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Home My WebLink About20150813PAC to Staff 1-10.pdfROCKY MOUNTAIN PIOA'ER August 13,2015 Jean Jewell Idaho Public Utilities Commission 472W. Washington Boise, ID 83702-5918 i ean j ewell@puc. idaho. gov (C) RE: ID PAC-E-I5-10 IPUC I't Set Data Request (1-10) Please find enclosed Rocky Mountain Power's Responses to IPUC Data Requests 1-10. Confidential information will be provided upon receipt of a confidentiality agreement. If you have any questions, plcase feel free to call me at (801) 220-2963. 201 South Main, Suite 2300 Salt Lake Ciry, Utah 841 I I Sincerely, $, kAln)"o[fis"/ / .*m J. Ted Weston Manager, Regulation PAC-E-I5-10 / Rocky Mountain Power August 13,2015 IPUC Data Request I IPUC Data Request I Please describe how the proposed curtailment stages relate to the NERC Alert levels, the Department of Energy outage reporting requirements, and to the Peak RC-required communications and emergency response protocols (,tee Application, Proposed Tariffs Clean and Legislative Sheet No. 13R.3). Response to IPUC Data Request I Please refer to Confidential Attachment IPUC 1. This will be provided upon receipt of a confidentiality agreement. The proposed curtailment stages referenced in 13R.3 are provided as an overview of the curtailment stages associated with increasing energy deficits, estimated impacts to customers, and the methods that may be employed to reach the required load curtailment necessary to stabilize the bulk electrical system. Incorporated into these stages, although not directly referenced, are corresponding NERC Alert levels, notification and reporting requirements in each Energy Emergency Alert level for all applicable entities, and designated authorized parties and their respective responsibilities. These steps are general guidelines. A further refined load curtailment response may be customized based on actual circumstances requiring load curtailment. Examples of these included - response time to mitigate the potential of rapid system degradation to mitigate a larger cascading reliability issue, availability of remote control capability of devices (SCADA), ability to implement specific contractual curtailment, and as directed by the PEAK regional reliability coordinator. See NERC Standard: EOP-002-3.1 - Capacity and Energy Emergencies Attachment l-EOP-002 Energy Emergency Alerts PacifiCorp is compliant with all required outage reporting and communications associated with each EEA level. and following any event. See NERC Standard: EOP-004-2 and EOP-004-3 - Event Reporting Confidential information will be provided upon receipt of a confidentiality agreement. Recordholder: Amy Shingleton Sponsor: Amy Shingleton PAC-E-I5-10 lRocky Mountain Power August 13,2015 IPUC Data Request 2 IPUC Data Request 2 Please provide sample customer and/or media notihcations for planned and un- planned outages, and requests for voluntary customer curtailments. Response to IPUC Data Request 2 Operating under the circumstances of an energy emergency (i.e. load curtailment necessary to maintain system integrity), and as related to PacifiCorp's proposed l3R filing, customer and/or media notifications for planned and un-planned outages, are not relevant to the intent of the 13R Curtailment Plan for Electric Energy. As stated in PacifiCorp's proposed 13R filing, "The circumstances necessitating a reduction in the demand or consumption of electricity in the short term will require that immediate emergency action is taken and may potentially lead directly to firm load curtailment." Also, 'oThe circumstances necessitating a reduction in the demand or consumption of electricity in the short term will normally require that immediate emergency action is taken and there may be no warning." (See Application, Proposed Tariffs Clean and Legislative Sheet No. 13R.2 and 13R.3). However, cuStomer and/or media notification as related to requests for voluntary customer curtailments are deemed relevant. Samples of these requests and the methods of distribution have been provided in the Confidential Attachment IPUC l Recordholder: Amy Shingleton Sponsor: Amy Shingleton PAC-E-I5-10 / Rocky Mountain Power August 13,2015 IPUC Data Request 3 IPUC Data Request 3 Please explain the Company's communication process with local and state government authorities (See Application, Proposed Tariffs Clean and Legislative Sheet No. 13R.5) in the event that Peak RC, WECC, or NERC issues the following alerts to the Company:l. Wildfire near multiple or critical transmission infrastructure 2. Physical- and/or cyber-attacks 3. Potential geo-magnetic event Response to IPUC Data Request 3 For any alerts received by the Company that require notification to any local or state govemment authorities, the information will be provided to the Company's respective regional business manager, and/or the govemment affairs office, who will then make the necessary communications to any local or state government authorities. Neither the Peak RC, WECC, or NERC issue the types of alerts as listed in I.Wildfire near multiple or critical transmission infrastructure. The Electricity Sector Information Sharing and Analysis Center (ES-ISAC) gathers and distributes any information about