NERC watch: New/revised standards, audit expectations

Distinguishing between what’s important and what’s not in the myriad regulations plant managers must deal with these days is particularly challenging given all the other things that must be done. Plant personnel need all the help CTOTF and other user organizations can provide to keep them current on regulations, as well as changes to existing rules. They know that slip-ups in compliance—accidental or not—will be penalized, sometimes harshly.

Alan Bull, PE, NERC manager for NAES Corp, updated participants in the Regulatory and Compliance Roundtable on the following new/revised standards:

• PRC-005-2, Protection System Maintenance and Testing.
• CIP Revision 4, Critical Infrastructure Protection (CIP).
• IRO-004-2, Operations Planning.

Bull understands well the information needs of plant personnel and is expert in translating regulatory language into plain English so appropriate deck-plates action items can be implemented.

Revision 2 of PRC-005, the fifth draft of the standard, merges previous standards PRC-005-1, PRC-008-0, PRC-017-0. It also addresses FERC comments from Order 693 and observations from the NERC System Protection and Control Task Force. Acronyms: FERC is the Federal Energy Regulatory Commission and NERC is the North American Electric Reliability Corp.

Bull told the group that drafts of PRC-005-2, which have not yet been approved by NERC or FERC, can be accessed at in the “Standards Under Development” section as Project 2007-17, Protection System Maintenance and Testing.

The standard covers (1) protective relays, (2) communication systems necessary for correct operation of protective functions, (3) voltage and current sensing devices providing inputs to protective relays, (4) station dc supply associated with protective functions, and (5) control circuitry associated with protective functions through the trip coils of circuit breakers or other interrupting devices.

PRC-005 requires each transmission owner, generator owner, and distribution provider to establish a protection system maintenance program to protect critical bulk electric system (BES) components. The maintenance method (time- or performance-based) used for each type of component—for example, station batteries—must be identified as well.

CIP Revision 4. Bull next discussed the status of CIP Rev 4: (1) CIP-002-4 through CIP-009-4 are awaiting FERC approval; the Critical Asset Identification Method requirement was removed from CIP-002-4; CIP-003-4 through CIP-009-4 had no major changes. The effective date is the first day of the eighth calendar quarter after applicable regulatory approvals have been received.

Bull said that NERC is updating the CIP standards to Rev 4 because (1) the number of “self identified” critical assets is lower than expected and (2) authorities are questioning the validity of the methods used for identifying critical assets. He summarized the content of CIP-002-4 with the following bullet points:

• Eliminates subjectivity by entities over what is “critical.”

• Identifies critical assets in Attachment 1 to CIP-004-2. For generation owners, the following are considered critical assets:

  • A generating plant with a real power capability of 1500 MW or more.
  • Reactive power resources with a nameplate rating of 1000 MVAr or more.
  • Generating facilities deemed by the transmission planner as necessary to avoid adverse reliability impacts on the BES.
  • Black-start resources.
  • Special protection systems, remedial action scheme, or automated switching systems that operate BES elements.
  • Facilities that perform automatic load shedding of 300 MW or more.
  • Control centers that perform the functional obligations of the reliability coordinator.

IRO-004-2 was developed to assure that applicable entities comply with directives from the reliability coordinator so the BES can be operated reliably in anticipated normal and contingency conditions. The Interconnection Reliability Operations and Coordination (IRO) standard that existed before IRO-004-2 was drafted was said to have had inaccurate language. NERC said that the retired parts of predecessor IRO-004-01 (requirements R1 through R6) are appropriately addressed in new reliability standards IRO-008-1, IRO-009-1, and IRO-010-1a.

Violations. The NERC standards enforcement team is out “writing tickets” and noncompliance can be costly. One of the charts Bull put up before the group showed that the average number of violations recorded monthly from Jan 1, 2011 through June 30, 2011 was 274. This number is trending upward. Between mid 2007 and mid 2011 nearly 7500 violations were identified.

He also had a chart of financial penalties that could be applied for each day that a violation continues, which range from $1000 for the lowest risk factor and severity level to $1 million for the highest risk factor and severity level.

The standards most often cited for noncompliance are these: PRC-005, over 750 violations; CIP-007, more than 600; CIP-004 and CIP-001, each over 470; CIP-006, more than 300.


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