By Leland McMillan, NERC Services Supervisor
NAES’s WECC-Lead, Leland McMillan (Supervisor, NERC Services), recently attended via webinar the WECC Reliability & Security Workshop meeting held on October 27-28. NAES NERC Services has summarized the conference’s presentation information to provide your plant the opportunity to better understand WECC’s regulatory focus and interpretation and stay ahead of all future regulatory standards/requirements potentially impacting your plant. To provide you with a quick summary for reference, here is a list of key takeaways:
FAC-008 Facility Ratings: Guided Self Certification Walkthrough Presentation
-WECC provided an overview of Guided Self Certification process, which is essentially an audit.
FAC-008 general tips include:
▪ Entity must identify most limiting and second most limiting elements. If not evident, documentation is incomplete and must be resubmitted with elements clearly marked as most limiting
▪ Address all requirement of the standard elements. If you don’t have an element state that the plant does not have i.e. wave traps. This indicates to WECC that you have reviewed the applicability of all required elements.
▪ Review your most current One-Line Diagram and make sure that it has been updated and includes the entire footprint of the entity.
▪ The documentation shall be consistent with the principle that the
Facility Ratings do not exceed the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility. Therefore, all elements must be identified between the generator and the low side terminal or high side bushing.
▪ The scope of equipment addressed shall include, but not be limited to, conductors, bus bars, transformer, protective devices such as breakers and CTs, jumpers, any type of metering CTs, etc.
▪ Generator Owner should state whether it owns the Generator Step-up transformer (GSU) and identify the GSU’s rating
▪ NERC Glossary of Terms defines Element as an electrical device: Would not include mechanical devices (turbine, shaft, mechanical coupling, fuel flow restrictions, etc.) that may affect the capability of a generator
R2 does require an FRM: Must list all elements of the facility from the GSU to breaker protection at the substation to which it connects.
▪ R2 also requires, “Ambient conditions (for particular or average conditions or as they vary in real-time),” and “The scope of Ratings addressed shall include, as a minimum, both Normal and Emergency Ratings”
▪ FRM should address ambient conditions how they impact elements subject to ambient temperatures such as conductors, transformers and any protection equipment
▪ Joint or shared facilities should include all elements of the facility. Ownership does not terminate the responsibility of the ratings. Entities must communicate and coordinate with their neighbors when determining the list of elements of the facility and their ratings of joint or shared facilities.
▪ If IEEE Standards are used as references in the FRM, the entity must explain how the IEEE Standard is used and identify the page number(s) in the reference. Simply stating an IEEE Standard without any narrative on how it applies to establishing the ratings of the equipment is not sufficient.
▪ Operating limitations must be explained in the FRM document.
-Can include temporary derates, voltage limitations, and stability issues that impact a facility rating
Documentation Preparation and Checklist Activities Presentation
*Value of checklists
• Added Bonus—reduced Data Requests
*WECC Provided details on audit objectives and relation of risk, sufficiency, and appropriateness to evidence and audit evaluations including information on internal controls.
*Slides 12-18 demonstrate examples of good vs bad evidence
*Slides 19-23 provide helpful tips for PRC-005 Protection System Maintenance and FAC-008 Facility Ratings evidence (calculations and assumptions)
*Slides 24-25 demonstrates a VAR-002 voltage schedule example settings max/min voltage measured
*Indexing is an effective method to summarize evidence (Slides 28-30), file names should identify evidences.
Mock Audit Experience CIP-003, R2: Low Impact Presentation
*WECC will initiate data request for audit using the CIP Evidence Request Tool:
*WECC validated required actions and deadlines on slides 9-10
*Audit approach broken down as follows:
-Section 1: Cyber Security Awareness slides 12-16
*Section 2: Physical Security Plan slides 17-28
*Section 3: Electronic Security Plan slides 30-60
*Section 4: Cyber Security Incident Response Plan slides 61-68
*Section 5: Transient Cyber Asset/Removeable Media slides 69-81