What Is This NERC?

Kyle Heron, Premier Power MaintenanceFeatures, Winter 2021 Features

We find ourselves in a time where everyday life has become principally reliant on the uninterrupted supply of electricity. Powering our homes, sustaining mass transit infrastructure, and keeping the lights on at our healthcare facilities are prime examples of the importance reliable power holds to our way of life. But as our demand for electric power is ever-growing, our requirement for redundancy and reliability in our power system also scales.

Throughout the history of electrical generation and transmission, a number of devastating events have detrimentally impacted our electrical grid, but they have simultaneously spurred a growing awareness that voluntary guidelines for bulk electric system (BES) operation would simply not ensure reliability. The entity currently responsible for ensuring BES reliability is the North American Electric Reliability Corporation (NERC). But to better understand what NERC is, we’ll need to review the history of electrical generation and usage.

Electricity has been in use for roughly 130 years. In its infancy, it was primarily used in manufacturing, and generation took place onsite for immediate and localized consumption. Through the 1920s–1930s, electric usage began to scale, and generation shifted to a more centralized model that provided access for more Americans and extended it to rural areas. This shift relocated electrical generation farther from our communities, and electrical utilities began interconnecting their delivery systems as a means of increased efficiency. This introduced the need for transmission lines to take electricity to where it would ultimately be used and began the early formation of the bulk electric system — the electrical grid.

The bulk electric system is often referred to as the largest machine in the world, consisting of over 164,000 miles of transmission lines that interconnect a network capable of moving over 750,000 megawatts of electricity throughout the United States and Canada. According to NERC, the BES is defined as all transmission elements operated at 100 kV or higher, and real power and reactive power resources connected at 100 kV or higher. This does not include facilities used in the local distribution of electric energy.

The creation of the BES has allowed us to realize many benefits as the demand for electricity increased, such as increased redundancy of electrical circuits (improved reliability) and access to more sources of generation. But as is commonly the case, added benefits rarely come without compromise, and the bulk electric system’s compromise is the potential shared result of system failures.

HISTORY

One of the earliest examples of this drawback stems back to the Great Northeast Blackout of 1965. At the time, this was the largest power failure in United States history, affecting all of New York state, Connecticut, Massachusetts, New Hampshire, New Jersey, Pennsylvania, Rhode Island, and sections of Ontario, Canada. This catastrophic failure left over 800,000 commuters trapped in New York City’s subways and stranded many more in office buildings and elevators. The culprit of such a large-scale outage was the tripping of one 230-kilovolt transmission line that forced additional load onto many nearby lines, causing them to also fail. This surge of power led to the cascading tripping of additional lines, which ultimately resulted in the collapse of the northeastern transmission network.

Following the Northeast Blackout, the U.S. Electric Power Reliability Act, through the Federal Power Commission (precursor to FERC), urged the development of a council of power coordination responsible for reviewing and publicizing all matters pertaining to electrical power coordination. Until 1968, The North American Power Systems Interconnection Committee (NAPSIC) was the entity that provided guidelines for reliable operation, but the U.S. Electric Power Reliability Act would make way for the National Electric Reliability Council (NERC).

While NAPSIC was focused on reliable operation, NERC’s priority was to maintain regional planning coordination, which was accomplished by delegating through 12 regional organizations that effectively made up all of the power systems operating within the United States. Each region had its own representative on the NERC executive board. This was NERC’s early framework, but one important aspect is that the guidelines and criteria provided by NAPSIC and NERC were completely voluntary and unenforceable.

Over the next two decades, additional large-scale power outages (New York City 1977, western United States 1992) prompted a gradual transition toward enforceable standards with NERC redefining their guidelines as operating policies, and some regional councils agreeing to voluntarily pay fines if determined to be out of policy compliance. At this time, NERC still didn’t have the authority to enforce its policies; it was ultimately the Northeast Blackout of 2003, which saw fifty million people without power, that initiated NERC’s empowerment as a governing authority in electrical reliability.

In 2004, the US–Canada Power System Outage Task Force determined that the primary means to avoid future blackouts and diminish their impact was for the U.S. government to make reliability standards mandatory and enforceable and to upgrade equipment that was approaching its end of life.

