confidential Information (including Privileged and Critical Energy Infrastructure Information)
Has Been Removed
Objectives
All Registered Entities are subject to an audit for compliance with all reliability standards
applicable to the functions for which the Registered Entity is registered. † The audit objectives
are to:
·
·
·
·
·
·
Review compliance with the requirements of reliability standards that are applicable to
MPP, based on the functions that MPP is registered to perform;
Validate compliance with applicable reliability standards from the NERC 2011
Implementation Plan list of actively monitored standards and additional NERC
Reliability Standards selected by NPCC;
Validate compliance with applicable regional standards from the NPCC 2011
Implementation Plan list of actively monitored standards;
Validate evidence of self-reported violations and previous self-certifications;
Observe and document MPP’s compliance program and culture;
Review the status of mitigation plans.
Scope
The scope of the compliance audit included the NERC Reliability Standards from the NPCC
2011 Implementation Plan. There were no mitigation plans or remedial action directives which
have been completed or pending in the year of the compliance audit. There is a pending
investigation of a self-report by MPP regarding VAR-002-1.1b R3 which was not included as
part of this audit review.
At the time of the audit, MPP was registered for the functions of GO and GOP. The audit team
evaluated MPP for compliance during the period of June 21, 2007 to February 21, 2011.
Confidentiality and Conflict of Interest
Confidentiality and conflict of interest of the audit team are governed under the NPCC
Delegation Agreement with NERC and Section 1500 of the NERC Rules of Procedure. MPP was
informed of NPCC’s obligations and responsibilities under the agreement and procedures. The
work history for each audit team member was provided to MPP. MPP was given an opportunity
to object to an audit team member’s participation on the basis of a possible conflict of interest or
the existence of other circumstances that could interfere with an audit team member’s impartial
performance of duties. MPP had not submitted any objections by the stated fifteen day objection
due date and accepted the audit team member participants without objection. There have been no
denials of or access limitations placed upon this audit team by MPP.
†
North American Electric Reliability Corporation CMEP, paragraph 3.1, Compliance Audits
Millennium Power Partners, LP Compliance Audit Report
March 25, 2011
Page 2 of 5
Confidential Information (including Privileged and Critical Energy Infrastructure Information)
Has Been Removed
Methodology
The audit team reviewed the information, data, and evidence submitted by MPP and assessed
compliance with requirements of the applicable reliability standards. Submittal of information
and data were sent to NPCC before the scheduled date of the entity review. Additional
information relevant to the audit could be submitted until the conclusion of the exit briefing.
After that date, only data or information which was relevant to the content of the report or its
finding can be submitted upon agreement by the audit team lead.
The audit team requested and received additional information and sought clarification from
subject matter experts during the audit.
The audit team reviewed documentation provided by MPP. Data, information and evidence
submitted in the form of policies, procedures, e-mails, logs, studies, data sheets, etc. which were
validated, substantiated and cross-checked for accuracy as appropriate. Requirements which
required a sampling to be conducted were developed based upon the significance of the sampling
to the reliability of the bulk electric system (BES).
Findings were based on the audit team’s knowledge of the BES, the NERC Reliability Standards
and their professional judgment. All findings were developed based upon the consensus of the
audit team.
Company Profile
Millennium Power Partners, LP is owned by MachGen, LLC. Millennium is managed and
operated by two companies; Competitive Power Ventures, Inc (CPV) serves in the capacity of
Asset Manager and serves as the owner’s representative and NAES Corporation provides
operations and maintenance staffing and services. All of the employees on the plant site
including the plant manager are employees of NAES.
Millennium is located in Charlton, Massachusetts. Millennium’s system from the generator tie
lines to the interconnection is less than one mile and is connected via one interconnection point
to National Grid’s W-123 line (115kV) which connects to National Grid’s Carpenter Hill
substation located in Charlton, MA.
