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WECC COMPLIANCE OUTREACH OPEN WEBINAR. Thursday, May 15, 2014 2:00 pm MT. Agenda. CIP v5 Updates – B. Castagnetto BES Primer – B. Sudduth & K. Wilson Website Confidentiality – C. Albrecht TOP-001 R3 – P. O’Donnell & J. McGhee PRC-005 Workshop – P. O’Donnell & L. Scholl.

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wecc compliance outreach open webinar

WECC COMPLIANCE OUTREACH OPEN WEBINAR

Thursday, May 15, 2014

2:00 pm MT

agenda
Agenda
  • CIP v5 Updates – B. Castagnetto
  • BES Primer – B. Sudduth & K. Wilson
  • Website Confidentiality – C. Albrecht
  • TOP-001 R3 – P. O’Donnell & J. McGhee
  • PRC-005 Workshop – P. O’Donnell & L. Scholl
brent castagnetto manager cyber security audits and investigations

Brent CastagnettoManager, Cyber Security Audits and Investigations

CIP v5 Update

WECC Open Webinar

Thursday, May 15, 2014

lisa wood cisa cbrm cbra compliance auditor cyber security

Lisa Wood, CISA, CBRM, CBRACompliance Auditor, Cyber Security

CIP-003-6 R2 Low Impact Update

May 15, 2014

agenda1
Agenda
  • SDT Progress
  • CIP-003-6 R2 Draft Language
  • Anticipated Dates
  • Comment Form
cip 003 5 r2 progress
CIP-003-5 R2 Progress
  • The Standard Drafting Team (SDT) has been hard at work
    • Still working on the requirements, measures, and rationale.
    • CIP-003-5 draft is now CIP-003-6
    • Nothing is final as of yet
    • Changed to table format
cip 003 6 r2 current draft
CIP-003-6 R2 Current DRAFT

R2. Each Responsible Entity for its assets containing low impact BES Cyber Systems shall:

cip 003 6 r2 anticipated dates
CIP-003-6 R2 Anticipated Dates
  • If you’d like to get on the SDT_plus distribution list, contact Ryan Stewart with NERC at: ryan.stewart@nerc.net
wrap up
Wrap-up
  • Stay tuned for more information surrounding low impact BCS.
slide14
Questions?

Lisa Wood, CISA CBRM, CBRA

ComplianceAuditor, Cyber Security

lwood@wecc.biz

Desk: 801-819-7601

Cell: 801-300-0225

kenneth wilson wecc staff

Kenneth WilsonWECC Staff

Bulk Electric System (BES) Definition Update

May 15, 2014

Outreach Webinar

bes definition at a glance
BES Definition at a Glance
  • Consistent, uniform way to determine BES assets
  • Effective 7/1/2014
  • Transition period through 7/2016
  • ERO enterprise common process and tool for implementation
  • Documents and training readily available
  • BES web page – one stop shopping
  • Regional and NERC staff resources available to answer detailed questions and implementation
bes core definition
Bulk Electric System (BES): Unless modified by the lists shown below, all Transmission Elements operated at 100 kV or higher and Real Power and Reactive Power resources connected at 100 kV or higher. This does not include facilities used in the local distribution of electric energy.

Establishes the overall demarcation point between BES and non-BES Elements.

BES ‘Core’ Definition
bes definition inclusions
Provide additional clarification for the purposes of identifying specific Elements that are included in the BES. 

I1. BES Transformers

I2. Real Power Resources

I3. Blackstart Resources

I4. Dispersed power producing resources meeting certain criteria

I5. Reactive Power Resources

BES Definition Inclusions
bes definition exclusions
Provide additional clarification for the purposes of identifying specific Elements that may be excluded from the BES. 

