Discussion Items – September 10, 2012
I.
Welcome/Roll Call


II.
Antitrust Admonition/Disclaimer
Comments on notes from last meeting
Announcements/FERC/NERC Developments

Texas RE Report (Don Jones)

Recent FERC Actions (Don Jones)

Reminder: Self-Certifications (again!) 
III.
Recent Ballot Results
Type of
Ballot
Ballot Close
Date
Result
Pct
Next Step
Interpretation of BAL-002-0 R4
and R5 by NWPP Reserve Sharing
Group
Successive
9/4/12
Passed
88%
Should be
Recirculation
2007-17
Successive Ballot – Protection
System Maintenance & Testing
(PRC-005)
Successive
8/27/12
Passed
80%
SDT will
consider
comments
201005.1
Protection Systems: Phase 1
(Misoperations)
Initial
9/7/12
?
Project
Description
2009-19
1
IV.
Standards Under Development - Ballots/Comments
1. Ballots
#
Description
Type of Ballot
Ballot End
Date
1
2006-06 Reliability Coordination – COM-001
Recirculation
9/17/12
2
2007-02 Operating Personnel Communications Protocols – COM-003
Successive/NonBinding Poll
9/20/12
3
2009-01 Disturbance and Sabotage Reporting – CIP-001 & EOP-004
Successive/NonBinding Poll
9/27/12
Initial
10/12/12
Non-Binding
Poll
10/19/12
Project #
4
--
Standard Processes Manual Revisions to Implement SPIG
Recommendations
5
--
Revisions to Outstanding VRFs and VSLs
(1)
Project 2006-06 - Reliability Coordination – COM-001
The SDT posted its consideration of comments received during a parallel formal comment period
and successive ballot in July. The SDT made the following changes to the Standard:
o In R1, R3, R5, R7, R8 and R11, the word “experiences” was changed to “detects” and
respective changes were made to the measures.
o In R7, the VRF was changed from high to medium.
o In R10, the word “respectively” was added to connect referenced requirements to the
responsible entities named in the requirement. The respective changes was made in
the measure.
o In M3, “and” was changed to “or”.
o The data retention section was updated for readability and retention of voice
recordings was added.
(2)
Project 2007-02 - Operating Personnel Communications Protocols – COM-003
In response to comments received during the last comment period and other input, the
SDT is taking a new approach to COM-003-1. This version requires entities to establish
communication protocols and then implement a process for identifying, assessing and
correcting deficiencies with adherence to those communication protocols. The entity is to
ensure that its process is working, rather than requiring the demonstration of absolute
compliance with communication protocols at all times and identifying each deficiency as
a possible violation.
2
This version was also drafted in conjunction with the development of the RSAW. The
parallel development of these documents provided the opportunity for the SDT to
consider the compliance implications of the language in the Standard and offer input into
the language of the RSAW. The RSAW is posted for comments along with the Standard.
(3)
Project 2009-01 - Disturbance and Sabotage Reporting – CIP-001 & EOP-004
(Ballot & Comments)
The SDT made the following changes to the Standard:
Most of the language contained in the “background” section was moved to the
“Guidelines and Technical Basis” Section. Minor language changes were made to
the measures and the data retention section. Attachment 2 was revised to list
events in the same order as they appear in Attachment 1.
Requirement 1 was revised to include the Parts in the main body of the
Requirement. The Measure and VSLs were updated accordingly.
Following review of industry comments, the SDT re-examined the FERC
Directive in Order 693 and dropped R3 and R$ as they were written and
established a new R3 to have the Registered Entity “validate” the contact
information in the contact list for events applicable to them. This validation needs
to be performed each calendar year to ensure the list has current, up-to-date
contact data.
A red-lined version of EOP-004-2 is not posted because it is a consolidation of CIP-0012a and EOP-004-1. A red-lined version of EOP-004-2 would be difficult to follow.
(4)
Standard Processes Manual Revisions to Implement SPIG Recommendations



