EOP-008

Global Audit-Ready Standards Updates

Global Audit-Ready Standards Updates

March 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

  • Global Audit-Ready Enhancements

  • Upcoming Industry Events

  • Retiring Standards

  • New or Revised NERC Standards

  • NERC Standards Under Development

  • Standards That Recently Became Effective

  • New RSAWs

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Cooper Compliance News

NERCRequirements List Updated

Summary of changes (more details below0
Added: PER-003-2, TPL-007-3
Retiring: IRO-006-TRE-1, PER-004-2, PRC-004-WECC-2
Changed Effective Dates: PRC-002-2

Several revised standards have recently become effective. See Standards That Recently Became Effective below for more details.

 

Global Audit-Ready Application Enhancements

Global Audit-Ready Approval Tracking System: The Global Audit-Ready Approval Tracking System 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 Authorization Requests for access to BES Cyber Assets or Information, BES Cyber Asset software upgrades, or 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: The new Global Audit-Ready Survey tool 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. An escalation email reminder is sent if the survey and associated tasks have not been completed within the designated time period. This powerful automated tool can assist with many compliance-related activities including the reporting of number of accidents, endangered species or other activities. This month, we added additional information to the Survey Answer list. We also added the ability to assign Survey-initiated tasks to other people

Global Audit-Ready Compliance Status Report: The next due dates appear under the processes.

Global Audit-Ready Dashboard: There is now a button to open a one page summary.

Global Audit-Ready Operating Instruction Log:

  • Add logos to OIL emails

  • Add ability to search descriptions in Open Logs

  • Add ability to specify scheduled date in logs

Global Audit-Ready PSMP Application Release Notes:

  • Update of maintenance log interface

    • Change equipment selection to checkbox to make it easier to select multiple pieces of equipment

    • Selecting new equipment will not clear out data entered for previously selected equipment.

    • New document Note window; enter notes that will appear in the Compliance Status Report and the completed RSAW

    • Equipment Selection box is now resizable

    • Lets users add additional work order instructions if unresolved issue box is checked

  • Improved robustness and error checking

    • Fixed a problem where clients change the library name after it’s created)

    • Disallows attachments that have # in the title to maintain SharePoint compatibility.

    • Prevents a security error if the user takes more than 30 minutes to submit a log

    • If there are no checked instructions, gives a warning and does not update the equipment list dates

  • Updated how unresolved work orders are handled

    • Lets users close all open unresolved work orders for a piece of equipment if all the instructions for that instruction is checked

    • Adds support to create a unique unresolved work order for each equipment

    • No longer automatically creates a new unresolved work order if there is already an active unresolved work order.   There is now a confirmation window to let a user create a new work order if there is already an open one.

    • Lets the user update multiple unresolved work orders on the same equipment. 

    • Due dates for the unresolved work orders are displayed in unresolved work order selection window

  • Updated data fields

    • Added EquipmentType to EquipmentLog list

    • In EquipmentLog list, MaintenanceComplete is "Yes" only if there was no unresolved issue

Upcoming Industry Events

Here are a few upcoming industry events. See Erica and Mary Jo from Cooper Compliance TOMORROW at WECC. Drop by our booth to see a demo of our great new product enhancements.

  • Tomorrow! 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

IRO-006-TRE-1: RC  (IROL and SOL Mitigation in the ERCOT Region)
For the Texas Reliability Entity region, per FERC order RD19-2-000, IRO-006-TRE-1 is retired on 1/29/2019. NERC contends "continent-wide Reliability Standards have been approved that cover the same reliability goals as the requirements in regional Reliability Standard IRO-006-TRE-1, rendering the regional Reliability Standard redundant."

PER-004-2:  RC  (Reliability Coordination — Staffing)
On November 21, 2018 in FERC order RD18-9-000 FERC approved retirement of PER-004-2. The order states,  "With respect to the proposed retirement of Reliability Standard PER-004-2, NERC states that Reliability Standard PER-004-2 contains two requirements that are redundant with other Commission‐approved Reliability Standards." It becomes retired the day before PER-003-2 becomes effective 6/30/2019.

PRC-004-WECC-2  TO, GO, TOP  (Protection System and Remedial Action Scheme Misoperation)  
This regional Reliability Standard is becoming redundant with other approved standards and no longer necessary for reliability. In particular, Reliability Standard PRC-012-2 (Remedial Action Schemes), approved by the Commission in Order No. 837, contains requirements for remedial action scheme analysis. Reliability Standard PRC-012-2 will become effective in the United States on January 1, 2021. According to NERC and WECC, PRC-004-WECC-2  may therefore be retired at that time with no adverse effect on reliability. According to FERC order RD18-3-000 on March 28,2019,  regional Reliability Standard PRC-004-WECC-2  has a retirement effective date of January 1, 2021
 

New or Revised Standards In the CCC Standards Database

PER-003-2 (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.

