Global Audit-Ready Standards Updates

Spring 2018

Cooper Compliance is excited to announce that Lisa Ellis has joined our team.  Lisa is certified as a NERC Certified System Operator (Reliability Coordinator).  Prior to joining the Cooper Compliance team, she worked at Peak Reliability as a RC in training. She was also employed for many years at the California Independent System Operator in both grid and market operations, including working as a generation dispatcher.   A fun fact about Lisa: Some of you may have heard her singing in the California Independent System Operator band called “Smooth Operators”. She is going to use all of her skills to provide you a smooth compliance program.

This Newsletter provides details for the following:

  • Cooper Compliance News
  • Revised NERC Standards, along with descriptions of changes
  • New Standards
  • Standards Made Inactive
  • Recently Added RSAWs
  • Standards Under Review: Balloting and Commenting

Cooper Compliance Customer News

In other news, Cooper Compliance continues to build compliance into out customer's organizations. We have enhanced our Global Audit-Ready suite to make your SharePoint experience soar. Your Cooper Compliance Project Manager will soon contact you to go over the improvements.

Recent enhancements to Cooper Compliance products include:

  • Improved Auditor module,
  • Enhanced Dashboard
  • Program optimization

New products available to Cooper Compliance customers include:

  • A SharePoint training module to replace Microsoft Office Mix.
    We recently rolled out our "Introduction to NERC" training module to prepare new personnel with a firm foundation in NERC practices.
  • Global Audit-Ready Event Analysis form
    Used to analyze each breaker operation, conduct root cause analysis, and determine corrective action plans with automated reminders to ensure timeliness.
  • Global Audit-Ready Administrator
    Used to maintain the database of Standards within the Global Audit-Ready products and implement changes to SharePoint lists and libraries when we roll out enhancements. We provide the csv file and either you or your Cooper Compliance Project Manager uploads with a click of a button.
  • Global Audit-Ready Audit-Package Creator
    We are thrilled to introduce our latest time-saving compliance application: Audit Package Creator. This app lets you generate RSAWs at the click of a button. Watch the video below.

 

This SharePoint application will revolutionize the way you go about creating audit packages, such as RSAW packages. When integrated as part of the Cooper Compliance Global Audit-Ready Application suite, this application lets you choose the desired standard, and then create a complete, professional audit package filing in under a minute.  The simplicity and efficiency of this app cannot be matched, saving you time and money.
 
Click the video link above to be redirected to our website, which contains a demo video on this new exciting product.

Revised NERC Standards

Cooper Compliance continues to build compliance into your organization and enhance our Global Audit-Ready suite to make your SharePoint experience soar. 

 

FAC-501-WECC-2

Applies to:
Transmission Owner TO in the WECC region with Major WECC Transfer Paths in the Bulk Electric System
Standard: Transmission Maintenance
Date: 7/1/2018
Notes: Replaces FAC-501-WECC-1 which became inactive 6/30/18.

  • Both old and new versions say that TOs must have a TMIP that includes items listed in an Attachment. The Attachment that defines TMIP content has been updated to contain more detail.
  • Requirements have been slightly re-arranged with previous R1.1 becoming a major R2 in new version, and previous R2 being integrated into R1 in new version.
  • R1.1 in previous version says TMIP should be annually reviewed and updated as required, whereas in new version, it has been changed to R2 and states that TMIP must be annually updated.
  • Previous R3 said that TOs shall implement and follow their TMIP, whereas new R3 simply says they shall adhere to their TMIP.

