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

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.

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

Audit Violations – “THEN” (2009) TOP 10 Most Violated Standards PRC VAR FAC PER FAC CIP FAC TOP EOP CIP This was 2009!!! The old Training Standard was PER-002 – among the top 10 most violated FERC-enforceable standards

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. NERC used to publish a report for each of the top 10 standards, called a Compliance Analysis Report, or CAR CAR is a public document that provides guidance on how to comply with the standard. This report was specifically for the Training Standard that was enforceable at the time – PER-002!

PER-002: “Operating Personnel Training” The old standard had 4 requirements. They pertained to only TOPs & BAs. RCs had a separate training standard (PER-004 is the RC standard, V2 current) The Standard required : Staff must be trained Must have a training program Program must have objectives, initial & continuing training, enough training time and qualified instructors At least 5 days of EOP training & drills per year. This R4 was retired early – 3-31-2011, since the 32 hour EOP requirement was incorporated into the new PER-005-1 as R3 and R3 became effective April 1, 2011 Most of this standard (First 3 Reqm’ts) was in effect until last year, March 31st , 2013, when PER-002 was replaced by the new Training Std, PER-005, enforceable 4-1-2013 PER-002 FULLY RETIRED 3/31/2013 PER-005-1 R1 & R2 Enforceable 4/1/2013

PER-002 Violations - 2010 R2 R3 R1 R4 91 Total PER-002 Violations Number of Violations 91 Total PER-002 Violations 52 Program Deficiency Violations! So back in 2010, for the old training standard -- Most of the violations were about the training program itself – either they did not have one or……. ………the program they had was deficient in some way – Learning Objectives was the most violated req’mt – folks just did not know what they were or how to write them. Basically, they did not know how to properly design a training program! (since learning objectives are the roadmap to get you there!) R2 R3 R4 R1

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 Now in 2014 – what is the picture???? Look at the LIGHT BLUE Bars – you can see an improvement over 2013. (Good outreach – NERC, SERC & other RE outreach events, plus conferences and info sharing such as the IEEE conference we are attending now!) We have a NEW Training Std – PER-005-1, System Personnel Training, Most of it became enforceable on April 1, 2013, just when the old standard went away. Now we have 7 of the 10 most violated as CIP. Only operating std is VAR and that is VAR-002, the voltage and reactive standard for GOPs! The GOOD NEWS – PER-005-1 did not make this cut!!!. It is only in this type of a report that we want our standard NOT to make the cut…… So…………(on to next slide) PER-005-1 did not make the list!!!

We’ve Come a Long Way – Baby!

PER-005-1 Implementation All 3 Rqmts now enforceable! SO here is the Training Standard that is enforceable right now – PER-005- VERSION 1. ALL THREE requirements are NOW fully enforceable as of April 1, 2014. Resp. Entities are RC, BA, TOP and they have, by now,: Developed their company-specific, RR task lists Developed their learning objectives & plan for developing & delivering content under SAT Verified operators can perform the tasks Provided for 32 hours emergency ops training every 12 months

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 We have already discussed the main training standard, PER-005-1. But the others are 001, 003 and 004, which deal with operator responsibility & authority, operator certification and RC staffing. Only the PER-005-1 TRAINING STANDARD is going away – the date of retirement is 6-30-2016 And so how are we doing with all the PER standards now in effect???? 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

And How Are We Doing With PER? NERC Searchable NOP Spreadsheet Searchable Enforcement Page 11-25-14 Well….. There is something on the NERC website called a Searchable Notice of Penalty (NOP) Spreadsheet that lists all the violations for registered entities, which standard was violated, which specific requirement & sub-requirement, and what the penalty was in dollars. This info is available to the public. The Searchable Notice of Penalty (NOP) spreadsheet is based on filed NOPs and is provided for informational purposes only. In the event of a conflict between information on the Searchable NOP spreadsheet and filed NOPs, the filed NOPs govern. I searched on all the PER standards that are NOW enforceable and got ……. www.nerc.com/Program Areas & Departments/Compliance & Enforcement/Enforcement & Mitigation

