Audit Report Rottnest Island 2015 Network Quality and Reliability of Supply Performance Audit - Operation of Compliance Monitoring Systems

Transcription

1 ABN Rottnest Island 2015 Network Quality and Reliability of Supply Performance Audit - Operation of Compliance Monitoring Systems Telephone: Fax: projects@qualeng.net Web: Postal Address: PO Box Z5261, St George s Terrace, PERTH WA 6831 Office: Level 2, 231 Adelaide Terrace, Perth, Western Australia, 6000

2 executive summary Under the Electricity Industry (Network Quality and Reliability of Supply) Code 2005 (the Code), Division 3, Section 26, Rottnest Island Authority (RIA) is required to arrange for an independent audit of the operation of the systems that are in place to monitor its compliance with Part 2 of the Code or an instrument made under Section 14(3). In July 2015 the RIA commissioned to carry out the audit in respect of the operation of the systems to cover the period 1 July 2014 to 30 June The RIA's distribution system consists of an 11 kv distribution network (defined as the 11 kv HV Transmission System), both underground and above ground, a number of substations and a 415V LV distribution network comprising five underground feeders. The RIA has contracted Programmed Facility Management (PFM) to manage, operate and maintain the electricity assets and to be responsible for compliance with the licence conditions and with the Code. The audit was conducted between August and September 2015 and included: review of the actions resulting from previous audit recommendations, review of supporting documentation, interviews of key personnel, review of evidence, data, reports and processes demonstrating the operation and performance of the systems. The audit found that the action arising from the previous audit finding had not been completed. The finding and recommendation are still open: No evaluation of the power quality monitoring results was noted. An assessment is required and outcome and actions documented. One opportunity for improvement arising from the previous audit is also pending: Verification of network reliability figures is carried out informally. Data entry, calculation results and report figures should be subject to verification.

3 The audit found that the RIA and PFM have maintained adequate systems to monitor compliance with the requirements of Part 2 of the Code. There are processes in place for: monitoring of power quality through measurement of voltage fluctuations (flicker) and voltage harmonic distortion; monitoring of interruption duration, frequency and causes of interruption by means of registers for planned and unplanned outages; managing planned and forced interruptions; documenting outage procedures, restoration priority, emergency response and disaster recovery plans to maintain supply to customers; providing alternative power supplies to reduce the effect of interruptions; providing notifications of planned outages to customers; calculation and reporting of reliability data. As well as the findings open from the previous audit two additional findings were recorded: There were no register or records to indicate that the 72 hour minimum outage notification had been monitored during the reporting period. There was no evidence in the current registers that interruptions over 12 hours or that frequency of interruptions in excess of 16 per year are monitored over the 10 year period. Based on the scope of the audit defined in section 26 of the Code, and except for the findings noted above, has found that Rottnest Island Authority has in place systems to monitor its compliance with the requirements of Part 2 of the Code, Quality and Reliability Standards.

4 This report is an accurate representation of the findings and opinions of the auditors following the assessment of the client's conformance to nominated Licence conditions. The report is reliant on evidence provided by other parties and is subject to limitations due to the nature of the evidence available to the auditor, the sampling process inherent in the audit process, the limitations of internal controls and the need to use judgement in the assessment of evidence. On this basis shall not be liable for loss or damage to other parties due to their reliance on the information contained in this report or in its supporting documentation. Approvals Representation Name Signature Position Date Auditor: M Zammit Lead Auditor / Engineering Manager, 23/09/2015 Audit Team M Zammit S Campbell Audit Team Description Project Director and Lead Auditor Reviewer Issue Status Issue No Date Description Approved A 22/09/2015 First Draft issue MZ 1 23/09/2015 First Issue MZ AUDITREPORT-4807-RIA QUAL&RELIAB Page 4 of

5 TABLE OF CONTENTS 1 OBJECTIVES AND SCOPE OF AUDIT Introduction Audit Objectives Audit Scope Audit Methodology Limitations and Qualifications Acronyms and Abbreviations LICENSEE'S RESPONSE TO PREVIOUS AUDIT RECOMMENDATIONS Background Progress of actions from 2014 Audit KEY FINDINGS System to manage compliance with Part 2, Division 1, Quality Standards (sec. 5 to 8) Quality of Supply: System/Process Duty to Disconnect if Quality of Supply may Lead to Damage (section 8) Summary of power quality issues and reports System to manage compliance with Part 2, Division 2, Standards for Interruption of Supply (Sec. 9-12) Duty to maintain the supply with a minimum number and duration of interruptions (Sec. 9) Duty to reduce the effects of interruptions and provision for alternative supplies for proposed interruptions (Sec. 10) Planned interruptions and Notifications (Sec. 11) Significant interruptions to small use customers (Sec.12) System to manage compliance with Part 2, Division 3, Standards for the duration of interruption of supply in particular areas (Sec. 13) Provisions may be excluded or modified by agreement with customers (Sec 15) AUDIT SUMMARY AND RECOMMENDATIONS...24 AUDITREPORT-4807-RIA QUAL&RELIAB Page 5 of