TPL-007-3  (Transmission System Planned Performance for Geomagnetic Disturbance )
Was added to Cooper Compliance NERC database. It is the same as TPL-007-2 except -3 adds a Canadian Variance. Thus TPL-007-2 never becomes effective but is superceded by the revised TPL-007-3, with all phased-in compliance dates carried forward unchanged.
Effective Date: Earliest is 7/1/19, with varying effective dates for specific requirements thereafter.
Applies to: PC, TP, TO, GO

PRC-002-2: (Disturbance Monitoring and Reporting Requirements)
For R2, R3, R4, R6, R7, R8, R9, R10, R11 , changed Effective Date from 7/1/2022 to 7/1/2020. This is because according to the NERC Implementation Plan, 50% compliance is required at 7/1/2020 and 100% compliance is required at the stated NERC effective date of 7/1/2022.
Applies to: PC, RC, TO, GO
 

Standards Under Development

2018-03 Standards Efficiency Review Retirements Project Scope
The Standard Authorization Request (SAR) drafting team evaluated NERC Reliability Standards using a risk-based approach to identify potential efficiencies through retirement or modification of Reliability Standard Requirements. Many Reliability Standards have been mandatory and enforceable for 10+ years in North America. The SAR drafting team identified potential candidate requirements that are not essential for reliability, could be simplified or consolidated, and could thereby reduce regulatory obligations and/or compliance burden.Initial Ballots and Non-binding Pollsstart: 4/3/2019end: 4/12/2019 Comment Period                            start 2/27/2019end: 4/12/2019

2019-02 BES Cyber System Information Access Management

Background
This project enhances BES reliability by creating increased choice, greater flexibility, higher availability, and reduced-cost options for entities to manage their BES Cyber System Information, by providing a secure path towards utilization of modern third-party data storage and analysis systems. In addition, the proposed project would clarify the protections expected when utilizing third-party solutions (aka cloud), such as Microsoft 365.

Standard(s) Affected – CIP-004-6 - Cyber Security - Personnel & Training | CIP-011-2 - Cyber Security - Information Protection

Comment Period start: 3/28/20194/26/2019

Standards That Recently Became Effective

On 4/1/2019 (No Joke!), the following standards become effective, replacing their previous versions:
BAL-002-3 BA RSG Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event
EOP-004-4 BA DP GO GOP RC TO TOP Event Reporting
EOP-005-3  DP TO TOP GOP System Restoration from Blackstart Resources
EOP-006-3  RC  System Restoration Coordination
EOP-008-2  BA RC TOP Loss of Control Center Functionality

BAL-002-3  Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event
R1.3.1  expanded and clarified under what situations the Responsible Entity experiencing a Reportable Balancing Contingency Event shall deploy Contingency Reserve. It now includes Responsible Entities that have, during communications with its Reliability Coordinator in accordance with the Energy Emergency Alert procedures, (i) notified the Reliability Coordinator of the conditions described in the preceding two bullet points preventing the Responsible Entity from complying with Requirement R1 part 1.1, and (ii) provided the Reliability Coordinator with an ACE recovery plan, including target recovery time.
Applies to: BA RSG


EOP-004-4  Event Reporting
For R2, entities shall report events by the later of 24 hours of recognition of meeting an event type threshold for reporting or by the end of the Responsible Entity’s next business day (4 p.m. local time will be considered the end of the business day). Previously, events had to be reported within 24 hours of recognition or by end of next business day if event occurred on a weekend.
Also, R3, which existed in EOP-004-3, no longer exists in EOP-004-4. R3 was this: "Each Responsible Entity shall validate all contact information contained in the Operating Plan pursuant to Requirement R1 each calendar year." Cooper Compliance feels this exercise is a good one to continue.  For our clients we simply move the validation process to R1, as an internal control.
Applies to: BA DP GO GOP RC TO TOP

EOP-005-3   System Restoration from Blackstart Resources
EOP-005-3 has extensive revisions, including updated restoration plan guidelines, testing requirements, documentation requirements, and training requirement for restoration.
Applies to: TOP, GOP, TO, DP

EOP-006-3    System Restoration Coordination
Clarifies re-establishing interconnections during restoration.
In the new standard, if conflicts between restoration plans are found, the RC must notify neighboring RCs of such conflicts in 60 days. The new standard mandates System restoration drills/simulations per year. The requirement for the RC to coordinate resynchronizing islanded areas has been dropped.
Applies to: RC

EOP-008-2   Loss of Control Center Functionality
Data Communications has been changed to Data exchange capabilities for R1.2.2.
Voice communciation has been changed to Interpersonal Communications for R1.2.3
Applies to: BA RC TOP
 

New RSAWs

No new RSAWs have been released recently.

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