' Y2K Coordination Plan for the Electricity Production and Delivery Systems of North America
Phase 1: June-September 1998 Initial Assessment and Coordination
June 12, 1998
Department of Energy Request
The U.S. Department of Energy has asked the North American Electric Reliability Council (NERC) to assume a leadership role in preparing the electricity production and delivery systems of the United States for the transition to the Year 2000 (Y2K). This transition effort is necessary because certain software and hardware in use in the electric and other industries use a two-digit code to represent the last two digits of the year. As a result, these software and hardware may misinterpret the change from 1999 to the Year 2000 as they process data. DOE's request is part of a broad initiative by the President of the United States to ensure that infrastructure essential to the nation's security and well being remains operational during critical Y2K transition periods. The letter to NERC from the Secretary and Deputy Secretary of Energy is provided in Appendix A. DOE requests a status report and coordination plan by September 1998 and a full status report by July 1999. The status reports will review the measures that are being taken to prepare the electric power production and delivery systems for the transition to Y2K. Because NERC is an international organization and the electricity systems of the United States are interconnected with those of Canada and a part of Mexico, NERC's plan, of necessity, must include all of these interconnected systems. Thus, this document defines NERC's initial plan for coordinating the Y2K preparedness plans of the electric utilities that operate the electricity systems of North America.
Consolidating the Prior Work of the Industry
Y2K is not a new issue to the electric industry. NERC, its ten Regional Reliability Councils, and their members recognized the threat posed by Y2K several years ago and have been working toward solutions at several levels. Although the effort to date has not been entirely consistent across the industry, most electric utilities have established Y2K programs and invested substantial personnel and technical resources in identifying and resolving Y2K problems. The industry has been testing critical software, and embedded digital controllers, and working with vendors to find solutions. NERC and the ten Regional Reliability Councils have been providing high-level coordination of Y2K efforts, principally through technical committee activities and information sharing through the NERC web site at www.nerc.com.
Nearly all of the detailed problem identification and resolution to date has been performed by the individual electric utilities. Those electric utilities that have attacked the problem aggressively are to be commended. However, NERC's concern is that all electric utilities with a direct reliability impact on North American electrical Interconnections must address the Y2K problem in a coordinated manner. This concern is due to the high degree of interdependence of electric systems within an electrical Interconnection. One unprepared system has the potential to adversely impact the operation of the rest of the Interconnection.
In response to the DOE letter, the NERC Y2K program will focus activities in three principal areas: a) sharing of Y2K solutions, b) identifying potential weaknesses in interconnected system security, and c) operational preparedness. DOE's request provides NERC with an opportunity and a challenge to coordinate the efforts of individual Regions and electricity providers across North America toward a collective goal of maintaining secure operation of the electric systems through critical Y2K transition periods.
Importance of Meeting the Challenge
More than any other element of the North American economic and social infrastructure, the electricity production and delivery systems must be dependable during the transition to Y2K. Every other critical element of infrastructure depends on the availability of an interconnected, reliable supply of electrical power. There is no doubt that cascading or even localized outages of generators and transmission facilities could have serious short- and long-term consequences.
The Weakest Link Concept
The electric systems of North America are connected within four large Interconnections The largest, the Eastern Interconnection, covers the eastern two-thirds of North America, including the United States and Canada. The second largest, the Western Interconnection, covers the western one-third of the U.S. and Canada, as well as a portion of the Baja California Norte region of Mexico. The other two Interconnections include 1) most of the state of Texas - also known as the ERCOT Region - and 2) the Quebec Interconnection, which covers the province of Quebec, Canada.
Each of these four Interconnections is a highly connected network. A major disturbance within one part of an Interconnection will rapidly have an impact throughout the Interconnection and has the potential to cascade the effect to the entire Interconnection. The four Interconnections are for the most part independent from each other, because they are connected by comparatively small high voltage direct current (HVDC) electrical ties and do not interconnect synchronously. The one notable exception is the major HVDC tie lines from Hydro-Quebec into the Northeastern United States. Loss of these facilities and the power supply from Quebec can have a substantial impact on power delivery systems in the Northeastern portion of the United States.