6 1 Objectives and Scope of Audit 1.1 INTRODUCTION Rottnest Island Authority (RIA) has an Electricity Integrated Regional Licence (EIRL3 Licence) (the Licence) issued by the Economic Regulation Authority (the Authority) under Sections 7 and 15(2) of the Electricity Industry Act 2004 (WA) (the Act). Under the scope of the Licence RIA generates and distributes electricity to commercial customers. Under the terms of the Act RIA is required to comply with the Electricity Industry (Network Quality and Reliability of Supply) Code 2005 (the Code). In accordance with Division 3 "Performance reporting", Section 26 "Annual report on monitoring systems" of the Code, RIA is required to arrange for an independent audit of the operation of the systems that are in place to monitor its compliance with Part 2 of the Code or an instrument under Section 14(3). In July 2015 RIA commissioned to carry out the Performance Audit to cover the period 1 July 2014 to 30 June The audit has been conducted and this report prepared in accordance with the Code. The RIA's distribution system consist of an 11 kv network (identified as the 11 kv HV Transmission System) comprising two feeders (number 2 and number 6), both underground and above ground, a number of substations and a 415V LV distribution network comprising five feeders (Feeders 1, 3, 4, 5 and 7). The RIA has placed the responsibility for managing the operation and maintenance of the licence assets on Programmed Facility Management (PFM) under a contractual agreement, the "Facilities, Operations and Utilities Management Agreement" (FOU) which was replaced by the Facilities Utilities and Support Services (FUSS) at the start of Under this agreement PFM is responsible for compliance with the licence conditions and with the Code. 1.2 AUDIT OBJECTIVES The purpose of the Performance Audit is to assess and report on the operation of the systems implemented by the licensee to monitor its compliance with Part 2 of the Code or an instrument under section 14(3). AUDITREPORT-4807-RIA QUAL&RELIAB Page 6 of

7 1.3 AUDIT SCOPE Part 2 of the Code includes 4 Divisions: 1. Division 1, "Quality Standards" for compliance with requirements for quality of supply at the point of connection to the customer, in regard to voltage fluctuations and harmonic distortion. 2. Division 2, "Standards for the interruption of supply to individual customers" provides for the maintenance of supply and management of interruptions to customers, both in terms of the duration and number of interruptions. It includes for: 2.1. Provision of supply with the minimum number and duration of interruptions Consideration of providing alternative supply if the interruption is expected to be significant, its effect substantial or if the customer has special health needs that require continuous supply Allowing planned interruptions if the customer is notified within a suitable time and where the duration does not exceed 6 hours, or 4 hours for temperatures over 30 C or north of the 26th parallel Provides for the distributor to remedy the causes of interruptions or enter into alternative arrangements if the supply has been interrupted more than 12 hours continuously or more than 16 times in the prescribed 12 months and it is considered that the prescribed standard is unlikely to be met for the customer. 3. Division 3, "Standards for the duration of interruptions of supply in particular areas" provides that the average length of interruptions should not exceed 290 minutes in any area of the State, other than the Perth CBD and urban areas and 160 minutes for urban areas other than the Perth CBD (calculated as average of the yearly averages over 4 years). 4. Division 4, "Variations of obligations under this Part" provides for: 4.1. review and approval by the Minister of alternative requirements and 4.2. agreement between the transmitter/distributor and the customer of extensions and modifications to the standards. The audit was carried out between August and September The following representatives participated in the audit on RIA's behalf and/or contributed to sourcing the documentation and providing evidence to the audit: Ms Janett Enke, Contracts & Project Officer, RIA Mr Orrin Neale, Island Engineer, PFM Mr Dino Ajid, Power Generation Supervisor, PFM Mr Roger Fletcher, Risk, Compliance & HSE Manager, PFM. The main auditor representative was Mr M Zammit, Lead Auditor and Mr S Campbell was the AUDITREPORT-4807-RIA QUAL&RELIAB Page 7 of

