2013 SPP RE Annual CMEP Implementation Plan

Transcription

1 2013 SPP RE Annual CMEP Implementation Plan December 3, 2012 Jeff Rooker, Lead Compliance Engineer Leesa Oakes, Compliance Specialist II

2 Outline CMEP General 2013 NERC High Priorities Key Points from 2013 Compliance Monitoring and Enforcement Program (CMEP) - Compliance Assessments after Events/Disturbances - Audit Scope determination - CIP Requirements Tier Changes AML Changes - Audit Schedules - Reporting Periods 2

3 What is the CMEP? The NERC CMEP Annual Implementation Plan is the annual operating plan for compliance monitoring and enforcement activities to ensure NERC and the Regional Entities fulfill their responsibilities under U.S. legislation 3

4 SPP RE 2013 CMEP Implementation Plan SPP.org->Regional Entity->Compliance 2013 will be the 6 th year of the SPP RE program Some entities have yet to be audited Less than 10% have not been audited for % have not been audited for CIP 4

5 Plan s Principles and Objectives Promote BPS reliability through rigorous compliance monitoring and enforcement activities Facilitate improved consistency of compliance activities throughout North America Monitor all regulatory authority-approved Reliability Standards by using eight CMEP compliance monitoring methods Use risk-based and performance-based criteria for determining the scope for compliance audits Allow flexibility for ERO and REs to investigate trends that may pose a near term reliability risk either across North American BPS, across an Interconnection, or within an RE boundary Improve compliance program by analyzing the compliance monitoring experience across North America and implementing necessary improvements 5

6 2013 High Priorities 1. Misoperations of relay protection and control systems 2. Human errors by field personnel 3. Ambiguous or incomplete voice communications 4. Right-of-way maintenance 5. Changing resource mix 6. Integration of new technologies 7. Preparedness for high-impact, low-frequency events 8. Non-traditional threats via cyber-security vulnerabilities 6

7 MISOPERATIONS HIGH PRIORITY 7

8 Misoperations Overall Status NERC Q REs Providing Data 8 Misoperations 250 Unnecessary Trip 89% (224) Slow or Failure to Trip 2% (5) SPP RE Q Misoperations 46 Unnecessary Trip 93% (43) Slow or Failure to Trip 6% (3) Top cause Incorrect setting/design error Tracking Aggregated at NERC and RE level See 2012 Fall Workshop Misoperations Update (item 4) 8

9 SPP RE Misoperation Counts Q Q Q ? Q ? 2010 SPP definition/regional voluntary reporting 2011 National definition/mandatory reporting 2012 Success Rate- Q % Q % 9

10 SPP RE Region by Cause and Quarter AC system As-left personnel error Communication failures DC system Incorrect setting/logic/design errors Relay failures/malfunctions 0 Q1-11 Q2-11 Q3-11 Q4-11 Q1-12 Q

11 Misoperation Submittals Starting with Q data there will be an updated NERC Misoperation spreadsheet NERC will start collecting total number of relay operations - no change for SPP RE Starting in the Q SPP RE & other REs using WebCDMS will start using new module to submit Misoperations Misoperations Reporting in webcdms webinar, January 8, 10:00-10:45 CST 11

12 RIGHT OF WAY MAINTENANCE 12

13 Grow-in Outages 13 RELIABILITY ACCOUNTABILITY

14 Facility Ratings Alert Background See 2012 Fall Workshop Facility Ratings Alert (item 6) NERC issued Facilities Ratings Alert in 4Q 2010 Entities asked to assess physical attributes of transmission lines and compare as-built to design ratings Facilities ranked: High, Medium, Low Entities began assessments and remediation efforts in 2011 Assessments staged over 3 years (2011 to 2013) 14

15 Current Status High Priority Lines All 8 SPP entities with High Priority Lines have completed assessments Remediation underway Over 5,000 miles assessed using Lidar, Aerial Patrol and/or Field Inspections 400+ discrepancies found including: Transmission and/or distribution under-build Conductor to conductor clearances Uneven terrain Entities have one year to complete discrepancy remediation 15

16 Current Status Medium Priority First half 2012 reports submitted mid-july: 7 entities reported inspections/assessments ~ 3,800 miles inspected ~ 1,800 miles assessments complete ~ 30 discrepancies All assessments and remediation can be reported Things to watch for keeping on schedule: Availability of ROW contractors Outage scheduling and conflicts 16

17 100% 90% Discrepancy Breakdown by Region 80% 70% 60% 50% 40% 30% 20% 10% 0% FRCC MRO NPCC RFC SERC SPP TRE WECC Clearance to Underbuild Conductor-Conductor Clearance Ground / Structure Clearance Other Transmission Crossing Underbuild Uneven Terrain Various Discrepancies Types 17

18 What to expect in 2013 regarding FAC alert Low priority line assessment begins Reports due: Completion of medium priority lines NERC FAC page 18

19 NON-TRADITIONAL THREATS HIGH PRIORITY 19

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22 KEY POINTS FROM 2013 CMEP 22

23 Key Points from 2013 Plan Entities will not be expected to provide evidence outside of current audit period unless it is required to confirm compliance in accordance with entity s processes/procedures Audit scope will continue to include review of all mitigation plans that are open during audit period Electronic signatures by officer, employee, attorney or other representative are permitted in accordance with NERC/entity processes 23

24 Key Points from 2013 Plan Compliance Assessments after Events/Disturbances Audit Scope determination CIP Requirements Tier Changes 2013 AML Changes Audit Schedules Reporting Periods 24