PRC-025-2

Applies to: 
Distribution Provider DP
Generator Owner GO
Transmission Owner TO
Standard:  Generator Relay Loadability
 Date:  7/1/2018
Notes:  Replaces PRC-025-1
The single requirement did not change—that GOs, TOs, and DPs apply settings in accordance with Attachment 1: Relay Settings. However, there were some changes in the attachment as follows:

  • In Attachment 1: Relay Settings, verbiage has been added that GOs may base relay settings on a capability that is higher than what is reported to the Transmission Planner, and clarifies seasonal capabilities.
  • Also, low voltage protection devices that do not have adjustable settings  are now excluded from requirements of this standard.
  • In the Relay Loadability Evaluation Criteria, several references to “Elements that connect the GSU Transformers to the Transmission system” have been changed to “Relays installed on the high-side of the GSU transformer” for such elements as above. A further discussion of these elements has been added under the Figure 1 heading.
  • In the Relay Loadability Evaluation Criteria, an option 5b along with accompanying figure has been added to further clarify Phase overcurrent relay. From Attachment 1: “For Option 5b, the overcurrent element shall be set to exceed the maximum capability of the asynchronous resource and applicable equipment (e.g., windings, power electronics, cables, or bus).”
  • A figure 4 has been added to clarify Elements utilized in the aggregation of dispersed power producing resources.

 
 

TOP-001-4

Applies to (variously, depending on requirement number):
Balancing Authority BA
Transmission Operator TOP
Generator Operator GOP
Distribution Provider DP
Standard:  Transmission Operations
Date:  7/1/2018

Notes: TOP-001-4 replaces TOP-001-3.

  • R10 has been clarified and expanded.
    R10 in previous standard:

R10. Each Transmission Operator shall perform the following as necessary for determining System Operating Limit (SOL) exceedances within its Transmission Operator Area: [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]
10.1. Within its Transmission Operator Area, monitor Facilities and the status of Special Protection Systems, and
10.2. Outside its Transmission Operator Area, obtain and utilize status, voltages, and flow data for Facilities and the status of Special Protection Systems.
 
R10 in new standard: 
R10. Each Transmission Operator shall perform the following for determining System Operating Limit (SOL) exceedances within its Transmission Operator Area: [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]
10.1. Monitor Facilities within its Transmission Operator Area;
10.2. Monitor the status of Remedial Action Schemes within its Transmission Operator Area;
10.3. Monitor non-BES facilities within its Transmission Operator Area identified as necessary by the Transmission Operator;
10.4. Obtain and utilize status, voltages, and flow data for Facilities outside its Transmission Operator Area identified as necessary by the Transmission Operator;
10.5. Obtain and utilize the status of Remedial Action Schemes outside its Transmission Operator Area identified as necessary by the Transmission Operator; and
10.6. Obtain and utilize status, voltages, and flow data for non-BES facilities outside its Transmission Operator Area identified as necessary by the Transmission Operator.

  • R20 clarifies that data exchanges must be real-time and must have backups and it also details the entities with whom the data exchange capability must exist.
  • The following 4 requirements were added in the new version:

R21. Each Transmission Operator shall test its primary Control Center data exchange capabilities specified in Requirement R20 for redundant functionality at least once every 90 calendar days. If the test is unsuccessful, the Transmission Operator shall initiate action within two hours to restore redundant functionality. [Violation Risk Factor: Medium ] [Time Horizon: Operations Planning] 
R22. Each Balancing Authority shall have data exchange capabilities with the entities it has identified it needs data from in order to develop its Operating Plan for next-day operations. [Violation Risk Factor: Medium] [Time Horizon: Operations Planning] 
R23. Each Balancing Authority shall have data exchange capabilities, with redundant and diversely routed data exchange infrastructure within the Balancing Authority's primary Control Center, for the exchange of Real-time data with its Reliability Coordinator, Transmission Operator, and the entities it has identified it needs data from in order for it to perform its Real-time monitoring and analysis functions. [Violation Risk Factor: High] [Time Horizon: Same-Day Operations, Real-time Operations] 
R24. Each Balancing Authority shall test its primary Control Center data exchange capabilities specified in Requirement R23 for redundant functionality at least once every 90 calendar days. If the test is unsuccessful, the Balancing Authority shall initiate action within two hours to restore redundant functionality. [Violation Risk Factor: Medium ] [Time Horizon: Operations Planning]