8 documentation reviewer. 1.4 AUDIT METHODOLOGY The audit followed in part the methodology defined in the Authority's Audit and Review Guidelines: Electricity and Gas Licences, April 2014, including: preparation of an audit plan and risk assessment for internal control, fieldwork, reporting. The audit proceeded through a documentation review, meetings, interviews and checks of processes. These were supported by additional queries to clarify aspects of policies and procedures. 1.5 LIMITATIONS AND QUALIFICATIONS An audit provides a reasonable level of assurance on the effectiveness of control procedures, however there are limitations due to the nature of the evidence available to the auditor, the sampling process inherent in checking the evidence, the limitations of internal controls and the need to use judgement in the assessment of evidence. 1.6 ACRONYMS AND ABBREVIATIONS Abbreviation Authority CAIDI CMMS Description Economic Regulation Authority Customer Average Interruption Duration Index Computerised Maintenance Management System Code Electricity Industry (Network Quality and Reliability of Supply) Code 2005 FUSS NA PFM Plt Pst RIA Facilities Utilities and Support Services Not Applicable Programmed Facility Management Long Term Flicker (as defined in the Code) Short Term Flicker (as defined in the Code) Rottnest Island Authority AUDITREPORT-4807-RIA QUAL&RELIAB Page 8 of

9 Abbreviation RMU SAIDI SAIFI THD Description Ring Main Unit System Average Interruption Duration Index System Average Frequency Duration Index Total Harmonic Distortion AUDITREPORT-4807-RIA QUAL&RELIAB Page 9 of

10 2 Licensee's Response to Previous Audit Recommendations 2.1 BACKGROUND The previous quality and reliability of supply audit was completed in September This section reviews RIA's progress on the recommendations of the 2014 audit as well as RIA's planned actions to address any outstanding issues. The recommendations arising from the previous report and the status of the actions determined in this audit have been summarised in the following table. AUDITREPORT-4807-RIA QUAL&RELIAB Page 10 of

11 SUPPLY PERFORMANCE AUDIT - OPERATION OF COMPLIANCE REF 48/7 2.2 PROGRESS OF ACTIONS FROM 2014 AUDIT The following table lists the recommendations made in the 2014 audit and records progress of any actions. Item No Code Ref 1 Part 2 Div 1, Sec Div 3, Sec. 13 Requirement Findings 2014 Recommendations and Opportunities for Improvement Quality and Reliability standards, voltage fluctuations, harmonics: A transmitter and a distributor must, so far as is reasonably practicable, ensure that electricity supplied by the transmitter or distributor to a customer s electrical installations, as measured at the point of connection of those installations to the network, at all times complies with the standards including voltage fluctuation (flicker) and harmonics. Standards for the duration of interruption of supply in particular areas System to monitor compliance with standards for the duration of interruption of supply in particular areas (30, 160, 290 min) Results for fluctuations (flicker) were mainly in accordance with the Code with some excursion in excess of the limit. No evaluation of the power quality monitoring results was noted. An evaluation is required leading to acceptance of the results or improvement action. At present there is no formal verification of reported information. 1/2014. Implement a process to ensure that results of power quality monitoring are reviewed and either accepted or appropriate action taken. 2/2014. (OFI) Data entered, calculation results and report figures should be subject to verification. Verification process should be documented; this could be achieved by Status Process has not been formalised, however action is in place to document the review of power quality monitoring. Open, finding carried over to the 2015 audit. Verification was carried out informally in Process was due to be documented in the calculation file however due to change in systems and personnel the process is still under review. AUDITREPORT-4807-RIA QUAL&RELIAB Page11 of

12 SUPPLY PERFORMANCE AUDIT - OPERATION OF COMPLIANCE REF 48/7 Item No Code Ref Requirement Findings 2014 Recommendations and Opportunities for Improvement Status describing it in the calculation sheets (action carry over from audit). It is noted that a corrective action was in progress at the end of the audit Open, finding carried over to the 2015 audit. Note: "Open"actions have been included in the recommendations for the new audit period. AUDITREPORT-4807-RIA QUAL&RELIAB Page12 of