August 29-October 12, 2012: 45-day Formal Comment Period
August 29-Setember 28, 2012: Join Ballot Pool
October 3-12, 2012: Initial Ballot
At its February 9, 2012 meeting, the NERC BOT requested the assistance of the NERC
MRC to provide policy input and a proposed framework for specific improvements to the
standards development process. NERC then formed the Standard Process Input Group or
SPIG) to develop recommendations to improve the standards development process.
The SPIG focused its efforts on the most important areas for improvement by gathering
input from the regions, the MRC, standard drafting team leaders, NERC staff and other
stakeholders. They collected this input through interviews and a formal survey. Based on
that input, the SPIG produced a document with 5 recommendations to modify the way
3
NERC develops Standards and other solutions intended to improve the priority, product,
and process of standards development:
1. Continue to meet the minimum requirements of the American National Standards
Institute process to preserve ANSI accreditation.
2. Form a Reliability Issues Steering Committee (RISC) to conduct front-end, highlevel reviews of nominated reliability issues and direct the initiation of standards
projects or other solutions that will address the reliability issues. (Note: the RISC was
formed during the August 16 BOT meeting.)
3. Task NERC management, working with a broad array of ERO resources to develop
a strategy for improving the communication and awareness of effective reliability risk
controls to increase input and alignment with state, federal, and provincial authorities.
4. Require that the standards development process address the use of results-based
standards; cost effectiveness of standards and standards development; alignment of
standards requirements/measures with RSAWs; and the retirement of standards no
longer needed to meet an adequate level of reliability.
5. Require the standards development process to be revised to improve timely,
stakeholder consensus in support of new or revised reliability standards and require
standard development resources to achieve and address formal and consistent project
management and efficient formation and composition of standard drafting teams.
The recommendations also aim to strengthen consensus building: (1) on the need for a
standard and (2) on the requirements themselves.
The BOT approved the recommendations on May 9, 2012. The SC was specifically
charged with addressing SPIG Recommendations 1, 4 and 5.
In June, the first draft of SPM revisions was posted for a 30-day stakeholder comment
period. The team has spent the last several weeks reviewing this feedback, revising the
proposed SPM as necessary, and responding to stakeholder comments. The proposed
revisions to the SPM are included in the posted redline version of the document and can
be summarized as follows:



Clarifying the requirements for responding to stakeholder comments during
informal and formal comment periods
Retaining the concept of including ‘no’ ballots not accompanied by comments in
the calculation of quorum, but not counting them in the calculation of consensus;
elimination of the evaluation of comments submitted alongside a ‘no’ vote to
determine relevance
Clarifying the proposal to move measures from standards to RSAWs
4



(5)
Removing the proposal to eliminate VRFs and VSLs from standards
Clarifying the handling and purpose of interpretations
Clarifying the intent of the waiver provision in section 16.0
Revisions to Outstanding VRFs and VSLs
NERC standards, legal, and enforcement staffs have been working with FERC staff to
review a set of VRF and VSL assignments for possible revision or further justification.
The VRFs and VSLs in need of review have one of two origins:
•
Deferred VRFs and VSLs: Three years ago, sub-requirement VRFs and VSLs were
rolled up with main requirement VSLs and new guidelines were issued by FERC and
NERC with respect to how VRFs and VSLs are assigned. Orders approving standards
were issued in the midst of this roll-up process and FERC deferred approval of the
VRFs and VSLs associated with those standards until the new VRF/VSL assignment
process was formally approved and implemented. FERC has now reviewed those
VRFs and VSLs and, in cases where staff found issues that may be correctable (typos
and obvious guideline violations) or that require further justification, they have
identified those VRFs and VSLs to give NERC staff a chance to review them and
modify them before the Commission issues a final order.