E1. Radial Systems

E2. Retail Generation

E3. Local Networks

E4. Reactive Power Devices installed solely for retail customers

BES Definition Exclusions
how to apply the bes definition inclusions and exclusions
Consistent methodology outlined in the BES Definition Reference Document

STEP 1: CORE DEFINITION

STEP 2: INCLUSIONS

STEP 3: EXCLUSIONS

STEP 3: EXCLUSIONS should be applied in the following sequence:

E2 Retail Generation (supersedes I2 Real Power Resources)

E4 Retail Reactive Power Devices (supersedes I5 Reactive Power Resources)

E3 Local Networks (does not exclude interconnection facilities or generators)

E1 Radial Systems (does not exclude interconnection facilities or generators)

How to Apply the BES Definition, Inclusions, and Exclusions
bes notifications
BES Notifications
  • Applies to newly self-identified inclusions to and exclusions from the BES
  • Assures that entities are appropriately implementing the revised definition
  • Compliance obligations cease for facilities excluded from the BES
  • 24-month implementation period to bring newly-identified Facilities included in the BES into compliance
self determination notification information requirements
Self-Determination Notification Information Requirements
  • Each notification should at a minimum include the following:
    • Current one-line diagrams
    • For E2 Retail Generation Exclusion notifications
      • Net Capacity Transactional Data (12 months of hourly data)
      • Standby, back-up and maintenance power service documentation
  • For E3 Local Network Exclusion notifications
    • Power Flow Transactional Data (24 months of hourly data)
bes exception requests
BES Exception Requests
  • Considerations:
  • Applicable to all Exception Requests
  • Applicable to specific Elements or groups of Elements

Must demonstrate that the requested facilities are (for inclusions) or are not (for exclusions) necessary for the reliable operation of the interconnected transmission system

who can submit an exception request
Who can Submit an Exception Request?
  • Owner of the Element(s)
  • Regional Entity
  • Entity with Scope of Responsibility for the Element(s) under consideration:
    • Regional Entity
    • Planning Authority
    • Reliability Coordinator
    • Transmission Operator
    • Transmission Planner
    • Balancing Authority
the exception request process
The Exception Request Process

Submitting Entity prepares Exception Request

RE initial screening and applicable entity input

Appeal of Rejection based on completeness

Up to 75 days

RE substantive review and recommendation

Technical Review Panel input

(if applicable)

Up to 6 months

NERC Panel Review and Decision

Challenge of NERC Decision

(Rule 1703)

Up to 120 days

many resources to assist you
Many Resources to Assist You
  • Bulk Electric System Definition Reference Document

Describes the application of the BES Definition

  • BES Notification Review Guidelines

Describes how ERO Enterprise staff will review Self-Determined Notifications submitted through BESnet

  • BES Exception Request Evaluation Guidelines

Describes how ERO Enterprise staff will review Exception Requests submitted through BESnet

  • BES Implementation Reference Document

Outlines standards applicability and registration expectations

  • BESnet Application Users Guide

Manual for the online BESnet application

for additional information
For Additional Information
  • Go to www.nerc.com
  • Under Program Areas and Departments, click Reliability Assessment and Performance Analysis
  • From there, click

Bulk Electric System (BES) Definition, Notification, and Exception Process Project

for additional information1
For Additional Information

http://www.nerc.com/pa/RAPA/Pages/BES.aspx

besnet schedule
BESnet Schedule
  • May 12, 2014: BESnet system available for each registered entity’s BESnet Administrator to create an ERO Platform account and/or request access to BESnet
    • Access requests will be reviewed by Regional BESnet Administrators
  • May 30, 2014: BESnet system available for each registered entity’s BESnet users to create an ERO Platform account and/or request access to BESnet
    • Access requests will be reviewed by Entity BESnet Administrators
  • July 1, 2014: BESnet system available users to submit Self-Determined Notifications and Exception Requests
    • Notifications and Exceptions will be processed by Regions and NERC
besnet training schedule
BESnet Training Schedule
  • BESnet Training Schedule (tentative)
    • May 15-30 – NERC will post
      • BESnetVideo Training Modules
      • BESnetUser Guides
      • BES Business Process Video Training Modules
    • June 2 – BES Business Process Q&A Webinar
    • June 4 – WECC BESnet Training at CUG meeting
besnet training schedule1
BESnet Training Schedule
  • BESnet Training Schedule (tentative)
    • June 10 – Standing Committee Q&A Workshop
    • June 16 – BES Business Process Q&A Webinar
    • June 23 – BES Business Process Q&A Webinar
    • June 30 – BES Business Process Q&A Webinar
    • June TBD – NERC BESnet Training Webinar
wecc staff contacts
WECC Staff Contacts
  • Application of “Core” Definition and Definitional Exclusion Submittals, De-registration Process
  • Notification of Self-Determinations
  • Rules of Procedure Exception Process
  • Contacts
    • WECC Support
      • Support@wecc.biz, Tel. (801) 883-6879, or
    • Kenneth Wilson
      • Email: ken@wecc.biz, Tel. (801) 883-6886
chris albrecht legal counsel