13 3 Key Findings 3.1 SYSTEM TO MANAGE COMPLIANCE WITH PART 2, DIVISION 1, QUALITY STANDARDS (SEC. 5 TO 8) Requirement: The Licensee is required to have systems in place to monitor compliance with requirements for quality of supply at the point of connection to the customer, both in terms of voltage fluctuations and harmonic distortion and for disconnection of customer where there is a possibility of damage to the customer installation Quality of Supply: System/Process Systems are in place for monitoring compliance with the Code quality standards including: the "RIA Electrical Water Gas Licence Compliance Register" (April 2015) a spreadsheet listing compliance requirements, timing and appropriate actions required; PFM's procedure "PRO-ROT-ELEC Voltage and Harmonic Fluctuation Monitoring" (14/8/2013) setting out the requirements for power quality measurements; the "FUSS Compliance and Licence Bible" setting up the dates for compliance activities (where FUSS is Facilities Utilities and Support Services contract for operational services; annual independent testing of connections and analysis of data for power quality coinciding with the island peak demand period. It was noted that the operator (PFM) procedures are under review and scheduled for weekly discussions with the operational crews for further consolidation and updating. Quality of supply monitoring was carried out by the external consultant Nilsen WA Pty Ltd. The testing was carried out during the Summer peak demand period under work order "WA217212" generated by the work management system "Maximo" in accordance with the "Compliance and Utilities Spreadsheet". The Work Order prompt is in the process of been shifted to the FUSS CMMS (Computerised maintenance management system). Results and analysis were reported in Nielsen's "Rottnest Island Power Quality Report: Dec Jan. 2015". Measurements were taken at 6 locations: Abbott St substation Hotel Rottnest Shopping Precinct Tea Rooms Lodge Waste Water Treatment Plant. AUDITREPORT-4807-RIA QUAL&RELIAB Page 13 of

14 Not all of the above connections had been tested in It is noted that the Waste Water Treatment Plant is part of RIA's facilities, therefore it does not represent customers. Each location was monitored over a continuous period of 7 days. Total Harmonic Distortion (THD) was measured and was well within limits. Flicker was within limits at all sites except for Abbott St where there were flicker spikes over the limit. Flicker spikes appeared to be one-off occurrences. Table 1: Flicker and Harmonics Measurements Site Hotel Rottnest Flicker (Pst 1.0; Plt 0.8) Harmonics (THD 8%) Pst Plt (Max %) Customer's Complaints on Quality Shopping Precinct Tea Rooms Lodge peak < 0.83 peak < Abbott St peak peak avg 0.56 avg Nil Notes: 1. Five spikes over the limit. 2. One single occurrence over 7 day period, on 22:00, 9 January Overall the power quality measurements in the audit period indicated that the supply at the connections monitored are in general compliance with the requirement of the Code. There are occasional peaks in flicker that exceed the prescribed limit. The THD measurements were also in accordance with the Code. The audit noted that the test results had not been adequately reviewed: No evaluation of the power quality monitoring results was noted. This was also the case in the previous reporting period, however there have been both system and operator changes during the current reporting period and the previous action has been noted by PFM Duty to Disconnect if Quality of Supply may Lead to Damage (section 8) PFM has procedure "PRO-RNI-I Voltage and Harmonic Fluctuation Monitoring Procedure" in place to guide the disconnection of customers in the event that results of power quality monitoring AUDITREPORT-4807-RIA QUAL&RELIAB Page 14 of

15 exceed the Code limits and damage may result to a customer electrical installation. In addition there are procedures for responding to customers' power quality complaints: the "FUSS Complaint Handling Procedure; RIA's "Utilities Customer Complaints Procedure", (updated 15/4/2015). A register is in place to record customer complaints including power quality complaints: RIA's "Electrical Customer Complaints Reporting Register". No customer complaints related to power quality were registered during the audit period Summary of power quality issues and reports Review of the systems, processes and practices dealing with quality of supply has shown the following gap: 1. No evaluation of the power quality monitoring results was noted during the reporting period. An assessment is required and outcomes documented. No significant "quality" event were reported during the audit period and there were no customer complaints for either voltage fluctuations and harmonics. 3.2 SYSTEM TO MANAGE COMPLIANCE WITH PART 2, DIVISION 2, STANDARDS FOR INTERRUPTION OF SUPPLY (SEC. 9-12) The licensee has to have systems to monitor compliance with requirements for the minimisation of interruptions to customers, both in term of the duration and number of interruptions. The requirements are for the licensee to: Maintain the supply with the minimum number and duration of interruptions (Sec. 9); Reduce the effects of interruptions; consider providing alternative supply if the proposed interruption is expected to be significant, its effect substantial or if the customer has special health needs that require continuous supply (Sec. 10); Ensure that where interruptions are planned, where practicable the customer is notified within a suitable time and the duration does not exceed 6 hours, or 4 hours for temperatures over 30 C or north of the 26th parallel (Sec. 11); Remedy the causes of interruptions or enter into alternative arrangements if the supply has been interrupted more than 12 hours continuously or more than 16 times in the prescribed 12 months and it is considered that the prescribed standard is unlikely to be met for the customer (Sec. 12). AUDITREPORT-4807-RIA QUAL&RELIAB Page 15 of

