Compliance

NERC Update Summary February 2019

Global Audit-Ready Standards Updates

February 2019
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

  • Upcoming Industry Events

  • New or Revised NERC Standards

  • NERC Standards Under Development

  • Standards Becoming Effective

  • New RSAWs


Cooper Compliance News

NERCRequirements List Updated

In January, BAL-002-3 and VAR-001-5 RSAWs were added to the Cooper Compliance database. See the New RSAWs section.
The future enforceable standard PER-003-2 has been added,and retirement dates have been entered for PER-003-1 and PER-004-2 (which is being retired with no new version to replace it).

Global Audit-Ready Application Enhancements

Development at Cooper Compliance continues at a steady pace to give you more control and automation for managing your compliance program.
Approval Tracking System:Last month, as you may remember, we announced our new Global Audit-Ready app, the Approval Tracking System. This lets you track not only one-time data requests, but also cyclical required updates to documents such as policies and procedures. You can also use it to process reviews of RSAWs.  A reminder based tracking system cycles documents through the updating, reviewing, finalizing, and approving stages of document update, while obtaining electronic signatures throughout the process. You have the ability to add notes at each stage and assign different stakeholders to various tasks relating to the update.

Global Audit-Ready Survey tool:Feeling overwhelmed? Short of resources? Not enough time to keep up with all the activity going on around you and maintain compliance with the ever-growing regulations?

Cooper Compliance has you covered through automation!

This month, we are very excited to announce the new Global Audit-Ready Survey tool, which is an automated internal control system. This interactive survey tool allows you to query your SMEs to determine if certain activities occurred.  A positive response generates a task prompting them to take action and provide evidence related to a Requirement. It can also be used to simply collect information needed for regulatory reporting. All survey questions are listed by the subject matter expert in one form with one email reminder whenever the survey period opens up. A second email reminder is sent if the survey and associated tasks have not been completed within the designated time period.  Features include:

  • Drill down survey capability

  • Task creation to upload documents

  • Task creation to report a value or text

This powerful automated tool can assist with many compliance-related activities including the reporting of number of accidents, endangered species or other activities.

PSMP App:The PSMP app has been updated with some interface changes to make it easier to select multipl pieces of equipment. A new Notes window, for notes that will appear in Compliance Status Report and the finished RSAW, has been added. You can now add additional work order instructions for unresolved issues. Due dates for unresolved work orders are now displayed. The new PSMP app also includes other changes that allow for a smoother and more efficient user experience.

Industry News

It turns out that NERC penalties are real and can cost you a bundle:https://www.eenews.net/stories/1060119265

The California PUC recently implemented Cyber Security regulations, applicable to DPs in the state: http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M260/K335/260335905.PDF

Upcoming Industry Events

Here are a few industry events where you might see Cooper Compliance. Drop by our booth to see a demo of our great new product enhancements.

  • Solar Asset Management, March 26 - 27, San Francisco CA. More details.

  • WECC Spring Workshop, April 9 - 11, Garden Grove CA (near Anaheim). More details.

  • NPCC Spring Compliance & Standards Workshop, May 22 - May 23, Groton CT. Get tickets.

Retired Standards

No standards are being retired at this time.
PER-004-2 is scheduled to retire 6/30/2019 due to its requirements being redundant with other enforceable standards.

New or Revised Standards In the CCC Standards Database

PER-003-2, titled Operating Personnel Credentials, will replace PER-003-1 as of 7/1/2019.  The only substantive change is that a clarifying footnote is added to ensure that stakeholders (now and in the future) understand (i) the connection between the Standard and the Program Manual; and (ii) that the certifications referenced under PER-003-2 are those under the NERC System Operator Certification Program.. Also, boilerplate text common to all standards has been updated to reflect NERC's current template.
Effective Date: 7/1/2019
Applies to: RC, TOP, BA.

Standards Under Development

At this time, there are no upcoming Ballots, no ballot pools open for joining, and no standard changes posted for comment.

Standards Becoming Effective Soon

On 4/1/2019, the following standards become effective:
BAL-002-3
EOP-004-4
EOP-005-3
EOP-006-3
EOP-008-2
See future newsletters for what these changes mean for you.