Chris AlbrechtLegal Counsel

WECC Confidentiality Agreement

WECC Open Webinar

May 15, 2014

background
Background
  • WECC Information Sharing Policy (ISP) - Confidential Information may only be shared with persons who have:
    • demonstrated a legitimate need; and
    • have executed a non-disclosure agreement.
  • ISP presumes that WECC members have a legitimate need.
agreement
Agreement
  • Acceptance of the WECC Confidentiality Agreement is required to access non-public information on the WECC website.
  • May agree via the pop-up or print, sign and mail to WECC.
  • Without agreement, access to Confidential Information on the WECC website will be removed (can still access public portions).
individual basis
Individual Basis
  • Website interaction, logins and permissions are all on an individual basis.
    • WECC determined responsibility and agreement should be at the individual level.
  • Concerns with acting in individual capacity
    • Implemented suggestion of members/federal entities
    • Opportunity to specify whether acting as authorized representative of an employer
other wecc ndas
Other WECC NDAs
  • The WECC Synchrophasor and Operating Reliability Data Sharing Agreement (UNDA) not sufficient
    • Does not cover all information on the WECC website.
    • Applies only to synchrophasor and operating (system control/metered) data submitted to Peak Reliability.
    • Current plan is to assign UNDA to Peak Reliability.
  • There is no other WECC NDA that covers all confidential information on the WECC website.
questions
Questions

Chris Albrecht

WECC Legal Counsel

801-819-7616

calbrecht@wecc.biz

reliability directives wecc open webinar may 15 2014

Reliability DirectivesWECC Open WebinarMay 15, 2014

Phil O’Donnell

Manager, Operations and Planning Audits

generic directive language deconstructed
Generic Directive Language Deconstructed

The receiver of the directive

“shall comply with reliability directives issued by…”

the issuer of the directive…

“unless such actions would violate safety, equipment, regulatory or statutory requirements”.

“Under these circumstances”

the receiver of the directive

“shall immediately inform”

the issuer of the directive

“of the inability to perform the directive so that”

the issuer of the directive

“can implement alternate remedial actions”.

what you s hould n ot d o
What You Should Not Do.
  • Receiver is not expected to take directive actions which would
  • Jeopordize safety
    • This includes safety of your company personnel and safety of the public
  • Damage equipment
    • Should not be expected to damage equipment or exceed any limits which could violate operating requirements
  • Violate regulatory requirements
    • Do not follow one regulation which violates another
  • Violate statutory requirements
    • Do not break the law
be aware
Be Aware
  • Issuer of the directive will generally be focused on a bigger picture of the situation.
  • Receiver may not initially be provided all of the information.
  • Time may be critical. (for reliability conditions)
  • Issuer knows that load shed will impact street lights and elevators and can have some safety impacts.
  • Issuer may not know of unusual local conditions, unique circumstances, laws or regulations.
your obligations
Your Obligations
  • Inform the issuer of the directive if complying with the directive as issued would cause any impact on safety, equipment or other regulatory or legal obligations.
  • Offer any alternatives you can come up with.
  • Agree on expectations and outcomes.
    • The directive as issued may be the only option.
slide46
Phil O’Donnell

Manager, O&P Audits & Investigations

podonnell@wecc.biz

phil o donnell and laura scholl

Phil O’Donnell andLaura Scholl

PRC-005 Workshop

July 29 – 30, 2014

Salt Lake City, UT

upcoming events
Upcoming Events
  • WECC Compliance 101 Webinar | May 29 - 2:00p MT
  • WECC CUG & CIPUG Meetings | June 3 - 5 in Salt Lake City
  • WECC Open Webinar | June 19 – 2:00p MT
  • WECC PRC-005 Workshop | July 29 – 30 in Salt Lake City
slide49
WECC Open Webinar

May 15, 2014