Within each Interconnection, power production and delivery systems are highly interdependent. In general, systems are operated such that the loss of one facility, or in some cases two or three facilities, will not cause cascading outages. Y2K poses the threat that common mode failures (such as all generator protection relays of a particular model failing simultaneously) or the coincident loss of multiple failures may result in stressing the electric system to the point of a cascading outage over a large area.
This high level of interdependence within an Interconnection means that the robustness of the overall system needs to be tested against this new "contingency." An individualistic approach to the problem may not cover all potential problem areas, e.g., coordination with neighboring utilities, and, thus, could adversely affect operations within an Interconnection. An individual electric utility that invests tens of millions of dollars in solving Y2K problems could be affected in a major way by an outage initiated in neighboring systems that have not been as diligent. Therefore, preparation of the electricity power production and delivery systems in North America must be a coordinated team effort by those entities responsible for system reliability. All preventive programs do not have to be the same, but they do have to be coordinated. The industry will succeed or fail together in its readiness for Y2K.
Although the written request that sparked initiation of the NERC coordination program was received from the U.S. Department of Energy, NERC recognizes that maintaining grid security during the Y2K transition is an international issue requiring coordination with the United States, Canadian, and Mexican governments.
Nature of the Y2K Problem in Electricity Production and Delivery
Maintaining a reliable supply of electricity during the Y2K transition is not an insurmountable task. There are four critical areas that pose the greatest direct threat to power production and delivery:
Power production - Generating units must be able to operate through critical Y2K periods without inadvertently tripping off-line. The threat is most severe in power plants with digital control systems (DCSs). Numerous control and protection systems within these DCS use time-dependent algorithms that may result in unit trips. Most older plants operating with analog controls will be less problematic. Digital controllers built into station equipment, protection relays, and communications also may pose a threat.
Energy management systems - Control computer systems within the electric control centers across North America use complex algorithms to operate transmission facilities and control generating units. Many of these control center software applications contain built-in time clocks used to run various power system monitoring, dispatch, and control functions. Many energy management systems are dependent on time signal emissions from Global Positioning Satellites, which reference the number of weeks and seconds since 00:00:00 UTC January 6, 1980. In addition to resolving Y2K problems within utility energy management systems, these supporting satellite systems, which are operated by the U.S. government, must be Y2K compliant.
Telecommunications - Electric supply and delivery systems are highly dependent on microwave, telephone, and VHF radio communications. The dependency of the electric supply on facilities leased from telephone companies and commercial communications network service providers is a crucial factor. With telecommunications systems being the nerve center of the electric networks, it is important to address the dependencies of electric utility systems on the telecommunications industry during critical Y2K transition periods. Protection systems - Although many relay protection devices in use today are electromagnetic, newer systems are digital. The greatest threat here is a common mode failure in which all the relays of a certain model fail simultaneously, resulting in a large number of coincident transmission facility outages.
Scope is Electric Power Production and Delivery Systems
Several key elements are identified in this goal statement. First, the initial focus is on power production and transmission facilities. The goal is to maintain the "backbone" of the electricity supply infrastructure. As such, NERC will work closely with entities responsible for the operation and security of electric systems. These entities include:
NERC Regional Reliability Councils Control Areas within the four major electrical Interconnections in North America NERC Security Coordinators Independent System Operators Owners/operators of high voltage transmission facilities Owners/operators of bulk power generating facilities Owners/operators of distribution supply system not included in the other categories
NERC will initially focus on the bulk electric systems because distribution systems are generally radial from the bulk supply network and cannot function without a robust bulk supply network or Interconnection. The Interconnection can function without reliable radial distribution systems. Maintaining the operability of this electric supply backbone may be the single most important step toward supporting our North American infrastructure during the Y2K transition. The Y2K needs of distribution systems will become understandable as bulk power supply issues are resolved.
