NERC Reliability Readiness The Next Steps Mitch Needham NERC Readiness Evaluator September 24, 2007

About the Speaker BSEE from the University of Tennessee, Knoxville, 1978 MS Engineering from the University of Tennessee, Chattanooga, 1985 28½ Years with the Tennessee Valley Authority Energy Research Protective Relaying Event Analysis Performance Benchmarking Regulatory Compliance Joined NERC as a Readiness Evaluator 10/2006

Readiness - Brief History Reliability coordinator ‘audits’ conducted since 2001 February 10, 2004 - NERC Board of Trustees approved Recommendation 3 Jointly establish a program to audit the reliability readiness of reliability coordinators and control areas on a three-year cycle Establish a set of baseline audit criteria U.S. Canada Power System Outage Task Force Report – August 14, 2003 Blackout Recommendation 18 Supported NERC Board recommendations Added public posting of audit reports To respond to the sweeping industry changes, in the mid 1990’s NERC began to set the course for the future. In 1997, an independent “blue ribbon” panel formed by NERC, and an Electric System Reliability Task Force established by the U.S. Department of Energy, both determined that in an increasingly competitive marketplace, reliability rules for the bulk electric system in North America had to be made mandatory and enforceable. These groups separately recommended that a single, independent self-regulatory electric reliability organization (ERO) be established to develop and enforce electric reliability rules throughout North America. Both groups also concluded that federal legislation was needed in the United States to accomplish this. Something that became a reality in 2005. A number of other industries with enforceable standards were reviewed to determine the best model for the electric utility industry. The NERC program was designed similar to the securities industry where the legislative authority is vested in the Securities and Exchange Commission and the actual compliance monitoring is accomplished by an industry self-regulatory organization, the National Association of Security Dealers (NASD) regulation division among others.

Basis for Readiness Evaluations Operational Excellence RC TOP BA Readiness Standards cannot prescribe every aspect of reliable operations. Standards set minimum thresholds, not targets for performance.

Original Program Application Establish the Readiness Audit Program for reliability coordinators, transmission operators, and balancing authorities Program organizationally aligned with compliance and enforcement program Make recommendations to audited entities that address deficiencies and promote compliance Publicly post audit reports

Presentation Focus Findings from the first cycle of ‘audits’ (Round 1) Changes made to the readiness program (Round 2) Steps to be taken in the future (initiatives)

NERC Reliability Readiness Findings from Round 1 7

Audits by Function

Recommendations by Function

Recommendations By Function(s) *** This data has been normalized by the number of recommendations made per function and the number of evaluations completed per function

Recommendations By Region *** This data has been normalized by the number of recommendations made per region and the number of evaluations completed per region

20 Areas Evaluated Agreements Operator Authority Delegation of Authority Staff Certification Training Operating Policies and Operating Procedures Planning Outage Coordination and Communication Plans for Loss of Control Facilities Tools Load Shedding Plans Real-Time Monitoring System Restoration Capacity and Energy Emergency Plan Equipment Maintenance and Testing Vegetation Management Nuclear Power Plant Requirements Physical Security Cyber Security Infrastructure

Recommendations Data 163 Audits/Evaluations completed 2727 Total Recommendations 426 Open (15.6 %) 677 In Progress (24.8 %) 1540 Completed (56.5 %) 84 No Action (3.1 %)

Grouping of Recommendations

Areas Evaluated 48% of the 2727 recommendations found in 3 areas Training Real-Time Monitoring Operating Policies and Procedures

Areas of Interest – Top 3

Training By Category

Recommendation Status By Year

NERC Reliability Readiness Changes Made for Round 2 19

Response to Industry Feedback Increased consistency (NERC staffing and contractors) Reduction of preparation time by focusing on demonstration and observation Review the link to compliance Changed from “audit” to “evaluation” Re-aligning NERC Reduce on-site evaluation time – (under investigation) Increased flexibility of on-site schedule – (under investigation) Limit the evaluation scope Higher degree of focus on targeted topics Size of entities should be considered – (under investigation)

Revamped Readiness Evaluation Program Shifted to a framework used in the nuclear industry Developed by a self-regulatory organization Uses an evaluation process refined over nearly 25 years Consists of cycled evaluations of many nuclear power plants Based on a documented set of principles, objectives, and criteria that support operational excellence of plant operations

2004-2007 Framework Operational Excellence/Readiness Core Principles Not Documented Core Principles Performance Objectives Performance Objectives Performance Objectives Criteria Criteria Criteria Criteria Criteria Criteria Readiness Topics Readiness Topics Readiness Topics Auditor Guides Auditor Guides Auditor Guides

Five Major Program Groupings Culture Corporate support of reliability Fundamentals of Operations System operators, operations management, operator tools, infrastructure Fundamentals of Training Approach adopted, provision, tracking Fundamentals of Maintenance Focusing on the control center environment Fundamentals of Operational Planning Near term planning and interface with operations

Secondary Program Groupings Physical Security Policy and reality Cyber Security Status of compliance to upcoming standards Loss of Facilities Plans and procedures, interim activities and notifications Computer Systems and Support Focusing on the control center environment Power Supply for Control Facilities Backup generators, uninterruptible power supplies, testing and adequacy Non published, critical infrastructure information.

Current Program Application Ensure and improve reliability Provide an independent review of registered RC/BA/TOP operations Share noteworthy practices Provide constructive feedback Raise the bar in order to help achieve excellence

Current Program Application The NERC Readiness Evaluation is not a Compliance Audit. The Regions are responsible for Compliance Audits. There will be a single NERC Readiness Report issued.

Compliance Caveat Any possible non-compliance issue observed during the evaluation will be sent to the NERC Vice President – Compliance. The NERC VP - Compliance will refer the matter to the regional compliance manager. Possible noncompliance with a NERC standard will not be identified in the final readiness report but a recommendation may be reported. [Paraphrased from the NERC Rules of Procedure, Appendix 7.]

Reliability Readiness Products Potential Examples of Excellence Above and Beyond Industry Leaders Final Determination by NERC Readiness Developed with Entity and Shared with Industry Notation of Positive Observations (in posted report) Improvement Possibilities Recommendations from the Team Perspective (Expert Consultants) “Key” Recommendations Identified by Entity Tracked by the Region(s) Notation of additional things to consider (not a separate list, not tracked by regions)

NERC Reliability Readiness Additional Initiatives 29

Additional Initiatives Procedure development for Examples of Excellence Teams nominate Potential Examples of Excellence NERC team and industry representatives develop and implement criteria Operating Reliability Subcommittee

Questions