25 Compliance Assessments after Events or Disturbances Registered entities are encouraged to conduct formal compliance assessments of Category 2 events and disturbances and submit a report to the RE for review. Appendix 5 of the NERC CMEP Implementation Plan (page 63) is a Compliance Assessment Template designed to help registered entities with their compliance assessments. 25

26 Risk Based Audit Approach Entity s Risk Based Assessment Attributes: 1. Entity s Technical and Risk Profile Size, # of interconnects 2. Reliability performance metrics Events, misoperations, vegetation contacts 3. Compliance and Enforcement metrics and status Violation history, TFEs 4. Regional Entity qualitative assessment What entity does well and areas of improvement 26

27 Audit Scope Expansion Entity s Risk Based Assessment will determine initial scope that will be included in initial notice Audit team may increase scope during audit activities based on: Audit team s professional judgment Discovery of non-compliance or problematic compliance history Will notify entity of increased scope as soon as possible 27

28 Risk Based Monitoring Standards/Requirements are assigned one of three Tiers in NERC s 2013 Actively Monitored List Tier 1 High-risk priorities performance based Example: PRC-005 R2 - shall provide documentation of its Protection System maintenance and testing program and implementation of that program to its RRO Tier 2 Lower-risk than Tier 1 many are documentationrelated Example PRC-005 R1 - shall have a Protection System maintenance and testing program for Protection Systems that affect the reliability of the BES. Tier 3 Lowest risk many are administrative EOP R5 shall annually review and update each emergency plan. 28

29 2013 AML Spreadsheet Requirements Detail tab contains every requirement. Effective and inactive dates are listed in red if occurring in Download sortable 2013 AML spreadsheet 29

30 2013 AML Spreadsheet Summary tab contains all standards and indicates which are subject to annual self-certification and which are assigned to Tier 1 30

31 2013 AML Spreadsheet 31

32 Risk-Based Monitoring 2013 AML very similar to 2012 Per SPP RE 2013 Audit Scope Plan All entities audited for first time for 693 Tier 1 and Tier 2 PRC-004-2a R1-R3-Misoperations PRC R1-R2-UFLS PRC R1-R2 SPS (if applicable) All other audits-693 Tier 1 plus standards/requirements above Plus any standards/requirements added from entity s risk assessment and review of open enforcement actions 32

33 Risk-Based Monitoring - CIP All entities audited for first time for CIP Tier 1 and Tier 2 Terminated TFEs All other CIP audits Tier 1 Terminated TFEs Plus any standards/requirements added from entity s risk assessment and review of open enforcement actions 33

34 Risk Profile Does Not Limit an Audit Registered entities are responsible for compliance with all regulatory approved Reliability Standards and Requirements in effect per their registered function at all times, regardless of what a registered entity s risk profile may indicate. 34 RELIABILITY ACCOUNTABILITY

35 CIP Tier Changes Tier assignments were reassigned so each CIP requirement & sub-requirements share the same tier New tier assignments are effective 1/1/2013 and on 2013 AML Spreadsheet 35

36 2013 AML Analysis 2013 AML assigns Tiers for standards scheduled to come into effect in 2013 (see New Standards Effective 2013 webinar for more details) Emergency Preparedness and Operations (EOP) EOP-001-2b, EOP-005-2, EOP-006-2, and EOP Emergency Operations Planning, System Restoration from Blackstart Resources, System Restoration Coordination, and Loss of Control Center Functionality Come into effect July 1, 2013, and replace previous standards Adds five requirements to the AML for generator operator (GOP) and four for RC Reduces AML requirements by two for TOP and three for BA 36

37 Facilities Design, Connections, and Maintenance (FAC) FAC Facility Rating Methodology - Comes into effect January 1, Has two Tier 1 requirements (R6 and R7) - Replaces two similar Tier 1 requirements that were in FAC which is being retired 37

38 Personnel Performance, Training, and Qualifications (PER) PER System Personnel Training - Comes into effect April 1, Introduces four AML requirements (R1.3, R2, R2.1, and R3) for functions BA, RC, and TOP - Functions BA and TOP will have reduction of four requirements due to retirement of PER

39 Protection and Control (PRC) PRC (R4 and R5) - Transmission Relay Loadability - R4 and R5 come into effect January 1, Not assigned to AML tier but required for annual self certification 39

40 2013 Reliability Standard Audit Worksheets (RSAWs) Available on NERC.com>Compliance>Resources Provide documentation for the requirements in initial audit scope We recommend completion of all requirements in RSAWS New RSAW format for newly posted standards Review compliance assessment approach and measures Includes reference sources such as CANs, CARs, etc. 40

41 2013 AUDIT DATES 41

42 693 Audit Schedule 42

43 CIP Audit Schedule 43

44 Reporting Periods SPP.org->Regional Entity->Compliance-> Compliance Program 2013 folder CIP annual and 693 quarterly/annual Self Certification Periodic Data Submittal Exception Reporting TFEs 44

45 Conclusion 2013 SPP RE Implementation Plan is now posted to SPP.org Entities scheduled for 2013 audits have been notified except those singularly registered as PSE, which will be performed as spot checks Program continues to evolve and improve its focus on highest reliability risks 45

46 Coming Attractions March 5-6 RE Spring Workshop, Dallas May CIP Workshop, Dallas Oct 8-9 RE Fall Workshop, Little Rock 46

47 SPP RE Training Videos: vimeopro.com/sppre/basics Top 10 Ways Prepare for Audit CIP Audit: What to Expect Mock 693 Audit Submitting Quality Evidence and more! 47

48 Jeff Rooker, Lead Compliance Engineer Leesa Oakes, Compliance Specialist II