impacts and implementation: nerc reliability …...2014/03/02  · impacts and implementation: nerc...

Impacts and Implementation: NERC Reliability Standards, Compliance Initiatives, and Regulatory

ActivitiesNRECA TechAdvantage

March 2014

Patti MetroManager, Transmission & Reliability Standards

NRECA

Barry LawsonAssociate Director, Power Delivery & Reliability

NRECA

Introduction• Provide an overview of the Reliability

Assurance Initiative (RAI)• Discuss Risk-Based Registration Project• Update on BES Definition Implementation• Provide an overview of various Reliability

Standards– Geomagnetic Disturbances– Operating Personnel Communications Protocols– CIP Standard

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NERC Reliability Assurance Initiative

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Initiative - Purpose• Identify and implement changes that

enhance the effectiveness of the Electric Reliability Organization (ERO) compliance and enforcement program

• Functional and implemented by 2016• Support the ultimate goals of avoiding

cascading events and the resulting major loss of load.

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NERC Website - Postings• Frequently Asked Questions (FAQs)• Working definitions of internal controls

and their significance in risk-based compliance

• Information regarding workshops and other forums for discussing RAI

• Activities and milestones related to the RAI

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2014 - Progress on Auditors’ Manual • March - Training to Compliance

Auditors• April - Publish handbook on the NERC

website• August - Complete training for all

Compliance Auditors• September - All audit engagement use

and follow the handbook6

2014 - Progress on Auditors’ Manual • Advantages from Industry Perspective

– Common language to communicate with industry

– Standardized audit approach across the ERO Enterprise

– Transparent audit activities

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2014 - Progress Pilots and Evaluation of Pilot Methods • January – Pilot evaluation criteria

finalized• April – ERO executive management

presented with recommend audit design• October – Finalize compliance audit

design approved for training and deployment in 2015

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2014 - Progress Pilots and Evaluation of Pilot Methods • Advantages from Industry Perspective

– Defined risk approach that supports two way discussion

– Evaluation criteria results in appropriately scoped audits based on an entities size and risk

– Control evaluation is clearly defined and understood

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Material and Questions/Comments

Posted Material:http://www.nerc.com/pa/comp/Pages/Reliability-Assurance-Intiative.aspx

Submit:RAIcomments@nerc.net

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Risk-Based Registration Project

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NERC’s SCRC Initiative

• NERC’s plan for 2014 and 2015• NRECA/APPA focus and efforts• LSE/DP, TO/TOP, GO/GOP and other

SCRC provisions• Working to decrease compliance

responsibilities for smaller co-ops

NERC’s SCRC Initiative

• Best opportunity to make changes• Will need your feedback as we proceed• Technical support may be needed• http://www.nerc.com/FilingsOrders/us/R

uleOfProcedureDL/Appendix_5B_RegistrationCriteria_20121220.pdf

BES Definition Update

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Regulatory Status of Revised BES Definition• Inconsistent use of longstanding BES

definition by Regional Entities• FERC effort started in 2010• Important definition for determining

mandatory standards applicability• Can help on TO/TOP/radial line issues• Not going to help on DP/LSE issues• Related to SCRC and deregistration

Regulatory Status of Revised BES Definition• Phase 1 BES definition approved by

FERC end of 2012• Starting July 1, 2014 self-determined

application of definition and exception requests can be submitted

• New compliance date of July 1, 2016

Phase 1 BES Definition• Core definition

– 100kV and above– No facilities used in local distribution

• Inclusions– Transformers: primary and at least one secondary

terminal above 100kV– Generators :20 and 75 MVA (all nameplate)– Blackstart resources: identified in TOP restoration plan– Dispersed power producing resources: when

aggregating to greater than 75 MVA– Reactive power devices: connected at 100kV or above

or through a BES transformer

Phase 1 BES Definition• Exclusions

– Radial systems: load only, 75 MVA or less generation, combo, normally open devices

