PER Update_Compliance LLs_IEEEWGOT 12_9

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Transcript PER Update_Compliance LLs_IEEEWGOT 12_9

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IEEE/WGOT December 9-10, 2014, Orlando FL

PER Update &

Compliance Lessons Learned

IEEE Working Group on Operator Training December 9-10, 2014, Orlando, FL Margaret Stambach

SERC Reliability Corporation Training Programs Manager

IEEE/WGOT December 9-10, 2014, Orlando FL

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Learning Objectives

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At the conclusion of this tutorial, you should be able to:

Identify the NERC standard from the PER family that was historically among the top 10 most violated.

State the PER training standard currently in effect, when it became fully enforceable and when it will be fully retired.

List the major differences between the currently enforceable training standard and the new emerging standard.

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IEEE/WGOT December 9-10, 2014, Orlando FL

Topics

• • • • Audit Violations – “Then” and “Now” Training Standards History • PER-002-0 vs. PER-005-1 vs. PER-005-2 PER Family of Standards • Enforcement & Inactive Dates PER-005-1compared to emerging PER-005-2

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IEEE/WGOT December 9-10, 2014, Orlando FL

Audit Violations – “THEN” (2009)

TOP 10 Most Violated Standards PRC CIP CIP VAR FAC TOP FAC PER FAC EOP

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IEEE/WGOT December 9-10, 2014, Orlando FL

PER Violations – 2010 CAR

• • In 2010, PER-002 Training Standard was ranked as one of the

Top 10 Most Violated Standards.

PER-002 CAR publicly provided information and guidance to facilitate compliance.

IEEE/WGOT December 9-10, 2014, Orlando FL

PER 002: “ Operating Personnel Training ”

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PER-002 FULLY RETIRED 3/31/2013 PER-005-1 R1 & R2 Enforceable 4/1/2013

Number of Violations IEEE/WGOT December 9-10, 2014, Orlando FL

PER-002 Violations - 2010

91 Total PER-002 Violations 52 Program Deficiency Violations!

R2 R3 R4 R1

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Audit Violations – “NOW” (2014)

TOP 10 Most Violated Standards Key Compliance Enforcement Metrics and Trends Compliance Committee Open Session August 13, 2014 7 CIP 1 PRC 1 VAR 1 FAC

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PER-005-1 did not make the list!!!

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We’ve Come a Long Way – Baby!

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PER-005-1 Implementation

All 3 Rqmts now enforceable!

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Other PER Standards Now Enforceable

ENF. DATE To implement ALL actions necessary.

Assure all real-time operators are certified RC entity must be staffed with trained, certified personnel with wide-area view NO inactive date NO inactive date NO inactive date Systematic approach, task verification, EOPs training with sim www.nerc.com/Program Areas & Departments/Standards/US Enforcement Dates INACTIVE 6-30-2016

IEEE/WGOT December 9-10, 2014, Orlando FL

And How Are We Doing With PER?

NERC Searchable NOP Spreadsheet Searchable Enforcement Page 11-25-14

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www.nerc.com/Program Areas & Departments/Compliance & Enforcement/Enforcement & Mitigation

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IEEE/WGOT December 9-10, 2014, Orlando FL

• • • •

NOP Search Results for PER

June 2008-November 2014

PER-005-1 (System Personnel Training)

• • 2 violations: R1. 1.1, 1.2, R2. (List of RR Tasks, Task Updates, Design & Development of Program, Verification) Previous version: PER-002 had many – in top 10 most violated.

PER-004-2 (RC Staffing)

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*** Higher Fines!!

None for current version.

5 violations of previous version (V1), relating to lack of credentials & wide-area understanding.

PER-003-1 (Operating Personnel Credentials) *** Higher Fines!!

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None for current version.

Many for the Version 0.

PER-001-0.2 (Operating Personnel Resp/Auth)

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None for current version

. 5 violations of previous version (V0)

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Transition to PER-005-2

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FERC Order Approving PER-005-2

IEEE/WGOT December 9-10, 2014, Orlando FL

PER Inactive Date – Version 1 PER Enforcement Date – Version 2

6/30/2016 PER-005-2 16

All PER-005-1 Requirements Become Inactive 6-30-2016 Per-005-2 Becomes Enforceable 7-1-2016

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IEEE/WGOT December 9-10, 2014, Orlando FL

PER-005 1, “

System Personnel Training”

Purpose/Applicability

Purpose: To ensure that System Operators performing real-time, reliability-related tasks on the North American Bulk Electric System (BES) are competent to perform those reliability related tasks.

