Mike WellsSenior Compliance AuditorPER-005-1 CUG Meeting June 3-4, 2014 Salt Lake City, Utah
Introduction – Mike Wells WECC Sr. Compliance Auditor • Power Industry for 40 years • Certified Switchman, Power Plant Operator • System Dispatcher, Chief Dispatcher • WECC Staff for over 11 years • Sr. Compliance Auditor – 6 years • Member NERC Personnel Subcommittee • Member of initial PER-005-1 SDT • Chair, WECC Operations Training Subcommittee • Director Market-Operations Interface
This Presentation • Explain the Audit Approach for R1.1, entity to create list of reliability-related tasks upon which the training program is developed • Seed the panel Q&A session on all facets of PER-005-1
DISCLAIMER • This material presented by a WECC Compliance Auditor is accurate to the best of our understanding, and all the information is provided in good faith. If in conflict with NERC, FERC, or other statutory requirements, NERC standards and Rules of Procedure take precedence over any material or information provided in this presentation. • This presentation contains information that is intended to support the compliance process across North America. Before relying solely on the information in this presentation, users should independently verify its accuracy, completeness, and relevance for their purposes and that it is up-to-date.
The Word on the Street It has been said Audit Teams are: • Not auditing to the standard • PER-005-1 Outreach has been insufficient • Nit Picking the task lists • Looking for certain number of tasks • Issuing Possible Violations but should be issuing Area of Concern or Recommendation
PER-005-1: System Personnel Training R1 Each entity shall use a systematic approach to training to establish a training program for the BES, company-specific reliability-related tasks performed by its System Operators and shall implement the program. Note the training program associated with Reliability Standards is established for the identified tasks.
PER-005-1: System Personnel Training R1.1 Each entity shall create a list of BES company-specific reliability-related tasks performed by its System Operators.
R1.1: Task Lists So the entity simply provides the list of tasks and auditors give them a No Finding. Right??? Wrong???
2013 WECC Trainers Workshop Below is an excerpt from Slide 72: The WECC approach is the entity is to identify all the BES reliability-related tasks performed by its system operators. This does not mean the task lists are automatically deemed sufficient. If a review of the tasks results in concern there are additional tasks being performed by the operators, there may be cause for a violation or area of concern.
R1.1: Task Lists So the entity simply provides the list of tasks and auditors give them a No Finding. Wrong
Reliability Related Tasks The standard does not define a real-time reliability related task. Entities must identify tasks performed by their system operators that can impact their system’s reliability. At one time, the standard contained examples of reliability‐related tasks, but industry felt including these would imply the examples were prescriptive and had to be used, thus they were removed.
Reliability Related Tasks QUESTION to Ponder Is a reliability-related task only those that address an emergent condition with a potential that instability, uncontrolled separation or cascading failures may occur? Or, Is a reliability-related task those tasks that must be performed only by a NERC-certified System Operator?
PER-003-1: Operating Personnel Credentials PER-003-1 Section 3. Purpose: To ensure that System Operators performing the reliability-related tasksof the RC, BA and TOP are certified through the NERC System Operator Certification Program when filling Real-time operating position responsible for control of the Bulk Electric System. (Underline added)
PER-003-1: Operating Personnel Credentials R1, R2, R3 have this in common: The RC, BA and TOP shall staff its Real-time operating positions performing reliability-related tasks with System Operators who have demonstrated minimum competency in the areas listed by obtaining and maintaining one of the following valid NERC certificates… (Underline added)
PER-003-1: Operating Personnel Credentials Reliability Coordinator 1.1. Areas of Competency 1.1.1. Resource and demand balancing 1.1.2. Transmission operations 1.1.3. Emergency preparedness and operations 1.1.4. System operations 1.1.5. Protection and control 1.1.6. Voltage and reactive 1.1.7. Interchange scheduling and coordination 1.1.8. Interconnection reliability operations and coordination
PER-003-1: Operating Personnel Credentials Transmission Operator 2.1. Areas of Competency 2.1.1. Transmission operations 2.1.2. Emergency preparedness and operations 2.1.3. System operations 2.1.4. Protection and control 2.1.5. Voltage and reactive
PER-003-1: Operating Personnel Credentials Balancing Authority 3.1. Areas of Competency 3.1.1. Resources and demand balancing 3.1.2. Emergency preparedness and operations 3.1.3. System operations 3.1.4. Interchange scheduling and coordination
Audit Teams Audit Area of Concern Definition An Area of Concern is defined as a situation that does not appear to involve a current or ongoing violation of a Reliability Standard requirement, but instead represents a situation or practice that could become a violation if not corrected.
Audit Teams Audit Recommendation Definition A Recommendation is a notification to a registered entity of a situation where there may be opportunity for improving compliance related processes, procedures or tools.
Examples of Audit Team Options Professional Judgment: Size, Scope, Risk • Informal Suggestion:possible;add/delete a few of tasks to strengthen the list. • Recommendation: possible; if doubt entity will do it, review and strengthen level of details in the tasks. • Area of Concern:unlikely; tasks or fundamental areas are so limited a subsequent audit team might find a PV • Possible Violation:very unlikely; if tasks apply only to emergencies, or missing entire fundamental topic areas.
The Word on the Street Entities nearly always say they want audit team Recommendations But does this apply to the Compliance Staff? SMEs? Both?
Audit Findings for PER-005-1 R1.1 Number of Audits = No Finding = Possible Violation = Area of Concern = Recommendations =
Questions? Michael Wells WECC Compliance Staff Sr. Compliance Auditor 801-883-6884 firstname.lastname@example.org