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Impacts and Implementation: NERC Reliability Standards, Compliance Initiatives, and Regulatory
Barry LawsonAssociate Director, Power Delivery & Reliability
NRECA
Introduction• Provide an overview of the Reliability
Assurance Initiative (RAI)• Discuss Risk-Based Registration Project• Update on BES Definition Implementation• Provide an overview of various Reliability
Standards– Geomagnetic Disturbances– Operating Personnel Communications Protocols– CIP Standard
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NERC Reliability Assurance Initiative
3
Initiative - Purpose• Identify and implement changes that
enhance the effectiveness of the Electric Reliability Organization (ERO) compliance and enforcement program
• Functional and implemented by 2016• Support the ultimate goals of avoiding
cascading events and the resulting major loss of load.
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NERC Website - Postings• Frequently Asked Questions (FAQs)• Working definitions of internal controls
and their significance in risk-based compliance
• Information regarding workshops and other forums for discussing RAI
• Activities and milestones related to the RAI
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2014 - Progress on Auditors’ Manual • March - Training to Compliance
Auditors• April - Publish handbook on the NERC
website• August - Complete training for all
Compliance Auditors• September - All audit engagement use
and follow the handbook6
2014 - Progress on Auditors’ Manual • Advantages from Industry Perspective
– Common language to communicate with industry
– Standardized audit approach across the ERO Enterprise
– Transparent audit activities
7
2014 - Progress Pilots and Evaluation of Pilot Methods • January – Pilot evaluation criteria
finalized• April – ERO executive management
presented with recommend audit design• October – Finalize compliance audit
design approved for training and deployment in 2015
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2014 - Progress Pilots and Evaluation of Pilot Methods • Advantages from Industry Perspective
– Defined risk approach that supports two way discussion
– Evaluation criteria results in appropriately scoped audits based on an entities size and risk
– Control evaluation is clearly defined and understood
Regulatory Status of Revised BES Definition• Inconsistent use of longstanding BES
definition by Regional Entities• FERC effort started in 2010• Important definition for determining
mandatory standards applicability• Can help on TO/TOP/radial line issues• Not going to help on DP/LSE issues• Related to SCRC and deregistration
Regulatory Status of Revised BES Definition• Phase 1 BES definition approved by
FERC end of 2012• Starting July 1, 2014 self-determined
application of definition and exception requests can be submitted
• New compliance date of July 1, 2016
Phase 1 BES Definition• Core definition
– 100kV and above– No facilities used in local distribution
• Inclusions– Transformers: primary and at least one secondary
terminal above 100kV– Generators :20 and 75 MVA (all nameplate)– Blackstart resources: identified in TOP restoration plan– Dispersed power producing resources: when
aggregating to greater than 75 MVA– Reactive power devices: connected at 100kV or above
or through a BES transformer
Phase 1 BES Definition• Exclusions
– Radial systems: load only, 75 MVA or less generation, combo, normally open devices
– Retail generation: net capacity back to BES is 75 MVA or less
– Local networks: for networks 100kV to 300kV with no flow back to BES, 75 MVA or less generation, no Blackstart resources and no flowgates
– Reactive power devices: owned/operated by retail customer for its own use
• Exception process in NERC Rules of Procedure (ROP) Appendix 5C
Phase 2 BES Definition• Addressing FERC directives from order on
Phase 1 definition and other industry comments from Phase 1– Radial exclusion changes for BES generation– Less than 100 kV looping issue – 50 kV solution
and Local Network exclusion changes– Dispersed power producing resources and the
collector system
Phase 2 BES Definition• Phase 2 filed with FERC Dec. 2013• Likely order in March 2014• Same compliance dates??• Skip phase 1??• http://www.nerc.com/pa/Stand/Pages/Pr
oject2010-17_BES.aspx
Reliability Standards Update
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• May 16, 2013 - FERC issued Order 779 which directs NERC to submit Reliability Standards that address the impact of geomagnetic disturbances (GMD) on the reliable operation of the Bulk-Power System.– Stage 1 – Operating
Procedures– Stage 2 – Detailed
Assessments (Planning Studies)
Geomagnetic Disturbances
Phase 1: EOP-10• Final ballot approval - 91.95 %• Approved by NERC Board of Trustees -
November 7, 2013• Submitted to FERC - November 2013
as required by FERC Order 779• FERC - January 16 indicated intention
to approve the standard, subject to NOPR comments
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EOP-10: Applicability• Reliability Coordinators (RCs)• Transmission Operators (TOPs) with a
Transmission Operator Area that includes a power transformer with a high side wye-grounded winding with terminal voltage greater than 200KV.
