CCC Compliance Guidance Task Force. Patti Metro, Manager, Transmission & Reliability Standards, NRECA Compliance Committee May 4, 2016

Transcription

1 CCC Compliance Guidance Task Force Patti Metro, Manager, Transmission & Reliability Standards, NRECA Compliance Committee May 4, 2016

2 Key CCC Compliance Guidance Task Force Deliverables Developed procedure to become a pre-qualified organization eligible to submit implementation guidance to ERO Enterprise Recommended list of existing documents to be endorsed as Implementation Guidance Will support the Standards Committee in its review of Section 11 of the Standard Processes Manual Will review purposes of Reliability Standards measures and Reliability Standard Audit Worksheets (RSAWs) 2

3 Pre-qualified Organization Procedure Compliance Processes and Procedures Subcommittee (CPPS) reviews pending applications during each quarterly CCC meeting CPPS provides recommendations to CCC CCC acts on CPPS recommendation CCC notifies ERO Enterprise to modify the pre-qualified list 3

4 List of Endorsement Documents Starting Point for Document Review (NERC Website) Document Measures RSAWs Guidelines White Papers Responses to Comments FAQs Webinars Lessons Learned Reports Purpose Provides a non-exclusive list of evidence to demonstrate compliance Worksheet used by CMEP auditors and may be used by entities to prepare for compliance monitoring Provides the technical basis for the standard Provides a technical basis for the standard Provides answers to industry questions or comments raised during standards development Provides answers to straightforward or simple industry questions Provides information related to the standards Provides answers to complex industry questions Provides historical information or trends 4

5 List of Endorsement Documents Document Type Results of Review Documents Available Status Standards Supporting Documents 24-5 documents ready for ERO endorsement - 7 documents potential candidates - 2 documents potential CMEP Practice Guides - 10 documents rejected Compliance Training, Workshop Materials and Webinars 15 Not relevant for ERO endorsement Compliance Process Bulletins 23 Probably not relevant, no further review Compliance Application Notices (CANs) Compliance Analysis Reports (CIP Transition Page) Guidance Documents Developed by Technical Committees 32 CANs related to CIP likely outdated with transition to CIP V5. Others pending further review 4 Need further review Numerous (Undetermined) Other Documents ERO Case Studies 1 Need further review Need to involve various technical committees to determine extent of documents to review RSAWs 120 To be reviewed by CPPS as separate phase of review 5

6 List of Endorsement Documents Standard Version Five Documents Proposed for ERO Enterprise Endorsement Standard Title Supporting Document PER System Personnel Training PER-005 System Personnel Training Reference Document PER Operations Personnel Training Compliance Operations Draft Reliability Standard Compliance Guidance for PER October 1, 2013 TOP Transmissions Operations System Operating Limit Definition and Exceedance Clarification TPL TPL Transmission System Planned Performance for Geomagnetic Disturbance Events Transmission System Planned Performance for Geomagnetic Disturbance Events Transformer Thermal Impact Assessment White Paper Screening Criterion for Transformer Thermal Impact Assessment 6

7 Next Steps Support Standards Committee in its review of Section 11 of the Standard Processes Manual Review Reliability Standards measures and RSAWs 7

8 Compliance Guidance Implementation Valerie Agnew, Senior Director of Reliability Assurance, NERC Compliance Committee Meeting May 4, 2016

9 Key Activities in Compliance Guidance Policy Implementation Developed ERO Enterprise process for endorsement review of proposed Implementation Guidance Created compliance guidance website Developed CMEP Practice Guide on deference 9

10 Process for ERO Enterprise Endorsement Proposed Implementation Guidance posted on NERC s website Regional Entity Compliance Monitoring Group and Regional Entity subject matter experts review proposed Implementation Guidance NERC Enforcement reviews proposed Implementation Guidance Endorsed Implementation Guidance posted on NERC s website 10

11 Compliance Guidance Webpage Key Resources CMEP Practice Guides Endorsed Implementation Guidance Proposed Implementation Guidance 11

12 Status of Proposed Implementation Guidance 23 submittals for proposed Implementation Guidance received Five from CCC Task Force 12 from Compliance Guidance Policy Team o CIP v5 Transition Advisory Group Lessons Learned and Frequently Asked Questions (FAQs) o North American Transmission Forum CIP-014-1, Requirement R1 Guideline o Determination and Application of Practical Relaying Loadability Ratings, Version 1.0, June 2008 for PRC-023 Six from Midwest Reliability Organization Standards Committee 12

