PER Update_Compliance LLs_IEEEWGOT 12_9

Report
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
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IEEE/WGOT
December 9-10, 2014, Orlando FL
Learning Objectives
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
VAR
CIP
CIP
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FAC PER
FAC
FAC TOP
EOP
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.
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IEEE/WGOT
December 9-10, 2014, Orlando FL
PER-002: “Operating Personnel Training”
PER-002 FULLY RETIRED 3/31/2013
PER-005-1 R1 & R2 Enforceable 4/1/2013
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IEEE/WGOT
December 9-10, 2014, Orlando FL
PER-002 Violations - 2010
Number of
Violations
91 Total PER-002 Violations
52 Program
Deficiency Violations!
R2
R3
7
R4
R1
IEEE/WGOT
December 9-10, 2014, Orlando FL
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
PER-005-1 did not
make the list!!!
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IEEE/WGOT
December 9-10, 2014, Orlando FL
We’ve Come a Long Way – Baby!
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IEEE/WGOT
December 9-10, 2014, Orlando FL
PER-005-1 Implementation
All 3 Rqmts now
enforceable!
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IEEE/WGOT
December 9-10, 2014, Orlando FL
Other PER Standards Now Enforceable
ENF. DATE
To implement ALL
actions necessary.
NO inactive date
Assure all real-time
operators are certified
NO inactive date
RC entity must be
staffed with trained,
certified personnel with
wide-area view
NO inactive date
Systematic approach,
task verification, EOPs
training with sim
INACTIVE 6-30-2016
www.nerc.com/Program Areas & Departments/Standards/US Enforcement Dates
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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
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) *** 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!!
•
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)
IEEE/WGOT
December 9-10, 2014, Orlando FL
Transition to PER-005-2
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IEEE/WGOT
December 9-10, 2014, Orlando FL
FERC Order Approving PER-005-2
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IEEE/WGOT
December 9-10, 2014, Orlando FL
PER Inactive Date – Version 1
PER Enforcement Date – Version 2
6/30/2016
PER-005-2
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 reliabilityrelated tasks.
TOP
Transmission
Operator
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Reliability
Coordinator
Reliabilityrelated
tasks on
the BES
RC
BA
Balancing
Authority
IEEE/WGOT
December 9-10, 2014, Orlando FL
PER-005-2, “Operations Personnel Training”
Purpose/Applicability
Purpose:
To ensure that personnel performing or
supporting Real-time operations on the
“Certain”
Bulk Electric System (BES) are trained
GOP
using a systematic approach.
Generator
Operator
“Certain”
Reliability
Coordinator
Reliabilityrelated
tasks on
the BES
Balancing
Authority
TO
ENFORCEMENT
7/1/2016
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Transmission
Owner
Transmission
Operator
IEEE/WGOT
December 9-10, 2014, Orlando FL
PER-005-2
(Enforceable 7-1-2016)
• 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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IEEE/WGOT
December 9-10, 2014, Orlando FL
“Other” Personnel - TO
• 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?
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IEEE/WGOT
December 9-10, 2014, Orlando FL
“Other” Personnel - GOP
• 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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IEEE/WGOT
December 9-10, 2014, Orlando FL
Comparison Highlights
PER-005-1
3 Requirements
6 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
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PER-005-2
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
IEEE/WGOT
December 9-10, 2014, Orlando FL
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.
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Order 742
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.
• The removal of 32 hours is also considered to
qualify for paragraph 81 because it is
redundant to SAT process.
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IEEE/WGOT
December 9-10, 2014, Orlando FL
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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IEEE/WGOT
December 9-10, 2014, Orlando FL
Questions?
mstambach@serc1.org
704-940-8226
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