Susan Sosbe, WVPA COMPLIANCE

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NERC COMPLIANCE
REFRESHER TRAINING 2014
Susan Sosbe, WVPA COMPLIANCE
SS 3/19/14
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NERC REFRESHER TRAINING

• Quick Review What is NERC?
• Compliance Commitment
• Cooperative Responsibility Review
• Event Reporting Operating Plan and
• Procedure For Reporting a Potential
• Non-Conformance.

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NERC REFRESHER TRAINING

• WHAT IS NERC?
• North American Electric Reliability Corp.
• The mission of NERC is to ensure the reliability
  of the Bulk Electric System (BES) in North
  America (U.S. and Canada).
• Under the authority of FERC, NERC enforces the
  Reliability Standards with all entities who have
  registered in one (1) or more of the ten (10)
  industry segments defined by NERC.

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NERC EMPLOYEE TRAINING

• How Does NERC Apply To Wabash Valley?
• Reliability Standards are the planning and
  operating rules that Registered Entities must
  follow to ensure the most reliable system
  possible.
• Compliance is mandatory enforceable under the
  scope of NERCs Regulatory Authority.
• We must have Procedures and Documentation for
  each Standard/Requirement/Measure that is
  applicable to us.
• Wabash Valley falls under the jurisdiction of two
  (2) Regional Reliability Organizations
  (Reliability First Corporation-RFC and SERC
  Reliability Corporation-SERC).
• Co-ops in Indiana are in the RFC Region.
• Co-ops in Illinois and Missouri are in the SERC
  Region.
• Holland Energy, LLC is in the SERC Region.

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NERC EMPLOYEE TRAINING

• How Does NERC Apply To Wabash Valley?
• Currently, Wabash Valleys Registrations are
• Distribution Provider (DP) Provides and
  operates wires between the transmission system
  and the end-use customer. This registration
  incorporates our Co-ops.
• Load-Serving Entity (LSE) - Secures energy and
  transmission service (and related Interconnected
  Operations Services) to serve the electrical
  demand and energy requirements of its end-use
  customers.
• Purchasing Selling Entity (PSE) - The entity
  that purchases or sells, takes title to energy,
  capacity, and Interconnected Operations Services.
  
• Generator Owner (GO) - The entity that owns and
  maintains generating units. WVPA is the GO
  for the Wabash River Combined Cycle Plant
  (WRCCP). Duke is the Generator Operator (GOP)
  for this facility. We work together to ensure
  compliance for this facility. WVPA became the GO
  effective 9/7/11. WVPA is registered as a GO in
  the RFC Region only.

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NERC ANNUAL TRAINING

• Key Elements of Compliance
• Wabash Valley is committed to fulfilling all of
  its responsibilities and requirements under NERC.
• It is the responsibility of every Wabash Valley
  and Member Co-op Employee to follow the Policies,
  Procedures, and Requirements of the NERC
  Compliance Program.

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NERC ANNUAL TRAINING

• Compliance Program
• Goals and Objectives
• Ensure that WVPA complies with all applicable
  NERC, RFC, and SERC Reliability Standards, which
  in turn, supports the goal of reliable and secure
  power production and supply.
• Ensure that WVPA is prepared to provide required
  information and data to RFC, SERC, and NERC in
  order to demonstrate compliance with all
  applicable Reliability Standards.
• To build a Culture of Compliance.

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NERC ANNUAL TRAINING

• Co-op Responsibilities
• Complete Return Equipment Confirmation Form
  (annually).
• Conduct Employee Training Sessions (New
  Employees/Annual Refresher).
• For those Cooperatives with a Transmission
  Protection System (TPS), complete required
  inspections to ensure compliance with PRC-005-1a.
  Those Cooperatives with such systems are
  Jasper, Kosciusko, and Northeastern.
• Report any Transmission Protection System
  MisOperations ASAP to WVPA.
• Report Any Potential Non-Compliance Immediately.
• Report any Events that meet the WVPA Event
  Reporting Operating Plan criteria immediately.

