PENALTIES

PENALTIES 4-11

INTRODUCTION 4-22

ISO MONITORING PROCESS 4-22

ISO ACTIONS 4-33

INTRODUCTION

The most probable outcome of the Generation Maintenance Program monitoring will be acceptable resolution of any questionable performance, or appropriate corrective actions agreed to by the generating asset owner. This is based on the fact that both parties have goals that are, to a large degree, mutually beneficial. However, this may not always be the outcome. This section outlines the process the CPUC will use in those cases where the CPUC identifies questionable practices and the outcome remains contentious.

Monitoring Process

As outlined in Section 2 of the Generation Maintenance Program, Generating Unit Performance Metrics, the CPUC will primarily monitor the effectiveness of maintenance programs by monitoring the performance of the generating unit itself. When questionable performance is noted in the Unit's CUF or other operational data, the CPUC will implement an interrogatory process to determine the cause for questionable performance. This process will include, as a minimum, the following steps:

1. Review of CUF data against pre-defined performance analysis thresholds.

2. Review of other NERC GADS operating data for adverse trends. As a minimum this would include review of the following for impact of changes in operating practices:

a. Net Actual Generation for the period compared to historical

b. Actual starts for the period compared to historical

c. Service hours for the period compared to historical

d. Outage hours for period compared to historical

3. Review Outage information for the affected unit.

a. Deferrals of scheduled outages

b. Denials of requested outages

c. Forced Outage and Derate History.

4. Examine unexplained questionable performance with the Generating Asset Owner by any, or all of the following:

a. Review prior communication with Generating Asset Owner (if any).

i) Discussion of prior performance questions

ii) Notification of prior equipment problems

b. Direct telephone conversations.

c. Conduct an on-site visit.

If this investigation does not identify mitigating circumstances explaining the change in performance, the CPUC shall conduct a "Triggered Audit" in accordance with the guidance in the Verification and Audit section. In preparation for this audit, additional information will be reviewed, as applicable:

1. Review reports from prior audits (if any)

2. Review of information from prior site visits (if any)

Actions

Findings include, but are not absolutely limited to:

1. A material discrepancy in the generating asset owner's certification report

a. No evidence to substantiate a claim made

b. Justified alternative not achieving results

2. Performance not meeting standards

a. Poor unit performance without mitigating factors

b. Not performing to something that was accurately stated in certification

c. Clearly not meeting one or more performance standards

d. Failure to meet a prior commitment to take action

Inaccurate or untimely performance metric reporting