VERSION 0 RELIABILITY STANDARDS

NERC’s response to this conclusion was to revise its planning standards and operating policies into a set of reliability standards titled Version 0 Reliability Standards that would be widely embraced and adopted by the NERC Board of Trustees. In addition to implementing the Version 0 Reliability Standards, the Energy Policy Act of 2005 — now signed into law — declared that the Federal Energy Regulatory Commission (FERC) would oversee the creation of an electric reliability organization (ERO) as the authority responsible for enforcing reliability standards. NERC filed separately to be the ERO in the United States and Canada and was named as ERO for both countries by 2006. For the first time since its inception in 1968, NERC would finally have the means to enforce its reliability standards throughout North America.

NERC’s Version 0 Reliability Standards, and all subsequent revisions of NERC Reliability Standards, are developed through an ANSI-accredited process focusing on reliability as well as market principles. The intent behind this foundation for NERC Reliability Standards is to ensure all existing and future standards are written in a way that preserves their objective of reliable planning and operation without negatively impacting competitive electric markets through an unfair competitive advantage. Reliability standards are proposed by NERC, approved by FERC, and ultimately enforced by NERC or the regional entity to which NERC has delegated authority. As of 2021, NERC has 14 mandatory standards subject to enforcement. Those in the electrical testing industry most commonly deal with the standards involving cybersecurity (Critical Infrastructure Protection — CIP), protection and controls testing/commissioning (PRC), and station battery testing and maintenance.

Figure 1: P&C Technicians Perform End-to-End Testing on a D60 Line Relay

CIP

To be able to work at a location where NERC Critical Infrastructure Protection (CIP) standards are in effect requires additional training to ensure workers do not inadvertently connect to an intelligent electronic device (IED), such as a microprocessor relay, in a way that can potentially pass harmful code to the device and result in a CIP violation. This specialized training, usually provided or administered by the customer, is essential to help ensure testing and commissioning activities are CIP-compliant. In addition to training, workers encounter additional requirements including customer-issued laptops dedicated to CIP sites and audits of internal information technology (IT) policies and procedures for CIP compliance.

PRC

While it’s crucial to be mindful of the devices we plug our laptops into as it is pertinent to CIP compliance, we should also be aware of how testing and commissioning differs for NERC PRC compliance. NERC Standard PRC-005, Protection System Maintenance has specific requirements for the testing and commissioning of items like protective relays, instrument transformer circuits, trip paths, protective communication circuits, and alarm reporting.

Figure 2: P&C Technician Reviewing CT Isolations for an HV Transformer Replacement

Every test conducted is required to be properly documented for NERC compliance. Failure to perform required testing or properly complete the necessary documentation can result in the customer being faced with fines of up to $1,000,000 per day, depending on the severity level of the violation or the inability to proceed with system operation in the event of a failed NERC audit.

Additionally, NERC has specific requirements for installation, testing, and maintenance of station batteries that provide the DC control voltage for intelligent electronic devices (IEDs) and substation equipment associated with the bulk electric system. This standard also includes guidelines on how frequently each test must be performed to maintain the security and reliability of the BES.

Figure 3: Fiber-Optic Junction Cabinet Taking Signals from Regulator Controller Back to Remote Terminal Unit

CONCLUSION

Grid reliability improvement has been a constantly evolving practice that will continue to be updated as we meet new challenges capable of threatening the reliable delivery of electrical power to end-users.

NERC’s standards and requirements are not an end-all-be-all answer to eradicating adverse system-wide events, but the goal is that we will avoid the recurrence of another 2003 Northeast Blackout, or an event of a similar scale, through our current protocol.

From a compliance standpoint, my hope is that, rather than approaching this challenge as avoidance of fines and potential system shutdown for non-compliance, operators view this as an opportunity to ensure their utility customers continue to do all in their power to keep the lights on for our homes, mass transit infrastructure, and healthcare facilities.

REFERENCES

(1) United States Environmental Protection Agency. Centralized Generation of Electricity and its Impacts on the Environment, January 4, 2021. Online: www.epa.gov/energy/centralized-generation-electricity-and-its-impacts-environment.

(2) History.com. “The Great Northeast Blackout,” March 4, 2010. Online:
www.history.com/this-day-in-history/the-great-northeast-blackout.

(3) Nevius, David. The History of the North American Electric Reliability Corporation. North American Electric Reliability Corporation, January 2020.

(4) NERC Market Principles. Online: Market_Principles.pdf (nerc.com).

(5) NERC. Milestones — NERC Reliability Standards. Online: Milestones_NERC_Reliability_Standards.pdf.

Kyle Heron joined Premier Power Maintenance in 2019 and is currently the Protection and Controls Sales Coordinator. He graduated from Indiana University Purdue University Indianapolis (IUPUI) with a degree in informatics.