 

IRO-018-1(i)

Applies to: 
Reliability Coordinator RC

Standard:  Reliability Coordinator Real-time Reliability Monitoring and Analysis Capabilities
Date:  4/1/2018

Notes:  Replaces IRO-018-1.
R1 VRF for R1 changed from medium to high.
TOP-010-1(i)

Applies to: 
Balancing Authority BA
Transmission Operator TOP
Standard:  Real-time Reliability Monitoring and Analysis Capabilities
 Date:  4/1/2018
Notes:  Replaces TOP-010-1.
VRF for R1 and R2 changed from medium to high.
 

Standards Made Inactive

  • FAC-501-WECC-1
  • PRC-025-1
  • TOP-001-3
  • IRO-018-1
  • TOP-010-1


New Standards
None

Cooper Compliance - Keeping you Audit Ready

Cooper Compliance strives to simplify compliance by integrating compliance into our clients’ daily work.  The Global Audit-Ready system records and stores evidence as you perform your normal activities, freeing-up time so you can focus on adding value to your organization. Let us know if we can help, or if you would like a demo of our transformative Global Audit-Ready compliance applications.

Cooper Compliance has been providing NERC Compliance services since 2007.  The Global Audit-Ready Software suite by Cooper Compliance are SharePoint applications designed to provide automatic RSAW Development as well as controls to ensure accuracy when demonstrating compliance.

 

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NERC Update - February 18

February 2018

Why focus on Compliance? Not just because the regulatory bodies tell us to, but more importantly to avoid and mitigate dangerous situations like these:

  • Electrical worker in critical condition after touching high-voltage wire, Miami Herald, Feb 13, 2018
  • Explosion, fire at power plant cause blackout in northern Puerto Rico, CBS News, Feb 12, 2018
  • Nearly 1,000 miners trapped underground in South Africa after power outage, Independent, Feb 1, 2018


To help you achieve safety and reliability, Cooper Compliance is pleased to provide news that compliance professionals need to know. In this newsletter, learn what standards are imminently changing, retiring, or becoming effective. Keep up to date with your entity’s responsibilities for NERC standards. We sift through the NERC website and bring it all together for you in a neat and succinct summary, freeing your time to build your business.   

This report provides:

  • A summary of the NERC updates that were made during January of 2018.
  • A description of NERC projects under development and our comments on each
  • A list of new RSAWs that have been added to the databases underlying Global Audit-Ready, our cutting edge compliance software package for energy industry compliance to government standards.
  • Updates to Cooper Compliance Global Audit-Ready SharePoint applications, which help your organization adhere to ever changing standards of compliance.

Revised NERC Standards

BAL-002-2(i) (R1, R2)
Title: Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event
Applicability: Balancing Authority or Reserve Sharing Group
Effective Date: 2/5/2018
BAL-002-2(i) replaces BAL-002-2 on 2/5/18. For R1 and R2, the VRF was changed from Medium to High.  To comply with R1 and R2, the responsible entity must supply evidence and documents proving compliance if there is a reportable balancing contingency event.

NERC Standards Under Development January/February 2017

  • 2017-02 Modifications to PER Standards  Posted for comment and balloting, both of which close on 3/7/2018.
    Proposed changes are as follows:
    PER-003-1 R1-R3: A clarifying footnote needs to be added to ensure that stakeholders  understand (i) the connection between the Standard and the Program Manual ; and (ii) that the certifications referenced under PER-003-1 are those under the NERC System Operator Certification Program.
    PER-004-2: The Project Team recommends that PER-004-2 be retired. All of its requirements are redundant with requirements in other FERC-approved reliability standards that are in effect or soon to be effective.  It is not necessary or efficient to maintain such duplicative requirements.
    VOTING RECOMMENDATION: Cooper Compliance recommends voting Yes.
  • 2017-07 Standards Alignment with Registration | Standards Authorization Reques.  Commenting closes on 3/2/2018.
    Project 2017-7 Standards Alignment with Registration is focused on making updates necessary to reflect the retirement of functional registration of PSEs, IAs, and LSEs. This includes replacing with another function, removal of function, and informing other period reviewers of the necessity of removing these functional registrations.
    COMMENT RECOMMENDATION: Cooper Compliance recommends agreement with these minor standard revisions to remove references to retired functional registrations.