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) None for current version. 5 violations of previous version (V1), relating to lack of credentials & wide-area understanding. PER-003-1 (Operating Personnel Credentials) None for current version. Many for the Version 0. PER-001-0.2 (Operating Personnel Resp/Auth) None for current version. 5 violations of previous version (V0) *** Higher Fines!! Two of the PER-004-2 violations had pretty hefty fines – 384K each. Highest penalty for PER violations were related to RC staffing!!! PER-003-on operator credentials also had some bigger fines, like 200K or 160K. So basically the bigger fines were about failure to have qualified and trained staff in the control rooms – a very high risk factor!! *** Higher Fines!!

Transition to PER-005-2 Remember we said PER-005-1 is the only PER standard that is going away. WHY???? Because the second version, PER-005-2 is becoming enforceable in 2016!!! The FERC Order approving the new training standard was issued this year on JUNE 19, 2014 and it has a 2-year lead time!!

FERC Order Approving PER-005-2 This is an excerpt from the FERC order. FERC approved: The new Version 2 that NERC submitted NERC’s proposed implementation plan (2 year lead time), AND NERC’s proposed changes to the Glossary – a new definition (Operations Support Personnel) and a change to an old definition (System

PER Inactive Date – Version 1 PER Enforcement Date – Version 2 6/30/2016 PER-005-2 Here is a list published on the NERC website. FOR THE CURRENT VERSION 1, it shows each requirement, when it became enforceable, and when it will be inactive. You can see that: The requirements were phased in over time – in 2011, 2013 & 2014 But they will ALL be retired on June 30, 2016 THE DAY BEFORE THE NEW STANDRAD BECOMES ENFORCEABLE – July 1, 2016 All PER-005-1 Requirements Become Inactive 6-30-2016 Per-005-2 Becomes Enforceable 7-1-2016

PER-005-1, “System Personnel Training” Purpose/Applicability 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 REFRESHER ON VERSION 1: Only applied to our 3 main groups of operating personnel: RC, BA & TOPs Assure competency to perform tasks. Many stakeholders were uncomfortable with “competency”. How do you measure competency – performing a task one time correctly? Competency takes not just training & verification, but also years of experience. Better to have a standard with a measurable outcome – personnel need to be TRAINED via the systematic approach….. Hence we settled on PER-005-2 where the purpose is to TRAIN. TOP BA

PER-005-2, “Operations Personnel Training” Purpose/Applicability To ensure that personnel performing or supporting Real-time operations on the Bulk Electric System (BES) are trained using a systematic approach. Reliability-related tasks on the BES Reliability Coordinator Balancing Authority Transmission Operator Transmission Owner Generator Operator “Certain”GOP REFRESHER ON VERSION 2: Notice it is for personnel either performing OR SUPPORTING. So covers operations support personnel, certain TOs & GOPs Changed title from System Personnel to Operations Personnel – to include the additional applicable entities. Now the purpose is to TRAIN using a systematic approach – “competency” taken out of the equation! Applies to 2 additional entities -- CERTAIN Transmission Owners and CERTAIN Generator Operators – NOT every entity with that registration. “Certain”TO ENFORCEMENT 7/1/2016

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!

“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. Operative words are: “act independently” Transmission Owner that has: 4.1.4.1 Personnel in a transmission control center who operate a portion of the Bulk Electric System at the direction of its Transmission Operator. EXAMPLE: IN SERC – SoCo is registered TOP who supervises local transmission control centers AL Power, GA Power, MS Power, Gulf Power (TOs). TOs operate the breakers, SoCo does not, but gives direction to TOs Rationale for Transmission Owner: Extending the applicability to Transmission Owners is necessary to address the FERC directive that the ERO develop formal training requirements for local transmission control center operator personnel. In Order No. 742 at P 62, the Commission clarified its understanding that local control center personnel exercise control over a significant portion of the Bulk-Power System under the supervision of the personnel of the registered transmission operator. The supervision may take the form of directive specific step-by-step instructions and at other times may take the form of the implementation of predefined operating procedures. In all cases, the Commission continued, the local transmission control center personnel must understand what they are required to do in the performance of their duties to perform them effectively on a timely basis. Thus, omitting such local transmission control center personnel from the PER-005-1 training requirements creates a reliability gap. 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?

