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.

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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