New RSAWs

These RSAWs have been added to the NERC website and have also been added to the Global Audit-Ready software for Cooper Compliance clients.

BAL-002-3

VAR-001-5


Global Audit-Ready users will be provided these RSAWs to upload to your RSAW Documents library in a separate email.

NERC Update Summary September 2018

Global Audit-Ready Standards Updates

September 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

  • Retired Standards

  • New or Revised NERC Standards

  • NERC Standards Under Development

  • New NERC Guidance Documents

  • Recently Added RSAWs

Cooper Compliance News

NERC Requirements List Updated

Over the next few days, the Global Audit-Ready database of NERC and regional standards will be updated for Cooper Compliance clients to keep pace with changes released on the NERC website. Look for these changes if you have Global Audit-Ready applications:

  • Add standard of PER-006-1.

  • Added standard of PRC-027-1.

  • Added standard of BAL-002-3 and set retirement date of BAL -002-2, which it replaces.

  • Retired VAR-002-WECC-2.

  • Added RSAW for EOP-004-4.

  • Added RSAW for EOP-006-3.

Global Audit-Ready Application Enhancements

This month we have released enhancements to our workflow capabilities, our Editor tool which is used to set up new facilities or new Standards, and our Operator Instruction Log.

The Global Audit-Ready workflow capability just got better.
These changes affect workflows and  Global Audit-Ready Dashboard, Reporter, Editor, SME Responsibility Report, Document Loader.

  • When the due date is approaching for a compliance task that repeats over a predefined period, the workflow sends an email, creates an item in the SharePoint task list, and changes the status for the associated process. Once documentation is loaded that demonstrates completion of the task, the workflow will advance based on a predesignated cycle.  A new enhancement allows the user to specify if the start of the next workflow should advance based on a fixed (i.e. each quarter) or performance (i.e. 15 calendar months) cycle.  The enhancement also allows for the user to schedule a one-time occurrence task.

  • A task description field has been added to allow the user to provide specific instructions to the recipient of the task.

  • Multiple tasks can be assigned to one process.  Previously we only allowed for one task per process.  An example of where this feature might be used is MOD-032, where you may have multiple base case data submittals in one year, with some occurring at the same time.

  • The recipient of an outgoing email for a generated task can click on a link embedded within the email to upload a document to the system directly.

The Global Audit-Ready editor feature just got more efficient.
The Global Audit Ready Editor feature now allows the user to inherit attributes from an existing process.  This makes improves efficiencies when adding a new generator or facility.  With a click, the user can inherit a process from a similar generator and modify the properties such as assigning it to a different subject matter expert.  

The Operator Instruction Log just made logging more efficient and incorporates key indicators for SAIDI and SAIFI.  

  • An Open Logs report allows the operator to click on a link from the report to improve logging efficiency.

  • SAIDI (System Average Interruption Duration Index) and SAIFI (System Average Interruption Frequency Index) values are calculated when logging a distribution or transmission outage.

Industry Events

North American Generator Forum Annual Meeting
Cooper Compliance attended the North American Generator Forum (NAGF) annual meeting held at the NERC headquarters in Atlanta. NAGF was founded in 2009 and has grown to the point that there was standing room only. Presenters from highly knowledgeable industry experts, regions and NERC were extremely informative and valuable. NAGF offers an opportunity for generators to come together to influence and shape the development of regulations, and to share valuable technical information and techniques for meeting your compliance program.  If you are not yet a member of this forum and you are a generator we highly recommend you join NAGF. Request to join NAGF by filling out this information form.

WECC Reliability and Security Workshop
The WECC Reliability and Security Workshop (formerly "Compliance Workshop") is in San Diego from October 22 to 25.  Please come to the Cooper Compliance booth to view our latest products.  We will post our notes at
https://www.coopercompliance.com/download/
Sign up for the conference here.

 
NPCC Fall Compliance & Standards Workshop
The 2018 NPCC Fall Compliance & Standards Workshop is in Providence Rhode Island November 7 - 8. Cooper Compliance will be there!  Sign up here.
 

