WECC COMPLIANCE OUTREACH OPEN WEBINAR

WECC COMPLIANCE OUTREACH OPEN WEBINAR Thursday, July 17, 2014 2:00 pm MT

Agenda • CIP v5 Transition • SRS/RAS Schemes • TOP-007-WECC • Registered Entity Comparable Metrics • Self-Certification Validation • New Meeting Registration Site

Brent CastagnettoManager, Cyber Security Audits and Investigations CIP v5 Transition WECC Open Webinar Thursday, July 17, 2014

Phil O’DonnellManager Operations & Planning AuditsOpen Webinar July 17, 2014 Remedial Action Schemes/Special Protection Systems and Impact of TOP-007-WECC-1 Interpretation

Basic Protection System Actuating Device Sensing Device Relay Trip Circuitry Batteries or DC Supply

What is an SPS/RAS An automatic protection system designed to detect abnormal or predetermined system conditions, and take corrective actions other than and/or in addition to the isolation of faulted componentsto maintain system reliability. Such action may include changes in demand, generation (MW and Mvar), or system configuration to maintain system stability, acceptable voltage, or power flows. An SPS does not include: • underfrequency or undervoltage load shedding or • fault conditions that must be isolated or • out-of-step relaying (not designed as an integral part of an SPS). Also called Remedial Action Scheme.

Very Basic SPS/RAS Communications Communications and Trip Circuitry Actuating Device Sensing Device Outputs Actuating Device Sensing Device Sensing Device Actuating Device Logic Controller Batteries or DC Supply Actuating Device

Standards Related to SPS/RAS • EOP-004-2 – Event Reporting • IRO-005-3.1a- Reporting Status • PRC-015-0 - Data and Documentation • PRC-016-0.1 - Misoperations • PRC-017-0 Maintenance & Testing • PRC-005-2 Maintenance & Testing PRC standards apply to TO, GO or DP… “that owns an SPS”

Applicability of Standards • Application of standard requirements may depend on what part of an SPS an entity owns and what role they have in operating the scheme. • Any TO, GO or DP by virtue of registration. • Actual applicability depends on ownership and responsibility to scheme owner.

Applicability of Standards • It is possible for a TO, GO or DP that “owns” an element of a SPS/RAS to be considered as Not Applicable for some Standards related to SPS/RAS but fully responsible for others. • Reporting and Testing applicable to the “Scheme” Owner (entity serves as “Operator”). • Repair, Maintenance and Condition of elements applicable to “element” owner.

Compliance Expectations • Know if you own any element that is part of an SPS/RAS • Know who is responsible for testing and or maintenance for the SPS/RAS elements. • Know who is responsible for reporting status and who should receive the report. *Highly recommend developing procedures to clarify this.

TOP-007-WECC-1a

History… Since 2007 TOP-STD-007-0 TOP-007-WECC-1 TOP-007-WECC-1a • 13 Violations • All self-identified by entities registered as TOPs

Applicability before Interpretation TOP-STD-007-0 • This criterion applies to each Transmission Operator of a transmission path in the Attachment A – WECC Table 2 TOP-007-WECC-1 • Transmission Operators for the transmission paths in the most current Table titled “Major WECC Transfer Paths in the Bulk Electric System”

Interpretation Request • Request for clarification that the Requirement R1 applies “to Transmission Operators, as defined in the NERC Glossary of Terms, and not to the path operators who have no compliance responsibilities under TOP-007-WECC-1 (TOP), other than any responsibilities they may have as a Transmission Operator for facilities in their respective Transmission Operator Areas.”

Interpretation Response The document only applies to the stated Transmission Operators and does not apply to Path Operators. Oddly enough… • Every entity that would possibly be considered a “Path Operator” just happens to be registered as a Transmission Operator.

Applicability After Interpretation TOP-007-WECC-1a • Transmission Operators for the transmission paths in the most current Table titled “Major WECC Transfer Paths in the Bulk Electric System” Technically …No Change in applicability!

So What does this mean? • Previously there was probably some “assumption” that the designated Operating Agent was either the indicated TOP or at least the primary TOP. • “Operating Agent” identified from the voluntary RMS process which preceded Mandatory Standards.

So What does this mean? • TOP-007-WECC-1a becomes essentially a Regional standard which specifies more restrictive operating actions for each Transmission Operator which operates any elements of designated WECC Paths.

Paths • 40 identified paths defined in …. “Major WECC Transfer Paths in the Bulk Electric System” http://www.wecc.biz/Standards/Approved%20Standards/Supporting%20Tables/Table%20Major%20Paths%204-28-08.pdf

Summary of Requirements Actual flow cannot exceed path limit for more than 30 minutes. • (Essentially treated like an IROL with Tv of 30 minutes.) Scheduled flow cannot exceed value of SOL • (Technically this would also be a violation of INT-006 R1.2 for any TSP that was responsible for the excess schedule)

Who is this applicable to? • Are you registered as a Transmission Operator? • Are you responsible for Operation of any part of a specified path? • Switching or controlling devices • Monitoring • Scheduling or approval of Schedules

But who is really responsible? TOP-004-2 Transmission Operations R6. Transmission Operators, individually and jointly with other Transmission Operators, shall develop, maintain, and implement formal policies and procedures to provide for transmission reliability. These policies and procedures shall address the execution and coordination of activities that impact inter- and intra-Regional reliability, including: R6.1. Monitoring and controlling voltage levels and real and reactive power flows. R6.2. Switching transmission elements. R6.3. Planned outages of transmission elements. R6.4. Responding to IROL and SOL violations.