Millennium is a one CT x One ST combined cycle plant. The combustion turbine generator
voltage is 16.0kV and the steam turbine generator voltage is 13.8kV. The voltage from each
generator flows through separate step-up transformers, manufactured by North American
Transformers, located on site, and is stepped up to the 115kV. The combustion turbine generator
is a Siemens-Westinghouse 501G with a nameplate MW rating of 230MW. The steam turbine
generator is a Siemens-Westinghouse unit with a nameplate MW rating of 130MW.
Millennium’s peak output is 385MW and occurs in the winter.
Millennium Power Partners, LP Compliance Audit Report
March 25, 2011
Page 3 of 5
Confidential Information (including Privileged and Critical Energy Infrastructure Information)
Has Been Removed
Audit Participants
The following is a listing of all personnel from the Audit Team and MPP who were present
during the meetings or interviews.
NPCC Audit Team Participants
Title
Entity
Lead Auditor
Senior Compliance Engineer
AVP-Compliance Audits and Investigations
NPCC
NPCC
NPCC
Millennium Power Partners, LP Audit Participants
Title
Entity
Vice President
Compliance Officer
Plant Manager
Plant Engineer
CPV
CPV
NAES
NAES
Audit Results
The audit team evaluated MPP for compliance with seventy-four (74) of the seventy-seven (77)
requirements/sub-requirements in the 2011 NERC Compliance Monitoring and Enforcement
Program (CMEP). The audit reviewed NERC Reliability Standards for the period of June 21,
2007 to February 21, 2011. MPP submitted information and documentation for the audit team’s
evaluation of compliance with requirements. The audit team reviewed and evaluated all
information provided by MPP to assess compliance with standards applicable to MPP at this
time.
Based on the information and documentation provided by MPP, the audit team found MPP to
have no findings of non-compliance with forty-one (41) applicable requirements/subrequirements. The audit team determined that thirty-three (33) requirements/sub-requirements
were not applicable to MPP. Three (3) of the requirements/sub-requirements were not audited as
they are involved with a pending investigation of a Self-Reported Violation. The audit team
identified Zero (0) Possible Violation(s).
Millennium Power Partners, LP Compliance Audit Report
March 25, 2011
Page 4 of 5
Confidential Information (including Privileged and Critical Energy Infrastructure Information)
Has Been Removed
Findings
The following table details the findings for compliance for the scope identified for this audit.
Reliability Standard
Requirement
Finding
CIP-001-1
CIP-001-1
CIP-001-1
CIP-001-1
COM-001-1.1
COM-002-2
FAC-008-1
FAC-008-1
FAC-009-1
FAC-009-1
IRO-004-1
IRO-005-2
PRC-001-1
PRC-001-1
PRC-001-1
PRC-001-1
PRC-004-1
PRC-005-1
PRC-005-1
PRC-017-0
PRC-017-0
PRC-023-1
PRC-023-1
TOP-002-2a
TOP-002-2a
VAR-002-1.1b
VAR-002-1.1b
VAR-002-1.1b
R1.
R2.
R3.
R4.
R6.
R1.
R1.
R2.
R1.
R2.
R4.
R13.
R1.
R2.
R3.
R5.
R2.
R1.
R2.
R1.
R2.
R1.
R2.
R3.
R18.
R1.
R2.
R3.
No Finding
No Finding
No Finding
No Finding
N/A
No Finding
No Finding
No Finding
No Finding
No Finding
No Finding
No Finding
No Finding
No Finding
No Finding
No Finding
No Finding
No Finding
No Finding
N/A
N/A
N/A
N/A
No Finding
No Finding
No Finding
No Finding
Not Audited
Compliance Culture
MPP’s compliance culture was reviewed by the audit team. During all contacts, the MPP audit
representatives were very professional and positive in their approach to compliance. All
additional information and data requested was provided promptly, comprehensively and well
organized. MPP exhibited a positive commitment to compliance with the NERC standards.
Additional information pertaining to the compliance culture of MPP can be found in the Internal
Compliance Survey contained in the Pre-Audit Survey.
Millennium Power Partners, LP Compliance Audit Report
March 25, 2011
Page 5 of 5