Retired Standards

For the WECC region, VAR-002-WECC-2 has been retired, as of September 5, 2018. NERC and WECC stated that VAR-002-WECC-2 is no longer necessary because reliability issues addressed in the regional Reliability Standard are adequately addressed by the continent-wide Voltage and Reactive (VAR) Reliability Standards and the retention of the regional Reliability Standard would not provide additional benefits for reliability.
 

New or Revised Standards

BAL-004-WECC-02 was replaced by BAL-004-WECC-3. Titled, “Automatic Time Error
Correction,” BAL-004-WECC-02 became inactive on September 30, and BAL-004-WECC-3 became effective on Oct 1.

PER-006-1, titled “Specific Training for Personnel,” has been approved for future enforcement. The purpose is to ensure that personnel are trained on specific topics essential to reliability to perform or support Real-time operations of the Bulk Electric System. This change replaces the current Standard PRC-001 R1 that requires that the generator operator is familiar with protection systems and their limitations. 
Effective Date: 10/1/2020
Applies to: GOP
 
PRC-027-1, titled “Coordination of Protection Systems for Performance During Faults,” has been approved for future enforcement. The purpose is to maintain the coordination of Protection Systems installed to detect and isolate Faults on Bulk Electric System (BES) Elements, such that those Protection Systems operate in the intended sequence during Faults.
Effective Date: 10/1/2020
Applies to: TO GO DP
 
BAL-002-3 will replace BAL -002-2. Titled “Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event,” this standard’s purpose is to ensure the Balancing Authority or Reserve Sharing Group balances resources and demand and returns the Balancing Authority's or Reserve Sharing Group's Area Control Error to defined values (subject to applicable limits) following a Reportable Balancing Contingency Event.
Effective Date: 10/1/2020
Applies to: BA and RSG
 

Standards Under Development

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

Balloting dates: 9/28/18 to 10/9/18
Comment Period:: 8/23/2018 to 10/9/2018
The SDT 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: 10/8/2018  to  10/17/2018
Comment Period: 8/24/2018  to 10/17/2018
Facilities Design, Connections, and Maintenance (FAC) standards fulfill an important reliability objective for determining and communicating System Operating Limits (SOLs) used in the reliable planning and operation of the Bulk Electric System (BES). This project will revise requirements for determining and communicating these SOLs. Revisions are necessary to improve the requirements by eliminating overlap with approved Transmission Planning (TPL) requirements, enhancing consistency with Transmission Operations (TOP) and Interconnection Reliability Operations (IRO) standards, and addressing issues with determining and communicating SOLs and Interconnection Reliability Operating Limits (IROLs).
 

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

Comment Period: passed
Initial Ballot and Non-Binding Poll: 10/18/2018 to 10/22/2018
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 Electric 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.

 2018-01 Canadian-specific Revisions to TPL-007-2
Join Ballot Pool: 10/2/2018 to 10/31/2018
Comment Period: 10/2/2018 to 11/15/2018
Initial Ballot:   11/6/2018 to 11/15/2018
The purpose of this project is to enable the option for Canadian Registered Entities to leverage operating experience, observed GMD effects, and on-going research efforts for defining alternative Benchmark GMD Events and/or Supplemental GMD Events that appropriately reflect their specific geographical and geological characteristics. This project also addresses regulatory frameworks specific to Canadian jurisdictions.
 

NERC Guidance Documents

The NERC Planning Committee has released three new helpful guidance documents for those who need to verify and model inverter-based resources.
 
BPS-Connected Inverter-Based Resource Performance guideline provides recommendations for steady-state and dynamic performance characteristics for modeling inverter-based resources.

Methods for Establishing IROLs guideline provides recommendations for conducting analysis of instability, system instability, uncontrolled separation, and cascading for determining Interconnection Reliability Operating Limits (IROLs).

Power Plant Model Verification for Inverter-based Resources guideline provides clarity on validating MOD-025 for Inverter Based generators and the use of performance data as well as additional information needed for proper modeling.  It provides clarification on the difference of data provided under MOD-025, MOD-025, MOD-027 versus MOD-032 and MOD-033.  It provides recommendations on different methods for obtaining modeling data through testing and data validation.

New RSAWs

These RSAWs have been added to the NERC website and have also been added to the Global Audit-Ready software for Cooper Compliance clients.

EOP-004-4

EOP-006-3