16 3.2.1 Duty to maintain the supply with a minimum number and duration of interruptions (Sec. 9) Requirement: The licensee must establish systems to monitor compliance with the requirement to ensure, so far as is reasonably practicable, that the supply of electricity to a customer is maintained and the occurrence and duration of any interruptions is kept to a minimum. PFM has systems in place to monitor compliance with the requirements for a minimum number and duration of interruptions. PFM uses two outage registers to record details of planned and forced interruptions. Details include outage identification, date, disconnection and reconnection times, duration, location, area, customers and connections affected. The registers are: a register of "Operational Outages" which provides details of all forced outages including both transmission and distribution interruptions and identifies causes, including generation faults; a register of "Planned Outages" recording outages due to maintenance, asset improvement etc. In addition PFM has plans and procedures to react to interruptions and reduce their impact: "Electrical Disaster Recovery Plan" (DRP), 29/12/2011), including the provision of mobile generators in case of loss of feeders; "Power Reinstatement Procedure" (14/8/2014); "Restoration Priority Register" for allocating priority to customer reconnections; "PRO-RNI-I Powerhouse Outages Procedure" (14/8/2013); "PRO-RNI-I Planned Outage Notification Procedure" (14/8/2013). Every forced interruption is documented in the "Operational Incident Report Form" that records the nature of the incident, causes, details of damage and corrective actions. In total there were 5 Planned and 5 Operational outages for the period. One of the planned outages was over 6 hours however the outage did not affect any customers. One of the forced outages was over 6 hours and affected eight customers and nine connections. In regard to Planned Outages: one outage was for pole top washdown on pole W13 on the 11 kv line in December 2014; it lasted 10.5 hours but it did not affect any customers through the provision of mobile generators; a further outage was for 5.5 hours but did not affect any customers; a further two other were due to pole top washdown; one was for a repair to an inspection cover and affected three customers and 54 connections. In regard to Operational (Forced) outages: one outage was 8 hours and was due to an RMU trip at the Powerhouse switchyard. AUDITREPORT-4807-RIA QUAL&RELIAB Page 16 of

17 Summary: Table 2: Systems to monitor compliance with requirement to maintain supply and the occurrence and duration of interruptions to a minimum Site Procedures dealing with outages Systems and Procedures monitoring performance All Yes Yes Duty to reduce the effects of interruptions and provision for alternative supplies for proposed interruptions (Sec. 10) Requirement: The licensee must establish systems to monitor compliance with its duty to reduce, so far as is reasonably practicable, the effect of any interruptions and consider providing alternative supply for proposed interruptions if the interruption is greater than 6 hours, or there is a substantial effect on the business or there are special health needs customers. Reduce the effect of any interruptions The audit found that there are systems in place to monitor interruptions and provide alternative supplies to reduce the effect of interruptions. PFM has plans and procedures in place to monitor and deal with emergencies and crisis, these include: the outage registers noted in section the "Electrical Services Disaster Recovery Plan, Electrical Disaster Recovery Plan, Business Continuity Planning", (ESDRP), December 2011, which analyses the network and identifies the most likely disaster scenarios, the action and recovery plans together with an estimate of outage duration; the Disaster Recovery Plan for the Electrical Distribution Network (DRP), February 2013, which defines the steps necessary to provide alternative electrical supply to Rottnest Island electrical services with mobile gen-sets as well as the connection arrangements for temporary generation; the "PRO-RNI-I ", Restoration Priority Register Electrical Services, setting the restoration order of RIA's electrical services; the "PRO-RNI-I Powerhouse Outages Procedure" which provides for the power station restart in case of distribution circuit breaker trips, generator trips, power blackouts and includes black start procedures; emergency response tests are documented in the "Electricity Business Continuity Drill Form". AUDITREPORT-4807-RIA QUAL&RELIAB Page 17 of