As discussed in the next section, NERC is likely to work closely with other organizations to address the coordination of electricity distribution aspects of the Y2K problem. Likely participants in this joint effort include DOE, the Electric Power Research Institute, Edison Electric Institute, the National Rural Electric Cooperative Association, the American Public Power Association, and others.
Defense in Depth
The second key element of the goal statement is that NERC is focused on operational security through a "defense-in-depth" concept, which has been well developed in the design and operation of nuclear facilities. The defense-in-depth concept assumes that although one has taken all reasonable and necessary preventive steps, there can never be one hundred percent assurance that major system failures cannot cause a catastrophic outcome. Instead, multiple defense barriers are established to reduce the risk of catastrophic results to extremely small probability levels and to mitigate the severity of any such events.
It is certain that not all Y2K problems have been or will be identified, fixed, and tested in the time remaining. Also, it would not be prudent to expend unlimited resources on potential problems in search of one hundred percent avoidance of component failures. The cornerstone of the NERC Y2K plan, therefore, is to coordinate industry actions in implementing the following defense-in-depth strategy:
1.Identify and fix known Y2K problems.
NERC is providing a vehicle for sharing of information on known and suspected Y2K problem areas and solutions associated with the operation, control, and protection of bulk power generation and transmission facilities. From this information exchange, a master list of critical Y2K problem areas and solutions will be developed and made widely available. NERC will initiate a reporting process for key entities to report progress against specific criteria designed to address a known list of Y2K problem areas. Through its Regional Reliability Councils, NERC will review the progress of these entities to verify that appropriate measures are being taken by all responsible parties. This identification of problem areas, solutions, and testing of the solution is a process that will continue into the millenium.
2.Identify worst case conditions.
NERC will coordinate the conduct of Regional and individual system simulations to identify moderate and worst-case scenarios in response to various classes of Y2K failures. Specific classes of failures that result in the worst conditions will be examined further to determine possible fixes and preventive or mitigation measures.
3.Prepare for the worst.
NERC will coordinate efforts to prepare for safe operation of the electric systems under potential worst-case conditions. Preparations will include development of special operating procedures and conducting training and system-wide drills.
4.Operate systems in a precautionary posture during critical Y2K transition periods.
NERC will coordinate efforts to operate transmission and generation facilities in precautionary configurations and loadings during critical Y2K periods. Examples of precautionary measures may include reducing the level of planned electricity transfers between utilities, placing all available transmission facilities into service, bringing additional generating units on-line, and rearranging the generation mix to include older units with analog controls. Another example is increased staffing at control centers, substations, and generating stations during critical periods. Fortunately, from an electric reliability perspective, New Year's Eve falls on Friday, December 31, 1999, and January 1 is a Saturday. Therefore, electric system conditions are likely to be favorable with the level of electricity transfers at light levels and extra generating capacity available during the most critical period.
NERC's Y2K program depends on cooperation by the electric utilities of North America. NERC does not currently have the authority in its Bylaws to order electric utilities to take Y2K corrective actions. Nor does NERC currently have the authority to conduct inspections or enforce compliance. The binding obligations of electric utilities are embodied in state and federal laws, filed transmission tariffs, and contractual agreements. Electric utility legal responsibilities are to shareholders, customers, the public, and state and federal regulators. NERC's role is to facilitate North American-wide coordination so that the collective efforts of the industry will minimize risks imposed by Y2K to a reliable supply of electricity.
The roles and responsibilities of participants in the NERC Y2K program are defined below:
NERC - NERC staff and support contractors will coordinate the NERC Y2K efforts defined within this plan. This activity includes collecting, consolidating, and distributing information on Y2K problems and solutions, and it includes coordination of system studies and preparedness plans. The information collected will be compiled into a report that will periodically be presented to the NERC Board of Trustees and DOE.
