Brent Read Compliance Engineer - Enforcement. NERC PER Standards January 29, 2013 Compliance User Group

Transcription

1 Brent Read Compliance Engineer - Enforcement NERC PER Standards January 29, 2013 Compliance User Group

2 2 Personnel, Training, and Qualifications

3 System Operators are single handedly the most important people in the electric industry. -Thomas Edison, maybe? The trouble with quotes on the internet is that you can never know if they are genuine. -Abraham Lincoln 3

4 Background B.S. in Mechanical Engineering Technology o Texas A&M University, College Station, TX 7 Years at a TO/TOP in TX Interconnection o 4 yrs in engineering group o 3 yrs supervising/managing the control room Joined WECC Enforcement in June 2012 NERC Certified Transmission Operator 4

5 5 Importance of the PER Standards

6 Importance of the PER Standards 6 System Operators are the most important parts of the BES. System Operators are responsible for ensuring a stable and reliable BES. System Operators must be able to take proper actions in normal and emergency system conditions. System Operators must be able to respond quickly and appropriately.

7 Agenda Review PER Standards. Discuss Best Practices and Resources for working with PER standards. Discuss the Enforcement Review Approach to the PER Standards. 7

8 Standards Review 8 PER o Operating Personnel Responsibility and Authority PER o Operating Personnel Training PER o Operating Personnel Credentials PER o System Personnel Training

9 Standard Review: PER R1. Each TOP and BA shall provide operating personnel with the responsibility and authority to implement real-time actions to ensure the stable and reliable operation of the Bulk Electric System. 9

10 Standard Review: PER R1. Each TOP and BA shall be staffed with adequately trained operating personnel. 10

11 Standard Review: PER R2. Each TOP and BA shall have a training program for all operating personnel that are in: o R2.1. Positions that have the primary responsibility, either directly or through communications with others, for the real-time operation of the interconnected Bulk Electric System. o R2.2. Positions directly responsible for complying with NERC standards.

12 Standard Review: PER R3. For personnel identified in Requirement R2, the TOP and BA shall provide a training program meeting the following criteria: 12

13 Standard Review: PER o R3.1. A set of training program objectives must be defined, based on NERC and RRO standards, entity operating procedures, and applicable regulatory requirements. These objectives shall reference the knowledge and competencies needed to apply those standards, procedures, and requirements to normal, emergency, and restoration conditions for the TOP and BA operating positions 13

14 Standard Review: PER o R3.2. The training program must include a plan for the initial and continuing training of TOP and BA operating personnel. That plan shall address knowledge and competencies required for reliable system operations. o R3.3. The training program must include training time for all TOP and BA operating personnel to ensure their operating proficiency. 14

15 Standard Review: PER o R3.4. Training staff must be identified, and the staff must be competent in both knowledge of system operations and instructional capabilities. 15

16 Standard Review: PER R4. For personnel identified in Requirement R2, each TOP and BA shall provide its operating personnel at least five days per year of training and drills using realistic simulations of system emergencies, in addition to other training required to maintain qualified operating personnel. 16

17 Standard Review: PER R1. Each RC shall staff its Real-time operating positions performing RC reliability-related tasks with System Operators who have demonstrated minimum competency in the areas listed by obtaining and maintaining a valid NERC Reliability Operator certificate: 17

18 Standard Review: PER o R1.1. Areas of competency R Resource and demand balancing R Transmission operations R Emergency preparedness and operations R System operations R Protection and control R Voltage and reactive R Interchange scheduling and coordination R Interconnection reliability operations and coordination 18

19 Standard Review: PER R2. Each TOP shall staff its Real-time operating positions performing TOP reliability-related tasks with System Operators who have demonstrated minimum competency in the areas listed by obtaining and maintaining one of the following valid NERC certificates: 19

20 Standard Review: PER o R2.1. Areas of competency R Transmission operations R Emergency preparedness and operations R System operations R Protection and control R Voltage and reactive o R2.2. Certificates Reliability Operator Balancing, Interchange and Transmission Operator Transmission Operator 20