18 Due to the compact size and topology of the network the extent of outages can be readily assessed. As noted in section 3.2.1, PFM monitors both planned and forced outages for duration, location, customers, connections and causes, as well as mitigating actions such as availability or provision of alternative supply. The data from the outage registers is entered in the "Network Reliability Parameters" spreadsheet which collects all yearly and historical data as well as customer and connection numbers. Calculations for duration and frequency of interruptions are performed in this file and used for further reports. The SCADA computerised management system provides for automatic restoration of power to the distribution system in the event of power failure. The powerhouse operator can manually override the SCADA system to restore power in accordance with the order of the Restoration Register. Desktop tests of emergency response have been carried out for scenarios selected from the DRP. the tests are scheduled in the operator calendar. Records of tests are documented in the "Electricity Business Continuity Drill Form" and were examined by the auditor. Provision of Alternative Supply The DRP documents the arrangement of plant and procedures for providing and restoring supply in response to a range of power outages at different network locations. The DRP provides the connection arrangement for each location, wiring diagram for the equipment installation and the equipment required for generation. Special Health Needs Customers and Commercially Sensitive Loads There were no special health needs (SN) customers on the island during the audit period. SN customers are managed by the RIA. SN customers have to apply for special support to the RIA, the process is informal and there have been no instances of applications in the last few years. The island has no facilities or resources for supporting SN customers. Some of the critical customers on the island, such as Telstra, have their own back up generator sets, whilst others, like the nursing post and the police rely on PFM for back up supplies. The audit confirmed evidence of consultation process with businesses in preparation to planned outages. AUDITREPORT-4807-RIA QUAL&RELIAB Page 18 of

19 Summary Table 3: Systems to monitor compliance with duty to reduce the effect of interruptions and provide alternative supply for planned interruptions Site Reduce the Effect of Interruptions Alternative Supply Special Needs Customers All Yes Yes NA (There were no special health needs customers on Rottnest Island in the audit period) Planned interruptions and Notifications (Sec. 11) Requirement: The licensee must establish systems to monitor compliance with the requirement to maintain planned outages which do not exceed 6 hours and providing notifications at least 72 hours before each outage for eligible persons (using no more than 50 MW per year). PFM has a system to manage and monitor planned outages and notifications. Planned Outages Not Exceeding 4 or 6 Hours As noted in sections 3.2.1, PFM maintains a register of planned outages with details of start and end dates, duration, location, causes and customers affected. While the duration of planned outages was recorded, there was no clear indication in the outage register that it is a breach of section 11 of the Code when an outage exceeds 6 hours duration nor clear provision in the register to document reasons for excessive duration. However all outages with a duration in excess of the limit did not impact on any customers due to adequate provision of alternative power supply. Planned Outage Notifications PFM's "PRO-RNI-I Planned Outage Notification Procedure" is in place addressing outage notification including the 72 hours advance warning. The notification process requires the operator, PFM, to advise both the RIA and customers of impending outages by letter, and/or phone. The audit examined evidence of notifications for four of the planned outages. The evidence viewed showed that customers had received advice at least 72 hours ahead of the outages. It is noted that while records are available to show compliance with the Code, there are no register AUDITREPORT-4807-RIA QUAL&RELIAB Page 19 of

20 or records to confirm that the 72 hour minimum notification warning has been monitored for each planned outage. Summary Table 4: Systems to monitor compliance with planned outages not exceeding 4 or 6 hours and providing notifications at least 72 hours before each planned outage Site Duration ( 6h) Systems to monitor notifications 72 hours prior All Yes Not fully implemented 2. There were no register or records to indicate that the 72 hour minimum notification warning had been monitored during the reporting period. There should be evidence to show that compliance with the notification requirement is being monitored Significant interruptions to small use customers (Sec.12) Requirement: The licensee must establish systems to monitor compliance with the requirement to remedy the causes of interruptions or make alternative arrangements where significant interruption (duration over 12 hours or more than 16 interruptions in the preceding year) occurred for small use customers and where the Licensee considers that the prescribed standard (9 years out of 10) is unlikely to be met. Outage durations are monitored through the Planned and Operational Outages registers noted at section There were no significant interruptions in the audit period. No customer supply was interrupted more than 16 times in the audit period. In regard to performance over 10 years, records are available up to 2007 and show that there was only one interruption over 12 hours, in and 16 interruptions within a single audit period occurred only once in the period, in As this performance is in compliance with the Code, there was no obligation under the Code for the licensee to take any actions under this section. While the duration and number of annual outages is recorded, there was no evidence in the current registers that interruptions over 12 hours or that frequency of interruptions in excess of 16 per year are monitored over the 10 year period. AUDITREPORT-4807-RIA QUAL&RELIAB Page 20 of