NERC Regional Reliability Councils - Regional staff will coordinate NERC Y2K activities within their Regions. Responsibilities are similar to those listed above for NERC, but at the Regional level.
NERC Operating and Security Entities - Operating entities, such as Control Area Operators, Security Coordinators, Independent System Operators, high voltage transmission system operators, and power producers, are on the front line of Y2K preparations. The NERC Y2K program provides these operating entities with an opportunity to share in Y2K solutions and prepare coordination plans with neighboring systems and Regions. The responsibilities of these operating entities within the NERC Y2K program are to share information on known Y2K problems and solutions and to report their progress according to the schedule established by the NERC Y2K program. These entities are expected to participate in system studies, coordinated system preparations, and precautionary system operating measures.
NERC Y2K Coordination Task Force - NERC is forming a Y2K Coordination Task Force to focus on implementing this plan. The focus of the task force is on maintaining the reliable operation of bulk electricity production and delivery systems during Y2K transitions. The task force will facilitate coordination among the ten NERC Regional Reliability Councils. The task force will be organized around the four key technical areas identified in the previous section: Power Production, Energy Management Systems, Telecommunications, and Protection Systems.
Coordination with External Agencies
NERC Y2K efforts are closely aligned with those of many other government and private agencies. Key partners with the NERC Y2K program are identified below.
Department of Energy - DOE is the principal federal agency with oversight responsibility for Y2K issues in electricity supply systems. As such, NERC will report the results of the NERC Y2K program to DOE and work in close coordination with broader DOE efforts.
Edison Electric Institute - EEI has established a program to address Y2K technical, regulatory, and liability issues. NERC is committed to full cooperation with EEI in identification of Y2K technical problem areas and solutions. The NERC Y2K program does not, however, address regulatory requirements or legal liabilities. As such, NERC defers to EEI's leadership in resolving these issues. NERC is particularly concerned that efforts to obtain full disclosure by electric utilities of potential Y2K problems and solutions may be met with resistance due to the liabilities of exposing this information publicly. Public exchange of information is a cornerstone of NERC's Y2K program and must not be viewed by participants as feeding information to potential litigants. NERC expects full support of EEI in defining and promulgating industry needs for protection in this area.
Electric Power Research Institute - EPRI has a well established Y2K program to identify Y2K problems and solutions in embedded systems. EPRI's program spans a full spectrum of electricity production, delivery, and end use. NERC is committed to full cooperation with EPRI in the exchange of information related to electric power production and delivery. NERC encourages all elements of the electric power industry to participate in EPRI's Y2K embedded systems program.
Nuclear Regulatory Commission and Nuclear Energy Institute - There is an obvious need to prepare nuclear facilities for Y2K and the remote, but real possibility of interruptions of off-site power. NERC will be coordinating efforts to maintain a reliable transmission network capable of providing continuous off-site power for nuclear facilities. However, NERC expects that the NRC, NEI, DOE, and others will take the leadership role in coordinating the Y2K activities of nuclear facilities.
Electric Power Supply Association - NERC expects to work closely with EPSA in coordinating the resolution of Y2K problems in power production facilities.
American Public Power Association - NERC will coordinate directly with APPA's larger members who operate control areas and high-voltage transmission systems. APPA is expected to be the primary way of coordinating with electric distribution systems that are not members of a Regional Council to resolve Y2K problems in state/municipal electric distribution systems.
National Rural Electric Cooperative Association - NERC will coordinate directly with NRECA's larger members who operate control areas and high-voltage transmission systems. NRECA is expected to be the primary way of coordinating with electric distribution systems that are not members of a Regional Council to resolve Y2K problems in cooperative electric distribution systems.
Canadian Electricity Association - NERC will work closely with CEA to assure coordination of Y2K efforts among electric power producers and delivery systems in Canada as well as electrical ties that connect Canada and the United States.
Additional Coordination - NERC will cooperate fully with other federal and state government agencies and trade associations working toward Y2K solutions.