Audit Assessment Process • An Assessment of TOP-004-2 R6 shall be conducted anytime an assessment of TOP-007-WECC-1a is considered. • Expectation is that a review of the procedures which are required to be compliant with of TOP-004-2 R6 will clearly identify responsibilities for TOP-007-WECC-1a.

Entity (TOP) Expectation • Any TOP which is responsible for any monitoring or operation of any element associated with a specified path… Shall have procedures developed jointly with the other TOPs associated with the paths which clearly identifies responsibilities for monitoring and operation of the designated WECC Paths. (per TOP-004-2 R6)

Entity (TOP) Expectation • Any TOP which is responsible for any monitoring or operation of any element associated with a specified WECC path… Shall use and comply with the formal procedures to address excess flows and excess schedules on the specified paths.

Phil O’Donnell Manager Operations & Planning Audits podonnell@wecc.biz Questions?

Duane CookeCompliance Analyst Registered Entity Comparable Metrics and Self-Certification Validation July 17, 2014

Registered Entity Comparable Metrics • Beginning with data through 2nd Quarter 2014, WECC will publish a set of “Registered Entity Comparable Metrics” for the WECC Region on a quarterly basis • Metrics include: • Average Violations per Entity • Percent Violations by Discovery Method • Violation Distribution and Percent Self-Report Summaries

Registered Entity Comparable Metrics Why? • Entities have expressed interest in knowing how they compare with other Entities • Gives individual Entities ability to gauge performance with respect to the violation of Reliability Standard Requirements against WECC Regional averages and percentages • Allows Entities with different function configurations to compare to the WECC Regional averages and percentagesof similarly situated Entities • Provides internal tool for Entity compliance staffs

Registered Entity Comparable Metrics Key Points: • Metrics focus on the violation of Reliability Standard Requirements • WECC will publish updated metrics during the month following the end of each quarter • WECC will publish metrics on the WECC Website • http://www.wecc.biz/compliance/United_States/Pages/Fundamentals.aspx • Individual Entities calculate own metrics for comparison

Registered Entity Comparable Metrics Average Violations per Entity: • Shows the average number of violations per Entity 2007-to-date, and also segmented by year and by selected Registered Function Groups • The selected Function Groups are: • Entities with BA, TOP and/or RC Functions • Entities with TO Function • Entities with GO and/or GOP Functions • Entities without BA, RC, TO, TOP, GO and/or GOP Functions

Registered Entity Comparable Metrics Average Violations per Entity: • Calculated by dividing the total number of violations for all currently registered Entities and for each segmentation (year and selected Function Group) by the current number of Entities in the applicable segmentations

Registered Entity Comparable Metrics Average Violations per Entity: Group 1 - Entities with BA, TOP and/or RC Functions (As of 6/30/2014) Note: Excludes Entities not currently registered and violations with status of "Dismissed" or "Not Required“ * The current number of Entities is used for all years because a snapshot of the number of Entities at the end of each year is not readily available ** Year-to-date

Registered Entity Comparable Metrics Percent Violations by Discovery Method: • Shows the percent of violations by discovery method: Self-Report; Self-Certification; Audit; and Other (Spot Check, Periodic Data Submittal, Exception Report and Investigation) • Calculated by dividing the total number of violations for each discovery method by the total number of violations 2007-to-date • Not segmented by selected Function Groups - no significant difference in percentages

Registered Entity Comparable Metrics Percent Violations by Discovery Method: All Entities with Violations - 2007-to-Date (As of 6/30/2014) Note: Excludes Entities not currently registered and violations with status of "Dismissed" or "Not Required“

Registered Entity Comparable Metrics Violation Distribution Summary: Note: Excludes Entities not currently registered and violations with status of "Dismissed" or "Not Required“ Group 1 Entities with BA, TOP and/or RC Functions Average = 32.8

Registered Entity Comparable Metrics Percent Self-Reports Summary: Note: Excludes Entities not currently registered and violations with status of "Dismissed" or "Not Required“ All Entities with Violations Average = 55.9%

Self-Certification Validation • WECC Compliance is continuing the Self-Certification Validation effort initiated last year • WECC will: • Conduct validation of “Compliant” Self-Certifications submitted by U.S. Registered Entities for reporting year 2013 • Select random sample of Self-Certifications submitted as “Compliant” for a predetermined subset of Reliability Standard Requirements • CIP and O&P

Self-Certification Validation • WECC will: • Notify Entities with randomly selected Compliant Self-Certifications on or before August 1, 2014 • Issue Data Requests to Entities that submitted the Self-Certifications randomly selected • Ask for certain evidence to validate compliance • Review evidence • Notify Entities when validation is complete and identify any findings

Self-Certification Validation • All Data Request responses will be due September 15, 2014 • No action required by Entities not notified by WECC • Change from last year: Self-Certification submittals by Entities that have undergone, or are scheduled to undergo a Compliance Audit during 2014 (e.g. Entities with an Audit start date in 2014) will be excluded from population to be sampled

Duane Cooke Compliance Analyst Western Electricity Coordinating Council dcooke@wecc.biz 801-819-7639 Questions?

New Meeting Registration Tool July 17, 2014 WECC Compliance Open Webinar

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Western Electricity Coordinating Council Compliance Open Webinar July 17, 2014 Questions?

WECC COMPLIANCE OUTREACH OPEN WEBINAR