See the NERC Balloting and Commenting page for details of how to participate.
 

Updates to Global Audit-Ready SharePoint Applications


RSAW Creator. This exciting new application lets you prepare RSAWs, complete with ordered references to evidence, with the click of a button. All evidence files are collected into a single folder for easy attachment to the package.

Operator Instruction Log Site Access.  A new Site Access tab lets you easily keep track of who accesses each facility, when they arrive, and when they leave. Use this data as an audit trail of personnel access, and for more immediate purposes, such as to respond timely if personnel does not exit when expected.

Updates to Standards. As always, those subscribing to Global Audit-Ready applications receive all NERC and GO167 standards in database format, updated with all relevant information, such as VRF, functional registration, and more.

New and Updated RSAW Documents:

Standard Description Date Updated
PRC-006-3 Automatic Underfrequency Load,Shedding 11/29/2017
VAR-001-4.2 Voltage and Reactive Control 11/29/2017
VAR-002-4.1 Generator Operation for Maintaining Network Voltage 11/29/2017
BAL-002-2 Disturbance Control Performance - Contingency Reserve for Recovery from a Balancing Contingency Event 10/11/2017
IRO-018-1(i) Reliability Coordinator,Real-time Reliability Monitoring and Analysis Capabilities 10/11/2017
TOP-010-1 Real-time Reliability Monitoring,and Analysis Capabilities 10/11/2017
PRC-026-1 Relay Performance During Stable,Power Swings 9/25/2017

 

Cooper Compliance - Keeping you Audit Ready

Cooper Compliance strives to simplify compliance by integrating compliance into our clients’ daily work.  The Global Audit-Ready system records and stores evidence as you perform your normal activities, freeing-up time so you can focus on adding value to your organization. Let us know if we can help, or if you would like a demo of our transformative Global Audit-Ready compliance applications.

Cooper Compliance has been providing NERC Compliance services since 2007.  The Global Audit-Ready Software suite by Cooper Compliance are SharePoint applications designed to provide automatic RSAW Development as well as controls to ensure accuracy when demonstrating compliance.

Global Audit Ready Standards Update

Happy New Year from Cooper Compliance!

Cooper Compliance is pleased to provide news that compliance professionals need to know. In this newsletter, learn what standards are imminently changing, retiring, or becoming effective. Keep up to date with your entity’s responsibilities for NERC standards. We sift through the NERC website and bring it all together for you in a neat and succinct summary, freeing your time to build your business.   

This report provides:

  • A summary of the updates that were made during the fourth quarter of 2017.
  • A description of projects under development and our comments on each
  • A list of new RSAWs that have been added to the databases underlying Global Audit-Ready, our cutting edge compliance software package for energy industry compliance to government standards.

Those entities utilizing SharePoint 2013 or higher will soon be upgraded to our latest version of Global Audit-Ready that contains many new and exciting features.  For example, word RSAWs and RSAW packages are now auto-generated to prepare you for an audit with a click of a button.  The Global Audit-Ready Operator Instruction Log (OIL) for SP 2013 and higher has many great reporting features.  Contact Cooper Compliance if you are not already a user of OIL to see how it can help your organization raise its bar with a robust compliance program and internal controls.
 