Reliability Coordinator

RC TOP

Reliability related tasks on the BES

BA

Transmission Operator Balancing Authority

IEEE/WGOT December 9-10, 2014, Orlando FL

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PER-005 2, “

Operations Personnel Training”

Purpose/Applicability

Purpose: To ensure that personnel performing or supporting Real-time operations on the Bulk Electric System (BES) are trained “Certain” using a systematic approach.

GOP

Reliability Coordinator

ENFORCEMENT 7/1/2016

Generator Operator

“Certain” TO

Reliability related tasks on the BES Transmission Owner Balancing Authority Transmission Operator

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IEEE/WGOT December 9-10, 2014, Orlando FL

PER-005-2 (Enforceable 7-1-2016 )

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Expansion of “Applicable Entities”

Recognizes that personnel OTHER than System Operators need formal Systematic Approach to Training (SAT) if they perform RR tasks!

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“Other” Personnel - TO

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Expanded list of “Applicable Entities”

• RC, BA, TOP (as before), but added 4.1.4

Transmission Owner

that has: 4.1.4.1 Personnel, excluding field switching personnel, who can act independently to operate or direct the operation of the Transmission Owner’s Bulk Electric System transmission Facilities in Real-time.

Addresses FERC Directive about “Local Transmission Control Center (LTCC)” Personnel. Under direction of TOP, but exercise control over a significant portion of the BES. Example?

IEEE/WGOT December 9-10, 2014, Orlando FL

“Other” Personnel - GOP

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Expanded list of “Applicable Entities”

• RC, BA, TOP (as before), but added: 4.1.5

Generator Operator

that has: 4.1.5.1 Dispatch personnel at a centrally located dispatch center who receive direction from the Generator Operator’s Reliability Coordinator, Balancing Authority, Transmission Operator, or Transmission Owner, and may develop specific dispatch instructions for plant operators under their control.

These personnel do not include plant operators located at a generator plant site or personnel at a centrally located dispatch center who relay dispatch instructions without making any modifications.

Addresses FERC directive about including “generator operators”. NOT plant operators of individual units!

Example: BA directs GOP to deliver 300 MW to grid and GOP’s central dispatch determines best way to deliver from its portfolio of units . . .the key is – does GOP have decision-making duties?

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IEEE/WGOT December 9-10, 2014, Orlando FL

New NERC Glossary Definition: Operations Support Personnel

Individuals who perform current day or next day outage coordination or assessments, or who determine SOLs, IROLs, or operating nomograms, in direct support of Real-time operations of the Bulk Electric System.

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IEEE/WGOT December 9-10, 2014, Orlando FL

Revised NERC Glossary Definition: System Operator

An Individual at a Control Center of a Balancing Authority, Transmission Operator, or Reliability Coordinator, who operates or directs the operation of the Bulk Electric System (BES) in Real-time.

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Comparison Highlights

PER-005-1 PER-005-2

3 Requirements • R1: SAT for RC, BA, TOP • R2: Verify RR Tasks • R3: 32 hours emergency ops training per year – R3.1: Simulation technology for emergency training if entity meets IROL/SOL criteria 6 Requirements • R1: SAT for RC, BA, TOP • R2: SAT for applicable TOs • R3: Verify RR Tasks • R4: Simulation technology for emergency training if entity meets IROL/SOL criteria • R5: SAT for Operations Support Personnel • R6: SAT for applicable GOPs

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PER-005-2:

FERC Directives Addressed

• Includes Local Transmission Control Center Personnel (TO) – Order 742 • Includes applicable GOPs Order 693 • Includes outage coordination & assessment personnel and those who determine SOL/IROLs and operating nomograms. Order 693 • Considers an implementation plan for entities gaining IROL control/authority and thus becoming subject to R4. The implementation plan is that the entity has 12 months to comply with R4.

Order 742

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IEEE/WGOT December 9-10, 2014, Orlando FL PER-005-2:

32 EOPs Hours Eliminated

• To mandate a pre-set number of hours is inconsistent with a systematic approach to training (SAT). • The number of emergency training hours should be dictated by the RR tasks that need to be trained upon

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• The removal of 32 hours is also considered to qualify for paragraph 81 because it is redundant to SAT process.

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• • •

Summary

The original PER Training Standard, “Operating Personnel Training” (PER-002-0) was among the top 10 most violated standards.

• PER-005 1 has a much better compliance “track record” PER-005 1, “System Personnel Training” is currently in effect. Fully enforceable on April 1, 2014, will be retired June 30, 2016.

PER-005-2, the emerging standard, has broader applicability and more requirements than the currently enforceable standard. It also eliminates the 32 EOPs hours per year.

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Questions?

[email protected]

704-940-8226