21 Standard Review: PER R3. Each BA shall staff its Real-time operating positions performing BA reliabilityrelated tasks with System Operators who have demonstrated minimum competency in the areas listed by obtaining and maintaining one of the following valid NERC certificates: 21

22 Standard Review: PER o R3.1. Areas of competency R Resources and demand balancing R Emergency preparedness and operations R System operations R Interchange scheduling and coordination o R3.2. Certificates Reliability Operator Balancing, Interchange and Transmission Operator Balancing and Interchange Operator 22

23 Standard Review: PER PER Footnote o Non-NERC certified personnel performing any reliability-related task of a real-time operating position must be under the direct supervision of a NERC Certified System Operator stationed at that operating position; the NERC Certified System Operator at that operating position has ultimate responsibility for the performance of the reliability related tasks. 23

24 Standard Review: PER R1. Each RC, BA and TOP shall use a systematic approach to training to establish a training program for the BES companyspecific reliability-related tasks performed by its System Operators and shall implement the program. 24

25 Standard Review: PER o R1.1. Each RC, BA and TOP shall create a list of BES company-specific reliability-related tasks performed by its System Operators. R Each RC, BA and TOP shall update its list of BES company-specific reliability-related tasks performed by its System Operators each calendar year to identify new or modified tasks for inclusion in training. 25

26 Standard Review: PER o R1.2. Each RC, BA and TOP shall design and develop learning objectives and training materials based on the task list created in R1.1. o R1.3. Each RC, BA and TOP shall deliver the training established in R1.2. o R1.4. Each RC, BA and TOP shall conduct an annual evaluation of the training program established in R1, to identify any needed changes to the training program and shall implement the changes identified. 26

27 Standard Review: PER R2. Each RC, BA and TOP shall verify each of its System Operator s capabilities to perform each assigned task identified in R1.1 at least one time. o R2.1. Within six months of a modification of the BES company-specific reliability-related tasks, each RC, BA and TOP shall verify each of its System Operator s capabilities to perform the new or modified tasks. 27

28 28 Standard Review: PER R3. At least every 12 months each RC, BA and TOP shall provide each of its System Operators with at least 32 hours of emergency operations training applicable to its organization that reflects emergency operations topics, which includes system restoration using drills, exercises or other training required to maintain qualified personnel.

29 Standard Review: PER o R3.1. Each RC, BA and TOP that has operational authority or control over Facilities with established IROLs or has established operating guides or protection system to mitigate IROL violations shall provide each System Operator with emergency operations training using simulation technology such as a simulator, virtual technology, or other technology that replicates the operational behavior of the BES during normal and emergency conditions.

30 Standards Review 30 PER o Operating Personnel Responsibility and Authority PER o Operating Personnel Training PER o Operating Personnel Credentials PER o System Personnel Training

31 31 Best Practices

32 Best Practices for Training Programs What are the challenges? o Compliance with standards. o Content. o Creating clean and functional documentation. o Availability of resources, including operating personnel. o Training programs can be overwhelming. 32

33 33 Best Practices: Reliability Standard Measures Reliability Standard Measures are often overlooked When reviewing the standards continue beyond the Requirements to the Measures o Part of the individual standards; Follows the Requirements in the standard. o Gives additional information to assist in complying with the Requirements. o Too often the Measures get overlooked.

34 PER Measures M1. Each RC, TOP and BA shall have the following evidence to show that it staffed its Real-time operating positions performing reliabilityrelated tasks with System Operators who have demonstrated the applicable minimum competency by obtaining and maintaining the appropriate, valid NERC certificate (R1, R2, R3): o o o o M1.1. A List of Real-time operating positions. M1.2. A list of System Operators assigned to its Real-time operating positions. M1.3. A copy of each of its System Operator s NERC certificate or NERC certificate number with expiration date which demonstrates compliance with the applicable Areas of Competency. M1.4. Work schedules, work logs, or other equivalent evidence showing which System Operators were assigned to work in Real-time operating positions 34

35 35 Best Practices: Cross Reference Standards Some standards require training and can strengthen the training program. Use the non-per standards as part of the training program o Use the standards to provide content. o Use the standards to improve the quality of the content. o Use the standards to track the level of detail in the training program.