13 Status of CIP V5 TAG Lessons Learned and FAQs Handled outside of Implementation Guidance Developed for ERO Enterprise-wide use prior to the Compliance Guidance Policy ERO Enterprise will honor the final Lessons Learned and FAQs 13

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15 Coordinated Oversight of Multi-Region Registered Entities Stacy Dochoda, President and CEO, FRCC Compliance Committee May 4, 2016

16 Overview Objective is to improve efficiency for registered entities in multiple regions and increase consistency in compliance operations. One or more Lead Regional Entities (LREs) will coordinate all CMEP activities for each multi-region registered entity (MRRE) or group of MRREs. LRE will coordinate activities with the Affected Regional Entity (ARE). 2

17 Overview Each ARE will be involved in all aspects of CMEP activities related to the MRREs within their region. NERCwillcontinue to oversee allcoordinated activities. No effect on registration. Voluntary participation 3

18 Participation in the Program 4

19 Mechanism MRREs contact NERC or the Regional Entity, express interest in coordinated oversight LRE selectedbased on a number of factors, including: Location of highand medium Bulk Electric System impact assets Seams issues/registered functions Entity s footprint load, generation capacity, control centers, transmission interties 5

20 Mechanism LRE s responsibilities include: Ensureadequate resources Serve as primary regional interface for MRRE Coordinate with AREs for all aspects of CMEP activities as well as other activities (e.g. NERC Alerts) ARE s responsibilities include: Coordinate and participate with LRE in all aspects of CMEP activities 6

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22 Duke Energy s Participation in the NERC Coordinated Oversight Program Roxanne A. Scacco, Manager - NERC Corporate Compliance

23 Merger of Progress Energy and Duke Energy in years of service 7.3 million customer accounts $118 billion in assets $23.9 billion in revenue 28,324 employees Headquarters: Charlotte, NC Duke Energy Overview

24 Duke Energy Overview Regulated Utilities 6 states: North Carolina South Carolina Indiana Ohio Kentucky Florida 32,000 miles of transmission lines covering 95,000 square miles of service area 49,600 MW of regulated generating capacity

25 Duke Energy NERC-Registered Entities WECC TRE SPP SERC FRCC RF Commercial Renewables Regulated Utilities Duke Energy Renewables Svcs, LLC (DERS) Duke Energy Renewables Svcs, LLC (DERS) Duke Energy Renewables Svcs, LLC (DERS) Duke Energy Progress (DEP) Duke Energy Florida (DEF) Duke Energy Corp. (DECorp) Three Buttes Windpower LLC Notrees Windpower, LP Cimarron Windpower II, LLC Duke Energy Carolinas (DEC) Top of the World Wind Energy, LLC Los Vientos Windpower IA, IB, III, and V Ironwood Windpower, LLC Conetoe II Solar LLC (DERS) Mesquite Creek Wind LLC Duke Energy Renewables Svcs, LLC (DERS) 4

26 Duke Energy NERC Registrations

27 Duke Energy - MRRE Experience Our Participation Fully opt-in in 2015: all registrations, all registered functions, all Standards (CIP + O&P) Customized participation in the Coordinated Oversight Program Regulated Operations: SERC as Lead Region, RF and FRCC as AREs Renewables: TRE as Lead Region, WECC and SPP as AREs MRRE Experience Focus Issue Management (enforcement) Opportunities Audit Inherent risk assessment for MRRE Coordination of communications Coordination of schedules, due dates Regional portals/systems Consistency of compliance guidance Data Submittals 6

28 Roxanne A. Scacco Manager NERC Corporate Compliance office cell 7

29 Coordinated Oversight Experiences Thad Ness Xcel Energy 5/4/2016

30 Agenda Company Overview Registered Functions Audit Timeline Coordinated Oversight Experiences Pros and Cons Evaluated On-going Activities 2 2

31 Xcel Energy - Overview Northern States Power Company- Minnesota Northern States Power Company- Wisconsin Public Service Company of Colorado Southwestern Public Service Company Electric Customers Transmission Lines Generation NERC Regions 3.5 million 19,523 miles 18,000 MWs MRO, SPP RE, WECC 3 3