Revised NERC Standards:

BAL-002-2 (R1, R2)
Title: Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event
Applicability: Balancing Authority or Reserve Sharing Group
Effective Date: 1/1/2018
BAL-002-2 contains revisions to, and replaces, BAL-002-1. Major changes are as follows:
In R1 and R2 the VRF (Violation Risk Factor) has been moved from medium to high, replacing BAL-002-01.  To comply with R1 and R2, the responsible entity must supply evidence and documents proving compliance if there is a reportable balancing contingency event.

BAL-502-RF-03
Title: Planning Resource Adequacy Analysis, Assessment and Documentation
Applicability: Planning Coordinator in the Reliability First (RF) region
Effective Date: 1/1/2018
BAL-502-RF-03 contains revisions to, and replaces, BAL-502-RF-02. Major changes are as follows:
From M1, "Each Planning coordinator shall possess the documentation that a valid Resource Adequacy analysis was performed or verified in accordance with R1".  From M3, " Each Planning Coordinator shall possess the documentation identifying any gaps between the needed amounts of planning reserves and projected planning reserves in accordance with R3."  A third requirement was added, which states, “The Planning Coordinator shall identify any gaps between the needed amount of planning reserves defined in Requirement R1, Part 1.1 and the projected planning reserves documented in Requirement R2.”


PRC-006-SERC-02
Title: Automatic Underfrequency Load Shedding Requirements
Applicability: Planning Coordinators, Generator Owners, and UFLS entities, which might include Transmission Owners or Distribution Providers in the SERC region
Effective Date: 1/1/2018
PRC-006-SERC-02 contains revisions to, and replaces, PRC-006-SERC-01. Major changes are as follows:
In this update, the planning coordinator decides when the peak time is for each requirement as seen in R2, either summer or winter.


IRO-002-5
Title: Reliability Coordination – Monitoring and Analysis
Applicability: Reliability Coordinator
Effective Date: 10/1/2017
IRO-002-5 contains revisions to, and replaces, IRO-002-4. Major changes are as follows:

  • R1 Risk factor moved from High to Medium, and Time Horizon reduced to Operations Planning only.
  • Two new requirements were added. The first requires RCs to have data exchange capabilities and spells out the details of those capabilities. The second new requirement describes needed testing of the Control Center data exchange capabilities. R5 now directs that the status of Remedial Action Schemes, rather than the status of Special Protection Systems, be monitored.
  • The Compliance Enforcement Authority is expanded to include any entity designated by the applicable Governmental Authority.

.
COM-001-3
Title: Communications
Applicability: Transmission Operator, Balancing Authority, Reliability Coordinator, Distribution Provider, Generator Operator
Effective Date: 10/1/2017
COM-001-3 contains revisions to, and replaces, COM-001-2.1. Major changes are as follows:

  • The format of the requirement has been updated to include measures directly after the corresponding requirement.
  • Two new requirements, R12 and R13, specify additional interpersonal communication capabilities. R12 specifies that each RC, TO, GO, and BA shall have interpersonal communication that enables operation of the BES while specifying these communications must exist between control centers to control centers as wells as field personnel. R13 specifies that each DP shall have the same.  

The Compliance Enforcement Authority is expanded to include any entity designated by the applicable Governmental Authority.  In this update, the planning coordinator decides whether the peak demand is summer or winter for the purposes of each sub-requirement of R2.

VAR-501-WECC-3.1
Title: Power System Stabilizer(PSS)
Applicability: Generator Owner, Generator Operator in the WECC region
Effective Date: 9/26/2017
VAR-501-WECC-3.1 contains revisions to, and replaces, VAR-501-WECC-3. Major changes are as follows: 

This standard was written to ensure that the Western Interconnection is operated in a coordinated manner under any condition establishing performance criteria for WECC power system stabilizers. This update is due to an errata that corrects the effective date.  .  Requirement R3 has an effective date of July 1, 2017 for first time service after regulatory approval and R3 has an effective date of July 1, 2022 for units placed in service prior to final regulatory approval.  