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NERC EMPLOYEE TRAINING AUDIT SPOT CHECK
RESULTS
Entity Activity
Organization Results Holland
On-site Audit-09 SERC
Compliant WVPA Off-site Audit 09
RFC SERC Compliant WVPA CIP-1 Spot
Check (2009) RFC
Compliant WVPA PRC 1011 Spot Check
(2009) RFC Compliant WVPA
CIP-2 Spot Check (2010) RFC
Compliant Next SCHEDULED Audits are in 2015 for
both Holland and WVPA. WVPA Audit will also
include Generator Owner (GO) function for WRCCP.
Compliance is our
Commitment EVERYDAY.
PRC - Protection Reliability Control CIP
Critical Infrastructure Protection
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PLANS/PROCEDURES

• WVPA EVENT REPORTING OPERATING PLAN
• Replaces Disturbance Reporting and Sabotage
  Reporting,
• effective 1/1/14.
• Procedure For Reporting A Potential
• Non-Conformance, Procedure 5064.

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EVENT REPORTING OPERATING PLAN

• Purpose
• To outline the Protocol for reporting Events
  within timelines, and to the Entities, outlined
  in EOP-004-2 for BES Facilities.
• Events will be reported within 24 hours of
  recognition of meeting a Reportable Event type
  threshold and within the 1 to 6 hour reporting
  requirements of DOE, if applicable.

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EVENT REPORTING OPERATING PLAN
REPORTABLE EVENTS BY EVENT TYPE
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EVENT REPORTING OPERATING PLAN
REPORTABLE EVENTS BY EVENT TYPE
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WVPA REPORTING GUIDELINES BASED UPON EVENT TYPE
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WVPA REPORTING GUIDELINES BASED UPON EVENT TYPE
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EVENT REPORTING OPERATING PLAN

• Protocol
• Contact Susan, Brent, Kari, or Lee.
• Work with WVPA to complete appropriate
  documentation (NERC Event Report Form/DOE
  OE-417).
• Co-ops use Event Reporting System.
• Susan will handle reporting to appropriate
  Entities.
• Act of Terrorism
• Susan will report to the Joint Terrorism Task
  Force (JTTF).
• Contacts must be verified annually and
  verification must be documented (Susan).

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PROCEDURE FOR REPORTING A POTENTIAL
NON-CONFORMANCE
Procedure Purpose To outline the steps that
internal external personnel must follow in
order to properly report a potential
non-conformance pursuant to NERC
Compliance. PLEASE REPORT IMMEDIATELY UPON
DISCOVERY!
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PROCEDURE FOR REPORTING A POTENTIAL
NON-CONFORMANCE

• Procedure Steps
• WVPA Employee, Co-op, or an external entity
  becomes
• aware of a potential non-conformance. They
  report it
• to one of the following personnel
• - WVPA Compliance Manager
• - WVPA Vice President, Power Supply
• - WVPA President/CEO
• - WVPA Legal Counsel

Communication Flow
Depending upon the severity, the WVPA Board of
Directors may also be notified. Depending upon
circumstance, Co-op Board of Directors may be
notified as well.
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PROCEDURE FOR REPORTING A POTENTIAL
NON-CONFORMANCE
Procedure Steps

• The WVPA Compliance Manager investigates
• documents the potential non-conformance.
• If the issue is NOT a non-conformance, the WVPA
• Compliance Mgr. will communicate the status,
  implement
• improvement measures, and will retain all
  documentation.
• If the issue IS a non-conformance, the WVPA
• Compliance Mgr. will
• Report to the Appropriate Agency Develop a
  Mitigation Plan
• Implement Corrective Actions
• Communicate Status
• Retain All Documentation.

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NERC NEW EMPLOYEE TRAINING

• Remember,
• Failure to Comply with NERCs Reliability
  Standards is SERIOUS BUSINESS and can result in
  large fines, damage to our credibility, and
  potentially, loss of business. Most importantly,
  the reliability of the Bulk Electric System (BES)
  could be affected.
• Highest fine in 2014 to date 465,000
• An Unidentified Entity in the WECC Region was
  found to be in violation of three (3) Critical
  Infrastructure Protection (CIP) Standards and
  eight (8) Requirements.
• Highest fines in 2013
• 725,000 for CIP Violations (10 Standards, 33
  Requirements) Unidentified Entity in RFC
  Region.
• 650,000 for Non-CIP Violations, Metropolitan
  Edison RFC Region. FAC-003-1, R2.
• Highest fine in 2012 950,000
• A company in the SERC Region was found to be in
  violation of seven (7) CIP Standards and
  twenty-four (24) Requirements.

Highest Fine to Date 2010 25 million
Florida Power and Light.
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NERC ANNUAL REFRESHER TRAINING

• QUESTIONS?
• Please contact
• Susan Sosbe, Compliance Manager
  
• Office 317-481-2848 Cell
  317-430-5175