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IEEE/WGOT December 9-10, 2014, Orlando FL 1 PER Update & Compliance Lessons Learned IEEE Working Group on Operator Training December 9-10, 2014, Orlando,

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Presentation on theme: "IEEE/WGOT December 9-10, 2014, Orlando FL 1 PER Update & Compliance Lessons Learned IEEE Working Group on Operator Training December 9-10, 2014, Orlando,"— Presentation transcript:

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2 IEEE/WGOT December 9-10, 2014, Orlando FL 1 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

3 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. 2

4 IEEE/WGOT December 9-10, 2014, Orlando FL Topics 3 Audit Violations – “Then” and “Now” Training Standards History PER vs. PER vs. PER PER Family of Standards Enforcement & Inactive Dates PER-005-1compared to emerging PER-005-2

5 IEEE/WGOT December 9-10, 2014, Orlando FL Audit Violations – “THEN” (2009) 4 TOP 10 Most Violated Standards PRC CIP VAR FAC TOP PER FAC EOP

6 IEEE/WGOT December 9-10, 2014, Orlando FL PER Violations – 2010 CAR 5 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.

7 IEEE/WGOT December 9-10, 2014, Orlando FL PER-002: “ Operating Personnel Training ” 6 PER-002 FULLY RETIRED 3/31/2013 PER R1 & R2 Enforceable 4/1/2013

8 IEEE/WGOT December 9-10, 2014, Orlando FL PER-002 Violations Total PER-002 Violations 52 Program Deficiency Violations! R2 R3 R4 R1 Number of Violations

9 IEEE/WGOT December 9-10, 2014, Orlando FL Audit Violations – “NOW” (2014) 8 TOP 10 Most Violated Standards Key Compliance Enforcement Metrics and Trends Compliance Committee Open Session August 13, CIP 1 PRC 1 VAR 1 FAC PER did not make the list!!!

10 IEEE/WGOT December 9-10, 2014, Orlando FL We’ve Come a Long Way – Baby! 9

11 IEEE/WGOT December 9-10, 2014, Orlando FL PER Implementation 10 All 3 Rqmts now enforceable!

12 IEEE/WGOT December 9-10, 2014, Orlando FL Other PER Standards Now Enforceable 11 Areas & Departments/Standards/US Enforcement Dates 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 ENF. DATE INACTIVE Systematic approach, task verification, EOPs training with sim NO inactive date

13 IEEE/WGOT December 9-10, 2014, Orlando FL And How Are We Doing With PER? 12 NERC Searchable NOP Spreadsheet Areas & Departments/Compliance & Enforcement/Enforcement & Mitigation Searchable Enforcement Page

14 IEEE/WGOT December 9-10, 2014, Orlando FL 13 NOP Search Results for PER June 2008-November 2014 PER (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 (RC Staffing) None for current version. 5 violations of previous version (V1), relating to lack of credentials & wide-area understanding. PER (Operating Personnel Credentials) None for current version. Many for the Version 0. PER (Operating Personnel Resp/Auth) None for current version. 5 violations of previous version (V0) *** Higher Fines!!

15 IEEE/WGOT December 9-10, 2014, Orlando FL Transition to PER

16 IEEE/WGOT December 9-10, 2014, Orlando FL FERC Order Approving PER

17 IEEE/WGOT December 9-10, 2014, Orlando FL PER Inactive Date – Version 1 PER Enforcement Date – Version /30/2016 PER All PER Requirements Become Inactive Per Becomes Enforceable

18 IEEE/WGOT December 9-10, 2014, Orlando FL PER-005-1, “ System Personnel Training” Purpose/Applicability 17 Reliability- related tasks on the BES Reliability Coordinator Balancing Authority Transmission Operator 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. RC BATOP

19 IEEE/WGOT December 9-10, 2014, Orlando FL PER-005-2, “ Operations Personnel Training” Purpose/Applicability 18 Reliability- related tasks on the BES Reliability Coordinator Balancing Authority Transmission Operator Transmission Owner Generator Operator Purpose: To ensure that personnel performing or supporting Real-time operations on the Bulk Electric System (BES) are trained using a systematic approach. ENFORCEMENT 7/1/2016 “Certain” GOP “Certain” TO

20 IEEE/WGOT December 9-10, 2014, Orlando FL PER (Enforceable ) Expansion of “Applicable Entities” 19 Recognizes that personnel OTHER than System Operators need formal Systematic Approach to Training (SAT) if they perform RR tasks!

21 IEEE/WGOT December 9-10, 2014, Orlando FL “Other” Personnel - TO Expanded list of “Applicable Entities” RC, BA, TOP (as before), but added Transmission Owner that has: 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. 20 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?

22 IEEE/WGOT December 9-10, 2014, Orlando FL Expanded list of “Applicable Entities” RC, BA, TOP (as before), but added: Generator Operator that has: 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. 21 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? “Other” Personnel - GOP

23 IEEE/WGOT December 9-10, 2014, Orlando FL 22 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.

24 IEEE/WGOT December 9-10, 2014, Orlando FL 23 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.

25 IEEE/WGOT December 9-10, 2014, Orlando FL 24 Comparison Highlights PER 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 PER 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

26 IEEE/WGOT December 9-10, 2014, Orlando FL 25 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

27 IEEE/WGOT December 9-10, 2014, Orlando FL 26 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.

28 IEEE/WGOT December 9-10, 2014, Orlando FL Summary 27 The original PER Training Standard, “Operating Personnel Training” (PER-002-0) was among the top 10 most violated standards. PER 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, 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.

29 IEEE/WGOT December 9-10, 2014, Orlando FL Questions?


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