“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. Operative words: develop specific dispatch instructions From the FERC Directive: GOP: Some GOPs are structured in such a way that they have a centrally-located dispatch center that receives direction and then develops specific dispatch instructions for plant operators under their control. For example, a Balancing Authority may direct a centrally-located dispatch center to deliver 300 MW to the grid, and the dispatch center would determine the best way to deliver that generation from its portfolio of units. In this type of structure, it is the personnel of the centrally located dispatch center that must receive formal training in accordance with the Reliability Standard. Plant operators located at the generator plant site also need to be trained but the responsibility for this training is outside the scope of the Reliability Standard. 4.1.5 Generator Operator that has: 4.1.5.1 Personnel at a centrally located dispatch center who receive direction from their Reliability Coordinator, Balancing Authority, Transmission Operator, or Transmission Owner and may develop specific dispatch instructions for plant operators under their control. 4.1.5.1.1 Personnel at a centrally located dispatch center who relay dispatch instructions, without making any modifications, are excluded. Rationale for Generator Operator: Extending the applicability to Generator Operators at a centrally located dispatch center is necessary to address the FERC directive that the ERO develop specific requirements addressing the scope, content and duration appropriate for generator operator personnel. The Commission explains in Order No. 693 at P 1359 that although a generator operator typically receives instructions from a balancing authority, it is essential that generator operator personnel have appropriate training to understand those instructions, particularly in an emergency situation in which instructions may be succinct and require immediate action. Order No. 742 further clarified that the directive applies to generator operator personnel at a centrally-located dispatch center who receive direction and then develop specific dispatch instructions for plant operators under their control. Plant operators located at the generator plant site are not required to be trained in PER-005-2. 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?

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. R5 requires systematic approach to training for all RC, TOP, BA personnel identified as “Operations Support Personnel” Effective in Glossary just as the new standard becomes enforceable – July 1, 2016.

Revised NERC Glossary Definition: System Operator New System Operator Definition removes the GOP from the definition and adds wording to better describe what a System Operator does. Effective in Glossary just as the new standard becomes enforceable – July 1, 2016. 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.

Comparison Highlights PER-005-1 PER-005-2 3 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 6 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 PER-005-2 R1 requires RC, BA, TOP to use a systematic approach to developing and implementing a training program for system operators, including development of specific task lists and an annual evaluation of the training program. R2 requires CERTAIN TO to use a systematic approach to developing and implementing a training program for system operators, including development of specific task lists and an annual evaluation of the training program. R3 requires RC, BA, TOP, & TO to verify the capabilities of their identified personnel. Verify at least one time! R4 requires RC, BA, TOP, TO to provide those personnel identified in Requirement R1 or R2 with emergency operations training using simulation technology to the extent that …have IROL, established protection system or operating guide to mitigate IROL violations. R5 requires RC, BA, TOP to use a systematic approach to develop and implement training for their operations SUPPORT personnel, providing training on how their job functions impact the real-time reliability-related tasks identified. R6 requires applicable GOP to use a systematic approach to develop and implement training for certain of their dispatch personnel at a centrally located dispatch center on how their job functions impact the reliable operations of the BES.

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 FERC ORDER 693 (re: PER-002, retired training standard) Include in training requirements: GOP personnel Outage coordination/assessment personnel Personnel who determine SOL/IROLs, operating nomograms Consider including: EMS support personnel FERC ORDER 742 (approved PER-005-1) Consider implementation plan for use of simulation technology in emergency training (R3.1) for entities that gain IROL control/authority. Develop a definition for and include in training requirements: “Local Transmission Control Center” (LTCC) personnel.

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.

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.

Questions? mstambach@serc1.org 704-940-8226