Global Audit Ready Standards Updates - August 2018

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Global Audit-Ready Standards Updates
August 2018


This newsletter contains information of interest to compliance professionals in the electric utility industry. Cooper Compliance clients and non-clients alike will find useful, timely information, including the following:
  • Cooper Compliance News
  • Industry Events
  • Industry News
  • New or Revised NERC Standards
  • NERC Standards Under Development
  • Recently Added RSAWs

Cooper Compliance News

NERCRequirements List Updated

You might notice a couple of new standards in the lists of standards for Global Audit-Ready applications. We recently updated all clients’ standard databases to keep pace with the released standards on the NERC website. These reside in your Cooper Compliance SharePoint website in the NERCRequirements list.
Here are the highlights:
  • Added BAL-002-2i
  • Added BAL-004-WECC-03
  • Added CIP-003-7
  • Added EOP-006-3
  • Added EOP-008-2
 

Global Audit-Ready Application Enhancements

  • Global Audit-Ready Operator Instructor Log – Added the ability to automatically send logs such as outages as SMS text messages instead of email.
  • All apps – Improved product robustness to load faster and manage SharePoint requests from multiple users. 
  • Global Audit-Ready Reporter – New interface elements for Internal Auditors allow for audit ratings, attaching audit work papers, and preserving audit results for different audit periods.
  • Global Audit-Ready Editor – Just became even faster to setup new Standards with inherent existing process feature.
 

Come See Us and View our Products...

Please come to the Cooper Compliance booth to view our latest products.

The WECC Reliability and Security Workshop (formerly "Compliance Workshop") is in San Diego from October 23 to 25.  
Sign up for the conference here.

The Northeast Power Coordinating Council 2018 Fall Compliance & Standards Workshop is in Providence, RI from November 7 to 8.
Sign up for the conference here. 

The North American Generator Forum (NAGF) annual member meeting is at the NERC headquarters in Atlanta from October 2 to 3.  
Sign up for the conference here.

We will post our notes at https://www.coopercompliance.com/download/
 

Industry News

Peak Reliability announced that it will cease operations at the end of 2019. The CAISO will be offering Reliability Coordinator services for the independent system operator footprint and will also offer those services to others in the West. Press release is here.
 
WECC will begin collecting functional relationship information between Generator Owners (GO) mapping to Transmission Planners (TP), and Generator Operators (GOP) mapping to Transmission Operators (TOP), and Transmission Operators (TOP) mapping to Balancing Authorities (BA). Deadline for submission of this data via webCDMS is September 28, 2018. FAQ is here
 

New or Revised Standards

There have been no new or revised standards released since the last newsletter.
 

Standards Under Development

2018 Bulk Electric System Definition Reference

The BES Definition Reference Document is being revised.
Comment Period: 8/7/2018 to 9/10/2018

This document explains how the revised Bulk Electric System (BES) definition should be applied. 
Cooper Compliance plans to submit the following comments on the new reference document:
  • In general, for all proposed modifications, clarity should be made to Figure I2.1, which attempts to define what is considered a “single point of interconnection”. Further clarification is attempted under the heading Common Point of Connection (p 22 of clean copy linked above). Neither provide full clarity and need to be improved.
    • Does the configuration represent the breaker scheme, a substation, or a line?
    • Does breaker configuration matter? If breaker configuration prevents a cascade outage on both generators, should they be added together?
    • Do the boxes in figure E3.3 represent a breaker configuration or a substation configuration?

Functional Model Advisory Group (Reliability Functional Model and Functional Model Technical Document)

Comment Period: 8/3/2018 to 9/17/2018
The Reliability Functional Model (FM), Function Definitions and Function Entities, and Reliability Functional Model Technical Document (FMTD), have come up for review again. Cooper Compliance, on behalf of several of our clients, had proposed significant changes to provide clarification during the last round of edits. No changes were accepted based on the fact that the drafting team explained that the functional model is not tied to the registration process and is only used as guidance for the development of Standards.We feel this complete disconnect should not be accepted given the functional model explains the activities of a registered entity. If the registration process is flawed and includes entities that don't perform the activities listed in the functional model, then the document has very little value and NERC should consider retiring it.

2018-02 Modifications to CIP-008 Cyber Security Incident Reporting (SAR)

Comment Period: 8/10/2018 to  9/10/2018

In Order No. 848 FERC has directed NERC to revise the Standard to require the reporting of Cyber Security Incidents that compromise, or attempt to compromise, a responsible entity’s Electronic Security Perimeter (ESP) or associated Electronic Access Control or Monitoring Systems (EACMs). Cooper Compliance agrees that reporting should be made as directed by NERC. However, it seems that this Standard should be merged with EOP-004, which requires redundant reporting.
 

2015-10 Single Points of Failure | TPL-001-5 and Implementation Plan

Comment Period: 7/30/2018 to 9/14/2018
Balloting dates: 9/5/18 to 9/14/18
The proposed standard project will benefit reliability by providing clear, unambiguous and results-based reliability standard requirements to address the assessment’s recommendations for modifying NERC Reliability Standard TPL-001-4 (Transmission System Planning Performance Requirements)
 

2016-02 Modifications to CIP Standards | CIP-002-6 and CIP-003-8

Join Ballot Pool: 8/23/18 to 9/21/18
Balloting dates: 9/28/18 to 10/9/18
Comment Period: 8/23/2018 to 10/9/2018
This will modify the CIP family of standards (or develop an equally efficient and effective alternative) to address issues identified by the CIP V5 TAG, address FERC directives contained in Order 822; and address requests for interpretations as directed by the NERC Standards.
 

2015-09 Establish and Communicate System Operating Limits

Balloting dates: 10/1/2018 to 10/10/2018
Comment Period: 8/24/2018 to 10/10/2018
The project will revise the requirements for determining and communicating SOLs and IROLs to address the issues identified in Project 2015-03 Periodic Review of System Operating Limit Standards.
 

New RSAWs

Click the Microsoft Word icon below to be taken to the RSAW on NERC’s website.
 
d8756b7a-f702-4bc9-a2fa-863f50bd2f32.jpg  BAL-002-2(i) Disturbance Control Performance - Contingency Reserve for Recovery from a Balancing Contingency Event 8/22/2018
d8756b7a-f702-4bc9-a2fa-863f50bd2f32.jpg  BAL-005-1 Balancing Authority Control 8/22/2018
d8756b7a-f702-4bc9-a2fa-863f50bd2f32.jpg  FAC-001-3 Facility Interconnection Requirements 8/21/2018
d8756b7a-f702-4bc9-a2fa-863f50bd2f32.jpg  PRC-025-2 Generator Relay Loadability 8/21/2018
 

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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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Newsletter Archive






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 here to watch the 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.