possible system threats/vulnerabilities, and it is the responsibility of the Peak RC, Transmission Operators, Balancing Authorities, etc. to prepare for, act, and report any system disturbance resulting from said events and in accordance to the applicable NERC standard. NERC through the NERC Alerts process may issue alerts relatedto 2. Physical- and/or cyber- attacks. These may be advisory in nature, or may require some action on the part of the receiving entity. If the alert results in the activation of the PacifiCorp Cybersecurity Incident Response PIan, the incident response team will initiate necessary internal and external communications. For alerts listed in 3. Potential geo-magnetic event, per their Geomagnetic Disturbance Operating Plan the Peak RC will notifu area Transmission Operators via the WECC Net reliability messaging system for Space Weather Prediction Center (SWPC) watches. warnings and alerts that meet or exceed the Peak RC defined criteria. Per the PacifiCorp procedure the Transmission Operator will notif,v the intemal PacifiCorp parties to initiate necessary communications. Applicable NERC standards include, but are not limited to:. NERC Standard EOP-004-2 and EOP-004-3 - Event Reporting requires "...the reporting of events by Responsible Entities.". NERC Standard CIP-008-3 - Cyber Security - Incident Reporting and Response Planning; "...ensttres the identification, classification, response, and reporting of Cyber Security Incidents related to Critical Cyber Assets." PAC-E-15-10 / Rocky Mountain Power August 13,2015 IPUC Data Request 3 Recordholder: Amy Shingleton Sponsor: Amy Shingleton ! Section B.Rl of the standard requires that "The Responsible Entity shall develop and maintain a Cyber Security Incident response plan and implement the plan in response to Cyber Security Incidents." U Section B.Rl.3. requires that "The Responsible Entity...include a [sicJ Process for reporting Cyber Security Incidents to the Electricity Sector Information Sharing and Analysis Center (ES- ISAC). The Responsible Entity mttst ensure that all reportable Cyber Security Incidents are reporled to the ES-ISAC either directly or through an intermediary." NERC Standard EOP- EOP-010-1 - Geomagnetic Disturbance Operations; requires the Peak RC and Transmission Operators to have "plans in place to mitigate the fficts of geomagnetic disturbance (GMD) events by implementing Operating Plans, Processes, and Procedures." PAC-E-15-10 / Rocky Mountain Power August 13,2015 IPUC Data Request 4 IPUC Data Request 4 Please provide a copy of the Company's current outage communication process used to notifu all State-level emergency coordination entities of planned and un- planned service intemrptions (See Application, Proposed Tariffs Clean and Legislative Sheet No. 13R.5). Response to IPUC Data Request 4 Operating under the circumstances of an energy emergency (i.e. load curtailment necessary to maintain system integrity), and as related to PacifiCorp's proposed 13R filing, "planned...service interruptionr" is not relevant to the intent of the l3R Curtailment Plan for Electric Energy. As stated in PacifiCorp's proposed l3R filing, "The circumstances necessitating a reduction in the demand or consumption of electricity in the short termwill require that immediate emergency action is taken and may potentially lead directly to firm load curtailment. " Also, "The circumstqnces necessitating a reduction in the demand or consumption of electricity in the short term will normally require that immediate emergency action is taken and there may be no warning. " (See Application, Proposed Tariffs Clean and Legislative Sheet No. 13R.2 and 13R.3). However, notification of "un-planned sertice interruptions" is relevant to the intent of the 13R Curtailment Plan for Electric Energy. Said notifications and the methods of distribution have been provided as an attachment to PacifiCorp's response to IPUC 1. Please note that any notifications of "un-planned service interruplions " will be made as soon as reasonably practical given the immediate and criticality of actions required to stabilize the system during energy emergency. Recordholder: Amy Shingleton Sponsor: Amy Shingleton PAC-E-I5-10 / Rocky Mountain Power August 73,2015 IPUC Data Request 5 IPUC Data Request 5 Please describe the process for updating the Company's proposed Curtailment Plan. As part of the response please explain how often the Company expects to develop updates and submit future updates for approval by the Commissions in its various jurisdictions. Response to IPUC Data Request 5 In general, the NERC standards relevant to l3R Curtailment Plan for Electric Energy require an annual review and "self-certification" of compliance, Provisions for Spot Check Audits (Conducted anytime with up to 30 days' notice given to prepare.), Periodic Audits (Conducted once every three years according to schedule.), and Triggered Investigations are included in the "Compliance Monitoring Process" section of each standard. Should any annual review or audit identiff necessary changes and updates to the Company's 13R Curtailment Plan for Electric Energy, the Company will notify the respective Commission(s) of said changes and submit the updated plan for