36 Best Practices: Cross Reference Standards Example of using the standards to improve content: Black Start Restoration: In an emergency restoration situation the priority is integrity of the Interconnection, not consumer load (EOP R3). 36

37 Best Practices: Cross Reference Standards Example of using the standards to provide content: PRC R1: Each Transmission Operator, Balancing Authority, and Generator Operator shall be familiar with the purpose and limitations of Protection System schemes applied in its area. 37

38 Best Practices: Cross Reference Standards For more related standards that may provide content review the following: o EOP R6 o EOP R10 o EOP R1.6 38

39 Best Practices: Documentation Stack the evidence. Keep your documentation clean and intact. o Keep training documentation together in one place. o Duplication causes confusion. Specify the method of delivery of training. 39

40 Best Practices: Documentation Plan your training schedule ahead of time. o Create a timeline for delivering training. o Prevents rushing to complete training at the end of the year. o Identifies available resources Define Annual in your training program o If not defined, we will default to Calendar year. 40

41 Best Practices: Documentation Tell a good story. o Use narratives to help explain the training program, training and learning objectives, processes, and procedures. Use diagrams, charts, and/or pictures where appropriate. o Illustrate your points. o Provide additional clarity. 41

42 Best Practices: Use Available Resources Use other entities as a resource o Communicate with each other. o Share training programs and resources. o Share processes and methodologies. o Assist each other in preparation for audits. o Don t be afraid to reach out to each other. o Be willing to help each other. 42

43 Best Practices: Use Available Resources NERC Generic Task List o stem_operator_task_list.xls DOE Systematic Approach to Training o docs/handbook/hdbk1078.pdf 43

44 Best Practices: Use Available Resources DOE Guide to Good Practices for Continuing Training o docs/handbook/hdbk pdf 44 DOE Guide to Good Practices Evaluation Instrument Examples o docs/handbook/hdbk1201.pdf

45 Best Practices: Use Available Resources DOE Guide to Good Practices for On-the- Job Training o docs/handbook/hdbk1206.pdf 45

46 Best Practices: Use Available Resources NERC Reliability Standards o 20 RSAWs o Documents/Complete%20set%20of%20RSAW s.zip 46

47 Review of Best Practices The Measures section of each standard provides clear guidance. Cross reference all applicable standards. Invest time in your documentation. The devil is in the details. Use existing resources. 47

48 48 Enforcement Review Approach

49 Enforcement Review Approach Does your training program ensure that operating personnel are familiar with all of the applicable NERC standards? Does your training program ensure operating personnel are trained to properly respond to any situation within their area of responsibility within the BES? 49

50 Enforcement Review Approach Does your training program provide Initial and continuing training for operating personnel? Does your training program have clear training and learning objectives? For individual standard requirement Audit Approaches use the RSAWs. 50

51 Enforcement Review Approach: RSAW Example PER R1 o Evidence that the entity provides (and has provided) operating personnel with the responsibility and authority to implement real-time actions to ensure the stable and reliable operation of the Bulk Electric System. 51

52 Enforcement Review Approach: RSAW Example 52

53 53 Too much?

54 A Look Back Reviewed the PER Standards. Discussed Best Practices and Resources available. Discussed the Enforcement Review Approach used when reviewing training programs and documentation. 54

55 WECC Staff Is this your reaction when we call you or you have to call us? 55

56 We re Here to Help Our goal is the same as yours, we want to improve the reliability of the BES. Take the time to review your training program on a regular basis. Utilize all of the available resources you can find. Remember, the devil is in the details. 56

57 Questions? Brent Read Compliance Engineer Enforcement (801)