21 Summary Table 4: Systems for monitoring compliance with interruption duration not to exceed 12 hours Site 2015 # interruptions > 12 hours Compliance = 0 All 0 No small use customer affected 9 Years out of 10 ( 12 hours) Compliance Yes Complying between 2007 and 2015 (only one year interruption > 12 h ( )) Causes of Interruption Remedied / Alternative Arrangements No action necessary. Table 5: Systems for monitoring compliance with interruption frequency not to exceed 16 per customer per period Site 2015 # interruptions > 16 per period 9 Years out of 10 (# 16) 2014 # > 16 Compliance = 0 Compliance Compliance = 0 All 0 Yes Complying between 2007 and 2015 (only one year > 16 interruptions ( )) Causes of Interruption Remedied / Alternative Arrangements 0 No action necessary. Note: it is noted that the Code and criteria have changed over the 9 year period. 3. There was no evidence in the current registers that interruptions over 12 hours or that frequency of interruptions in excess of 16 per year are monitored over the 10 year period. AUDITREPORT-4807-RIA QUAL&RELIAB Page 21 of

22 3.3 SYSTEM TO MANAGE COMPLIANCE WITH PART 2, DIVISION 3, STANDARDS FOR THE DURATION OF INTERRUPTION OF SUPPLY IN PARTICULAR AREAS (SEC. 13) Requirement: The licensee must establish systems to monitor compliance with the Code requirement to ensure that the average length of interruptions to customer premises for the four years up to the current year for areas other than the Perth CBD do not exceed 160 minutes in urban areas and 290 minutes in any other area of the State. PFM monitors the duration of interruptions through the Planned and Forced Outage registers noted in section and through a spreadsheet, the "Network Reliability Parameters" which records the data and carries out the calculations that provide the required performance figures. The spreadsheet carries records of several years so that long term performance can be assessed. As noted in section above, operational development and plant upgrades have been implemented both over the audit period and over previous periods. This has led to an improvement in the performance of the system in regard to the length of interruptions to customers. The figure of total length of interruptions per customer premises over a year has dropped to minutes in from a high of in At present there is no formal verification of reported information. Summary Table 6: Systems to monitor compliance with requirement for interruption not to exceed 290 minutes average per customer over 4 years. Site 2015 ( < 290 m) All using distribution connections using customer served 4 Year Average (Avg over 4 years 290 min) using distribution connections using customer served Note: Definitions of customer numbers and connections were changed in Calculations are based on 527 connections (which includes accommodation units) whilst previously 191 connections were used. PFM are reviewing the number of customer premises being supplied. The review is currently taking place and may result in a change to the interruption duration figures for the next reporting period under section 13 of the Code. AUDITREPORT-4807-RIA QUAL&RELIAB Page 22 of

23 4. (OFI) At present there is no formal verification of reported information. Entry data, calculation results and report figures should be subject to verification and verification process documented. 3.4 PROVISIONS MAY BE EXCLUDED OR MODIFIED BY AGREEMENT WITH CUSTOMERS (SEC 15) Requirement: A customer and a transmitter or a distributor may agree in writing that a provision of this Part is excluded or modified in relation to the supply of electricity by the transmitter or distributor to the customer and the agreement must set out the matters that the parties consider are the advantages and disadvantages. There are no agreements in place to exclude or modify provisions of this Part of the code. AUDITREPORT-4807-RIA QUAL&RELIAB Page 23 of

24 4 Audit Summary and Recommendations Under Section 26 "Annual report on monitoring systems" of the Code, Rottnest Island Authority is required to arrange for an independent audit of the operation of the systems that are in place to monitor its compliance with Part 2 of the Code. or an instrument under Section 14(3). The audit has found that monitoring systems are in operation and are in compliance with the requirements of the Code except as noted in the following summary. There was one recommendation and one Opportunity for Improvement (OFI) arising from the audit, both findings and recommendations are still open: The recommendation was in regard to implementing a process to ensure that results of power quality monitoring are reviewed and acted upon. The action arising from the recommendations has not been completed and the recommendations has carried over to this audit period. The lack of evaluation of the power quality monitoring results was confirmed during the reporting period. An assessment is required and outcome and actions, if any, documented. The OFI was in regard to the need to verify the entry of data and calculation results including reliability and report figures. The audit found that the OFI action is still open and has been included in this year findings. Together with the recommendation and OFI still open from the previous audit, the audit made two findings: There were no register or records to indicate that the 72 hour minimum notification warning had been monitored during the reporting period. There should be evidence to show that compliance with the notification requirement of section 11 of the Code is being monitored. While the duration and number of annual outages is recorded, there was no evidence in the current registers that interruptions over 12 hours or that frequency of interruptions in excess of 16 per year are monitored over the 10 year period. The audit and recommendations summary is provided in the next table. The table summarises the findings and recommendations of the report in regard to the system operation and compliance. The table rates the various element as complying (), not in compliance ( ), or as actions in progress, observations or opportunities for improvement (OFI). Based on the scope of the audit defined in section 26 of the Code and except for the findings noted above, has found that the system and processes within RIA and PFM are in compliance with the requirements of Part 2 of the Code, "Quality and Reliability Standards". AUDITREPORT-4807-RIA QUAL&RELIAB Page 24 of