VSLs from “Filing 2”: During the VRF and VSL roll-up process, NERC staff
identified existing VSLs that needed modification to make them conform to the rollup or to other aspects of the FERC and NERC guidelines. NERC staff filed those
corrections in two big batches: Filing 1 (filed on March 5, 2010 and updated in a
supplemental information filing on March 21, 2011), and Filing 2 (filed on December
1, 2010). As with Filing 1, FERC staff has reviewed Filing 2 and identified VSLs that
could require additional work before an order is issued. FERC is giving NERC staff a
chance to address those issues now.
Both VRFs and VSLs are typically posted with standards and subject to review periods
and non-binding polls. Because these VRF and VSL changes are not associated with
active standards projects, there is no built-in mechanism for ensuring their review by
stakeholders, but NERC staff wants to ensure that the proposed revisions or justifications
for the outstanding VRFs and VSLs undergo the same industry review as other VRFs and
VSLs. Thus, NERC has posted its proposals for addressing the outstanding VRFs and
VSLs for a 45-day comment period and 10-day nonbinding poll.
There is a lot more information available on the project page:
http://www.nerc.com/docs/standards/sar/Detailed_Background_Document_final_VRF_V
SL_090512.pdf
5
2. Posted for Comments
#
1
2
Project #
Project 2010-05.1
--
3
--
4
Project 2007-02
5
Project 2009-01
6
--
7
--
8
--
(1)
Description
Protection Systems: Phase 1 (Misoperations)
Definition of Adequate Level of Reliability
2013-2015 Reliability Standards Development
Plan
Operating Personnel Communications
Protocols ― COM-003
Disturbance and Sabotage Reporting ― CIP001 and EOP-004
Order 754
Standard Processes Manual Revisions to
Implement SPIG Recommendations
Revisions to Outstanding VRFs and VSLs
Closing Date
9/7/12
9/13/12
9/18/12
9/20/12
9/27/12
10/5/12
10/12/12
10/19/12
Project 2010-05.1 Protection Systems: Phase 1 (Misoperations)

Revises many of the definitions used in PRC-004 (Failure to Trip – During Fault; Failure
to Trip – Other Than Fault; Slow Trip – During Fault; Slow Trip – Other Than Fault)

Applies to TO, GO, DP

Purpose: Ensure transmission and generation Protection System Misoperations affecting
the reliability of the Bulk Electric System (BES) are analyzed and mitigated.

Combines the reliability intent of the two legacy standards PRC-003-1 and PRC-004-2a

Adds definitions (Unnecessary Trip - During Fault; Unnecessary Trip - Other Than Fault)

Does not cover SPS and RMS. Those will be covered in second phase of Project.

(R1) Within 120 days of an “interrupting device operation” caused by a Protection
System, the entity must:



Identify and review the operation;

Notify other entity if you think its Protection System component contributed to
event;

Designate each Misoperation

Investigate each Misoperation and document findings (including cause)
(R2) Within 60 days of identifying the cause of the Misoperation, entity must:

Develop and document a Corrective Action Plan or

Explain why corrective actions are beyond the entity’s control or would reduce BES
reliability
(R3) For Misoperations w/o an identified cause, the entity must (w/n 180 days of the
associated interrupting device operation), complete:
6


(2)
Development of an action plan that identifies: (i) any additional investigation or
Protection System modifications (including a timetable) or (ii) a declaration
explaining why no further actions will be taken
(R4) For each CAP or action plan, the entity must:

