Impacts and Implementation: NERC Reliability Standards, Compliance Initiatives, and Regulatory Activities NRECA TechAdvantage March 2014 Patti Metro Manager, Transmission & Reliability Standards NRECA Barry Lawson Associate 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 2
NERC Reliability Assurance Initiative 3
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. 4
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 5
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 handbook 6
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 7
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 8
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 9
Material and Questions/Comments Posted Material: http://www.nerc.com/pa/comp/pages/reliability- Assurance-Intiative.aspx Submit: RAIcomments@nerc.net 10
Risk-Based Registration Project 11
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_regis trationcriteria_20121220.pdf
BES Definition Update 14
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 21
Geomagnetic Disturbances 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)
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 23
EOP-10: Applicability Reliability Coordinators (RCs) Transmission Operators (TOPs) with a Transmission Operator Area that includes a power transformer with a high side wyegrounded winding with terminal voltage greater than 200KV. Does not apply to: Balancing Authorities (BAs) Generator Operators (GOPs) 24
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. 25
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. 26
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 27
Phase 2: TPL-007 Draft 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 28
GMD Resources Operating Procedure Template - Transmission Operator http://www.nerc.com/comm/pc/geomagnetic%20disturbance%20task%20for ce%20gmdtf%202013/template_top.pdf Operating Procedure Template Generation Operator http://www.nerc.com/comm/pc/geomagnetic%20disturbance%20task%20for ce%20gmdtf%202013/template_gop.pdf GIC Application Guide http://www.nerc.com/comm/pc/geomagnetic%20disturbance%20task%20for ce%20gmdtf%202013/gic%20application%20guide%202013_approved.pdf 29
Operating Personnel Communications Protocols Seven year development history COM-002-4: 8 th 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. 30
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 31
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. 32
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 33
NERC CIP Standards Current 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 Standards Current 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-pressoffice/2013/02/12/executive-orderimproving-critical-infrastructurecybersecurity
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 Activities http://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 44
Patti Metro Manager, Transmission & Reliability Standards PH 703.907.5817 CELL 571.334.8890 patti.metro@nreca.coop Barry Lawson Associate Director, Power Delivery & Reliability PH 703.907.5781 CELL 703.966.3123 barry.lawson@nreca.coop