Phase 1 (May-September 1998)
NERC will mobilize coordination and information sharing efforts and perform a preliminary review of Y2K readiness of electricity power production and delivery systems. Detailed plans for Phases 2 and 3 will be developed. Phase 1 will culminate with an initial report to the NERC Board of Trustees (BOT) and to DOE covering the preliminary situation report and a detailed work plan for Phases 2 and 3.
Phase 2 (September 1998-July 1999)
NERC will facilitate efforts by the Regional Reliability Councils and responsible operating entities to resolve the known Y2K technical problems. A process will be established for periodic progress reports using an established list of reporting criteria. System simulations and engineering studies will be conducted during this phase to understand likely and worst-case scenarios. This Phase will culminate in July 1999 with a report to the NERC BOT and to DOE on measures being taken to prepare electric power production and delivery systems for operation during the Y2K transition.
Phase 3 (July 1999-January 2000)
During this period, NERC will review the preparation of contingency plans and operating procedures. NERC will assist Regions in the conduct of drills and final arrangements to prepare for critical Y2K periods. Although the most critical period is expected to be on the dates of December 31, 1999 and January 1, 2000, configuring systems in a precautionary posture and then restoring normal conditions afterward are expected to require several weeks.
Phase 1 Tasks and Schedule
Task 1. Establish an Internet Web Site for sharing of information on known Y2K problem areas and solutions related to electric power production and delivery systems.
Task 2. Prepare a list of bulk electric system Y2K key entities and contacts.
This list will identify key personnel in each Region and note areas of expertise, such as generation, protection, communications, energy management systems, etc. As stated previously, the key entities include Regional Reliability Councils, Control Area Operators, Security Coordinators, Independent System Operators, selected Transmission Operators, and selected power producers. The lists of entities and contacts will be posted on the Web Site. The key entities identified will be responsible for participating in the reporting requirements below. [List posted by June 30, 1998 with continued updates through Phase 3.]
Task 3. Establish a NERC Y2K Coordination Task Force.
This task force will have at least one representative from each Region who is knowledgeable about Y2K technical issues and the activities within his or her Region. The task force will establish four technical subgroups to focus on identifying known Y2K technical problems and solutions in the areas of power production (generation), energy management systems, telecommunications, and system protection. System vendors and manufacturers will be asked to participate with the technical subgroups. The task force and subgroups will coordinate through frequent telephonic meetings to ensure high levels of information exchange and coordination of efforts. [Task force will be established and populated by July 1 and will function until the end of Phase 3.]
Task 4. Consolidate known Y2K problems and solutions into a master checklist.
The NERC Y2K Coordination Task Force will develop and post publicly a master list of Y2K problem areas and solutions related to electric power production and delivery. The master checklist will be categorized for efficient reference. The list will identify down to the component or software module level any known or suspected Y2K problems. Fixes, available resources, and contacts will be identified for each problem area as the information becomes known. The solutions posted will draw from "best practices" of organizations that have had the greatest success in resolving a Y2K bug. Known problems will be rated by a simple numbering scheme denoting the criticality of the component to Interconnection reliability. This effort is focused on consolidating known information into a common reference file for all impacted parties to use. [The initial outline of the master checklist will be posted by June 30, 1998. The goal is to have a completed list by September 15, 1998, but the list will continue to be updated as additional knowledge is gained.]
Task 5. Coordinate a preliminary review of Y2K activities by key entities.
NERC, along with the Regional Reliability Councils, will facilitate reporting of a preliminary status of Y2K activities by key operating entities. This report will be consolidated into an industry report to DOE in September 1998. [Reporting criteria will be established by July 31, 1998, entity reports completed by August 31, 1998, and the consolidated report completed by September 15, 1998. The report will be presented to the NERC BOT and then to DOE.]
Task 6. Prepare a detailed plan for Phase 2.
NERC will prepare a detailed plan for implementing Phase 2 activities. [Presented to NERC BOT in September 1998 followed by DOE.]
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