VAR-002-4.1
Title: Power System Stabilizer(PSS)
Applicability: Generator Owner, Generator Operator
Effective Date: 9/26/2017
VAR-002-4.1 contains revisions to, and replaces, VAR-002-4. Major changes are as follows: 
The standard contained measures to ensure the generator provide voltage and reactive power control within generation facilities.   This update is due to an errata that adjusts foot note 4 to capitalize “Reactive Power” in order to reference the NERC definition for Reactive Power.
 

VAR-001-4.2
Title: Voltage and Reactive Control
Applicability: Transmission Operators, Generator Operators within the Western Interconnection(WECC)
Effective Date: 9/26/2017
VAR-001-4.2 contains revisions to, and replaces, VAR-001-4.1. Major changes are as follows:
The standard was replaced due to an errata that corrected NERC terms, corrected grammar, and other minor grammatical clarifications.  For example, The time horizon was modified from Operational Planning to Operations Planning and M1 clarifies that 30 days means 30 calendar days.
 

NERC Standards Under Development January 2017:

  • 2017-07  Standards Alignment with Registration. Open for comment until January 9. FERC approved the removal of two functional categories, Purchasing-Selling Entity (PSE) and Interchange Authority (IA), from the NERC Compliance Registry due to the commercial nature of these categories posing little or no risk to the reliability of the bulk power system.  FERC also approved the creation of a new registration category, Underfrequency Load Shedding (UFLS)-only Distribution Provider (DP), for PRC-005 and its progeny standards.(Reference) . 

Regarding 2017-07  Standards Alignment with Registration above, the Cooper Compliance feedback to NERC is that we agree with the proposed scope and objectives and with the merging of two SARs into a single SAR. Our comments to FERC are as follows:
Yes we agree the scope is appropriate, we also feel it could be expanded to cover the function of Generator Lead Lines Interconnection Facilities and TOP lite. While there is no registration type as Generator Lead Line Interconnection Facility, the concept has been introduced but is not well defined in the Standards.  In addition, while NERC has temporarily dismissed the concept of a TOP lite, it would be good to reintroduce this concept.  For example, a TOP that only owns a bus bar should not have to have a full blown backup control room and so forth. The Standards should match the risk to the Bulk Electric System. 


•    2017-05 NUC-001-3 Periodic Review. Open for comment through 1/29/2018.  The drafting team did not identify any changes that warrant a new project.  Cooper Compliance Agrees with this assessment.

Regarding 2017-07  Standards Alignment with Registration above, the Cooper Compliance feedback to NERC is that we agree with the proposed scope and objectives and with the merging of two SARs into a single SAR. Our comments to FERC are as follows:
Yes we agree the scope is appropriate, we also feel it could be expanded to cover the function of Generator Interconnection Facilities and TOP lite. While there is no registration type as Generator Interconnection Facility, the concept has been introduced but is not well defined in the Standards.  In addition, while NERC has temporarily dismissed the concept of a TOP lite, it would be good to reintroduce this concept.  For example, a TOP that only owns a bus bar should not have to have a full blown backup control room and so forth. The Standards should match the risk to the Bulk Electric System.

New and Updated RSAW Documents:

Standard Description Date Updated
PRC-006-3 Automatic Underfrequency Load,Shedding 11/29/2017
VAR-001-4.2 Voltage and Reactive Control 11/29/2017
VAR-002-4.1 Generator Operation for Maintaining Network Voltage 11/29/2017
BAL-002-2 Disturbance Control Performance - Contingency Reserve for Recovery from a Balancing Contingency Event 10/11/2017
IRO-018-1(i) Reliability Coordinator,Real-time Reliability Monitoring and Analysis Capabilities 10/11/2017
TOP-010-1 Real-time Reliability Monitoring,and Analysis Capabilities 10/11/2017
PRC-026-1 Relay Performance During Stable,Power Swings 9/25/2017