32 Xcel Energy Registered Functions Function NSP PSCo SPS Balancing Authority (BA) Coordinated Functional Registration Transmission Owner (TO) Transmission Operator (TOP) Transmission Planner (TP) Transmission Service Provider (TSP) Planning Authority/Coordinator (PA/PC) Generator Owner (GO) Generator Operator (GOP) Resource Planner (RP) Distribution Provider (DP) 4

33 Xcel Energy Audit Timeline 5 5

34 Coordinated Oversight Experiences Regional Entities provided opportunities to leverage coordination where possible Gradual evolution of coordination on ad-hoc basis Some alignment on Self-Certification schedules Coordinated CIP audits Joint enforcement activities with one Region taking lead Xcel Energy formally enrolled in Coordinated Oversight Program in

35 Pros and Cons Evaluated Full Coordinated Oversight (Everything Coordinated) Partial Coordinated Oversight (CIP Only) No Coordinated Oversight Expand positive coordination experiences Status quo with some additional coordination Existing Operations & Planning audit expectations maintained Pros Maximize consistency in practices and perspectives Reduced number of audits Slightly fewer data submissions Existing Operations & Planning audit expectations maintained Keeps matters within the respective Region Fewer data submissions No experience with joint Operations & Planning audit Inconsistent internal program (CIP different then Ops & Planning) Would have to revert back from progress made in coordination Cons Potentially less interaction with Associated Regional Entities (ARE) Continue volume of data submissions and more audits Some differences across Regions 7 7

36 On-going Activities Finishing prior open enforcement with respective Region New enforcement matters coordinated with Lead Regional Entity (LRE) Working with LRE on new opportunities as they arise Self-Certification Data submissions Future audits 8 8

37 9 Questions?

38 Critical Infrastructure Protection Standards and Compliance Update Carl Herron, Principal Critical Infrastructure Physical Advisor Tobias Whitney, CIP Compliance Manager Compliance Committee May 4, 2016

39 2016 Key Activities CIP Physical Security CIP Oversight Activities Initial Outreach and Exploratory Field Visits CIP Version 5 (CIP V5) Cyber Security Standards Activity Compliance and Oversight 2

40 FERC Order No. 822 Approved revisions to seven CIP Reliability Standards Directed NERC to develop modifications to address: Transient electronic devices; Communication network components between control centers; and Low-impact external routable connectivity. Effectiveness of remote access controls Does not address supply chain management 3

41 CIP V5 Standard Enhancement NERC-led technical conference held on April 19, 2016 Drafting team appointments made April 20, 2016 Team will review SAR comments and make necessary revisions First drafting team meeting planned for end of May Like CIP V5, communication and outreach plan to be developed 4

42 New Effective Date for CIP V5 Activities and clarifications: NERC has published a detailed set of effective dates reflecting FERC Orders Webinar focused on new dates and compliance expectations High and Medium impact requirements become effective on July 1, 2016 Low impact requirements have no change to effective date: April 1,

43 CIP V5 and CIP Related Parts Supply Chain Standards Revisions FERC Order No. 822 and New Directives Standards NERC Coordination Oversight and Consistency Outreach ERO Monitoring V5 ERO Monitoring CIP-014 FERC-led Audits V5 FERC-led Audits CIP-014 Compliance 6

44 NERC s Coordinated Approach SDT REs Standards Compliance Coordination and Oversight NERC Aware, Informed, and Engaged 7

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46 Compliance Monitoring and Enforcement Program Sonia Mendonca, VP of Enforcement, Deputy General Counsel Compliance Committee May 4, 2016

47 First Quarter Highlights Progress in mitigationof noncompliance Over 99% of older violations (2013 and older) are fully mitigated Self-identification of noncompliance 93% of noncompliance discovered in the first quarter of 2016 was selfidentified Completion of Inherent Risk Assessments (IRAs) Plans in development for completion of all IRAs Balancing Authorities, Reliability Coordinators, and Transmission Operators prioritized for completion in

48 First Quarter Highlights Participation in Self-Logging Ten new entrants; qualitative review of the program is underway Disposition of Noncompliance 49% of the noncompliance posing a minimal risk was treated as a compliance exception. A few significant cases involving violations of Critical Infrastructure Protection Standards were resolved throughnotices of Penalty. 3

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