Does not apply to:• Balancing Authorities (BAs)• Generator Operators (GOPs)
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EOP-010: 200 kV Threshold Rationale • For lines less than 200kV, impedance is
higher, lines are generally shorter, and lower voltage lines provide minimal contribution to GIC; hence, such lines are ignored in analysis.
• If 230 kV lines were ignored, significant GIC would be mistakenly excluded from analysis and could result in inaccurate var consumption calculations.
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EOP-10: Requirements• R1- Each Reliability Coordinator (RC) required to
develop, coordinate, maintain, and implement, as necessary, a GMD Operating Plan.
• R2 – Each RC is responsible for disseminating forecast and current space weather information.
• R3 – Each Transmission Operator (TOP) required to develop, maintain, and implement an Operating Procedure or Operating Process to mitigate the effects of GMD events.
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Phase 2: TPL-007 Draft• Applicability: PC,TP,TO and GO• Require a planning assessment of the system
for its ability to withstand a Benchmark GMD Event without causing a wide area blackout, voltage collapse, or large load loss.
• Need system models - DC (GIC calculation) and AC (power flow)– Transformer information - internal winding
resistance– Substation grounding information
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• Studies (proposed every 5 years) that may be necessary to perform a GMD assessment:– Transformer GIC Impact Calculations– Power Flow System Studies – calculate
reactive power loss– Impact of Harmonics on Protection and
Operating Personnel Communications Protocols• Seven year development history• COM-002-4: 8th posting continuation of
the previous draft which combined COM-002-3 and COM-003-1
– Addresses communications protocols for operating personnel in Emergency, alert, and non-emergency situations.
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Operating Personnel Communications Protocols• Applicability: BA, DP, RC, TO and GO• Defined Operating Instruction• Initial training for DP operating
personnel– Repeat, not necessarily verbatim, the Operating
Instruction and receive confirmation from the issuer that the response was correct, or
– Request that the issuer reissue the Operating Instruction
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COM-002-4: NRECA Perspective• NRECA recommended a “negative”
ballot• NRECA focused comments
– Approach to limit the burden on Distribution Providers by providing alternative applicability language to limit the impact to small distribution cooperatives.
– Modify the “assess adherence and assess effectiveness” language in R4.
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COM-004-2: Ballot Results and Timeline• Initial ballot approval - 71.86% • Expected approval by the NERC Board
of Trustees - May 2014• Expected submittal to FERC – Summer
2014
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NERC CIP StandardsCurrent State of Play• NERC CIP V3, V4 and V5 standards
– CIP V3 in effect now– CIP V4 can be skipped– CIP V5 approved by FERC Nov. 2013
• FERC directives– CIP V5.1 or V6
• Compliance/enforcement confusion with multiple versions of CIP in play
NERC CIP StandardsCurrent State of Play• FERC’s directives in final Rule
– Identify, assess and correct (IAC)– Low category requirements– Communication networks– Transient devices
• New standard drafting team formed• Deadline for addressing IAC and
communication networks Feb. 2015• Drafting team goal of Nov. 2014
CIP V3 and V5 Differences
• CIP V3– RBAM (CIP-002)– If no CAs, no further significant requirements– If CAs and CCAs, then many other standards
apply (CIP-003 thru 009)• CIP V5
– Complete overhaul of CIP standards– no RBAM– High, Medium and Low criteria and requirements
Cyber Security EO
• President issued Executive Order (EO) on February 12, 2013 addressing– Information sharing between Federal government
and private sector– Security clearances for critical infrastructure
owners/operators– Development of Cyber Security framework by