Implement the CAP or action plan

Maintain detailed implementation records of each CAP or action plan, including
dated information surrounding any revision or completion.
Definition of Adequate Level of Reliability
With this posting, the ALR Task Force is soliciting comments on the proposed
revision to the Adequate Level of Reliability definition and a technical report
supporting the definition.
The ALR Task Force (ALRTF) was formed in May 2011 to address concerns
expressed by the NERC BOT, the MRC and stakeholders that NERC’s current
definition of ALR needs reassessment to ensure the definition supports and helps
define NERC’s mission to ensure reliable operation of the BPS.
The ALRTF is working to develop a definition of ALR that encompasses NERC’s
responsibility to ensure reliable planning and operation of the BPS and to identify and
define reliability objectives and performance characteristics that drive what system
planners and operators do on a day-to-day basis to ensure that the BPS is reliable.
The ALRTF received comments during its last posting from April 24 through June
25, 2012. The Task Force reviewed and considered all feedback and proposed
language changes and updated the ALR definition and its accompanying technical
report to address the most common and compelling concerns. The ALRTF, NERC
staff, and most commenters agree that the detailed proposed definition, which now
includes performance and assessment objectives, time frames and associated
outcomes, is both useful and superior to the current definition of ALR.
Once it is finalized, the ALR definition will be filed with FERC for information, as
the current definition was. The definition will then be used by the NERC Performance
Analysis Subcommittee and NERC reliability assessment staff to assess BES
reliability, to identify gaps in data and begin developing the framework within which
the Reliability Issues Steering Committee (RISC) will be able to work.
(3)
2013-2015 Reliability Standards Development Plan
NERC is developing the 2013-2015 Reliability Standards Development Plan (Plan)
and issued a call for projects in April 2012. Suggestions were due May 2012. The
submitted suggestions were included in the draft prioritization spreadsheets. The
draft spreadsheets containing project prioritizations were endorsed for industry
comment by the Standards Committee (SC) at their August 2012 meeting.
The prioritization will be posted for 30 days. Following consideration of the
comments received, the Plan will be submitted to the SC for approval at the October
2012 meeting and subsequently presented to the NERC BOT in November 2012.
7
This Plan was developed using a methodology designed to provide an objective
method for prioritizing projects. Thus, at this stage of developing the Plan, comments
should be focused on the ranking of each of the criteria provided in the downloadable
excel spreadsheet rather than the final result. In formulating comments, entities are to
use the excel versions of the prioritization spreadsheets (one includes all projects; one
eliminates the currently active projects). The PDF spreadsheets are provided for
information only to show how, using the currently identified rankings, the projects
would be prioritized.
Information obtained from the comments received will be utilized to develop the final
version of the Plan. The final version will be developed to incorporate the top eight
projects from the Reliability sort, the top three projects from the Time Sensitive sort,
and the top two projects from the Practicality sort, as possible. The number of
projects from each category may be adjusted based on the degree of complexity in the
top projects, the completion of technical research, and the availability of resources
required for a specific project or other considerations. Unless brought into priority
status due to a necessary adjustment, other projects will be deferred pending
completion of the top priority projects. The Plan is only a guide and will be adjusted
for emerging issues, necessary adjustments or other demands that are deemed to take
priority.
(4)
Project 2007-02 Operating Personnel Communications Protocols ― COM-003
[See Item #2, above]
(5)
Project 2009-01 Disturbance and Sabotage Reporting ― CIP-001 and EOP-004
[See Item #3, above]
(6)
Order 754
The NERC BOT approved the Order No. 754 Request for Data or Information on
August 16, 2012 and it became effective September 1, 2012. It applies to each
Transmission Planner with regard to reporting. Each Generator Owner, Distribution
Provider and Transmission Owner is required to support the Transmission Planner in
completing the steps necessary to obtain the data for reporting.
Required Action: Only the Transmission Planner is required to acknowledge
notification of the data request. The portal for registering and data submittal is in
development and will be available in stages and announced later. When ready,
NERC will hold a webinar for interested industry stakeholders.
(7)
Standard Processes Manual Revisions to Implement SPIG Recommendations
[See Item #4, above]
(8)
Revisions to Outstanding VRFs and VSLs
[See Item #5, above]
8
V.
Compliance Application Notices

VI.
CANS posted for industry comment – Nothing new
Violations
Region
WECC
Entity
URE
Amount
$70,000
WECC
Cedar Creek Wind
Energy, LLC
$60,000
SERC
Entergy
$150,000
Standards
CIP-004
PRC-005
FAC-001-0
EOP-005-1
FAC-001-0
FAC-001-0
PER-002-0
PER-002-0
PER-002-0
PER-003-0
PRC-005-1
EOP-005-1
FAC-008-1
COM-002-2
COM-002-2
COM-002-2
COM-002-2
COM-002-2
FAC-009-1
See also, FFTR Spreadsheet and Spreadsheet NOPs
VII.

Misc.
Upcoming Events
o
o
o
o
o
o
o
o
o
o
NERC “Zero Defect” Webinar – 9/11
CIP Version 5: Focus on Correcting Deficiencies – 9/11
CVA Workshop – 9/18/12 (St. Louis)
NERC Industry Seminar on Internal Controls – 9/20-21 (Atlanta)
CIP Version 5: Successive Ballot Update – 9/21
Fall Reliability Standards and Compliance Workshop – 10/23-25 (Atlanta)
EnergySec Summit – 9/25-27 (Portland)
Model Validation Workshop – 10/1 to 10/3 (Bloomington, MN)
NERC GridSecCon 2012 – 10/17-18 (San Diego)
NERC Reliability Standards and Compliance Workshop – 10/23 to 10/25 (Atlanta)
9
VIII. Future Meetings



IX.
9/24/12
10/8/12
10/22/12
Action Items

None
10