– Retail generation: net capacity back to BES is 75 MVA or less

– Local networks: for networks 100kV to 300kV with no flow back to BES, 75 MVA or less generation, no Blackstart resources and no flowgates

– Reactive power devices: owned/operated by retail customer for its own use

• Exception process in NERC Rules of Procedure (ROP) Appendix 5C

Phase 2 BES Definition• Addressing FERC directives from order on

Phase 1 definition and other industry comments from Phase 1– Radial exclusion changes for BES generation– Less than 100 kV looping issue – 50 kV solution

and Local Network exclusion changes– Dispersed power producing resources and the

collector system

Phase 2 BES Definition• Phase 2 filed with FERC Dec. 2013• Likely order in March 2014• Same compliance dates??• Skip phase 1??• http://www.nerc.com/pa/Stand/Pages/Pr

oject2010-17_BES.aspx

Reliability Standards Update

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• May 16, 2013 - FERC issued Order 779 which directs NERC to submit Reliability Standards that address the impact of geomagnetic disturbances (GMD) on the reliable operation of the Bulk-Power System.– Stage 1 – Operating

Procedures– Stage 2 – Detailed

Assessments (Planning Studies)

Geomagnetic Disturbances

Phase 1: EOP-10• Final ballot approval - 91.95 %• Approved by NERC Board of Trustees -

November 7, 2013• Submitted to FERC - November 2013

as required by FERC Order 779• FERC - January 16 indicated intention

to approve the standard, subject to NOPR comments

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EOP-10: Applicability• Reliability Coordinators (RCs)• Transmission Operators (TOPs) with a

Transmission Operator Area that includes a power transformer with a high side wye-grounded winding with terminal voltage greater than 200KV.

Does not apply to:• Balancing Authorities (BAs)• Generator Operators (GOPs)

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EOP-010: 200 kV Threshold Rationale • For lines less than 200kV, impedance is

higher, lines are generally shorter, and lower voltage lines provide minimal contribution to GIC; hence, such lines are ignored in analysis.

• If 230 kV lines were ignored, significant GIC would be mistakenly excluded from analysis and could result in inaccurate var consumption calculations.

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EOP-10: Requirements• R1- Each Reliability Coordinator (RC) required to

develop, coordinate, maintain, and implement, as necessary, a GMD Operating Plan.

• R2 – Each RC is responsible for disseminating forecast and current space weather information.

• R3 – Each Transmission Operator (TOP) required to develop, maintain, and implement an Operating Procedure or Operating Process to mitigate the effects of GMD events.

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Phase 2: TPL-007 Draft• Applicability: PC,TP,TO and GO• Require a planning assessment of the system

for its ability to withstand a Benchmark GMD Event without causing a wide area blackout, voltage collapse, or large load loss.

• Need system models - DC (GIC calculation) and AC (power flow)– Transformer information - internal winding

resistance– Substation grounding information

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• Studies (proposed every 5 years) that may be necessary to perform a GMD assessment:– Transformer GIC Impact Calculations– Power Flow System Studies – calculate

reactive power loss– Impact of Harmonics on Protection and

Control– Generator Impact Studies

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Phase 2: TPL-007 Draft

GMD Resources• Operating Procedure Template - Transmission

Operatorhttp://www.nerc.com/comm/PC/Geomagnetic%20Disturbance%20Task%20Force%20GMDTF%202013/Template_TOP.pdf

• Operating Procedure Template – Generation Operatorhttp://www.nerc.com/comm/PC/Geomagnetic%20Disturbance%20Task%20Force%20GMDTF%202013/Template_GOP.pdf

• GIC Application Guidehttp://www.nerc.com/comm/PC/Geomagnetic%20Disturbance%20Task%20Force%20GMDTF%202013/GIC%20Application%20Guide%202013_approved.pdf

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Operating Personnel Communications Protocols• Seven year development history• COM-002-4: 8th posting continuation of

the previous draft which combined COM-002-3 and COM-003-1

– Addresses communications protocols for operating personnel in Emergency, alert, and non-emergency situations.