25 SUPPLY PERFORMANCE AUDIT - OPERATION OF COMPLIANCE REF 48/7 Table 7: Systems Compliance Summary Code Division, Section Div 1, Sec. 5-7 Code Requirement General System System to monitor compliance with requirements of the Code. System to monitor compliance with quality and Reliability standards: voltage fluctuations, harmonics. Evidence of System Evidence of Process Findings / Comments Recommended Corrective Actions / Operation of the systems which monitor Rottnest Island Authority's compliance with the Code, complies with the Code requirements except for the findings reported below. Measurements are systematic, initiated from compliance calendars and CMMS and occur annually at peak demand time. No complaints from customers on quality of supply. THD is measured and is in compliance. Opportunities for Improvement (OFI) All flicker readings were in compliance except for one-off peaks. Results for fluctuations (flicker) were mainly in accordance with the Code with some excursion in excess of the limit. No evaluation of the power quality monitoring results was noted. An assessment is required and outcome and actions, if any, documented. 1/2015. Implement a process to ensure that results of power quality monitoring are reviewed and outcomes and actions documented. AUDITREPORT-4807-RIA QUAL&RELIAB Page25 of

26 SUPPLY PERFORMANCE AUDIT - OPERATION OF COMPLIANCE REF 48/7 Code Division, Section Div 1, Sec. 8 Div 2, Sec. 9 Div 2, Sec. 10 Div 2, Sec. 11 Code Requirement System to monitor compliance with duty to disconnect if damage may result due to power quality. System to monitor compliance with maintaining the supply with a minimum number and duration of interruptions. System to monitor compliance with reduction of effects of interruptions or provision for alternative supplies for proposed interruptions. System to monitor compliance with length and (continued below) Evidence of System Evidence of Process Findings / Comments Recommended Corrective Actions / Disconnections are covered by procedures, can proceed in case of emergencies and are documented. PFM monitors the number of interruptions, their duration, customers affected and causes. Procedures and processes are in place to monitor and reduce the effects of interruptions and provide alternative supplies. PFM records the length of interruptions. There was no indication in the outage register or other control document that it is a breach of section 11 of the Code when an outage exceeds 6 hours duration. However no customers were affected by any planned outage exceeding the duration requirement of the Code. Opportunities for Improvement (OFI) AUDITREPORT-4807-RIA QUAL&RELIAB Page26 of

27 SUPPLY PERFORMANCE AUDIT - OPERATION OF COMPLIANCE REF 48/7 Code Division, Section Div 2, Sec. 12 Div 3, Sec. 13 Code Requirement notifications for planned interruptions. System to monitor compliance with limiting significant interruptions to small use customers ( 16 times or 12 Hours) and to provide remedial action where breaches occur. System to monitor compliance with standards for the duration of interruption of supply in particular areas (30, 160, 290 min) Evidence of System Evidence of Process Findings / Comments Recommended Corrective Actions / A system is in place to issue notifications of planned interruptions. There were no register or records to indicate that the 72 hour minimum notification had been monitored during the reporting period. Outage numbers are monitored. There is evidence of compliance in 8 years out of 9. There is evidence of improvement actions. There was no evidence in the current registers that interruptions over 12 hours or that frequency of interruptions in excess of 16 per year are monitored over the 10 year period Figures are monitored. Complies. At present there is no formal verification of reported information. Opportunities for Improvement (OFI) 2/2015. There should be evidence to show that compliance with the notification requirement of section 11 of the Code is being monitored. 3/2015. Establish a process for monitoring compliance of the number and frequency of significant interruptions over 10 years, in accordance with section 12 of the Code. 4/2015. (OFI) Entry data, calculation results and report figures should be subject to verification. Verification process should be documented; this could be achieved by describing it in the calculation sheets (action carry over from audit). It is noted that a corrective action was in progress at the end of the previous audit period. AUDITREPORT-4807-RIA QUAL&RELIAB Page27 of