approval. Recordholder: Amy Shingleton Sponsor: Amy Shingleton PAC-E-I5-10 /Rocky Mountain Power August 13,2015 IPUC Data Request 6 IPUC Data Request 6 Please provide a list of distribution circuits, along with their locations, that will be subject to the block curtailment protocol (See Shingleton DI, pg. 4, line 3 and Application, Proposed fariffs, Clean and Legislative Sheet No. 13R.4). Please explain the equipment utilized on the distribution circuits that enable the 2 hour block rotation for curtailment. Please also provide a list of distribution circuits and locations that do not have the necessary equipment to perform 2 hour block rotations during curtailment. Response to IPUC Data Request 6 Regarding the requested list of distribution circuits subject to the block curtailment protocol, it should be noted and understood that the electrical system as a whole is dynamic and complex, requiring constant monitoring and adjustments in order to maintain the integrity of the bulk electrical system, sub- transmission system, and the distribution system. Therefore, any submitted list of distribution circuits, and associated locations identified for possible inclusion in any block curtailment should not be considered static and is subject to immediate modifi cations as necessary. The requested list of distribution circuits subject to the block curtailment protocol is provided in Confidential Attachment IPUC l. Substation breakers and switches remotely operated utitizing Supervisory Control And Data Acquisition (SCADA) are the primary equipment utilized on the substation distribution circuits that enable block rotation curtailment Recordholder: Amy Shingleton Sponsor: Amy Shingleton PAC-E-15-10 / Rocky Mountain Power August 13,2015 IPUC Data Request 7 IPUC Data Request 7 Please provide a list and/or map of the predetermined localized load shed groups and the associated high load areas (,See Application, Proposed Taritrs Clean and Legislative Sheet No. 13R.4). Response to IPUC Data Request 7 The requested list of predetermined load shed groups is provided in Con{idential Attachment IPUC 1. Also, see the Company's response to IPUC Data Request 6. Recordholder: Amy Shingleton Sponsor: Amy Shingleton PAC-E-I5-10 /Rocky Mountain Power August 13,2015 IPUC Data Request 8 IPUC Data Request 8 Please describe the Company's utility-scale, of Balancing Authority Area-scale emergency planning and response training activities. Response to IPUC Data Request 8 PacifiCorp is in compliance with all NERC standards relating to emergency planning and response training activities. Standards encompassed under the Personnel Performance, Training, and Qualifications (PER) suite of standards outline training requirements. o Standard PER-001 -0.2 - Operating Personnel Responsibility and Authorityo Standard PER-003-1 - Operating Personnel Credentials Standardo Standard PER-005-1 - System Personnel Trainingo Standard PER-005-2 - Operations Personnel Training Recordholder: Amy Shingleton Sponsor: Amy Shingleton PAC-E-I5-10 lRocky Mountain Power August 13,2015 IPUC Data Request 9 IPUC Data Request 9 Did the Company participate in the Northwest Power Pool Energy Emergency Plan (EEP) training in May, 2015? If so, did this training compliment or replace any Company-planned emergency response training? If the Company did not participate, please provide the Company's reasons for not participating and a description of the Company's regional-scale emergency response exercise and training efforts. Response to IPUC Data Request 9 PacifiCorp Grid Operations participated in the NWPP Energy Emergency Plan table top exercise in May 2015. This exercise compliments and supports Pacifi Corp's existing emergency operations procedures. Recordholder: Amy Shingleton Sponsor: Amy Shingleton PAC-E-I5-10 / Rocky Mountain Power August 13,2015 IPUC Data Request l0 IPUC Data Request 10 Does the Company plan to participate in, or observe the GridEx ilI emergency response exercise planned for November 2016? If so, please provide the list of staff expected to participate and their roles within the Company and with GridEx III. If not, please provide the Company's reasons for not participating and a description of the Company's national-scale emergency response exercise and training efforts. Response to IPUC Data Request l0 PacifiCorp will participate in the 2016 GridEx III emergency response exercise. The following personnel are currently engaged in the planning process led by Peak Reliability Coordinator, Jill Hoyt, Amy Shingleton Amy Shingleton Name Company Role Milton Patzkowski Manaqer. PacifiCom Transmission Operations - Main Grid Debbie Guena Director, Pacific Power Transmission & Distribution Operations Support John Plechinser Manager, Pacific Power Disaster/Ri sk P I anning Lou Seooi Director, Pacifi Com Transmission & Distribution, Distribution Dispatch Brent Roholt Director, Main Grid Operations, Transmission Dispatch Cindv Jurgenson BCP/DR Specialist, IT Disaster Recovery/Business Continuity Planning David Summers BCP/IT Security Specialist, [T Disaster Recovery/Business Continuity Plannins Stan Sutton BCP/DR Soecialist. [T Disaster Recoverv/Business Continuitv Plannins Amy Shineleton Manager, Rocky Mountain Power Disaster/Risk Planning