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Operating Personnel Communications Protocols• Applicability: BA, DP, RC, TO and GO• Defined Operating Instruction• Initial training for DP operating

personnel– Repeat, not necessarily verbatim, the Operating

Instruction and receive confirmation from the issuer that the response was correct, or

– Request that the issuer reissue the Operating Instruction

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COM-002-4: NRECA Perspective• NRECA recommended a “negative”

ballot• NRECA focused comments

– Approach to limit the burden on Distribution Providers by providing alternative applicability language to limit the impact to small distribution cooperatives.

– Modify the “assess adherence and assess effectiveness” language in R4.

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COM-004-2: Ballot Results and Timeline• Initial ballot approval - 71.86% • Expected approval by the NERC Board

of Trustees - May 2014• Expected submittal to FERC – Summer

2014

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NERC CIP StandardsCurrent State of Play• NERC CIP V3, V4 and V5 standards

– CIP V3 in effect now– CIP V4 can be skipped– CIP V5 approved by FERC Nov. 2013

• FERC directives– CIP V5.1 or V6

• Compliance/enforcement confusion with multiple versions of CIP in play

NERC CIP StandardsCurrent State of Play• FERC’s directives in final Rule

– Identify, assess and correct (IAC)– Low category requirements– Communication networks– Transient devices

• New standard drafting team formed• Deadline for addressing IAC and

communication networks Feb. 2015• Drafting team goal of Nov. 2014

CIP V3 and V5 Differences

• CIP V3– RBAM (CIP-002)– If no CAs, no further significant requirements– If CAs and CCAs, then many other standards

apply (CIP-003 thru 009)• CIP V5

– Complete overhaul of CIP standards– no RBAM– High, Medium and Low criteria and requirements

Cyber Security EO

• President issued Executive Order (EO) on February 12, 2013 addressing– Information sharing between Federal government

and private sector– Security clearances for critical infrastructure

owners/operators– Development of Cyber Security framework by

NIST for voluntary private sector adoption

Cyber Security EO

http://www.whitehouse.gov/the-press-office/2013/02/12/executive-order-improving-critical-infrastructure-cybersecurity

Cyber Security Framework

• Primary focus is on critical infrastructure as defined in EO, but will likely have some usefulness to all private sector entities

• Public process to develop the framework

• Final version of framework published on February 12, 2014

Cyber Security Framework

• NIST will now hand off framework to DHS for private sector adoption efforts

• For critical infrastructure owners/operators there will be a strong push by DHS for adoption

• Federal government is looking at incentives to encourage adoption

Cyber Security Framework Development Activitieshttp://www.nist.gov/itl/cyberframework.cfm

RTF and Reliability Listserv• Reliability Listserv (excludes cyber)

• Designed for co-ops to communicate with other co-ops on reliability matters

• Not widely used• reliability@lists.cooperative.com

• To join let me know

NRECA Task Forces• Cyber Security Task Force (CSTF)

• Focus on NERC CIP standards, DOE/DHS/NIST initiatives, other regulatory and legislative cyber security activities

• Reliability Task Force (RTF) (excludes cyber)

• Focus on all non-cyber NERC/FERC reliability issues

• To join let me know

Conclusion• Provided an overview of the Reliability

Assurance Infinitive (RAI)• Discussed Risk-Based Registration

Project• Provided update on BES Definition

Implementation• Provided an overview of various

Reliability Standards

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Patti MetroManager, Transmission & Reliability Standards

PH 703.907.5817CELL 571.334.8890

patti.metro@nreca.coop

Barry LawsonAssociate Director, Power Delivery & Reliability

PH 703.907.5781CELL 703.966.3123

barry.lawson@nreca.coop