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Reduce the Risk of NERC Fines with a Step-by-Step Guide to VAR-002 Compliance

Introduction

The North American Electric Reliability Corporation (NERC) establishes standards to ensure the reliability and security of the bulk electric system. Among these, the VAR-002 standard focuses on maintaining voltage and reactive power within the bulk electric system, which is crucial for system stability and reliability. Compliance with VAR-002 is essential for Generator Operators (GOPs) and Generator Owners (GOs) to avoid hefty fines and ensure the smooth operation of the power grid. This guide provides a comprehensive overview of the VAR-002 standard and a step-by-step approach to achieving and maintaining compliance.

What Is the VAR-002 Standard?

The VAR-002 standard is designed to ensure that generators provide reactive support and voltage control within their capabilities to protect equipment and maintain reliable operation of the interconnected transmission system. The main objectives of VAR-002 include maintaining voltage levels within specified limits, managing reactive power resources effectively, and ensuring continuous monitoring and reporting of these parameters.

What Are the Key Requirements of VAR-002?

Voltage Control

Generator Operators must operate each generator connected to the interconnected transmission system in automatic voltage control mode or as instructed by the Transmission Operator (TO), unless exempted. This ensures that voltage levels are maintained within specified limits to support system stability.

Reactive Power Management

Proper management of reactive power resources is essential. Generator Operators must maintain the generator voltage or reactive power schedule provided by the TO. If the Automatic Voltage Regulator (AVR) is out of service, an alternative method must be used to control reactive output. 

Monitoring and Reporting

Generator Operators are required to continuously monitor voltage levels and to report any deviations from the voltage or reactive power schedule to the TO. Timely notifications of status changes in the AVR, or reactive capability, are also mandated. 

Why Is Compliance with VAR-002 Challenging?

Compliance with VAR-002 can be challenging because of several factors:

  1. Complexity of Requirements: The standard encompasses various technical requirements and operational practices that must be precisely followed.
  2. Continuous Monitoring: Ensuring ongoing monitoring and reporting of voltage and reactive power levels requires robust systems and processes.
  3. Documentation and Reporting: Accurate documentation and timely reporting are critical to demonstrate compliance, which can be resource intensive.
  4. Coordination with Transmission Operators (TOs): Effective communication and coordination with TOs are necessary to manage voltage and reactive power schedules, adding another layer of complexity.

Steps for Ensuring Compliance with VAR-002

Documentation Review

Regularly review all necessary documentation to ensure it is accurate and up-to-date. This includes operating procedures, communication logs, and compliance evidence such as operator logs and SCADA data.

Field Inspections

Conduct physical inspections of the generating facilities to verify compliance with VAR-002 requirements. This includes checking the status of AVRs and reactive power control devices, and ensuring all equipment operates as per the TO’s instructions.

Ongoing Monitoring

Establish processes for continuous monitoring of voltage and reactive power levels. The SCADA systems and other monitoring tools are used to track performance and identify any deviations from the prescribed schedules.

How Should the Compliance Team for VAR-002 Be Structured?

A well-structured compliance team is crucial for maintaining VAR-002 compliance. The team should include

  1. Preparers who are responsible for gathering data and preparing compliance documentation.
  2. Reviewers who ensure the accuracy and completeness of the documentation and compliance evidence.
  3. Technical experts who provide technical expertise on voltage control and reactive power management and assist in resolving any operational issues.

You can learn more about complying with the VAR-002 NERC standard by reading the Certrec white paper: Navigating the Strategic Role of VAR-002 on Reactive Power Regulation

How Often Should Compliance Activities Be Performed?

Compliance activities should be performed regularly to ensure ongoing adherence to VAR-002 standards. Recommended frequencies include

  • Quarterly documentation reviews
  • Biannual field inspections
  • Continuous, ongoing monitoring with daily checks and monthly reports.

Examples of Recent Violations and Penalties Related to VAR-002

Compliance with VAR-002 is crucial for maintaining voltage and reactive power within the bulk electric system. However, instances of noncompliance can occur, leading to potential penalties and fines. Here are two recent examples of VAR-002 violations.

Dakota Range III, LLC

Broad River Energy faced a $115,000 penalty for violations of VAR-002-4 R2, PRC-005-1b R2, and PRC-005-6 R3. They failed to maintain the generator voltage schedule provided by the Transmission Operator (TOP) and did not notify the TOP about deviations. Over an audit period from August 1, 2015, to October 18, 2019, Broad River identified 419 excursions outside the voltage schedule, with 362 instances lacking required notifications to the TOP. Additionally, Broad River was noncompliant with PRC-005-6 R3, failing to maintain its protection system and related components. From December 27, 2012, to November 5, 2021, they could not provide evidence of required testing and maintenance for 86 percent of their devices, except for batteries. These violations highlight the importance of systematic tracking and updates in power systems to ensure compliance and avoid significant penalties. 

sPower Services, LLC

sPower Services, LLC, was found non-compliant with VAR-002-4.1 R1 for failing to operate each generator in automatic voltage control mode with its AVR in service and for not notifying the Transmission Operator as required. This occurred on September 13, 2023, during a capacity test on a newly commissioned Battery Energy Storage System (BESS). The AVR unexpectedly shifted to “Mode Local,” causing voltage control issues. The violation lasted from 0754 to 1821, when the AVR was restored to automatic mode and the TOP was notified. The cause was a knowledge gap and an incomplete procedure, as it was the first time this test had been performed with new technology. WECC issued a compliance exception after determining that there were no relevant instances of noncompliance in the entity’s history.

What are the Common Methodologies for Ensuring VAR-002 Compliance?

Entities use various methodologies to meet VAR-002 requirements, including:

  1. Automated Monitoring Systems: Utilizing SCADA systems for real-time monitoring and automated reporting.
  2. Regular Training Programs: Ensuring all personnel are trained in the latest compliance requirements and operational procedures.
  3. Internal Audits: Conducting regular internal audits to identify and address compliance gaps.

How Can Certrec Assist in VAR-002 Compliance?

Certrec offers a range of services to help entities achieve and maintain compliance with VAR-002:

  • Compliance Consultations: Receive expert advice on understanding and implementing VAR-002 requirements.
  • Documentation Assistance: Certrec has the knowledge and tools to help your facility with preparation and reviewing compliance documentation.
  • Training Programs: We can provide training in compliance and operational best practices across a number of standards, including VAR-002.
  • Monitoring Solutions: Through our alliance with Fischer Block, Inc., we offer tools and systems for continuous monitoring of voltage and reactive power levels.

Conclusion

Ensuring compliance with the VAR-002 standard is vital for the stability and reliability of the bulk electric system. By understanding the requirements, addressing challenges, and implementing effective compliance strategies, Generator Operators and Owners can prevent costly NERC fines. Leveraging Certrec’s expertise and resources further enhances compliance efforts, ensuring operational excellence and regulatory adherence. Maintaining continuous monitoring, accurate documentation, and proactive engagement with compliance activities will help entities navigate the complexities of VAR-002 and contribute to the overall reliability of the power grid.

For more information on how Certrec can assist with VAR-002 compliance, visit www.certrec.com or contact us at NERCExperts@certrec.com

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