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Problem Areas Updates Penalties. FRCC Compliance Workshop September / October 2008. Problem Areas. NERC Top Violations since 6/18/2007 FRCC Top Violations since 6/18/2007 NERC Examples - PER-003, PRC-005, CIP-001, EOP-005, FAC-008, FAC-009. Problem Areas -NERC Top Violations.

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problem areas updates penalties

Problem Areas Updates Penalties

FRCC Compliance WorkshopSeptember / October 2008

problem areas
Problem Areas
  • NERC Top Violations since 6/18/2007
  • FRCC Top Violations since 6/18/2007
  • NERC Examples - PER-003, PRC-005, CIP-001, EOP-005, FAC-008, FAC-009
problem areas frcc possible violations
Problem Areas –FRCC Possible Violations

Reported Since June 18, 2007

  • PER-003 – Operating Personnel Credentials
  • PRC-005 –Transmission & Generation Protection System Maintenance & Testing
  • CIP-001 – Sabotage Reporting
  • EOP-005 – System Restoration Plans
  • FAC-008 – Facility Ratings Methodology
  • FAC-009 – Establish & Communicate Facility Ratings
problem areas1
Problem Areas

The following are examples of non-compliance problems found throughout NERC for specific Standards.

problem areas per 003
Problem Areas – PER-003
  • Having NERC Certified Operators on duty at all times.

Operating Personnel Credentials

problem areas prc 005
Problem Areas – PRC-005
  • The Protection System Maintenance and Testing Program does NOT exist
  • The documentation of the maintenance and testing plan/program has not been maintained according to standard requirements (i.e. within specified intervals and their basis)
  • Testing records of all Protection System devices have not been maintained

Transmission & Generation Protection System Maintenance and Testing


Problem Areas – CIP-001

  • Incomplete documentation
    • The document doesn’t exist
    • The document does not define or provide examples of what sabotage is
    • Reporting Plan is not included in the document
        • including specific contact information for local, state, federal enforcement agencies and the region
  • Sabotage Reporting

Problem Areas – EOP-005

  • Incomplete Documentation
    • The System Restoration Plan document does not exist
    • The System Restoration Plan is out of date
  • Evidence that the restoration plan is reviewed annually
  • Evidence that the System Restoration Plan is being coordinated with the entity’s neighbors
  • Evidence that training on the System Restoration Plan has taken place
  • Evidence that the System Restoration Plan is being tested through actual testing or simulation
  • System Restoration Plans

Problem Areas – FAC-008

  • Facility Rating Methodology is not documented or incomplete
    • The Facility Ratings Methodology did not contain a statement that a Facility Rating shall equal the most limiting element
    • Not all of the component equipment ratings were included when the overall Facility Rating is determined
  • Facility Ratings Methodology

Problem Areas – FAC-009

  • Ratings were inconsistent with the associated Facility Ratings Methodology document. (FAC-008)
  • Lack of Evidence that ratings have been communicated to the RC, PA, TP, TOP
  • Establish and Communicate Facility Ratings

Problem Areas – Lessons Learned

  • Read the standards - including the RSAWs
    • What are the standards asking for?
    • Talk with others, what did they do?
    • Ask questions, the FRCC Compliance staff will help as much as we can
  • Good documentation is critical
    • Make sure you have what is needed
    • If not, create what is needed
    • Maintain it once its in place
    • Update it as required
    • Management approval, with effective date
  • Educate and Train your employees and management
  • Have good quality up-to-date procedures
  • 2009 FRCC Compliance Activities
  • FAQ – Frequently Asked Questions
updates 2009 activities
Updates – 2009 Activities
  • 19 On-Site Audits
  • CIP-002 through CIP-009 Self Certification
  • CIP-002 through CIP-009 Spot Checks will be done On-Site (starting in July)
        • BAs & TOPs under UA-1200
      • Annual Compliance Workshop (1 or 2)
updates 2009 activities1
Updates – 2009 Activities
  • Annual Self Certification
      • CTS – Adding Features
        • User Group
      • Annual Spot Check
updates faq
Updates – FAQ


  • Expand the Frequently Asked Compliance Related Questions section on the FRCC Website
    • Important information related to specific Standards and Requirements
  • Penalty Calculation
  • Reducing Penalties
  • Avoiding Penalties
penalties calculation1
PENALTIES - Calculation
  • FERC expects penalty to be calculated on a per day per violation basis
    • This could be from $1,000 up to a $1,000,000per day, per violation
  • Final Penalty Assessment can ratchet up or down pending on the entities actions
penalties reducing or increasing
PENALTIES – Reducing (or Increasing)
  • Adjustment Factors per Violation / Violator
    • Repetitive Violations
    • Violator’s Compliance History
    • Failure to Comply with Compliance Directives
    • Degree and Quality of Cooperation
    • Compliance Program Quality
    • Attempt to Conceal the Violation
    • Intentional Violation
    • Extenuating Circumstances
penalties reducing
PENALTIES - Reducing
  • Settlements preferred
    • Can occur anytime up to the filing of the Notice of Penalty to FERC!
penalties reducing1
PENALTIES - Reducing
  • Mitigation Plan submittals and timeliness
    • Every violation of a standard requires mitigation
    • Mitigation should begin when a possible violation is identified
      • FRCC accepts the Mitigation Plan
      • NERC approves the Mitigation Plan
penalties reducing2
PENALTIES - Reducing
  • Mitigation Plan submittals and timeliness (continued)
    • Follow the Standard
    • Accurate and Complete
    • Measureable milestone dates
    • Reasonable completion date
penalties reducing3
PENALTIES - Reducing
  • Mitigation Plan submittals and timeliness (continued)
    • Must submit evidence with completion form for FRCC Compliance staff to verify MP completed and in compliance
    • A Request for an extension (at least 5 days prior)



penalties avoiding
PENALTIES - Avoiding
  • Reliability Standards – Linda
    • Understand the Standards
    • Identify the Standards that are applicable to you
    • Participate in the Standards process both with NERC and FRCC
penalties avoiding1
PENALTIES - Avoiding
  • Audit Preparation – Barry
    • Determine what you are responsible for
    • Establish / Assign Ownership
    • Organize your Evidence
penalties avoiding2
PENALTIES - Avoiding
  • Quality of Evidence – Jim
    • Appropriate and Sufficient to meet the requirement and standard
    • All evidence needs to be basedonfacts
    • Quality not necessarily Quantity
q a s
Q & A’s
  • Final Questions and Answer Session
  • Topics for 2009 Compliance Workshop