By Peter Kelly-Detwiler - Storyteller in Residence
On May 16, Husch Blackwell Partner (and TREIA board member) Chris Reeder hosted TREIA’s second webinar of 2019. This two-part event (click for link to TREIA webinars past and future) focused on security requirements within the context of the North American Electric Reliability Corporation (NERC) rules, as well as solar facility operation & maintenance (O&M) in Texas.
Navigating the Framework of Security Requirements
Trey Kirkpatrick, Vice President of ABZ Inc., - a new TREIA member - started off the conversation, and guided attendees through the regulatory thicket surrounding the NERC physical and cyber security requirements.
ABZ is an engineering and consulting services firm that offers many services to actors in the energy space, including utilities, cooperative, owners, and developers. It provides assistance related to NERC compliance programs, audits, and software
integration, and has been assisting renewable companies in Texas with their compliance programs. Kirkpatrick’s presentation focused on many of the critical aspects of the NERC Critical Infrastructure Protection (CIP) standards, focusing on the physical and cyber security requirements for projects tied to the bulk electric system. He outlined the process that renewable generation owners must go through with the Texas RE (regional entity). These include compliance audits for generation facilities and control centers, with the stringency of performance requirements based on the specific facility’s risk to the bulk electric system. Compliance also involves a self-certification process - with worksheets developed by the Texas RE - that is becoming more complex.
Kirkpatrick’s presentation highlighted the interaction of generators with the RE, one that starts with an Initial Risk Assessment (IRA) - where the RE assesses the quality of the submission - and usually culminates in on-site visit. The RE process also includes a review of Internal Control Effectiveness (ICE) where internal controls are evaluated. The better these controls are at the outset, the lower is the likelihood that companies will be exposed to unexpected subsequent audits from the RE.
In addition to these NERC-related concerns, developers must also deal with a number of other issues including ERCOT protocols and guides, and a generation availability data system (GADS) for wind. A similar requirement for solar generators is expected to be in place by 2022.
In summary, security requirements for utility-scale renewables owners and operators are constantly evolving. They address both the cyber and physical components, and they require proactive and detailed plans. Strategies range from adopting physical measures such as fences and locks, to implementing cyber measures such as protecting and patching software, and addressing transient resources such as laptops and memory sticks. Adequate procedures must be developed for each applicable standard, training regimes must be adhered to, and reporting requirements must be closely followed. For larger companies, it may be feasible to maintain that level of expertise in-house, but for smaller organizations, bringing in a consultant to assist in the process may be the most cost-effective may to address the constantly moving security target.
Solar Operations and Maintenance: No Longer an Afterthought
The second half of the webinar was devoted to utility-scale solar operations and maintenance (O&M), with a presentation delivered by TREIA member SunPower’s Director of Business Operations, Michael Yellin.
SunPower is one of the country’s largest solar companies, with facilities ranging from utility-scale down to the residential rooftop, and covers the spectrum from manufacturing to installation and O&M. SunPower has an increasing presence in Texas, as the solar sector in the state gears up for rapid growth.
SunPower has been involved in O&M for two decades, with 250 dedicated employees actively managing over 950 utility-scale and commercial projects totaling nearly 3 gigawatts on five continents. The O&M service involves 24x7 monitoring from three control centers. The main NERC-compliant facility, as well as a back-up, are located in Austin, Texas. An additional facility is located in the Philippines. The company is also staffed in-house professional engineering and performance analysis teams.
Yellin commented that a focus on O&M costs has become increasingly important component in overall cost management as capital expenditures have declined in recent years and O&M now represents a lager share of the pie. There is still significant room to both cut costs and increase energy output through a well-managed O&M program.
In Texas, one of the critical challenges to optimizing solar energy output is to ensure that the panels’ access to sunlight remain unimpeded. Soiling, from agricultural dust and pollen, is a particular challenge. In some areas of the world, soiling losses can reach as high as 40%, though most are not impeded to that extent. The level of soiling often varies by the climate type, and depends to a large extent on when precipitation occurs, since rain can mitigate the need for cleaning.
In West Texas, for example, precipitation is concentrated mainly in the summer, with the resulting rain cleaning solar panels when the solar output is highest. By contrast, when rainfall is minimal during spring and fall some cleaning may be needed. In northern Texas, however, precipitation is relatively constant across the year so that little cleaning is required. Not surprisingly, the angle of the panels is also a significant factor, with horizontal panels tending to soil more easily.
Although cleaning can be performed manually, it’s labor and water intensive. Robotic cleaning systems, which can be 20 times faster, can be programmed to work at night to minimize loss of energy output.
With the initial capital costs falling and increasingly competitive power markets, the O&M portion as a total percentage of overall costs has risen significantly. A well-planned O&M program is no longer a ‘nice-to-have,’ but rather a critical component of a cost-effective and economically efficient solar generating facility.