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,

IEEE/WGOTDecember 9-10, 2014, Orlando FL

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PER Update &Compliance Lessons Learned

IEEE Working Group on Operator TrainingDecember 9-10, 2014, Orlando, FL

Margaret StambachSERC Reliability CorporationTraining Programs Manager


Learning ObjectivesAt 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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Topics

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• 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)

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TOP 10 Most Violated Standards

PRC

CIPCIP

VARFAC

FACTOP

PERFAC

EOP


PER Violations – 2010 CAR

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• 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.


PER-002: “Operating Personnel Training”

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PER-002 FULLY RETIRED 3/31/2013PER-005-1 R1 & R2 Enforceable 4/1/2013


PER-002 Violations - 2010

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91 Total PER-002 Violations

52 Program Deficiency Violations!

R2 R3

R4 R1

Number of Violations


Audit Violations – “NOW” (2014)

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TOP 10 Most Violated StandardsKey Compliance Enforcement Metrics and TrendsCompliance Committee Open SessionAugust 13, 2014

7 CIP1 PRC1 VAR1 FAC

PER-005-1 did not make the list!!!


We’ve Come a Long Way – Baby!

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PER-005-1 Implementation

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All 3 Rqmts now enforceable!


Other PER Standards Now Enforceable

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www.nerc.com/Program 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

NO inactive date

ENF. DATE

INACTIVE 6-30-2016Systematic approach, task verification, EOPs training with sim

NO inactive date

http://www.nerc.com/Program


And How Are We Doing With PER?

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NERC Searchable NOP Spreadsheet

www.nerc.com/Program Areas & Departments/Compliance & Enforcement/Enforcement & Mitigation

Searchable Enforcement Page 11-25-14


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NOP Search Results for PERJune 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!!

*** Higher Fines!!


Transition to PER-005-2

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FERC Order Approving PER-005-2

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PER Inactive Date – Version 1PER Enforcement Date – Version 2

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6/30/2016 PER-005-2

All PER-005-1 Requirements Become Inactive 6-30-2016Per-005-2 Becomes Enforceable 7-1-2016


PER-005-1, “System Personnel Training”

Purpose/Applicability

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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


PER-005-2, “Operations Personnel Training”

Purpose/Applicability

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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.

ENFORCEMENT7/1/2016

“Certain”

GOP

“Certain”TO


PER-005-2 (Enforceable 7-1-2016)

• Expansion of “Applicable Entities”

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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.

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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?


• 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.

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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


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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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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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Comparison HighlightsPER-005-1

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

PER-005-2

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


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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


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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

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• 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.


[email protected]

704-940-8226

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mailto:[email protected]

Documents

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,